"Endangered" matsutake......OR "junk science" run amok?

Eugene Wheeler greenenuf at yahoo.com
Mon Jul 16 00:28:37 EST 2001


Hi everyone:

This is a long post, so I am providing a summary for the
time-challenged.  Others will probably want to read the rest of the
message.  If you are concerned (and you should be) please feel free to
forward to other electronic forums or organizations. (Readers of the
agroforestry group should also note that several other plant species
commonly gathered and sold as "special forest products" are also
included in this proposal including cascara, blue cohosh, black
cohosh, ironwood, bloodroot and a variety of mosses.  I have appended
the relevant text regarding these other species from the Federal
Register announcement at the end of this message.)


SUMMARY: On June 12, 2001 the US Fish and Wildlife Service (FWS)
posted a notice in the Federal Register (page 31689) regarding listing
the American matsutake mushroom (Tricholoma magnivelare) in Appendix
II of CITES, the Convention on International Trade in Endangered
Species.  It appears that the proposal is being pushed by the National
Park Service (NPS) because they have a problem with poaching of
matsutake in some NPS units in the northwestern US.  It appears to be
an effort to prevent poaching by making ALL trade in T. magnivelare
illegal NO MATTER WHERE they were actually obtained.  There is NO
scientific evidence whatsoever that T. magnivelare is actually
endangered ANYWHERE in its range and this listing appears to be a
classic example of what has come to be known as "junk science".  It is
an audacious attempt to misuse endangered species laws to combat a
localized law enforcement problem and all concerned amateur and
professional mycologists should oppose it as such.  The FWS will be
accepting comments on this ill-advised proposal until Monday, August
13, 2001. (end summary)


I know most of you are not regular readers of the Federal Register,
since it makes for famously dull reading.  However, buried on page
31689 of the June 12, 2001 Federal Register is an item that should
make us all sit up and take notice.  The US Fish and Wildlife Service
(FWS) is soliciting "information on the biological and trade status of
these taxa, and whether or not they meet the CITES criteria for
listing in Appendix II".  OK, what does THAT mean?  One of the taxa
named in the notice is the American matsutake mushroom (Tricholoma
magnivelare).  CITES is the Convention on International Trade in
Endangered Species, an international agreement regulating trade in
endangered species of animals and plants.  In other words they are
proposing to make matsutake an "endangered species" with heavy fines
and potential jail time for collection, possession or sale.

Here is the URL:
http://www.access.gpo.gov/su_docs/fedreg/a010612c.html
then scroll down to "Fish and Wildlife Service: NOTICES"

As many of the readers of this list are no doubt aware the matsutake
is NOT actually "endangered".  It turns out that the proposal is being
pushed by the National Park Service (NPS) because they have a problem
with matsutake poaching in some NPS units in the Northwestern US. 
Apparently, some genius in the NPS figured that they could
conveniently stop the poaching problem by having matsutake declared an
"endangered species" which would of course make trade in the mushrooms
illegal.  The fact that there is NO scientific evidence published in
peer-reviewed journals to support the notion that matsutake is
actually "endangered" and that it is not supported by professional
mycologists such as David Pilz of the USDA Forestry Sciences
Laboratory, Corvallis, Oregon seems not to have troubled NPS in the
least.  The NPS proposal to list matsutake as published by CITES
contains exactly TWO references supporting the application, one of
which is a newspaper article (I'm not making this up!).  The other is
a survey article by a couple of social scientists and not a
field-based study.  There are also a couple of web page citations. 
The applicants cited NO field studies and indeed no real research of
any kind.  You can see for yourself just how flimsy the case for this
listing really is at:

http://www.cites.org/eng/cttee/plants/10/PC10-9-2.pdf
see pages 2-3 (You need Acrobat Reader for this.)

The NPS probably figured that they could slip this through because
almost no one reads the Federal Register.  By claiming that T.
magnivelare is an "endangered species" it would be relatively easy to
portray this proposal as a good environmental move and thereby
marginalize anyone who might actually notice and criticize this
proposal.

