Saturday, October 16, 2021

Comment Examples for Ivory-billed Woodpecker, to USFWS

Rapid instructions to send in comment letter saying the Ivory-billed Woodpecker is not extinct.   

1. go below, pick and copy one of the 23 possible comment letters.  

2. Open first link right below to USFWS,  and paste in comment letter.

3. fill in your email and name, summit

4. get others to do same by sending this link 

Read this intro as needed or go to comments letters: 


Intro: The USFWS has proposed that the Ivory-billed Woodpecker be declared extinct in the USA. It's not a final decision yet. Before it is decided the  comments from the public and organizations must be considered. The more public input the better---it can make a difference. Please have anyone in your supporting family/friends submit separate comments from your and distribute this list to others including any clubs, groups or NGOs. 

Below is an assortment of sample comments that can be used, changed, combined, or expanded upon by you, if desired, to prepare your own. These samples come in various forms that try and reflect different interests or opinions that the public may have. Your comments must be sent to the following link by November 29, 1159PM.

Use Cut on comment letter below and paste in to first link below.  

Largest Virgin Forest Left East of the Mississippi, Congaree River, South Carolina 

Please use Comments of your Choice from Below to Send to These Links

Comment Link to USFWS

Another Link: 

Comment Link to US GOV on Ivory-billed

Duplicate Link to USFWS:  

Federal Register :: Endangered and Threatened Wildlife and Plants; Removal of 23 Extinct Species From the Lists of Endangered and Threatened Wildlife and Plants

Please forward any additional sample comments to us of your own or any improved comments from below you have made. We would like to add that sample comment to the below collection to assist others.

NBP is looking for volunteers to write comments and to spread this effort and document to others. Stipend is available.

We also may field a qualified team to perform a permitted organized IBWO survey on controlled access, permit only property. Please send your brief qualifications to us and ~ months of availability in '21 and '22. 

Please note the citizen who helps generate the most support letters (over 50)  will be eligible to receive a new Busnell Spotting Scope 45X. 

Comments are numbered and briefly described here:      

  1. you had sighting
  2. general, wariness, sightings
  1. taxpayer, Kulivan sighting of pair, sightings
  2. someone you know had sighting , sightings, video
  3. wariness, sightings
  4. inadequate surveys, states with IB
  5. IB long life span, private property
  6. Video, audio
  7. USFWS do not make a mistake
  8. USFWS has not done enough work, management needed
  9. hunting, wariness, JJ Kuhn
  10. mistake USFWS, sightings, California Swamp, behavior, more
  11. sightings, list of species thought extinct,
  12. long, sightings, skeptics, mistakes, list of evidence, USFWS responsibility
  13. 100 sightings, published papers, video audio
  14. survey methods, detection functions, more
  15. USFWS mission statement 
  16. sightings in 3 states and evidence 
  17. history of hunting; literature on  wariness
  18. species that have disappeared, then found
  19. mistakes by governments; do not repeat
  20. recent interactions with USFWS 
  21. up to date reasons why the USFWS should not declare sp. extinct   

Darien NP, Panama NBP

Sample Comments


To the Department of the Interior:

The Ivory-billed Woodpecker should not be declared extinct in the United States. I have personally seen one of the woodpeckers and please see attached dated and signed field notes and sketches after this brief description here:

On,            20   , I was at              .   It was (time) when a large black and white woodpecker 


This was not a Pileated Woodpecker because


I saw the bird from   feet away and observed it for            seconds. I lost sight of it when it


Again, see my attached notes and sketches 

In addition to my sighting there have numerous excellent sightings and some confirmatory or at least very suggestive videos made from 2005 onwards in multiple location in the SE United States. These videos are certainly not or almost surely do not depict a Pileated Woodpecker but do show a very large woodpecker.  Ivory-billeds and Pileateds are the only possible species that can be seen in the area where the videos were taken and again the videos do not show Pileated Woodpeckers.



------- ------ ----- ----- 


To the Department of the Interior:

It is very unlikely that the Ivory-billed Woodpecker is extinct in the United States. There are several recent sightings that seem to be describing Ivory-bills and only Ivory-bills.

This species has been persecuted for centuries and is not easily approached and obviously is not easily photographed or videoed. Regardless some birds have been videoed this century that appear to be Ivory bills. Audio recording are also almost surely Ivory-bills.

Just because a species is very wary, very rare and seeks secluded and often flooded forested areas does not make it extinct. It only means the species is very hard to locate, detect, see and photograph.

There is no reason to reach an extinction declaration that will remove any formal protections the last birds have. This species is critically endangered; it needs assistance from the USFWS not delisting.



 __ ---- -------__----

On the Atchafalaya River ~ 20 miles NW of Morgan  City, LA with Scott Ramsey 


Dear Department of the Interior:

.As a tax paying citizen I do not support any declaration or opinion the Ivory-billed Woodpecker is extinct in the United States. There are several million acres of suitable habitat, some private and most of these acres have not been adequately surveyed or surveyed at all. 

The species is well documented to be a moving needle in a haystack. The acres have been incompletely searched especially by any USFWS or government personnel. The USFWS supported that one or two birds were extant in east Arkansas in 2005.

