Friday, September 9, 2016
I recently had the honor of being interviewed by Breathe California's executive director on my local cable channel. We discussed a wide range of topic including the new San Francisco Bay Restoration Act and the impacts of fire on our health! Please take a few minutest to check out my interview! http://www.creatvsj.org/207-2/?showid=27336&channel=1
Thursday, July 23, 2015
As long term strategic planners, we are often asked to take abstract concepts that require forecasting into the future and create logical solutions that we can implement now in the hopes of creating a sustainable solution for current problem. This can not only be a daunting task but require decision makers to take out their crystal balls and predict the future. In our world, the crystal ball is usually an extensive uncertainly model, years of monitoring data, or maps generated with layers of data, but the reality is that we use these tools to help us make predictions about the future so that we can develop long terms plans now. This is essential and if done correctly, can result in highly productive and sustainable solutions for a diverse set of issues. Long term planning is a key feature of any sustainable program and is the hallmark of sustainability. The following piece explores this concept in more detail.
Today, I am excited to introduce Dr. Susan Schneider as our guest blogger. She has packed a lot into a short piece where she looks at the consequences of sustainability with regard to overfishing. Susan Schneider, PhD is the author of the award-winning book The Science of Consequences and has just completed a book tour of 90 talks across the US and Scandinavia. Her book brings an inclusive interdisciplinary approach to learning principles, their biological context, and their many applications, including sustainability. The book received coverage in Nature. As a Visiting Scholar at the University of the Pacific, Schneider holds graduate degrees in engineering (Brown) and psychology (University of Kansas). She has been a board member for several Audubon chapters for 14 years, and is currently seeking to transition from academia to the nonprofit sector. You can email Susan Schneider at firstname.lastname@example.org to learn more about her work.
Consequences for Sustainability
Susan M. Schneider
“Incentives are the cornerstone of modern life. And understanding them—or, often, ferreting them out—is the key to solving just about any riddle.” - Levitt & Dubner, Freakonomics
One of the poster children for sustainability riddles is overfishing. The late 20th century collapse of the Atlantic shad and cod fisheries are just two of the more recent examples in a long history. As award-winning journalist Tom Horton noted of the Chesapeake Bay’s depleted shad fishery: "By 1890, bay watermen had responded to the relative scarcity in the same, time-honored fashion they still often follow - they redoubled harvesting efforts and developed more efficient catching methods" (Bay Country, p. 45). It’s a matter of short-term vs long-term consequences. Guess which ones often win.
Individually, too: Even when long-term consequences are as sure as anything can be - such as painful tooth decay and expensive dental work - people can still put off dentist visits. Throw in a little uncertainty and toss the wiser choice with it. A riddle indeed.
Native Americans kept their harvesting of Atlantic shad sustainable. It was only with the arrival of the European colonists that overfishing became a problem. Early regulations were largely ignored, and in 1738 a full-scale battle ensued. Lives were lost.
We can project benefits-to-costs ratios over time, and Cambridge Professor Andrew Balmford did just that for a number of environmental policy challenges like overfishing (Science). Going for the desirable long-term consequences of sustainability often brought very high ratios - but in the face of substantial short-term costs. Can we develop strategies to help surmount this barrier?
Yes, but we need all the help we can get. Nobel Prize-winning environmental economist Elinor Ostrom wrote of the “complex, multivariable, nonlinear, cross‑scale, and changing systems" that made careful tailoring essential for success in addressing each challenge. With a multitude of factors to consider, an interdisciplinary analysis is often essential. But it can be helpful to remember that everything still comes down to lots of individual choices - choices influenced by their consequences.
One of the relevant sciences has long focused on the role of consequences. In The Science of Consequences, I cover the principles of learning from consequences, their biological context, and their wide range of applications. Researchers in this area worked out the mathematics of the most typical drop in consequence value over time: the "delay discounting" function that is pivotal in behavioral economics as well. Not surprisingly, the longer the delay, the more the consequences get discounted. That’s just the beginning of analyses based on the functions of our choices, and all the factors influencing them.
A few of the many success stories:
* US Safe Harbor programs provide incentives for landowners to preserve habitat for endangered species. Andrew Balmford again (Wild Hope): Despite Endangered Species Act protection, a woodpecker species was losing ground. When the arrival of these birds meant increased liability and restrictions, landowners used techniques like preemptive logging to avoid these consequences. Instead, putting out the welcome mat under a Safe Harbor agreements offered protection, and sometimes cost-sharing. So far, most landowners have been happy.
* Utilities send community comparison reports to consumers, with happy faces for reduced energy use. It made a difference in places like California, Minnesota, and Washington. Once new habits become established – turning off lights, unplugging "vampire" electronics - how much easier to maintain a more sustainable lifestyle.
* In a very direct approach, arid Las Vegas successfully paid residents to switch from water-wasting lawns to water-wise yards. Again, once established, people adapt to the new lifestyle (as they've done with recycling). And there's much to appreciate in addition to the savings in water charges: more birds and butterflies and (often) decreased maintenance. New social norms have developed, helping to support the new look and change attitudes.
These are all positive strategies that make economic sense as well. Positive consequences aren’t just what we hope for when we work toward sustainability. They’re an essential tool to help us get there.
Atlantic States Marine Fisheries Commission. "Shad and River Herring," website, consulted July 13, 2015. http://www.asmfc.org/species/shad‑river‑herring
Balmford, A. Wild Hope: On the Front Lines of Conservation Success. Chicago: University of Chicago, 2012.
Balmford, A., A. Bruner, P. Cooper, R. Costanza, S. Farber, R. E. Green, M. Jenkins, et al. “Economic Reasons for Conserving Wild Nature.” Science 297 (2002): 950–53.
Horton, T. Bay Country. Baltimore, MD: Johns Hopkins, 1987.
Levitt, S. D., & S. J. Dubner. Freakonomics: A Rogue Economist Explores the Hidden Side of Everything. New York: Morrow, 2005.
Ostrom, E. “A Diagnostic Approach for Going beyond Panaceas.” Proceedings of the National Academy of Sciences 104 (2007): 15181–87.
Schneider, S. M. The Science of Consequences: How They Affect Genes, Change the Brain, and Impact Our World. Amherst, NY: Prometheus, 2012.
Schneider, S. M. "For Presidents' Day (US): Sustainability, Consequences, and the ‘Founding Fish.’" Web blog post, The Science of Consequences, February 22, 2013.
