Archive | August, 2013

After Sandy: Re-building Smarter, Re-building Greener

After Sandy: Re-building Smarter, Re-building Greener

Last summer, Defenders released a report, “Harnessing Nature: The Ecosystem Approach to Climate Change Preparedness,” to demonstrate the potential for ecosystem-based approaches – restored wetlands, protected habitats, and resilient forests – to help protect communities and infrastructure in the face of increasingly severe floods, droughts and heat waves that we expect a changing climate to bring. Little did we know that the nation would soon be faced with one of the costliest weather disasters in our nation’s history, a massive and deadly superstorm that demonstrated unequivocally that climate change is here, and it is happening now.

In the wake of Hurricane Sandy, President Obama recognized the need for massive public investment in order to help rebuild one of the nation’s most populous regions, as well as the need to coordinate these investments in order to expedite recovery, avoid duplication of effort, and rebuild with an eye to withstanding challenges that climate change is sure to bring down the road. Thus, the Administration convened the Hurricane Sandy Rebuilding Task Force, which today released a Strategy “to serve as a model for communities across the nation facing greater risks from extreme weather and to continue helping the Sandy-affected region rebuild.” Defenders is pleased to see that among the report’s recommendations are several that highlight the invaluable role played by our natural capital during Sandy itself, and point to a more widespread use of this “green infrastructure” to enhance resilience to future climate challenges.

In building its case, the Strategy highlights the role that a restored oyster reef in Pamlico Sound played in reducing flooding at Alligator River National Wildlife Refuge. It could have just as easily discussed how communities in New York and New Jersey with intact dune systems fared far better than those that did not, or how restoration of wetlands and living shorelines to absorb storm waters and reduce wave action is an integral part of New York City’s resilience plan.

The Task Force lays out its “Green Infrastructure” strategies in Recommendations 19- 22:

Consider green infrastructure options in all Sandy infrastructure investments. Toward this end, the Task Force has developed Guidelines for incorporation of ecosystem services into projects:

“(1) provision of habitat (coastal, inter-coastal, inland)

(2) landscape conservation for the tourism, recreation, and aesthetic values on which economies depend

(3) watershed protection for clean drinking water and improved flood management

(4) threatened and endangered species conservation and restoration

(5) other associated ecosystem services from which people derive benefits (e.g., aquaculture and recreational and commercial fishing).”

Improve the understanding and decision-making tools for green infrastructure through projects funded by the Sandy Supplemental. Agencies are developing monitoring, mapping, remote sensing, valuation tools, and design protocols to better understand and apply the full range of benefits that natural solutions can provide.

Create opportunities for innovations in green infrastructure technology and design using Sandy funding, particularly in vulnerable communities. The Sandy supplemental was unprecedented in its support for natural resilience solutions, with funding available for protective measures like restoration of sand dunes and wetlands, water-absorbing measures like green roofs and permeable pavement, as well as ecosystem restoration at parks, refuges and Tribal lands in the region.

Develop a consistent approach to valuing the benefits of green approaches to infrastructure development and develop tools, data, and best practices to advance the broad integration of green infrastructure. The agencies are in the process of developing tools for encouraging the broader adoption of green infrastructure.

As we showed in “Harnessing Nature,” Natural solutions have proven value in helping to protect people and communities from some of the challenges that climate change will bring, like storms and floods, droughts and wildfires, and deadly heat waves. With the release of the Hurricane Sandy Task Force recommendations, hopefully the region – and the nation – will embark on a path to their broader adoption.

Brown Pelican, USFWS

Posted in Climate Change, Federal Policy, Florida, Imperiled Wildlife0 Comments


Quit Your Grousing! Debunking Industry Objections to Sage-Grouse Conservation Measures

The greater sage-grouse is in trouble. Populations have been trending downward for years with many factors contributing to the species’ decline. Scientists have documented no fewer than 26 land uses and related effects that threaten sage-grouse, ranging from energy development and livestock grazing, to invasive species, wildfire and disease.

