The OBPA submitted comments to the U.S. Fish and Wildlife Service on September 14 on the proposed rule to designate terrestrial critical habitat for the Loggerhead sea turtle.  The rule was published in the Federal Register on March 25, 2013 with notice of a public comment period.  The public comment period was reopened by notice in the Federal Register on July 18, 2013.  The comment period ends on September 16. 

The rule considers all beaches in North Carolina, South Carolina, Georgia, Florida, Alabama and Mississippi as potential candidates for designation for the Loggerhead Northwest Atlantic Distinct Population Segment. A total of 184 different beach segments ranging in length from 0.2 km to 90.0 km are found in these states.  Total length for all beach segments considered is 2,464 km.  Of the 184 segments, 90 segments totaling 1,189.9 km are being proposed as Critical Habitat designation.

In North Carolina,  eight beach segments totaling 154.6 km are proposed as critical habitat.  These  segments are Bogue Banks, Bear Island, Topsail Island, Lea-Hutaff Island, Pleasure Island, Bald Head Island, Oak Island and Holden Beach.

Neither Cape Hatteras National Seashore Recreational Area nor Cape Lookout National Seashore are designated as Critical Habitat in the current proposal. 
The Southern Environmental Law Center submitted comments asking that both CAHA and CALO be added to the designated Critical Habitat units.

The OBPA made ten recommendations in the comments it submitted.  One recommendation was that Cape Hatteras not be added to the Critical Habitat designation.  A second recommendation was that no beaches in North Carolina should be designated as Critical Habitat.  In each case, the OBPA argued that the nest counts and nest density per kilometer compared to other beach segments within the six states are far too low for Cape Hatteras or other North Carolina beaches to be considered critical to the survival of the species.

Click here to read the comments, details for these two recommendations and the other eight recommendations submitted.