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Comments by the North American Section of the Society for Conservation Biology on Proposed Rule to Delist the Northern Rocky Mountain Population of Gray Wolf (50 CFR Part 17, 72 FR 6106)
May 7, 2007
Prepared by Adam Switalski, Rebecca Wahl, Reed Noss, and Carlos Carroll
c/o Dr. Reed F. Noss
President, North American Section, Society for Conservation Biology
Department of Biology
University of Central Florida
Orlando, FL 32816-2368
Submitted to:
U.S. Fish & Wildlife Service
Western Gray Wolf Recovery Coordinator
585 Shepard Way
Helena, MT 59601
Executive Summary
The Society for Conservation Biology (SCB) is an international professional organization dedicated to promoting the scientific study of the phenomena that affect the maintenance, loss, and restoration of biological diversity. Our peer-reviewed journal, Conservation Biology, has published dozens of articles addressing both the Endangered Species Act and wolf restoration in the United States. Here, we draw upon fundamental principles of conservation biology and specific information on wolf biology to evaluate the proposal for delisting wolves in the U.S. Northern Rockies (50 CFR Part 17, 72 FR 6106).
We do not believe the proposed rule to designate the Northern Rocky Mountain (NRM) Population of gray wolf as a Distinct Population Segment (DPS) and remove this Distinct Population Segment from the Federal List of Endangered and Threatened Wildlife is warranted at this time. Our concerns about the proposed rule can be summarized into the following specific areas:
1. Inadequate state management plans to protect the long-term viability of the regional metapopulation
2. Inadequate consideration of what constitutes a significant portion of range, connectivity between high quality habitat in adjacent regions, and the historic range of the taxon
3. Inadequate consideration of threats due to increasing loss of habitat and natural- and human-caused mortality
4. Outdated recovery goals that do not reflect the realized carrying capacity of wolves in the U.S. Northern Rockies
5. Inappropriate interpretation of habitat models (e.g., Carroll et al. 2006)
6. Inadequate consideration of gray wolf taxonomy
The proposed state wolf management plans (excluding Montana) will not protect viable metapopulations. The proposed delisting rule does not address a significant portion of the wolf’s range, would eliminate connectivity between high quality habitats in several states, and would leave a significant gap in the historic range of the species. The proposed delisting rule does not adequately consider long-term threats in the region. Furthermore, the proposed delisting rule inappropriately interprets recent regional-scale habitat models and does not adequately consider which subspecies of gray wolf is being restored. The recovery goals set forth in the rule are outdated. We therefore ask that the proposed rule be replaced by one that better ensures the long-term viability of the Northern Rocky Mountain population as part of a connected metapopulation of wolves throughout the U.S. Rocky Mountains.
Complete document available (Word format)
Ecological Science Relevant to Management Policies for Fire-prone Forests of the Western United States
Society for Conservation Biology Scientific Panel on Fire in Western U.S. Forests
Authors: Reed F. Noss (editor), Jerry F. Franklin, William Baker Tania Schoennagel, and Peter B. Moyle
Society for Conservation Biology, North American Section, Arlington, VA.
February 24, 2006
EXECUTIVE SUMMARY
Fire is a primary natural disturbance in most forests of western North America and has shaped their plant and animal communities for millions of years. Native species and fundamental ecological processes are dependent on conditions created by fire. However, many western forests have experienced shifts in wildfire regimes and forest structure following a century or more of resource use and management, with some past and present management activities lacking a scientific basis. Changes in wildfire and fuel management policies are needed to address social and environmental problems that have arisen as a result of these activities.
Incorporation of current scientific knowledge into revised policies and practices is essential to insure that the productivity, biological diversity, and ecological values of western forests are sustained. As an example, implementation of the Healthy Forests Restoration Act (HFRA) of 2003 will benefit from adaptive application of the dramatically expanding base of scientific knowledge. Our review addresses the ecological science relevant to developing and implementing forest restoration and fuel management policies, including activities conducted before, during, and after forest wildfires. An essential principle of ecological variability within and among forests underlies all of our findings.
In this summary and in the background report we use the term "characteristic" in referring to the dominant natural disturbance regime of a forest type or site. For example, some types of dry forests are described as being historically or naturally "characterized by a frequent, low-severity fire regime" while some coastal and sub-alpine forests are "characterized by an infrequent, high-severity fire regime." These are generalized characterizations of the regimes that these types experience and are not necessarily exclusive. For example, forests characterized by high-severity fire regimes may also experience low-severity events and vice versa. The term "uncharacteristic" refers to disturbances, forest structure, or fuel loads of a scale or type outside the historic range of variability based on site-specific vegetation reconstructions using tree rings, fire scars, pollen, charcoal, or early historical records.
