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Noonday Snail: "Essentially nothing is known about the snail's biology," "No estimates of population size have been made since the exact range has never been determined."

Palos Verdes Blue Butterfly: "The historical distribution of the butterfly is unknown..."

Painted Snake Coiled Forest Snail: "Information on the snail's ecology and natural history is almost completely lacking.”

Price's Potato Bean: "It is very likely that undiscovered populations of A. priceana exist...”

Puerto Rican Boa: "A lack of population estimates prevents reaching conclusions regarding the status of the species."

Red Hills Salamander: "Comparative data relating temporal trends in population densities are unavailable..."

Virginia Fringed Mountain Snail: "Almost nothing is known about the numbers, population dynamics or reproduction of P. virginianus..."

Virgin Islands Tree Boa: "Population trends cannot be determined because of lack of data," "lack of available information on this secretive, nocturnal snake precludes formulation of a quantitative recovery level."

In at least 79 of the 306 plans reviewed there was some degree of uncertainty regarding the taxonomic classification of an endangered plant or animal.

B. Plans often call for additional laws and regulations or the
employment of legal tools other than the Act

Of the 306 plans reviewed in this study, at least 51 called for or suggested that additional laws or regulations be considered to protect a particular species. Numerous plans called for the application of other laws such as the Clean Water Act or consideration for the application of other federal laws such as designating a Scenic River to protect a species. Additionally, numerous plans called for encouraging, requesting or otherwise influencing state or lower level governmental entities to pass regulations, employ other laws or enforce ordinances, such as zoning laws, as a tool to protect listed species.

Examples:

Cumberland Monkeyface Pearly Mussel: "Investigate the use of Scenic River Status, mussel sanctuaries, land acquisition..."

Florida Golden Aster: "Arrange for protection of land through ownership, cooperative agreements with landowners or other legal measures.”

Key Tree Cactus: "Local ordinances should be employed to prevent taking from non-federal lands."

Painted Snake Coiled Forest Snail: "The species cannot be fully secure without some control of land use in the cove." "If landowners are not in agreement, investigate other options for protecting habitat."

Blunt-Nosed Leopard Lizard: "Use zoning process and ordinances."

Swamp Pink: "In addition, the enforcement capability of existing regulations will be strengthened where possible, and nontraditional avenues for endangered species protection that may benefit Hdonias (through wetlands legislation, soil erosion control requirements, etc.) will be investigated."

C. Recovery Plans often conflict with the definition of "conservation"

in the Act by stating that recovery is unlikely or impossible

The Endangered Species Act defines "conservation" as the use of all methods and procedures necessary to bring listed species to the point at which the Act's protection is no longer needed. FWS states that, "The principal goal of the U. S. Fish and Wildlife Service and the National Marine Fisheries Service is to return listed species to a point at which protection under the Act is no longer required." Several recovery plans, however, conclude that delisting is unachievable or even not “desirable.”

Examples:

Cave Crayfish: "Due to the apparent limited potential for discovering new populations, the delisting objective may never be attainable."

Florida Scrub Jay: "Because of the extreme usefulness of the Act in this case, it is not desirable to remove the scrub jay from protection under the Endangered Species Act." "There is no anticipated date of recovery because it may never be feasible to delist this species."

Mexican Wolf: "...the Mexican Wolf Recovery Team sees no possibility for complete delisting of the Mexican wolf."

Red Hills Salamander: (delisting] "may not be attainable within the foreseeable future because of the animals small range..."

Ring Pink Mussel: "Total recovery is not thought possible."

Spikedace: "Protection of existing population. Eventual delisting, if possible."

Tar River Spinymussel: "Though the ultimate goal is to recover the species to the point where it can be removed from the Federal List of Threatened and Endangered Wildlife and Plants, full recovery of the Tar River Spinymussel may not be possible."

Tuberculed-Blossom, Turgid-Blossom & Yellow-Blossom Pearly Mussels: “it is highly improbable, if and when living specimens of any one of the three subject species are found that... the species can ever recover to the point of delisting."

White Cat's Paw Pearly Mussel: "...recovery to the point where the species no longer requires protection under the Act is unlikely."

Examples:

D. Plans often have criteria for "delisting" or "downlisting"

which appear unattainable

Iowa Pleistocene Snail: "With a return to glacial conditions it will be resuscitated over the major part of the upper Midwest, provided its relictual areas are preserved and maintained..."

Mount Graham Red Squirrel: “...at least 100 to 300 years will be necessary to restore Mount Graham red squirrel habitat."

Stock Island Snail: "Although no estimates of historical population sizes are available, the extant population is presumed to have been moderately stable in the recent past because its present habitat has been stable... for the last 40 years... 4.8 acres." Recovery criteria called for expanding the snail's population from the only known 4.8 acre habitat to 20 acres and establishing 30 new populations. "Hopefully the 'recovered' population would then be able to withstand the major stress of a severe hurricane."

Utah Prairie Dog: "To establish and maintain the species as a self-sustaining, viable unit with retention of 90 percent of its genetic diversity for 200 years."

E. Plans often call for large scale habitat purchase

Of the 306 plans reviewed, at least 184 call for purchase or 'securing' of property for endangered species. Examples:

Blunt-Nosed Leopard Lizard: " A current target acreage figure of 30,000 acres has been established for the San Joaquin Valley floor, with acquisitions emphasis on optional habitats containing high density blunt-nosed leopard lizard (BNLL) populations in identified "priority" habitat areas... conflicting land users will be reduced or eliminated in an effort to restore habitat to optimal condition. Consideration for delisting would be appropriate when similar objectives have been obtained for adjacent foothill and plain areas known to contain BNLL populations."