In 2010, the U.S. Fish and Wildlife Service determined that sage-grouse warranted protection under the Endangered Species Act (ESA), but that listing was precluded by other, higher priorities. But then just a year later, the agency committed in a court-approved settlement agreement to address sage-grouse for listing by 2015. After decades of population declines and habitat loss, this charismatic prairie dancer will finally receive a listing decision in two years.

Sage-grouse need large expanses of healthy sagebrush steppe to survive. Tatiana Gettelman/Flickr.

The certainty of the decision has prompted the Bureau of Land Management (BLM) and other federal and state agencies to initiate an unprecedented planning effort to conserve sage-grouse across its range. This process has produced new compilations of science-based recommendations for conserving sage-grouse.

Among these is “A Report on National Greater Sage-Grouse Conservation Measures” written by a National Technical Team (NTT) of sage-grouse experts and land managers. The NTT report asserts that the BLM must adopt a “new paradigm” for managing sage-grouse, including much stricter land use standards on public lands to conserve grouse habitat.

Although they claim to support the species’ conservation, extractive industries are becoming nervous about what may be required to protect sage-grouse and their habitat. The NTT report, in particular, has drawn heavy fire from resource users that would prefer business as usual on public lands, including strong objections from the Northwest Mining Association (NMA), which published a critique of the NTT recommendations. A journalist invited Defenders of Wildlife to comment on the NWA report. If you are feeling wonky, you may be interested in our review, below.


I have read the Northwest Mining Association’s (NMA) report, “BLM’s NTT Report: Is It the Best Available Science or a Tool to Support a Predetermined Outcome?” The NWA report is meaningless. The author misunderstands the relationship between the Bureau of Land Management’s (BLM) sensitive species policy and the National Technical Team’s (NTT) conservation recommendations for sage-grouse. While the BLM’s sensitive species policy requires the agency to conserve sensitive, candidate and listed species, it doesn’t include actual management prescriptions for doing so. The NTT report, on the other hand, presents recommendations by 23 sage-grouse experts and land managers (including 14 BLM officials) to conserve and recover sage-grouse. Fully implemented, the NTT report recommendations would help BLM meet its policy requirement to conserve sensitive species. In other words, the NTT report doesn’t replace the sensitive species policy, it is intended to guide agency management to achieve the goal of that policy.

The NMA report is also confusing, makes numerous baseless contentions and twists applicability of federal environmental law and regulation to reach strained conclusions about the NTT report. I have highlighted just a few of the questionable contentions from the report below.

“As such, [the NTT report] inappropriately discards an existing agency [sensitive species] policy without ever justifying the radical change advanced in the NTT [report], and is thus arbitrary and capricious” (p. i).

As noted above, the NTT report is intended to help BLM achieve the goal of its sensitive species policy. The NTT report recognized that BLM must commit to a “new paradigm” to manage sagebrush steppe and conserve sage-grouse (NTT report: 6). The report “provides the latest science and best biological judgment to assist in making management decisions” for sage-grouse (NTT report: 5).

“To that end, failing to include full implementation of Manual 6840 and the 2004 Guidance as an alternative in the Draft EIS documents is arbitrary and capricious, and the Draft EIS documents should not be published for public review until full analysis of this alternative is included” (p. ii).

See explanation of the BLM sensitive species policy above. The BLM will fully analyze all alternatives in sage-grouse planning documents in accordance with the National Environmental Policy Act.

“Additionally, information just made public by the Federal government has revealed that BLM is presently incorporating elements of the NTT Report’s conservation measures into many of its 79 Resource Management Plans impacted by sage grouse through interim guidance prior to completing the EIS process” (news release).

This statement is further evidence of the author’s lack of awareness of the current sage-grouse planning process. The BLM announced as early as summer 2011 that it would update resource management plans with sage-grouse management prescriptions to support the species’ conservation and recovery on public lands. The agency also announced the policy in an instruction memorandum and a rangewide scoping notice in winter 2012. The planning process is depicted on a rangewide planning map that is regularly updated by the agency.

“…BLM chartered the Sage-Grouse National Technical Team who was charged with developing policy on how to manage sage-grouse conservation and protection under its jurisdiction, and against which all BLM activities would be measured” (p. 1).

