Last week, I posted about the court hearing on whether the USFWS decision not to list wolverines was “arbitrary and capricious.” During that hearing, the lawyers for the USFWS and the defendant-intervenors referenced a number of arguments against listing. Many of these arguments were heavily promoted by the states opposed to listing (per a USFWS email cited during the hearing, these arguments ‘originated’ with Idaho, Wyoming, and Montana). I referenced these arguments piecemeal as I summarized the hearing, but they were presented in a more structured way in the comments of various entities – including the states – on the proposed rule for listing. They were then succinctly and coherently summarized in September 2014 when the states published a letter, in various news outlets, in response to the decision not to list.
Before I delve into further analysis of the science and the conflicting narratives about what the research says, I’m going to post the letter so that readers can assess the structure and merits of the state’s contentions on their own. I’ll be discussing both the scientific details of these arguments, and the overall arc of the different narratives about wolverine conservation, in following posts. There are a number of other documents relevant to this set of arguments, but as the letter is the most concise, I’m going to use it as a point from which to elaborate and bring in additional details. Feel free to share your thoughts and impressions before I start with my own analysis.
Here’s the letter:
Wolverine fares well
The states of Montana, Idaho and Wyoming have noted the recent criticisms about the U.S. Fish and Wildlife Service’s Aug. 12 decision to not list wolverine in the western United States as threatened under the Endangered Species Act. For the record, our states opposed the service’s original recommendation to list wolverines based on our concerns about listing a species that is at its highest population level in the past 80-100 years and still increasing. This fact supports the conclusion that state management works for the wolverine. The states also expressed our concerns over the uncertainty inherent in using projected changes in climate over the next 40-80 years to speculate about what might happen to wolverine habitat and wolverine populations.
The service, however, didn’t reverse its original proposal due solely to state input. The service chose, instead, to convene an independent panel of climate and wildlife scientists to review and discuss the science underlying the original listing proposal. Endangered Species Act listing is a complex arena that requires decisions based on imperfect data, and we applaud the service’s efforts to seek independent advice. It’s likely the model used for wolverines — a model based on cooperation with the states — will have utility for future decisions. Ultimately, the service made the right decision for wolverines for the right reasons. We thank the service for its willingness to listen, keep an open mind and utilize additional methods to fully explore science in its decision process.
Together we remain fully committed to the conservation of wolverines.
Idaho Department of Fish and Game
M. Jeff Hagener
Montana Fish, Wildlife & Parks
Wyoming Game and Fish Department