I know many of you are inclined to regard this as some kind of bizarre
joke perpetrated by bureaucrats with too much time on their hands, but
the fact is that the mycological community really needs to stand up
and with one voice say "Enough of this nonsense!"

Here are just a few of the reasons that you should contact the FWS to
express your opposition to this bizarre proposal:

1. The proposal lacks ANY foundation in sound science.  In fact,
mycologists knowledgeable about T. magnivelare refute the assertion
that it is "endangered" or "threatened".  There are NO peer-reviewed
studies that support the assertion that T. magnivelare is genuinely
"endangered".

2. This proposal is a gross abuse of endangered species legislation
and of international agreements designed to protect endangered
species.  It bolsters the widely held perception that many endangered
species are not really "endangered", but are being used to advance an
agenda which has little to do with actually protecting the species. 
It trivializes efforts to protect species that are genuinely
endangered.  Gresham's Law applies: "junk science" drives out good
science.

3. As many of you know, matsutake and other mushrooms, along with a
variety of other "special forest products" are being harvested
throughout the northwestern US and western Canada and are a major
contributor to economies of rural communities which are recovering
from the loss of jobs in logging and other resource industries.  This
proposal will further devastate these communities, leading to more
unemployment and misery.

4. If matsutake can be added to the "endangered" species list without
scientific evidence, the harvesting of ANY other mushroom which is
inconvenient to a government agency can also be made illegal on
similarly preposterous grounds.  Morels, chanterelles, porcini, black
trumpets or anything else can be declared "endangered" or "threatened"
without the bothersome requirement of scientific fact.

5. The NPS's spearheading of this proposal cements the widely held
view of many in the scientific community that the NPS pays lip service
to science but ignores it when doing so suits its interests.  The NPS
needs to understand that it cannot play on BOTH sides of the fence. 
The Fish and Wildlife Service also needs to understand that it cannot
allow itself to be used by other agencies to unquestioningly shepherd
scientifically unsound proposals through the bureaucratic process.

Without a doubt, some amateur mushroom collectors will be inclined to
support this proposal because they believe it will curtail commercial
mushroom harvesting, which they loathe.  Such support would be
shortsighted and self-destructive.  If this proposal becomes law ALL
matsutake collecting will be illegal, whether commercial or not.

If you would like to comment to the FWS regarding this proposal please
refer to the following information:

We will consider all information and comments received by August 13,
2001. ADDRESSES: Send correspondence concerning this request
pertaining to species amendments to: Chief, Division of Scientific
Authority; U.S. Fish and Wildlife Service; 4401 North Fairfax Drive,
Room 750; Arlington, Virginia 22203-1610, or via E-mail to:
fw9ia--dsa at fws.gov. Comments and materials received will be available
for public inspection by appointment from 8 a.m. to 4 p.m., Monday
through Friday, at the Division of Scientific Authority. FOR FURTHER
INFORMATION CONTACT: Dr. Susan Lieberman, Chief, Division of
Scientific Authority, phone 703-358-1708, fax 703-358-2276, E-mail:
fw9ia_dsa at fws.gov


Species proposed to be added to CITES per June 12, 2001 Federal
Register announcement.

Plants
We are seeking additional information
on the biological and trade status of the
following North American cacti, and
whether they qualify for transfer to
Appendix I due to possible
unsustainable trade in individual
species or seeds collected from the wild:

Species Geographic scope Current status
Sclerocactus nyensis
......................................................................................
U.S.A. (Arizona) ........................................ Appendix II.
Sclerocactus parviflorus
.................................................................................
U.S.A. (Nevada) ........................................ Appendix II.
Sclerocactus sileri ...........................................................................................
U.S.A. (Arizona) ........................................ Appendix II.
Sclerocactus spinosior ssp. blainei
................................................................
U.S.A. (Nevada, Utah) .............................. Appendix II.

At COP11 the following plant species
were proposed by Switzerland on behalf
of the Plants Committee for transfer
from Appendix I to II or for removal
from Appendix II. However, these
proposals were not adopted due to lack
of consensus regarding the proposed
actions. We are seeking additional
information on the biological and trade
status of the following taxa, and
whether they qualify for transfer to
Appendix II or for removal from
Appendix II.

