Connecticut Audbon Society


The Endangered Species Act must be saved

September 24, 2018 – The Endangered Species Act protects wildlife throughout the United States and its territories, and it has a direct affect on several species of bird in Connecticut. Those birds could suffer population declines if the act is weakened, as the U.S. Fish and Wildlife Service proposes.

Here is the letter from Executive Director Patrick Comins outlining why we oppose the changes.

Bridget Fahey
U.S. Fish and Wildlife Service, Division of Conservation and Classification
5275 Leesburg Pike
Falls Church, VA 22041-3803

September 24, 2018

Testimony of the Connecticut Audubon Society RE Endangered and Threatened Species: Revision of Regulations for Prohibitions to Threatened Wildlife and Plants FWS-HQ-ES-2018-0007.

Dear Ms. Fahey:
The Connecticut Audubon Society is opposed to some key adverse changes to the Endangered Species Act proposed by the U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Administration. Those changes could put endangered and threatened species at greater risk and set back species on the edge like Piping Plovers, Roseate Terns and others that are struggling to survive in their already shrunken and degraded Connecticut habitats.

The Society conserves Connecticut’s environment through science-based education and advocacy focused on the state’s bird populations and habitats and manages 20 wildlife sanctuaries encompassing almost 3,300 acres of open space in Connecticut. We reach out and educate over 200,000 children and adults annually. Connecticut Audubon is an independent organization, not affiliated with any national or governmental group. Our work includes sanctuary management, advocacy, environmental education and activities at our centers, scientific studies, and our annual Connecticut State of the Birds report.

We urge the USF&WS and NOAA to retain the blanket protections for threatened species, to avoid a direct negative impact on our most vulnerable wildlife. The clause “without reference to possible economic or other impacts of such determination” will prioritize economic considerations over wildlife protection in a state where the citizens unite behind wildlife biodiversity and conservation.

Instead, we call on you to strengthen the Endangered Species Act by improving the process for recovering species, many of which are important to the diversity and people of Connecticut.

The Act has had many successes and has helped save many species from extinction. The results are obvious here in Connecticut, where it’s no longer unusual to see Peregrine Falcons or Bald Eagles – or even Brown Pelicans, whose numbers in the heart of their range have recovered.

The presence of those species in Connecticut benefits the state and its residents immeasurably. It’s for that very reason that our immediate concern is the proposed rollback of protections for threatened species such as Northern Long-eared Bat, Bog Turtle, Red Knot, and especially Piping Plover, which need the protections afforded Peregrine Falcons, Bald Eagle and Brown Pelicans if they are to recover.. Connecticut Audubon in partnership with the Audubon Alliance for Coastal Waterbirds, municipalities, the U.S. Fish and Wildlife Service and the Connecticut Department of Energy and Environmental Protection has worked hard for years to successfully increase the numbers of nesting Piping Plovers in the state. Last year there was a record 66 pairs. If they lose protection throughout their range, it could be a disaster for the birds.

We also have serious concerns about making it more difficult to add new species to the list, even if protections are warranted. There is currently a review of the status of Saltmarsh Sparrows for their inclusion on the list. Saltmarsh Sparrows nest in Connecticut and are highly vulnerable to sea level rise. If that decision is delayed it may mean this bird could go extinct before it is even afforded additional protections or conservation resources to find solutions that may lead to its recovery. There may be other Connecticut species worthy of inclusion on the list such as Wood Turtles, Spotted Turtles and the Frosted Elfin butterfly. Such declining animals deserve a thorough review of their status based solely upon the biological merits of the threats facing them.

Thank you for the opportunity to comment on this important issue.

Patrick M. Comins
Executive Director






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