The NTT report recommends management prescriptions to conserve and recover sage-grouse on public land. It is not a document by which “all BLM activities would be measured.” BLM Instruction Memorandum 2012-044—which was issued with the NTT report, and which the NMA report failed to reference—instructs BLM planners on how to use the NTT report (as well as the 2004 sage-grouse guidance) to update sage-grouse plans.

“…lack of consideration of the Policy for the Evaluation of Conservation Efforts (PECE)” (p. 1).

The PECE policy is the Fish and Wildlife Service’s guidance for measuring the effectiveness of conservation efforts to protect imperiled species. While the policy may be a helpful reference for BLM in developing sage-grouse conservation measures, it would be odd for the BLM to analyze the FWS policy itself in their planning process.

“To achieve the primary objective the NTT sets forth sub-objectives. Two of the four sub-objectives assert that 70% of the range within priority habitat needs to provide ‘adequate’ sagebrush habitat to meet sage-grouse needs, and that discrete anthropogenic disturbances in priority habitat be limited to less than 3% of the total sage-grouse habitat regardless of ownership (NTT at 7). These objectives are not supported by the literature” (p. 2).

These prescriptions were not only supported by science when the NTT report was written, new peer-reviewed research published this spring (Knick et al. 2013) confirms that sage-grouse persistence depends on large, undisturbed landscapes (<3% anthropogenic disturbance) mostly covered by sagebrush (average 79% sagebrush cover within 5 km of active leks).

The NMA report, citing others, criticizes Greater Sage-Grouse: Ecology and Conservation of a Landscape Species and Its Habitats (monograph).

The sage-grouse monograph was written by the top 38 sage-grouse and sagebrush experts in the world, edited by S. Knick and J. Connelly (experts on sagebrush and sage-grouse ecology), technically edited by C. Braun (sage-grouse expert), published by Studies in Avian Biology (Cooper Ornithological Society) and printed by the University of California Press. While NMA may not agree with information presented in the monograph, there is no questioning its validity.

“We were unable to obtain the following source. As such, any conclusions that are drawn in this report relating to this source are subject to change: M.J. Wisdom, Factors Associated with Extirpation of Sage-grouse. 2011. Pages 451-472 in S.T. Knick and J.W. Connelly (editors). Greater Sage-grouse: Ecology and Conservation of a Landscape Species and Its Habitats. Studies in Avian Biology (Vol. 38). University of California press, Berkeley, California, USA” (p. 14-15, fn. 25).

Interesting that the NMA report would criticize the sage-grouse monograph without even having a copy to review. The monograph is available for purchase and the chapters are easily acquired from individual authors.

“The peer reviewers recognized the lack of discussion related to current state level sage-grouse plans, and other regulatory mechanisms that are protective in nature, as well as the complete disregard of Federal Land Policy Management Act (FLPMA) and PECE considerations” (p. 6).

See above explanation of the relationship between federal law and policy and the NTT report. FLPMA and the BLM sensitive species policy are management requirements; the NTT report presents scientific recommendations for achieving management goals. Also, most states are still in the process of developing sage-grouse conservation plans. Some of them are not very helpful to sage-grouse.

“In other words, all BLM needs to do is monitor and implement its own policy with regards to “special status species” under the Manual and provide data to USFWS in a useable format so that they can show reliable, quantifiable trends relating to the effectiveness of the Manual’s provisions in RMPs to the USFWS” (p. 8).

The problem with this assumption is that the Fish and Wildlife Service has already found that current BLM management done in accordance with its sensitive species policy and other law and regulation has failed to conserve sage-grouse. This is why the BLM commissioned the NTT report—to provide additional guidance for improving sage-grouse conservation on public lands.

Posted in Imperiled Wildlife, Public Lands0 Comments

Climate Change and NEPA: Getting it Right

Climate Change and NEPA: Getting it Right

The National Environmental Policy Act (NEPA) was signed into law in 1969 and has gone on to be one of our country’s most important environmental laws. The law creates a framework and process by which federal agencies must consider the impacts of their actions on the environment – including natural resources, human health, infrastructure, and land use. Since climate change is one of the most important environmental issues to emerge in the past few decades, and promises to remain so for the foreseeable future, it is clear that NEPA has an important role to play in how agencies consider the effects of climate change both on their investments, and also on the resources that their projects affect. It is increasingly critical for agencies to thoughtfully and thoroughly consider climate change, from both an emissions and adaptation standpoint, as part of NEPA analysis, particularly in the most detailed and through decision documents, Environmental Impact Statements.

