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Gail Norton left The Deparment of Interior accused of mismangement of the funds budgeted to The Department of the Interior. It is time to resume that investigation and see it through as well as start a new investigation of the complete disregard of the Endangered Species Act and the proposed destruction of The Northern Spotted Owl.
October 2, 2007
Secretary Dirk Kempthorne
1849 C Street, NW
Washington, DC 20240
RE: Northern Spotted Owl Draft Recovery Plan
Dear Secretary Kempthorne:
The northern spotted owl is one of the most intensively studied endangered raptors in the
world. Decades of scientific research and the largest mark-recapture population studies
ever conducted on a threatened species have provided valuable insights into the owls’
habitat requirements, prey base, and demographic characteristics 1 . As scientists with
backgrounds in population ecology, wildlife and endangered species management,
natural resource management and forest ecosystems, we are greatly concerned that,
according to scientific peer review recently conducted by owl experts and three of the
nation’s leading scientific societies, much of this science was ignored in the published
draft recovery plan for the northern spotted owl 2 . Based on these reviews, and the
alleged political interference documented in a May 9 hearing on the Endangered Species
Act in the House Natural Resources Committee, 3 we respectfully request that you
withdraw the draft owl recovery plan and assemble a team of scientists to redraft a
recovery plan truly based on the best available science.
The spotted owl is an indicator species of the status of old-growth forests in the Pacific
Northwest, which historically included up to two-thirds of the forest age classes in the
region but now represent just under 20 percent 4 . In particular, the Northwest Forest Plan
(NWFP) is a landmark ecosystem management plan that put in place a reserve system for
the owl and hundreds of species associated with older forests throughout the region.
Recent scientific assessments have concluded that there is no reason to depart from a
conservation strategy rooted in fixed reserves and the spotted owl situation would be far
bleaker today if not for the protections afforded to it under the NWFP 5 . While there has ...
1 Anthony, R.G., E.D. Forsman, A.B. Franklin, D.R. Anderson, K.P. Burnham, G.C. White, C.J. Schwarz, J. Nichols, J.E. Hines, G.S. Olson, S.H. Ackers, S.L. Andrews, B.L. Biswell, P.C. Carlson, L.V. Diller, K.M. Dugger, K.E. Fehring, T.L. Fleming, R.P. Gerhardt, S.A. Gremel, R.J. Gutierrez, P.J. Happe, D.R. Herter, J.M. Higley, R.B. Horn, L.L. Irwin, P.J. Loschl, J.A. Reid, and S.G. Sovern. 2006. Status and trends in demography of northern spotted owls, 1985-2003. Wildlife Monographs No. 163:1-47.
2
www.conbio.org/Sections/NAmerica/SCBA%20Comments%20to%20FWS%20Northern%20Spotted%20
Owl.pdf; http://www.wildlife.org/policy/index.cfm;
http://www.fws.gov/pacific/ecoservices/endangered/recovery/peer.html
3
DellaSala, Dominick. Written testimony for the House Natural Resources Committee Hearing entitled
“Endangered Species Act Implementation: Science or Politics?”
http://www.nccsp.org/files/land/spottedowltestimonydds.pdf Additional information available at
http://www.nccsp.org/
4
Strittholt, J.R., D.A. DellaSala, and H. Jiang. 2006. Status of mature and old-growth forests in
the Pacific Northwest, USA. Conservation Biology 20:363-374.
5
Courtney, S.P., J.A. Blakesley, R.E. Bigley, M.L. Cody, J.P. Dumbacher, R.L. Fleischer, A.B. Franklin,
J.F., R.J. Gutierrez, J.M. Marzluff, and L. Sztukowski (eds). 2004. Scientific evaluation of the status of the
Page 2
been ground-breaking research on owl habitat relations 6 that has expanded our understanding of owl habitat use, there is no scientific basis for departing from the
reserve network of the NWFP or any reason to conclude that old-growth forests are no
longer essential to the owl’s survival. And though barred owls have emerged as a
growing threat to spotted owls, the science is far from conclusive regarding how this
biological invasion will affect the survival and recovery of the northern spotted owl.
