There are two aspects to this question regarding whether or not a species should be protected "on a significant portion of its range" and both relate to how we define "significant." The first aspect is protecting a species from extinction. The second aspect is preserving ecosystem diversity. Certainly if an at-risk species is not protected on at least part of its range it is in danger of extinction. But there is an implication in this proposed revision that it does not require protection over its entire range if it can be adequately protected on this "significant" part of its range. This reasoning does not consider the second aspect of why we have an Endangered Species Act, and this aspect relates to protecting the resilience, diversity and sustainability of natural ecosystems. If a species is lost in part of its range, this part of its range has become devalued in terms of ecosystem health -- to me, that is also significant. I have chosen to sign onto this letter for this reason.
Warren W. Aney Senior Wildlife Ecologist 9403 SW 74th Ave Tigard, OR 97223 (503) 539-1009 (503) 246-2605 fax -----Original Message----- From: Ecological Society of America: grants, jobs, news [mailto:[email protected]] On Behalf Of Kim Landsbergen Ph.D. Sent: Tuesday, 07 February, 2012 16:54 To: [email protected] Subject: [ECOLOG-L] request for your comments concerning proposed changes to Endangered Species Act ECOLOG members, I am sharing a letter with you on behalf of a colleague of mine at the Center for Biological Diversity (CBD). This letter encourages ecologists to participate in an open request for comments from the USFWS and NMFS about proposed revisions to the Endangered Species Act. Please direct your questions to CBD's Noah Greenwald - his contact information is at the end of this email. Kim Landsbergen Ph.D., Certified Senior Ecologist Associate Professor, Columbus College of Art & Design Visiting Research Scholar, EEOB, The Ohio State University CarbonEcology Consulting LLC, Owner e: kim.landsbergen at gmail dot com p: 01-614-795-6003 - - - - - - - - - - Dear Scientists, The U.S. Fish and Wildlife Service and National Marine Fisheries Service are currently accepting comments on a draft policy that interprets the phrase significant portion of its range (SPOIR) in the Endangered Species Act. The Act defines an endangered species as any species which is in danger of extinction throughout all or a significant portion of its range and a threatened species as any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range. These definitions make clear that a species need not be at risk of worldwide extinction to qualify for Endangered Species Act protection. Rather, as noted in the draft policy, a species would qualify as an endangered species if it is in danger of extinction throughout all of its range, or if it is in danger of extinction in a significant portion of its range.[1] As such, this provision provides a means to protect species before they are on the brink of extinction and is thus of tantamount importance to species conservation. Unfortunately, the draft policy includes two provisions that were first proposed under the Bush administration and have the effect of sharply limiting the circumstances under which species will be protected because they are in trouble in portions of their range. First, the draft policy specifies that a portion of the range of a species is significant if its contribution to the viability of the species is so important that without that portion, the species would be in danger of extinction. This is a distinction without a difference and as a result overly restrictive. In effect, any species that would qualify for protection because it is endangered in a SPOIR, would qualify for protection anyway because it is endangered in all of its range. This approach will result in species that are severely endangered in portions of their range being denied protection because they are secure in some portion of their range even if that portion is just a fraction. This reasoning has already resulted in denial of protection for the cactus ferruginous pygmy-owl, which is undeniably endangered in the Sonoran Desert in Arizona and New Mexico, but arguably common further south in Mexico in different habitats. Fish and Wildlife denied protection despite recognizing that the Sonoran Desert Ecoregion represents an important portion of the Western DPS, and of the taxon as a whole, and that the birds found here were adapted to a drier warmer climate, so may be better adapted to a warming world. Another example of a species that may very well get denied protection under this policy is the little brown bat, which has undergone severe declines across the northeastern U.S. because of white-nose syndrome, but still remains common where the disease has not yet reached. The policy simply does not allow them to protect a species even if it has undergone severe declines across a large area. The second problem with the policy is that it specifies that historic range cannot be considered when determining if a species is threatened or endangered in a SPOIR. This amounts to a shifting baseline whereby recent losses of a species can be effectively ignored. A recent example of a species that was denied protection by ignoring historic range is the plains bison, which as Im sure most of you are aware has lost more than 99% of its range. FWS concluded that roughly 50 conservation herds amounting to roughly 20,000 animals was sufficient to secure the species despite the fact that many of these herds are suffering from hybridization with cattle and increasing domestication and only occupy a small fraction of those areas that could support bison. Please consider signing onto a letter expressing concern about these provisions. The letter, the draft policy itself and further information can all be viewed here: http://action.biologicaldiversity.org/p/salsa/web/common/public/content?cont ent_item_KEY=10927 The letter does not argue that anytime a species has lost range it should be protected or that species must be recovered to their entire historic range, but rather that lost historic range should be considered to determine if it is significant. It further argues that a range of factors should be used to determine significance, including whether the portion supports unique habitats or adaptations for the species, whether its loss would result in a significant gap in the species range and others. Thank-you for your consideration and please do not hesitate to contact me if you have questions, Noah Noah Greenwald M.S. Endangered Species Program Director Center for Biological Diversity PO Box 11374 Portland, OR 97211 503-484-7495
