Uncommon Ground


Proposed revisions to US Endangered Species Act regulations

On Monday I pointed out that the US Fish & Wildlife Service and the National Marine Service planned to propose revisions to regulations that affect how the Endangered Species Act is implemented. The proposed changes were published in the Federal Register today. There are three sets of changes. Here are links and the accompanying summary for each:

We, the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) (collectively referred to as the “Services” or “we”), propose to revise portions of our regulations that implement section 4 of the Endangered Species Act of 1973, as amended (Act). The proposed revisions to the regulations clarify, interpret, and implement portions of the Act concerning the procedures and criteria used for listing or removing species from the Lists of Endangered and Threatened Wildlife and Plants and designating critical habitat. We also propose to make multiple technical revisions to update existing sections or to refer appropriately to other sections. https://www.federalregister.gov/documents/2018/07/25/2018-15810/endangered-and-threatened-wildlife-and-plants-revision-of-the-regulations-for-listing-species-and

We, the U.S. Fish and Wildlife Service, propose to revise our regulations extending most of the prohibitions for activities involving endangered species to threatened species. For species already listed as a threatened species, the proposed regulations would not alter the applicable prohibitions. The proposed regulations would require the Service, pursuant to section 4(d) of the Endangered Species Act, to determine what, if any, protective regulations are appropriate for species that the Service in the future determines to be threatened. https://www.federalregister.gov/documents/2018/07/25/2018-15811/endangered-and-threatened-wildlife-and-plants-revision-of-the-regulations-for-prohibitions-to

We, FWS and NMFS (collectively referred to as the “Services” or “we”), propose to amend portions of our regulations that implement section 7 of the Endangered Species Act of 1973, as amended. The Services are proposing these changes to improve and clarify the interagency consultation processes and make them more efficient and consistent. https://www.federalregister.gov/documents/2018/07/25/2018-15812/endangered-and-threatened-wildlife-and-plants-revision-of-regulations-for-interagency-cooperation

The period for public comment ends on 24 September 2018.

Proposed revisions to regulations implementing the US Endangered Species Act

The US Fish & Wildlife Service and the National Marine Fisheries Service are charged with implementing the US Endangered Species Act. On Wednesday, they will publish three proposed rules in the Federal Register that modify existing regulations by which they implement the act. The proposed rules deal specifically with

  • Criteria for listing of species as endangered or threatened and for designation of critical habitat,
  • Aligning the way in which protections to threatened species are applied between USFWS and NMFS, and
  • Changing requirements and procedures associated with interagency cooperation on activities that affect endangered species.

If you are interested in how the Endangered Species Act is implemented in the United States, I urge you to read the proposed changes. If you want to comment on them, you have two options (on or after Wednesday, 25 July):

  1. Go to the Federal eRulemaking Portal (http://www.regulations.gov), enter FWS-HQ-ES-2018-0006 in the search box, click on the “Proposed Rules” link, click on “Comment Now!”, and submit your comment.
  2. Deliver a hard copy of you comments by US mail or hand delivery to
    • Public Comments Processing, Attn: FWS–HQ–ES–2018–0006; U.S. Fish & Wildlife Service, MS: BPHC, 5275 Leesburg Pike, Falls Church, VA 22041–3803
    • National Marine Fisheries Service, Office of Protected Resources, 1315 East West Highway, Silver Spring, MD 20910.

If you submit comments, they will be posted at http://www.regulations.gov.

I expect to review the proposed changes over the next few weeks and to post my comments on each of the proposals here. Then I’ll collect them into a single comment and post them at http://www.regulations.gov. If you read my comments and disagree, please explain how and why you disagree in the comments. Your comments will make my the comments I share with USFWS and NMFS much better.

Saturday afternoon at Trail Wood

OK. This is mildly embarrassing. I moved to Connecticut in 1986, I was one of the co-founders of the Edwin Way Teale Lecture Series on Nature and the Environment in 1996, I’ve read A Naturalist Buys an Old Farm at least half a dozen times, and Trail Wood is less than 30 miles (40 minutes) from my home in Coventry, but it wasn’t until Saturday that I finally visited. It won’t be the last time. I expect to return once or twice a year to the Beaver Pond Trail, to cross Starfield and Firefly Meadow, and to visit the Summerhouse and Writing Cabin.

Black-eyed susan (Rudbeckia hirta) photographed at Trail Wood

A nice patch of black-eyed susan (Rudbeckia hirta) greeted me near the parking area, which is just a short walk from the house at Trail Brook. Rather than following Veery Lane, I turned left and followed the path through Firefly Meadow towards the small pond.

Edwin Way Teale’s writing cabin at Trail Wood

The Writing Cabin is on the southwest shore of the pond. I turned right and followed the northeast shore to Summerhouse. From there I followed a path along the stone wall bordering Woodcock Pasture until it met the Shagbark Hickory Trail.

Spotted wintergreen (Chimaphila maculata) photographed at Trail Wood

I found spotted wintergreen (Chimaphila maculata) along the Shagbark Hickory Trail , which I followed to the Old Colonial Road. From their I followed the Beaver Pond Trail to the edge of the pond.

Beaver Pond at Trail Wood

After sitting for a while on a nice bench at the south end of the pond, I backtracked on the Beaver Pond Trail and followed the Fern Brook trail through Starfield back to the house and then to the parking area. The whole walk was less than a mile and a half, and the total elevation gain was only 55 feet. It was definitely an easy walk, not a hike, but it was very pleasant, and it was nice to spend time on the old farm where Teale spent so much of his time.

So to anyone from UConn (or nearby) who reads this and hasn’t been to Trail Wood yet, take a couple of hours some afternoon, drive to Hampton, and explore. Trail Wood is easy to find, and it’s open from dawn to dusk. It’s a gem in our own backyard. And if you haven’t read A Naturalist Buys an Old Farm, do it now. You’ll enjoy your visit to Trail Wood even more if you do.

