Archive | Public Lands

2-Forest-with-heavy-invasion1-300×225

Earthworm Invasions: Here’s Something to Make us Squirm

An astounding sixty of the 182 total species of earthworms that occur in the United States and Canada come from other lands. Not all of these foreign earthworms are destructive, but about 16 European and Asian varieties do real damage to our native ecosystems. During the Wisconsonian glaciation, native earthworms in North America were severely impacted by the ice sheets then covering much of the continent. In areas north of this glacial boundary, the absence or lowered populations of native earthworms later facilitated the spread of the exotic invaders.

Invasive, exotic species are recognized as a leading cause in species’ declines and extinctions. Exotic species tend conjure up the most conspicuous instances, for example, pythons invading the Everglades or lionfish in the Florida Keys and Caribbean. On a more subtle level, exotic plants and animals often compete with native species and change entire ecosystems, such as when multiflora rose take over wetlands inhabited by bog turtles. Introduced earthworms probably do not even come to mind as an exotic nuisance. Nevertheless, earthworm invasions and their ability to damage ecosystems have become a global problem. Invasive worms have now spread through almost every habitat, including desert oases. Except for Antarctica, they occur on every continent and many oceanic islands.

Usually out of sight, all worms tend to look more or less the same. And earthworms would seem to be a good thing. Gardeners, composters, fishermen, students needing specimens for dissection, and robins feeding young certainly think of worms in positive terms. The role that earthworms play in building and aerating soils is well known. In the early 1880s Darwin demonstrated that worms on just one acre of land could convert living and dead vegetation into 18 tons of productive soil in just twelve months.

Earthworm invasions have depleted herbaceous plants and seedlings, the litter layer, and led to patches of bare soil in this Wisconsin forest. Photo by Scott Loss

Earthworm invasions have depleted herbaceous plants and seedlings, the litter layer, and led to patches of bare soil in this Wisconsin forest. Photo by Scott Loss, Smithsonian Magazine

Under normal conditions it takes microbes and fungi three to five years to decompose a deciduous leaf to the point that it becomes incorporated into the soil. In a forest infested with introduced night crawlers, however, this process takes as little as four weeks. Although organic duff covering a forest floor may take decades to accumulate, duff can be consumed by introduced earthworms in short order. Accumulation of undecayed and decaying litter is an important feature of temperate forest ecosystems. Exotic earthworms decompose this leaf layer more rapidly than their native counterparts, compromising this micro-habitat on the forest floor. Conditions become unsuitable for seed germination and the various creatures dependent on leaf layer for foraging, humidity, and concealment. In addition, the levels of moisture, temperature, pH, and nutrient levels change substantially. Eventually, this redistribution of organic matter and nutrient loss results in declines in native understory plant cover and an increase in nonnative plants. Soils are often exposed as every leaf, small seed, and tiny twig is devoured by the highly-efficient introduced worms. Soil exposure can then lead to erosion.

Many of the harmful invasive earthworms in the United States arrived in the 18th century. They were accidentally introduced in soil surrounding bulbs and rootstocks of plants brought to the New World by Europeans wanting familiar species for gardens and landscaping. In more recent times, additional species of worms were introduced from Europe and Asia, and cultured on worm farms for use as fish bait. The annual global export of earthworms is a multimillion-dollar business. Unlike many of our native species, these exotic worms are tolerant of disturbed habitats and have high reproductive rates.

Invasions of non-indigenous worms harm woodland wildlife. Worms alter the habitat used by ground roosting bats, ground foraging birds, terrestrial salamanders, and invertebrates that inhabit leaf litter. In addition, changes in leaf litter result in loss of mycorrhizal fungi, thereby paving the way for exotic plants. Because most of our native understory requires a deep, rich, and fertile layer of leaf litter for germination, these invasive earthworms threaten woodland ferns and spring wildflowers like bellworts, trilliums, yellow violets and wild ginger. Invasive earthworms have already denuded forests in the Great Lakes. It’s enough to make you squirm…

David S. Lee

Guest blogger

The Tortoise Reserve, White Lake, NC

 

J. Christopher Haney, Ph.D.

Chief scientist

Defenders of Wildlife

Posted in private lands, Public Lands0 Comments

Lower Klamath National Wildlife Refuge

Strategically Growing the Refuge System

The U.S. Fish and Wildlife Service recently issued a draft “Strategic Growth Policy” for the National Wildlife Refuge System.  The draft policy is intended to guide how the Fish and Wildlife Service will add lands and new wildlife refuges to the refuge system.  This policy is sorely needed and long overdue. As the Service points out in the release of the draft policy, the complexities of modern conservation and its limited budgetary resources require the Service to be strategic in all facets of conservation, particularly when making long-term investments like land protection.

