A. INTRODUCTION
CCA Florida believes that the
Florida
manatee is a special animal which deserves special management attention. As conservation minded saltwater anglers who share
Florida
’s waters with manatees we have a responsibility to work with the FWC to develop management plans and protection zones which provide both protection for manatees and reasonable access for saltwater anglers and boaters. Further, these plans and zones must be based on science, not emotion and lawsuits.
On
March 18, 2003
, a stipulations agreement between the U.S. Fish and Wildlife Service (USFWS) and the Save the Manatee Club, et.al. was approved by a federal judge despite formal written objections filed by the FWC and others. The stipulation mandates the USFWS to advertise three major areas for additional federal speed zones and final federal zone rules must be adopted by July 31. Nearly 3,000 people went to the public hearing in
Ft.
Myers
to oppose these actions by the federal government and the Manatee Club to override state management efforts and impose more extreme regulations in areas that are already heavily regulated and restricted under state law. These zones will significantly damage access for recreational fishing in major areas of the state. The central focus in this confrontation, and in the entire manatee controversy, is the biological status of manatees and the need for such extreme zones to protect manatees.
We wish to note that CCA Florida was willing to agree to a “ceasefire” on the manatee battles, including a delay on this re-evaluation, and participate in a conflict resolution process. However, the Manatee Club and their plaintiffs in the federal lawsuit did not agree and are continuing in their efforts to enact extreme speed zones. As such, it is extremely important that
Florida
’s Fish and Wildlife Conservation Commission take final action to establish the true biological status of manatees for the confrontation that is occurring.
B. RECOMMENDATIONS
#1. THE FWC SHOULD CLASSIFY MANATEES AS “SPECIES OF SPECIAL CONCERN” BECAUSE A CORRECT APPLICATION OF THE FWC CRITERIA WOULD PLACE THE CURRENT BIOLOGICAL STATUS AS “SPECIES OF SPECIAL CONCERN” NOT AS THREATENED.
- Documented science does not allow the manatee to be listed as endangered or threatened under the FWC Imperiled Species criteria. That is simply a function of the fact, which is documented in the FWC report, that there is no evidence of any declines in manatee populations over the last 45 years. In fact, manatee populations have been expanding since the 70’s. The only way manatees may fit under other criteria is to simulate declines in a computer. Major problems still exist with the computer model. Our major concerns can be seen by running the model with double, triple, and quadruple the current manatee population. We believe that the computer model will continue to classify manatees as “threatened” even with these population increases because the assumptions in the model make the populations decline. A computer model and a process which never changes the outcome and classification, no matter how large the populations becomes, is simply not a valid decision making tool.
#2. THE MANATEES BIOLOGICAL STATUS SHOULD BE RE-EVALUATED NO LESS THAN EVERY FIVE YEARS.
- It should be made clear to the public that the Commission’s action represents the status of
Florida
manatees in May 2003, not 50 years from now. The FWC and federal agencies do not need to wait another 31 years to do a comprehensive assessment. Much of the hype, hysteria and concern would be eliminated if the re-evaluations were done more frequently.
CCA Florida understands that the FWC’s action to re-classify will not actually occur until Phase II of the Imperiled Species Rule, the adoption of the management plan, is complete. We also know that such listing action will not result in any actions to remove existing speed zones. However, we hope that status upgrade and recognition of the true biological status will help to moderate future proposals.
We also acknowledge that the FWC re-classification does not impact the manatee’s status or protection under the federal Endangered Species or Marine Mammal Protection Acts.
C. COMMENTS
- The problems regarding the computer model involve simulations not scientific facts. Computer models can be constructed and adjusted to simulate virtually anything. Staff should layout in detail the simulations that were developed and Commissioners can decide whether or not those simulations reflect the reality of the future. Furthermore, the FWC Imperiled Species rule does not require the development of a computer model.
- THE FWC EVALUATION HAS INCORPORATED A “RISK FACTOR” INTO THE ANALYSIS WHICH DOES NOT APPEAR ANYWHERE IN THE FWC RULE CRITERIA OR IN THE IUCN CRITERIA OR STANDARDS.
The 5 percent, 10 percent and 20 percent risk factors used in conjunction with selected computer simulation scenarios establishes major biases in interpreting the outcome of the simulation and the final evaluation. Given the fact that extremely negative scenarios are purposefully modeled into the computer simulations there is no way possible for future population reductions in a predetermined number of simulations to ever be less than 10 percent. The current variables in the simulations combined with the inserted “risk factors” insure that the population can never achieve “species of special concern” or “recovered” status. For example, in the case of species of special concern, even if 89 percent of a set of simulations does not meet the criteria, it would still qualify as meeting the criteria for “species of special concern.” The imposed risk factor in conjunction with the evaluation system used by FWC staff allows a criteria to be achieved even when 89 percent of the simulations do not meet the criteria. Such a system is simply not valid or reasonable.
