Current work in wildlife, rivers, public lands, and climate

Thank you for the opportunity to provide comments on your recently distributed Policy on Genetics in Endangered Species. I applaud your efforts to provide guidance on the use of genetics in endangered species decisions, but I have concerns that the policy could run counter to the purpose of the Endangered Species Act to recover the ecosystems upon which endangered and threatened species depend. It also may contradict our direction to use the best available science in endangered species decisions in some cases.

Your memorandum states genetic discussions during recovery planning “should be limited to reducing or minimizing threats to the species so that the protection of the Act is no longer needed.” It also suggests that recognizing genetic divergence in a recovery plan is only appropriate if that divergence was identified at the time of listing. Finally, you provide direction that preserving unique genetic lineages is inappropriate to require for delisting or downlisting. I can think of several situations where it may be necessary to preserve unique genetic combinations throughout the range of a listed entity in order to reduce risk of extinction and ensure that the species continues to exist in the wild. For this reason, I conclude that a broad application of your policy would conflict with the purposes of the ESA.

Read the Memorandum from Ralph O. Morgenweck, USFWS Regional Director, Region 6 (PDF) 3/11/05