As I point out in my comments on the draft policy, climate change in particular requires the Service to reevaluate its approach to land protection policies.  The National Fish, Wildlife and Plants Climate Adaptation Strategy, co-developed by the Service, states this new challenge well:

“Increasing the number, quality, and size of conservation areas can increase the opportunities for individual species to adapt to climate change, and also make it more likely that native biodiversity will be conserved. Some species’ habitat under climate change may be well outside their current or historic range. Healthy and biologically diverse ecosystems are likely to better withstand or adjust to the impacts of climate change. Increasing the number (redundancy) and distribution of protected fish, wildlife, and plant populations is important for the same reason. Establishing larger and more hospitable conservation areas for species to transition to will also increase opportunities for species to create new assemblages of species that are better able to persist in a dynamic climate.

Arctic National Wildlife Refuge. Image courtesy USFWS

Arctic National Wildlife Refuge. Image courtesy USFWS

Another challenge will be providing corridors between conservation areas so that species can freely move to new locations with suitable habitat. Protecting and restoring large blocks of habitat and using linkages and corridors to develop networks for movement will facilitate connectivity. Riparian corridors, such as floodplains, are useful as a conduit for migratory species and for providing access to water. In addition, appropriate transitory or “stopover” habitat for migratory species can promote biological connectivity between non-physically connected areas.”

The first goal of the Wildlife Adaptation Strategy emphasizes the need for identifying and conserving areas for an “ecologically-connected network” of public and private terrestrial, freshwater, coastal, and marine “conservation areas that are likely to be resilient to climate change and to support a broad range of species under changed conditions.”  In addition, the Wildlife Adaptation Strategy calls for the conservation and restoration of “ecological connections among conservation areas to facilitate fish, wildlife, and plant migration, range shifts, and other transitions caused by climate change.”  This goal was recently adopted by all the Landscape Conservation Cooperative Coordinators: “LCCs support the creation of an ecologically connected network of landscapes, as defined in the National Fish, Wildlife and Plants Climate Adaptation Strategy.”  This should be the overarching goal of the Service’s Strategic Growth Policy, identifying the refuge system’s specific role in achieving this goal across the nation with partners.

The FWS derives its authority for developing this new policy from the 1997 National Wildlife Refuge System Improvement Act which directs the Secretary of the Interior (acting through the Fish and Wildlife Service Director) to “plan and direct the continued growth of the System in a manner that is best designed to accomplish the mission of the System, to contribute to the conservation of the ecosystems of the United States, to complement efforts of States and other Federal agencies to conserve fish and wildlife and their habitats, and to increase support for the System and participation from conservation partners and the public.”

The draft policy excluded the highlighted portions of this provision.  These mandates provide critical direction directly relevant to this policy, and should be incorporated and implemented in the final policy statement.  Importantly, this provision, in its entirety, provides the legislative authorization for the refuge system to support the ecologically-connected network of conservation areas identified in the Wildlife Adaptation Strategy.  In our view, this important provision of law guides the Service to assess the entire “conservation estate” (the existing mix of federal, state, tribal, local, and private conservation lands and waters) and build upon it, focusing on those ecosystems that are not sufficiently protected by our existing conservation network.

Lower Klamath National Wildlife Refuge. Image Courtesy of USFWS

Lower Klamath National Wildlife Refuge. Image Courtesy of USFWS

The draft policy incorporates many important modern landscape-level conservation planning elements into planning for new and expanded refuges.  The policy requires land acquisition planners to explicitly identify conservation targets, look to “national, Regional, State, Landscape Conservation Cooperative (LCC), or species-specific conservation, management, or recovery plans” for science-based management objectives and to help identify priority conservation areas.  The policy also requires projects to identify vulnerability and resiliency to climate change and other stressors and “describe how the Refuge System will mitigate stressors to ensure the project’s resiliency.”  Our comments focused on improving and strengthening the provisions pertaining to these important concepts to provide clarity to refuge land protection planners and ensure they are actually implemented and operationalized to make strategic conservation investments in the refuge system.

