Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Rufa Red Knot

Please see attached comment letter from Defenders of Wildlife.

On behalf of the members and constituents of the organizations named in the attached document, we submit these comments on the U.S. Fish and Wildlife Service's ("Service") proposal to designate critical habitat for the threatened rufa red knot. Our organizations applaud this long-overdue draft rule. However, the proposal appears to devalue the importance of horseshoe crab eggs to red knots, and it should include special management considerations or protections addressing horseshoe crab collection wherever horseshoe crab eggs are a physical or biological feature ("PBF") essential to the conservation of the species. Moreover, we urge the Service to reconsider designating any areas that were excluded from the proposal on the sole basis of there being an insufficient number of documented sightings in the area. Finally, while we generally support the Service's proposal to designate all 120 proposed units in its draft rule, it omits certain areas in which the PBFs essential to the conservation of the red knot are present, as well as areas that may require special management considerations or protection. We discuss these concerns in further detail in the attached. See attached file(s)