Help Save Newcomb's Snail

COMMENT PERIOD REOPENED! Aloha. We request your kokua. Please submit comments in support of critical habitat designation for Newcomb's snail, a threatened freshwater species found only on Kaua`i.

Sample Letter for Campaign

Subject: Proposed Determination of Critical Habitat for the Newcomb's Snail, 67 Fed. Reg. 3849 (1/28/02)

Dear [ Decision Maker ] ,

I am writing to support strong critical habitat designation for the Newcomb's snail. I am pleased that your proposal (67 Fed. Reg. 3849) recognized the importance of protecting currently unoccupied habitat for the future recovery of this critically imperiled native species that is found only on Kaua`i. However, your proposal does not go far enough and must be amended to designate all areas where Newcomb's snail existed formerly, including Hanapepe Stream.

As the proposed rule explains, protection of unoccupied habitat is necessary to provide the geographic separation needed to give Newcomb's snail the best chance of surviving unpredictable catastrophic events (e.g., Hurricanes `Iwa and `Iniki), which can swiftly wipe out its few remaining populations. To reduce the risk of extinction, unoccupied areas that are suitable for reintroduction of Newcomb's snail must be designated as critical habitat. Accordingly, the Service should designate all areas where Newcomb's snail existed formerly, but are no longer found. This includes not only the three unoccupied streams the Service has proposed--Hanakoa Stream, Hanakapi`ai Stream and Wainiha River--but Hanapepe Stream as well.

Additionally, areas already subject to conservation measures--or that may be the subject of conservation agreements in the future--should not be excluded from critical habitat. While landowners that undertake efforts to conserve Hawai`i's imperiled species should be praised, conservation efforts do not alter the habitat's critical nature or the need to ensure its long-term protection.

Protecting critical habitat is essential not only for the recovery of this species, but also to protect the ecosystem on which Newcomb's snail relies for its long-term survival and recovery. Critical habitat for Newcomb's snail would help ensure that cool, clean water will flow in designated streams. Protecting water quality and quantity benefits all of Hawai`i's native stream species, guaranteeing that healthy streams and stream life will be there for future generations to enjoy.

Unfortunately, the Service's draft economic analysis completely ignores the significant benefits associated with protecting the watersheds proposed as critical habitat for Newcomb's snail. It failed to discuss the benefits of keeping other native species off the endangered species list by protecting the habitat they share with the snail, of maintaining water quality and quantity, of promoting ground water recharge, and of preventing siltation of the marine environment (and, thus, protecting coral reefs). All of these economic benefits must be taken into consideration before the Service decides whether to exclude any area from critical habitat on economic grounds.

Please take the necessary steps to protect the Newcomb's snail by designating its critical habitat. Newcomb's snail is an irreplaceable treasure and a vital part of Hawai`i's natural and cultural heritage.

Sincerely,

Campaign Launched:
March 27, 2002

Background Information

Critical habitat is defined as those areas essential to the conservation (i.e., recovery) of threatened and endangered species. The Endangered Species Act prohibits federal agencies from funding, authorizing, or participating in any action that adversely modifies or destroys critical habitat.

On January 28, 2002, the U.S. Fish and Wildlife Service proposed to designate critical habitat for Newcomb's snail, a threatened freshwater species found only on Kaua`i. The proposed critical habitat consists of nine stream segments and associated tributaries, springs and seeps totaling approximately 26 kilometers (16 miles) and covering approximately 5,000 acres (including upland riparian habitat). The proposed critical habitat designation can be found in the January 28, 2002 Federal Register (Vol. 67) at pages 3849-3867.

Main Points * Designating critical habitat is essential to help restore Newcomb's snail and get it off the endangered species list.

* Critical habitat is especially important in Hawai`i because of the significant federal presence here (military training, federally funded highway, sewage plant, and airport construction, etc.). Designating critical habitat would protect Newcomb's snail from harmful stream diversion projects, which require a federal permit from the Army Corps of Engineers.

* Newcomb's snail is particularly vulnerable to unpredictable catastrophic events (e.g., Hurricanes `Iwa and `Iniki), which can swiftly wipe out its few remaining populations. To reduce the risk of extinction, unoccupied areas that are suitable for reintroduction of Newcomb's snail must be designated as critical habitat. Accordingly, the Service should designate all areas where Newcomb's snail existed formerly, but are no longer found. This includes not only the three unoccupied streams the Service has proposed--Hanakoa Stream, Hanakapi`ai Stream and Wainiha River--but Hanapepe Stream as well.

* Critical habitat for Newcomb's snail would help ensure that cool, clean water will flow in designated streams. Protecting water quality and quantity benefits all of Hawai`i's native stream species, guaranteeing that healthy streams and stream life will be there for future generations to enjoy.

* Critical habitat helps protect entire watersheds from degradation, promoting groundwater recharge, maintaining surface water quality, preventing siltation of nearshore reefs and other marine resources, attracting ecotourism, and so on. A recent study sponsored by the University of Hawai`i's Secretariat of Conservation Biology estimated the value of such "ecosystem services" and other amenities provided by the forests of the Ko`olau Mountains on O`ahu alone at $7 billion to over $14 billion. See http://www2.hawaii.edu/~uhero/workingpaper/HawaiiEnviroEvaluation.pdf. Protecting riparian habitat on Kaua`i would confer similarly significant economic benefits.

Unfortunately, the Service's draft economic analysis (dated March 2002 and available at http://pacific.fws.gov/news/2002/pdf/snail_draft_ea.pdf) completely ignores the significant benefits associated with protecting the watersheds proposed as critical habitat for Newcomb's snail. It failed to discuss the benefits of keeping other native species off the endangered species list by protecting the habitat they share with the snail, of maintaining water quality and quantity, of promoting ground water recharge, and of preventing siltation of the marine environment (and, thus, protecting coral reefs). All of these economic benefits must be taken into consideration before the Service decides whether to exclude any area from critical habitat on economic grounds.