Although the public comment period on the U.S. Fish & Wildlife Service’s proposal to list the Northern Long-Eared Bat under the protection of the Endangered Species Act closed in August, both private and official communications to the Service continue. In early October, a large number of state natural resource agency representatives met in Minneapolis to share their views of the Bat’s actual status and the potential impacts an ESA listing might have on their states’ own resource management and conservation goals. This group, led by the Midwest Association of Fish and Wildlife Agencies, prepared a consensus supplemental comment, dated November 5, which USF&WS agreed to accept into the public comment record, and it even agreed to re-open the public comment process to accept new comments limited to responses to this submission.
This strongly argued letter, (click here), signed by four regional coalitions of state agency leaders, consists of 13 pages of interpretive comments on USF&WS’s evidence for proposing a listing, followed by another 4 pages of literature citations. In essence, the letter:
• reiterates that White-Nose Syndrome is the “primary threat” to the Bat;
• argues that USF&WS’s techniques for monitoring Bat populations or projecting WNS’s spread are inadequate;
• argues that existing, or “normal,” forest management practices adequately protect the Bat during its roosting period;
• proposes that even if USF&WS finds for a “threatened” status, minimally disruptive options exist to protect the Bat within such a finding; and
• proposes that the kind of minimal “takes” of Bat specimens that may occur during normal forest management should not be a cause for concern.
USF&WS is expected to post this comment soon, and FRA will notify members of the protocol for reviewing it and submitting comments on it at that time. Background at this link.