There have been many excellent to suggestive sightings of birds in the last 22 years starting with the long and detailed sighting by David Kulivan in 1999. Kulivan saw a healthy pair and there have been numerous independent sighting in this area during the last 22 years. There is no evidence that these birds were not successfully breeding and in fact the evidence is the opposite since as mentioned  many sightings have continued since 1999 including pairs.  

There are other habitat blocks that have the same context as the Kulivan birds. The bird or birds were seen in a definitive area and then others also saw the species. There are a few areas where there have been repeated sightings inclusive of pairs. This supports the possibility of there being a small breeding population, or at least a pair still being present in a few areas of the US. Regardless if you do not believe it's possible evidence of breeding it certainly IS NOT evidence of extinction.






Perhaps the last Picture ever taken of any of the N. Ivory-billed group, Cuba, possibly Lamb 




The ivory-billed woodpecker (Campephilus principals) is not extinct. An associate of mine who is a superior birder would testify they saw one in an appropriate state and habitat.

In addition to this sighting there have been numerous excellent sightings and some confirmatory or at least very suggestive videos made from 2005 onwards in multiple locations in the SE United States.  These videos are certainly not or almost surely do not depict a Pileated Woodpecker but do show a very large woodpecker.

Ivory-billeds and Pileateds are the only possible large species that can be seen in the area where the videos were taken and again the videos do not show Pileated Woodpeckers. Of course you need to be familiar with the flight characteristics of the two species and how they differ.    




Black-bellied Whistling Duck, USA, NBP 


Dear Department of the Interior:

The many observations and evidence points to the conclusion that the ivory-billed woodpecker is NOT extinct in the United States. There are numerous recent sightings that can only match ivory-bills when the details of the sightings, markings, habitat, and behavior is considered. Many of the viewers are experienced outdoor enthusiasts and they are not making mistakes.   

This bird like many hunted animals is not easily seen and the habitat it is in can be incredibly difficult to traverse. It is understandable that it is not easily photographed or videoed. Regardless some birds have been videoed and sound recorded this century; they are almost surely ivory-bills. 

The bird is very wary and seeks solitude in quiet dense, forest areas. Flooded areas can be frequented.   It only means the species is very hard to find and see even if you are in the right spot with a bird close by. 

Do not remove this species from the ES List.





Interviewed Former Head Ranger Here;  this is the best area for IB in S Florida but His Sighting Was Very Unconvincing as Far as Inconsistent Details.   


To the USFWS.

It is not anywhere near proven that the Ivory-billed Woodpecker is extinct in the United States.The surveys have been inadequate when this large area is considered and private property especially in LA, FL and SC is noted. There are several sightings within the last ten years. These seem to be credible reports describing Ivory-bills and not Pileateds by credible citizens.  Stop ignoring these sightings like there has been the habit of for 100 years. 

This species has been persecuted for centuries and is not easily approached and obviously is not easily photographed or videoed.  Regardless some birds have been videoed this century that appear to be Ivory bills. Audio recording are also almost surely Ivory-bills.

Just because a species is very wary, very rare and seeks secluded and often flooded forested areas does not make it extinct. It only means the species is very hard to detect and photograph.

There is no reason to reach an extinction declaration that will remove any formal protections the last birds have. This species is critically endangered; it needs assistance from the USFWS  not delisting.




Painted Bunting on the Edge of IB Habitat, FL 


Department of the Interior:


Dear Public Servants:

Due to the known longevity of large birds including woodpeckers it is not probable that the IBWO is presently extinct. There are several sightings within the last ten years. These seem to be credible reports describing Ivory-bills and not Pileateds. The formal and informal surveys have been inadequate when the large possible habitat footprint is considered as it must be. Private property is also substantial in the SE USA, look at  LA and parts of FL and SC.

Please do not declare this species extinct for at least ten more years. 




This species has been persecuted for centuries and is not easily approached and obviously is not easily captured on cameras in dark, moist forests. Regardless some birds have been videoed this century that appear to be Ivory bills. Audio recording are also almost surely Ivory-bills.

Just because a species is very wary, very rare and seeks secluded and often flooded forested areas does not make it extinct.  It only means the species is very hard to detect and photograph.

There is no reason to reach an extinction declaration that will remove any formal protections the last birds have. This species is critically endangered; it needs assistance from the USFWS  not delisting.





Dear Department of the Interior:

Please do not declare this species extinct for at least several more years and only then if applicable.  A premature listing could be devastatingly embarrassing to the USFWS and more importantly the bird needs the protections afforded by the ESA.

IBs have been taken by humans for several centuries, they now have a large flush distance. It’s is not easily approached and obviously a photo or video is hard to get.  Regardless some birds have been videoed this century that appear to be Ivory bills. Audio recording are also almost surely Ivory-bills.

Please consider this, thanks,



On these tracks went the trees of Singer by the thousands of tons, with a few ounces of Ivory-bill feathers in some unusual "holes" no doubt  


To all departments of the Federal Government:

The Ivory-billed Woodpecker, Campephilus principalis is an incredible animal.  Extinction has finality to it and the USFWS has not done its work in the field for this species for decades. This is no time to suddenly be diligent and hasty. 

There is no reason to presently reach an extinction declaration that will remove any formal protections for the very few birds that are likely left.

This species is exceedingly rare and endangered; it needs habitat management and assistance from the USFWS not delisting.

