Comment from Towers Saint Amand, TerryAnn

I agree with the proposed critical habitat designation for these 22 species and encourage the U.S. Fish and Wildlife Service to adopt the strongest scientifically supported protections possible. Many of these species exist only on a handful of islands. Some occur in extraordinarily limited areas and have already experienced significant declines from habitat loss, invasive species, development, military activity, altered ecosystems, and other human pressures. Island species often have nowhere else to go when habitat is degraded. Once populations are lost, recovery may be difficult or impossible. One aspect of this proposal stands out to me. Many of these species were listed approximately a decade ago, yet critical habitat protections are only now being proposed. Given the vulnerability of island ecosystems and the ongoing threats these species face, I encourage the Service to approach habitat protection with urgency and precaution. Protecting species without protecting the places they depend on rarely succeeds. Habitat is not simply the location where species happen to exist today. It is the foundation for recovery, climate resilience, breeding, feeding, shelter, movement, and long-term survival. Habitat protection should therefore prioritize ecological connectivity, watershed health, native vegetation, and resilience to future climate conditions including stronger storms, drought, sea-level rise, wildfire, and changing rainfall patterns. I am concerned by the continued impacts of invasive species. Invasive predators, invasive plants, and other introduced species have played a major role in biodiversity declines throughout the Pacific. Habitat designation alone will not be sufficient without sustained invasive species management, monitoring, and restoration efforts. I am also concerned by the proposed exclusion of Department of Defense lands that contain habitat for many of the species covered by this rule. While military readiness is important, exclusions should be granted only when there is compelling scientific evidence that conservation outcomes under existing management plans will be equal to or greater than those provided by critical habitat designation. Given the rarity of these species and the limited amount of suitable habitat available, the burden of proof should be high. The Service should clearly explain how conservation performance on excluded lands will be measured, how monitoring results will be made available to the public, and what corrective actions will occur if recovery objectives are not being achieved. Conservation plans are only as effective as their implementation and accountability. I also encourage continued collaboration with Indigenous communities and local residents whose knowledge, stewardship, and cultural connections to these landscapes can contribute significantly to long-term conservation success. Future generations should inherit functioning island ecosystems rather than records describing species that once existed there. I strongly support the proposed designation and encourage the Service to ensure that habitat protections are comprehensive, transparent, climate-resilient, and guided by the long-term recovery needs of these unique species. Thank you for considering my comments. TerryAnn Towers Saint Amand