On July 2, the Society for Conservation Biology, on behalf of its Marine Section, submitted formal comments to the Bureau of Ocean Energy Management (BOEM) within the Department of Interior regarding its draft programmatic environmental impact statement (PEIS) regarding possible geological and geophysical seismic activities in support of oil and gas exploration and development in the Atlantic Ocean. In 2010, Congress ordered BOEM to examine the possible environmental impacts of seismic activities in the Atlantic Ocean, a necessary precursor to further oil exploration and development activities off the Atlantic coast. SCB is concernd that the draft PEIS underestimates the risks that seismic activities, especially deep penetration seismic air gun surveys, pose for the critically endangered north Atlantic right whale (Eubalaena glacialis). Given the suite of anthropogenic threats that this species already faces from commercial and recreational fisheries, collisions with large vessels, renewable energy development, marine minerals use, LNG import terminals, military training, and dredged material disposal, as well as long-term challenges of climate change, seismic surveys will likely place this species in greater jeopardy of extinction.
High-intensity pulses produced by seismic air gun surveys can cause a range of impacts on marine mammals, fish, and other marine life, including habitat displacement and disruption of vital behaviors essential to foraging and breeding. In some cases, seismic air gun surveys can result in injuries or mortalities to marine species, including marine mammals. For these reasons, SCB is supporting Alternative C, the no action alternative, because it represents the most precautionary approach to managing the ongoing development of the Atlantic Ocean’s natural resources, while providing sufficient protection for its critically endangered wildlife. Under this alternative, BOEM would not permit any seismic activities in the Atlantic ocean with regard to oil and gas exploration. Adoption of Alternative C would not affect BOEM's ability to move forward with offshore wind or other renewable energy activities.
The SCB comment letter can be found HERE.
On June 18, the Society for Conservation Biology and the American Society of Mammalogists (ASM) submitted formal comments (available here) to the National Marine Fisheries Service (NMFS) regarding the agency’s proposal to remove the Eastern Distinct Population Segment of Steller Sea Lion from the list of threatened and endangered species.
Steller sea lions (Eumetopias jubatus) were protected under the Endangered Species Act as a threatened species in 1990 based primarily on population declines that resulted from unsustainable fisheries management. In 1994, NMFS divided the Steller sea lion into two Distinct Population Segments (DPS). The Western DPS of Steller sea lion was uplisted to endangered status, while the Eastern DPS remained threatened. While the data indicate that conservation actions have helped the Eastern DPS meet its recovery targets for delisting in eastern Alaska, British Columbia, and possibly Washington and Oregon, the data do not demonstrate that recovery targets have been met in California. Steller sea lions were extirpated from the Channel Islands in the 1980s and remain well below their historic population levels. Today, Steller sea lion populations in California are only one-third their populations levels from the first half of the 20th century. For this reason, SCB and ASM believe that it is premature to delist the Eastern DPS at this point.
The Endangered Species Act (ESA) provides the National Marine Fisheries Service with the ability to protect a species that is threatened or endangered in “a significant portion of its range” as well as those species that are threatened or endangered throughout their entire range. The offshore waters of the California Current represent an ecological region that is distinct from those ecological regions farther north. Accordingly, SCB and ASM are urging the NMFS to protect the California portion of the Steller sea lion’s range under the ESA. SCB is particularly concerned that NMFS is discounting the value of the California population based on a draft joint policy with the Fish and Wildlife Service which would re-interpret the phrase “significant portion of its range” in the ESA to mean something far less than the best available science, the plain language of the Act, and the purposes of the Act would indicate. SCB provided extensive comments on this draft policy earlier in 2012 because the Services draft joint policy risked stripping the term “significant portion of its range” of any independent meaning or conservation value. Although the draft policy has not been finalized, NMFS appears to rely on this policy in denying the Steller sea lion continued protection in California.
On April 20, the second anniversary of BP’s Deepwater Horizon spill in the Gulf of Mexico, SCB, along with three other scientific societies (The Wildlife Society, Ornithological Council, and the Society for Ecological Restoration), asked the Department of Justice to seek fines for the loss of protected wildlife that was caused by the spill. The resulting funds could then be used for restoration of affected wildlife populations. According to the National Marine Fisheries Service, the Gulf oil spill killed hundreds of federally-protected sea turtles, marine mammals, and thousands of similarly protected migratory birds, and did vast damage to other fish and marine and coastal resources. However, the Department of Justice has yet to seek fines or other relief for these violations of the Endangered Species Act and other federal wildlife laws.
The scientific societies urged the DOJ to seek fines under a 1988 provision that requires the fines to be directed to cooperative state and Federal efforts to conserve and recover endangered and threatened species. This could provide as much as $57 million for the Cooperative Endangered Species Conservation Fund in response to the documented deaths of sea turtles alone. Funds from oil spill fines allocated through the ESA’s Section 6 Cooperative Fund might also be used to help restore some of the listed and candidate plant species that were destroyed or adversely affected by the spill. Such broader restoration work is essential as wildlife and fish depend on healthy marine, littoral, and estuarial plants. The impacts of the spill on species and ecosystems may persist far into the future and might require hundreds of millions of dollars in restoration to correct the damage.
The full letter is here.
Today, the Society for Conservation Biology submitted extensive comments to the U.S. Fish and Wildlife Service and the National Marine Fisheries Service concerning the Services’ proposal to define and implement the U.S. Endangered Species Act’s phrase “significant portion of its range.” Because the U.S. Endangered Species Act allows the Services to list species as threatened or endangered based on threats “throughout all or a significant portion” of a species’ range, it is critically important that this definition be based on the best available science in order to effectively conserve biodiversity.
SCB outlined several areas where the Services’ draft policy appears to ignore key principles from the field of conservation biology. Most importantly, the policy appears to ignore the basic purpose of the ESA, which clearly envisions protecting declining species, and the ecosystems on which they depend, before they become threatened or endangered with extinction globally, and to restore such threatened species that have been extirpated from significant portions of their historic range.
SCB developed a detailed alternative to the Services’ proposed policy that would better reflect the intent and goals of the ESA and best practice in applyng conservation science to effect recovery of endangered and threatened species.
The full text of SCB comments can be found here.
Background provided by the Fish and Wildlife Service on the Services’ draft policy can be found here.