Thanks you,




NBP Permitted Study Using Calls, Megaphone and ADK 



There are likely a few ivory-billed woodpeckers still alive.  Being a hunter I can attest to how animals that are even common cannot be seen for days or even weeks but are there. 

The ivory-billed’s modern behavior fits perfectly the model of what animals do when hunted.  A.T. Wayne (1892) noticed a substantial increase in flush distance of the remaining ivory-bills after a few seasons of intense shooting around California Swamp, FL (present day area around the lower Suwanee River). Take of birds dropped substantially after the initial year even though they were seen/heard from many yards away. Birds were there but much harder to shoot with guns let alone non-existent cameras.

At the Singer Tract (NE LA) J.J. Kuhn, the preserve caretaker sometimes would take days to locate the birds event though he know their general roosting and nesting areas. He had been protecting them from shooting as warden and had built up locational data on them while concurrently acclimating them to some human presence. 

The only place a picture was possible was at its nest. Reduced wariness at a nest may be more due to nest fidelity than any high level of tameness.

If one studies the non-stochastic effects of intense and increasing lethal take on many populations of animals you will notice an unmistakable increase in wariness can evolve rapidly.


It would be a horrific mistake if you called this species extinct. 






Male, April 1935 at Nest


To the Department of Interior:

I vehemently vote against the Ivory-billed Woodpecker being designated as extinct since this mistake has been made or attempted before by many entities and careless people. Perhaps the USFWS is making another false extinction declaration.

Its prudent to be cautious after evidence  soon came after the words “its gone forever” were confidently proclaimed in past centuries. As their pencils scribbled on deskbound pads, evidence/proof came from S FL 1920’s. Singer Tract 1932, Singer Tract until mid 1940’s, Central FL 1967, Cuba 1987, Kulivan LA 1999, a pair seen close for several minutes, AR 2005, Panhandle FL 2006-10, and many lesser publicized but likely good sighting from the same areas and more locations.       

 Heavy, labored, breathing claiming to know the unknowable, should wait at least until good sightings this century cease for at least ten years.

It’s prudent to recognize the more diligent searching has now waned in the 16th year. With perhaps two hundred seeing a bird, scores seeing pairs, a few hundred more hearing it and a few thousand trying and failing. Successful observers had cameras; but the bird doesn’t come to feeders, perch in plain sight, on open water, or lay exhausted at your feet from a long migration.      

It’s not surprising that effort and interest has lessened, the most tenacious early arrivers saw/heard the bird, others have moved on, some are awaiting an opportune moment to try and look again. Lessened interest has many inputs and factors resulting in some drawing false conclusions of extinctions.

The odds of the contemporary naysayers getting the extinction decade right for a species extant over for several hundred thousand years, over ~ 8 million acres is minimal. Certainly there are only a few IBs left, unfortunately. But there have been post 2015 sightings. As search hours drop, observations have concomitantly decreased; nothing surprising there for a rare bird even if here are 25 birds left. This “stasis” in not evidence of an increasing  population or decreasing population.  But it’s certainly not yet and excuse to jokingly gloat about extinction or exaggerate ones actual knowledge, assuming some reasonable streak exists in birders, conservationists and USFWS personnel.       

 Searching for IBs without a known nest location and/or bow, gun or rifle has often failed to produce much evidence of presence. A successful search historically numbered in the days or weeks. Failure to find a bird by well staffed “parties” or “expeditions” has occurred for more than a century. Tanner was led to nests and birds by the refuge caretaker. One IB can range over 20 to 50 square miles of often difficult  first and second bottoms. They are likely trapline feeders, not visiting the same tree for weeks if ever. And not surprisingly the bird can recognize a group, person, etc. may be pursuing it and respond with increased vigilance and evasive behaviors.

If one views the IB and Imperial Woodpecker films (Rhein) observant, wary birds are seen. Woodpeckers are considered a relatively modern, intelligent family of birds. The species have been hunted for centuries and its (IB) tasty flesh is locally well know. The flush distance was reported by A.T. Wayne (1890’s) and others to be in the hundreds of yards. Also see N. Synder's (USFWS retired) monograph on the disappearance of IB in relation to wilting hunting pressure.  

The Bayou De View, AR bird almost certainly came from more southerly haunts. This seemingly young male had moved into, and for several months frequented, a narrow corridor of riparian forest that broadened towards large habitat patches to the S.  The modest linear strip of several miles was only ¾ miles wide, making a lone male with no known nest or mate periodically viewable.  

Most male woodpeckers including IB males disperse fulfilling the need for an outbreeding mechanism The totality of the AR situation indicated breeding had occurred in either SE AR or in NE LA. A male Red-cockaded Woodpecker that was banded was found to have moved hundreds of miles in a short time frame.   Pairs of IBs were also seen in other areas of LA and FL this century. 

I am skeptical that the USFWS has done the needed field work to call this species extinct unless we consider ignoring the positive results in the last 22 years (post Kulivan pair).

The USFWS, US Forest Service, USDA and any state equivalents should manage forests for IBs. This species needs concentrated, recently dead trees. The constant damaged timber harvesting post fire, hurricane and tornado have unnecessarily damaged the population recovery process. 

