cactus ferruginous pygmy-owl
The Obama government is now accepting comments on a draft policy that would sharply limit the number of species given protection under the Endangered Species Act. The policy in question is a Bush-era throwback that ignores entire populations of imperiled species.
Unlike weaker wildlife laws, the Endangered Species Act does not require a species to be at risk of global extinction to qualify for protection; it must only be at risk in a “significant portion of its range.” This provision ensures species are protected before they’re past the point of no return; it fulfills the Act’s purpose of protecting the ecosystems on which endangered species depend.
Unfortunately the policy the Obama administration is proposing would ignore historic losses of habitat and reestablish the global-endangerment criterion — a standard that has already allowed the government to downplay the urgent plight of the cactus ferruginous pygmy owl.
Sample letter content:
Subject: Comment on Policy on Significant Portion of Range
I am writing to request that you rescind the proposed policy interpreting the phrase “significant portion of its range” (SPOIR), and replace it with a policy that will truly ensure that species are not lost from significant portions of range.
The draft policy specifies that a portion of the range of a species is significant only 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 definition does not provide a meaningful distinction between when a species is endangered in a SPOIR and when a species is endangered throughout all its range, thereby rendering the SPOIR phrase superfluous and nullifying any conservation benefit of protecting species before they are threatened with worldwide extinction.
The draft policy further specifies that when considering whether a species is endangered in a SPOIR, only the current range of a species will be considered. Ignoring historic range when determining whether species are endangered in significant portions of range amounts to a shifting baseline, whereby species that experienced major declines are considered secure only because the analysis is limited solely to current range. Such an approach is clearly not in the interest of species conservation.
I ask that you rescind this anti-science, anti-common-sense draft policy and instead adopt one that considers the significance of both current and historic range and adopts a broad definition of significance that considers many factors when evaluating portions of range, including biological importance, ecological value and size.
Please take action by February 7, 2012.