http://www.huntingreport.com/c...ion_force.cfm?id=394


Polar Bear Five-Year Status Review – Perhaps a Chance to Reevaluate the Threatened Listing



Written By John J. Jackson III, Conservation Force Chairman & President
(posted February 2016)

In October, US Fish & Wildlife Service (FWS) initiated a (belated) five-year status review of the polar bear, which was listed as threatened in 2008, primarily due to concern about the long-term impacts on polar bear populations of sea-ice loss caused by global climate warming.

On December 14, Conservation Force submitted detailed information available since the listing, and suggested that FWS should re-evaluate the threatened status of polar bear and consider delisting. Our comment included over 50 attachments and made the following, well-supported points, in line with the four main factors FWS considers in making a listing determination.

First, we submitted newly available information showing that the global polar bear population is stable or increasing since 2008. We submitted the 2015 IUCN Red List assessment, which calls into question the model FWS used in finding the polar bear threatened.

The new Red List assessment raised the global population estimate for polar bear from the former range of 20,000-25,000 to 26,000 in 2015. The estimate includes data sets FWS did not include in its listing determination (although they were available). This current population estimate is greater than before not simply because of the inclusion of additional subpopulation data, but because polar bear estimates seem to have increased overall. Since the 2008 listing, three subpopulations (Foxe Basin, Southern Hudson Bay, and Western Hudson Bay) have repeat estimates that suggest a population gain. Only one subpopulation (Southern Beaufort Sea) has a repeat estimate showing a decline. The three positive estimates are greater than the negative one by 147 polar bear (2.77%). This data suggests that seven years later, the bear is not declining as believed at the time of listing. New, best-available information points to growth as a whole, even if there may be some pockets of decline. The speculative reason for listing was erroneous.

Further, the Red List shortens the generation interval used by FWS. This is important because the ESA definition of "threatened" considers whether the species is "likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range." The Red List's generation interval shortens the "foreseeable future" by a decade from that used by FWS, which means the effects of climate change are not likely to be as severe. In this 35-year period, according to the Red List, the polar bear population faces a "significant" probability of a decline of marginally more than 30% of current estimates, but a "low" risk of a decline of more than 50% of current estimates. In addition, the Polar Bear Specialist Group estimated that in 2015, six polar bear subpopulations are stable, one is increasing, and only three are potentially in decline. Taken together, this data undercuts the FWS' 2008 model which supported the listing. That model looked at sea-ice losses over a 45-year period. It predicted that several polar bear sub-populations would face a "trend towards extirpation" within 45 years. But the Red List data suggests polar bear will not decline significantly within 35 years. That is also a reason for delisting, as it means the polar bear is not likely to become endangered any time soon.

Second, in the listing determination, FWS expressed concerns about overharvest of polar bear exacerbating the decline caused by climate change. But we submitted new information showing that polar bear harvests are lower now than in 2008. In particular, we submitted information about Canada's offtake, as Canada is the only country that allows offtake for sport-hunting and commercial trade in polar bear products. We submitted information showing Canada carefully controls and monitors offtakes, limited to a sustainable level of less than 4% of the country's total polar bear population.

FWS acknowledged in it s recently published draft Polar Bear Conservation Management Plan that a fixed-rate harvest of polar bears is sustainable, even in a declining population, as long as the population is adequately monitored and the offtake is adjusted based on the decline. Canada helped write FWS' draft plan, and will include the same concept in its management plan for polar bear. And Canadian territories already adaptively manage their offtakes in this way.

We also submitted information showing that a limited, regulated offtake is necessary to maintain indigenous support to manage polar bear populations at high levels of recovery, and information showing that regulated sport-hunting can be a critical generator of indigenous support because it generates more revenue than commercial trade in polar bear products. The revenue is critical for communities in the Arctic because the cost of living is high and there are few other sources of income. The IUCN recognized this fact in the 2015 Red List assessment, and we submitted additional information from TRAFFIC and other sources to drive it home.

We also pointed out that the CITES Parties have twice refused to uplist the polar bear to Appendix I, acknowledging that limited trade in polar bear parts is not a detriment to the species. Most recently the CITES Animals Committee removed polar bear from the Review of Significant Tradeprocess. These actions acknowledge that Canada is effectively managing its polar bear populations, which FWS must take into account in a listing determination.

