Sufficient conservation warrants delisting

Navasota ladies’-tresses (Spiranthes parksii), is an orchid the U.S. Fish and Wildlife Service (Service) listed as an endangered species in 1982. In the agency’s final listing rule, the Service stated that S. parksii is “primarily threatened due to extremely low numbers, urbanization, and possible over-utilization.”.

In the more than three decades since the 1982 listing, a substantial amount of new information has become available demonstrating the species is not at risk of extinction and that the original listing was in error. Sufficient conservation for the species is in place so that neither the existence nor the magnitude of the once perceived potential threats to the species indicates that the Navasota Ladies’-tresses is at risk now or in the foreseeable future. Therefore, the protections of the ESA were not originally and are not currently warranted.

Furthermore, molecular analyses by numerous researchers using a variety of different markers and methods, including work that has been published in peer-reviewed scientific journals, have failed to support the treatment of this orchid as a distinct species apart from the local form of the co-occurring nodding ladies’-tresses. As such, the best available scientific and commercial information suggests that the Navasota ladies’-tresses may not even be a valid species eligible for listing.

Species inappropriately receiving the protections of the ESA causes significant economic harm to landowners who are prevented from using their land and to local governments who need to provide necessary community services. Objectives of the ESA are best served by focusing limited conservation resources on species that truly warrant the protections of the ESA. The Navasota Ladies’-tresses should no longer be listed as threatened or endangered under the ESA.