Endangered Species Act Not Using Peer Reviewed Science
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Science is integral to the Endangered Species Act. Considering scientific data are used to back up or reject the protection of a species nether the Endangered Species Act (ESA), the validity—or perceived validity—of the data used in those decisions is primal to the law's effectiveness.
Once a species is listed as endangered or threatened, the U.Southward. Fish and Wildlife Service imposes regulations to protect those species. These regulations may include a prohibition against taking listed species, which directly affects private belongings use and restrictions on federally permitted or funded actions. Because of the social, environmental, and economic impacts of Endangered Species Act decisions, the adequacy of the scientific discipline supporting Endangered Species Act decisions is often debated.
HIGHLIGHTS
Groundwork
The National Academy of Sciences defines science as "a particular manner of knowing about the globe. In science, explanations are limited to those based on observations and experiments that can exist substantiated by other scientists. Explanations that cannot be based on empirical evidence are not a function of science."
According to the Congressional Research Service, the employ of science in the Endangered Species Act (ESA) involves "complexity, uncertainty, and gamble." Under the ESA, the federal government must list species as endangered or threatened based on "the best scientific and commercial data bachelor" at the time the government makes the decision. The scientific basis of Endangered Species Act decisions is important because the act gives potent legal tools to the federal government for the protection of listed species, including regulations on land use and federally authorized projects. Science must as well place which species are in need of federal protection and how severe the threats to a species are.
How science is used in the ESA
Scientific discipline is used to listing species, to consult on federally permitted projects, to designate critical habitat for listed species, and to develop recovery plans. Federal scientists tin employ informal information, such as oral or anecdotal information, besides as peer-reviewed scientific studies as long as the information represents "the all-time scientific and commercial information available." At diverse points, business organization groups, environmental organizations, holding rights groups, and other interests have criticized the scientific basis of sure Endangered Species Act decisions. The reasons for the criticism vary depending on the political agenda of these groups, which are often opposed to each other.
Biologists and researchers decide whether a species is endangered or threatened based on any of the following factors:[2]
" |
| " |
—U.S. Fish and Wildlife Service |
Federal endangered species scientists work with staff from other federal agencies, state natural resource departments, academia, conservation groups, and other private groups to identify which species could exist listed. If the U.S. Fish and Wildlife Service receives a petition to listing a species, the agency often requests scientific information to supplement its own data. Fish and Wild animals Service field offices partner with country and local scientists to bear surveys determining the presence and distribution of a species within a certain expanse.[2]
One time a species is listed as endangered, the U.S. Fish and Wildlife Service must utilise the full protections of the Endangered Species Act. These protections include the prohibition of taking a listed species. To "take" a species means "to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in whatever such conduct." Since the 1990s, the service has expanded the definition of "taking" a species to include "pregnant habitat modification or deposition that actually kills or injures wild animals." The Fish and Wild animals Service has discretion only in regulating the taking of threatened species and in designating disquisitional habitat.[2]
Critics of the police'south implementation take argued that the Fish and Wildlife Service should exist granted more discretion to apply dissimilar kinds of protection on a per-species basis. The list process would remain unchanged, and the service would decide which species deserve certain kinds of protection. Proponents of this view accept argued that the science supporting the listing of a species would become less politicized because the listing would no longer involve the Endangered Species Act's full regulatory controls. Those who support listing a species in guild to implement potent regulatory controls would have less of an incentive to back up listing the species if the full regulatory controls are not guaranteed. Instead, the decision to listing a species would include not solely scientific concerns but economic and social concerns. Proponents of this view accept argued that the Endangered Species Deed equally originally written cannot guarantee a completely scientific approach to listing species considering such an arroyo must necessarily include economical, social, and other not-scientific factors. Farther, these proponents argue that the listing process should reflect those non-scientific factors.[4]
Science and policy
Science and policy are distinct simply often intertwined. In the context of the Endangered Species Act's implementation, scientists offering a hypothesis about the futurity of a species and its surroundings, while policymakers decide whether dedicating resource to protect that species is expert policy. While scientific data helps approximate whether a species' chance of survival is at risk, policy tries to determine whether conservation is a worthwhile goal and what conservation measures may exist appropriate in light of their costs and trade-offs. Policy decisions reflect the differing political, economic, scientific, and environmental views and goals of scientists and policymakers, while scientific information is supported by empirical facts and repeatable observation. Meanwhile, the Endangered Species Act mandates that listing a species be made solely on scientific data. Equally a outcome, the U.S. Fish and Wildlife Service lacks discretion in determining the protections for endangered species if the best scientific data back up the listing of that species. The service has discretion in considering economic and social impacts only in the designation of critical habitat. When a species is federally listed, property use and federally permitted activities are regulated to avoid causing damage to a listed species. Consequently, the use of science and its event on policy decisions will ultimately affect private individuals and groups.
