pFrom: Friends of Animals, Inc., 777 Post Rd., Darien, Connecticut 06820 US/p
pTo: Paul Henson, State Supervisor, U.S. Fish and Wildlife Service, Oregon Fish and Wildlife Office, 2600 SE 98th Ave., Suite 100, Portland, OR 97266 US/p
pDate: 30 May 2012/p
pOn behalf of our members throughout the United States, please accept this statement in OPPOSITION to the proposals by the U.S. Fish and Wildlife Service to kill OR engage in experimental relocation of the barred owls, OR both. /p
pOur statement has value particularly with regard to two aspects of the call for public comments:/p
p•Social and human value/ethics, including the intrinsic value of spotted and barred owls and human culpability in the presence of barred owls in the West; and /p
p•Effects of the alternatives on visitor use and recreation, and visitor experience, especially in National Parks and Recreation Areas and other recreation sites./p
pThe Fish and Wildlife Service proposes to “experiment” with strategies to remove barred owls (Strix varia) for 3 to 10 years in various areas to determine whether eliminating them is a realistic way to bring back spotted owls (Strix occidentalis caurina). The spotted owls are listed as threatened under the Endangered Species Act. /p
pRemoving the barred owls would require an extermination program on a mass scale by the U.S. Fish and Wildlife Service-which has acknowledged this. We oppose this approach to owl spotted conservation in the strongest terms, and we support the NO ACTION alternative yet observe there are other actions that can help achieve the worthy aim of northern spotted owl protection. /p
pWe do support proposals to increase protected habitat for the Northwest’s owls./p
pOur members are hikers, birdwatchers, environmental writers, photographers, and animal-rights advocates. Many are all of these things. Many decline to eat the products of ranchers, on account of their acute concerns over deforestation and resource-costly methods of feeding our population. The impacts of heavy-handed government-directed eradication projects affect our members’ and supporters’ interests and disappoints our expectations for funding and having a federal government that serves and protects rather than annihilates and panders. Our staff and members are visitors to public lands who appreciate viewing any and all birds acting according to their natures and interacting, whether co-operatively or competitively, with members of their own and other species. We value the spotted owls and their continued survival and the goal of their ultimate ability to thrive; we value equally the barred owls and their individual and collective struggles to adapt to humanity’s overwhelming impacts on their environment. Our experiences as visitors to public lands, especially in National Parks and recreation sites, are embittered by the knowledge that barred owls would be killed and tormented by the proposals at issue./p
pIn our view, the U.S. government should be moving the pressure where it belongs in order to support a variety of owls-including barred owls as well as northern spotted owls-and decline to clear any public lands at the behest of developers and timber businesses. /p
pThough ostensibly proposed in the interest of saving spotted owls, projects to eliminate or move one group of owls will harm both groups. Increasing resentment against barred owls in order to claim action is being taken for spotted owls will mean less attention will be paid to habitat protection, and logging will be resumed in protected spotted owl areas./p
pBarred owls, though their west-coast population is sometimes called invasive, are true owls, native to North America, and closely related to the spotted owls. Barred owls should not be considered a community of invasive species. Since the 1960s, pushed to adapt by human development, barred owls have been expanding their range westward from the eastern United States on their own accord and in harmony with their chosen environment. The two groups of owls are so closely related that they mate. (Notably, this is not a case of domesticated animals escaping or being abandoned into habitat and mating with a free-living community.)/p
pIt is thought, but not certain, that barred owls are a hindrance to the ability of northern spotted owls to thrive in the Pacific Northwest. Northern spotted owls of the pacific coast are particularly vulnerable to habitat decimation because they are old-growth forest specialists. Unlike the barred owls, their future depends on protections for old-growth territory./p
pHuman commerce is responsible for destroying old-growth forestlands-in effect, turning spotted owl habitat into barred owl habitat. Thus, human destruction of old-growth forests allowed or encouraged the barred owl to move westward-some say to the detriment of the spotted owl communities already there. /p
pThe U.S. government has presented the proposals at issue here to suppress the population of barred owls. In other words, the proposal to exterminate barred owls across the Pacific Northwest is part of a wider project in the name of bolstering the northern spotted owls. /p
