Tag Archive | "Public Lands"

Getting Off on the Right Foot with Conservation Planning Part III: How to Define the Problem

Conservation planning is a decision-making process to identify, prioritize, pursue, and protect conservation priorities in a way that will most effectively and efficiently achieve a goal.  (Third in a three part series).

Part 2 described why defining the problem is difficult, frequently overlooked, and yet important. Below is a list of questions that should help define the problem and develop a decision statement as the first step in the planning process.

How do we begin? We should start by evaluating our current decision-making processes. Ask why and how we need to improve the way we make decisions.

Who is the decision maker? This is a surprisingly difficult question and there are several scenarios – we may have single decision-maker, delegated authority, multiple decision-makers. Stakeholders, people outside the organization or agency that have interest or power in the decisions, have influence but they may not be decision makers.

What is our decision statement? At home it may be “My kid is acting up.” Our decision statement may be “How can we improve my kid’s behavior?”  At work it may be “We face competing interests between agricultural needs and habitat goals for riparian bird populations.” Our decision statement may be: “How can we optimize protection of riparian habitat for bird populations given competing needs for agriculture”.

Are we attempting to solve the right problem? Beware of decision frame blindness. Conservation issues are not simply technical or scientific, they reflect societal values – scientific, economic, political, and cultural values.  Are there other perspectives that aren’t being considered?  Are we framing the problem by earlier successes or failures? Are our assumptions false?   

Are we recognizing intractable problems? Intractable problems have already been decided, they are decisions that are out of our control, or they are decisions that require a greater level of investment of time, personnel, and resources than we have available. Failure is highly probable unless we re-define the problem so that it is within our ability to solve.

What is the scope of the decision? When & how often will the decision be made?  How large, broad, complicated is the decision?

What are our constraints for making the decision? Are there legal, financial, political constrains for making the decision. Are they perceived or real constraints?

A well-defined decision statement might take multiple attempts, but once you have a grasp on these questions, you can most likely develop a strong decision statement and get your conservation planning process off on the right foot.

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Getting Off on the Right Foot with Conservation Planning Part II: Why Identifying the Problem can be the Biggest Challenge

Conservation planning is a decision-making process to identify, prioritize, pursue, and protect conservation priorities in a way that will most effectively and efficiently achieve a goal.  (Part II of a three part series)

Defining your decision problem is the first, most important, but  often most difficult  and overlooked step in a conservation planning process. 

A decision is as an outcome of a thought process that leads to a course of actions (among many possible actions).  A decision is many times an irrevocable allocation of resources.

What decisions do we need to make during a planning process? Values and Visions: What do we care about, and what do we want the future to look like if we are successful in our mission?  Priorities: Are some conservation values are more important to us than others? Stakeholders: Who has power and interest in what decisions we make?  If our projects are land-based, where are our conservation values located on the landscape? Strategies: What actions are we going to take to reach our conservation goals? Implementation: Who is responsible for each action and by when do we want them to implement? Monitoring: How are we going to measure our success towards meeting our conservation goals? Adaptive Management: How do we learn from our projects and readjust our strategies as needed?

Why are decisions are hard? Uncertainty: We feel we don’t have all the information we need to make conservation decisions.  Complexity: We need to consider many interrelated factors. High-risk consequences: The impact of the decision may be significant and costly. Alternatives: We may have many alternative projects with each its own set of uncertainties and consequences to weigh. Controversy: It can be difficult to predict how other people will react to our decisions?

Part 3 will describe how to define the decision problem to get off on the right foot with conservation planning.

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Getting Off on the Right Foot with Conservation Planning Part I: Why plan?

Conservation planning is a decision-making process to identify, prioritize, pursue, and protect conservation priorities in a way that will most effectively and efficiently achieve a goal.  (First in a three part series)

Why plan? Just to name a few reasons: Planning builds organizational consensus over the selection of projects and allows the organization to be more proactive. Planning improves outreach to the community by stating the values of the organization or agency and by rigorously reviewing projects for public benefits.  Planning improves chances for success with funding programs that rely on criteria for selecting successful applicants. Planning helps with vetting conservation projects for their long-term suitability to meet the mission. Planning makes conservation decisions more defensible to withstand scrutiny by outside parties and the community in general.

