[PCA] FWS and surrogate species

[Addsum-Tony Frates]

I've read some of the FWS literature on this topic, but am wondering  
why it won't just focus on doing its job and administer the ESA (which  
includes listing species and not trying to subvert or delay its own  
listing proposals).

We simply need to protect the ecosystems of threatened and endangered species.

What is being proposed does not sound like modernization to me, but  
more like avoidance and/or becoming significantly side-tracked.

No doubt the identification of a surrogate species could be useful  
under certain circumstances, but I suspect very often not it would not  
even be applicable.


Further, from 2011:

http://calwatercenter.org/images/11_01_14_A_Critical_Assessment_of_the_Use_of_Surrogate_Species_in_Conservation_Planning_paper.pdf

See the end of the abstract:

" . . . conservation biologists demonstrated that the surrogate  
concept is generally unsupported by ecological theory and empirical  
evidence. Recently developed validation procedures may allow for the  
productive use of surrogates in conservation planning, but, used  
without validation, the surrogate species concept is not a reliable  
planning tool."


As with some of the other more recent FWS policies/rules/regulations  
including PECE analysis and the "significant range" policy fiasco, we  
do not seem to be going in the right direction.




Tony Frates
Salt Lake City, Utah