As the only federal land system that can administratively create new units, the refuge system has a unique role to play in conserving the nation’s wildlife and ecosystems in the face of climate change, rapid development, and other landscape stressors.  The final Strategic Growth Policy for the refuge system needs to ensure that refuges play this unique role in the most effective way possible.

Posted in Federal Policy, National Wildlife Refuges, Public Lands0 Comments

sage_grouse_Tatiana_Gettelman

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 et.al., 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

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, Uncategorized1 Comment

Sage Grouse Crossing

A Conservation Checklist for Sage-Grouse

The greater sage-grouse has been of conservation concern for more than 100 years, when both locals and visiting naturalists first observed population declines. Conservationists began advocating for protection for the species 15 years ago and, after a “convoluted journey” through the federal Endangered Species Act listing process, the U.S. Fish and Wildlife Service will finally consider the species for listing in 2015.

This date certain for a listing decision has compelled a multitude of federal and state agencies and local entities to finally develop conservation strategies to protect and recover sage-grouse and their habitat. Defenders of Wildlife is heavily engaged in these planning processes. We are analyzing thousands of pages of documents and working to improve federal and state conservation strategies for the species. To this end, we have developed a science-based checklist to evaluate planning efforts.

A successful sage-grouse conservation plan will include, at a minimum, the following measures to ensure sage-grouse conservation. They are based on sage-grouse and sagebrush ecology, as well as key principles of conservation biology of protecting and managing habitat to conserve species. The checklist also addresses three sage-grouse habitat categories—“priority,” “restoration” and “general” habitat—that federal and state agencies have already defined for sage-grouse planning purposes.

  1. Identify, designate and preserve priority habitat essential to sage-grouse conservation and restoration. The first rule for conserving imperiled species is to prevent continued loss and degradation of habitat essential for the species persistence. This is especially important for sage-grouse, which are highly sensitive to disturbance, particularly in their breeding, nesting and brood-rearing habitat. Protecting winter habitat is also critical for sage-grouse conservation.
  2. Create and expand existing protected areas critical to sage-grouse and sagebrush conservation. Some proportion of remaining sage-grouse range is so important for conservation that it should be protected and specially managed as permanent reserves for sage-grouse and other sagebrush-dependent species. These can include new and expanded national wildlife refuges; Congressional designations, such as wilderness and national conservation areas; and administrative allocations, like areas of critical environmental concern. A reserve system should protect large expanses of sagebrush steppe, important seasonal habitats and connectivity, and the system should be large enough to achieve the goals of biological representation, and ecological redundancy and resiliency.
  3. Designate restoration habitat to focus habitat restoration efforts. Restoration habitat is degraded or fragmented habitat that may not be currently occupied by sage-grouse, but might support the species if restored. Land managers should target passive and active habitat restoration efforts in these areas to extend current sage-grouse range and mitigate for future loss of priority habitat.
  4. Reduce and mitigate threats in sage-grouse general habitat, outside of priority habitat, protected areas, and restoration habitat. The goal for managing general habitat is to support habitat connectivity and increase sage-grouse populations within and outside of the other sage-grouse habitat designations.
  5. Develop adaptive management plans with sciencedriven triggers that indicate when management is not leading to desired outcomes. Plans should institute adequate, consistent, objective-driven monitoring keyed to appropriate indicators that provide the information needed for adaptive management—and then require changes when current management fails to meet conservation objectives.

These simple, sensible precepts, if adopted and implemented across sage-grouse range, would provide a basis for sage-grouse restoration in theWest. We encourage Defenders’ members and supporters to participate in the current planning process for greater sage-grouse. Navigating these bulky, intimidating, but vitally important conservation plans will be far more manageable with our conservation checklist in hand.