Seems logical enough, no?  Then why is even the idea of undertaking a conservation planning process is a seemingly overwhelming task for both small and large conservation organizations and agencies alike?  Even though we know that we need conservation planning to move us from being opportunistic  (taking projects as they  come through the door) to being more strategic (figuring out a decision process for selecting actions that will be the most effective at meeting conservation goals), we can’t seem to muster the time, energy, or resources to begin the journey.  The notion of embarking on a lengthy and complicated process, taking time away from the “real work” of conservation, and stretching limited resources even further can be a strong deterrent from planning. 

So, it seems, if we are going to plan, we should make the process as useful as possible.  No one wants to think they are being more strategic because we have a plan, then to realize down the road that their plans are not useful in the end. We all know it is pointless to go through the process of developing plans that are not being used to guide our decisions, yet it happens all of the time.  Many times it happens because the process is flawed from the beginning.

Planning Parts 2 will describe why identifying a decision problem is the biggest challenge, but one of the most important initial steps in the planning process. Planning Part 3 will describe how to define the decision-problem.

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Attacks on oil and gas leasing reforms continue

Attacks on oil and gas leasing reforms continue

Prairie dogs are among the wildlife species impacted by oil and gas drilling in the Western U.S. (Photo: Michelle Thomas).

The Obama administration initiated reforms to make the oil and gas leasing process on public lands work better for industry, government, taxpayers, and wildlife.  The reforms have received praise and  demonstrated results – environmental groups have filed fewer objections to leases in response to this more transparent process.  The reforms have also ensured full environmental reviews that examine the risks to wildlife and provide for mitigation measures whenever potential impacts are present or when previous environmental analysis has not been completed on a site.

Energy industry groups, however, have challenged the reforms from the beginning.  Reversing the reforms would mean a return to a closed system in which companies select public land acres they want to lease for drilling and proceed to development with almost no transparency, out of reach from members of the public that want to ensure wildlife, water, air quality and other concerns are fully incorporated into decision making.

Last week, at the request of an energy industry trade group, a Federal Judge in Wyoming vacated a segment of these leasing reforms.  The Western Energy Alliance sued the Department of the Interior over Secretary Salazar’s Instruction Memorandum 2010-118 clarifying the use of categorical exclusions (CX’s), which exempt certain activities from environmental review.  This memorandum is important because it responds to deep concerns about the misuse of categorical exclusions to fast-track oil and gas development projects on public lands without adequate environmental or public review.  IM 2010-118 resolved long-standing issues (highlighted by the GAO) by making the following changes:

1.      BLM would evaluate whether “extraordinary circumstances” were present that precluded use of the CXs to skip environmental review;

2.      BLM would require environmental analysis prior to permitting new drilling at a site where drilling had occurred, but might not have been analyzed before;

3.      BLM would require specific analysis of place-based development before permitting new drilling at a site that was part of a larger field (previously not required).

The judge’s decision to vacate these three targeted reforms found that the BLM’s process for changing its position on CXs was not correct – it did not find that the changes themselves were illegal or wrong.  Industry spokespeople, however, have already tried to use this ruling as proof that leasing reforms should be thrown out or ignored.  This is an incorrect interpretation of this narrow ruling.

The ruling expressed no opinion on the merits of the agency’s policies to ensure that oil and gas drilling will not proceed without necessary environmental analysis. The court’s decision means BLM cannot rely on its 2010 guidance right now, but it does not require BLM to return to a practice of endangering our wildlife and natural resources to permit drilling without any common sense limitations. The BLM retains ultimate discretion over both deciding what lands should be leased for drilling and if, how, and when they should be drilled – and the agency can and should continue to exercise its authority wisely.

