Letter: Northern Long-Eared Bat
October 1, 2014
Dear Secretary Jewell and Director Ashe:
We write to express our concerns with the U.S. Fish and Wildlife Service (FWS) proposal to list the Northern Long-Eared bat as an endangered species. This listing would have a significant impact on industries throughout the upper-Midwest while doing little to address the cause of the Northern Long-Eared bats’ supposed population decline. For this reason, we ask that you refrain from listing the Northern Long-Eared Bat as an endangered species.
FWS contends that the primary threat to the Northern Long-Eared bat’s population is the fungal disease known as White Nose Syndrome (WNS). We share these concerns and support pro-active measures to combat its spread throughout the upper-Midwest. The FWS should continue to focus on improving existing efforts to combat WNS, including use of the Federal Caves Resources Protection Act, the National Environmental Policy Act, the National Plan for Managing White-Nose Syndrome in Bats, and separate programs in 21 states. Additional information on how WNS is transmitted or spread is needed before implementing regulations that will do nothing to control this disease.
Furthermore, the Endangered Species Act requires that an endangered species listing decision be based on the best available science. Yet many concerns remain about the science and methodology used in the proposed listing. Among these concerns are USFWS’s reliance on winter survey data that tend to be unreliable and inaccurate; failure to include summer survey data that shows Northern Long-Eared bat populations increasing in many areas; and use of data from only a small fraction of caves where Northern Long-Eared bats exist.
The FWS itself recognizes that human activities and land management have not had an appreciable effect on the Northern Long-Eared bat. Yet an endangered species listing would likely focus on curtailing all conceivable human-induced impacts. Specifically, the USFWS’s interim draft guidance would put a large amount of upper-Midwest timber off-limits to harvesting from April to October of each year. The guidance also restricts other land management tools, including prescribed burning and herbicide use, that are used protect habitats for rare species. In fact, a listing on the Endangered Species List would place significant burdens on the forest products industry, electric transmission maintenance, agriculture, manufacturing, and land and energy development.
While we support efforts to address the spread of WNS, we believe that an endangered species listing based on incomplete science will not only fail to address the root issues affecting Northern Long-Eared bat populations, but will significantly burden upper-Midwest businesses in the process. We urge you to reconsider this proposed rule and refrain from listing the Northern Long-Eared bat as an endangered species. Finally, should you feel compelled to list the Northern Long-Eared bat as threatened, we urge you to refrain from crafting land management guidelines that would restrict rural economic development or limit forest management and conservation efforts that benefit other forest wildlife.
Sean P. Duffy
Sen. Ron Johnson
Dan Benishek M.D.
Reid J. Ribble
Collin C. Peterson
F. James Sensenbrenner
To view a signed copy of the letter, click 2014.10.01 Final NLEB Letter copy.pdf