Problems of science
In that location are applied problems with the use of scientific information, making the determination to list or delist a species difficult. Sometimes the available scientific data are not all-encompassing enough or the fourth dimension and costs of acquiring more than data are too high. Some endangered species are difficult to locate, and thus little information exist near them or few sufficient experts can provide peer reviews. Moreover, the impartiality of scientists tin can be questioned if economic factors are involved. For example, research funding or employment could influence a decision to list a species.[5]
Below are some of the common applied issues associated with the utilise of science to determine endangered species policy:
- The distribution of a species is sometimes poorly known because the species is rare. Moreover, fourth dimension and resources may not be bachelor to engage in surveys or monitor a species.
- A subspecies' taxonomic status is a disputable effect. Taxonomy refers to the classification of species, and the biological distinction between "subspecies," which is a classification included within the Endangered Species Act's definition of species, is strongly debated among scientists because the category of subspecies is often subjective. As a result, the argue has centered on how to classify subspecies based on different categories, such as geography or genetic differentiation.
- Some species may reappear on their ain in an area they once occupied, raising questions almost whether land use restrictions should use in that area.
- Political and other non-scientific factors influence list decisions in add-on to the scientific data.
- Landowners have an incentive to continue scientists from conducting inquiry on their individual land out of concern that property regulations would ensue if a rare animate being or plant species was found. According to a 2003 study from the journal Conservation Biology, many landowners refused to allow scientists onto their land to research a rare mouse population out of concern that holding restrictions would result if a mouse were institute.[5]
Major issues
The science behind Endangered Species Act decisions—including the prohibition on
Declared political interference with scientific data
Charges of political interference with scientific data emerged during the George Westward. Bush administration. The deputy banana secretary for Fish and Wildlife and Parks was criticized for interfering with critical habitat designations for listed species for non-scientific reasons. The environmental group Center for Biological Diversity defendant the official—Julie MacDonald—of overruling the opinions of scientists at the U.Southward. Fish and Wild fauna Service. Specifically, MacDonald was critical of designating critical habitat for listed species. Disquisitional habitats are specific geographic areas, whether occupied past listed species or not, that are determined to be essential for the conservation and management of listed species.[six]
The standards for critical habitat designation for occupied and unoccupied habitat are different under the Endangered Species Act. The standard for designating occupied habitat requires designating areas that contain the physical and biological features essential to the species' conservation. The standard for designating unoccupied habitat requires that the area itself be considered essential to the species' conservation. The standard for designating unoccupied critical habitat is considered more enervating than the standard for occupied habitat. Critics of the designation process, such as MacDonald, have argued that the U.S. Fish and Wildlife Service has often taken more broader, less scientifically rigorous arroyo to designating unoccupied disquisitional habitat that ignores the economical impact of the designations. Holding rights groups have argued that the designation process should be more rigorous in basing certain designations on adequate scientific information, while ecology groups have argued that the designation process does not become far enough in establishing disquisitional habitats for the protection of species. Meanwhile, the Spousal relationship of Concerned Scientists, a nonprofit political advocacy organization, said MacDonald's activities represented "specific instances where endangered species data has been compromised," while sure staff complained that their scientific conclusions were "overruled or disparaged" past MacDonald. In March 2007, the inspector full general of the Interior Department institute that MacDonald broke federal rules by leaking non-public federal data near endangered species to private nonprofit groups, such equally the California Farm Bureau Federation and the Pacific Legal Foundation.[6] [7] [8] [9] [ten] [11]
In 2009, the Centre for Biological Diversity formally apologized to MacDonald every bit function of a settlement of a defamation suit filed by MacDonald. The grouping accused MacDonald of being personally responsible for what it considered an "illegal" decision in 2003 to remove the Sacramento splittail fish from the list of threatened species during the Bush assistants. MacDonald and scientists argued that the all-time scientific data available did not back up list the fish as threatened. The U.Due south. Fish and Wildlife Service nether the Obama administration agreed with MacDonald and scientists in 2010 that the fish did not warrant Endangered Species Act protection and removed the fish from the federal listing. The center posted an apology on its website in which executive manager Kieran Suckling said that the center "retracts and apologizes for any statements ... that you lot alone were personally responsible for what CBD asserts was the authorities'southward illegal splittail conclusion." Co-ordinate to Suckling, the center's comments "were not intended to impugn" MacDonald's character.[12]
Adoption of flawed scientific opinions
