U.S. Senator John Thune (R-South Dakota) and Representative Kristi Noem (R-South Dakota) today sent a letter to U.S. Secretary of the Interior Sally Jewell and U.S. Fish and Wildlife Service (FWS) Director Dan Ashe calling on the FWS to withdraw its proposed listing of the northern long-eared bat (NLEB) as endangered due to insufficient supporting data to warrant the listing.
“I am deeply concerned by the FWS’s pending decision to list the northern long-eared bat as endangered while simultaneously proposing flawed forest management guidance that could significantly harm the Black Hills economy,” said Thune. “These proposed regulations don’t address the real problem—eradicating white nose syndrome. The long-eared bat’s population decline is due to the white-nose syndrome and is not related to current forest management practices. If FWS and the Interior Department are serious about protecting both the northern long-eared bat and the Black Hills National Forest—it will repeal its proposed listing, focus on addressing white-nose syndrome, and continue active forest management, including timber sales.”
“The proposed listing of the long-eared bat as endangered and corresponding guidance provides a significant and unnecessary distraction from the real issues at hand,” said Rep. Noem. “While White Nose Syndrome is a species-threatening disease that has jeopardized northern long-eared bat populations in many states, the proposal focuses primarily on habitat – a non-factor according to many researchers. The misguided proposal not only avoids the primary cause of the problem, but also restricts active forest management, endangering more than 1,500 jobs in the Black Hills area. Any effort to preserve the species should focus on the disease.”
"The restrictions proposed by the FWS are an eminent threat to forest products companies and sustainable forest management in the Black Hills, and will do nothing to address the disease that is the sole cause for concern with this species,” said Ben Wudtke, Forest Programs Manager of the Black Hills Forest Resource Association. "These restrictions on forest management are proposed despite acknowledgement by the FWS that timber harvest activities have not posed any threat to this species and may actually improve habitat used by the long-eared bat. It is imperative the FWS change their interim guidance to reflect the benefits of active forest management for long-eared bat habitat in western forests."
Listing the long-eared bat as endangered and the ensuing regulatory restrictions on forest management could effectively end active management in the Black Hills National Forest, which will cause declining forest health, increase the likelihood of large scale wildfires, and severely impact the timber industry in the Black Hills. Thune and Noem’s letter cites the more than 1,500 jobs that contribute over $119 million to local economies in the Black Hills that will be jeopardized if these regulations are put into place.
Text of Thune and Noem’s letter is below:
October 14, 2014
Secretary Sally Jewell
U.S. Department of the Interior
1849 C Street, NW
Washington, D.C. 20240
Director Dan Ashe
U.S. Fish and Wildlife Service
1849 C Street, NW
Washington, D.C. 20240
Dear Secretary Jewell and Director Ashe:
We are writing regarding the U.S. Fish and Wildlife Service (FWS) proposal, published in the Federal Register (FR Volume 78, Issue 191, October 2, 2013), to list the northern long-eared bat (NLEB) as endangered due to the effects of white-nose syndrome (WNS).
It is our concern that the FWS has insufficient supporting data to warrant listing the NLEB as an endangered species, particularly given the absence of WNS in so much of its range. In addition, we believe the FWS failed to adequately gather and consider credible information available from state government entities and other non-federal sources before proposing to list the NLEB.
According to the proposed listing, WNS was recognized by the FWS as the single overriding factor in the listing decision: “WNS alone has led to dramatic and rapid population level effects on the northern long-eared bat” and “the species likely would not be imperiled were it not for this disease.” At the same time, the Service recognizes that the distribution of WNS covers only portions of the NLEB’s range in the U.S. and abroad. In fact, as of this past August, WNS has never been documented in 17 of the 39 states within the NLEB’s U.S. range, and the idea of WNS expanding across the entirety of the NLEB range is only speculation.
The South Dakota Department of Agriculture joined the FWS in identifying WNS as the primary threat to the NLEB, stating in its comments on the listing that “research indicates that northern long-eared bat population reductions appear to be disease driven rather than habitat loss driven.” However, the majority of the restrictive conservation measures recommended in the Interim Conference and Planning Guidance (ICPG) apply not to disease but to habitat-related activities, including forest management. These recommendations are especially troubling since the FWS findings show that forest management does not have a significant negative impact on the species.
Although appropriate measures should be taken to stem the spread of WNS, the proposed restrictions on forest management in the ICPG are overly burdensome and may actually lead to deterioration of NLEB habitat. The South Dakota Department of Agriculture shares our concerns and explains in its comments: “We are concerned that the ICPG is overly restrictive … The measures would severely limit our ability to manage forests for insect and disease outbreaks, fuel reduction, and habitat for other species.” Extensive buffers and seasonal and other management restrictions identified in the ICPG will have significant negative impacts on forest management activities throughout the Black Hills region.
Contrary to what the ICPG recommendations imply, forest management activities can significantly improve NLEB habitat, which was also highlighted in the proposed listing (FR Volume 78, Issue 191, October 2, 2013). Additionally, accumulation of fuel load in the absence of adequate forest management will result in wildfires burning much hotter, potentially destroying larger areas of suitable NLEB foraging and summer roosting habitat.
If the FWS determines that the NLEB is an endangered species, we request that any listing focus on addressing WNS and not forest management activities that are unrelated to the spread of WNS. Prior to any listing decision, the ICPG should be revised to recognize the many benefits of responsible forest management throughout the western range of the NLEB, and the overly burdensome restrictions on forest management activities should be removed.
More than 1,500 jobs, which contribute more than $119 million to local economies in the Black Hills region, are at stake. If the restrictions outlined in the ICPG are adopted, those communities would suffer devastating losses with no real benefit to the NLEB. The most constructive step the FWS could take to benefit the NLEB would be to focus on addressing WNS, which is the primary threat to the species.
Cc: Tom Tidwell, Chief, U.S. Forest Service