On June 6, 2012, Seattle Audubon provided comments on the Experimental Removal of Barred Owls to Benefit Threatened Northern Spotted Owls Draft Environmental Impact Statement (DEIS) dated March, 2012. Seattle Audubon’s comment letter is available here. Below is a summary of Seattle Audubon’s position.
Seattle Audubon cultivates and leads a community that values and protects birds and the natural environment. Our community wants to see the recovery of NSO across its historic range and supports the use of strong science to inform decision making. Listed as Threatened under the Endangered Species Act in 1990, the Northern Spotted Owl (NSO) has continued to decline at alarming rates. Seattle Audubon has been engaged in helping with the protection and recovery of the NSO for over three decades. Our primary concern is and will continue to be the protection of critical habitat for this species. Under no circumstances can NSO recovery occur without committed and focused on-going habitat protection and restoration efforts.
The primary emphasis for Northern Spotted Owl recovery should continue to be on habitat management, preservation, and enhancement. In particular, Seattle Audubon continues to believe that there is a need to change industrial forest practices on both public and private lands to preserve and foster sustainable mixed species with multiple canopy layers, large trees, horizontal patchiness, and understories of native shrubs and forbs. A comprehensive approach would promote structural and functional diversity, conferring ecological resilience. Such resilience provides benefits to multiple wildlife species and a robust flow of ecosystem services - both of which are important overall conservation objectives beyond the preservation of the Northern Spotted Owl.
Seattle Audubon acknowledges that there are many stresses on the NSO population, including Barred Owl competition. While the Barred Owl has displaced the NSO from some suitable habitats, reduced NSO breeding success, and sped NSO decline, Barred Owls’ impacts on NSO cannot be used as an excuse to not address habitat loss issues. Barred Owl should not become a scapegoat for the decline of NSO (DEIS, pg. 322). The 2011 federal Revised Recovery Plan for the Northern Spotted Owl states that Barred Owl presence actually increases the need for additional habitat protection.
Seattle Audubon strongly agrees with USFWS’s statement in the Recovery Plan that “In order to reduce or not increase this potential competitive pressure while the threat from barred owls is being addressed, this Revised Recovery Plan now recommends conserving and restoring older, multi-layered forests across the range of the spotted owl” (Revised Recovery Plan for the Northern Spotted Owl, pgs. I-9). Potential Barred Owl management is no substitute for critical habitat preservation.
Seattle Audubon supports the implementation and continuation of statistically rigorous research studies on Barred Owl ecology and Barred Owl-Northern Spotted Owl interactions in order to inform potential future management decisions. After review of the DEIS, Seattle Audubon asks USFWS for rigorous research studies regarding Barred Owl removal that are timely
, utilize demographic studie
s to evaluate multiple sites
, and include sufficient pre-treatment data
. Alternatives that utilize occupancy studies (limited data), have limited/no pre-treatment data, utilize only one study area, or delay removal experiments in order obtain pre-treatment data are unacceptable.
Seattle Audubon recommends that the USFWS create a review team of independent scientists to monitor the entire experimental process and keep the public informed about the progress.
This panel should monitor the lethal removal of Barred Owls to ensure humane treatment of the birds, to sustain a rigorous removal protocol, to monitor the process, and to ensure scientific transparency. In the context of the DEIS, “experimental removal” and “treatment” mean killing Barred Owls. As a bird advocacy organization, killing birds is a contentious and serious ethical matter. Seattle Audubon’s conditional support of experimental removal is reliant on USFWS’ consistent application of a rigorous, independently verified, scientific approach that minimizes the killing of Barred Owls. We urge the USFWS to establish this review team because independent scientific evaluation, separate from the USFW staff, will be critical to the credibility of the results and in future decisions.
Seattle Audubon is deeply concerned about the future prospect of managing one bird species for the preservation of another bird species, especially when the changes to commercial logging (quantity and practices) would have a significant habitat impact on NSO recovery. While the alternatives in this DEIS strive to understand the biological interactions between Barred Owls and NSO, the DEIS neglects the fact that humans are a major factor in NSO’s decline. Increased human use of forests lands, increased forest developments, and other habitat alternations impact the NSO. Ultimately, NSO issues are not about Barred Owl but the future of our older-growth forests and the need for changes to commercial logging practices.
If you have any questions regarding these comments, please contact Brian Windrope at firstname.lastname@example.org