Climate change and Pelargonium in South Africa

For more than a decade my colleagues Margaret Rubega and Bob Wyss have co-taught a course to graduate students in science and engineering and undergraduates in Journalism.1 The purpose of the course is to help science students improve their skills in working with journalists and to help journalist increase their skills in interviewing scientists and developing stories from those interviews. One of the projects in this fall’s edition of the course was for the journalism students to interview one of the science graduate students and produce a short video describing the student’s research. Daniela Doncel interviewed Tanisha Williams, a PhD student in EEB whom I co-advise with Carl Schlichting. In addition to interviewing Tanisha, Daniela also interviewed Cindi Jones and me. She assembled a video that explains Tanisha’s work very well. I think Daniela did a very nice job of weaving the disparate interviews into a compelling story, and I think the video looks very good (even though it has me in it). I hope that you agree.


Rediscovering Adonis cyllenea

Adonis cyllenea

Adonis cyllenea – Photographed at the 8th International Alpine Conference, Nottingham, UK. Photo by Todd Boland (from the North American Rock Garden Society)

Adonis cyllenea was described in 1856 from a specimen collected in the Peloponnese Mountains of Greece (http://bit.ly/2xgG1lS). It was thought to be extinct in the wild until 1976 when it was rediscovered (https://en.wikipedia.org/wiki/Adonis_cyllenea). It was recorded in the Giresun province of Turkey in 1867 and was just rediscovered there (http://bit.ly/2vfDPcO). Occasionally, there is good news about plants that were thought to be extinct. Mostly when they disappear, they are gone for good.

Discussing privilege in environmental conservation

I last taught my graduate course in conservation biology in Fall 2015. Holly Brown, my teaching assistant in the course, had to fill in for me a couple of times because of commitments that took me out of town. She designed a creative and powerful exercise for one of the times I was out of town. In written evaluations of the course, almost every student reported that it was eye opening and, quite possibly, the most useful exercise in the course. What was this creative and powerful exercise? Holly’s version of a privilege walk. If you don’t know what that is or you want to know how she used a privilege walk in the context of conservation or both, it’s your lucky day. A paper describing the exercise recently appeared in Conservation Biology. Here’s the citation and a link.

Brown, H.M., A. Kamath, and M. Rubega.  2017.  Facilitating discussions about privilege among future conservation practitioners. Conservation Biology 31:727-730.  doi: 10.1111/cobi.12810

Science, doubt, and the need for action

From Merchants of Doubt, by Naomi Oreskes and Erik M. Conway:

All scientific work is incomplete—whether it be observational or experimental. All scientific work is liable to be upset or modified by advancing knowledge. That does not confer upon us a freedom to ignore the knowledge we already have, to postpone action that it appears to demand at a given time. Who knows, asks Robert Browning, but the world may end tonight? True, but on available evidence most of us make ready to commute on the 8:30 next day.

“A demand for scientific proof is always a formula for inaction and delay, and usually the first reaction of the guilty. The proper basis for such decisions is, of course, quite simply that which is reasonable in the circumstances.” Or as Bill Nierenberg put it in a candid moment, “You just know in your heart that you can’t throw 25 million tons a year of sulfates into the Northeast and not expect some … consequences.”


Barnes & Noble

A thought on science and public policy

From Merchants of Doubt, by Naomi Oreskes and Erik M. Conway:

if science is about studying the world as it actually is—rather than as we wish it to be—then science will always have the potential to unsettle the status quo. As an independent source of authority and knowledge, science has always had the capacity to challenge ruling powers’ ability to control people by controlling their beliefs. Indeed, it has the power to challenge anyone who wishes to preserve, protect, or defend the status quo.


Barnes & Noble

The debate about new conservation and alternatives

I mentioned a couple of weeks ago that I fall roughly into the camp of New Conservationists. When I took the Future of Conservation survey, I scored relatively strongly on  “means of improving human welfare” and slightly positive on “willingness to embrace markets and capitalism.” In catching up on my reading this weekend, I discovered that the folks behind the survey also surveyed attendees at the 2015 International Congress of Conservation Biology. Here’s the abstract of the paper describing what they found (full citation and link below):

A vibrant debate about the future direction of biodiversity conservation centers on the merits of the so-called new conservation. Proponents of the new conservation advocate a series of positions on key conservation ideas, such as the importance of human-dominated landscapes and conservation’s engagement with capitalism. These have been fiercely contested in a debate dominated by a few high-profile individuals, and so far there has been no empirical exploration of existing perspectives on these issues among a wider community of conservationists. We used Q methodology to examine empirically perspectives on the new conservation held by attendees at the 2015 International Congress for Conservation Biology (ICCB). Although we identified a consensus on several key issues, 3 distinct positions emerged: in favor of conservation to benefit people but opposed to links with capitalism and corporations, in favor of biocentric approaches but with less emphasis on wilderness protection than prominent opponents of new conservation, and in favor of the published new conservation perspective but with less emphasis on increasing human well-being as a goal of conservation. Our results revealed differences between the debate on the new conservation in the literature and views held within a wider, but still limited, conservation community and demonstrated the existence of at least one viewpoint (in favor of conservation to benefit people but opposed to links with capitalism and corporations) that is almost absent from the published debate. We hope the fuller understanding we present of the variety of views that exist but have not yet been heard, will improve the quality and tone of debates on the subject.

Holmes, G., C. Sandbrook, and J.A. Fisher. 2017. Understanding conservationists’ perspectives on the new-conservation debate. Conservation Biology 31:353–363  doi: 10.1111/cobi.12811