December 25, 2015
Steve Spangle, Field Supervisor
Arizona Ecological Services Office
2321 West Royal Palm Road
Phoenix, Arizona 85021
602/242-0210, x-244
Comment on Gila Chub Draft Recovery Plan, FR Doc No: 2015-27259
sent by email to Steve_Spangle@fws.gov
ISSUE: Recovery Plan Ranking of Threats
The Recovery Planning Guidance (RPG) considers the ranking of threats to be an essential and
important part of threats assessment. The RPG contains many statements about ranking threats,
assigning priorities to threats and how the ranking is used to guide actions. Quotes from the RPG are
provided below.
The Gila Chub Recovery Plan does not rank or prioritize the threats, or discuss relationships of threats.
The recovery plan states that its prioritization scheme merely adds up the number of different types of
threats in each habitat area and a number for the chub population being low, medium or high. This
statement is under II.4 Recovery Criteria, p.40 (bold added):
We developed a prioritization scheme to direct management efforts toward population
replications by assigning weighted population size scores (low, medium, high, according to Table
I.3), totaling the number of threats to each population from Table I.4, and ranking
populations according to conservation priority, as developed by Clarkson et al. (2012).
Appendix C contains Table C.2, has this description: (bold added)
Table C.2. Scoring to prioritize needs to replicate Management Unit population groupings
according to estimated population size, the number of threats to each population from
Table I.4, and ranks of population priority for conservation action from Clarkson et al. (2012).
Scores are based on the sum of size, threat, and rank scores; ties were ranked identically.
Table I-4 is a matrix of threats and explicitly states that it is not intended to indicate the severity of threats.
The score is calculated by adding the number of threats: (bold added):
Table I.4. Matrix of threats, for remnant populations of Gila chub that are identified in Factors AE. The table is used to indicate the presence of a potential or documented occurrence of a
threat and is not intended to indicate severity of threats. Score is the sum across rows of
the number of threats identified for each population that is used in Table C.2.
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The total score adds the number of threats. That means every threat is counted as “1” and is treated as
equivalent to every other threat, i.e. every threat is of equal severity, significance, and importance. This is
contrary to the RPG direction of differentiating between threats.
The intent and direction of the Recovery Planning Guidance is clear. The purpose of ranking threats is
stated concisely under 1.3.2 The Significance of Threats in Recovery Planning: (bold added). We note the
use of “must”; the analysis must determine the relationship among threats. This is not optional and it has
not been done in the Recovery Plan. (bold added)
The reasons for a species’ decline often comprise an interrelated, interactive suite of factors,
rather than a linear cause-and-effect of a single factor. Therefore, a recovery plan must not
only identify the different threats, but also analyze and determine the relationships among
threats so that a recovery strategy can be designed to effectively reduce these threats. A
threats assessment can be used in recovery planning to determine the relative importance
of various threats to a species (see section 5.1.6.7, Reasons for Listing/Threats, and Appendix
C). A threats assessment includes (1) identifying threats and their sources, (2) determining the
effects of threats, and (3) ranking each threat based on relative effects. This guidance
recommends using a threats assessment for species with multiple threats to help identify
the relative importance of each threat to the species’ status, and, therefore, to prioritize
recovery actions in a manner most likely to be effective for the species’ recovery.
The RPG makes these statements at 5.1.6.7 Reasons for Listing / Threats Assessment: (bold added)
When discussing each threat and its source(s), the geographic scope, severity, and frequency of
the various threats should be indicated, noting those that present greater or lesser threats to
the species.
Conducting a threats assessment for the species is strongly recommended. A threats
assessment is a structured approach to assessing threats, sources of threats, and their relative
importance to the species’ status, and often results in a threats table which summarizes the
findings of the assessment.
We note that Table I.4 is titled Matrix of threats but does not described relative importance. It does just
the opposite, by treating all threats as being equally important. This statutory requirement in the RPG is
not addressed in the recovery plan; under RPG 5.1.8.3 Recovery Criteria (bold added):
Developing recovery criteria that are both objective and measurable is a statutory requirement in
the ESA for recovery plans and a useful exercise in terms of planning. The ESA states that each
recovery plan shall incorporate, to the maximum extent practicable, threats, recovery may
be possible in multiple states, e.g., a species might be able to tolerate a continuing level of
one threat if another threat has been eliminated.
