A group of independent scientists is speaking out in response to an order from a high-ranking U.S. Fish and Wildlife Service official to not protect wolverines under the U. S. Endangered Species Act. The scientists are saying the order ignores the best available science and could set a dangerous precedent for future candidates for ESA protection.
That order came in the form of a May 30 memo from Noreen Walsh, a regional director, in which she cited "uncertainty" about the effect of climate change on specific pieces of wolverine habitat as justification for her order to abandon the listing process for the species.
But in a letter sent Thursday to Interior Secretary Sally Jewell and USFWS director Dan Ashe, a group of 56 wildlife ecologists and conservation biologists say that Walsh's order violates USFWS's obligation to use the best available science. And a second letter sent the same day on behalf of two prestigious scientific organizations echoed that charge.
The issue: snow. The wolverine, Gulo gulo, needs deep, persistent snow in order to reproduce, as females of the species dig birthing dens in snowbanks five feet deep or more, and those snowbanks have to last until at least May before melting. Though it's true that climate modeling can't yet predict exactly how deep snowbanks will be under specific trees in the early spring of 2073, scientists have reached consensus that the warmer it gets, the faster snow melts. The warmer North America becomes, the harder it will be to find deep snowbanks that last until May. And that poses a serious threat to an already rare carnivore.
Which is what USFWS staff had said in their recommendation that the wolverine be listed as a Threatened species. An assistant regional director working under Walsh drew up a formal memo recommending that listing, which would apparently have been a done deal if not for Walsh's subsequent order to back off.
In Thursday's letter to Jewell and Ashe, the 56 scientists -- who represent a range of institutions from universities to environmental groups to private consulting firms -- point out that the "uncertainty" Walsh cited is rife in many areas of wildlife science, and that the ESA anticipates that by tilting the scale in favor of protection:
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 signers implore Jewell and Ashe to set aside Walsh's order. "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," reads the letter. "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."
A second letter sent to Dan Ashe by the Society for Conservation Biology, North America section (SCB-NA) and the American Society of Mammalogists (ASM) on Thursday amplified the independent scientists' criticism. Signed by SCB-NA President Carlos Carroll and his ASM counterpart Eileen Lacey, along with SCB-NA's Policy Director Doug Parsons and ASM Conservation Chair Bradley Bergstrom, the groups' letter rather robustly dismantle's Walsh's arguments about the uncertainties of predictive modeling of the effects of climate change on the landscape.
The groups charge that the kind of evidence Walsh needs in order to sign off on listing the wolverine "in all likelihood would be impractical or impossible to obtain for a rare free-living animal," and that her hesitation to accept predictive modeling as scientific evidence runs counter not only to established science but to official USFWS policy as well.
The groups mince no words in the conclusion of their letter:
In order to demonstrate the Service's commitment to scientific integrity in the implementation of the Endangered Species Act, the Society for Conservation Biology's North America Section and the American Society of Mammalogists urge your agency to reconsider the determination made in the May 30 memo that listing of the wolverine as threatened is not warranted.
USFWS is expected to make a final decision on whether to list the wolverine in the next few days.