Gunnison Sage-Grouse Comments
April 5, 2013

The Public Lands Council, National Cattlemen’s Beef Association, American Sheep Industry Association and Association of National Grasslands formally submitted comments in regard to the endangered status for the Gunnison sage grouse (GUSG). The livestock associations strongly oppose the proposed listing and corresponding habitat designation. 
Based on the deficit of science on the part of U.S. Fish and Wildlife Services (FWS) supporting the proposed decisions, the lack of proper economic analysis of the proposed critical habitat designation and the conflicting biological opinion of the State of Colorado’s Parks and Wildlife Division (CPW), the organizations believe FWS should issue a “Not Warranted for Listing” status for the GSUG. 
Existing GUSG conservation strategies and regulatory constructs are adequate to protect the species. An Endangered Species Act listing would only serve to detract from these regulatory constructs and voluntary conservation initiatives. FWS should consider the public and private conservation strategies implemented through such actions as the Sage Grouse Initiative, voluntary conservation agreements, conservation actions by CPW, county governments encompassing each of the GUSG leeks and associated habitats and private and federal landholdings efforts. A listing will discourage such voluntary initiatives in the future not only for the GUSG, but for other species being considered for listing, as well.