Based on our understanding of the ecology of the spotted owl, we see no scientific basis
for either reducing habitat protections for the owl – as currently proposed under Option 1
of the recovery plan– or departing from a conservation strategy that is rooted in the fixed
reserves of the NWFP such as Option 2 7. Rather, increased threats from barred owls and
potential climate change effects justify protecting more habitat – not less – as a
precautionary principle in the conservation and recovery of listed species that is clearly
missing from the draft recovery plan.
In closing, we understand that you have recently commissioned a review of eight
Endangered Species Act decisions influenced by former Assistant Deputy Secretary Julie
MacDonald as part of reforms underway to improve the Fish & Wildlife Service’s track
record on Endangered Species Act decision making. We request that you include in these
department reviews the draft spotted owl recovery plan for three reasons: (1) the science
may have been tampered with by high ranking officials; (2) the plan is not based on
credible science as indicated by scientific peer review; and (3) the plan is a key decision
document that could determine the fate of millions of acres of old-growth forests in the
Pacific Northwest.
Fish & Wildlife Service policy requires recovery plans to be based on the best available
science in order to recover a species to the point where it no longer requires protections
afforded under the Endangered Species Act. We are concerned that because this recovery
plan would remove from protection old-growth forest habitat at a time when threats are
increasing and owl population declines are accelerating that it could lead to future up-
listing of the species to endangered status. For these reasons, we request that you
commission a team of scientists to redraft the recovery plan and place related forest
management policies on hold until a new draft is proposed.
Northern Spotted Owl. Sustainable Ecosystems Institute, Portland, OR. Lint, J. 2005. Status and trends of
Northern Spotted Owls populations and habitat. USDA PNW-GTR-648. DellaSala, D. A., and J. Williams.
2006. Northwest Forest Plan Ten Years Later – how far have we come and where are we going.
Conservation Biology 20:274-276. 6
Franklin, A.B., D.R. Anderson, R.J. Gutierrez, and K.P. Burnham. 2000. Climate, habitat quality, and fitness in Northern Spotted Owl populations in northwestern California. Ecological Monographs 70:539- 590. Dugger, K.M., F. Wagner, R.G. Anthony, and G.S. Olson. 2005. The relationship between habitat characteristics and demographic performance of Northern Spotted Owls in Southern Oregon. The Condor 107:863-878. Olson, G.S., and several others. 2004. Modeling demographic performance of Northern Spotted Owls relative to forest habitat in Oregon. J. Wildlife Management 68:1039-1063. 7 Carroll, C., and D.S. Johnson. In review. The importance of being spatial and reserved: assessing habitat relationships and conservation options for the northern spotted owl with Bayesian spatial autoregressive models.
Page 3
Sincerely,
*
Affiliation are provided for identification only
Dominick A. DellaSala, Ph.D.
Chief Scientist, Executive Director
National Center for Conservation Science & Policy, Ashland, OR
Carlos Carroll, Ph.D., Research Ecologist
Klamath Center for Conservation Research
Orleans, CA
Gordon H. Orians, Ph.D.
Professor Emeritus of Biology
University of Washington, Seattle
Dave Perry, Ph.D. Forest Ecologist
Emeritus Oregon State University
Corvallis, OR
James R. Karr, Ph.D. Professor Emeritus
University of Washington, Seattle
David W. Inouye, Ph.D.
Ecologist and Conservation Biologist
University of Maryland, College Park
Dan Rosenberg, Ph.D., Wildlife Biologist
Oregon Wildlife Institute and Department of Fisheries and Wildlife
Oregon State University, Corvallis
Trina B. Bassoff, Ph.D.
Biological Anthropology
Steven Green, Ph.D.
Professor of Biology
University of Miami
Matthew I. Palmer, Ph.D.
Department of Ecology, Evolution and Environmental Biology
Columbia University, New York, NY
Francis G. Howarth, Ph.D. Conservation Biology
L.A. Bishop Distinguished Chair of Zoology
Bishop Museum, Honolulu
Marc Meyer, Ph.D., Research Wildlife Ecologist and Postdoctoral Fellow
University of California Merced Wawona, CA
