KAS Letter to U.S. Fish and Wildlife Service

RE:  Docket No. FWS-R1-ES-2022-0074

Thank you for the opportunity to comment on the DEIS and Barred Owl Management Strategy. 

Kittitas Audubon is a local chapter of the Audubon Society, and its area lies within the Central Washington East Cascades General Management Area.  This area includes the recent Cle Elum experimental Barred Owl removal project. Since its inception in the 1990’s, the Kittitas Audubon Society chapter has been interested in the Northern Spotted Owl, the forest stands with which it is associated, and the interactions between the Northern Spotted Owl and the Barred Owl.  Our membership includes people who are or have been professionally involved with spotted owl issues through their employment in the timber industry, and the federal and state agencies responsible for management of forests and forest wildlife. This issue is of special importance to our membership.

Members of Kittitas Audubon reviewed and studied the Barred Owl Management Strategy, the DEIS, its appendixes and the executive summary.    We found the executive summary to the DEIS to be a concise, quick read.  Maps and tables in the document provide information in a manner that helps quickly compare alternatives. The appendices explain methods and research well. 

We recognize the perilous status of the Northern Spotted Owl and the need for action to save the Northern Spotted Owl from extirpation.  Your case for declaring the Barred Owl an invasive species is convincing.  The Barred Owl is a more aggressive competitor and is better adapted to the new forest environment humans have created in the West than is the Northern Spotted Owl. The pilot study conducted in our area and elsewhere in the Pacific Northwest suggests that removing Barred Owls does indeed help maintain and slowly increase spotted owl numbers. 

Kittitas Audubon supports the need for action and recognizes Alternative 1 is not an option. We believe Strategy Implementation and the proposed action would be the most beneficial course of action to benefit Northern Spotted Owls across a broad range of remaining large blocks of suitable habitat on the landscape.  However, we have reservations about Alternative 2 for implementation of the Strategy.  We make these following comments with grave concern for the future of the Northern Spotted Owl. Please take our comments under advisement and provide additional analysis where requested. 

Sustainability:  As a recovery strategy, the proposed action necessarily requires long-term funding and a commitment to continue removing Barred Owls every year.  To maintain a viable and stable population of Northern Spotted Owls on the landscape, this program must continue for the foreseeable future.  It seems that this proposal can buy time, but the likelihood of permanent success seems unlikely unless there is concurrent restoration of forest habitat conditions which reduces the ability of Barred Owls to outcompete Northern Spotted Owls.

Sustainability of the project over the long term (30 Years) is questionable, due to reliance on partners and unreliable federal funding.  The USFWS is relying on issuing Migratory Bird Treaty Act (MBTA) permits to a variety of partners with different missions and foci, rather than administering the Endangered Species Act and protecting migratory birds.  Will these partners continue participating in the projects if there is public outcry against Barred Owl removal, a shortage of funding, or a shift in distribution of funds?  The DEIS does not discuss these concerns, and we ask for acknowledgement and analysis of these concerns. 

Alternative 2 and the Strategy forecast that 20,000 Barred Owls will be removed the first full year of implementation, and optimally 90% of the Barred Owl population over the long term.  To accomplish this, small Focal Management Areas (FMAs) are to be created for Barred Owl management within each General Management Area (GMA).  FMAs would be limited to 50% of each GMA.  Therefore Barred Owl management will be limited to, at most, 50% of the identified suitable habitat.  Will this be enough to stabilize the Northern Spotted Owl population?  What are the determined measures of success and at what levels are these measures successful?

Alternative 2 analyzes the effects under the assumption that the Strategy is fully implemented.  What management acreage and what number of Barred Owls removed is determined successful and effective if the Strategy is less than fully implemented?  What are the effects if the Strategy is partially implemented due to partners not participating and/or funding limitations?  What are the definitions and/or parameters of “success” for the Strategy, and what hinges on achieving such success?  What is the threshold point at which low numbers of Barred Owls removed indicate failure?  The final EIS should provide answers to these questions along with a full analysis. The DEIS does not define or answer these questions despite earlier comments; see page 247, A5.3.3 of the DEIS. 

Ethics:  The plan to lethally remove Barred Owls from key areas is offensive to many of Kittitas Audubon’s members.  Discussion of the ethical dilemma inherent in lethal control of one species of wildlife to conserve native wildlife was requested in earlier documents; see A5.3.3.  Shooting of one species may be a gateway to eliminate other species in the future under an unknown future of climate change.  Future climate change migrants are inevitable, and must be considered to guide USFWS actions. This should be acknowledged under cumulative effects.

