The letter in its entirety is provided below.
The Honorable Sally Jewell
U.S. Department of Interior
1849 C St., NW
Washington, DC 20240
The Honorable Dan Ashe
U.S. Fish and Wildlife Service
1849 C St., NW
Washington, DC 20240
RE: Protect the Florida Manatee by Maintaining Classification as Endangered
Thank you for the opportunity to relay our concern for the endangered West Indian Manatee, including its subspecies, the Florida Manatee and the Antillean Manatee as it relates to the "Petition to Reclassify the West Indian Manatee From Endangered to Threatened" to the U.S. Fish and Wildlife Service (FWS) filed by the Pacific Legal Foundation (PLF). The PLF argues in favor of taking the Florida Manatee off the endangered species list and demoting its classification to "threatened" under the federal Endangered Species Act. We strongly disagree with the PLF and urge you to maintain the Florida Manatee's classification as "endangered", a classification that is clearly required under current environmental conditions and the law.
We understand that the FWS has not conducted its required Five Year review or any other study that substantiates the need for a reclassification from "endangered" to "threatened". Although a previous 2007 FWS 5-Year Review of the West Indian Manatee suggested downlisting the species to threatened, FWS rightly did not change the classification. The flawed analysis contained in that report has become more obvious in the years since it was published. Manatees were originally included on the federal endangered species list in 1967 due to dire threats from pollution, loss of habitat and speeding boats. All of these threats have grown since that time. The FWS was right not to downlist manatees in the past and has no legal or scientific basis to do so now due to the new and ongoing threats to manatee habitat. The FWS must maintain the manatee's endangered status to ensure the best protections moving forward.
As evidence of just how tenuous a situation exists, compare the last four years of manatee mortality (2010-2013) to the previous four years of mortality (2006-2009). Documented manatee deaths have increased nearly 63% on average since the last status report was released. At the same time, manatee populations appear to be on the decline in the last five years. The most recent synoptic survey of manatees in 2014 by the Florida Fish and Wildlife Conservation Commission found fewer than 5,000 manatees in Florida waters, continuing the downward trend in population since the 2010 survey. Meanwhile, we trust that you can see through the PLF's cited 2001 study that contended that there was "virtually no real probability" of manatees going extinct in the next century. Press reports have confirmed that state and federal biologists debunked that study, for which a pro-boating group paid $10,000 to an environmental consultant who specialized in dock permits for developers.
One of the criteria for listing a species as endangered is "the present or threatened destruction, modification, or curtailment of its habitat or range." There is little doubt that the habitat of the Florida Manatee is under extreme threat of destruction, modification, and curtailment. As a marine mammal, the manatee relies on a healthy aquatic ecosystem for its survival. Critical water issues, such as pollution from storm water runoff that leads to the formation of harmful algal blooms such as "brown tides" and "red tides," plague Florida waterways. Such threats contributed significantly to massive seagrass losses and the record deaths of 830 manatees in 2013. Red tide alone killed 276 manatees in 2013 while an unknown toxin related to ecosystem collapse in the Indian River Lagoon killed over 110 manatees. With red tide claiming record numbers of manatees last year and the cause of the Unusual Mortality Event (UME) in Brevard County still unknown but believed to be linked to the loss of more than 47,000 acres of seagrass through a series of events that began in 2010 (when a record number of 766 manatees were confirmed to die from cold stress and other factors), Florida Manatees are under siege from new and nefarious threats.
Meanwhile, reckless vessel activity in Florida waters continues to cause harm to manatees, along with entanglement in fishing gear and entrapment and crushing in water control structures. While many initiatives have been put in place by the FWS and its state partners during the 47 years that manatees have been listed as an endangered species, the agencies have not managed to safeguard the manatees' habitat, as evidenced by the previously mentioned large scale mortality events from cold stress, red tide and UME events, along with other seagrass losses, stormwater runoff issues, other point and nonpoint source pollution, and habitat losses due to coastal development. Other uncontrolled factors, such as the future loss of artificial warm water sources and the over pumping of our aquifer that is endangering critical natural winter warm water springs habitat, continue to place the survival of manatees at grave risk.
We urge the FWS to stand up to special interests who wish to see protections removed for manatees at a time when the threats against the species are growing. The Florida Manatee's endangered status has allowed the species to advance on the road to recovery, but the threats to its habitat are still too great to warrant a change to its listing status at this time without dire consequences.
U.S. Representative - Florida
U.S. Rep. Kathy Castor (FL-14)
U.S. Rep. Corrine Brown (FL-5)
U.S. Rep. Debbie Wasserman Schultz (FL-23)
U.S. Rep. Alcee L. Hastings (FL-20)
U.S. Rep. Frederica Wilson (FL-24)
U.S. Rep. Theodore Deutch (FL-21)
U.S. Rep. Patrick Murphy (FL-18)
U.S. Rep. Alan Grayson (FL-9)
U.S. Rep. Joe Garcia (FL-26)