Dear colleagues,
We are circulating a scientist sign-on letter to the Fish and Wildlife Service voicing concern over efforts by an agency administrator to withdraw the scientifically well-supported listing proposal for the American wolverine as a threatened species under the Endangered Species Act. The administrator's action would override the scientific judgment of the Service's scientists, peer reviewers, and an independent science panel. This reversal conflicts with the Act's best available science standard. The letter asks Secretary Jewell and Director Ashe to uphold the integrity of the ESA's science-based listing process and follow the recommendations of the Service's scientists and independent peer reviewers. The letter is copied below. Please email Shaye Wolf at [email protected] by July 30 to add your signature or if you have any questions. Thank you for considering signing on. Shaye Wolf, Ph.D. Climate Science Director Center for Biological Diversity office: (415) 632-5301 cell: (415) 385-5746 [email protected] Sign-on letter text: Sally Jewell, Secretary U.S. Department of the Interior 1849 C Street, N.W. Washington, DC 20240 [email protected] Dan Ashe, Director United States Fish and Wildlife Service 1849 C Street, NW, Room 3256 MailStop 3238 MIB Washington, DC 20240-0001 [email protected] Dear Secretary Jewell and Director Ashe, As wildlife ecologists, conservation biologists, and climate scientists, we are writing to express concern about the Endangered Species Act listing process for the American wolverine (Gulo gulo). In February 2013, Fish and Wildlife Service scientists proposed that the wolverine be designated as a threatened species in the lower 48 states based on threats from loss of snowpack due to climate change, combined with stresses from small population size and trapping. The listing proposal was based on the best available scientific information, including numerous peer-reviewed scientific studies demonstrating the wolverine's dependence on snowpack, and studies projecting the continued and extensive loss of snowpack across the wolverine's range due to climate change. This scientific determination was supported by five of seven peer reviewers and received strong support from a nine-person independent science panel convened in April to review the science underlying the proposal. On May 17th, the assistant regional director of the Mountain-Prairie Region issued a memo recommending finalization of the threatened listing. Despite the strong scientific support for the listing proposal as written, it has come to our attention that the Service's regional director has ordered the scientists responsible for reviewing the status of the wolverine to withdraw the proposed listing. In a memo issued on May 30th, the regional director acknowledged that her decision was based on no new scientific information, but rather on her opinion regarding uncertainties in the modeling studies used in the listing determination. Endangered Species Act listing decisions must be based on the best available science. This standard does not require absolute scientific certainty prior to taking action and gives the benefit of the doubt to the species. In contrast, the regional director's decision to overturn the listing determination because climate model uncertainty prevents "definitive conclusions" about "the amount and persistence of snowfall at the scale of specific wolverine den sites" stands in conflict with Act's best-available science standard. The regional director's decision to overturn a scientifically well-vetted and well-supported listing determination sets a bad precedent by allowing an administrator to overrule the expert judgment of the Service's scientists as well as independent peer reviewers. Using "uncertainty" as an excuse to dismiss the best available science sets an equally dangerous precedent given that so many rare and imperiled species are very difficult to study and assess. We urge the Fish and Wildlife Service to uphold the integrity of the Act's science-based listing process and follow the recommendations of the Service's scientists. Sincerely,