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oil and gas drilling

The push to “un-reform” oil and gas leasing reform

After taking office the Obama administration took common sense steps to reverse the Bush administration’s unbalanced approach to developing oil and gas on our public lands.  The administration rightly recognized that a “drill baby drill” policy posed a significant threat to wildlife, water, wild places and western values, and was leading to more and more conflict over every lease.  In an effort to reduce the conflict in the leasing process and balance out resource considerations, the Department of Interior provided a number of reforms through Instruction Memoranda.  Reforms from these memos require the Bureau of Land Management to do things like:

  • Standardize oil and gas lease stipulations that protect wildlife and other resources by setting a baseline of protections that have to be incorporated into any drilling project
  • Incorporate new adaptive management features that allow adjustments to be made as more information is gained on how drilling is impacting the natural environment
  • Establish local “Master Leasing Plans” throughout the west to facilitate thorough environmental review of potential drilling impacts BEFORE offering leases in areas with high energy potential and high risk of environmental conflicts
  • Get rid of policies that previously reduced the amount of environmental review required for oil and gas leasing

BLM’s fact sheet on the reforms is here and a chart comparing the old and the new is here.

These reforms were an important step in streamlining and modernizing the process by fully taking into account all resources affected by leasing and by pushing leases into lower conflict areas.  However, as is the case with many of the common sense policy changes initiated on our public lands, these reforms are under attack in this Congress.  Despite the fact that recent reports show onshore oil and gas drilling at a twenty year high even with these reforms in place, a bill introduced in the Senate would reverse the administration’s reform agenda along with a number of other important progressive actions taken by the Obama administration to improve oil and gas leasing.

In addition to the bill, a recent letter from Republican Senators attacked the BLMs leasing reforms.  In response to this letter, former head of the BLM Mike Dombeck said: “It is disappointing to see members of Congress, presumably at the request of industry, attempting to roll back such common sense policies on the land that belongs to ‘we the people.’”

A halt to the Master Leasing Plans (MLPs) currently under development, in particular, would be a huge loss.  These innovative plans provide a new and powerful opportunity to avoid and minimize wildlife and other environmental conflicts that could result from poorly planned oil and gas leasing before a project is sited and investments are made.  This type of “smart from the start” planning results in a win-win because it has the potential to resolve conflicts prior to the siting and development of oil and natural gas wells, thus avoiding costly controversies that always seems to end up in court.  A law that gets rid the MLP process would stop this good policy in its tracks.

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pronghorn

Wild Lands for Wildlife

A new order from Secretary Salazar of the Department of the Interior creates a “Wild Lands” system for the BLM to preserve lands with wilderness characteristics while they await potential designation by Congress as Wilderness Areas.  This is not a new idea, but replaces a similar system that was in place until the Bush Administration got rid of it in 2003.

Pronghorn depend on public lands throughout the west for survival.

Protecting “Wild Lands” is especially important for wildlife because Wilderness Areas provide a stronghold for many of the most iconic species on our public lands, including sage grouse, bison, and pronghorn.  With more than 41 million acres of public land leased to oil and gas companies for drilling (and that’s in addition to heavy-duty mining activity and hundreds of thousands of acres of potential renewable energy development), it is necessary that the DOI hold true to its multi-use mission and provide for wilderness, wildlife habitat, and recreation as well.

Lands with wilderness characteristics spur billions of dollars in spending by outdoor enthusiasts of all types throughout the country, and these economic benefits show that a smart, effective system for preserving lands with wilderness characteristics will be a key factor in protecting both wildlife and the businesses supported by our wildlife resources.  Development levels on our public lands are skyrocketing, and Secretary Salazar’s order is an attempt at balancing out that development with a smart wilderness protection system.

We support the policy, along with 40 other groups signed onto a conservation community letter addressed to the House Natural Resources Committee.  We “believe this fundamental tool for the protection of our public lands should be supported by the Congress and encourage the members of this committee to show its support for public process on the issue of the wild character of our public lands.”

Someone needs to stand up to exaggerated attacks from Republicans on Capitol Hill, which came to a head yesterday in a hearing of the House Natural Resources committee on the Wild Lands policy.  Opposition to the policy has referred to it as a “war on the west,” accusing BLM of a land grab away from industry.  This view, however, ignores the fact that less than 30% of the millions of acres of BLM lands leased to oil and gas companies are actually being used by industry, and that a much smaller fraction has ever been subject to BLM wilderness policy.  It also ignores the $730 billion spent on outdoor recreation every year, which Black Diamond Equipment CEO Peter Metcalfe noted in his testimony before the committee, where he also discussed America’s wilderness and wild lands as the base upon which the US outdoor recreation industry is built.

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