SOKD response to: 2022 USFWS SSA

SOKD provides USFWS habitat information for on-going 5-Year Status Review

After shelving its multiple drafts of a Species Status Assessment (SSA) aimed at potentially delisting or downlisting the Key Deer from endangered status, the US Fish and Wildlife Service has begun a new 5-Year Status Review. As part of this process, the USFWS has announced a Request for Information from the public, seeking input that could enhance the completeness and accuracy of the review. SOKD has responded to the request on 8/23/2021. Our response primarily focuses on two topics that were erroneous and/or incomplete in the previous SSA:

1) The inadequate analysis of present-day and future natural drinking water availability for the Key deer. 

2) The incorrect representation of post Hurricane Irma vegetation habitat available to the Key Deer.

Natural drinking water availability is vital to the future of Key deer but it has never been regularly monitored by the USFWS. The previous SSA used a data base of “water holes” compiled by a student in 1988 which SOKD has found, through our on-going water salinity monitoring project, to not at all reflect present-day fresh water availability conditions. As we explain in a recently released 2-year project summary report (which was attached to our response), many of the water holes listed in the 20+ year old data base either do not exist, are filled with salt water, are too saline for use by animals or are dry for much of the year. We also point out two additional errors in the past SSA’s analyses: First, as per our own monitoring results, many of the water holes that actually presently exist do not provide drinkable water year-round, especially during the dry season. We have found that especially after Hurricane Irma, some large parts of the Key deer habitat completely lack fresh water for part of the year and the deer living there become completely dependent on artificial (human) water sources. Second, future habitat modeling done in the past SSA considers loss of habitat due to sea level rise but incorrectly assumes available fresh water holes will be lost only after the surrounding area becomes submerged. Since many of the water holes are linked to underground fresh water lenses, and the lenses will continue to be compromised as sea water rises from below, the water holes will disappear long before their area actually submerges. Without drinking water, actual habitat loss will be quicker and larger than the SSA predicts.

For their habitat characterization and modeling, the USFWS SSA has used a vegetation cover data base of (to us) unknown origin and date, but very obviously pre-Irma. It does not reflect significant vegetation habitat losses and changes that in some areas continue to exist years after the hurricane. SOKD’s own Jan Svejkovsky (with colleagues from Florida International University) published a peer-reviewed paper in 2020 on the long-term effects of Irma on Key’s vegetation.  They utilized very high resolution satellite imaging to assess initial post-storm damage to the major vegetation classes, and documented their recovery trends for the following 1.5 years. They found severe long-term reduction in mangrove areas, many of which continue to lack mangroves into 2021. Since mangroves are one of the prime foods of the Key deer, it is incorrect to make habitat resource availability conclusions using old, pre-Irma vegetation maps that are no longer valid.

We welcome anyone with useful, documentable information on the present status of the Key deer and their habitat to respond to the USFWS Request for information. Full description and response instructions can be found at:

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