Tuesday, April 21, 2015
Conducting Research for Strategic Plans that follow an Integrated Approach to Natural Resource Management
Strategies for Conducting Research Using an Integrated Approach to Natural Resource Management
Many of the environmental challenges we face are so complex that it almost seems impossible to identify the heart of the problem, let alone identify and prioritize solutions, trade-offs, and potential conflicts for the given problem. My advice is to always start by taking a step back to attempt to see the 25,000 foot view before diving into the specific problems. This type of approach enables you to identify all of the parts of the problem before you start to understand each part individually and then together as an entire system. This is often referred to as a systems approach with the goal of ensuring that every perspective is considered and addressed throughout the planning process. Another important aspect at this stage in the planning process is to attempt to remain as open as possible to all of the information you come across and evaluate each piece of information on its own merits. This will allow you to remain as unbiased as possible during the information gathering stage of the planning process.
At this stage of the game, you need to understand what the issues are, who the stakeholders are, and what the overlapping and competing issues that contribute to the issue at hand are. Before you meet with a stakeholder group or attempt to identify and prioritize the issues, it is pertinent to conduct a detailed assessment of the history of the problem, identify the historical conflicts between stakeholders, understand past planning efforts, and identify trends for the future. The following case study is an assessment of the combined impacts of climate change and invasive species on island ecosystems. It provided the necessary background information needed to develop an integrated strategic plan that was later used to develop projects for biodiversity conservation, as well as identify potential impacts to island ecosystems from the combined effects of climate change and invasive species.
This case study is a summary of the expected impacts from climate change on islands, from invasive species on islands, and their likely combined effects. Additionally, the assessment reviews the social, political, and economic effects of both climate change and invasive species on island biodiversity. This information was used to help inform the stakeholder working group, set priorities that were rooted in science, and educate the stakeholders so that they were contributing to the strategic plan in an effective manner. Moreover, this type of inclusive assessment allowed us to ensure that each stakeholders concerns and needs were taken into consideration during the strategic planning process.
As usual, I welcome your comments or questions. Thank you, Gabrielle
Outlining the Combined Effects of Climate Change and Invasive Species on Islands
Expected Impacts from Climate Change to Marine Life and Small Islands
· Many important coastal habitats that provide benefits to human society and the environment alike are also highly likely to experience severe declines.
· Higher sea level and warmer ocean temperatures can alter ocean circulation and current flow, increase the frequency and intensity of storms, alter habitat, and impact weather worldwide (Baker et al. 2008, Carpenter et al. 2008, Bakun 1990, Nicholls et al. 1999, and Bindoff et al. 2007).
· Despite the differences in erosion potential along the world’s coastlines, there has been a dramatic increase in coastal erosion over the last two decades (Morton et al. 2004) and this is expected to continue as sea level rises (Brown and McLachlan 2002) and storm frequency and severity increase.
· Rising sea level is most threatening to low lying island nations and the delta populations of South and Southeastern Asia and the Nile Delta in Africa (Nicholls et al. 2007 and Nicholls et al. 1999).
· Many climate change impacts are likely to affect island communities in both the Caribbean and Pacific, including higher sea levels, more powerful tropical storms (such as hurricanes in the Atlantic and typhoons in the Pacific), and warmer, more acidic coastal waters. Unique island ecosystems, such as coral reefs and mangrove forests, are already facing stress from human development and pollution, making them particularly sensitive to additional stresses from climate chance (USGCRP 2009).
· Islands are home to unique ecosystems and species that provide economic opportunities, safety, nourishment, and cultural value to island communities (USGCRP 2009 and Mimura et al. 2007).
· The loss and inundation of other coastal habitats, such as mangroves, from sea level rise and storm surge could endanger species that use these habitats for nesting, nursing, and nutrients (USGCRP 2009).
· Climate change may enhance conditions that facilitate the spread of invasive species and marine and terrestrial pathogens and diseases, which would affect and island’s natural ecosystem and biodiversity (Mimura et al. 2007).
Impacts from Invasive Species on Island Ecosystems
· The Earth has approximately 100,000 islands many of which are important biodiversity hotspots made up of fragile ecosystems that are home to some of the most unique species in the world (CBD 2010). Island ecosystems are key areas for biodiversity conservation worldwide since they represent less than 5% of the planet’s land mass, yet are home to 39% of critically endangered species (Whittaker 1998, Diamond 1985, 1989, Olson 1989). Island species are more susceptible to environmental stressors that cause extinctions as a result of their small population sizes and limited habitat availability. In addition, island species have adapted in isolated environments making them particularly vulnerable to impacts from invasive species (Diamond 1985, 1989, Olson 1989).
· It is widely accepted that the natural world is facing a very high rate of species extinction (Raup 1988), that most recent extinctions can be directly attributed to human activity (Diamond 1989), and that for ethical, cultural, aesthetic, and economic reasons this current rate of extinction is cause for considerable concern (Ehrlich 1988, Ledec and Goodland 1988). One of the major worldwide causes of anthropogenic extinctions is the introduction of invasive species. Of the 245 recorded animal species extinctions since 1500, 75% were species endemic to islands (World Conservation Monitoring Centre 1992). Invasive species were at least partially responsible for a minimum of 54% of documented island extinctions, based on the 170 island species for which the cause of extinction is known (Ricketts et al. 2005).
· The effects of invasive species on islands accounts for 80% of all species extinctions recorded so far. Half of these recorded extinctions were caused by invasive alien vertebrates (IAV) such as rats, mice, pigs, goats, etc. Rodents (rats and mice), the most prolific of all invasive vertebrates, are estimated to have been introduced to more than 80% of the world’s islands as the result of human activities. Invasive species continue to invade new islands today with the ever-increasing movement of people and goods around the world. When introduced to islands, invasive species upset an island’s natural equilibrium and severely impact native plants and animals that lack adaptations to protect themselves from the intruders. There is a relatively simple, efficient, and cost effective solution to this island-species extinction crisis: when invasive species are removed from islands, native plants, animals, and ecosystems recover with little or no additional intervention. Combined with effective biosecurity, the eradication of invasive species is one of the most effective ways to protect threatened island biodiversity.
How do Invasive Species aggravate the effects of Climate Change on biodiversity?
