Dear Conservation Delivery Team,

I am posting comments pertaining to your team. Thank you for your consideration.

Brian Czech, Conservation Biologist
National Wildlife Refuge System
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Page 7, lines 15-16. “Such trade-offs in conservation are nothing new, of course, but are likely to become ever more urgent in the coming years.” This sentence provides sound rationale for addressing the trade-off between economic growth and wildlife conservation. Trade-offs between wildlife conservation and other societal goals are not surprising, but some are kept from open view, and part of our job should be to help clarify such trade-offs when necessary. This is necessary in the case of economic growth because many Americans have been led to believe that there is no trade-off between economic growth and wildlife conservation, even though wildlife conservation is an “opportunity cost” of economic growth and vice versa. Many of these same Americans see conflicts between growth and conservation on the ground, but are led to believe that such conflicts may somehow be reconciled with technological progress, an increasingly services-oriented economy, or some form of “green growth.” The notion of reconciling economic growth with wildlife conservation has been found scientifically unsound (The Wildlife Society 2003), but it is politically convenient and persuasive to a public that prefers not to incur opportunity costs.

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Page 7, line 46. The “changing role of the Service in collaborative conservation” is another indication that the Service needs to work beyond the traditional ‘stovepipes’ of biology, ecology, and even conventional conservation planning.”

This is true, and we should not let a stovepipe prevent us from help to raise awareness of the trade-off between economic growth and wildlife conservation. (See Bold Ideas).

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Page 8, lines 14-19. “Conservation delivery is not a new concept, but the job has grown in complexity because of unprecedented habitat fragmentation, invasive species, climate change impacts, and other stressors. Conservation professionals must contend with the endless variability and interdependence of ecological systems, and work to achieve positive conservation outcomes with information that will always be incomplete. Conservation professionals will require skill, adaptability and the capacity for innovation to meet such threats.”

This paragraph is a good example of the reactive (as opposed to proactive) nature of the the Draft Vision. No one plans to commit “habitat fragmentation, invasive species, or climate change.” Rather, these are unintended side-effects of other activities, and naturally our response is primarily reactive. These and almost all other major stressors are clear outcomes or functions of increasing human population and per capita consumption; i.e., economic growth (IPCC 2000, Czech et al. 2000, Ericson 2005, Miller-Reed and Czech 2005, Rose 2005).

Meanwhile, the rate of economic growth is a policy goal open for proactive discussion at all times (Collins 2000). While no one plans to commit habitat fragmentation, plenty of planning for economic growth has transpired (and continues). At every step of the way, such planning could have been informed by concerns about wildlife conservation, environmental protection at large, and other opportunity costs of growth, if only the affected parties had been bold enough to raise such concerns among the public and policy makers. Yet the Draft Vision says nothing about economic growth while repeating the conventional lists of growth symptoms at numerous points in the document. Noting the “unprecedented” nature of these symptoms seems like an affected and unnecessarily dramatic attempt to add an element of newness to the list. The unprecedented nature of the symptoms simply reflects the unprecedented levels of production and consumption occurring in the American and global economies. We would not have been caught off guard by the level of these threats, had we been heeding the trade-off between economic growth and wildlife conservation.

The paragraph also provides an excellent example of how the phrase “economic growth” can be easily and appropriately included among a list of broad threats to the Refuge System, in order to help raise awareness of the trade-off between economic growth and wildlife conservation. This alone would be conducive to achieving “positive” or proactive conservation outcomes by demonstrating “adaptability and the capacity for innovation” in dealing with threats.

I suggest rewording the paragraph as follows: “Conservation delivery is not a new concept, but the job has grown in complexity because of ongoing economic growth (including population and per capita consumption growth), habitat fragmentation, invasive species, climate change, and other stressors. Conservation professionals must contend with the endless variability and interdependence of ecological and economic systems, and work to achieve positive conservation outcomes with information that will always be incomplete. Conservation professionals will require skill, adaptability and the capacity for innovation to meet such threats proactively and reactively. They will be challenged to address causal mechanisms (such as economic growth) as well as distal effects (such as habitat fragmentation).”

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Page 8, lines 39-41. “Recommendation: All future land protection strategies should incorporate local, landscape and other necessary ecological scales and emphasize the importance of working lands in the surrounding landscape.”

Not all recommendations in the Vision must be bold, but this particular recommendation provides nothing new, either. Don’t we already do precisely what this recommendation states? We’re supposed to. Perhaps there is some degree of novelty in the “importance of working lands” emphasis, but the recommendation provides no way of emphasizing that importance.