Complete Document Available as PDF
Scientific Societies' Statement on the Endangered Species Act
The Endangered Species Act of 1973 (ESA) is the subject of ongoing Congressional scrutiny that
may result in the amendment of the law. Many of the proposed changes involve scientific issues and
how science, research, and scientists advance the conservation of endangered plants and animals.
Our societies are committed to the goals of the ESA and assert that the best available science must
be used in its implementation. The ESA is a vital and fundamentally sound tool in this Nation's effort
to maintain biological diversity. The law's effectiveness in protecting and recovering species has
been hamstrung by insufficient funding, little of which has been used to implement on-the-ground
recovery actions. Many of our societies have issued position statements or reports on the ESA in
the past, most recently, "Practical solutions to improve the effectiveness of the Endangered
Species Act for wildlife conservation" by The Wildlife Society.
We [the below societies] provide the following comments on the Endangered Species Act, focusing on those areas
where we believe our expertise as scientists and experience in helping implement the ESA is most
relevant. Our professional scientific societies represent thousands of scientists and natural
resource managers in the United States. These recommendations were developed by scientists
representing each of our societies and have been approved by the governing board of each society.
We believe that the recommendations contained herein, if adopted, would improve the protection
and recovery of endangered wildlife in the U.S. while reducing conflict over the law.
North American Section, Society for Conservation Biology
The Wildlife Society
American Fisheries Society
Ecological Society of America
Society for Range Management
Entomological Society of America
Complete document available here.
Grizzly Bear protection under the Endangered Species Act
The SCB-NA board encourages all members to submit comments to the U.S. Fish and Wildlife Service
by 17 March 2006
Complete document available here.
Directions for submitting comments: The U.S. Fish and Wildlife Service will consider comments on this proposed rule received until the close of business on March 17, 2006. ADDRESSES: If you wish to comment, you may submit your comments and materials concerning this proposal by any one of several methods: 1. You may submit written comments to the Grizzly Bear Recovery Coordinator, U.S. Fish and Wildlife Service, University Hall 309, University of Montana, Missoula, Montana 59812. 2. You may hand deliver written comments to our Missoula office at the address given above. 3. You may send comments by electronic mail (e-mail) to FW6_grizzly_yellowstone@fws.gov. If you wish to submit comments by e-mail, please avoid the use of special characters and any form of encryption. Please also include your name and return address in your e-mail message.
The Steady State Economy as a Sustainable Alternative to Economic Growth
Position of the Society for Conservation Biology, North America Section as
adopted 16 August 2004.
Complete document available here.
Comments on H.R. 2933, The Critical Habitat Reform Act of 2003
Prepared for the Section by Kathryn Kennedy and Karen Hodges for the North
American Section of the Society for Conservation Biology - 22 April 2004
In this document, we provide a section-by-section analysis of certain sections
of H.R. 2933, highlighting various scientific issues pertaining to the conservation
of endangered species and the designation of critical habitat.
The full document in PDF format is available
here.
Comments on proposed changes to the National Forest System Land and Resources
Management Planning Rule (36 CFR Part 219)
Submitted by the Society for Conservation Biology, North American Section
Committee on National Forest Planning and Management
The Society for Conservation Biology is an international professional organization
committed to developing the scientific and technical means for protection, maintenance,
and restoration of biological diversity. The North American Section of the Society
charged this Committee to prepare and file comments on the proposed changes
to the National Forest System Land and Resources Management Planning Rule (36
CFR Part 219) published in the Federal Register on December 6, 2002, referred
to here as the "proposed changes". More specifically, the Committee was charged
with assessing whether the proposed rule is likely to protect adequately biological
diversity and ecological sustainability in National Forest System lands over
the long term. In our evaluation, we considered (1) the principles of conservation
biology, a discipline that integrates ecology and population genetics with the
social sciences; (2) the 1976 National Forest Management Act (NFMA); (3) the
planning regulations promulgated in 1982 and 2000; and (4) the 1999 report of
the Committee of Scientists charged to review the National Forest planning process.
Our comments include suggested modifications to the proposed rule that we believe
will improve forest management and conserve biological diversity in our National
Forests for future generations.
The full document
in PDF format is available here.
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