The USFWS is coming under heavy criticism for this flawed extinction hypotheses. If this proposal passes and a bird is accidentally taken or photographed the USFWS will come under wilting scrutiny. The USFWS will be permanently damaged. The conservation story of the century will have been prematurely snuffed put. The new story will be labeled the failure of the century, with the USFWS and Department of the Interior being the horrific parents of the unholy product. 

There is a de minimis gain for the USFWS or US citizens to prematurely call this species extinct.




Campephilus in Colombia, NBP


The Ivory-billed Woodpecker has had many recent observations including some with audio and video data.

The species is hard to locate repeatedly even after good reports because individuals and pairs can range over 50 square miles. Do not declare this species extinct at this time.

The following is an incomplete list off species that were prematurely declared extinct by various people or entities.


Forest Owlet

Known only from 7 specimens collected over 120 years ago.

Until rediscovered in 1997.


Cherry-throated Tanager

Was originally found in mountain forests of SE Brazil.

Sightings finally reported in 1994 with 10 birds confirmed in 1998.

White-winged Guan

Originally in remote forested valleys of NW Peru

Bird discovered in 1876-77, and after that the status was unknown.

It was rediscovered in 1977 with possibly fewer than 100 wild birds.


Jerdon’s Courser

Was found in the early 1900 is sparse shrubland in central India

Assumed extinct but rediscovered in 1986.

Population estimate was 50 - 249 birds but it may have again disappeared. 


Cebu Flowerpecker

Was Endemic to the island of Cebu, Philippines

Was last seen in 1906 but rediscovered in 1992.

Population was fewer than 50 birds but mat now be a bit higher due to projects. 


Bermuda Petrel

Nests on rocky Bermuda islets, in Atlantic Ocean. Has been seen in NC waters on pelagic trips.

Was last seen in 1620 but rediscovered in 1951

Population was thought to be 200 birds but now is 400-500.

The USFWS must avoid being associated with this list. The IB is not extinct. 



Various Sightings in The Draft Recovery Plan are Vague but a FOI Request was able to Shed Some Sunlight on this mysterious line. Several sightings from some good IB searchers buried by USFWS with inadequate follow up by anyone but Dennis. See Article By NBP 2021, Here.   



The Ivory-billed is likely not extinct since it has been seen recently in four states. Large woodpeckers are noted as living up to 12 years (see literature Pileated Woodpecker and Great Slaty Woodpecker).

The USFWS should not be swayed by IBWO pseudo-skeptics or skeptics. I define a pseudo-skeptic as one who presents flawed data or deliberately misleading presentations (Sibley, Jackson, Bevier, et al.) or a person that treats their own sighting differently then they do other’s sightings (Jackson).  They were predisposed to disparage any data, evidence and reasoning that supported the existence of the IB. Pseudo-skeptics often do not spend much or any time in the field with effective survey methods, yet talk with authority on presence-absence of the species over several million acres.

The source of this group’s pseudo-skepticism is varied but seems to propagate out of jealousy, disappointment of not being invited onto the IB Rediscovery Team, and from disbelief that after decades of work and research his life’s work, his field guide, had a terrible omission in it (no IBWO  pictured or described and other mistakes). 

Skeptics had various reasons for their unhappiness; its included some with genuine concerns that the data was inconclusive; some too time burdened to look at the data with care. Others were so fearful that their research projects would not be funded they deliberately forced themselves onto the IB Recovery Team and then preceded to weaken the field search teams methods.

The skeptics on the IB Recovery Plan Committee went to work watering down the potential effectiveness of the field search teams by insisting on adding survey responsibilities for species and data sets that had nothing to do with locating rare Ivory-bills on several million acres. They also complained about funding going to this species; no doubt they were likely concerned about grants for their research projects being canceled rather than any real intent to save the IB. Within academia competition for funding it fierce and combative.  

These skeptics should have recused themselves or been recused by the USFWS since they were grossly biased. How can outwardly hostile people to the 2004-07 rediscovery events, be on a recovery team supporting an effort they do not support? It's nonsensical. They were biased against the IB being rediscovered in obvious ways and acted to lessen the results of the field surveys.  

The survey results produced by the IB Working Group, USFWS, Cornell University, etc. are therefore suspect due to inappropriate design and inefficient methods. In addition the actual double knock survey methods were specifically flawed via embracing of "super stimuli". If an animal rarely seen in 60 years is really there it will be the most wary that have survived. The remaining birds are very likely to be prudent with knocks and kents. The aggressive knocking the field teams performed was a potentially fatal methodology flaw. This may have actually scared IBs away. It was a rudimentary mistake.

Here are just two of the myriad of unethical and erroneous skeptical behaviors; presented here as evidence of their odd bias against the US IBWO that has no doubt crept into these and prior proceedings on recovery and extinction status. They ultimately negatively impacted the accuracy of the data the USFWS is now using to wrongly assert extinction.

a) They disparaged various strong evidence of IBWO in numerous journals, articles, websites, inaccurate videos, papers and posts. Many of their points were obvious`ly errors or stretches from  there inception; they were gradually proven to be over reach, purposely misleading or false.

b) This pseudoskeptic example has a dual purpose; it shows the extensive evidence for IB presence in the US while laying out and exposing Jackson's double standards. Jackson was not a skeptic of the poor sightings of IB in Cuba of ‘86 through ’88. This ”rediscovery” by Alayon and Estrada was eventually confirmed by L. Short and J. Horne. In ’88 Jackson showed up with others and seems to be the only one claiming a very poor possible, brief sighting that year. There had been a 40 year gap from the previous Cuban sightings. The “recent” birds were found in rather poor secondary forest and were said to be eking out an existence. It was hilly and open habitat rather than the often difficult and at times dangerous conditions encountered in the USA. Although it must have been hot, the terrain was far from impenetrable or thick. Yet there are no pictures, no bad pictures, no film of any quality, sound recordings or feathers by any of those alleging the encounters over years including Jackson.

