Geocarpon minimum anchors the specialized glade ecosystems where it grows, stabilizing fragile soils and supporting unique plant communities that exist nowhere else on Earth. Climate change now threatens the moisture and temperature conditions these ecosystems require. Scientists have documented how climate shifts alter plant diversity, species phenology and distribution, and extinction risk. Localized weather pattern changes bring more frequent and longer-lasting droughts, while warming temperatures accelerate the spread of non-native species. Changes in dought cycles and rising air and soil temperatures affect seed set, germination, and overall fitness of Geocarpon minimum, yet the proposed rule inadequately accounts for how these mounting pressures will impact the species’ long-term survival.
Diving into this project required our team to carefully examine both the scientific evidence and legal framework surrounding species delisting. We analyzed population data, climate models, and threat assessments while tracing the legal requirements from the Endangered Species Act, relevant case law, and federal agency guidance documents. The process revealed how crucial it is to integrate rigorous scientific analysis with legal scrutiny when evaluating federal agency decisions that affect imperiled species.
The proposed delisting would remove federal protections for Geocarpon minimum, a tiny plant found only in specific glade habitats in Arkansas and Missouri. The proposed rule asserts that the species has recovered sufficiently to warrant delisting, citing improved population counts and reduced threats. However, our team found significant gaps in this analysis that raise serious concerns about whether the species has truly recovered and whether ongoing threats have been adequately addressed.
Our comment focuses on two overarching gaps in the Agency’s proposal. First, we assert that the Fish and Wildlife Service failed to demonstrate true recovery of Geocarpon minimum. We discuss how improved detection of the species does not equate to population growth, and that analyzing population growth using peak population counts rather than multi-year trends can misrepresent the plant’s true population size.
Our second main challenge to the proposed rule is a failure to adequately account for ongoing and future threats to the population. Within this, we determined that the proposed rule incorrectly used a land use model for climate predictions, ignored extreme events, and avoided modeling uncertainty. Additionally, feral hog populations pose a serious threat to the plant’s soil quality and can uproot Geocarpon minimum, and the Agency provided little evaluation of how these hogs are increasingly encroaching on Geocarpon minimum's habitat or how warming will make these habitats more suitable for feral hogs. Similarly, there is evidence of worsening invasive vegetative encroachment into the plant’s habitats, which was also addressed in the proposed rule with little analysis of its risk. All in all, while the agency acknowledges threats to Geocarpon minimum, we conclude that the proposed rule failed to use the best available science to account for their future impacts, and whether there are sufficient regulatory mechanisms in place to protect Geocarpon minimum and its habitat, were it delisted.
The Endangered Species Act requires that a species undergo both threat reduction and population recovery in order to justify delisting. Our team concluded that the Fish and Wildlife Service did not meet these legal standards for delisting the species, as it failed to use the best available science.
We are all proud to contribute to the Environmental Law and Science Changemaker Program’s third comment and are excited to see the impact of our work. We believe that our contribution to notice-and-comment rulemaking has the potential to create a positive impact on our environment, and we look forward to what is to come!