pstrongWe oppose killing of barred owls/strong/p
pOne section of the U.S. Fish and Wildlife Service proposals involves the outright killing. In March, the Democratic party of Clallam County, Washington went on record against plans to hunt barred owls. (See “a href=”″Clallam Democrats Opposing Owl Plan/a.”) The party’s executive board voted to support a resolution opposing the U.S. Fish Wildlife Service’s proposal to implement plans to hunt hundreds of barred owls yearly. /p
pWith the kind of common-sense thinking that is becoming ever less common, Clallam County Democratic Party leaders indicated their view that waging war on the barred owls is both mean-spirited and unworkable in the long run, for we humans can’t legislate the natural advantages the barred owls have over spotted owls; and nature will take its course./p
pWe think the federal government ought to be able to acknowledge the wisdom in that. We urge the government to focus on, and spend taxpayers’ resources on, protecting habitat so the problems faced by threatened and endangered animals do not worsen, rather than spending money and other resources on projects to eradicate indigenous bird life. Significant perils to the spotted owls’ future include climate change, drought and drought-related fires, habitat loss, the grazing of non-indigenous animals for profit, continued forest thinning and the construction and maintenance of energy transmission lines. Interfering with indigenous and naturalized animals’ lives, as they do their best to adapt with human encroachment, should not be the focus of spotted owl protection./p
pstrongWe oppose relocation as well as killing/strong/p
pWe understand that some groups have supported the U.S. Fish and Wildlife Service’s proposal to relocate some of the barred owls, as an experiment. It is neither feasible nor respectful to think we could just pluck these birds from the place they’ve evolved and raised their young year after year and stick them somewhere else. And the ones left uncaught would still reproduce and fill the vacuum remaining. /p
pstrongOur main concerns about the relocation of some owls are: /strong/p
p•Stress of relocation, including in capture, disorientation, travel, and possible mortality./p
p•Owls in the population who are not moved would still breed and still be subject to the government-imposed animal-control policy./p
p•Neither shooting nor moving barred owls would confront or check the underlying problems, such as logging and deforestation for agribusiness. /p
pIn short, we consider relocation as well as killing inappropriate human interference in the barred owls’ natural interests and adaptations. Bottom line: habitat is the issue. Killing or moving barred owls won’t fix anything. Through the proposals at issue, the federal government is thrusting itself into an expensive and grotesque cycle whereby it would have to remove and to kill barred owls forever to achieve its ostensible aims. The underlying problem remains: logged forests are more hospitable to barred owls than to northern spotted owls./p
pstrongEthical action entails respect for the intrinsic value of spotted and barred owls /strong/p
p”Environmental law, once focused on direct threats to human health, now is concerned with assaults on non-human life,” write Professors Dale D. Goble and Eric T. Freyfogle in the casebook Wildlife Law (2002; preface page v). Ecologists and, in turn, people who make decisions about water and land are questioning the assumption that nature is merely a store of material value. And insofar as it offers material value, they’re suggesting it belongs to members of the bio-community. Environmental law to date would not necessarily contradict this goal. The National Environmental Policy Act of 1969 (P.L. 91-190) “encourages productive and enjoyable harmony between man and his environment.” Productive and enjoyable harmony is not fostered through killing and forcibly removing owls. Nor is this conducive to the interests of our members in enjoying public lands or appreciating our government’s attitudes to animals in their habitat./p
pKilling is immoral, and fails to solve problems in any case because killing barred owls to save northern spotted owls lets logging companies and other development in spotted owl territory off the hook. Timber sales in northern spotted owl territory have not ceased; yet the government wishes to torment endangered-species law by using it to blame and exterminate one type of owl-for its natural conduct-when the root cause is people manipulating the forest. /p
pstrongHuman culpability underlies the presence of barred owls in the West/strong/p
pHuman commerce, as well as industrial, residential and tourism development, and the imposition of forest management techniques have all threatened spotted owls for decades. Now, those same activities are prompting barred owls to adapt and spread west. Amidst all the pro-commerce cheerleading of federal-level government officials, the barred owls are saddled with a terrible burden, which reasonable minds could conclude is a way to appease logging firms and private landowners in Oregon, Washington and California. /p