The RPG makes this statement under Control of Threats, in the section 5.1.8.3 Recovery Criteria (bold
added):
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When putting together the recovery action narrative, clarify to the reader the magnitude and
immediacy of the threats (this information should be obtainable, and paraphrased, from the
Threats Assessment in section 5.1.6.7), and state the priority and extent to which the threats
are expected to be addressed with the given management action.
RPG 5.1.10 Implementation Schedule and Cost Estimates says that the implementation schedule is
required under the ESA and that it must identify a priority for each recovery action. This is followed by a
very detailed discussion of how priorities must be assigned (only partially reproduced here). Again, it is
quite clear that ranking and prioritization of threats is necessary in order to comply with the ESA. (bold
added).
The implementation schedule is designed to satisfy the requirement under the ESA that
recovery plans must contain “estimates of the time required and the cost to carry out those
measures needed to achieve the plan’s goal and to achieve intermediate steps toward that goal”
(ESA section 4 (f)(1)(A)(iii)). The implementation schedule also identifies a priority for each
recovery action in the narrative and recommends responsible party(ies) for carrying out each
recovery action.
Assigning priorities – Priorities are assigned to each action in the implementation
schedule. In compliance with NMFS’ Endangered and Threatened Species Listing
and Recovery Priority Guidelines (55 FR 24296) (Appendix S), all recovery actions
will have assigned priorities based on the following:
Priority 1: Actions that must be taken to prevent extinction or to prevent the species from
declining irreversibly
Priority 2: Actions that must be taken to prevent a
significant decline in species population/habitat
quality or in some other significant negative
impact short of extinction
Priority 3: All other actions necessary to provide for full recovery of the species.
It is important to emphasize that a priority 1 recovery action is an action that must be
taken to prevent extinction. Therefore, the use of priority 1 recovery actions in a recovery
plan for a threatened species should be done judiciously and with a constant reflection
back to the original definitions.
RPG 5.2.1.2 Analysis includes this statement (bolded added):
This step involves careful assessment of the biology, status, and threats information compiled to
ascertain the relative significance of the various issues facing the species, the possible
ramifications of these issues, and the opportunities currently available for addressing these
issues and advancing recovery.
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The RPG repeatedly describes the need, purpose, importance, and utility of analyzing the threats to rank
and prioritize them, and determine magnitude, severity, greater and lesser, etc. The RPG says it in many
ways:
…identify the relative importance of each threat to the species’ status, and, therefore, to
prioritize recovery actions in a manner most likely to be effective
for the species’ recovery
Therefore, a recovery plan must not only identify the different threats, but also analyze and
determine the relationships among threats so that a recovery strategy can be designed to
effectively reduce these threats. A threats assessment can be used in recovery planning to
determine the relative importance of various threats to a species noting those that present
greater or lesser threats to the species.
…assessing threats, sources of threats, and their relative importance to the species’ status
clarify to the reader the magnitude and immediacy of the threats
The implementation schedule also identifies a priority for each recovery action
all recovery actions will have assigned priorities
the relative significance of the various issues facing the species
Recovery plan Table lll-2 page 60, Gila Chub Threats Tracking Table assigns threats to the listing factors.
Contrary to the RPG, it does not rank or prioritize them. Natural and manmade factors are lumped
together as “O”, for “other”. Management through habitat modification is named as threat “M” and never
explained. Example below from Table lll-2:
Under III.2 Narrative Outline for Recovery Actions, page 63, in item 1.1 the recovery plan two primary
and secondary categories. Each category lists many diverse threats that include intransigent threats
(climate change), predation by nonnatives, diseases (nonnative pathogens), human actions (e.g. road
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and dam construction), and natural events (wildfire). The Narrative Outline for Recovery Actions does not
satisfy RPG 5.1.6.7 Reasons for Listing / Threats Assessment (bold added).
When discussing each threat and its source(s), the geographic scope, severity, and frequency of
the various threats should be indicated, noting those that present greater or lesser threats to the
species.
There are isolated statements in the recovery plan about individual threats, such as this at page 51, but
the recovery plan never presents a comprehensive comparative ranking of all the named threats or
examines relationships between threats.
Where perennial streams remain, the most significant and common threat to Gila chub is the
presence of nonnative fishes that suppress or eliminate populations via predation, competition,
and other mechanisms.
REMEDY: The recovery plan must be revised to comply with the RPG; clearly present the ranking and
prioritization for threats, severity, magnitude, relationships between threats, comparison of great and
lesser threats etc. Then the narrative and recovery actions must be revised to reflect the prioritization of
threats.
Thank you for the opportunity to comment.
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