List the Red Knot Under the Endangered Species Act

Dear Secretary Kempthorne,

I am concerned about the problems facing the rufa subspecies of red knot (Calidris canutus rufa), a migratory shorebird that faces extinction if we fail to act. The science behind this claim is compelling, increasingly disturbing, and borne out in U.S. Fish and Wildlife Service (FWS) reports. The 2001 National Shorebird Conservation Plan recognized the red knot as "highly imperiled," and their plight has since gotten worse. I urge you to immediately list the Red Knot for protection under the Endangered Species Act of 1973 (ESA).

In 2006, the FWS designated the red knot as a "candidate species" for protection under the ESA. But being on the candidate list confers no statutory protection. Although the ESA requires that the FWS make "expeditious progress" toward listing candidate species, over the past decade, very few species have been moved from the "candidate list" to either the threatened or endangered list. Despite the growing list of candidates, now totaling 282, the proposed Department of Interior budget for endangered species protection requested an 11% decrease for candidate conservation. I am concerned that protecting endangered species is not a priority for the Department.

Every spring, the red knot migrates from as far south as Tierra del Fuego to the Canadian Arctic. Its last stop is on the Delaware Bay shores, where it feeds on horseshoe crab eggs. Each red knot must eat enough horseshoe crab eggs to quickly double its weight in order to survive the last part of its journey to the Arctic and successfully breed. But as horseshoe crabs became a popular source of bait for the commercial fishing industry in the 1990's, the horseshoe crab population plummeted. Without eggs to feed on, the number of red knots stopping at Delaware Bay has dropped from almost 95,000 in 1989 to only 12,375 in 2007. Scientific models predict that the Red Knot may become extinct in just a few years.

Although local action has been taken to help the horseshoe crab recover and should be applauded -- including Governor Corzine and the New Jersey legislature passing a bill in March 2008 that implements a moratorium on the state's horseshoe crab fishery -- the current restrictions in other states that affect the Delaware Bay population of horseshoe crabs are insufficient.

For red knots and other species that feed on horseshoe crab eggs in Delaware Bay to recover, the number of breeding crabs must return to the levels of the early 1990's. We know that the current horseshoe crab population is not large enough to provide for the nutritional needs of the migrating red knots because egg density on the beaches is not increasing.

Listing the red knot as threatened or endangered will lead to a true recovery plan that takes the full needs of this incredible migratory species, instead of the piecemeal approach we have now. The red knot's problems span several states, and saving it requires integrated fisheries management and habitat protection.

I urge you to quickly place the rufa subspecies of red knot on the endangered species list.