Policy Statements » Letters from the President:

The Ecological Society of America Comments on H.R. 1662, November 7, 2003

The Ecological Society of America is the nation’s primary professional organization of ecologists, representing more than 8,000 scientists in the United States and around the world. Founded in 1915, the Ecological Society of America is a scientific, non-profit organization dedicated to the advancement of the ecological sciences.

The Endangered Species Act (ESA) is a powerful conservation tool, offering critical protections for our biological heritage. The Ecological Society of America is committed to the goals of the ESA and to providing the best available science for implementation of the Act. The Ecological Society of America position paper titled, “Strengthening the Use of Science in Achieving the Goals of the Endangered Species Act: An Assessment by the Ecological Society of America”, published in the peer-reviewed journal Ecological Applications, outlined the steps the Society believes would best serve to achieve this goal.

The Ecological Society of America supports the reexamination of the ESA and the use of science within the Act. We hope to be of assistance to the committee as you take up this important work. However, we are deeply concerned that the proposed legislation, H.R. 1662, “Sound Science for Endangered species Act Planning Act of 2003”, will not improve the application of science to the ESA. We ask you to consider the following points in your discussions of the legislation and explorations of ESA reauthorization.

• There is no scientific justification for giving greater weight to empirical data over modeling results.
  We are firmly in support of empirical data in the ecological sciences, but modeling is an important tool and a critical component of recovery planning. The Ecological Society of America’s position paper recommended increased use of methods such as Population Viability Analysis because of the wealth of information available from such models. At its heart, the ESA is about risk assessment. Assessing the risk of extinction is an inherently theoretical exercise. Just as the Environmental Protection Agency must use models to assess the risk of air pollution to human health and the Federal Reserve must use models to predict the response of the economy to monetary policies, so must ecological scientists use models to predict the risk of extinction. Stripping ecologists of one of their most effective tools will weaken, not strengthen the use of science in the ESA.
• Unnecessary listing of species is not occurring.
  Of the more than 1800 species listed under the ESA, approximately 15 have been found to be not endangered or not a distinct population. An unnecessary listing rate of less than 0.1% should be viewed as a success, not a failure.
• Additional peer review requirements are an unnecessary burden to the functioning of the ESA.
  The peer review process called for in HR 1662 is unnecessary and raises serious implementation concerns. Outside peer review should be reserved for instances where new methodologies are being implemented or where the science is particularly complex. Mandating a review of all listings, delisting, recovery plans, and jeopardy findings will result in outside reviewers examining methods that have already been thoroughly vetted. This is a waste of time and of money and not in line with accepted peer review criteria.
  
  The Ecological Society of America position paper titled, “Strengthening the Use of Science in Achieving the Goals of the Endangered Species Act” made many recommendations of specific actions that should be undertaken. Absent from this list was an increased use of peer review. In fact, the paper stated “Adding independent peer review or other administrative processes to the listing process would unnecessarily lengthen the time to make a listing decision without providing any substantial benefits. The major problem with the listing process has been its slowness, not inadequacy of the quality of the listing decisions.”

There are several ways that science can be put to better use in the implementation of the ESA. We ask the committee to consider the following in their discussions of reauthorization of the Act.

• Fully fund the listing and recovery plan process.
  The greatest threat to the efficacy of the ESA is that species that need to be listed are not and recovery plans are not developed for all species. This is due mostly to the perpetual under-funding of these programs. By delaying the recovery efforts, the odds of a successful recovery are reduced. A successful ESA relies on good science and this requires that adequate resources be assigned for the task.
• Incorporate ecosystem-level conservation.
  The identification and conservation of ecosystems that have sustained significant degradation can lessen the need for the ESA. Most often endangered species are endangered due to habitat loss. By focusing on the protection of degraded ecosystems, the species that depend on such ecosystems can be helped before they become endangered. Such preemptive action increases the odds that they will not become extinct.

The loss of biological diversity that we are currently observing is unprecedented. The ramifications of these extinctions are unknown. Statutes like the ESA provide much need protections for at-risk species. The appropriate application of the best available science is a critical component in successfully implementing the Act. We urge you to consider the comments of the scientific community when deliberating on HR 1662 and other proposed changes to the ESA.

For further information or to access Ecological Society of America documents, please contact Maggie Smith, ESA Policy Analyst, at maggie@esa.org or 202.833.8773, extension 224.