There are only notes and drawings by the participants----nothing (nada) else. The sightings were distant and brief. Forty years earlier Crompton and Lamb had gotten several pictures of the birds in the same area.

Surveys and searches after these sighting have produced no reports although some pursuits lasted weeks to several months.

Jackson and the world easily accepted that some birds were alive in Cuba. Now look at all this evidence next that suddenly doesn’t satisfy Jackson and many. Seems like when there is grant money, ego and pride involved standards can change even when the serious question of extinction is being decided. The USFWS made the right decision in 2005 on the substantial  AR paper by 17 very acceptable authors. This is no time to side with those who have been wrong since then and have been unethical. The UFWS must err on the side of caution and respect the substantial evidence that fully supports the conclusions of 2005. The species was extant  then and is likely extant today (late 2021).

In the US from 1999 to 2021, 22 years, there are an estimated 200 + good sightings in many locations, some the same birds no doubt. There seems to be at a minimum 14 different birds involved, centered in only 4 states. A few of the sightings lasted many minutes, a few 30 seconds, and a few for several seconds; most were ~ 3 seconds and were flybys, some very close. Several sightings were by two people. Some of the sighting were made by two people within a minute of each other but not together and not knowing what the other person had seen. Many of the sightings were accompanied by tempo-spatial kents and/or double knocks. The great majority of sightings were made by very experienced outdoorspeople who are very familiar with the PIWO and what the IBWO should look and sound like. The species are not that similar at all. The sightings in general were in late successional, riparian forest, which fits the IB.

The different sightings over days to years are spatially clumped in a heterogeneous pattern, this obviously meets the standards of biologically defined occupancy of discreet areas by the IB. For some reason the pseudo-skeptics have convinced the world and evidently the USFWS that there were no repeated sightings of the IB in the USA. This is a blatant lie by them and poor dedction by those listening to these biased individuals.

Many of the sightings are correlated to the handful of larger ecosystems and riparian corridors that Tanner noted had IBs in ~ 1936. Sighting have occurred regularly for many decades in these areas; this fact should not be ignored just because concise records easily found in one place were not kept. The reports are not collated per area but do exist in scattered sources. Also see the extensive location records in the USFWS IBWO Recovery Plan.

From 1945 to 1999 there were many reported sightings, many suppressed. Here are just a few of the scores. John Terres one of the most prestigious ornithologists of modern times (see )  saw a pair in 1955. In this new article several birders saw an Ivory-billed including the very experienced Mr. Crompton, see 1960’s New Jersey Birders See Ivory-billed Woodpecker See Several More Ivory-billed Woodpecker Sighting But Not Well Known

The physical evidence includes a long audio tape by John Dennis of an IBWO after several sightings in East Texas in the 1960’s (see Macaulay Library Lab, Cornell U. IBWO) and IB feather(s) and IB roost from FL (Agey and H., The Florida Naturalist). Former ABA President D. Pranty highlighted these sightings in the Lane Guide to Florida Birds and again see - The Florida Naturalist for riveting article on these IBs and the evidence in Florida.

Over the last 16 years ~ 9 videos were taken at places where the above 21st century sightings were made. Two or three of the videos (AR, LA) show a bird the size of an IBWO that has the wing beat Hz of an IB vs PIWO. These videos are heavily analyzed and have been found by many to be an IB after very careful and intensive study and field measurements. Two or more of the videos include confirmatory audio of an IB. All of the videos were taken in areas that had multiple sightings by multiple reliable people over many years.

Several of these videos were featured in ~ 6 recently published papers fully supporting the existence of IB in a few places. Several videos are supporting material in these peer-reviewed papers. There is not one scientific paper that challenges the validity of all or even one-quarter of the substantial evidence supporting the IB's existence.

Audio from 3 separate areas includes ~ 150 Campephilus-like kents and double
knocks. Some audio and concurrent field ear detections indicated 2 birds were present and possibly interacting.

One site (FL, Hill et al.) had elegant data on bark scaling indicating IBs may be present.

Habitat-- There are millions of acres of potential habitat in the United States which is much greater than Cuba. Over the last 20 years more absolute acres have been surveyed in the US then Cuba but it is a minor percentage of the possible acres IBs might occupy in the US. Some strongly claim that many of the acres surveyed in the US were incorrectly surveyed by the “official” survey team and have therefore produced false negatives (very aggressive number of anthropogenic double knocks). Search methods in Cuba over the decades varied but for many less acres.

Conclusion by most of the public at the time ~ 1990--Cuban IB lives ‘87. 