pThe blame-shifting not only eases pressure where pressure is due-on human commerce-but it also is not necessarily based on reality with regard to the interactions between owl groups. The claim that barred owls overpower spotted owls is based on anecdotal evidence and recently published research. (See, e.g., Press release: U.S. Department of the Interior, U.S. Geological Survey, “High Numbers of Barred Owls Likely in Pacific Northwest Forests” (11 May 2011, stating, “Barred owls may be more abundant in coniferous forests of the Pacific Northwest than previously recognized, according to research published today in the Journal of Wildlife Management [citing J. David Wiens, Robert G. Anthony, and Eric D. Forsman, “Barred owl occupancy surveys within the range of the northern spotted owl” – Journal of Wildlife Management.] The follow-up research is new, arguably interpreted in a result-oriented manner, and not representative of an established body of knowledge. Key funders include the U.S. Fish and Wildlife Service, the National Park Service, U.S. Forest Service, the Bureau of Land Management, and the Oregon State Department of Forestry./p
pstrongFriends of Animals’ Recommendations/strong/p
pWe SUPPORT the no-action option and we OPPOSE capture, we OPPOSE relocation, and we OPPOSE killing of barred owls. a href=”″Internet reference URL summarizing the Alternatives/a: /p
pAlternative 1 proposes subjecting barred owls to lethal removal methods. We OPPOSE Alternative /
Alternative 2 proposes lethal and other methods. We OPPOSE Alternative /
Alternative 3 proposes lethal and other methods. We OPPOSE Alternative /
Alternative 4 proposes lethal and other methods. We OPPOSE Alternative /
Alternative 5 proposes lethal methods. We OPPOSE Alternative /
Alternative 6 proposes lethal and other methods. We OPPOSE Alternative /
Alternative 7 proposes lethal and other methods. We OPPOSE Alternative 7./p
pWe support the no-action option-with additional suggestions. The Fish and Wildlife Service, when framing the various alternative actions, has largely missed the best action, which will involve pro-active confrontation of the commercial problem faced by the owls rather than confronting the owls themselves. Perhaps this is not surprising, given the profit-oriented directions from the highest levels in government. For example, President Obama’s Spotted Owl Memo of 28 February 2012 puts emphasis on protection of commerce rather than the bio-community, and underscores the radical nature of current proposals when stating, “The proposal rejects the traditional view that land managers should take a ‘hands off’ approach to forest habitat in order to promote species health; on-going logging activity may be needed to enhance forest resilience.” As this is the case, it is left to non-governmental organizations to take a stand aligned with the “traditional” and best reading of the U.S. National Environmental Policy Act, the Migratory Bird Treaty Act, as well as U.S. endangered-species law and policy. As a society, our best attitude would be to respect both kinds of owls-their natures and interests. The only way to act accordingly is to protect substantial tracks of un-logged forests./p
pTherefore, in addition to the No-Action alternative:/p
p•The government should consider creating public-service announcements for television and radio outlets, newspapers and regional magazines, and social media that connect our use of resources with pressure on animal life, including spotted and barred owls. Builders should be encouraged to use reclaimed wood and other materials such as recycled industrial and construction materials: concrete made from foundry sand, reclaimed steel beams or recycled asphalt. This would have effects in the short term as well as over time. /p
p•The government should further consider creating public-service announcements that connect human population density with pressure on animal life, including spotted and barred owls. Without curbing human population density, not only will species become extinct, ecological systems will become simpler and less functional. The loss of ecosystem services will harm humans, the environment, and the planet. This is long-term thinking, which is needed now./p
p•The government should protect all remaining old-growth forestlands and place an immediate moratorium on the use and legal transfers of such lands./p
pThe spotted owl population has continued to decline in recent decades because of the loss of old- growth habitat. Yet the Department of the Interior continues to insist that some kinds of logging be allowed in areas designated as spotted owl habitat. Interior Secretary Ken Salazar has recommended “sustainable timber jobs” and harvests in mature forests. these forests because they are also important habitat for spotted owls, marbled murrelets, flying squirrels, red tree voles and many other species that are associated with old-growth forests./p
pstrongConclusion /strong/p
pFor all of the above reasons, we strenuously oppose killing or clearing out barred owls, oppose Alternatives 1-7, and support NO ACTION against barred owls./p