"Earthjustice supports the Fish and Wildlife Service's proposal to list polar bears as threatened under the Endangered Species Act, and we applaud the Service's science-based determination that global warming presents a serious threat to the continued survival of the species.
"The Service correctly reports that global warming has weakened polar bears' physical condition and inhibited polar bears' reproductive success and ultimately their survival. The scientific literature supports the Service's conclusion that as warming temperatures cause further sea-ice retreat, these adverse effects will worsen, resulting in precipitous declines in polar bear populations. Recent evidence showing not only declining populations, but also alarming signs such as cannibalism and drowning, demonstrates the urgency behind this proposal to list the species.
"We applaud the Fish and Wildlife Service for recognizing that polar bears face a severe threat from the loss of sea ice. Before finally listing the polar bear, however, we encourage the government to fully account for the loss to and damage of polar bear habitat due to the combination of global climate change and oil and gas development in the Arctic, as part of a cumulative review of all factors that contribute to the destruction of polar bear habitat.
"We also ask the Service to rethink its decision to define the 'foreseeable future' in the polar bear listing proposal as just forty-five years. The scientific community typically conducts population viability analyses over a time frame of one-hundred years or longer. For example, the National Marine Fisheries Service employed a one-hundred year time frame to assess threats when listing the Steller sea lion, a species which has a similar life-history to polar bears, but a far shorter reproductive interval. We urge the Service to employ a time frame of at least one-hundred years in reaching a final decision to list polar bears.
"Finally, Americans understand that you cannot protect a species without protecting the places it calls home. We are pleased that the Service has thoroughly chronicled polar bears' dependence on sea-ice, which always has been a dynamic habitat. We strongly urge the Service to designate critical habitat at this time in order not only to comply with the Endangered Species Act, but more importantly to ensure the continued existence of polar bears. At the very least, critical habitat should include all areas of the Chukchi, Beaufort, and Bering Seas that are seasonally covered by sea-ice, as well as coastal areas that offer potential denning habitat, and those which are used by polar bears during the open water period for movement, feeding and resting.
"Thank you for this opportunity to speak. In light of the serious threats to the polar bear's sea ice habitat, Earthjustice applauds the proposals to list the polar bear under the Endangered Species Act, and hopes that this important listing is finalized as soon as possible."
 62 Fed. Reg. 24345, 24346 (May 5, 1997).
Clayton Jernigan, Earthjustice, (907) 586-2751