The US IBWO was extant at the time 2005 but as more good data came in somehow it gradually drifted into stasis and then this ridiculous proposal to call it extinct. Note that Jerome Jackson was an unreasonable and emotional skeptic from 2005 onwards of the US IBWO sightings with, ten-infinite times more evidence in various data sets than the Cuban IBWO or ‘87. Infinite refers to the Cuban evidence not including ANY, ANY audio or video of the Cuban species but the US species had much audio and video evidence, various data sets (roosts, etc) and several peer reviewed papers.

Is this consistent treatment by Jackson between the two species/subspecies? All comments by this pseudo-skeptic should be removed from the record on this matter due to lack of credibility. If Jackson disparaged the 2004 AR sighting he could remain as the last person on Earth to have possibly seen an IB (Cuba, 1988). Always a good way to help sell books. Next comment will be on the other pseudo-skeptic, an artist who left out the IB in his field guide. He an others made outlandish heuristic predictions of the IBWO wing beat Hz that turned out to be totally ridiculous from the start of their assertions until it was dealt a fatal blow by the restoration of the Imperial Woodpecker films. The wing beat Hz of the Imperial supported the USFWS’s and many others conclusion that the Luneau video from AR was surely an IBWO. This artist's comments in this entire matter should also be reviewed and as appropriate stricken from this extinction proposal for lack of credibility.

In conclusion the USFWS is obligated to protect valuable natural resources such as the IBWO; due to the details above and many more too voluminous to even list it is unlikely that the IBWO is extinct. 

The USFWS should be satisfied with its correct decision of 2005, review subsequent reports over  recent years and not make the ultimate mistake of calling a species extinct which may not be.



Various Studies by NBP in the incredible Congaree NP,  SC. IBWO's were detected .

15. To the Department of the Interior:

It is very doubtful that the Ivory-billed Woodpecker is extinct. The federal government should not remove the needed ESA protections for this critically endangered species.  There have been approximately 100 reputable sighting of one or more IBWOs in the last 22 years. There are scores of additional sightings that are suggestive. There are good reports by academics, experienced scientists, birders and naturalists of  ~ 6 pairs in different discreet river bottoms or forests.

Approximately 6 recent, peer reviewed scientific papers support that Ivory-bills were very recently extant.

This species has been persecuted for centuries; it is not easily approached, and obviously not easily photographed or videoed. Regardless some birds have been videoed this century that appear to be Ivory bills. Audio recording are also almost surely Ivory-bills.

Just because a species is very wary, very rare and seeks secluded and often flooded forested areas does not make it extinct. It only means the species is very hard to detect and photograph.

There is no reason to reach an extinction declaration that will remove any formal protections the last birds have. This species needs assistance from the public, NGOs and government entities. The USFWS should not delist this species at this time. 







 Dear USFWS,

I am adamantly against the delisting of the Ivory-billed Woodpecker from protection. Both informal and formal surveys have been hampered by the low detection rate for this species caused by its well known evasiveness.  The importance of estimating detection probabilities for bird counts has long been recognized (Burnham 1981).

The bird has historically been documented as being hunted for various reasons including curiosity, target practice and food after southerners were desperate for protein post Civil War. Vocalizing birds were located by hunters; this was a driver for a more muted and skittish population of IBs post war.  The selection process was continued by museum specimen collectors. By normal evolutionary processes, not much different from other hunted species, the bird became very wary.

Detection probabilities are utilized to accurately calculate the number of birds present by established statistical analysis. In general the ratio of birds present vs detected must be deduced from carefully planned and prosecuted studies. For example if you perform point surveys via USFWS approved methods and you find 5 Hooded Warblers in a 100 acre forest patch and then you perform a net and band program for a month and find 20 warblers your detection rate via point survey is 25%. The ratio is then used to analyze the results for future point survey of Hooded Warbler. These probability studies have not occurred for the IBWO and therefore no accurate population number can be easily established.

Tanner and others said that even though they were in the area frequented by the birds it could often take three days to five days to locate one of the several birds known to be in the Singer Tract. Tanner never found a single bird outside of the Singer Tract although there seems to have been over 20 to 30 in other parts of the country that he searched for several months. 

From all of this its is obvious that 1) the Ivory-billed’s detection rate has not been established by the USFWS for the IB and 2)  the literature is clear that the IB can be very difficult to find even if they are known to be in the exact area surveyed. 3) the IB detection rate is undoubtedly very low. 4) despite the  low detection rate ~ 12 to 16 different IBWOs were found or were likely found post 1999.

Again there is no valid scientific reason to call this species extinct in 2021.


Thank you,




Pearl River, LA within 300 Yards of Sightings, Never Handed In, But Sighter Interviewed On Tape. 


To the USFWS:

Do not declare the ivory-billed woodpecker extinct since there are very recent reports of some birds including pairs.

And please refresh your memory on the department's goals: The USFWS’s mission is, working with others, to conserve, protect and enhance fish, wildlife, and plants and their habitats for the continuing benefit of the American people.

Continue working with people to give this species a chance for the taxpayer that pays your salary.




To The Department of the Interior:

The Ivory-billed Woodpecker is still here; it is not extinct.  There have over one hundred good sightings, hundreds of recordings of audio of double knocks and kents and several videos this century, some very recently. 