· Climate change and invasive species are considered by many scientists to be the greatest threats to biodiversity by the 21st Century. Climate change is projected to negatively impact global GDP by as much as 20%, while invasive species are expected to impact the GDP by as much as 5% of the global economy in the coming years. The combined effect of climate change and invasive species is estimated to be around 25% of the global economy by 2050 with the greatest impacts expected to occur on small islands (Burgiel and Muir 2010).
· The effects of invasive species are expected to be exacerbated with a changing climate by creating conditions that favor species that are highly adaptable and resilient to change, like invasive species (UNEP 2006). For example, Hellman et al. 2008 found that extreme weather events, shifting currents, and altered circulation patterns could enhance invasive species ability to disperse to new areas where they will likely have an advantage in overcoming biotic constraints and outcompeting native species. Researchers in New Zealand are concerned that invasive mammals like black rats, which are key drivers of the extinction rates of native species, are highly likely to adversely impact biodiversity conservation and ecosystem function with the combined effects of climate change (Tompkins et al. 2013). The Australian Invasive Species Council has identified five likely combined effects of climate change and invasive species to the native biota in Australia including the following (Invasive Species Council 2009):
1. Range changes due to new temperature and precipitation patterns
§ Hill et al. 2013 has determined that climate change is decreasing the productivity of Antarctic krill by decreasing the overall concentration of chlorophyll-a. Antarctic krill accounts for approximately 85% of Antarctic fur seal, 76% of grey-headed albatross, and 12% of wandering albatross diets. Any degradation of Antarctic krill growth habitat is likely to have consequences on predators on South Georgia Island, which could cause serious declines in their population.
2. Increased opportunity for invasive species incursion into new areas during extreme or abrupt weather events
§ Cook et al. 2010 has linked the glacial retreat on South Georgia Island with the increased incursion rate of rats into previously unoccupied areas of the island as a direct result of glacial retreat. This risk has serious implications for the important breeding populations of ground nesting seabirds on the island.
3. Increased susceptibility of native species to invasive species
§ A USGS 2006 report has determined that native Hawaiian birds are being decimated by avian malaria and pox transmitted by introduced mosquitoes. Invasive feral pigs exacerbate the problem by providing habitat for mosquito larvae by feeding on tree fern trunks. It has been determined that by reducing artificial larval habitat and removing feral pigs the mosquito population will be effectively reduced, which is the best hope for limiting disease transmission.
4. Increased chance of biosecurity breach with human responses to climate change
§ There are few if any documented cases of incursion as a result of conservation or restoration efforts; however, humans are the primary cause of the spread of invasive species. Witmer et al. 2011, summarized some of the reasons why human caused incursion are likely to occur:
· People often cannot distinguish between native and invasive species
· People are unaware of how their quality of life, economy, biodiversity, and conservation can be significantly affected by invasive species
· Many people believe in the sanctity of all life whether invasive or not and do not want invasives removed
· Many people have an inherent dislike or distrust of the use of chemicals and toxicants even though they may be necessary tools for invasive species management
5. Increases in carbon emissions by removing native vegetation that sequesters carbon
§ Godson 2008 assessed the risk that invasive rabbits have on vegetation in Australia and evaluated their potential to decrease carbon sequestration. Research found that 2 rabbits per hectare can decrease plant regeneration by 75%. Furthermore, there are concerns that an increasing rabbit population will create a high risk of rabbits consuming seedlings that were planted for carbon sequestration.
· Climate change is also likely to shift predator prey behavior through habitat modification, rising sea temperatures, ocean acidification, shifting marine and terrestrial community structures, and altered migratory patterns. These projected changes can lead to prey switching potentially increasing the threat to native species from both climate change and invasive species.
1. Iverson et al. 2014 recorded drops in prey fitness under changing predatory pressures. In particular, they found that polar bears were increasing predation pressure on Arctic seabirds with the loss of suitable marine mammal prey.
2. These types of shifting patterns that are likely to affect all migratory and marine species will be exacerbated by the negative effects of invasive species. Furthermore, it is predicted that the multiple and varied effects of climate change will affect every pillar of biodiversity and that sensitive species, that are often found on islands, are likely to exceed their ecosystem thresholds or “tipping point” potentially resulting in extinction (Rinawati et al. 2013). Species that have reached a tipping point can respond in three ways: change, move, or die.
· In order to minimize the likely outcome of many island dependent species from reaching their ecological tipping point, an integrated holistic approach to conservation and management of climate change and invasive species is essential to increase the resilience and adaptability of native species (Burgiel and Muir 2010). The Global Invasive Species Programme identified three key messages that are fundamental in integrating invasive species and climate change impacts across multiple sectors and regions. The key messages include (Burgiel and Muir 2010):
1. Climate change will have direct and indirect impacts that will facilitate the introduction and spread of invasive species,
2. Invasive species will likely increase the vulnerability of ecosystems to adapt to other climate related stressors, as well as reduce their carbon sequestration potential, and
3. Using an adaptive ecosystem based approach, the above pressures can be offset by preventing the introduction of new invasive species and by eradicating and controlling the invasive species that are already present.
· Eradicating invasive species from islands will have tremendous benefits for native species that are combating the combined effects of invasive pressures with a changing climate. Stress is one of the leading causes of species extinction and by eradicating invasive species from islands, multiple stressors will be relieved simultaneously. Invasive species eradications have a twofold benefit to impacted species by decreasing the direct and indirect effects of invasive predators and increasing overall resilience of biodiversity in the face of a changing climate.
Monday, March 16, 2015
Developing a Comprehensive Community Engagement Plan is a fundamental component of any successfully environmental program and can provide great insight into any social or political barriers to implementation, as well as help identify key stakeholders, and tease out potential points of controversy and potential trade-offs. Typically the goal of any community engagement plan is to gain public and agency buy-in for a project, as well as identify potential problems that could derail the project or result in litigation.
A successful outreach campaign should include the following key components a) clearly defined driving forces, goals, and objectives; b) holistic understanding of the target audience including the demographics, attitudes and behaviors, barriers to action, and a strategy to package and distribute your message (e.g. websites, FAQ’s, talking points, etc.); and c) metrics to track the success of the outreach campaign, as well as a plan to adaptively management the outreach strategy for the duration of the outreach phase of the project.