Sage Grouse Crossing

Posted in Imperiled Wildlife, Public Lands0 Comments

Defenders Comments on New Forest Planning Directives

Defenders Comments on New Forest Planning Directives

As long time followers know, Defenders has been working hard to shape National Forest conservation policy for decades, including non-stop campaigning for the last several years to make sure new forest planning regulations conserve and recover forest dependent wildlife.  To ensure that these new rules translate into real on-the-ground protections for wildlife and forest ecosystems, Defenders kicked off our Forests for Wildlife Initiative.  The goal of the initiative is to transform how the Forest Service manages forests for wildlife, and to protect and restore national forest landscapes through on-the-ground conservation projects and actions.

The Forests for Wildlife Initiative takes us from the policymaking world of Washington D.C., to the majestic landscapes of Alaska and California.  Last year, I was appointed by the Secretary of Agriculture to a Federal Advisory Committee charged with overseeing implementation of the new planning rule.  One of the committee’s first tasks was to work with the Forest Service to craft policy “directives” that will guide how the new regulation is interpreted and applied to individual national forests.  Our comments on the draft directives can be found here.  The complex forest policy world is like an onion trapped in a spider’s web.  Numerous statutes govern the management of National Forests, including the National Forest Management Act, as well as associated federal rules and regulations.  Keep peeling and one finally gets down to the highly technical internal agency policies that tell forest managers how to navigate and implement all of the various rules and regulations.  The directives tell managers “how” to do the “what”— the requirements that are spelled out in the regulations.  Good planning directives provide strong, clear direction to managers on how to identify, conserve and monitor species of conservation concern; account for ecosystem services; or manage in the face of climate change.  Poor directives can lead to inconsistent conservation decisions that could lessen protections and raise risks for forests and wildlife.

The current draft directives need some work to provide forest managers a clear path to effectively conserving forest integrity and wildlife.  The advisory committee will be working with the Forest Service all summer to make recommendations on how to improve them.  Stay tuned for more updates and campaign reports from the Forests for Wildlife Initiative.

Posted in Climate Change, Federal Policy, National Forests, Public Lands0 Comments

Incorporating Climate Change into the New Forest Planning Rule

Incorporating Climate Change into the New Forest Planning Rule

For much of the past two years, Defenders has been actively engaged in the Forest Service’s development of a new rule to guide planning within the National Forest System. We submitted extensive comments on last year’s proposed rule, but that was hardly the end of our involvement.  The Forest Service is now in the process of drafting “directives” to guide the implementation of the 2012 planning rule. As with the rule itself, we have quite a few suggestions for making it stronger, better and more clear (our full comments on the directives can be found here). This week’s blog installment focuses on incorporation of climate change.

The Forest Service has been a leader in understanding, researching, and developing policy mechanisms to deal with the impacts of climate change.  The planning rule itself broke new ground in directing forests to take into account the effects of climate change on ecosystem integrity and to incorporate climate change resilience into forest planning. We had expected, therefore, that the Directives would build on that track record and provide forest managers with clear direction on how to integrate assessment and response to climate change impacts into all phases of forest planning.  Unfortunately, the Directives don’t do much more than repeat some of the language from the planning rule itself.

Virtually absent from the directives is any clear description of the particular exposure factors associated with climate change, such as higher mean temperatures, hotter high temperatures, reduction in frost-free days, changing proportions of precipitation falling as rain vs. snow,  occurrences of extreme precipitation events, alterations in snowpack, and lengthier periods of drought (to name a few). Many species and habitats will be sensitive to one or more of these specific types of exposures, but there is no guidance on how select, evaluate or rank these. Climate-related stressors will also interact with other stressors (for instance, warmer winters may facilitate spread of invasive or noxious species that are held in check by winter die-off). Societal responses to climate change will also likely compound stresses to species and ecosystems (some examples include increased water withdrawals from stream systems in response to drought and heat, and habitat modification to reduce fire risk at the wildland-urban interface). Nowhere do the directives recommend how to find, evaluate, and use this information in forest planning.

The directives also fail to give forest managers a path for selecting appropriate responses. This is a pretty glaring omission, given that the Forest Service has already published extensive resources on various adaptation response options: resistance, resilience, response, and re-alignment. We had hoped that the directives would provide managers with a means to choose among these responses and select plan components to achieve those aims, but it does not do so.