The start of the compelling evidence of the species’ existence was obtained when the Ivory-billed Woodpecker was reported in Arkansas and presented by Fitzpatrick et al. (2005). On February 11, 2004, kayaker Gene Sparling observed a large woodpecker with characteristics of an Ivory-billed Woodpecker in Arkansas. The encounter spurred an extensive search led by the Cornell Laboratory of Ornithology and the Arkansas Nature Conservancy. In 2004 and 2005 observers reported multiple sightings and recorded audio and video interpreted to be an Ivory-billed Woodpecker within the same area as Sparling along Bayou DeView, located in the Cache River National Wildlife Refuge (NWR) in east-central Arkansas. 

Soon after evidence was very suggestive, approaching proof,  from Florida of ~ 4 birds by Auburn and Windsor University (many sets of field notes, hundred of knocks and kents by ARUs and people, videos, roost measurements) . Also there has been evidence given to the official IB Working Group from SC. The there is varied evidence from two locations in Louisiana, by multiple researchers (Videos independently confirmed by peers as IBWO, several papers, audio, stills, field notes, field logs etc).

Many other sightings also.





The Ivory-billed Woodpecker should not be declared extinct; the persecution of the species is obvious; it is now rare and very wary by definition. This skittishness is why there are so few opportunities to see or photograph the bird even when there. For several hundred years or more, Ivory-billed Woodpeckers have been hunted by humans. Mark Catesby (1731) first described this species, he stated in his Natural History of Carolina, Florida, and the Bahama Islands: "The bills of these Birds are much valued by the Canada Indians, who made Coronets of 'em for their Princes and great warriors, by fixing them round a Wreath, with their points outward. The Northern Indians having none of these Birds in their cold country, purchase them of the Southern People at the price of two, and sometimes three, Buck-skins a Bill."

Naturally when guns arrived in the SE USA flush distances for the IB must of increased like they have for an innumerable number of species that have been hunted. It is also replete in the literature that animals vocalize less if they are substantially located by their calls and knocks by those attempting lethal take. Many species of birds are located first by their song, call or knocks. 

Regardless there are numerous recent field sightings of the species and the habitat is in the millions of of acres, some of it private. And a few recent videos exist that best fit this species. To this day there are species that are rare, do exist in the hundreds but HAVE NEVER BEEN PHOTOGRAPHED. Within hours of the United States, thousands of Zapata Rails have been running around for a hundred years without ever smiling for even one picture.

Arthur Allen PhD stated of the Ivory-billed that "It is doubtful, however, if the loudest calls can be heard, under normal conditions, for a quarter of a mile, and some of the weaker ones are scarcely audible at 300 yards. The birds are so often quiet for such long periods that we can scarcely agree with Audubon's statement that "the bird spends few minutes of the day without uttering them." They seem much more likely to call when they are alarmed, as when they discover an intruder in their haunts. Both birds give the call, but that of the female is somewhat weaker.

 In addition to this kent note, as it is called by the natives of Louisiana, and because of which they call the birds "Kents," they have a variety of low conversational notes when they exchange places at the nest, which are suggestive of similar notes of the Flicker; but they never, so far as we know, give a call at all similar to the pup-pup-pup! of the pileated, nor have we ever heard them sound a real tattoo like other woodpeckers, such as described by Thompson (1885), and which Mcllhenny (Bendire, 1895) compares to the "roll of a snare drum." The birds in Florida and all those in Louisiana telegraphed to each other by single or double resounding whacks on the trunk or dead branches. Mr. Kuhn, who has had years of experience with them, likewise has never heard any notes or tattoos that were comparable with those of the Pileated.. 

Our observations agree with Audubon's, rather than with those of some others, in that "it never utters any sound while on the wing."

Do not call this species extinct at this time. And the various departments of the federal, state and local governments should provide hundreds of acres yearly of dead wood in a rotation, as proper management tool.




To the US Government, 

The Ivory-billed Woodpecker has had many recent observations including some with audio and video data.

The species is hard to locate repeatedly even after good reports because individuals and pairs can range over 50 square miles. Do not declare this species extinct at this time.

The following is an incomplete list off species that were prematurely declared extinct by various people or governments.

One of these birds, a large, forest inhabiting owl has some parallels to the Ivory-billed Woodpecker. This large owl was finally photographed this year after never being photographed in the wild before. 

 Large Bird finally found, and photographed 2021

Just some of the other species that disappeared from serious searchers for decades or centuries are Bermuda Petrel, Jerdon's Courser, White-winged Guan, Cherry-throated Tanager, Cebu Flowerpecker and Forest Owlet.  

The USFWS will look ridiculous and its reputation will be seriously injured when further evidence of the Ivory-billed is uncovered. There are millions of acres out there for this shy, retiring species; do not make a terrible mistake by your own choosing. 



To the USFWS,

The US government might get a pass for not preserving the Singer Tract, LA since we had a World War to contend with.  The USFWS and the government also did some good habitat preservation in 2006 onwards. 

But overall, the USFWS, USDA, the federal and state governments have done little to manage habitat for Ivory-bills even though it controlled several million acres of appropriate habitat. Girdling a few hundred acres every year in a few locations would have helped the IB during the critical breeding season. Other key species would have also been helped.  

