May1st, 2014
California Department of Fish and Wildlife Nongame Wildlife Program
Attn: Neil Clipperton1812 9thStreet
Sacramento, California 95811
Re: Comments Regarding CDFW Status Review for the Northern Spotted Owl (Strixoccidentalis caurina)
Dear Mr. Clipperton and Department Officials:
The undersigned conservation organizations submit the following comments on the California Department ofFish and Wildlife Status Review for the Northern Spotted Owl (Strix occidentaliscaurina) (NSO) pursuant to the California Endangered Species Act (CESA). Please consider these comments as part of the Department’s review.
The available evidence supports the conclusion that the Northern Spotted Owl warrants listing as either “threatened” or“endangered” under CESA. The Northern Spotted Owl warrants listing under CESA because it meets several of the criteria for listing a species as specified under the Act. Specifically, the NSO warrants listing due to the following factors: 1)past, present, and threatened habitat destruction, modification or curtailment; 2) competition from invasive species;
3) inadequate regulatory mechanisms; 4) climate change.
The status and trends of NSO in California on both public and private lands show continued declines in NSO fecundity,apparent survival, and population trends (e.g. Forsman et al. 2011). The best available evidence clearly points to habitat loss and the incursion of the invasive and aggressive barred owl among the primary reasons for declines in NSO across the species’ range,and in California specifically.
There is ample evidence available to the Department via long-term, independent, and peer-reviewed literature to show that the NSO warrants listing as either “threatened” or“endangered.”
Long-term demographic studies such as Forsmanet al. 2011 demonstrate that both public and private lands study are as show declines in key indicating factors.It is critical that the Department conduct its review with scientific rigor, and that it appropriately weighs available evidence based on the strengths of said evidence. We encourage the Department to seek and consider evidence of the highest quality and that represents the best available science.
CESA requires the Department to consider the best available information, but does not require certainty in the science or evidence. The Department must, therefore, conduct its evaluation through the lens ofthebest, most rigorous and most credible evidence.
The Northern Spotted Owl is clearly in decline in California and throughout its range,and is faced with a myriad of threats, and therefore warranting listing as either “threatened” or“endangered” under CESA. We appreciate the opportunityto provide comments to the Department and are happy to answer any questions that the Department may have.
Sincerely,
Susan Jane Brown Western Environmental Law Center
George Sexton Klamath-Siskiyou Wildlands Center
Kimberly Baker Klamath Forest Alliance
Justin Augustine Center for Biological Diversity
Steve Holmer American Bird Conservancy
Jodi Frediani Central Coast Forest Watch
Larry Glass SAFE Safe Alternatives for our Forest Environment
Daniel Ehresman NorthCoast Environmental Center
Paul Hughes Forests Forever
Marily Woodhouse Battle Creek Alliance
Susan Robinson Ebbetts Pass Forest Watch
