Comments on proposed USFWS designation of critical habitat for Elfin-woods Warbler.

After reviewing all materials provided to me by the USFWS in relation to the proposed designation of critical habitat for Elfin-woods Warbler, I conclude:

1. All publications known to me and relevant to the habitat, natural history, population dynamics, and ecology in general were included and discussed in the right context throughout the critical habitat proposed designation. 2. The analysis of data and assumptions in the habitat designation document were correct for most part. I will make the following comments and suggestions which I believe will benefit the proposed designation process.

In reference to page 40632, under the heading Information Requested, reasons why the USFWS should or should not designate habitat as “critical habitat”, my comment is: The designation of critical habitat is the right thing to do due to a disturbing pattern of conversion of Podocarpus and Elfin Forests to communication and recreation infrastructure (both expansion and construction) and road rehabilitation in El Yunque National Forest and Maricao Commonwealth Forests(Delannoy 2007, pages 21 and 22).

In reference to pages 40632 and 40633, under the heading Information Requested, areas that were occupied at the time of listing and contain physical and biological features essential to the conservation of the species and should be included in the designation and why, my comment is: Important occupied Elfin- woods Warbler’s habitat with physical-biological features on private lands outside the western boundary of the Maricao Commonwealth Forest was left out of the designation process. I recommend active and abandoned shade-grown coffee plantations, agricultural lands with native forest cover and closed canopies that exist in the mountainsides parallel to road PR#105 up to km 12.4 be included as designated critical habitat. This area encompasses suitable habitat consistently used and occupied by the Elfin-woods Warbler (Delannoy 2007, Figure 6, page 13). Abandoned shade-grown coffee plantations and secondary forests adjacent to the Maricao Commonwealth Forest were precisely among the human-modified habitats with moderate and significant higher Elfin-woods Warbler abundance (Delannoy 2007, Figure 9, page 15).

In reference to page 40633, under the heading Information Requested, likely impacts of climate change on the Elfin-woods Warbler and proposed critical habitat, my comment is: The most likely impact of climate change on the Elfin-woods Warbler and proposed critical habitat in Maricao Commonwealth Forest is a possible reduction in the amount of Podocarpus Forest available to the species. The reduction in the amount of Podocarpus Forest could have serious consequences due to the strong preference of the Elfin-woods Warbler for this forest type. This forest type covers a small area (80 ha, 1.9%) of the land area of the Maricao Commonwealth Forest (Delannoy 2007, page 21). 3. Certainly the best available science was included in the preparation of the proposed critical habitat designation document for the Elfin-woods Warbler. No disagreement at all.

Literature cited: Delannoy, C.A. 2007. Distribution, abundance and description of habitats of the Elfin-woods Warbler, Setophaga angelae, in southwestern Puerto Rico. Final Report submitted to the U.S. Fish and Wildlife Service under Grant Agreement No. 401814G078. University of Puerto Rico, Mayaguez Campus. 77 pp.