The federal government may rely on scientific opinions that are later on determined to be flawed. Erroneous scientific opinions can also outcome in restrictions on private individuals and local state employ, resulting in economic costs for residents. In 2001, the U.S. Fish and Wildlife Service recommended higher h2o levels in the Klamath River Basin, a region along the California-Oregon border, to protect federally listed fish species. Every bit a result, not plenty water was available to gargle the region's farms, and h2o users estimated that the surrounding economy would lose between $106.seven million and $222 1000000 for the 2001 crop twelvemonth from water cuts. A May 2001 study from Oregon State University'south Agricultural and Resources Economics Section found that water restrictions would reduce personal income in the Klamath area by $seventy million and reduce total gross sales in the area by $157 one thousand thousand in 2001 alone. Klamath Basin farmers argued that the irrigation water cuts benefiting the species "were not scientifically justifiable." The U.S. Secretary of the Interior recruited the National Enquiry Council (NRC), a part of the U.S. National Academy of Sciences, to review the science.
The NRC found that at that place was no sound scientific basis to go along more lake water for the listed species. Specifically, the NRC did not find a link between low lake levels and fish mortality. Moreover, although more than water might have benefited the fishes, there was no show that more lake water would have helped the federally listed species recover faster. Although the Endangered Species Act requires agencies to use the "best scientific data bachelor" to avoid jeopardizing listed species, the scientific reports were written without extensive monitoring or scientific experimentation to justify them, according to the Congressional Enquiry Service.[13]
Disputed taxonomy
Taxonomy refers to the classification of species, and the biological distinction between "subspecies," which is a classification included within the Endangered Species Act's definition of species, is strongly debated among scientists considering the category of subspecies is typically subjective. As a result, the argue has centered on how to allocate subspecies based on different categories, such every bit geography or genetic differentiation. Some of the federal government's taxonomic status of subspecies accept been criticized equally arbitrary or based on debatable scientific discipline—the coastal California gnatcatcher and the gray wolf, for example.
California gnatcatcher
The littoral California gnatcatcher example demonstrates that the U.S. Fish and Wild animals Service sometimes does not contrary its listing decisions even if new scientific information related to the taxonomic nomenclature of certain subspecies supports delisting the species. The U.S. Fish and Wildlife Service listed the coastal California gnatcatcher in 1993 as a threatened species. Since then, the service has received petitions to delist the species due to emerging scientific testify showing that the gnatcatcher was the aforementioned bird as the gnatcatcher institute in Baja California, Mexico. A scientist at the University of Minnesota performed a nuclear DNA analysis showing the similarity between the birds. As a event, the petition stated that the Fish and Wildlife Service erred in classifying the littoral California gnatcatcher as a subspecies since the millions of gnatcatchers inhabiting Baja California demonstrated that the gnatcatcher did non warrant protection under the Endangered Species Act. Further, the petition cited the U.S. Fish and Wildlife Service'southward guess that the listing of the gnatcatcher had approximately $1 billion in negative economic impacts affecting private landowners and individuals. In December 2014, the service announced that the petition to delist the coastal California gnatcatcher independent substantial scientific data suggesting that the bird should exist delisted. Every bit of November 2016, the species remained listed as a threatened species.[xiv] [15]
Gray wolf
The proposed delisting of the greyness wolf in 2013 was criticized for existence based on debatable scientific conclusions. In June 2013, the U.S. Fish and Wildlife Service proposed removing gray wolves from the federal listing based on the scientific conclusions of an October 2012 paper called "An Account of the Taxonomy of North American Wolves From Morphological and Genetic Analyses." The newspaper—written past Fish and Wild fauna Service biologists and published in the service's official journal N American Fauna—concluded that populations of wolves in eastern North America were a distinct species from the gray wolf species establish in western Northward America. If the eastern wolves could not be classified as gray wolves, the paper suggested, and then the greyness wolves were closer to recovery than previously expected, and thus could be proposed for delisting. If the eastern wolves were similar to gray wolves, and so the question of whether the gray wolf species had recovered remained open up.[16] [17]
The latter argument was made in a February 2014 contained written report by the National Center for Ecological Analysis and Synthesis, which challenged the Fish and Wild animals Service'due south scientific conclusion that eastern wolves were distinct from western grayness wolves. They argued that the Fish and Wild animals Service'due south conclusion was not agreed upon by wild animals biologists. Responding to these challenges, the Fish and Wildlife Service reopened the public comment process on its gray wolf delisting proposal in Feb 2014. "We are incorporating the peer review report into the public tape for the proposed rulemaking, and accordingly, reopening the public annotate menstruation to provide the public with the opportunity for input," said Fish and Wild animals Service director Dan Ashe. The Center for Biological Diversity, which opposed the grayness wolf's proposed delisting in 2013, endorsed the conclusions of the February 2014 independent report. "The nation's pinnacle wolf scientists today confirmed what we and millions of Americans have been saying for months: The task of wolf recovery is far from consummate. ... This peer review is a major blow to the Obama administration'south highly political effort to prematurely remove protections for wolves."[16] [17]
