Comment from Singleton, Steven

Field Supervisor Johnson-Hughes, I submit this comment as an independent researcher. On the current-condition prong, the record supports listing without much ambiguity. Of the 233 historical populations the SSA team identified from 1880-2023 occurrence data, 144 (61.8 percent) are now extirpated. Of the 87 populations still extant, only 17 (19.5 percent) carry high resiliency and 9 (10.3 percent) moderate; the remaining 61 (70.1 percent) are low-resiliency populations that, by the Service's own definition, are not fully meeting the species' habitat or connectivity needs. Two of the nine representative units used to measure representation, Alabama Central and West Alabama/Mississippi, have no extant populations at all, and a third, Atlantic Coastal Plain (Georgia/Florida), has lost 12 of its 14. That is not a borderline resiliency picture. It is a population range that has already contracted by roughly two-thirds and continues to lose latitudinal and longitudinal spread, which is precisely the kind of erosion in redundancy and representation the resiliency-redundancy-representation framework is designed to catch before a species reaches the endangered threshold. The habitat-loss data under Factor A is similarly unambiguous and, importantly, is not merely historical. The longleaf pine ecosystem the species depends on has declined from roughly 92 million acres to under 3 million, and only about 3 percent of what remains is in anything like natural, fire-maintained condition. The restoration initiatives cited in the rule are real but modest against that baseline (1.3 million acres replanted against a 92-million-acre historical footprint), and the rule itself states that continued fragmentation and urbanization is expected to keep driving habitat loss within the species' range. Road-mortality data reinforce the same trend at the individual level: * 84 percent of North Carolina detections between 1985 and 2012 were dead on road. * All 39 Florida detections in the 1998-2001 study were dead on road. Both threats are ongoing, and both are documented with empirical field data rather than modeled projection, which matters for how much weight they should carry. Where I think the rule is more vulnerable to challenge, and where I would encourage the Service to add clarifying language before finalizing, is the future-condition modeling that supports the foreseeable-future prong. The SSA's own text acknowledges that the six future scenarios, spanning low and high urbanization crossed with two climate pathways, produced nearly identical predictions, and attributes that convergence not to the modeled threats but to a structural feature of the model itself: it does not include colonization or recolonization, so every population's persistence probability necessarily erodes over a fifty-five-year horizon regardless of what urbanization or climate scenario is fed into it. The Service calls this an extinction debt and treats the convergence as confirmation that decline is already built into current conditions. That is a defensible reading, but a model that cannot register recolonization also cannot help but predict decline, which weakens its usefulness for isolating how much of the projected 64-percent extirpation rate by 2080 is attributable to urbanization and climate specifically, as opposed to model architecture. The final rule would be stronger if it addressed the point directly, for instance by running a sensitivity check against a plausible non-zero recolonization rate, rather than leaving the scenario-convergence finding to be read as an unaddressed structural weakness. That caveat is not enough to undercut the listing determination, for two reasons specific to this species rather than general modeling skepticism. First, the SSA is explicit that it could not model several threats already known to be acting on the species: red imported fire ant range expansion, which is independently documented and directly linked to the extirpation of southern hognose snake populations from Alabama and Mississippi by the late 1970s; pet-trade collection, with hatchlings reportedly selling for $200 to $500 at reptile shows and social media accelerating collector access to known sites; human persecution; and disease. Those are threats the model excludes for lack of spatial data, not threats the Service found immaterial. The 64-percent future-extirpation figure is more likely an underestimate than an artifact inflated by the model's design. Second, the current-condition numbers alone, independent of any future projection, already describe a species with two-thirds of its historical range gone and 70 percent of remaining populations in the low-resiliency category. Even a conservative reading of likely to become endangered within the foreseeable future is satisfied by a trajectory that starts from that baseline and adds ongoing threats under Factor A and Factor E. I believe the SSA record supports an affirmative answer.