Endangered Species Law & Policy

On February 28, 2023, I published a post on the Center for California Water Resources Policy and Management’s DeltaCurrents blog discussing Species Status Assessments (SSAs) as a tool to facilitate implementation of the federal Endangered Species Act (ESA). The U.S. Fish and Wildlife Service (Service) describes the SSA framework as “an analytical approach developed . . . to deliver foundational science for informing all [ESA] decisions.” The Service has explained it intends SSAs to provide “focused, repeatable, and rigorous scientific assessment” that results in “improved and more transparent and defensible decision making, and clearer and more concise documents.”

The Service overhauled its guidance on the preparation of SSAs in 2015 and 2016. At that time, in many respects, the guidance referred to as the SSA Framework reflected best practices in conservation biology. That said, several years of experience have identified ways in which the SSA Framework can be improved. In the blog post, I reference the longfin smelt SSA as a case study to demonstrate ways in which the SSA Framework can be strengthened, providing four specific recommendations:

• Make explicit the expectation that agency staff will include in each SSA a conceptual ecological model(s) developed consistent with best practices in conservation planning. Models should describe environmental drivers acting on the target species and its habitat, ecological factors that affect the species’ population size and distribution, and potential management actions that can be expected to contribute to its recovery.
• Instruct agency staff to identify a range of alternative probable future scenarios that reflects the reasonably foreseeable range of environmental conditions and conservation efforts that are anticipated to influence the target species’ population dynamics and the extent and condition of its habitat.
• Recognize and elaborate on the range of available tools and methods to model and assess the current condition and predict future condition of the target species’ population(s).
• Require an independent scientific (peer) review of each SSA, incorporate best practices with respect to that review, and in the final SSA respond to all expert input and feedback presented in the review.