U.S. Fish and Wildlife roadblocks Ntombi the Rhino

 

It is time for another update on the Black Rhino Genome Project. This update contains both good and bad news. Let's start with the good.

The Good

Our fallback plan to map the genome of a rhino specimen taken from a local museum is preceding apace. One of Dr. Murry's graduate students at the University of Washington (UW) has verified that the specimen is, in fact, a black rhino specimen using a species confirmation test. Additionally, the team has extracted DNA from the sample, cut it into fragments, and stored them in a way that they can be easily copied. The resulting collection, or genomic library, is now ready for sequencing, a process that involves reading the "letters" that spell out the black rhino's genomic code.

The Bad

On August 23, 2016, the U.S. Fish and Wildlife Service (FWS) denied the UW's application to import Ntombi the Rhino's ear notch from South Africa, thereby ending her bid to be the first black rhino ever sequenced. This denial came as a shock to us since we thought our troubles lay with the South African Department of Environmental Affairs (DEA), which was reviewing a corresponding export application. In its denial letter, attached as a PDF to this post, the FWS expressed concern over the UW's disclosure that a genomic map could assist in "understanding the biology of rhino horn growth and heart development." The agency also objected to Pembient's affiliation with the project due to its work on lab-grown rhino horn.

The dictionary defines a map as "a representation, usually on a flat surface, of the whole or a part of an area." Humankind has made been making maps for centuries. In the geographic realm, a map can be used to plan trips, define conservation areas, restore biodiversity, manage resources, specify mining sites, route pipelines, etc. The point being, just because a map might enable a certain activity does not mean it should not exist.

Frankly, we're disappointed a regulator would stymie basic scientific research, especially when the aim of that research is to produce a publicly available genomic map, something scientists have done for numerous species, including other species of rhino, over the past decade. The correct regulatory response should have been to allow the importation of the ear notch. If a company developed lab-grown horns utilizing information obtained from it, and there were compelling reasons against commercializing those horns, the regulator should forbid their export at that time.

The Ugly

To get a better understanding of why the FWS denied the UW's application, we submitted a Freedom of Information Act (FOIA) request to the agency on September 8, 2016. We were particularly interested in reading the comments received on the application during the required 30-day public comment period mentioned in the denial letter. These comments were supposed to be accessible via the federal government's Regulations.gov portal; however, none were there when we checked.

By early January of 2017, the FWS had responded to our request with 455 pages of documents. Within this cache of material, we found only one email thread (see attachment) that could be construed as a public comment on the UW's application. The comment, sent by an attorney for the Humane Society of the United States (HSUS), an organization with a questionable history in rhino conservation (Dien, 2014), claimed the import of Ntombi's ear notch was for "commercial purposes." This is demonstrably false; the money raised for the Black Rhino Genome Project was collected by a non-profit organization and gifted to the UW for the purpose of creating a genomic map. Pembient did not pay for, nor will it own, the results.

More worrisome than HSUS's misrepresentation is that their petition is seemingly connected to an FWS employee. If employees at the FWS are prompting special interest groups to oppose applications, they're letting policy drive science instead of science drive policy. When that happens, everyone loses.

Timeline

Below is an overview of the import application process:

• 11/04/2015, UW submits a permit application
• 12/04/2015, FWS acknowledges receipt of the application
• 01/29/2016, UW asks for an update
• 03/25/2016, FWS begins a scientific review of the application
• 03/25/2016, FWS explains the review process to UW
• 04/08/2016, FWS seeks public comments on the application
• 05/09/2016, UW asks for an update
• 05/12/2016, HSUS belatedly opposes the application
• 05/16/2016, FWS begins drafting a negative scientific finding
• 05/31/2016, DEA queries FWS about the application
• 05/31/2016, FWS queries DEA about the application
• 06/06/2016, DEA responds to FWS's queries
• 06/15/2016, FWS ends scientific review with a negative finding
• 08/05/2016, FWS begins drafting a denial letter
• 08/16/2016, FWS finishes a first draft of the denial letter
• 08/23/2016, FWS issues denial letter
• 08/25/2016, FWS informs UW of denial
• 08/31/2016, FWS informs DEA of denial