Letter to Sally Jewel, Secretary of the Interior, and Dan Ashe, Director of Fish and Wildlife Services - Listing Bat as Endangered Threatens Forest Health, Jobs

Letter

October 14, 2014

Secretary Sally Jewell
U.S. Department of the Interior
1849 C Street, NW
Washington, D.C. 20240

Director Dan Ashe
U.S. Fish and Wildlife Service
1849 C Street, NW
Washington, D.C. 20240

Dear Secretary Jewell and Director Ashe:

We are writing regarding the U.S. Fish and Wildlife Service (FWS) proposal, published in the Federal Register (FR Volume 78, Issue 191, October 2, 2013), to list the northern long-eared bat (NLEB) as endangered due to the effects of white-nose syndrome (WNS).

It is our concern that the FWS has insufficient supporting data to warrant listing the NLEB as an endangered species, particularly given the absence of WNS in so much of its range. In addition, we believe the FWS failed to adequately gather and consider credible information available from state government entities and other non-federal sources before proposing to list the NLEB.

According to the proposed listing, WNS was recognized by the FWS as the single overriding factor in the listing decision: "WNS alone has led to dramatic and rapid population level effects on the northern long-eared bat" and "the species likely would not be imperiled were it not for this disease." At the same time, the Service recognizes that the distribution of WNS covers only portions of the NLEB's range in the U.S. and abroad. In fact, as of this past August, WNS has never been documented in 17 of the 39 states within the NLEB's U.S. range, and the idea of WNS expanding across the entirety of the NLEB range is only speculation.

The South Dakota Department of Agriculture joined the FWS in identifying WNS as the primary threat to the NLEB, stating in its comments on the listing that "research indicates that northern long-eared bat population reductions appear to be disease driven rather than habitat loss driven." However, the majority of the restrictive conservation measures recommended in the Interim Conference and Planning Guidance (ICPG) apply not to disease but to habitat-related activities, including forest management. These recommendations are especially troubling since the FWS findings show that forest management does not have a significant negative impact on the species.

Although appropriate measures should be taken to stem the spread of WNS, the proposed restrictions on forest management in the ICPG are overly burdensome and may actually lead to deterioration of NLEB habitat. The South Dakota Department of Agriculture shares our concerns and explains in its comments: "We are concerned that the ICPG is overly restrictive … The measures would severely limit our ability to manage forests for insect and disease outbreaks, fuel reduction, and habitat for other species." Extensive buffers and seasonal and other management restrictions identified in the ICPG will have significant negative impacts on forest management activities throughout the Black Hills region.

Contrary to what the ICPG recommendations imply, forest management activities can significantly improve NLEB habitat, which was also highlighted in the proposed listing (FR Volume 78, Issue 191, October 2, 2013). Additionally, accumulation of fuel load in the absence of adequate forest management will result in wildfires burning much hotter, potentially destroying larger areas of suitable NLEB foraging and summer roosting habitat.

If the FWS determines that the NLEB is an endangered species, we request that any listing focus on addressing WNS and not forest management activities that are unrelated to the spread of WNS. Prior to any listing decision, the ICPG should be revised to recognize the many benefits of responsible forest management throughout the western range of the NLEB, and the overly burdensome restrictions on forest management activities should be removed.

More than 1,500 jobs, which contribute more than $119 million to local economies in the Black Hills region, are at stake. If the restrictions outlined in the ICPG are adopted, those communities would suffer devastating losses with no real benefit to the NLEB. The most constructive step the FWS could take to benefit the NLEB would be to focus on addressing WNS, which is the primary threat to the species.

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