Species Geographic scope Current status
Dudleya traskiae (Santa Barbara Dudleya)
................................................... U.S.A.
(California) ..................................... Appendix I.
Lewisia maguirei (Maguire's bitter-root)
......................................................... U.S.A.
(Nevada) ........................................ Appendix II.
Lewisia serrata (Saw-toothed Lewisia)
.......................................................... U.S.A.
(California) ..................................... Appendix II.
Sclerocactus mariposensis
.............................................................................
U.S.A. (Texas) .......................................... Appendix I.
Shortia galacifolia (O'conee-Bells)
.................................................................
U.S.A. (Appalachian Mountains) ..............

Appendix II.
We are seeking additional biological and trade information on the
following taxa native to the United States, and
whether or not they meet the CITES criteria for listing in Appendix
II:

Species or taxon Geographic scope Rationale
Cimicifuga (=Actaea) racemosa, C. (=Actaea)
americana (black cohosh).
U.S.A. (Eastern states) .................................... Suspected
over-harvest for export.
Echinacea spp. (coneflower) .............................. U.S.A.
(Eastern and Midwestern states) ......... Suspected over-harvest for
export.
Olneya tesota (ironwood) ................................... U.S.A
(Arizona and California), Mexico ........... Suspected unsustainable
harvest in Mexico
for import to the United States.
Sanguinaria canadensis (bloodroot) .................. U.S.A. (Eastern
states) .................................... Suspected over-harvest
for export.

We are soliciting additional
information on the following species
native to the United States and Canada
that are used in the floral and
horticulture markets. In particular, we
solicit information on the biological and
trade status of these taxa, and whether
or not they meet the CITES criteria for
listing in Appendix II:

Species Geographic scope
Antitrichia curtipendula (hanging moss)
................................................... U.S.A. and Canada
(Oregon, Washington, Alaska, and British Colum-bia).
Eurhynchium oreganum (=Kindbergia oregana) (Oregon beaked moss) U.S.A.
and Canada (Oregon, Washington, and British Columbia).
Hypnum curvifolium, H. impogens (log moss)
......................................... U.S.A. (Eastern states).
Isothecium myosuroides (Cat-tail moss)
.................................................. U.S.A. and Canada
(Oregon, Washington, Alaska, and British Colum-bia).
Meteaneckera menziesii (Menzies' neckera)
........................................... U.S.A. and Canada (Oregon,
Washington, Alaska, and British Colum-bia).
Neckera douglasii (Douglas' neckera)
..................................................... U.S.A. and
Canada (Oregon, Washington, and British Columbia).
Rhytidiadelphus loreus (lanky moss), R. riquetrus (cat's tail moss)
........ U.S.A. and Canada (Oregon, Washington, Alaska and British
Colum-bia).
Thuidium delicatum (log moss)
................................................................
U.S.A. (Eastern states).

We are soliciting additional information on the following species
native to the United States and Canada that are
used in the herbal medicinal market. In particular, we solicit
information on the biological and trade status of these
taxa, and whether or not they meet the CITES criteria for listing in
Appendix II.

Species Geographic scope
Caulophyllum thalictroides (blue cohosh)
................................................ U.S.A. and Canada
(New Brunswick).
Dioscorea villosa (wild yam)
.....................................................................
North and Central America.
Drosera spp. (sundews)
...........................................................................
U.S.A. and Canada.
Ligusticum porteri (osha)
..........................................................................
U.S.A. (Western states).
Rhamnus (=Frangula) purshiana (cascara sagrada)
............................... U.S.A. and Canada (Western states and
B.C.).
Tricholoma magnivelare (American matsutake mushroom)
.................... U.S.A. (California, Oregon, and Washington).
Trillium erectum (Beth root)
......................................................................
U.S.A. (Eastern states).
Usnea sp. (tree lichen)
.............................................................................
U.S.A.




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