Even worse, the directives at times seem to give managers an easy way out of doing the hard thinking about responding to climate change. For instance, the “Ecosystem Integrity” section of the assessment language says, “Where information is available, the responsible official should consider the influence of climate change. . .” (emphasis added). Later, the directives use climate change as an example of “factors outside of the agency’s control.” We are concerned that conditional language like this is tantamount to allowing planners an excuse to avoid the sometimes difficult task of finding and evaluating climate change information that may be applicable to the situation at hand. We see a high potential for this kind of omission to occur, given that the directives have provided so little guidance on where to find climate change information and how to incorporate it into assessment.

Defenders has submitted comments to the Forest Service pointing out these and other flaws in the directives, which will make it difficult for forest planners to realize the planning rule’s potential benefits to biodiversity over time. Stay tuned to find out if they take our recommendations into account.

Posted in Climate Change, Federal Policy, National Forests, Public Lands0 Comments

How Will the Forest Service Address Ecosystem Services in Forest Planning?

How Will the Forest Service Address Ecosystem Services in Forest Planning?

The Forest Service recently adopted new planning rule that will guide the agency’s process for forest planning for the next decade or so. For the first time, the planning rule directs the staff to consider ecosystem services when deciding what management actions to implement on the public lands. Following the adoption of the new rule, the Service issued 500+ pages of detailed “directives” to guide implementation of the new planning rule.

What are ecosystem services?  According to a recent article authored by several researchers with the Forest Service in the Pacific Northwest Research Station, In the context of public land management, ecosystem services are beneficial outcomes that derive from landscape conditions (e.g., forest structures, species compositions) and ecological processes as they are altered by both natural disturbance and management activities.

Though the draft directives mention ecosystem services multiple times, what effect this relatively new term will have on the planning process remains somewhat of a mystery. On the positive side, addressing ecosystem services may lead to the consideration of a much broader spectrum of values, including some tangible benefits like improved water and air quality, more and better fish and wildlife habitat, improvement in the condition of endangered species, and additional opportunities for nature-based recreation. The new emphasis may also lead to improved integration across programs, a reconsideration of management “targets” to include an assessment of ecological conditions and trends, and an improved understanding of context implied in the new “all lands approach” to management.  Ecosystem services assessments can also be a powerful tool for collaboration with stakeholders. Ideally, incorporating ecosystem services into forest planning will add value without overly complicating the assessment and decision process, raising the costs, or delaying implementation.

On the flip side, even a great idea can go astray if it is implemented in a manner that simply applies a new idea or term to an old way of doing business. The Forest Service staff will always be under political pressure from Congress and some interest groups to increase the output of commodities at the expense of protecting the ecological values on the land. Framed entirely as a utilitarian, anthropocentric concept, some interpret ecosystem services to include only benefits to human communities. Others extend the construct even further to emphasize only those values that can be quantified, and a cottage industry has emerged among economists offering tools and methods to assign monetary value to selected services. While it is sometimes very useful to calculate the monetary costs and benefits of different management options, it is neither necessary nor appropriate to apply dollar values to relatively intangible attributes like biodiversity.  Agencies can and do make decisions every day based on society’s evolving values and preferences, expressed in a variety of ways including the adoption of federal laws like the Endangered Species Act and National Forest Management Act. Meaningful engagement with the public during the decision process – including local, state, regional, and national interests – can lead to decisions that balance human needs for products like timber, forage and fuel against the need to sustain the lands and waters on public lands for future generations.

Given the attention that ecosystem services have received within academic and some government circles, there is also a risk that instead of adding value to the complex process of evaluating the potential benefits an ecosystem will provide over time, an entirely new process will be established.  If this new process focuses primarily on the benefits that ecosystems provide to people, without giving adequate consideration to the underlying ecological attributes and processes that create these services in the first place, then management to maximize certain ecosystem services ends up competing with, rather than enhancing values that are especially challenging to measure, like biodiversity. If ecosystem services offer a way of viewing the world in which the intrinsic values of nature are acknowledged along with utilitarian outputs, it could serve as a uniting rather than divisive force.  However, there will always be tradeoffs between services, human beneficiaries, and the needs of present vs. future generations.

There are a few important steps that the Forest Service can take to ensure that the ecosystem services requirement in the new directives has a positive influence on forest planning.