Don't make another mistake that dovetails nicely with prior errors. Resist calling this species extinct at this time. Then after consultation with ecologists and the "IB community" do some meaningful woodpecker management. Volunteers can help and the land is already there.   

Thank you,




Several citizens in late 2021 have tried to engage one, multiple or any pertinent USFWS personnel in a discussion on why the Ivory-billed Woodpecker has even been proposed for a damaging extinction declaration. 

The USFWS has only two people named in the official ivory-billed extinction proposal announcement. These individuals have recently been reached out to and documented to be either, ignorant on ivory-billed details, rude or no longer with the USFWS.  

Finally, after weeks we are getting people at the USFWS to take this issue that their department initiated seriously. 

Key USFWS personnel have been formally requested to get into the field with others to look for the Ivory-billed ASAP and separately attend a zoom meeting ASAP.  The government rushed the proposal for the Ivory-billed's extinction.  The USFWS should now act in a timely manner with due diligence to answer reasonable pre-comment questions or withdraw the proposal for extinction. 

The public or the ivory-billed should not be made to suffer on several levels because of poorly thought-out extinction proclamations by "new" administration personnel in Georgia, Louisiana or Washington, that are not fully aware of actual field conditions and related issues. Extinction is a well-defined and unambiguous scientific term; the USFWS has pledged to be a fact-based organization. 

This is a serious event and the USFWS has not done anywhere near the needed preliminary work to even make such a proposal let alone declare the species extinct. 

The USFWS must follow the science. Yet they have not contacted many modern witnesses and their teams including just for example, Jeff Hill PhD whose team has seen ivory-bills in Florida, with peer reviewed papers published. National Biodiversity Parks, Inc. also has the largest unpublished field data set of the Ivory-billed in existence; they have not been contacted after they contacted the USFWS.  

In that light at least one serious federal scientist 
who has studied the species in the field for 15 years has offered the USFWS his assistance to attempt to hear or see an ivory-billed this fall/winter (2021). This zoologist has led teams in the recent past that have seen and heard the IB per prior confidential reports to the US government. 

The USFWS must have people that can get out from behind their desks and get in the field to hear or see an Ivory-billed if it is offered by concerned, private, professional field personnel. Note that direct answers to prior questions, are now taking weeks with accompanying omissions, vagueness and excuses so far by the USFWS. Reasonable offers to assist the USFWS on the IB issue are also moving too slow. The USFWS has proposed a very serious and final opinion on extinction; this is no joke. 

The excuse to getting out in the field being that some government advisory disallows overnight stays in open forest because of Covid. Various government workers spoken to know of no such regulation that would absolutely apply to camping in field conditions for such an important task/event. Regardless most federal workers have weekends off, get several weeks leave a year or can request admin leave. They then could look for ivory-bills without any ridiculous shackles that are alleged to apply to open-are, open forest work.  

And regardless, if federal personnel cannot stay or refuse to stay overnight in forests, they can extract themselves from forests at the end of each field day as needed and go to their houses, or reasonable accommodations to meet any regulation. If USFWS will not retract the IB from the extinction proposal then NGOs will pay for their accommodations to eliminate any more disingenuous excuses to avoid getting into the field.  

This rushed, premature extinction proclamation was instituted by the USFWS during the end of the most well know pandemic in the history of mankind. The USFWS should either get in the field with precautions or retract the extinction proposal if it refuses to get into the field.  

It's evident from recent direct communications with several USFWS personnel that are good people that the USFWS has mistimed this extinction proposal.

For the sake of the USFWS, scientific protocol and to avoid potential PR disasters either recall this extinction proposal or failing that, keep the Ivory-billed Woodpecker on the US Endangered Species List.

After this self-inflicted possible blunder of the century is halted in the bird's favor, we can all determine where the last Ivory-billed Woodpeckers are at a pace that meets all parties' concerns, and see or hear at least one.  





This is the wrong time to call the ivory-billed woodpecker extinct in multiple pivotal ways. 

First an ivory-billed woodpecker or a pair have been seen or heard many times over the last 20 years by many reputable observers, including government personnel.  

Two, there are several recent videos that appear to be only Ivory-bills if you spend more than an hour looking carefully at the videos which are of low resolution but have a lot of information in them nonetheless. Before examining the putative IB videos one must look at the1956 Imperial Woodpecker flight films versus the many videos of flying Pileated Woodpecker.

Three it is clear from recent information that the USFWS has done little actual work itself in reviewing Ivory-billed evidence post 2005. The USFWS has also sent no personnel to look for the IB and relied on any evidence or suggestive information to just trickle in, or not trickle in. 

Fourth the USFWS seems unaware that Cornell University incorrectly designed the attraction methods used by official search teams. The IB is a very wary animal and the anthropogenic double knock methods were too aggressive.  

Fifth it seems the USFWS has been mostly desk bound during the pandemic and did little to nothing in the decade before. This of course is not the time to make the penultimate decision that must have field generated data to have any veracity whatever the determination.  

And finally the USFWS still seems reluctant to get in the field to look for Ivory-bills. They were contacted in early October '21 and invited to do so but are avoiding field work with vague responses.   

The USFWS should shun the third rail of conservation etiquette and not declare a species extinct when the decision is untenable. If they fail to leave this species on the ES list they are risking their entire core mission being damaged forever. 



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