On January 16, 2024, DTA submitted a public comment on Fish and Wildlife Service’s proposed Barred Owl Management Strategy (#FWS–R1–ES–2022–0074). 

The proposed Barred Owl Management Strategy (“Strategy”) aims to protect two Spotted Owl subspecies, the Northern Spotted Owl (Strix occidentalis caurina) and California Spotted Owl (Strix occidentalis occidentalis) (collectively “Spotted Owl”) by allowing commercial, private property, and tribal land owners to lethally remove Barred Owls (Strix varia) on their properties. If  approved, the Strategy could result in lethal taking of up to 470,000 Barred Owls over the next 30 years.

We acknowledge that issues involving wildlife conflicts and environmental protection are extremely complex, especially where value judgments between treasured species are required. Extinction of the Spotted Owl would certainly be tragic. Nonetheless, we fear that the proposed Strategy codifies a reactionary approach that fails to consider important factors contributing to, and possibly preventing, long term recovery of these species. Without more measured and nuanced considerations of novel ecosystems, including those forever changed by human activities, it is impossible to predict whether the stated purpose of the proposed strategy can be achieved and what unforeseen consequences may arise. 

We remain optimistic that additional information and scientific data will perpetuate a continued conversation around the protection of these species. Approval of a Strategy that authorizes actions of this scope and magnitude without a proper and complete analysis of their effects is inconsistent with the agency’s regulatory obligations under the National Environmental Policy Act (NEPA) and the Endangered Species Act (ESA). 

FWS suggests that Barred Owls pose “significant environmental harm” to the Spotted Owl, and are “…considered a risk to create a trophic cascade in some forest systems” (Strategy pg. 16). These assertions assume that the presence of Barred Owls is the primary causative factor in Spotted Owl declines. Without full and fair consideration of threats known to affect the species, such a conclusion seems dangerously speculative and irresponsible. 

Even if Barred Owls are primarily to blame, additional factors such as habitat loss, climatic change, disease, and contaminants known to affect Spotted Owls have not been properly considered. Furthermore, failure to properly analyze the role that rodenticides have played in negative population trends of Spotted Owls and the prey on which these species depend is essential to a reasoned choice among alternatives, and is critical for the public to understand before such drastic measures are permitted to take place.

Read the full text of DTA’s public comment here.