The goal of a successful outreach campaign should be transparency and public buy-in. For these reasons, you must identify all of the relevant stakeholders and actively conduct outreach to them. In the following Case Study we targeted groups that were clearly opposed to the proposed project, in addition to those that were supportive of the project and willing to write letters of support or more. There are several reasons that I advocate for the direct engagement with opposition groups: First, it is a gesture to the group acknowledging their interest and potential influence over the outcome of the project. Second, it allows you the opportunity to understand the group’s issues, reservations, and potential areas of compromise during the planning process. And finally, direct engagement and compromise are the best methods to reduce the likelihood of litigation or injunction against the project.
As a case study, I have provided an example of the Community Engagement Plan that was cooperatively developed with the US Fish and Wildlife Service and partner NGO’s for the proposed mouse eradication project on the Farallon Islands. I was a key member of the core partnership and the lead author of the Draft Environmental Impact Statement, as well as the project director for outreach and communications for select NGO partners. In the outline below, I have identified the key aspects of an effective strategic outreach plan with specific examples based from the Farallon Islands project. Please feel free to ask questions or provide feedback. Thank you,
Case Study: Farallon Islands Proposed Mouse Eradication Draft EIS Outreach Campaign
The Key Components of an Outreach Campaign Include:
A. Defining driving forces, goals, and objective
a. The primary driving force behind the proposed mouse eradication was to remove invasive house mice from the Farallon Islands to restore the ecosystems on the islands and protect native species including ashy storm-petrels, endemic arboreal salamanders, endemic cave crickets, and other species.
i. The specific needs for this outreach campaign were to educate the public on the need for mouse removal, to clearly explain the differences between the use of rodenticides on the mainland for rodent control purposes and the use of rodenticides designed for conservation purposes on islands, and to gain support for the project.
b. The goals of the project include:
i. Conduct outreach with interested parties and gain support from permitting agencies, NGOs and individuals prior to the release of the DEIS, as well as during the public comment period
ii. Educate the public and interested parties about the project and the Farallon Islands
iii. Hold a public meeting that was well attended and prevented grandstanding
iv. Work with the media to ensure that the project is projected in a good light
c. The objects of the project include:
i. Gather signatures for a letter of support for the project prior to the release of the DEIS
ii. Conduct an embargoed press release to ensure positive press coverage of the project on the release of the DEIS and the announcement in the Federal Register
iii. Develop a website, FAQs, fact-sheets, talking points, press releases, and more for the project
iv. Give radio interviews that are well informed, provided insight to the project, and ensured that it is viewed in a good light
B. Identify the target audience including the demographics, attitudes and behaviors, and barriers to action
a. The target audience for the outreach associated with the Farallones project included:
i. Animal Rights groups that oppose all of the potential alternatives proposed
ii. Anti-pesticide groups that oppose all of the potential alternatives proposed
iii. Environmental Interest Groups that understand the need for action, approve of the proposed alternatives, and support the project
iv. General public that is uninformed about the project and need for action, as well as a need to provide information that will give them a better understanding of the project, understand the need to act, and the rationale behind the proposed alternatives
v. Agencies that will be providing and approving permits, if the project is implemented
b. The primary barriers to action include:
i. Animal Rights groups and anti-pesticide groups could seek an injunction claiming that the FWS did not sufficiently evaluate all of the potential alternatives available to remove mice from the islands.
1. To overcome this barrier we actively communicated with detractor groups, invited them to participate in public meetings, and comment on the DEIS. We kept them in the loop with regard to outreach to interested parties. We also controlled their ability to grandstand during the public meeting and in the media through the design of the public meeting and outreach protocol.
ii. Agency buy in to the project that will need to issue and approve permits
1. To overcome this barrier we met with every agency that has a stake in the permitting of this project, gave presentations to their staff, and allowed them to comment on the project and identify the path forward to receiving a permit through their agency
iii. Public trust is an issue because many citizens do not trust the FWS to act in the best interest of the public with regard to the management of public lands
1. To overcome this barrier we worked with the public to answer any questions they had and allowed the public to feel like their input was going to be considered prior to choosing a preferred alternative. For this reason, the FWS and its partners did not choose a preferred alternative for the DEIS to allow the public to weigh in on the decision.
iv. Activist groups mistrust the motivation of some of the partner NGOs and claiming that they advocate for pesticides for pesticide companies
1. To overcome this barrier the NGO in question took a backseat during the public meeting to show that the FWS owns the project and that the NGO’s interests lie in the restoration and conservation of the island rather than the method used to remove the mice. It was also made clear that this NGO’s role in this project was only in the compliance and outreach processes and not the implementation. Additionally, I crafted a policy statement on the NGO’s position on the use of conservation rodenticides, as well as submitted comments to Cal DPR in support of its proposal to restrict the use of second generation anticoagulants in California.
c. Messaging - Creating, packaging, and distributing a message
i. The FWS and its partner NGOs worked together for several years to determine the ideal messaging for this project. We created several factsheets, FAQs, blog posts, and talking points that presented the project in the best light possible. Additionally, all of the partners were relaying the same message to the public, agencies, and interested parties.
ii. The partners framed the message in a way that would ensure that our message in support of the project was clear, transparent, and owned up to the risks rather than attempting to bury them.
iii. We used several different media and outreach approaches to ensure that the project was branded properly and steered clear of potential conflicts through social media.
C. Evaluating the campaign
a. Metrics used to Track campaign success
i. The campaign directly before and during the public comment period was highly successful at achieving it’s intended goals:
1. The partnership received support from over 20 NGO groups and individuals on the sign on letter
2. We held over 5 different radio interview that were highly successful Over 20 articles, blogs, and interviews were written and the majority of them portrayed the project in a positive light.
3. We received buy in and support from all permitting agencies and approval of much of the DEIS and the planning processes.
b. Adaptive Management Plan used as a framework adaptive decision making during the campaign
i. We developed a framework for decision making that included a command structure, risk scenarios, tipping points, contingency plans, and adaptive protocols
1. We developed potential risk scenarios based on perceived or known concerns with stakeholder groups, agencies, or other influential group
2. Based on what we knew about the different stakeholder, we held regular meeting to discuss outreach to those parties and determine if our protocol had changed or if a tipping point in the campaign had been reached that would negative affect our preferred outcome.
3. Risk scenarios were developed and modified throughout the implementation of the outreach campaign based on media, social media, agency, or public responses to the DEIS and public meeting. A tipping point, or threshold, was developed for each risk scenario, and a contingency plan was developed for each risk scenario.
