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,
Gabrielle
From Planning to Implementation: Streamlining
Compliance for U.S. Rodent Eradications
By: Gabrielle
Feldman and Gregg Howald
Abstract
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.
Introduction
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).
NEPA
Analysis
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.
Conclusion
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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