December 29, 2009
The HSUS, HSI Comment on Polar Bear Critical Habitat Designation
WASHINGTON — The Humane Society of the United States/Humane Society International have submitted a letter praising the U.S. Fish and Wildlife Service for its actions to protect polar bears by designating critical habitat for the species, but said more needs to be done. The agency proposes designating more than 200,000 square miles of Alaska's coastal areas as critical habitat for the polar bear, which is listed as threatened under the Endangered Species Act.* The comment period for this proposal closed on Dec. 28.
The HSUS/HSI letter makes three principal recommendations to strengthen the proposal. First, it urges the Service to expand the proposed critical habitat boundaries to include 100 percent of known and potential denning areas in Alaska, especially on the western coast of Alaska and further inland along the northern border of Alaska. Polar bear females build snow dens, mostly on land, to protect their cubs in the first vulnerable months of their lives. Reliable and undisturbed denning habitat is vitally important to cub survival.
Secondly, the HSUS/HSI letter recommends that the proposed critical habitat boundary for sea ice habitat, which currently extends only to the edge of the continental shelf, be extended some distance past this edge on the northern coast, to provide the bears with a buffer zone of protection. Sea ice is essential to polar bears as a platform for hunting seals and traveling across their range.
And third, the letter rejects the Service's conclusion that "the underlying causes of climate change" are "beyond the scope" of the ESA, a conclusion with no basis in law. The proposed designation does address proximate impacts of oil and gas related activities in the Arctic — for example, oil spills and disturbance — but resolutely refuses to address the ultimate connection between the burning of fossil fuels and climate change, which reduces the polar bear's sea ice habitat.
"The HSUS/HSI considers the U.S. government to be a leader in polar bear protection. However, the United States also needs to take the lead on actually changing the status quo with regard to oil and gas production in the Arctic — protecting this vast expanse of Alaska is important, but concluding that the Endangered Species Act can't be used to help address climate change is politics, not law," said HSI senior scientist Naomi Rose, Ph.D.
Under court order, the Service has until June 30, 2010 to complete this critical habitat designation.
When the Service previously listed the polar bear as threatened under the Endangered Species Act, it halted the import of sport-hunted polar bear trophies into the United States. More recently, the agency submitted a proposal to list the polar bear on Appendix 1 of the Convention on International Trade in Endangered Species, which would bar the international trade in polar bear skins. The HSUS/HSI applauds Interior Secretary Ken Salazar and the Service for their leadership in global protection of these threatened bears.
*Note: In May 2008, the U.S. Fish and Wildlife Service listed the polar bear as threatened under the Endangered Species Act. In October 2009, the U.S. Fish and Wildlife Service proposed to list the polar bear on Appendix I of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), a move that would prohibit international trade in the species for primarily commercial purposes. The final decision on this proposal will be made at the next CITES meeting in March 2010 in Doha, Qatar.
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The Humane Society of the United States is the nation's largest animal protection organization — backed by 11 million Americans, or one of every 28. For more than a half-century, The HSUS has been fighting for the protection of all animals through advocacy, education and hands-on programs. Celebrating animals and confronting cruelty — On the web at humanesociety.org.
Humane Society International and its partner organizations together constitute one of the world's largest animal protection organizations — backed by 11 million people. For nearly 20 years, HSI has been fighting for the protection of all animals through advocacy, education, and hands-on programs. Celebrating animals and confronting cruelty worldwide — On the web at hsi.org.