The use of surrogates in implementation of the federal Endangered Species Act—proposed fixes to a proposed rule

Abstract

The US Fish and Wildlife Service and National Marine Fisheries Service recently proposed to amend existing regulations that implement the Endangered Species Act's interagency consultation process by codifying their preexisting practice of using surrogates to express the amount or extent of incidental take of listed species. The agencies contend that amendments both are necessary as a practical matter and are defensible on ecological grounds. They propose the use of surrogates, either in the form of a substitute species filling in for a species that is challenging to observe or measure, or a land-cover type or another habitat attribute, as proxies for the amount or extent of anticipated take. We contend that the proposed rule leaves the process of surrogate selection and application without essential implementation details and describe five essential steps in surrogate selection and validation. In sum, an obligatory validation procedure should clearly articulate the reasoning behind the selection of the surrogate, including describing the similarities in responses by the surrogate and target species to the same environmental phenomena, linking demographic responses to habitat extent and condition, and describing the uncertainties that accompany the relationship between the status and trends of the surrogate and those of the target species or its habitat under common circumstances.

Is conservation based on best available science creating an ecological trap for an imperiled lagomorph?

“…For New England cottontails and many other imperiled species that are data-limited, conservation has often proceeded based on the standard of "best available science" (Doremus, 2004). In such cases, it is common for knowledge from one part of a species' range to be applied to conservation planning in a less-studied location, or ecological theory may be leveraged to make broader inferences from correlative studies (Murphy & Weiland, 2014 Relative likelihood = exp (−0.5 × ΔAIC c ), the likelihood ratio of the given model to the top model c AIC c = AIC corrected for small sample sizes.…”

Dietary assessment of age-0 pallid sturgeon and shovelnose sturgeon: implications for surrogacy

“…Given the extremely limited diet data available for wild age-0 pallid sturgeon throughout the species range (Gosch et al 2016 and the relevance to current recovery efforts, these new captures are critical for documenting wild age-0 pallid sturgeon prey use and further evaluating potential diet surrogacy with shovelnose sturgeon during the critical transition from endogenous to exogenous feeding. A fundamental tenet of surrogate validation is establishing that both species respond similarly when subjected to the same environmental conditions (Murphy & Weiland 2014). Unlike 2014, each age-0 pallid sturgeon was concurrently captured with multiple shovelnose sturgeon individuals during 2018.…”

A systems approach to ecosystem adaptive management : a USACE technical guide

“…Direct measures and environmental-condition indicators that are efficient at detecting effects of management actions should be identified. Where monitoring uses surrogate or proxy measures, those indicators should be subject to a validation process describing the similarities in responses of the surrogate and target measures to the same environmental phenomena, and describing the accompanying uncertainties (Murphy and Weiland 2014b). In addition, it is necessary to establish detection limits for the variables to be measured and condition indicators that are employed, and contingent decision values must be identified (thresholds or trigger points) for direct measures or indicators that have been validated.…”