  1. Adopt the definition of ecosystem services quoted above in place of the narrower definition limited by utility to humans, thereby explicitly including biodiversity – either as a service, necessary support for services, or both.
  2. Integrate ecosystem service assessments with ecological assessments rather than creating a separate process.
  3. Ensure that the planning process is as interdisciplinary as possible, taking advantage of the expertise of natural and social scientists, practitioners, and stakeholders, working across traditional boundaries and engaging people with diverse perspectives.
  4. Working with other agencies and organizations, invest in the development of more consistent measures of ecological integrity and biodiversity across jurisdictions and at multiple scales to improve our collective capacity understand ecological conditions and trends.
  5. Integrate the ecosystem services assessments with the “all lands” approach by engaging private landowners and other agencies in the process, before attempting to quantify and/or monetize ecosystem services at the project or site scale.

The Forest Service has struggled with communicating its mission over the past few decades. Creatively applying an ecosystem services approach to explain the benefits of the public lands to Congress and the public has great potential. Although different forests will likely approach this challenge differently, the new approach may create a pathway to a more harmonious and effective relationship with the public.  Or it may continue the divisive and antagonistic relationship under a new banner until the next shiny object comes into view. There isn’t much time to get it right.

You can find Defenders’ full comments on the proposed forest planning directives here.

Posted in Climate Change, Federal Policy, National Forests, Public Lands0 Comments

Integrating Climate Change into agency NEPA decisions

Integrating Climate Change into agency NEPA decisions

The National Environmental Policy Act (NEPA) has recently been in the news as it relates to climate change, as reports surfaced that the administration is finalizing long-awaited NEPA climate change guidance (you can find the draft guidance here), outraging Senate Republicans who fear the guidance is an attempt to regulate greenhouse gases.

NEPA is exactly the right context for federal agencies to be analyzing how their proposed actions affect and are affected by climate change. Federal actions, both directly and indirectly, can and do lead to the release of greenhouse gases. In addition – and importantly, since this seems to be missing from most of the debate surrounding NEPA and climate change – federal actions and projects permitted by federal agencies can be greatly affected by climate change, and affect the surrounding environment in combination with climate change. These effects need to be understood to make sound decisions and investments of federal tax dollars.

Contrary to the fears of NEPA as a regulatory force, NEPA’s purpose is not to force and prevent a particular action or outcome. Rather, its purpose is to “insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken” and “to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and enhance the environment.” As a result of agencies taking a “hard look at the environmental consequences” of their proposed actions, they can develop appropriate alternatives and mitigation measures to reduce impacts on the environment. NEPA is a critical planning tool to improve agency decision making.

The Obama administration issued draft guidance to federal agencies in 2010 on “Consideration of the Effects of Climate Change and Greenhouse Gas Emissions” under NEPA. The draft guidance lacked clarity on accounting for emissions and for understanding climate change impacts on projects and the affected environment, and it excluded federal land management decisions from the guidance altogether – a glaring omission given how sensitive land management and related natural resources are to climate change impacts. It is the finalization of this guidance that is garnering recent attention.

To assist the administration in addressing these climate impacts in the implementation of NEPA, Defenders of Wildlife recently sent a letter to the White House Council on Environmental Quality (CEQ), which is the lead office in charge of NEPA. In our letter we recommend the final guidance address the following issues:

