Some Troubling Decisions on Endangered Species by US Department of Interior
Many species advocates are understandably dismayed by the October 4 Department of Interior decision to deny federal protection for twenty-five seemingly deserving species under consideration for listing as ‘Endangered.’ Many of these species – including the Pacific Walrus, Florida Keys mole skink, and Bicknell’s Thrush – are thought to be extremely vulnerable to climate change, but will be deprived of federal protection nonetheless.
Denying an ESA listing to any one of these species alone may not justify intense scrutiny of the Trump administration’s handling of the extinction crisis, but the wholesale rejection of all twenty-five species has rekindled controversy--- critics claim too much political influence over decision outcomes prioritizes corporate interests, and makes questionable use of existing science concerning species vulnerability.
Indeed, the most peculiar issue with many of the Interior’s recent decisions is the way it has dealt with scientific uncertainty surrounding the precise fate of species under threat from climate change.
Even though climate change signals substantial threats to species’ long-term viability, climate and habitat models used to assess whether species might be at risk of extinction within the ‘foreseeable future’ obviously involve some degree of uncertainty. We cannot make perfect and guaranteed predictions of the scale of warming at a given time, or precisely how that warming will alter habitat, or the exact way species will respond to these changes. The longer time frame used in a model, the more uncertainty that model generally entails. Sometimes this leaves us with a wide range of possible outcomes to consider.
Thus far, the Interior’s common response to this challenge has been to shift to shorter time frames for analysis --- by assessing climate impacts on species after only, say, 20 or 30 years, which we can predict more confidently. The argument for this approach is that we are then using a more reliable scientific assessment of the fate of a given species. And that, after all, is how ESA-related decisions are supposed to unfold --- guided by the best available science.
But we need to have an honest discussion about whether such a short-term view truly represents a sensible use of science.
From a scientific standpoint, is it really wise to ignore probable climate impacts on species in the more distant future? When we zero in on only the most reliable, short-term data and analysis, are we really improving the scientific integrity of decisions with regard to species? Or, are we leaning on scientific certainty to justify government inaction on species that are, in fact, in dire need of protection?
A More Prudent Approach to Uncertainty, Climate Change, and the ESA
A more prudent strategy seems readily available and is probably already apparent to the scientific community, conservationists, and some government personnel. To begin, it is essential that when the directionality of climate change is abundantly clear we do not discount the threat of climate change simply because the precise ramifications at a particular time are not entirely certain.
Short-term analyses are prone to underestimating risks to species that long-term perspectives are more inclined to capture. It seems difficult to argue, then, that a short-term approach necessarily enables a more scientifically-informed or better scientifically-informed decision about whether or not to grant protection to a given species.
Second, we need to be a bit more delicate with how we engage the ambiguous language found within the ESA, particularly the terms ‘foreseeable future.’ The ESA is saturated with puzzling terms of this kind. Understanding their meaning can be a formidable task, but applying the terms to ESA implementation must be done with care given the profound influence that language may have over high stakes decisions concerning imperiled species.
It is tempting to assume that the scenarios we can most confidently predict, using the most reliable data, models, and so forth, fit the notion of ‘foreseeable future’. But that may not be the safest assumption. It may not truly reflect the approach to species protection that the architects of the ESA had envisioned.
Third, we need to be far less cavalier in how we incorporate evidence of species’ adaption into assessments of species’ long-term viability in the face of climate change. Granted, many species will adapt, persist, and thrive under changing climate conditions. But we must not lose sight of the fact that the conditions most favorable to species’ wellbeing are typically those that species have consistently faced for several millennia.
Written by ComET Research Associate Lee Brann