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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.



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