Third, we submitted documentation that disease and predation are not significant threats to the polar bear. And finally, we submitted documentation showing that several international initiatives which were not implemented in 2008 have now been implemented, including a bilateral agreement between the US and Russia and the Polar Bear Range Nations' Circumpolar Action Plan for polar bear management. This information is important because FWS based part of the listing determination on the inadequacy of existing regulatory measures, because these initiatives had not yet been developed.

We also submitted documentation of Canada's polar bear management because under the ESA, FWS must consider range nation management programs. Since FWS listed the polar bear as threatened in 2008, Canada has also listed the polar bear, as a species of Special Concern under its Species at Risk Act. Canada published a National Conservation Strategy and is close to finalizing a National Management Action Plan for polar bear. And in 2014, Canada presented on its polar bear management to the European Union's Scientific Review Group (SRG). The EU SRG approved imports of most polar bear hunting trophies after its review of Canada's efforts.

We argued that these factors suggest the polar bear is more than adequately safeguarded, is not at risk of "likely" extinction in the "foreseeable future," and is potentially most at risk from well-meaning overprotection . We submitted information to FWS that most Inuit believe there are too many polar bear right now, and increased protection (which means decreased hunting and trade) will weaken the buy-in of indigenous communities to the current high levels at which polar bear are managed. For these reasons, we argued that FWS should consider down-listing the polar bear under the ESA.

Information was also submitted by the Canadian Wildlife Service, the Alaska Department of Fish and Game, SCI, the Alaska Oil and Gas Association and American Petroleum Institute, Defenders of Wildlife, and the Center for Biological Diversity together with the Animal Welfare Institute, Humane Society International and HSUS, and the Natural Resources Defense Council. Of these comments, two (in addition to Conservation Force) asked FWS to consider de-listing the polar bear, one asked FWS to maintain the status quo, and two asked FWS to consider uplisting polar bear to endangered status.

The Canadian Wildlife Service (CWS) did not take a direct position on the listing. In keeping with FWS' request for newly available information to guide the five-year status review, CWS submitted 10 pages of references to "research papers and conservation efforts" published or established since the polar bear's listing in 2008 and that speak loudly for themselves.

The Alaska Department of Fish and Game expressed its continued opposition to the listing of polar bear as threatened and encouraged FWS to re-evaluate that listing. Alaska's submission attached its prior comments on FWS' draft Polar Bear Conservation Management Plan.

Like Conservation Force, SCI argued that FWS should reevaluate the polar bear's status and consider delisting. Among other things, SCI pointed out that if the global polar bear population declines due to sea-ice losses, certain regions will remain as a "long-term refuge" for polar bear. At least these regions could be delisted as distinct population segments (DPS). SCI also drew FWS' attention to the 2015 Red List assessment.

The Alaska Oil and Gas Association comment provided information about the oil and gas industry's polar bear conservation efforts. It also argued that polar bear are not an endangered species and asserted that there is no reason to change the current listing, rather than arguing for delisting.

On the other hand, Defenders of Wildlife and the Center for Biological Diversity advocated that FWS consider an uplisting to endangered status. Defenders of Wildlife suggested that an uplisting is warranted because the polar bear's "primary threat" of climate change has not been eliminated. Their comment submitted a list of "climatefocused polar bear studies" that are said to show continued great risk to the species.

The Center for Biological Diversity comment also asked FWS to consider uplisting. Among other things, the comment described what it calls "observed impacts" of sea-ice loss on polar bear, and attacked sustainable use of polar bear. The comment argued that "unsustainable polar bear hunting, particularly in declining populations, is a substantial and additive risk to the species' survival throughout its range." It also expressed concern with FWS' draft Polar Bear Conservation Management Plan, especially with the finding cited above that offtake from a declining population is permissible. The Center for Biological Diversity comment repeatedly criticizes Canada's polar bear management and allowance of offtake for sport hunting and commercial trade.

In short, these additional comments provide FWS with a lot of newly available information. On the whole, more commenters argued for delisting of the polar bear. Although it is true that the "primary threat" of climate change has not been eliminated, information submitted by Conservation Force and others demonstrates how this threat is being managed, and how polar bear may be sustainably used despite the threat.