Dear Secretary Salazar,
I am writing to request that you rescind the proposed policy interpreting the phrase "significant portion of its range" (SPOIR) and replace it with a policy that will truly ensure that species are not lost from significant portions of range.
The draft policy specifies that a portion of the range of a species is significant only if "its contribution to the viability of the species is so important that without that portion, the species would be in danger of extinction." This definition does not provide a meaningful distinction between when a species is endangered in a SPOIR and when a species is endangered throughout all its range, thereby rendering the SPOIR phrase superfluous and nullifying any conservation benefit of protecting species before they are threatened with worldwide extinction.
The draft policy further specifies that when considering whether a species is endangered in a SPOIR, only the current range of a species will be considered. Ignoring historic range when determining whether species are endangered in significant portions of range amounts to a shifting baseline, whereby species that experienced major declines are considered secure only because the analysis is limited solely to current range. Such an approach is clearly not in the interest of species conservation.
I ask that you rescind this anti-science, anti-common-sense draft policy and instead adopt one that considers the significance of both current and historic range and adopts a broad definition of significance that considers many factors when evaluating portions of range, including biological importance, ecological value and size.
