The Grand Portage Band of Lake Superior Chippewa is strongly opposed to listing moose under the Endangered Species Act (ESA).
Although moose populations have declined in Minnesota. The ESA is reserved for species that need urgent protection to prevent impending extinction. Self-sustaining populations of moose are found in the Midwestern states petitioned for listing and populations are not at critical levels that require additional protections.
It must be made clear that the group titled Honor the Earth (co-petitioner) is not a tribal government and does not represent the views of members of Midwestern tribes or any governments of federally recognized tribes. This organization implies that it represents tribal views to romanticize the idea of protection for moose and employs a deplorable tactic designed to generate support from a naïve public.
Protection under ESA will have little protective benefit to moose. In the affected Midwestern states, state and tribal agencies have managed the harvest of moose to help restore populations and determines factors affecting population status. The management agencies are accomplishing their role in protection without the need for federal oversight. Management agencies are already demonstrating that they can, and are, taking steps to monitor and actively manage for moose – something that listing under ESA will not enhance, and in fact will hinder management efforts, and in some cases prevent management some options altogether.
Listing under the ESA will severely impact the rights to subsistence that have been preserved by treaty. Indian tribes have reserved the rights to hunt, fish and gather on reservation lands and in ceded territories. While the federal government has a trust responsibility to ensure the viability of natural resources on those lands, unnecessary listing of species removes those rights, usurps tribal management authority that never was relinquished, takes away the ability to subsist, and destroys the cultural fabric of affected Indian tribes.
The petition for listing has numerous factual errors that it uses to justify enhanced protections for moose including the premise that logging and mining negatively impact moose populations. Logging is actually a preferred habitat management strategy to produce the young forest required to sustain healthy moose populations. In fact, our ongoing monitoring and research conducted by tribal staff clearly shows that moose in Minnesota are taking advantage of disturbances and the resulting forage regenerated by logging, fire and similar management activities – in some cases designed specifically for moose, in others as a beneficial byproduct of activities conducted for economic reasons or reduction of fuel loads. Regional mining also is one of the justifications used to support the idea that moose need federal protection. While the Grand Portage Band of Chippewa has significant concern over the environmental impacts of mining and there may be small, localized disturbances to moose habitat, there is no evidence to support negative impacts of historical mining on Minnesota moose at the population level.
The effect of listing moose will hinder rather than enhance moose management. Tribal and state natural resource management species have the authority, knowledge, capacity, expertise and infrastructure to manage moose populations. Listing species under the ESA effectively removes that capacity and puts the burden of management onto the federal government, which does not have the fiduciary or infrastructural capacity to manage natural resources. Moose populations in the Midwest are being actively managed by state and tribal agencies that have the capacity to research their populations and causative factors influencing recent declines. Protections under the ESA will remove management authority from the entities that have the capacity to accomplish the necessary work to restore populations, will add costly administrative burdens to accomplishing necessary work, and will impede natural resource management activities that produce moose habitat such as logging and prescribed burning.
The Grand Portage Band has invested heavily into restoration of moose in the Midwest and in the 1854 Ceded Territory. Our moose research and management has been nationally recognized, has resulted in peer-reviewed scientific literature, and has resulted in improvements in understanding the biology of the species and methods to improve moose populations. Our ability to continue this essential work to restore a culturally critical species would be severely restricted if moose are listed under the ESA.
For the reasons described above, and others that will be fully detailed in official consultation on the petition for listing by the Grand Portage Band of Chippewa, we assert that the protection of moose under the ESA is not warranted. In the next few weeks, we will submit the published literature, survey results, research summaries and descriptions of our management actions to improve moose habitat resulting from the Grand Portage Band’s moose management efforts.
Norman W. Deschampe
Tribal chairman,
Grand Portage Band of
Lake Superior Chippewa
The Grand Portage Reservation Tribal Council submitted this letter to U.S. Secretary of Interior Sally Jewell. Tribal Council Chairman Norman Deschampe shared it with the Cook County News-Herald’s editorial page.
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