4. A chain of command was developed for decision making and adaptive management in order to ensure that decision were made in an orderly and logical manor.
Friday, February 20, 2015
Strategies for Streamlining Compliance for Restoration Projects: Case Study - Streamlining Compliance for Rodent Eradication Projects in the United States
Outlining Strategies to Streamlining Compliance for Restoration Projects
One of the biggest complaints that I hear on a regular basis has to do with the gridlock and seemingly endless bureaucracy involved in planning a restoration project. I often hear that the cost of planning makes the project infeasible. So the question is, how can we effectively comply with environmental regulations while simultaneously implementing restoration projects without long delays? The answer is to streamline the compliance process.
What do I mean by streamlining compliance? Streamlining the compliance process is ideal for restoration projects that are likely to be implemented in multiple locations over multiple years. A good example might be shoreline restoration to prepare for sea level rise. This is something that needs to be done anywhere there is a shoreline, making it an ideal candidate. An analyst, could then identify all of the necessary permits and regulatory processes, including environmental impact assessment, and work with regulatory agencies to develop programmatic permitting processes or other similar approaches that will cut down on the planning time. Other ways to streamline compliance include developing templates and standard language that can be easily used for multiple projects. Additionally, modelers could develop tools that would allow analysts to easily evaluate impacts or design mitigation strategies.
To illustrate how one might go about developing a program to streamline compliance, I am sharing a paper that I wrote on this subject for rodent eradication projects in the United States. I presented my work at the 2014 Vertebrate Pest Conference in Hawaii, and the following article was published in the Conference Proceedings. The approach outlined in this paper is similar to one that I would take for any issue. It is first imperative to have a holistic understanding of the problem, an updated understanding of the regulatory aspects of project planning, and the role that social and political issues will play in the implementation of the project. Please feel free to ask any question or provide feedback in the comments. Thank you,
From Planning to Implementation: Streamlining Compliance for U.S. Rodent Eradications
By: Gabrielle Feldman and Gregg Howald
Implementing rodent eradication projects on federally owned islands in the U.S. can take ten or more years to plan and often accounts for more than 50% of total project expenses. Consequently, identifying ways to improve planning efficiency by streamlining the compliance process will allow land managers to restore more islands thereby increasing ecosystem productivity, and improve species resilience. The compliance process, defined here as fulfilling National Environmental Policy Act (NEPA) requirements and securing all necessary state and federal permits, creates a valuable and robust framework to examine goals, develop alternatives, assess anticipated impacts, establish partnerships, and engage the public, as well as provides permitting agencies and the public an opportunity to participate in the planning process. One significant challenge to the planning process is that many variables that need to be accounted for early in the process are social, economic, or political in nature and are frequently overlooked, downplayed, or disregarded. We reviewed the planning documents for several rodent eradication projects and identified areas where the process could be streamlined, described lessons learned, and made recommendations for future projects. Streamlining can be achieved by identifying programmatic solutions, understanding social and political constraints, and developing a robust, transparent assessment of a range of alternatives.
Key Words: environmental compliance, environmental planning, invasive species, NEPA, rodent eradication, streamlining compliance, stakeholder relations.
Invasive Species on Islands
The Earth has approximately 100,000 islands many of which are important biodiversity hotspots made up of fragile ecosystems that are home to some of the most unique species in the world (CBD 2010). Island ecosystems are key areas for biodiversity conservation worldwide since they represent less than 5% of the planet’s land mass, yet are home to 39% of critically endangered species (Whittaker 1998, Diamond 1985, 1989, Olson 1989). Island species are more susceptible to environmental stressors that cause extinctions as a result of their small population sizes and limited habitat availability. In addition, island species have adapted in isolated environments making them particularly vulnerable to impacts from invasive species (Diamond 1985, 1989, Olson 1989).
It is widely accepted that the natural world is facing a very high rate of species extinction (Raup 1988), that most recent extinctions can be directly attributed to human activity (Diamond 1989), and that for ethical, cultural, aesthetic, and economic reasons this current rate of extinction is cause for considerable concern (Ehrlich 1988, Ledec and Goodland 1988). One of the major worldwide causes of anthropogenic extinctions is the introduction of invasive species. Of the 245 recorded animal species extinctions since 1500, 75% were species endemic to islands (World Conservation Monitoring Centre 1992). Invasive species were at least partially responsible for a minimum of 54% of documented island extinctions, based on the 170 island species for which the cause of extinction is known (Ricketts et al. 2005).
Benefits of Eradicating Invasive Rodents
The effects of invasive species on islands accounts for 80% of all species extinctions recorded so far. Half of these recorded extinctions were caused by invasive alien vertebrates (IAV) such as rats, mice, pigs, goats, etc. Rodents (rats and mice), the most prolific of all invasive vertebrates, are estimated to have been introduced to more than 80% of the world’s islands as the result of human activities. Invasive species continue to invade new islands today with the ever-increasing movement of people and goods around the world. When introduced to islands, invasive species upset an island’s natural equilibrium and severely impact native plants and animals that lack adaptations to protect themselves from the intruders. There is a relatively simple, efficient, and cost effective solution to this island-species extinction crisis: when invasive species are removed from islands, native plants, animals, and ecosystems recover with little or no additional intervention. Combined with effective biosecurity, the eradication of invasive species is one of the most effective ways to protect threatened island biodiversity.
As a consequence of pioneering rodent eradication efforts in New Zealand during the 1970’s, eradication projects have successfully removed rodent from 571 islands in more than 50 countries around the world (Howald et al. 2007, Keitt et al. 2011). Moreover, there have been 19 successful rodent eradications in the United States (Keitt et al. 2011). These successes have invariably resulted in species and ecosystem recovery and almost certainly saved some species from extinction (Bellingham et al. 2010). For example the successful eradication of black rats (Rattus rattus) from Anacapa Island (California, Channel Islands) more than 10 years ago resulted in an increased abundance of the Scripps murrelet (Synthliboramphus scrippsi) and the reemergence of the rare ashy storm-petrel (Oceanodroma homochroa) (http://www.nps.gov/chis/naturescience/restoring-anacapa-island-sea-bird-habitat.htm). In the last twenty years, eradication of rodents from islands has become one of the most effective and powerful tools to prevent extinctions and restore ecosystems (Carrion et al. 2011). Since eradication projects are logistically complex, expensive, and controversial, they require a solid foundation of operational, legal, administrative, and communications support to ensure the successful removal of the target population (Morrison et al. 2011).