Public availability of data
-
- Run across also: Transparency and the Endangered Species Act
Federal guidelines exercise not require the public release of the raw scientific data used in Endangered Species Deed decisions. The studies that are publicly available ordinarily contain summaries of the scientific information, and the federal government is non required to release the raw data. Critics argue that this scenario allows policy decisions to be made without an independent or critical analysis of all the information, while others argue that raw data should be handled only past relevant experts so as to discourage misuse or political interference. Furthermore, others argue that making some data publicly bachelor would reveal the location of vulnerable species and encourage poaching or habitat devastation.[18]
According to a quondam science advisor to the U.S. Department of the Interior, if the scientific data cannot exist tested past other scientists or if the scientific results cannot be reproduced by other scientists, so the public cannot know whether policy decisions are based on well-tested scientific information or based solely on the opinions of a few scientists. An opinion may or may not pass more rigorous scientific review.[18] [19]
Meanwhile, supporters of current policy debate that requiring the publication of raw data would increase the Fish and Wild fauna Service's unfunded liabilities or encourage the misuse of data by those who are non experts in the relevant fields. The data may also comprise the location of some endangered species, making them vulnerable to collecting or poaching. Furthermore, scientists may be less likely to contribute their research to the federal regime if their unpublished data or any data that have non been peer-reviewed were released publicly.[20] [21]
In response, critics argued that the public release of data would be "neither difficult, nor costly," co-ordinate to a old science advisor to the U.S. Department of the Interior. The Fish and Wild fauna Service could exist required to archive data in online, library, and/or museum databases before the data are used to back up policy decisions. Peer reviewers would and so have greater access to information, which would encourage more scientific debate. To prevent the threat of poaching, narrow exceptions could be made to protect more vulnerable species while keeping the majority of scientific data publicly available. In 2014, Rep. Doc Hastings (R) introduced the Endangered Species Transparency and Reasonableness Act in Congress. The nib would crave the Fish and Wild fauna Service to publicize the underlying information of a listing.[22]
Global warming and climate alter
An emerging policy event is the intersection betwixt Endangered Species Act protections and global warming and potential human being-fabricated climate change. Some environmental activists have argued that listing a species as endangered or threatened should take into account the potential futurity effects of human-caused emissions of carbon dioxide, a colorless, odorless, and not-harmful gas that is linked to human being-caused global warming by some scientists. These effects would take place decades in the future, and thus there is strong scientific debate over the appropriateness of listing species based on these potential effects. In 2008, the U.S. Fish and Wildlife Service listed the polar bear equally threatened based on climate change and population models suggesting the species' time to come turn down caused by melting sea ice. This determination, the first time a listing was based on the effects of global warming, came despite the acquit's 2008 population, which totaled 25,000 bears, which was the highest number in recorded history at the fourth dimension. Critics of the decision take argued that the listing effectively changed the Endangered Species Deed to allow for any species with habitat at gamble could be listed without scientific evidence showing that the species itself is in decline.[23]
In October 2016, the United states Court of Appeals for the Ninth Circuit upheld a decision past the National Marine Fisheries Service to listing a population of disguised seals. The determination cited computer climate models from the Un' Intergovernmental Panel on Climatic change predicting that the seal would decline substantially earlier the twelvemonth 2095 due to reduced sea ice. The courtroom institute that the federal agency "need not expect until a species' habitat is destroyed to determine that habitat loss may facilitate extinction." The ruling reversed a commune court in Alaska, which ruled that the agency relied on theorize and speculation to list the species. Some environmental groups supported the ruling, arguing that the ruling should spur the listing of other species, such as salmon and other fish potentially affected by droughts or warming rivers. Further, these groups argued that federal scientists should take into account climate models and other predictions of potential species decline when listing a species. Belongings rights and business organization groups opposed the ruling, arguing that the conclusion sets a precedent for listing species despite little to no testify that the species are currently threatened or endangered. Further, these groups argued that the decisions would be used to limit economic activity, such as logging and mining, despite no present threats to a species.[24] [25]
Disquisitional habitat
