The National Canada Lynx Survey

As you may know, shortly after this story broke, several prominent members of Congress demanded a full investigation of this incident claiming that it "threatened the very economy of rural America". It is now under investigation by the GAO, the USDA Inspector General, and other Congressional entities.

Comments

I am writing to you today because as a voter and concerned citizen, I am deeply worried about the impact this incident may have on the future of the lynx and current efforts to save it. Though I believe firmly that this incident should be investigated, I have deep concerns about the objectivity of the investigations currently being conducted—particularly those that are being overseen by some members of Congress with a history of anti-environmental views. Since this story broke, I have been following it in various popular forums and newsgroups. From popular accounts right up to Congressional commentary, I have observed a general carelessness with facts on the part of critics of the ESA and NCLS. As a result, I fear that these investigations may have become witch-hunts rather than serious inquiries. The following examples should illustrate my concerns,

• NCLS critics have repeatedly claimed that the false hair samples in question were planted in the National Forest survey regions when in fact the samples were taken from other locations (including a stuffed bobcat owned by one of the technicians) and sent directly to the CCGL lab. This may seem like a minor distinction (it is), but it is exemplary of their frequent carelessness with details and their unfamiliarity with the basic NCLS protocols, which they appear not to have bothered to learn.
• NCLS critics have repeatedly referred to the people who were responsible for the false samples as "scientists" or "biologists". In fact, they were non-technical field personnel. Most had only bachelor's degree level training, if anything, and they were certainly NOT scientists or professional large predator biologists. As mentioned above, the NCLS protocols were specifically designed to be consistently and repeatably implemented by non-technical personnel who followed specifically spelled out guidelines.
• NCLS critics claim that this was a deliberate attempt to falsify the NCLS data for political reasons. Yet they routinely ignore facts that are inconsistent with such motives. It is clearly stated in the NCLS protocols that every sample must come from a predetermined location with a specific Site Number. The false samples in question however, were deliberately reported as having not come from one of these sites (WDFW, 2001)—a fact that would be immediately noticed by the survey's principle investigators. Why would someone trying to sneak false data into a study have done something like this? Why would they keep written records of this activity at their work desks—the first place an investigator would look if the incident ever became public? And for heaven's sake, why would they actually tell their supervisors what they were doing? Such behavior, however unprofessional, is NOT consistent with a desire to secretively skew a survey for any "higher agenda".
• NCLS critics repeatedly relate this incident to the 1998 Weaver survey. One member of the Washington State Legislature even told me in a personal e-mail that, "a central theme of the chain of events is the distrust of the 1998 Weaver lynx survey of the Cascades". He said that there is great concern over whether falsified samples were part of that study, claimed that the USFS had never explained to him or to its field technicians how the NCLS would be more accurate and that he was requesting the GAO to investigate. But as was pointed out previously, the GAO had already investigated the Weaver survey and ruled out tampering (GAO, 2001). The lessons learned from the Weaver incident and demonstrations of the NCLS's improved accuracy have already been provided (McKelvey, 2002). The protocols for hair gathering and mtDNA analysis have been blind tested, verified against existing mature data, and peer-reviewed, and are published (Mills et al., 2000; Mills, 2002; Schwartz et al., 2002; McDaniel et al., 2000; McKelvey, 2002). Regarding the education of field technicians, there is no need for them to know details of the design and effectiveness of the protocols involved since they were designed to be consistently and reliably implemented by non-technical personnel to begin with (McKelvey, 2002). None of this information appears to have been consulted, though any reasonable search should have turned it up.
• NCLS critics (including the Washington State legislator mentioned above) have repeatedly claimed that the Threatened listing for Lynx canadensis in the ESA was based on the Weaver study. However, the listing report clearly cites the Weaver survey as "preliminary data only" and states that it played little role in the decision to impart Threatened status (USFWS, 2000; Federal Register, Vol. 65, No. 58). Once again, this information is also easily obtainable in the public domain, yet appears not to have been consulted.
• There is an extensive amount of peer-reviewed science on the ecology and conservation of Lynx Canadensis that underscores the need for studies like the NCLS (see the references below, which I might add are by no means complete). Most of it is easily available online or from various libraries and academic databases. Yet despite this, I have seen few if any attempts on the part of NCLS critics to investigate any of it, and many of them are citing this incident as proof that the NCLS and the ESA need to be drastically rolled back or even eliminated. The original WT article makes no reference whatsoever to any science, peer-reviewed or otherwise. A few remarks were made about the NCLS being "rigged from the word go" and "full of bad biology and bad politics", but no scholarly citation or corroborating evidence of any kind was offered in support of this. The only supporting commentary provided came from representatives of the National Wilderness Institute (NWI). A check of their root URL (www.nwi.org) reveals them to be a Property Rights and Resource Use advocates group whose board of directors reads like a who's who of the ultra-conservative Wise Use Movement. While there is nothing wrong with this in itself (these interests are certainly entitled to their views and a forum to express them), they can hardly be called objective scientific sources. Furthermore, I have been in contact with state and federal policy makers who are highly critical of the NCLS and the ESA regarding this matter, and in every case their comments appear to have been based only on the WT's account and carefully selected portions of the USFS inquiry—virtually never on peer-reviewed scientific sources. I have even offered to provide such science to these individuals directly (abstracts and/or full text journal articles such as the ones listed below), but to date no one has accepted my offer. This widespread neglect of established peer-reviewed science is disturbing.
• It has been repeatedly claimed by the Washington Times and some members of Congress that if the falsified hair samples had not been exposed, entire regions of national forest would have been closed to all economic and recreational activity and "threatened the very economy of rural America". There would be "carte blanche to go after ski resorts, stop road building and go after ranchers and tree cutters" (Washington Times, 2001). Yet as has been shown, the NCLS includes a Follow-Up Confirmation phase. All positive sightings in areas not known to have populations of Lynx Canadensis are to be verified with extensive protocol controlled snow tracking. Without this confirmation, the presence of Lynx Canadensis would not be considered verified and further action would not be warranted. The NCLS has already identified two other populations of Lynx Canadensis in areas where it was not thought to exist (the Boise and Shoshone National Forests) and this follow-up plan is in fact currently being implemented in both locations (McKelvey, 2002). Furthermore, proposed conservation plans for Lynx Canadensis in areas where it is known to exist involve a wide range of contingencies with varying impacts and there is no reason to assume that the total and complete shutdown of all economic and recreational activity will necessarily be involved (Ruediger et al., 2000; Seattle PI, Dec. 18, 2001). Yet again, critics seem to have assumed outright that the most extreme possible options would be implemented with little or no attempt to consult any of this information.



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