In order to facilitate agencies’ consideration of climate change, the administration released Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions in 2010. The Draft Guidance clearly indicated that relevant climate information includes both greenhouse gas emissions information, and also climate change impacts and adaptation. To date, however, most of the attention paid to the guidance has been from the point of view of emissions analysis.

To get a better understanding of whether and how well agencies were incorporating the adaptation recommendations, we analyzed 154 Final Environmental Impact Statements released between July 2011 and April 2012. To our dismay, we found that very few incorporated the climate adaptation elements of the 2010 draft guidance. Even the best-performing EISs tended to incorporate climate change into a limited number of the elements of the affected environment, failed to make a full comparison between the various alternatives, or used short and qualitative statements rather than full analysis based on the best available science. We explore the possible reasons for this and present recommendations for overcoming these obstacles in our new report Reasonably Foreseeable Futures

The Chiracahua Mountains in the Coronado National Forest support the sky island ecosystems of the southwest, some of the most unique and biodiverse areas on our public lands.  Portions of the sky islands would be put at risk by this bill.

The Chiracahua Mountains in the Coronado National Forest support the sky island ecosystems of the southwest, some of the most unique and biodiverse areas on our public lands. These ecosystems are severely threatened by climate change, and climate-smart management will be key to their survival.


Posted in Climate Change, Federal Policy, National Forests, National Wildlife Refuges, NEPA, Public Lands, Smart from the Start, Uncategorized0 Comments

Graphium sarpedon

Paying the Price of Extinction Debt

The fact that species are being lost at an unprecedented rate is not in dispute, but how can conservation biologists who are trying to create protected areas account for extinctions which are occurring today because of events in the past?

Extinction is a natural process, but the current rate of species loss – at least 100 times what would be expected under normal conditions1 – is anything but natural. It is common knowledge that species are being lost as a result of human activities, but the fact that extinctions can occur because of historical events as well as contemporary pressures is less well known. This phenomenon is called extinction debt2 and has been documented by researchers working in a range of habitats3, 4, 5.

When an area of habitat becomes fragmented, the isolated patches which remain are not able to support the same array of species as the intact site due to a reduction in the amount of available resources. Over time, many of the species trapped within the patch will die off until, eventually, a new equilibrium is reached and the patch is only occupied by the species that it is able to support. The time taken for equilibrium to be reached is known as “relaxation time”3, because the habitat patch is relaxing back to equilibrium after a considerable disturbance.

In 2012, researchers from Japan studied the diversity of butterflies in a range of habitat patches scattered across Tokyo. They discovered that existing species richness was more closely correlated with the habitat conditions of 1971 than present day habitat conditions5, an indication of an extinction debt that has yet to be paid. They also mapped the predicted extinction debt of different habitat patches and found that the loss of species from large patches is likely to be lower than the loss from small patches5.

Graphium sarpedon

Graphium sarpedon, the blue triangle butterfly, is frequently found in Tokyo, where Soga and Koike (2012) mapped the potential extinction debt of butterfly species found in habitat patches in urban environments.

Source: Wikimedia Commons

Maps which indicate where biodiversity is likely to decline in the future can be used to inform prioritization. Instead of focusing limited resources on the protection of areas that are projected to lose biodiversity, conservation practitioners can more optimally focus their efforts on areas where species are more likely to persist into the future. Prioritization can even be based around the newly emerging concept of “conservation credit”6, which accounts for the colonization of newly suitable habitat by species from other areas.

However, it is important to remember that the disturbances and fragmentation leading to species loss through extinction debt are, in the majority of cases, the result of human activities. Extinction debt doesn’t just illustrate the complexity of the current biodiversity crisis; it emphasizes the importance of protecting habitat in the present in order to secure biodiversity into the future.


