Hello, Thank you for bringing attention to this very important issue. Just to clarify, the proposed policy will in fact afford protection to the entire species across all of its range if it is deemed endangered or threatened in a "significant portion of its range".
There are four main conclusions in this proposed policy (outlined in the announcement published in the Federal Register: http://www.fws.gov/endangered/esa-library/pdf/2011-31782.pdf) "(1) if a species is found to be endangered or threatened in only a significant portion of its range, the entire species is listed as endangered or threatened, respectively, and the Act’s protections apply across the species’ entire range; (2) 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; (3) the range of a species is considered to be the general geographical area within which that species can be found at the time FWS or NMFS makes any particular status determination; and (4) if the species is not endangered or threatened throughout all of its range, but it is endangered or threatened within a significant portion of its range, and the population in that significant portion is a valid DPS (distinct population segment), we will list the DPS rather than the entire taxonomic species or subspecies." Conclusions 1 and 4 appear to comport with the intent of the ESA, while conclusions 2 and 3 are troubling. Conclusion 2 raises the criteria for listing (it is very difficult to show that the loss of a species in a certain portion of its range will put the entire species at risk of extinction, unless the species is at risk in all of its range), and conclusion 3 ensures that listing decisions will be based on a shifted baseline. Please also note that this proposed policy applies to the National Marine Fisheries Service's management of endangered and threatened marine species. Best, Katie Cramer, PhD On Wed, Feb 8, 2012 at 12:26 AM, Warren W. Aney <[email protected]> wrote: > 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 I’m 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 > > >