Decisions regarding the designation of disquisitional habitat, which are specific geographic areas that are determined to be essential for the conservation and management of listed species, are frequently debated on scientific grounds. For example, the U.S. Fish and Wildlife Service designated one,554 acres of individual timber land in Louisiana in 2012 for the dusky gopher frog, an amphibian found in the southern United States. The service argued that it could regulate the land until information technology became usable and accessible for the frog'south conservation. Critics of the decision argued that the land did non contain the concrete and biological characteristics needed for the frog'southward survival as required past the Endangered Species Act. Further, the designation was estimated to price private landowners approximately $33.9 million in lost profit from potential timber production. The designation was challenged in the Us Court of Appeals for the 5th Circuit, which ruled in favor of the Fish and Wild animals Service by a two-to-one vote. The court majority agreed with the service'southward conclusion that the agency can designate areas as critical habitat fifty-fifty if the areas do not qualify every bit disquisitional habitat, would non serve as disquisitional habitat in the future, and are unoccupied past the species. By contrast, the dissenting gauge, calling the ruling "unprecedented and sweeping," argued that there was no prove suggesting that the country could become essential the frog's conservation and that the areas did non encounter the statutory definition of critical habitat.[26] [27]
Proposed reforms
Several scientists take recommended improving or reforming how science is used to implement the Endangered Species Act.
Independent peer review of listing
Some have argued that the science behind the decisions to listing a species should exist more carefully scrutinized. To improve the listing process, some scientists have suggested that a peer review system should be administered independently of the U.Southward. Fish and Wildlife Service. The reviews would focus on whether the available science is enough to support a listing decision.[28]
Landowner compensation
Some property rights advocates have favored compensation to landowners for the cost of Endangered Species Human action land use regulations. Compensating landowners whose land is unavailable for development due to species conservation would ensure that the benefits of species conservation would be paid by the public equally a whole and non a select few. According to property rights advocates, the U.South. Constitution reflects the principle that individuals should not pay a disproportionate amount in exchange for a public benefit. These advocates have argued that compensation would also reduce the politicization of Endangered Species Human activity decisions. Individuals who oppose listing a species because their country would be devalued would no longer have an incentive to politicize the science on the listing because they would be compensated. Farther, the compensation would put a more accurate toll on land utilise regulations, give landowners an incentive to allow scientists to conduct inquiry on their property, and provide landowners with the incentive to go on their property hospitable to potentially endangered species.[4]
Science-based listing organisation
The Endangered Species Act requires that any petition to list a species exist addressed past the Fish and Wildlife Service inside 12 months. Critics of this organisation have argued that the deadline pressures the service to have insufficient scientific data or focus more time and resources on a petition rather than on a species already listed. A backlog of listing petitions then accumulates, which permits private groups to sue the government for failing to respond to the petitions. Co-ordinate to some, a "science-based priority system" would let field scientists to interact more than with the public and to make the listing decisions without concern for legal deadlines.[28]
Brand data publicly available
Some scientists have argued that scientific information and decisions should exist available to Congress and the public. Scientists and researchers, they say, should be immune to share their piece of work publicly even if some research is controversial or could affect federal policy. Furthermore, others have argued that "whistleblowers" who expose efforts "to alter or suppress research or technical information" should be protected from retaliation. In 2014, Rep. Medico Hastings (R) introduced the Endangered Species Transparency and Reasonableness Act, which would require the Fish and Wild fauna Service to publicize the underlying data of a listing.[29]
Encourage more than participation by scientists
Some have argued that scientists and researchers should take the right to review, meliorate, and/or comment publicly about all federal documents that rely on their enquiry. These scientists would exist identified equally authors or contributors and be able to represent their scientific opinion in public. While non-scientist federal employees may edit these documents, scientists would have the right to the final review to ensure scientific integrity is maintained.[29]
Political context
Different groups react differently to Endangered Species Act decisions depending on their policy goals and political calendar. Those who face potential economic loss due to the economical touch on of listing species on private holding employ will fence that the federal regime should exist certain of a species' presence and threatened status before it is listed, also making certain that the species is protected no longer than is necessary or prudent. These groups tend to exist critical of the Endangered Species Act and its enforcement. Those involved in some scientific or environmental organizations will argue that the federal government should footstep in and protect species to avoid the irreversible extinction of species and to safeguard biodiversity, even if complete scientific data is unavailable. These groups tend to exist Endangered Species Act advocates.