Eastern Indigo Snake: "two 10,000-acre tracts recommended for acquisition: one in GA, one in FL."

Loggerhead Turtle: Recovery criteria require that "25% of all available nesting beaches (560 km) is in public ownership..."

NOTES FROM SELECTED RECOVERY PLANS

(DOLLAR FIGURES MENTIONED IN THIS SECTION ARE NOT ADJUSTED FOR INFLATION)

Common Name: Alabama Lamp Pearly Mussel, invertebrate

Scientific Name: Lampsilis virescens

Taxonomic Status: Species

Recovery Plan Goal: Delisting

Notes: None of the plan's 17 tasks have a cost estimate, including: “Determine... present distribution and status," "Implement reintroductions," "Locate suitable sites" and "Conduct life history research." The plan states: "Other aspects of the ecology of this species are totally unknown," and "The historically restricted distribution of L. virescens and lack of information about changes in various stream populations prevents a more precise determination of the reasons for the species decline."

Common Name: American Crocodile, reptile

Scientific Name: Crocodylus acutus

Taxonomic Status: Species

Recovery Plan Goal: "Due to the nature and the extent of the threats to the crocodile, complete delisting may never be possible." Reclassification to threatened is the "long term objective." Notes: Fifteen of the plan's 36 tasks have no cost estimate, including "Acquire suitable habitat." The plan states: "[Crocodylus acutus] reaches its northern range limit in southern Florida," "Little is known of American crocodile's behavior pattern or daily and seasonal activity patterns," and "The numbers of crocodiles in South Florida during the late Nineteenth Century is unknown, although it seems likely it was not a common animal." The plan attributes decline to two human activities, habitat alteration and direct disturbance of crocodiles or their nests. However, the plan states that known human-related mortality from 1971 to 1982 totaled 24 deaths, while 15% of nests in Florida Bay were destroyed by raccoons in the period 1970 - 1974." The plan also states, "The effects of commercial and sport fishing on crocodiles are unknown....," while one task includes "regulate commercial fishing in high mortality areas," "Regulate sport fishing, camping, boating and other public use of nesting areas during nesting season," and "Current human-related factors are clearly unnatural..."

Common Name: Arkansas Fatmucket, invertebrate

Scientific Name: Lampsilis powelli

Taxonomic Status: Species

Recovery Plan Goal: Delisting

Notes: According to the plan, "It is not possible to determine costs beyond the first few years. Cost estimates for the tasks to be conducted over the next three years total $528,000." $200,000 is dedicated to developing a life history.

Common Name: Atlantic Green Turtle, reptile

Scientific Name: Chelonia mydas

Taxonomic Status: Species

Recovery Plan Goal: Delisting in the US

Notes: Plan statements include: "More information is needed before detailed distribution maps or estimates of population number and structure can be made..." and "The number of nests deposited in Florida appears to be increasing, but whether this number is due to an increase in the number of

nests or more thorough monitoring of the nesting beeches is uncertain." According to the plan, egg clutch counts totaled 736 in ‘85,350 in ‘86, 866 in '87, 466 in ‘88, 559 in '89 and 2,288 in '90; however, the area of beach measured varied. The ratio of clutches per kilometer surveyed was 0.56 in '86, 1.05 in '87, 0.47 in ‘88, 0.60 in ‘89, and 2.26 in '90. Criteria for recovery include 5,000 nests for 6 years and public ownership of 25% of all nesting beaches encompassing greater than 50% of total nesting activity. Plan tasks include prosecution of “individuals or entities responsible for hatchling disorientation." Hatchlings are believed to be disoriented when they see artificial lights from cars, houses, street lamps, etc. The plan includes coastal development, commercial fishing and marine pollution as major causes of decline but also includes such things as "pedestrian tracks can interfere with the ability of hatchlings to reach the ocean... [as do] physical objects such as beach chairs..." However, the plan also states that raccoons "may take up to 96% of all nests deposited on a beach."

Common Name: Black Lace Cactus, plant

Scientific Name: Echinocereus reichenbachii albertii

Taxonomic Status: Subspecies

Recovery Plan Goal: Delisting

Notes: The plan states, "The populations all appear to be healthy and reproducing well.”

Common Name: Cave Crayfish, invertebrate

Scientific Name: Cambarus zophonastes

Taxonomic Status: Species

Recovery Plan Goal: "Due to the apparent limited potential for discovering new populations, the delisting objective may never be attainable."

Notes: The task to "protect identified properties" has no cost estimate. The plan states, "Sufficient data to estimate population size or trends is lacking."

Common Name: Chittenango Ovate Amber Snail, invertebrate

Scientific Name: Succinea chittenangoensis

Taxonomic Status: Species

Recovery Plan Goal: "To protect and ensure maintenance of the self-sustaining colony... at Chittenango Falls. Due to its extremely limited range, delisting may occur only as a result of verification of at least five additional self-sustaining colonies of these species..." Notes: The plan states, "...an electrophoretic determination of the genetic distance between S. chittenangoensis and S. ovalis is justifiable, and will help determine the genetic viability and heterozygosity of the population, as well." The plan also states, "Trampling of the snail habitat and the snails themselves [by visitors to Chittenango Falls State Park] has been identified as a major threat." Recovery tasks include: "Restrict access of park patrons to the population and the habitat" and "Increase surveillance of patrons and enforce rules to keep them off falls." $24,500 is earmarked for "limiting access to Falls."

Common & Scientific Names: mammals

Choctawahatchee Beach Mouse, Peromyscus polionotus ammobates

Perdido Key Mouse, P. p. trissyllepsis

Alabama Beach Mouse, P. p. allophrys

Taxonomic Status: 3 Subspecies

Recovery Plan Goal: Downlisting

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