The Need to Streamline
The successful eradication of black rats from Anacapa in 2002 was the ﬁrst-ever invasive rodent eradication from an entire island where an endemic rodent was present and the ﬁrst aerial application of a rodenticide in North America (Howald et al. 2009). This conservation success sparked a wave of rodent eradication efforts on federally owned islands in the United States. The science illustrating the need for rodent eradications and the benefits of rodent removal to island ecosystems has been well documented. Furthermore, several eradication tools have been used successful on hundreds of projects around the world with minimal long-term negative consequences. However, since Anacapa Island was the site of the first rodent eradication in the US to aerially broadcast rodenticide bait for eradication purposes, a National Environmental Policy Act (NEPA) analysis was required. An Environmental Impact Statement (EIS) was prepared along with numerous state and federal permits. The compliance process was relatively rigorous and took more than a year and a half to complete, paving the way for subsequent projects using similar techniques in the US.
Since the successful removal of rats from Anacapa Island, federal land managers have worked with eradication experts to plan and implement more than 10 additional island rodent eradication projects (Keitt et al. 2011). A majority of these projects successfully eradicated the target species with little to no long-term negative side effects to island ecosystems including Palmyra Atoll, Mokapu Island, Egmont Cay, Mokolii Island, and Alau Island. Rats were successfully removed from Rat Island; however, experts did not anticipate the mortality of over 300 glaucous-winged gulls (Larus glaucescens) and over 40 bald eagles (Haliaeetus leucocephalus) from the implementation of the project (Ornithological Council 2010). Recently, Desecheo Island and Wake Atoll projects were implemented according to plan; however, on Desecheo the eradication team failed to fully eradicate the target species, while on Wake the team successfully eradicated Asian rats (Rattus tanazumi) but not Polynesian rats (Rattus exulans; Griffiths 2014).
The recent mistakes in the US coupled with a growing concern over the use of rodenticides on the mainland and their negative impacts to wildlife, children, and pets (Daniels 2013) has complicated the compliance process for projects that are currently in the planning stages, and as a result these projects are being held to a higher standard requiring more rigorous analyses, additional public scrutiny, and supplemental compliance processes. For example, the proposed mouse eradication on the South Farallon Islands has been in the planning stages for over 10 years. The additional years of planning are due to more emerging information about the effects residues after eradication projects, more information and documentation about non-target take from eradication projects combined with an increased concern over the potential for a project to fail as a result of the recent unsuccessful projects. In addition there has been a surge in stakeholder engagement, agency concern over impacts to resources, as well as, concerns over losing the use of rodenticides for invasive rodent management in general. For these reasons, a systematic, transparent problem oriented approach should be used to identify social and political constraints, identify areas for programmatic planning solutions, and provide opportunities for stakeholder engagement in an effort to more efficiently complete the planning process for conservation purposes. Therefore, the goal of a the streamlining process should be to increase capacity to better anticipate risks and mitigate potential impacts, create opportunities to gain understanding of the project benefits and risks, provide an accurate and complete analysis of the costs and benefits of a proposed project, and enable stakeholders to make informed decisions on how and whether a project should proceed, as well as, outline a clearly defined permitting process.
From Planning to Implementation
The Role of Environmental Compliance in Project Implementation
An assessment of environmental impacts under NEPA is required for all activities that have the potential to cause “significant harm to the human environment” (42 USC 4321-4347). Environmental Impact Assessment (EIA) is a formal analysis used to forecast the environmental consequences of any project implemented on federal land. The purpose of developing a robust EIA is to ensure that any potential problems are identified and addressed early in the planning and design of a project. In addition, EIA’s enable decision makers to weigh the environmental costs and benefits of a project at an early stage (Ingole 2007). NEPA requires federal agencies to consider environmental issues prior to making any major decisions on projects that have federal involvement (e.g., funding or permitting). To determine a project's potential benefit or harm to the environment, NEPA requires an assessment of environmental impacts and an evaluation of alternatives through the development of an Environmental Assessment (EA) or EIS (42 USC 4321-4347). In addition, EIA’s provide the background and evidentiary support needed for other permits that are typically required for large projects.
The compliance process can take anywhere from 2 to 10 years or more to complete for rodent eradication projects in the United States. Navigating the compliance process can be quite cumbersome and complicated since the level of detail required is typically dictated by the perceived risks rather than the actual biological, social, or economic risks. Stakeholders can play a powerful role in the outcome of the planning process as NEPA is a procedural law that only outlines the steps necessary to complete the process, while the courts interpret the policy and determine the scope of work. Active stakeholders that are not properly engaged in the planning process can create unanticipated regulatory requirements resulting in projects that are often behind schedule and over budget. For these reasons, agency consultation and stakeholder engagement should be incorporated into the early phases of planning and continued throughout the compliance process. Furthermore, stakeholders that are engaged in the planning process are less likely to seek injunctions, require additional analyses, or disseminate misinformation (Clark 2002).
The National Environmental Policy Act (NEPA) of 1970 was the first law written to establish a broad national framework for environmental protecting. The basic premise of NEPA is to ensure that the federal government properly considers the environment prior to initiating any major federal action that has the potential to significantly affect the environment (42 U.S.C. § 4321 et seq.). NEPA analysis includes the completion of either an EA or an EIS depending on the predicted affects to the environment, the economy, and cultural and historic resources.
An EA as described in Section 1508.9 of CEQ's NEPA Regulations is a concise public document that has three defined functions including providing sufficient evidence and analysis to determine if an EIS is necessary, acting as the agency’s compliance analysis if an EIS is unnecessary, and facilitating the preparation of an EIS (EPA 2014). Since the EA is a concise document, it should not contain long descriptions or detailed data which the agency may have gathered. Rather, it should contain a brief discussion of the need for the proposal, alternatives to the proposal, the environmental impacts of the proposed action and alternatives, and a list of agencies and individuals consulted -- Section 1508.9(b). Agencies should make the Finding of No Significant Impact (FONSI) and EA available for 30 days of public comment and review before taking action -- Section 1501.4(e)(2). (March 16, 1981 – NEPA's 40 Most Asked Questions).
