Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Florida Bonneted Bat

To Whom It May Concern, Across a variety of ecosystems nationwide, American cattle producers play a pivotal role in the management of hundreds of millions of acres of private and public land. The National Cattlemen's Beef Association (NCBA) is the oldest and largest organization representing U.S. cattle producers, with nearly 26,000 direct members and 178,000 members enrolled with our state affiliates. Our members span all 50 states and collectively compromise the largest segment of American agriculture. We appreciate the attention paid by the U.S. Fish and Wildlife Service (FWS) to clarifying and refining the designation of critical habitat for the Florida bonneted bat, and accordingly, we wish to provide comment on excluding areas of proposed critical habitat pursuant to Section 4(b)(2) of the Endangered Species Act ("the Act.") Environmental stewardship has been a hallmark of the Florida cattle industry for centuries. That conservation work has historically been most effective when implemented privately or through voluntary public-private partnerships. There are numerous cattle operations within Units 1-9 of the proposed critical habitat that would be needlessly swept up in an overly broad regulatory net, should this proposal be finalized as written. Designating these ranches would not only exceed the mandate of the Act, but it would also discourage many of the management actions that producers currently employ to cultivate healthy wildlife habitat and healthy forage for their livestock. FWS has specifically solicited comment on several specific questions that pertain to cattle operations in the area. We respond to these inquiries below. "The present or threatened destruction, modification, or curtailment of a species' habitat or range is not a threat to the species, or threats to the species' habitat stem solely from causes that cannot be address through management actions resulting from consultations under section 7(a)(2) of the Act." Grazing is not a significant factor in the decline of the Florida bonneted bat. Cattle grazing and related on-ranch activities do not result in significant loss of roost sites, and livestock operations do not share the same pesticide use profile as row crop operations. "Whether any specific areas we are proposing for critical habitat designation should be considered for exclusion under section 4(b)(2) of the Act." Designating critical habitat over these ranches will not make an appreciable difference to the viability of the species, but it will have an impact on the value of that agricultural land, the ease with which private landowners can continue their operating their business, producers' willingness to engage in future conservation initiatives, and other unintended consequences. The harm to individual operations, the local economy, and the availability of prime agricultural acres in the region outweigh the imagined benefit to the species. We recommend that any currently-operating cattle ranch in Kissimmee, Peace River, Babcock, Fisheating Creek, Corkscrew, Big Cypress, Everglades Tree Islands, Long Pine Key, and Miami Rocklands be exempted from the critical habitat designation up to and including the borders of the property, as well as the land associated with necessary rights of way and access points to the property. America's farmers and ranchers share an abiding respect and love for our nation's wildlife and the varied landscapes they call home. However, these producers are often the first to suffer from the death by a thousand cuts that comes along with an ever-expanding and often ineffectual Endangered Species Act. Efforts to conserve the Florida bonneted bat must be based in science and weighed against the very real economic cost to producers that is incurred when species listings and critical habitat designations exceed their logical bounds. We appreciate your consideration of these exemptions and encourage you to consider how a redundant critical habitat designatio…