The relationship between science and politics is an ongoing debate. Many groups on the left and the correct have criticized what is chosen the "politicization" of science. This politicization can include the manipulation of scientific discipline for political reasons; the selective interpretation of scientific information in support of political, economic, and environmental goals; and the fashion in which political decisions are disguised equally science. Both ecology and property rights groups have argued that science has been misused to support political decisions. Further, environmental and property rights groups exercise not necessarily marshal with the politics of a particular presidential administration. For example, pro-Endangered Species Human activity ecology groups and property rights groups take criticized actions during both the George West. Bush and the Barack Obama administrations. Environmental groups have sometimes argued that decisions by the Bush assistants were based on political considerations and non scientific data. These groups have also characterized decisions past the Obama administration, such equally the decision not to list the sage bickering, as unsupported by scientific information. Similarly, property rights groups take criticized actions taken during the Bush administration, including the decision to list the polar deport as threatened and the conclusion to limit water usage by farmers and municipalities in gild to conserve the delta smelt. These groups argued that the polar comport decision was based on speculation and non scientific data and that the water usage limits would harm farmers and individuals and at the aforementioned time do little to conserve the delta smelt.[thirty] [31]
Democrats
Democrats have by and large supported the Endangered Species Human activity as an constructive tool to prevent the extinction of species. The party has generally opposed legislative changes to the way the law is written or implemented, arguing that the Endangered Species Act is working as it was designed. Furthermore, Democrats have argued that the law's requirement that Endangered Species Human action decisions to be fabricated based on the "all-time scientific and commercial information bachelor" has been implemented successfully and does non require revision. Congressional Democrats have largely opposed Republican-led legislative proposals that would crave the federal government to use scientific data submitted past states and local governments. Democrats have also opposed a Republican-led proposal assuasive land and congressional consent before species are listed or delisted, arguing that such a proposal would undermine the use of science.[32] [33]
Republicans
Though Republicans have supported protection for species threatened with global extinction, Republicans have more often than not argued that the Endangered Species Deed has not been effective at achieving this goal. Republicans take argued that the police force has been often used to pursue policy goals, and that Endangered Species Act decisions have not been based upon "sound science." Furthermore, Republicans take contended that Endangered Species Deed decisions take non been balanced with the costs of compliance and private property rights. Congressional Republicans accept introduced proposals requiring that the scientific data used to determine that certain species is endangered be made publicly available. Another proposal would require that the federal government take into business relationship the scientific data submitted past states and local governments. Republicans have argued these proposals would increase transparency and improve the federal regime'south use of science.[34] [35]
See too
- Endangered Species Human action
- Implementation of the Endangered Species Act
- U.Southward. Fish and Wild animals Service
- Endangered species
External links
- U.South. Fish and Wildlife Service website
- U.S. National Oceanic and Atmospheric Service
Footnotes
- ↑ two.0 two.i 2.2 U.S. Fish and Wildlife Service, "Listing a Species as Threatened or Endangered," accessed November thirteen, 2015
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 4.0 four.1 Environmental Law and Policy Journal, "The Endangered Species Human action at 40: A Tale of Radicalization, Politicization, Bureaucratization, and Senescence," July 25, 2014
