We urge the U.S. Fish and Wildlife Service to delay downlisting the manatee until threats to the species and its habitat are controlled.
Dear Director Ashe:
On January 8, 2016, the U.S. Fish and Wildlife Service (“Service”) published notice of its intention to downlist the West Indian Manatee from endangered to threatened throughout its range. [81 Fed. Reg. 1000.] This action is premature, and we urge the Service to postpone reclassification until the agency can assure ongoing protections and minimization of threats to the species and its habitat.
In making its downlisting determination, the Service has relied heavily on population counts, rather than evaluating the long-term viability of the population as required by the Endangered Species Act. Higher numbers of manatees does not mean that the population has recovered adequately to ensure its survival. In Florida, hundreds of manatees can die from single events including cold snaps and red tide.
The Service has failed to account for ongoing and increasing future threats to Florida manatee survival. In particular, the agency has failed to account for the increased danger to Florida manatees from the loss of both natural and artificial warm water refuges. Expected coal plant closures, anticipated future requirements to cease thermal discharges, reduced spring flows, and the absence of sanctuary protections at many springs leave manatees at risk of future significant population declines. The Service has not determined what level of population growth and subsequent loss are sustainable for Florida manatees although the Core Biological Model predicts future growth followed by population decline. The Service has also not adequately addressed cumulative impacts from continued development, increased vessel use, and ongoing water quality problems that threaten the aquatic habitats on which manatees depend for survival.
The Service must acknowledge that it cannot honor its promise of not reducing manatee protections with downlisting since so many of the current protections are not under its jurisdiction. Speed zones, for example, are primarily a state level protection. The Service must take steps to overlay state protections with federal ones in order to ensure that protections will not be reduced. The Service also needs to commit to not creating rules to allow take or pursuing 4(d) rules to create conservation loopholes. Just days after the downlisting proposal was announced, attempts by groups to weaken manatee protections began.
The Antillean manatee is also affected by development pressures, vessel traffic, and pollution of its habitat. The Service acknowledged in its 12-month finding that population trends are declining or unknown in 84% of the countries where manatees are found. The agency has not provided sufficient data to justify downlisting the Antillean manatee.