  • Purpose and Need: the purpose and need (See NEPA implementing regulations at 40 CFR §1502.13), which should be examined to determine if they are robust in a changing climate. For instance, a project designed to protect a coastal community from storm surge will not be responding to the right “need” if it only accounts for historic sea and surge levels.
  • Environmental assessments and Findings of No Significant Impacts: Determining “significance” is a critical component of NEPA analysis, and requires agencies to look at cumulative impacts. Guidance needs to be provided for understanding how to integrate climate change impacts into cumulative impacts analysis.
  • Analysis timeframe and geographic scope: The timeframe of analysis is relevant to how far into the future to analyze “reasonably foreseeable future actions” under Cumulative Impacts (§1508.7) and definition of “Significance,” which explicitly includes both long and short term effects (§1508.27). The analysis timeframe should be long enough to cover the period over which the project will potentially be affected by and interact with climate change effects. Similarly, the geographic scope of the analysis, as referred to under Affected Environment (§1502.45) and Context (§1508.27), should be large enough to account for potential range shifts in affected species and habitats, potential changes throughout an entire watershed, and similar landscape level effects that would affect the project and project impacts.
  • Alternatives: As part of the process of development of alternatives to the proposed action (§1502.14), the agency should consider whether climate change may impact the ability of each alternative to meet the purpose and need. This should include an assessment of the vulnerability of the various project alternatives to relevant climate change impacts. Where possible, agencies should incorporate into alternatives design elements that reduce the likelihood or severity of climate change impacts. Alternatives that fail to meet the purpose and need due to projected future climate change effects should be eliminated, and this should be noted in the discussion.
  • Affected Environment: As part of the EIS process, the agency discusses the Affected Environment (§1502.15), laying out which aspects of the natural environment (water, air, biodiversity, soils, aesthetics), built environment, human health, and sustainability of resources might be affected by the alternatives. As this section is the basis for comparisons of environmental consequences, it is critical that this section cover the full range of elements that could face effects, including cumulative effects from climate change. The agency should ensure that the environmental resources being considered includes the full suite of elements that could face effects from the project, and integrate climate change threats into the discussion of each element. Climate change is expected to worsen over time, and these changing effects on ecosystems should be incorporated into the Affected Environment and no action alternative sections of an EIS.
  • Environmental Consequences: At the heart of the analyses in an environmental impact statement is the Environmental Consequences section (§1502.16), which compares “The environmental effects of alternatives, including the proposed action” (§1502.16d) on various elements of the affected environment that were defined previously. Full incorporation of climate change into this analysis is warranted by the fact that the effects of climate change constitute a cumulative impact of “past, present, and reasonably foreseeable future actions” (§1508.7) that release greenhouse gases. We recommend that guidance should be provided that requires each EIS, in its analysis of the alternatives’ impacts on each aspect of the affected environment, include a discussion of the effects to that resource from climate change, and the extent to which the impacts of the alternative will be exacerbated by climate change impacts, and its interaction with other threats, stressors, and cumulative impacts.
  • Mitigation: Mitigation as defined by NEPA, includes actions to avoid impacts; minimize impacts; rectify impacts; reduce or eliminate impacts; and compensate for impacts (§1508.20). The draft guidance broadly states that both emissions reductions and adaptive responses are included here, but provides very little detail as to how to proceed:   “The agency should identity alternative actions that are both adapted to anticipated climate change impacts and mitigate the GHG emissions that cause climate change.” More guidance should be provided to agencies, particularly outlining steps agencies can take to reduce the combined effects of the proposed action and climate impacts on the affected environment.
  • Monitoring: An important aspect of successful mitigation is a monitoring strategy to ensure the effectiveness of mitigation measures (§1505.2c). We recommend that the guidance should be strengthened to stipulate that the monitoring plan should be implemented (not just considered), and should focus on indicators relevant to both the implementation of adaptation strategies and the effects of climate change and other threats. Monitoring is particularly critical where uncertainties regarding climate change impacts or interacting effects have been identified. This plan should articulate steps to ensure the effectiveness of mitigation strategies, and a means of identifying and addressing problems that are identified through monitoring.

Climate change is already impacting federal actions across the country and across agencies, not to mention wildlife and ecosystems. Integrating climate change analysis into federal agency NEPA analysis and decision making is one of the most important steps the federal government can take to account for its contribution to global warming, and importantly, to account for and mitigate the effects of climate change on agency actions and the environment. The administration needs to take the bold step of finalizing its guidance to agencies for accomplishing this. The sooner guidance is issued, the sooner the federal government can help the nation become better prepared to address climate impacts.

Posted in Climate Change, Federal Policy, NEPA, Public Lands0 Comments

Defenders Issues New Report on Candidate Species Agreements

Several months ago, the U.S. Fish & Wildlife Service finalized its schedule for deciding whether to propose listing of almost 200 candidate species under the Endangered Species Act (ESA).  Many private landowners and state wildlife agencies are eager to conserve these species, with the goal of avoiding the need for listing.  One of their chief tools is candidate conservation agreements with assurances (CCAAs).  By entering into a CCAA with the Service, participants get an important legal assurance: if a species is eventually listed despite the best efforts of the participants, they will not be required to take any conservation actions beyond those agreed to in the CCAA.  Not a bad deal.

