Comment from Prutehi Guåhan Inc.

Prutehi Guåhan (Prutehi) is a 501c3 organization committed to the protection of natural and cultural resources in Guam and the Marianas. We submit this comment to request the extension of the formal commenting period in order for the United States Fish and Wildlife Services (USFWS) to effectively communicate how the proposed ruling will affect private lands to the residents of Guam and the CNMI. It is crucial that residents of the Marianas understand the potential impacts these actions may have on Indigenous CHamoru and Carolinian practices, the use of Indigenous lands for familial and agricultural purposes, as well as on economic development within a region that lacks robust options for economic growth due to limited political autonomy. Prutehi also expresses concern regarding the USFWS’s use of the term “critical habitat.” For the people of the Marianas, the identification of lands as “critical habitat” has historically complicated the ability to protect sacred areas that fall under control of the Department of Defense (DoD), now the Department of War (DoW). Even when lands are appropriately referred to as critical habitats, the overriding and narrowing of conservation efforts often take place in the face of defense concerns, forcing local agencies and governments to conduct their preservation efforts around restrictions and actions that run counter to conservation efforts. Prutehi Guahan acknowledges the United States Fish and Wildlife Services’ effort to protect endangered species, but reiterates that the designation of critical habitat areas is unnecessary and destructive if our most valuable land and island resources are permanently destroyed due to their use as a staging ground for international conflicts. The CHamoru and Carolinian people of the Marianas have already witnessed the destruction of limestone forests which housed endangered species of cultural significance due to the use of “critical habitat” for live-fire training. We refer to the destruction of the prime limestone-forested area at Tailalo (Northwest Field), which housed endangered species such as the only seed-bearing mother tree of håyun lågo (Serianthes nelsonii), ababang, eight spot butterflies (Hypolimnas octocula marianensis) and their host plants, and fadang (Cycas micronesica), to build a live-fire training range. Further, using Section 4(b)2 of the ESA to exclude lands designated as critical habitat due to national security, immediately excludes Guam and CNMI residents from making any decisions regarding endangered species. Please help us prevent further destruction to our homelands and allow for a longer commenting period.