Date: 11/25/21 10:49 am
From: Thomas Foti <tfoti62...>
Subject: IBWO Delisting-Extinction
There is good, but maybe not yet compelling evidence for the persistence of IBWO in LA. I reproduce below a statement to FWS that may begin the dialog to delay the delisting.

from The National Aviary https://www.aviary.org/

The National Aviary submits the following comments to the U.S. Fish and Wildlife Service on the proposed delisting of the Ivory-billed Woodpecker.

Since 2018, the National Aviary has been actively engaged through Project Principalis in an organized and sustained search for the Ivory-billed Woodpecker at a study area in Louisiana. Our search includes boots on the ground, more automated recording units than ever used in any previous search, significant numbers of trail cameras, and drones. We have used machine learning to produce models that sort through hundreds of thousands of hours of recorded calls, and we have developed novel environmental DNA protocols to test biological samples. Our effort is intensive and sustained. It is also unique; as far as we know, there are no comparable searches, public or private, for this species. But our search has been rewarded; we have seen and heard enough to be firmly convinced that the species persists in our study area.

In our judgement, declaring the Ivory-billed Woodpecker extinct further threatens the species and its conservation.

Before delisting the Ivory-billed Woodpecker, Project Principalis encourages a thorough review of the Service’s files and sources, which include reports from credible ornithologists and scientists. The Ivory-billed Woodpecker Recovery Plan, which was prepared by the USFWS and completed in 2010, contains a detailed compilation of reports of the Ivory-billed Woodpecker, including approximately 100 reports of varying quality between 1944 and 2003. Some of these are aggregates, involving multiple observations. The number of observations is sometimes enumerated and sometimes characterized as "numerous", "multiple", or "several", so it is impossible to arrive at an accurate tally, but the total almost certainly exceeds 150 or 200.
Perhaps more importantly, the Recovery Plan was written in response to a video and associated sightings of a purported Ivory-billed Woodpecker in Arkansas in 2004-2005. That finding by the USFWS - that an Ivory-billed Woodpecker was present in Arkansas in 2004 - has not been reversed. Good conservation science should take into consideration the hundreds of reports since 1944 and the Recovery Plan based on the summation of the 2004-2005 records.

There is a climate of disbelief, if not discouragement, that has prejudiced other reporting of the Ivory-billed Woodpecker. Sightings of the species are frequently met with incredulity and disbelief, and there is good reason to accept that countless reports from local people, hunters, amateur birders, and citizen and community scientists have been overlooked by authorities. Individuals, especially those who have sight reports, which are not considered “objective evidence,” may already feel discouraged from bringing their sightings and observations forward. While a degree of professional scrutiny is important in evaluating the legitimacy of reports from community members, those same reports have the potential to yield productive information that
could lead to credible evidence. Delisting will further discourage and discredit future reports that could be critical to new research.

Aside from surveys of potential habitat for Ivory-billed Woodpeckers, modern searches have not been based on a systematic approach to finding the species. Instead they have been either perfunctory with no chance of verifying a report, or massive, intensive, and sometimes disruptive attempts to follow-up on the rare report that is considered credible. These searches have been reactive, not systematic, sustained, or hypothesis-driven. Given limited and often inaccurate understandings of the species’ natural history, and the difficulty in finding live birds even when they are known to be present, any modern search will have little chance of success, especially if the search is brief or disruptive. The lack of evidence from these efforts has reinforced the belief held by some that the species is extinct.

At Project Principalis our approach to verifying the presence of the Ivory-billed Woodpecker has been different. We use an organized, sober, consistent, and scientific approach, with an emphasis on a sustained presence in the field. We use new technologies, and committed field biologists willing to spend long hours on the ground. We are committed to the conservation of the Ivory-billed Woodpecker, bottomland forest habitat, and the flora and fauna that share the habitat. Our approach has yielded results, and we hope, data that will help render the species recoverable.
We have evidence from our study area from 2019-present that we think is compelling, suggesting that Ivory-billed Woodpeckers are, in fact, present in Louisiana. At this point we are not prepared to publicize the evidence as we have concerns for publication priority and the welfare of the birds. We request an opportunity to present some of our materials in a private, confidential setting to decision-makers involved in the delisting of the Ivory-billed Woodpecker.

To give up on the Ivory-billed Woodpecker now, when the evidence for persistence actually exists, would be tragic. In our view, maintaining the status quo is the prudent choice – scientifically, politically, and for the millions of bird lovers and conservationists in this country – as well as for the future of the Ivory-billed Woodpecker.

Dr. Steven C. Latta
Director of Conservation and Field Research
National Aviary
700 Arch St.
Pittsburgh, PA 15212

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