North Coast Chapter - CNPS

Scientists Call For An End To Habitat Destruction

Under The Endangered Species Act

The Presidents of 9 professional scientific societies, with a combined membership of over 30,000 scientists, have signed a letter to the Congress and the Clinton Administration outlining science-based standards for amending the federal Endangered Species Act (ESA). Recently proposed legislation by Senator Kempthorne (S. 1180) and Representative Miller (H.R. 2351) would reauthorize the ESA, but would also keep the controversial Section 10 which permits destruction of endangered species' habitat. "On the surface, these two bills appear to address quite different issues, but a careful examination suggests several similarities though both are somewhat flawed. We applaud the provision of proposed legislation and we hope we can provide them with the scientific information needed to perfect this legislation", said James MacMahon, President of the Ecological Society of America.

The letter represents the first comprehensive vision for ESA reform endorsed by a significant number of respected scientists. Their recommendations outline the changes that Congress must make in order to correct shortcomings of the current law. "The Endangered Species Act will only be effective if it ensures recovery of endangered wildlife and plants.

Destruction of habitat needed by endangered species is not compatible with recovery", said Alan Kohn, President of the Society for Integrative and Comparative Biology. Washington DC based environmental groups have endorsed the Miller bill, claiming that, in contrast to the Kempthorne bill, it would provide for stronger recovery provisions and is not based on habitat destruction. However, a close reading of the Miller bill reveals that it still needs work to meet this goal, especially insofar at it relates to the issue of destruction of habitat on private lands. "We are very concerned about the proposed Miller and Kempthorne bills which authorize significant habitat destruction and rely on mitigation techniques, the so-called habitat conservation plans, that have little or no scientific support", said Fraser Shilling, of the Society for Integrative and Comparative Biology. Under both bills mitigation plans call for "no further decline" in endangered species populations rather than the much higher recovery standard endorsed by the scientists' letter.

The letter from scientists is attached below. For more information, contact any of the co-signers, the President of the lead Society, Alan Kohn of the Society for Integrative and Comparative Biology (SICB), or the Conservation Chair of SICB, Fraser Shilling (; 530 752-7253).

America Needs an Endangered Species Act based on Science and Recovery, not Habitat Destruction

We, the undersigned Presidents of scientific Societies present to the Executive and Legislative branches of the federal government the following recommendations for reauthorizing the Endangered Species Act (1973) and development of guidelines for its use based on biological science. The collective membership of our societies is more than 30,000 scientists. Our expertise is in marine, terrestrial, and aquatic ecosystems, studying a wide variety of plant and animal species. The Endangered Species Act will be effective only if the strategies for habitat conservation, recovery planning, and protection from harm for listed species are based on sound scientific information. The majority of the American public has indicated a desire for conservation of threatened and endangered species and their habitats through a strong Endangered Species Act. It is our professional opinion that this goal can best be accomplished if the reauthorization incorporates the following principles and recommendations.

1) Reduce Extinction - The rate of human-caused extinction is from 100 to 1000 times higher than the natural rate.The purpose of the Endangered Species Act is to contain human actions that could threaten extinction of a species and to proactively plan for recovery of the listed and candidate species.

2) Critical Habitat - The federal government should declare and describe the critical habitat for threatened and endangered species at the time of listing, based upon sufficient scientific information. Critical habitat is defined as the specific areas within and outside the geographical area presently occupied by the listed species containing features essential to the conservation of the species.

3) Recovery Area - Recovery is a priority of the Endangered Species Act. To accomplish this, the federal government should designate recovery area(s) greater than that needed for a minimum viable population. Recovery plans should be reviewed by independent scientists and the implementation should take place before experimental efforts, such as "Habitat Conservation Plans".

4) Recovery Planning - Reasonable implemented recovery plans will provide for: a) an area sufficient to absorb 100% of the recovered population(s) and b) population goals based upon best available scientific information. Implementation of plans should take place within 90 days of listing. Successful recovery would take place across the available landscape previously occupied by the species.

5) Regional Planning - In order to achieve uniformity in successful endangered species conservation, the federal government should cooperate with local governing bodies to ensure that no action preempts the containment strategies central to the Act. New and existing Habitat Conservation Plans developed at the state, regional, county, and municipal level should follow the guidelines of the Act as described here. Habitat Conservation Plans should undergo an environmental impact analysis with attention paid to cumulative impacts within and outside the planning area.

6) No Harm to Species - To limit risks of extinction, no private or public agency action should negatively modify habitat occupied by threatened, endangered, or candidate species or habitat within the recovery area. No private or public agency action should threaten recovery or result in jeopardy, harassment, or harm to a listed or candidate species.

7) International Trade in Endangered Species The Convention on International Trade in Endangered Species of Wild Fauna and Flora (1973) needs support from the federal government through measures such as restriction of trade with any country repeatedly found to allow the trade of threatened or endangered species through insufficient regulation in a manner found to counteract recovery efforts.

8) Domestic Trade in Endangered Species - No listed or candidate species, or parts thereof, should be imported to, or exported from, the United States of America or its protectorates or traded between states. These provisions should only be preempted for traditional use by Native people of listed species and for scientific and restoration activities where a minor portion (<<10%) of the population(s) is affected.

9) No "Incidental Take" of Endangered Species - Harming of candidate or listed species through "incidental take" should be prohibited because it is considered to be inconsistent with the recovery of these species. Because of the risks posed by incidental take, this provision should be removed in order to decrease the risk that its use poses to listed species. Habitat Conservation Plans can be developed in the absence of incidental take and be used to do as their name suggests, plan for the conservation of ample available habitat for listed species.

10) Ecology and Economics in Planning - There should be no economic considerations or "cost-benefit analyses" associated with listing decisions, critical habitat designation, jeopardy determinations, or recovery plan development and implementation. These decisions are well made when based only on the best scientific information.


Alan Kohn, President,
Society for Integrative and Comparative Biology
Michael Hadfield, Past-President
Society for Integrative and Comparative Biology
James MacMahon, President
Ecological Society of America
Nancy Dengler, President
Botanical Society of America
Alicia Linzey, President
American Society of Mammologists
Doug Dahlman, President
Entomological Society of America
Richard Grosberg, President, and
Western Society of Naturalists,
Mark Denny, Past-President
Western Society of Naturalists
Alan Savitzky, President, and
American Society of Icthyologists and Herpetologists,
Ted Pietsch, Past-President
American Society of Icthyologists and Herpetologists
Robert Hershler, President
American Malacological Union
Diane McKnight, President, and
American Society of Limnology and Oceanography
Tom Malone, Past-President
American Society of Limnology and Oceanography

For more information, or a copy of the full version of this letter, contact the Society for Integrative and Comparative Biology, attn. ESA letter, 401 N. Michigan Ave., Chicago, IL 60611-4267. Phone: 312-527-6697, fax: 312-245-1085, email:

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California Native Plant Society - North Coast Chapter
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Last updated February 28, 1998