- ↑ v.0 5.1 U.Southward. House Committee on Science, "Testimony of Jonathan H. Adler on 'The Endangered Species Act: Reviewing the Nexus of Science and Policy,'" October 13, 2011
- ↑ half-dozen.0 6.1 The New York Times, "Written report Says Interior Official Overrode Work of Scientists," March 29, 2007
- ↑ Associated Press, "Report: Interior official blasted for twisting environmental data," March 29, 2007
- ↑ Washington Post, "Bush-league Appointee Said to Reject Advice on Endangered Species," October thirty, 2006
- ↑ U.S. House Natural Resources Commission, "Testimony of Francesca T. Grifo, Senior Scientist with the Marriage of Concern Scientists Scientific Integrity Program," May 9, 2007
- ↑ The New York Times, "Report Says Interior Official Overrode Work of Scientists," March 29, 2007
- ↑ Associated Printing, "Report: Interior official blasted for twisting environmental information," March 29, 2007
- ↑ Ventura County Star, "Ex-Bush official: Obama got information technology right on Calif fish," October seven, 2010
- ↑ Cite mistake: Invalid
<ref>
tag; no text was provided for refs namedklamath
- ↑ Pacific Legal Foundation, "Petition to delist coastal California gnatcatcher filed," June eleven, 2014
- ↑ Pacific Legal Foundation, "Petition of the Center for Ecology Science, Accuracy and Reliability; Coalition of Labor, Agriculture, and Business concern; Property Owners Association of Riverside County; National Association of Habitation Builders; and the California Building Manufacture Association to Remove the Coastal California Gnatcatcher from the List of Threatened Species under the Endangered Species Human action," accessed November 16, 2016
- ↑ 16.0 xvi.ane KCET.org, "Scientists Call B.S. -- Bad Science, That Is -- on Wolf Delisting," Feb 7, 2014
- ↑ 17.0 17.ane Slate, "Wolves May Be Losing a Nasty Political Battle," February 21, 2014
- ↑ xviii.0 18.1 U.S. Business firm Natural Resource Committee, "Testimony of Rob Roy Ramey, Ii., Ph.D., on 'Transparency and Audio Science Gone Extinct?'" August i, 2013
- ↑ Union of Concerned Scientists, "Your Handy Guide to Attacks on How the Endangered Species Act Uses Science," May vi, 2015
- ↑ Defenders of Wildlife, "Endangered Species Act 101," accessed September 17, 2015
- ↑ Spousal relationship of Concerned Scientists, "Your Handy Guide to Attacks on How the Endangered Species Human activity Uses Science," May half dozen, 2015
- ↑ U.S. Firm of Representatives, "Rob Roy Ramey 2, Ph.D. Testimony Earlier the Commission on Resources, United states of america Business firm of Representatives, 113th Congress Oversight Hearing," August ane, 2013
- ↑ Pacific Legal Foundation, "Hard questions about polar carry listing," September 27, 2013
- ↑ Sacramento Bee, "Climate-change ruling for Arctic seals has ramifications across U.S., California, "October 25, 2016
- ↑ Pacific Legal Foundation, "Global warming and bearded seals," Oct 26, 2016
- ↑ Pacific Legal Foundation, "'Critical habitat' decree opens the way for limitless federal land grabs," accessed November xvi, 2016
- ↑ United States Court of Appeals for the fifth Excursion, "Markle Interests, LLC v. U.S. Fish and Wildlife Service," accessed November 16, 2016
- ↑ 28.0 28.i U.Southward. House Committee on Science, "Testimony of Neal Wilkins, Ph.D., on 'The Endangered Species Act: Reviewing the Nexus of Science and Policy,'" Oct xiii, 2011
- ↑ 29.0 29.1 U.S. House Committee on Science, "Testimony of Francesca T. Grifo, Ph.D., on 'The Endangered Species Act: Reviewing the Nexus of Science and Policy,'" Oct 13, 2011
- ↑ Pacific Legal Foundation, "The delta smelt's dirty piddling hole-and-corner," May 26, 2009
- ↑ Pacific Legal Foundation, "PLF Announces Polar Deport Listing Claiming," October 2, 2008
- ↑ U.S. House Natural Resources Committee Democrats, "Preventing Extinction: A Potent Endangered Species Act," accessed August 23, 2016
- ↑ Daily Kos, "The Endangered Endangered Species Act; A Call to Action," accessed August 23, 2016
- ↑ The Loma, "GOP plots new course on Endangered Species Act reform," May 17, 2015
- ↑ CBS News, "GOP to suggest changing Endangered Species Deed," Feb 4, 2014
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