An EIS, on the other hand, is a detailed environmental analysis that serves to assure the public and permitting agencies that the policies and goals defined in NEPA are incorporated by federal agencies into planning decisions. EISs are generally prepared for projects that are likely to have significant environmental impacts. The EIS should provide a discussion of potential environmental impacts and a reasonable range of alternatives (including a No Action alternative) designed to meet the goals and objectives of the project, as well as avoid or minimize adverse impacts and enhance the quality of the human environment. Agencies should allow at least a 45-day comment period for Draft EISs and a 30-day review period for Final EISs (EPA 2014). The EIS process is the more streamlined approach for rodent eradication since the majority of recent projects have come under heavy public scrutiny over the use of rodenticides, the ability to successfully eradicate the target species, and the perceived risks to non-target species and the marine environment.
Rodent eradication projects are often perceived to have significant impacts to biological, social, or economic resources regardless of the actual long term risks from the operation. For this reason, it is recommended to proceed with a Draft EIS and subsequently to convert the document to a Finding of No Significant Impact (FONSI) if impacts are determined not to be significant with appropriate mitigation. The clear advantage to this method is that a lot of time, money, and other resources can be saved by avoiding a two-step EA-EIS process, if an EIS is determined to be required. Similarly, if the EIS analysis illustrates that there are no potential significant affects, a FONSI can be used as the final decision document. Moreover, starting with an EA and then determining that there are likely to be significant issues that require the preparation of an EIS, would entail starting from the beginning of the EIS process with public scoping. This can add anywhere from one to five additional years of planning to the process (Eccleston 2008). The proposed mouse eradication on the Farallon Islands began as an EA; however, after several years and multiple public meetings it was determined that an EIS would need to be prepared requiring FWS to begin with public scoping and adding at least 3 additional years to the planning process.
Agency and Stakeholder Engagement
Environmental problems, like introduced rodents on islands, and subsequent eradications are often complex, multi-scale issues that affect a large array of stakeholder and agencies. Additionally, most projects have a great deal of uncertainty associated with the outcome of the operation since it is difficult to accurately predict conservation benefits from large scale ecosystem wide projects. As a result, projects of this capacity require transparent decision-making, early and ongoing outreach with relevant stakeholders, and the ability to be flexible to changing circumstances (Reed 2008). Furthermore, Reed 2008 recommends that “participation should be considered as early as possible and throughout the process, representing relevant stakeholders systematically” to avoid unanticipated outcomes.
Stakeholder engagement includes outreach and communication with permitting agencies, interested parties, and relevant interest groups. Early engagement with permitting agencies provides an opportunity to determine the information, data, and field trials needed to issue a permit, as well as create an inclusive atmosphere that promotes collaboration and support for the project. Early engagement with interest groups will help identify the public’s perceived risks of the project as they are usually different than the actual biological, economic, or social risks of the operation. By engaging with stakeholders early in the process it is possible to address the public’s specific concerns, allow them to feel directly involved in the process, gain the public’s trust, potentially avert the spread of misinformation, and clarify technical aspects of a project that are difficult to understand. In general, the more engaged agencies and the public are in the planning process the more likely that controversial issues can be resolved without the threat of unanticipated outcomes like additional field trials, more in depth impacts analysis, injunctions, or denial of a permit.
The Need to Streamline Compliance
Streamlining is defined by Merriam-Webster’s online dictionary as being stripped of nonessentials, effectively integrated, and brought up to date. Streamlining compliance for rodent eradications is intended to make the process more efficient and effective by decreasing constraints; however, it is not a method to bypass the process. In fact, the importance of strict adherence to compliance and regulatory process cannot be understated (Morrison et al. 2011). The idea is that by thinking about rodent eradications globally and identifying programmatic solutions, decision makers will be able to tease out areas that can be streamlined in a manner that accelerates the process for specific projects.
This review covers six approaches to streamline compliance for rodent eradications that together will result in fewer roadblocks to conservation. Some of the approaches are intended to be preventative measures that can help decrease the likelihood of a long drawn out court battle, while others are approaches are intended to simplify the process. An integrated approach to streamlining will ultimately lead to a more holistic planning process for rodent eradication projects in the US, while enabling individual projects to get through the compliance phase and into the operational phase in a more timely and efficient manner. The following is a summary of the six recommended approaches to streamlining with a description of the benefits of employing each approach:
1. Identify programmatic planning and permitting opportunities that will increase efficiency by:
a. Reducing redundancy;
b. Decreasing the planning timeline and budget; and
c. Increasing continuity between projects.
2. Identify and understand social and political constraints that can be incorporated into the planning process to:
a. Minimize the risk of controversial law suits or injunctions;
b. Identify concepts that require clarification to gain support for the project;
c. Provide stakeholders with an opportunity to contribute to the planning and decision making of a project; and
d. Ensure that social and political constraints are included and evaluated in the planning process.
3. Develop a rigorous NEPA document that incorporates all of the social, environmental, and economic impacts while providing plenty of opportunities for public involvement by:
a. Producing a document that can stand up to public and political scrutiny;
b. Using NEPA as a method to minimize the risk of injunction, negative public and agency comments that can require additional document drafts, analyses, or field trials; and
c. Applying the Precautionary Principle by planning for a worst case scenario.
4. Strive for expert consensus within and among the eradication and planning community by:
a. Engaging experts in the early stages of planning to build consensus for the preferred eradication tools, non-target mitigation strategies, and to identify additional permits that may be needed;
b. Developing consensus will build confidence in the proposed operation with stakeholders; and
c. Adding continuity between projects by acknowledging the lessons learned from each additional project.
5. Be transparent during planning, outreach, and document developing to:
a. Decrease the appearance of impropriety;
b. Accurately portray the expected impacts from the alternatives;
c. Provide as much detail as possible without restricting the ability to adaptively manage the operation;
d. Provide an opportunity to gain buy-in and trust from stakeholders; and
e. Reduce the chance of injunction or law suit.
6. Engage all stakeholder by:
a. Identifying all relevant stakeholders;
b. Ensuring that the neglected perspective is included in planning;
c. Engaging stakeholders early and often during the planning process; and
d. Decreasing the risk of appearing biased or pre-decisional.
How can we streamline?
