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I. QUANTITATIVE COMPARISON OF ENDANGERED SPECIES CRITERIA AND KNOWN FACTS
FWC Rule 68A-F.A.C. defines endangered species by the following criteria:
Endangered Species – As designated by the Commission, a species, subspecies, or isolated population of a species or subspecies which is so few or depleted in number or so restricted in range that it is in imminent danger of extinction as determined by any of the following criteria:
A) Population reduction in the form of either:
1) An observed, estimated, inferred or suspected reduction of at least 80% over the previous 10 years or three generations, whichever is longer, based on, and specifying, any of the following:
a) direct observation
b) an index of abundance appropriate for the species
c) a decline in area of occupancy, extent of occurrence or quality of habitat
d) actual or potential levels of exploitation
e) the effects of introduced species, hybridization, pathogens, pollutants, competitors or parasites.
2) A reduction of at least 80% projected or suspected to be met within the next ten years or three generations, whichever is longer, based on, and specifying, any of (b), (c), (d) or (e) above.
RESPONSE: Population data from synoptic and other counts clearly indicate that manatee populations have been increasing over the last ten years. Total mortality data suggests that populations have sustained an increasing population for the last 25 years. There is certainly no conceivable interpretation that would suggest an 80% decline. In January 2001, state and federal scientists counted an all time record 3,276 manatees in statewide aerial surveys – more than double the number counted 10 years ago. The exact counts taken since 1991 are shown as follows:
MANATEE SYNOPTIC SURVEY COUNTS, 1991-2000, Data Source:
Florida
Fish & Wildlife Conservation Commission
1991 – 1,465 1998 – 2,002
1992 – 1,856 1999 – 2,353
1995 – 1,822 2000 – 2,222
1996 – 2,639 2001 – 3,276
1997 – 2,229
B) Extent of occurrence estimated to be less than 40 square miles or any area of occupancy estimated to be less than four square miles, and estimates indicating any two of the following:
1) Severely fragmented or known to exist at only a single location.
2) Continuing decline, observed, inferred or projected, in any of the following:
a) extent of occurrence
b) area of occupancy
c) area, extent and/or quality of habitat
d) number of locations or subpopulations
e) number of mature individuals
3) Extreme fluctuations in any of the following:
a) extent of occurrence
b) area of occupancy
c) number of locations or subpopulations
d) number of mature individuals
RESPONSE: Chapter 370.12(2)(j) F.S. allows state agencies to adopt manatee speed zones:
“only where manatee sightings are frequent and it can be generally assumed that they inhabit these areas on a regular or continuous basis”
Over the past 15 years, using the statutory criteria that manatees “inhabit these areas on a regular or continuous basis,” state agencies have enacted substantial manatee speed zones in Lee, Brevard, Indian River, St. Lucie, Palm Beach, Broward, Citrus, Levy, Hernando, Volusia, Putnam, Lake, Seminole, Flagler, Hillsborough, Collier, Martin, Dade, Sarasota, Manatee, Charlotte, Duval, Clay and St. Johns Counties. There is absolutely no doubt that the “extent of occurrence” dramatically and exponentially exceeds the 40 square mile criteria.
C) Population estimated to number fewer than 250 mature individuals and either:
1) An estimated continuing decline of at least 25% within three years or one generation whichever is longer or
2) A continuing decline, observed, projected, or inferred, in numbers of mature individuals and population structure in the form of either:
a) severely fragmented (that is, no subpopulations estimated to contain more than 50 mature individuals)
b) all individuals are in a single subpopulations
RESPONSE: The January 2001 count of 3,276 animals (which is an undercount) clearly and dramatically exceeds the 250 mature individuals criteria. Neither the synoptic counts nor any other data would suggest any “continuing decline of at least 25%”
D) Population estimated to number fewer than 50 mature individuals.
RESPONSE: See above response.
E) Quantitative analysis showing the probability of extinction in the wild is at least 50% within 10 years or three generations, whichever is longer.
RESPONSE: Population ecologists use a term called “contact extinction” which means that soon after coming in contact with humans an animal becomes extinct, usually because of excessive hunting. Prime examples are the dodo bird and stellar sea cows. The manatee has been in contact with humans for thousands of years and population counts indicate that manatee abundance has increased over the last 25 years. There is certainly no quantitative evidence to suggest that manatees will decline to extinction in 10 years or 3 generations.
II. TIMEFRAME FOR COMPLETION OF BIOLOGICAL REVIEW
It is our understanding that FWC staff is recommending that the deadline for completing the review be January of 2003. We find it difficult to believe that it would take more than a year to compare existing data to the quantitative criteria contained in the rule. We understand the benefit of waiting to incorporate any new data, which may be presented at the April 2002 Manatee Population Status Working Group meeting. However, fourteen months appears to be more of a timed delay for final action than a reasonable request for a review period.
We urge the FWC Commission to re-examine and reduce the staff proposed timeframe for the Phase I Review.
III. DESIGNATING AN IMPARTIAL REVIEW PANEL
The FWC rule states that “the Commission shall designate a review panel with a minimum of three scientists with demonstrated knowledge and expertise pertaining to species conservation and management.” Manatee management has been an emotional and highly polarized debate with scientists involved on all sides of the issue. It is absolutely essential that the Commission select scientists who are impartial and have no conflicts of interest with the issue.
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