1. Pimm, S.L., and C.N. Jenkins. 2005. Sustaining the Variety of Life. Scientific American 293: 66 – 73
2. Tilman, D., R.M. May, C.L. Lehman, and M.A. Novak. 1994. Habitat destruction and the extinction debt. Nature 317: 65 – 66
3. Diamond, J.M. 1972. Biogeographic kinetics: estimation of relaxation times for avifaunas of southwest Pacific islands. PNAS 69: 3199 – 3203
4. Krauss, J., R. Bommarco, M. Guardiola, R.K. Heikkinen, A. Helm, M. Kuussaari, and R. Lindborg. 2010. Habitat fragmentation causes immediate and time‐delayed biodiversity loss at different trophic levels. Ecology Letters 13: 597 – 605
5. Soga, M. and S. Koike. 2012. Mapping the potential extinction debt of butterflies in a modern city: implications for conservation priorities in urban landscapes. Animal Conservation 16: 1 – 11
6. Vellend. M., and H.M. Kharouba. 2013. Setting conservation priorities when what you see is not what you get. Animal Conservation 16: 14 – 15

Posted in Imperiled Wildlife0 Comments

Spawning salmon

Oregon’s O&C Public Lands: Legacy, Legislation and the Future of these Federal Forests

Railroad companies interested in westward expansion in the 1800s got a great deal from the federal government. To spur development of rail lines, Congress regularly granted companies public land that they could then sell or develop as an economic incentive for their investment in building railroad infrastructure. These land grants were often conferred in a checkerboard pattern, with  alternating blocks of land given to the railroad companies and retained by the government, which has resulted in endless management challenges ever since.

Speed forward several decades. In 1916, Congress determined that the Oregon and California, or O&C, railroad project had failed to meet its commitments for rail development from, you guessed it, Oregon to California, and took back, or “revested” the land the government had granted the company. Congress subsequently enacted special legislation in 1937, the O&C Act, reclaiming the lands, which now comprise about 2.1 million acres in western Oregon. These O&C lands were to be managed by the Department of the Interior’s Bureau of Land Management, or BLM:

…for permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with the principal of sustained yield for the purpose of providing a permanent source of timber supply, protecting watersheds, regulating stream flow, and contributing to the economic stability of local communities and industries, and providing recreational facilities . . . 

Old-growth forest

Old-growth forest on O&C lands.
Credit: Chandra LaGue, Oregon Wild.

The O&C Act also granted the 18 Oregon counties where O&C lands are located 75 percent of revenues generated from timber sales on the these lands. The counties still collect at least 50 percent of timber revenues today.

Zip forward a few more decades, when technology allowed for massive clearcutting of forests throughout the Northwest, including on O&C lands. Huge volumes of timber came off public forests in the 1970s and 80s, producing huge amounts of revenue to the O&C counties (which also began to take the federal revenue for granted and kept their own property taxes among the lowest in Oregon). But that harvest was unsustainable and in the early 90’s it came to a head, as species like the spotted owl and marbled murrelet, dependent on complex old-growth forests, showed precipitous declines—indicators of the ecological problems created by unsustainable logging of ancient forests.

Old-growth logging and its environmental consequences ultimately became a political issue in the 1992 presidential election. Candidate Bill Clinton promised to do something about it, and soon after he was elected he convened a forest summit in the Northwest and established a science-based process for developing a plan to conserve forest ecosystems while supporting a sustainable timber supply and rural jobs. The “Northwest Forest Plan,” finalized in 1994, adopted a system of conservation reserves, created a “matrix” for managing forests outside reserves, and established management standards to ensure the persistence of the northern spotted owl and other old-growth dependent species, protect watersheds and salmon, and provide a sustainable timber supply.  O&C lands became a core part of the Northwest Forest Plan, and for the past twenty years, those lands have been managed under the standards and guidelines of the plan.

Spawning salmon

Threatened salmon spawn in streams that flow through O&C lands. Credit: Bureau of Land Management.

The Northwest Forest Plan was also paired with additional assistance to rural communities to provide job training and other measures to transition to a new economy less dependent on old-growth forest logging. These federal resources were of considerable benefit to individuals and communities who chose to avail themselves of them.