- AN OVERWHELMING MAJORITY OF THE COMPUTER SIMULATIONS CREATED FOR FUTURE POPULATION PROJECTIONS DEVIATE FROM THE REALITY AND KNOWN FACTS ON MANATEE POPULATIONS FROM THE LAST 45 YEARS.
Some scenarios are justified to test worse case situations but not an overwhelming majority of the scenarios. The most obvious deviation is the assumption that “survivorship” will immediately decline by either 0.05 percent or 0.10 percent. This immediate decline is modeled into 10 of 16 (62.5 Percent) of the computer simulations. The report states that, “It is plausible to assume” such decline because average annual watercraft mortalities have risen by 10.3 percent per year over the last decade. Even if that percentage is correct, and we believe it is not, the information source quoted (Deutsh, et al) states that the number of deaths due to watercraft rose at 10.3 percent per year from 1976-2001 (except for one year – 1991-1992). How can it be “plausible to assume” that a stated percent annual increase in watercraft mortality will cause an immediate decline in survivorship when that percentage has been a constant since 1976 and there has been a substantial increase, not decrease, in manatee populations over that same time period. A majority of the computer simulations should be based upon past history and known facts not “plausible assumptions.”
- NEGATIVE VARIABLES ARE DOUBLE COUNTED IN THE SIMULATIONS
As a responsible fish and wildlife agency, the FWC should be cautious and err on the side of conservation. However, many of the variables modeled into the computer simulations amount to double counting of survival factors, which produces a more negative outcome for future population projections. For example, the computer simulations incorporate catastrophic events such as red tides and extremely cold winters. However, such events have been occurring naturally and, as such, are already reflected in the calculated adult and juvenile survival rates which are modeled into the simulations. Adding such events again in the computer simulations amounts to double counting and produces a biased and more negative outcome for future population projections. The bias is further compounded by the fact that catastrophes are modeled into (15 of 16) 93 percent of the computer scenarios.
- A major assumption in the model is that no additional management measures will be taken to protect manatees for the next 100 years; only bad events are placed in simulated futures.
- FWC ASSESSMENT DIFFERS SUBSTANTIALLY FROM IUCN ASSESSMENT.
In 1996, the IUCN’s a “Sirenia Specialist Group” assessed the status of Florida manatees and placed them in the VU – Vulnerable category. (The criteria for the IUCN’s Vulnerable is virtually identical to the FWC’s Species of Special Concern category). Since 1996, substantial additional population and adult survival information has been developed including the all time record population count in 2001. This newer data, which shows that manatee populations have not declined and have in fact expanded over the last 45 years, was not available to the IUCN’s assessment group in 1996.
How did the FWC evaluation, using essentially the same criteria as the IUCN but with more positive updated information on manatee populations, determine that manatees should be placed in a more imperiled category than the IUCN did in 1996?
D. CONCLUSION
The FWC has determined that the State of Floridaalone has established more than one quarter of a million acres of manatee protection zones. Those 298,816 acres represent 24% of Florida coastal and inland waters. Many Florida counties already have a substantial percentage of their inshore waters in regulated manatee protection zones; including, Citrus 100%, Lake 97%, Collier 67%, Indian River 65%, Martin 66%, Palm Beach 62%, Sarasota 48%, St. Lucie 48%, and Volusia 46%. Establishing the correct biological status and implementing the management plan required by the second phase of the process is essential to determining whether existing regulations and protections zones are sufficient to protect the expanding manatee populations. Otherwise, saltwater anglers will continue to face a never ending procession of additional zones and regulations based on lawsuits and emotions, instead of science.
The intent of the FWC’s Imperiled Species rule is to identify species whose survival is at risk, develop management plans to protect them, and as populations improve move them to less imperiled categories. The ultimate success is when the species population is at a level that they no longer need to be on the imperiled species list. However, using a computer model and assumptions which do not allow the species classification to be upgraded as populations expand undermines the intent of the program.
Through our analysis of the data, we believe that if the computer model was programmed to fit the reality of increasing populations over the last 45 years and more supportable assumptions were made regarding future impacts, the analysis will show that manatees should be listed as a “species of special concern.”
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