EY United States Department of the Interior FISH AND WILDLIFE SERVICE Havasu National Wildlife Refuge Post Office Box 3009 Needles, California 92363 Karl Taylor Mohave County Planning and Zoning P.O. Box 7000 Kingman, AZ 84602-7000 Dear Mr. Taylo: This letter is in reference to the First submittal of a Sketch Plan, for: the Cliffs at Lake Havasu, being a proposed subdivision of a portion of sections 20 and 21, T14N, R20W. I must begin by pointing out the extremely poor description of the project surroundings. It is clear to me looking at the sketch plan drawing that the developer is acutely aware of the boundary on the west and the south. However, there is no mention of the fact that it is Havasu National Wildlife Refuge. The Fish and Wildlife Service has serious concerns with this proposed land development and recommends that this type of development and zoning be DENIED for this plat. The reasons are as follows: It is well known that large amounts of chemicals including both herbicides and insecticides are an ongoing part of golf course management. The drainage of this 291.74 acre area drains onto the Refuge. Rain water will transport these chemicals in this community to the drainage tracts and onto the refuge. These chemicals may have negative impact on the native trees (riparian habitat) that are adjacent to. the lake. Also, these chemicals are a serious concern to us with regard to the likely negative impact to all of the fisheries on the Refuge and especially the endangered razorback sucker and bony-tailed chub. The native riparian vegetation on the lake shoreline adjacent to the proposed development is habitat to over 100 species of migratory birds. The endangered southwestern willow flycatcher has been observed annually during migration in this very habitat.Pomestic animals will be a part of the development these animals, primarily cats and dogs that ste accidental. or intentionally left unconfined will find their way to the” Refuge’s “Wildlife Habitat”. Cats are especially a problem, because they cannot be chained or kept in a back yard. Doge that are unconfined Present a threat to wildlife. Domestic cats and dogs still have instinctive killing behaviors which are obvious to the trained eye. Predatory behavior of domestic cats and dogs are even more apparent, when they are allowed to run free in a wild setting like the refuge. Cats and dogs are carnivores and they will kill refuge birds, small mammals, reptiles, amphibians and insects. The development will eliminate the habitat that exists for predators like the coyote. Currently, these coyote are a deterrent to domestic animals from traveling very far from their “home” and toward the Refuge. Once, the development is completed there will likely be no more coyote in this immediate area both on and off the refuge. This will give domestic cats and dogs a predator safe access to the refuge where they become the predator. The development will dramatically increase the population of residents adjacent to the Refuge. This easy walk distance will result in a dramatic increase of recreating public. We are sincerely interested in offering public use opportunities that are compatible with the refuge objectives. However, these sand dune buttes.and riparian habitat are fragile and cannot survive intense public use without destroying their WILDLIFE HABITAT QUALITY I propose the following DENY this project as proposed. Subsequently, for this area adjacent to Havasu National Wildlife Refuge Any developer be required to conduct an Environmental Assessment of the impacts of his development for public and agency review and comment. | Then agree to mitigate or plan the development to minimize or eliminate these impacts. Permit only zoning for single family dwellings. Prohibit the establishment of “living” lawns. Artificial lawns do not require chemicals. Require the creation of a perpetual fund to be used for immediate trapping and removal of domestic animals discovered on the refuge. Require homeowners to keep all domestic animals contained at or within the dwelling. Enforce these requirements.You may not be aware, but when Havasu National Wildlife Refuge was first established, in 1941, it included ALL of Lake Havasu and extended from Parker Dam to north of Interstate Highway 40 (Topock Marsh). The Department of Interior agreed in the early 1960's to withdraw all of Lake Havasu to the north delta. This land withdrawn was made available for recreational use, and only the most valuable wildlife habitat was retained in the Refuge and intended for wildlife. Now there are pressures everywhere from recreation and recreational living to destroy what remains of this jewel for wildlife. The Cliffs as proposed is a threat to the Refuge that remains. I repeat my sincerest recommendation that the commission deny this request. Thank you for your attention and serious consideration of this matter. If I may be of assistance, please call the office at 760/326- 3853. Sincerely, Kogag a hig Gregory A. Wolf Refuge Manager MOHAVE COUNTY PLANNING & ZONING 8.