Zoom forward another two decades, and now we’ve arrived to our situation today. Some O&C counties have failed to diversify their economies, and a number of timber mills have not adapted to the market conditions of 2013. In addition, federal appropriations to counties that were part of the earlier transition package are drying up, leaving some O&C counties with major budget shortfalls. This is why there is intense political interest to “solve” the problems facing rural western Oregon.

Representative Peter DeFazio of Oregon has proposed disastrous legislation that would carve out over a million acres of the O&C lands, de-federalizing them by creating a timber “trust” managed by local counties, timber industry representatives and others for the sole purpose of expediting and increasing timber production. This proposal would essentially privatize lands belonging to all Americans for the narrow and exclusive financial benefit of local counties and the timber industry.

But the real action is with Oregon’s Senator Ron Wyden, chair of the Senate Energy and Natural Resources Committee. In June he released a framework for legislation to address the issues facing O&C counties which:

  • …sets aside a “substantial” but undefined portion of the 2.1 million acres of O&C lands for accelerated and expanded commercial logging at an uninterrupted rate—a rate that can only be ensured by restricting the application of federal environmental laws.
  • …calls for limiting environmental review to “an initial review of all lands set aside” for timber harvest. This so-called “modernization” of federal land management planning would require an override of consultation requirements under the Endangered Species Act (ESA), which are the heart of the ESA’s protection for imperiled species.
  • …is silent on the conservation of mature forests—stands aged 80-120 years—which are vital to the survival of salmon, spotted owls, and other imperiled fish and wildlife. While his framework takes no position on stands of this age class, it will be impossible to meet the elevated harvest targets that Senator Wyden is promoting without aggressive harvesting in these forests.
  • …re-links county revenue generation to logging on federal public lands creating a powerful constituency for unsustainable high levels of extraction.

Senator Wyden’s framework envisions significantly increasing timber harvest on hundreds of thousands of acres of federal forests above the allowable levels set by the Northwest Forest Plan. Intensive logging at this scale with only the barest, one-time programmatic environmental review would contribute to the serious decline or loss of many imperiled plant and animal species from Northwest forests. (Consider, for example, that in 1991, BLM sought approval to proceed with 44 timber sales on just 4,500 acres of old-growth forests, even though this logging would have put the continued existence of the northern spotted owl in jeopardy.) Plus, O&C lands are the heart of the Northwest Forest Plan and aggressive harvests will inevitably undermine conservation strategies for imperiled species like the spotted owl, marbled murrelet, and salmon, and necessitate greater mitigating harvest restrictions in California and Washington.

O&C lands are key to the success of the Northwest Forest Plan.

O&C lands are key to the success of the Northwest Forest Plan.

The framework put forth by Senator Wyden would also establish a negative precedent for managing public lands and resources. O&C lands are federal public lands that benefit all Americans, and narrow, special interest legislation that limits environmental review and dedicates large areas to a single extractive use is counter to both existing law and our modern values for administering the public domain. Unlike fun times in Las Vegas, what happens on O&C lands will not stay on O&C lands and will affect federal forest management in California and Washington, and beyond.

Finally, the Wyden framework is not a path to a healthy environment and a vibrant economy. Unsustainable logging is…unsustainable. The timber industry and affected counties must adapt to a reduced timber supply from public lands and O&C counties must finally raise their property tax rates so they are comparable to rates for other Oregon counties. Logging conducted with only cursory environmental review and planning would threaten a host of imperiled species and other values public forests provide, including clean water, wildlife habitat, recreation and sustainable economic opportunities that are the foundation of the new economy in the New West. Congress should provide support to O&C communities to transition to stronger economies, but without linking federal payments to arbitrary and fixed timber production targets.

Senator Wyden is expected to introduce legislation based on his framework later this summer. Defenders of Wildlife and partners have already signaled our concerns about the framework that he has offered in multiple communications to his office. We will continue to engage in the legislative debate on O&C lands to ensure that any future management scheme for O&C lands—public forests that support a breadth of public values—supports and reflects the broader public interest of all Americans.

Posted in ESA, Federal Policy, Legislation, National Forests, NEPA, Public Lands, Uncategorized0 Comments

dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.