Public Comments Processing
Attn: Docket No. FWS-R2-ES-2018-0029 USFWS; MS: JAO/1N
5275 Leesburg Pike
Falls Church, VA 22041-3803
RE: Reclassifying the American Burying Beetle From Endangered to Threatened on the Federal List of Endangered and Threatened Wildlife with a 4(d) rule.
I am writing on behalf of the Association of Zoos and Aquariums (AZA) regarding the proposed reclassification of the American Burying Beetle (ABB) from Endangered to Threatened under the Endangered Species Act. We would like to associate ourselves with the comments submitted by Bob Merz, Zoological Manager of Invertebrates at the Saint Louis Zoo (an AZA-accredited institution) dated July 1, 2019. The concerns raised in that letter are consistent with those of the AZA…especially those related to the current capacity of zoo-based reintroductions for ABB survival in the wild. The Saint Louis Zoo letter states that, “While zoo-based reintroductions may, in the future provide a pathway for the recovery of this species, it is simply too early to consider reintroduction as a viable tool in the recovery of this species.”
AZA is a non-profit organization dedicated to the advancement of accredited zoos and aquariums in the areas of animal care and husbandry, conservation, education, science and recreation. AZA’s 239 accredited zoos and aquariums annually see nearly 200 million visitors, directly contribute over $23 billion to the U.S. economy, and support more than 208,000 jobs. AZA-accredited facilities spent over $220 million last year in support of field conservation efforts in more than 120 countries. AZA and its member facilities work in concert with Congress, the Federal agencies, conservation organizations, the private sector and the general public to conserve our wildlife heritage. Our collaborative efforts with USFWS have focused on endangered species recovery and reintroduction (black-footed ferrets, California condor, Mexican and red wolves, whooping cranes), multinational species conservation funds, state wildlife grants, wildlife refuges, migratory birds, freshwater fisheries, illegal wildlife trafficking and invasive species.
AZA members also have a strong commitment to conservation education and research. AZA has pioneered and established the afore-mentioned Species Survival Plan (SSP) program—a long-term plan involving genetically diverse breeding, habitat preservation, public education, field conservation and supportive research. SSP’s were developed by AZA in 1981 to oversee population management of select species through a variety of conservation, research, husbandry, and education initiatives within AZA member facilities and conservation partners and to enhance conservation of the species in the wild. Today, there are nearly 500 AZA SSPs under 46 AZA Taxon Advisory Groups….including the American Burying Beetle.
Echoing the Saint Louis Zoo’s letter, we greatly appreciate the hard work that the USFWS staff has put into the reclassification proposal and the supporting Species Status Assessment for the ABB, however we too, believe that it would be premature to down-list the beetle to threatened status until further genetic assessments, reintroduction assessments and current range surveys are completed.
Thank you for the opportunity to comment and we look forward to working with you and your dedicated staff in the future on this and many other fish and wildlife conservation initiatives.