Secretary of the Interior
US Department of the Interior
US Fish & Wildlife Service
Dear Sally Jewel and Daniel Ashe:
Please accept these comments in support of the protection of the diamond darter and its critical habitat under the Endangered Species Act. Because there are no existing laws that are adequate to save this rare fish from extinction, the Service should immediately finalize its protection and designate critical habitat for it in both West Virginia and Kentucky.
In 2009 the Service identified the darter as a candidate for protection because the ongoing threats to its survival are high and severe enough to result in total mortality for the species. The 2012 listing proposal for the darter identifies numerous threats which qualify the fish for Endangered Species Act protection including water-quality degradation, habitat loss, invasive algae, catastrophic events such as toxic spills, small population size and inadequate existing regulatory mechanisms. Activities
that are known to threaten the darter's habitat include coal mining, oil and gas development, sedimentation and erosion, logging and poor wastewater treatment.
Please do not bow to pressure from the energy industry to withdraw the proposed protection of this imperiled fish. The best available scientific information clearly shows that the diamond darter warrants protection as an endangered species. Further, the Service has already determined that the proposed critical habitat designation would not have a significant economic impact on a substantial number of small business entities.
The Service should take into consideration the economic benefits of protecting habitat for the darter including ecosystem services, the protection of clean water and the reduced cost of water treatment for drinking supplies. The Elk River is one of the most biodiverse rivers in the state of West Virginia and the Service should also consider the economic benefits of preserving the state's natural heritage.
Protecting the darter and its habitat will have positive benefits on public health in the region, and the Service should consider this in its economic analysis.
Both state and federal authorities have acknowledged that Endangered Species Act protection is the only prudent mechanism available to save the diamond darter from extinction.
Please immediately finalize its protection.