The underlying premise behind all rodent eradications is to remove 100% of the target species, while having a minimal effect on other non-target resources. The methods used to eradicate rodents, while they can be controversial in nature, have proven to effectively eradicate the target species with minimal non-target impacts (Howald et al. 2007). Additionally, since the island resources from project to project vary, the nature of the concerns over the implementation of the operation and the required permits are fairly standard. For these reasons, finding programmatic solutions that can be applied broadly are ideal for these types of projects particularly in light of the fact that the same federal permitting agencies are involved in all US based projects.
As an example, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires that all pesticides obtain a prescriptive use label that specifies the exact uses of the product, how it can be delivered, and restricted uses. Once a ‘parent label’ has been registered with the EPA, any project that complies with the restrictions listed on the label can obtain and use the product without any additional permitting under FIFRA. Furthermore, if a project specific label is needed for a particular project, a ‘supplemental label’ can be obtained without the need to re-register the product.
It is fairly easy to obtain a supplemental label for a project using a product that has been registered under FIFRA because all of the scientific evidence needed to regulate the product has already been reviewed; therefore, practitioners only need to justify the unique aspects of a project to obtain the supplemental label. The Palmyra Atoll rat eradication would have surely failed had the project team not obtained a supplemental label allowing the team to increase the application rate in order to account for nonlethal primary consumption by crabs. In addition without consulting with other eradication and island experts early in the process, it would have been much more difficult to obtain consensus for the operational plan to eradicate rats from Palmyra Atoll, which was essential for EPA to issue the supplemental label.
Another programmatic solution that has already been developed is a Special Purpose Permit under the Migratory Bird Treaty Act (MBTA) that allows for the take of MBTA listed species if the purpose of the operations is intended to result in species conservation. Prior to 2009 the US Fish and Wildlife Service (FWS) did not issue any incidental take permits for listed species. However, after the take of listed birds from the Rat Island eradication in 2008 (Ornithological Council 2010), the FWS began issuing take permits for eradication projects since the goal of these projects was to benefit listed species in the long-term (Kurth 2010).
In addition to programmatic solutions, compliance processes can be implemented more efficiently by developing robust NEPA analyses that clearly states the purpose and need for the project, evaluates a reasonable range of alternatives, fully assesses potential impacts and mitigation activities, and actively engages the public and experts throughout the process. The Anacapa Island rat eradication was the first aerial rodent eradication in the US. For this reason, the National Park Service (NPS) developed an EIS and conducted several field trials and risk assessments to identify the potential risk to the islands resources and develop an operational protocol to target 100% of the rats on the island. Despite all of the compliance effort and public involvement, the NPS was sued by an interest group seeking an injunction to halt the project. Since the EIS was well developed, fulfilled the procedural obligations of NEPA, and was supported by eradication experts the NPS was able to win the court case and implement the project on schedule due to the rigor in the compliance process (Howald et al. 2005). Another notable example stems from the pig eradication conducted on Santa Cruz Island, CA in 2005 where five legal challenges were brought to the courts with allegations that the EIS inadequately evaluated the risk to the islands species. The project team had developed an incredibly robust NEPA analysis that was supported by a team of experts and was able to withstand all five legal challenges without the need for any additional analysis (Morrison et al. 2011).
Along with developing a robust NEPA analysis, it is essential to include an assessment of the social and political environment to better understand the social conditions in the region, the underlying political concerns, as well as identify the perceived risks of the problem. Environmental problems, including invasive species management, are complex and dynamic issues requiring flexible, transparent decision-making that accounts for the diversity of values in the region, and identifies any gaps in knowledge of the different stakeholders (Reed 2008). Failure to assess stakeholder concerns could result in public relations issues, additional analyses, law suit, or injunction. For example, the planning for the proposed mouse eradication on the Farallon Islands was initiated prior to the implementation of the Rat Island, Palmyra Atoll, and Desecheo Island rat eradications when there was far less public scrutiny over the implementation of rodent eradications. However, the Rat Island rat eradication resulted in the unanticipated mortality of over 300 glaucuous-winged gulls (Larus glaucescens) and over 40 bald eagles (Haliaeetus leucocephalus), the Palmyra Atoll rat eradication resulted in unexpected mortality of a small number of mullets in the shallow lagoon, and the Desecheo Island rat eradication failed to successfully remove all individuals from the island. Subsequently, after these projects were completed, the public and permitting agencies began to look more closely at how rodent eradications were being implemented in the US, as well as the potential impacts to non-target species from the operation. The original EA that was developed for the proposed mouse eradication on the Farallon Islands was deemed to be inappropriate and as a result an EIS was developed along with several additional modeling efforts, field trials, and alternatives analyses that were needed to complete the compliance process.
Natural resource professionals manage large complex problems that are extremely dynamic, include both scientific and non-scientific issues, and are often limited by the perceived risks of the interested stakeholders. Problems related to invasive species management demand responses that are not conventional, yet are highly effective at eradicating the target species. The unconventional nature of eradication operations coupled with the social and political constraints associated with managing invasive species make planning and implementing eradications extremely difficult. In many cases it is difficult to analyze and solve the problem due to the complex, competing interests of a diverse group of stakeholders (Clark 2002). Moreover, the overarching regulatory environment exacerbates the conflict by requiring stakeholder engagement and regulatory oversight from permitting agencies. For these reasons the compliance process for rodent eradications is intended to provide the framework to assess alternatives, identify potential impacts, and actively engage with stakeholders.
After reviewing the planning documents for several of the most recent rodent eradication projects planned in the US, we identified areas where the process could be streamlined. Streamlining is a process that can be achieved by identifying programmatic solutions, understanding social and political constraints, and developing a robust, transparent assessment of a range of alternatives. The importance of the compliance process cannot be overstated. Streamlining environmental compliance for rodent eradications can help practitioners complete their compliance obligation in a timelier manner while maintaining environmental safeguards. Although each island is unique, many of the required regulatory hurdles including NEPA, Endangered Species Act, Clean Water Act, Coastal Zone Management Act, FIFRA, and the MBTA are relevant to all US based rodent eradications. Identifying areas to streamline within the required regulatory framework will make planning more efficient, more cost effective, and less burdensome. Looking for programmatic solutions, actively engaging with stakeholders and permitting agencies, developing robust, transparent NEPA documents, and incorporating social and political constraints into the decision making process can help promote stakeholder engagement, increase buy-in from the public and experts, and provide more opportunities to remove invasive rodents from islands and help prevent extinctions. The key is to think globally but act locally.
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