The U.S. Fish and Wildlife Service has announced the completion and 
availability of a new draft recovery plan for the northern spotted owl.  One 
threat is emphasized primarily in this recovery plan, and it is a threat 
that was essentially non-existent at the time the species was listed.  The 
barred owl has experienced a long-term range expansion that has brought it 
into virtually all habitat types occupied by spotted owls and now the barred 
owl is considered a threat to the spotted owl.  The primary management 
technique emphasized in the recovery plan is lethal control of barred owls 
over vast area and in large numbers.  Much of this management (lethal 
control) is for the stated purpose of experimenting to see how the 
management might impact the listed species; in other words, the "threat" is 
anecdotal.

Is anyone here aware of a precedent in endangered species protections and 
management in which a competitive species has experienced a huge range 
expansion during the period of listing resulting in a perceived threat to 
the listed species?

I am aware that a year or more ago, a prominent spotted owl species expert 
told me (and stated publicly, I believe) that it would be a practical 
impossibility to kill barred owls sufficiently to protect spotted owls.  And 
yet now that seems to be the priority of the Fish and Widllife Service for 
recovering spotted owls in a vast geographic area.

Does this not constitute a de facto attempted reversal of a natural range 
expansion of a native species?  Does this not mean in reality a permanent 
program of killing barred owls, because if the shotgunning of barred owls is 
brought to an end at some point in time, the expansion of the barred owl 
population and threat to spotted owls will resume, leading to further or 
future endangerment?

Something in the logic of this plan seems unworkable to me because the plan 
only addresses this issue anecdotally, without exploring the long-term 
ramifications of this management strategy, including looking past the 
projected time of delisting of spotted owls.  It seems hard to believe that 
spotted owls and barred owls cannot reach some sort of natural equilibrium 
and the idea of a permanent program of killing barred owls just for being 
barred owls is not something that makes a lot of sense to me, as much as I 
want to see spotted owl recovery.  Is this the best we can do?

This recovery plan, in my view, has other serious weaknesses, but the 
"shotgun management" approach is particularly distasteful to me in view of 
the geographic and temporal scales that would be necessary.


Stan Moore     San Geronimo, CA     [EMAIL PROTECTED]

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