The US Fish and Wildlife Service has reopened the proposed wolverine listing rule for comment. They will be accepting comments until December 2nd; details on submission procedures, as well as access to the proposed rule and associated documents, are available here. If you’re already submitted comments, you don’t need to resubmit them; they are already part of the record. The USFWS is seeking additional information on the following, taken from the published notice:
(1) Whether wolverines are dependent on cold and snowy conditions and habitat that closely approximates the area covered by snow until late spring (May 15).
a. Whether wolverines are dependent on such habitats defined by persistent spring snow for feeding, breeding, and sheltering.
b. Whether the projected impacts of climate change will result in loss of habitat for wolverines.
(2) The factors that are the basis for making a listing determination for a species under section 4(a) of the Act, which are:
a. The present or threatened destruction, modification, or curtailment of its habitat or range;
b. Overutilization for commercial, recreational, scientific, or educational purposes;
c. Disease or predation;
d. The inadequacy of existing regulatory mechanisms; or
e. Other natural or manmade factors affecting its continued existence.
(3) Information regarding the threats we identified in the proposed rule, or threats to the species that we may have overlooked in the proposed rule. Threats we identified were:
a. Habitat loss due to climate change;
b. Regulated trapping of wolverines and trapping of wolverines incidental to trapping for other species; and
c. Inbreeding and related genetic and demographic effects of small and isolated populations.
What happened to prompt the reopening of the comment period? It seems that in the process of the peer review that is required for proposed listing rules, conflicting scientific interpretations of the parameters of wolverine dependence on cold and snow emerged. The full documents of the different peer review parties are available, and for anyone who wants to understand how scientific debate happens, and how complicated the translation of science into wildlife policy actually is, these are worth the read. For many people, though, several hundred additional pages of very detailed information on how a MODIS satellite works, and the variation in wolverine parturition dates, and whether or not a given climate model is reliable, will probably be overwhelming. I’m cautious about taking on this discussion, but I do want to provide an overview to readers who don’t have the time to delve into all of these documents. I also think that this provides an instructive moment to reflect on what science is, what it can (and cannot) do in terms of helping us make decisions, and how it operates when it gets tossed into an arena of competing interests. I’ll deal with both of these questions later this week, in installments, in order to avoid the deadly sin of a 6000-word blog post.
For now, though, a quick note: my understanding, based on reading the peer reviews, is that the debate is about the snow model, the genetics, climate modeling, whether or not wolverines actually do depend on snow to den, and whether or not that dependence is the only explanatory factor in describing wolverine distribution and constraints. Less prominent in the discussion are trapping, incidental take, motorized recreation, or any of the other hot issues that provoke strong opinions, although some parties do, predictably, defend limited trapping. It’s possible that USFWS reopened the comment period in order to gather more information and give scientists the chance to resolve the debates about interpreting the published literature. It’s also possible that they reopened it because other scientific papers that might shed light on the questions are due for publication, and they want the opportunity to enter these papers into the record. I’m not sure. But I don’t see this as an invitation to push any opinions that lack very solid and credible science to back them up. Anyone with relevant information should comment, but at least glance through the peer reviews to get an idea of the debate and the competing arguments; it’s probably most constructive to target your comments and your evidence to those issues.