Public Relations and Education:   A public information and education program needs to be an essential component of all action alternatives.  Media coverage thus far has misrepresented proposed actions and locations of Barred Owl removal.  The high number of Barred Owls proposed to be removed has alarmed many people, including members of Kittitas Audubon.  Public acceptance of this killing of wildlife will be necessary to allow the program to proceed, and to secure and maintain funding.  We question whether partners will continue working with the program if there is large public resistance. 

Habitat:  The Purpose and Need of the DEIS and Strategy is limited to only Barred Owl elimination.  Failure to analyze habitat degradation because of such a narrow decision space does not relieve USFWS of responsibility to address habitat degradation under cumulative effects.  Habitat degradation persists despite the Northwest Forest Plan, Habitat Conservation Plans, and Safe Harbor permits, especially on non-federal lands.  Page 85 of the DEIS states carrying capacity of Northern Spotted Owl habitat is declining at a 5.3% rate but does not give data to support this figure.  Kittitas Audubon believes the estimate is most likely light due to old growth forest still being harvested in many areas.  This gives emphasis to the need for USFWS to limit take permits for the Northern Spotted Owl.  Please provide data for habitat decline rates and the number of annual take permits granted for Northern Spotted Owls.

Financial/Social Economics:  Commenters requested the following financial logistics for the proposed action and alternatives be addressed in the EIS, page 245, A5.3.2. 

  • Address how long-term actions would be supported if considerable funding support will be required for federal and non-federal implementers.
  • Consider scope and costs. 
  • Request the EIS address the long-term strategy for continuous funding for implementation on all land ownerships, including staff and funding.
  • (and again, in A5.3.3) Will the EIS assess the feasibility of expecting federal agencies to have the resources, funding, and commitment needed to sustain the Barred Owl removal program?

The social economics analysis did not consider the cumulative effects of federal partners having to redistribute funds from other natural resource projects in order to fund the hiring, training, and salaries of staff and support staff to implement the Strategy.  It briefly states vehicles and equipment are already available, but what projects and programs go without because of this shift in focus?  This effect needs to be acknowledged at a minimum, and should be discussed in cumulative effects.  Will the USFWS request additional funding from Congress? 

Thus, the DEIS did not respond adequately to the earlier comments for analysis.  Please provide such analysis in the FEIS. 

Monitoring:  We agree with the need to monitor the results of Strategy implementation.  We encourage the use of the newest technology of acoustic monitoring, as it is less intrusive for the Northern Spotted Owl and other wildlife.

Does the monitoring process allow for flexibility in case changes are needed?

Adaptive Management:  What is the adaptive management approach if the Strategy isn’t successful or doesn’t meet expected quotas?  Nowhere in the DEIS is adaptive management or other management tools beyond Barred Owl removal discussed.  Page 246 of the DEIS, A5.3.3 includes earlier comments asking for an adaptive approach that explores ways to adjust practices based on success or lack of success of the program.  What does USFWS plan to do if Barred Owls are eliminated from general management areas but the Northern Spotted Owl population still isn’t stable?  In areas such as Central Washington Eastern Cascades, if there is a lack of displaced adult Northern Spotted Owls to recolonize habitat after Barred Owls are removed, it is doubtful the Northern Spotted Owl population will improve or stabilize.  Capture and translocation of Northern Spotted Owls should be considered to augment these low population areas as an adaptive management tool, not eliminated from analysis as written in Chapter 2.10.10; even if additional analysis and documentation are needed to do so. 

Are there any examples suggesting that restoration/creation of networks of “old growth like” habitat patches can provide refuge habitat better suited for Northern Spotted Owl? If so, this practice should be considered as an adaptive management technique. 

Stronger actions taken in California to remove Barred Owls and protect Northern Spotted Owls should be undertaken in Alternative 2. Certainly, bolstering these actions as border control to protect a healthier population of Northern Spotted Owls and California Spotted Owls would be an adaptive management practice, should implementation of the Strategy fail in Oregon and Washington. 

Thank you again for the opportunity to review these draft documents and for considering our concerns and comments.  We look forward to your analysis and answers in the FEIS.


President, Kittitas Audubon

P.O. Box 1443

Ellensburg, WA 98926