The Service regulation that created CCAAs was finalized in 1999 under the leadership of Jamie Rappaport Clark, Defender’s current president and CEO.  Since that time, 27 CCAAs have been finalized, but no one has ever evaluated all the agreements and few people understand how they have been used.  In fact, no online database exists of all CCAAs (the Service’s online database is currently missing four agreements).

Earlier this week, Defenders released a report that evaluates all 26 CCAAs finalized through 2012 (the 27th CCAA was issued after we completed our report).  We evaluated agreements for 1) types of activities covered, 2) types of species covered, 3) number of agreements finalized per year, 4) number of programmatic agreements (applying to multiple participants rather than a single one), 5) duration of agreements, and 6) record of preventing species from being listed.

Our evaluation of the types of activities is perhaps the most interesting.  We assigned each CCAA into one of three categories: those that authorize only activities intended to conserve species; those that authorize reintroduction of species into their former range; and those that authorize both conservation and non-conservation activities.  That’s right—not every activity authorized under a CCAA is intended to conserve a species.  The important point is that the impacts of conservation activities should outweigh those of non-conservation activities, such that the species experiences an overall benefit.

Our report also recommends improvements to CCAA implementation.  We found that Service biologists have been implementing CCAAs in innovative ways that are not discussed in the CCAA regulation or draft handbook.  We underscore eight of these innovations and encourage the Service to consider incorporating them into its CCAA guidance documents.
*          *          *          *

This CCAA report is the third in a series of Defenders reports on improving endangered species law, policy, and science.  In case you missed them, the first report describes some of our strategies for making the ESA more effective and efficient, and the second report reveals serious flaws with the Service’s decision last year to withdraw its proposed rule to list the dunes sagebrush lizard and recommends ways to avoid these problems in future listing decisions.  A week after we published the second report, we filed a notice of intent to sue the Service over the withdrawal.

Click here to view the CCAA report

Louisiana pine snake, a candidate species. Photo courtesy of Louisiana Conservationist

Louisiana pine snake, a candidate species. Photo courtesy of Louisiana Conservationist

 

Posted in Imperiled Wildlife, Paying for Conservation, private lands, Public Lands0 Comments

Blackwater Map

Wildlife Refuges on Deck for Land Aquisition Funding Vulnerable to Sea Level Rise

There are over 150 national wildlife refuges located in coastal areas, yet the Refuge System has not adequately incorporated projections of sea level rise or other climate impacts into land acquisition planning.  Thus, the U.S. Fish and Wildlife Service may not be maximizing the effectiveness of its conservation investments if it is making fee-title acquisitions or purchasing long-term easements on lands that are going to be underwater within a few decades.

To get a better picture of the situation, we used the Sea Level Affecting Marshes Model (SLAMM) to assess the threat to the lands within both the acquired and approved boundaries of eight coastal refuges that have been assigned a high funding priority for land acquisitions in the coming year.

We found that sea-level rise impact will not be felt equally among coastal refuges. Great White Heron NWR, in the Florida Keys, is the highest ranked refuge for land protection funding for FY 2013 by the Fish and Wildlife Service, yet it is extremely vulnerable to sea level rise. Two of the refuges we assessed, Great White Heron and Blackwater, face potential net loss of over 40% of refuge lands by 2075, if sea level rises by one meter over the course of the century. On the other hand, four of the refuges have less than 5% of their land area vulnerable. Some refuges, like Blackwater, will face inundation but have newly created wetlands nearby, where the refuge could potentially expand to. Others, like Laguna Atascosa NWR, will face wetlands loss that will not be readily replaced with new areas of marsh. And refuges whose land area consists mainly of low-lying islands, like in the Florida Keys, may run out of land entirely.

 

 

 

 

 

 

 

 

 

 

 

 

 

The Fish and Wildlife Service urgently needs to better understand and incorporate climate change and sea level rise implications into its land acquisition planning to avoid investments that will ultimately be literally under water.

Our summary report with policy recommendations is available here.

The complete report is available here.

Posted in Climate Change, National Wildlife Refuges1 Comment