I suggest adding another recommendation as follows: “The Refuge System will develop initiatives with farmers, ranchers and others working in the landscape to raise awareness that the mutual interests of wildlife conservation and working landscapes are threatened by burgeoning populations and economies.”

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Page 9, lines 35-37. “But future land protection planning is hampered by the lack of an integrated strategy for accomplishing the varying missions of the land management agencies.”

Developing such an integrated strategy could lead us into an inconclusive maze with substantial opportunity costs and transaction costs. The major land management agencies have distinct missions, all for good reasons, and they have long-running and well-entrenched approaches to land acquisition and conservation. While we should collaborate with them as opportunities arise, especially on projects where their wildlife conservation interests dovetail with ours, it probably wouldn’t be optimizing our resources to try developing an integrated land conservation strategy for the agencies.

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Page 9, lines 35-37 (again). “But future land protection planning is hampered by the lack of an integrated strategy for accomplishing the varying missions of the land management agencies.”

It is also the case that future land protection planning is hampered by the lack of a strategy for coordinating with other (non-land management) agencies. In particular, we have no coordination with the departments and agencies that are intent upon growing the economy or carrying out growth programs. For example (and there are very many examples), the Department of Commerce has agencies and programs designed to stimulate economic growth in certain regions of the country (and in the country in general). We should be coordinating with these programs to share our concerns and obviate conflicts. Opening this dialog also gives us a chance to raise awareness of the trade-off between economic growth and wildlife conservation. It is easily conceivable that we could have greater conservation effect by coordinating with these agencies and programs than we do by over-emphasizing coordination with other land management agencies.

I suggest rewording as follows: “But future land protection planning is hampered by the lack of an integrated strategy for accomplishing the varying missions of government agencies. These include land management agencies that we already work with and other agencies that have direct effects on the American landscape. These include economic growth and development agencies in the U.S. Department of Commerce, Department of Transportation, and Department of Energy (and their state counterparts).”

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Page 9, lines 41-44. “The Refuge System must move quickly to participate in a collaborative landscape-level strategy for the National Wildlife Refuge System that can effectively address the most challenging and pervasive 21st century threats to biodiversity, such as climate change, urban development, habitat loss and fragmentation, and invasive species.”

This is an excellent example of a sentence with which it is easy, simple, scientifically sound, policy relevant, and politically innocuous to contribute to awareness of the challenge posed by economic growth. All we need to do is add the phrase among the list of challenges.

I suggest rewording as follows: The Refuge System must move quickly to participate in a collaborative landscape-level strategy for the National Wildlife Refuge System that can effectively address the most challenging and pervasive 21st century threats to biodiversity, such as climate change, economic growth, habitat loss, pollution, and invasive species.

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Page 10, lines 34-36. “…current human population and development trends threaten to overwhelm the value many of these habitats currently hold for wildlife and ecosystem integrity.”

This sentence probably comes closer than any other in the Draft Vision to acknowledging the trade-off between economic growth and wildlife conservation. Unfortunately the word “development” is a vague term in the vernacular and especially in economics, where development has often been conflated with economic growth. Therefore, in ecological economics and elsewhere an effort is made to reserve the word “development” for advances in human wellbeing (such as increased life expectancy or higher literacy rates) so the distinction between development and economic growth (increasing production and consumption of goods and services in the aggregate) is clear (Daly and Farley 2010). The sentence as written probably implies housing developments and other habitat-reducing activities in the construction sector, but it would be more accurate and less likely to be confusing if the word “economic” was used instead.

I suggest rewording as follows: “…current human demographic and economic trends threaten to overwhelm the value many of these habitats currently hold for wildlife and ecosystem integrity.”

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Page 10, lines 36-38. “By 2050, the U.S. population is expected to reach nearly 400 million, each of who require water, housing, roads, stores, and huge tracts of land to grow food and to recreate.”

This is another excellent example of a sentence with which it is easy to contribute to awareness of the challenge posed by economic growth. The economic aspect is important too, because far more habitat is lost to growth in per capita consumption than to growth in population. Furthermore, the sentence as written is likely to leave readers feeling powerless and resigned, because there is no policy arena for population issues. If the connection is made to macroeconomic trends, readers will correctly have some realistic hope that economic policy and consumer decision-making could be used to stem the tide of habitat loss. (Also, one of the primary reasons population growth remains unaddressed in the policy arena is because it is considered integral to economic growth, which has been an unchallenged goal. This nuance pertaining to growth politics and policy may not be within the purview of the Draft Vision, but it is good for us to be aware of.)

I suggest rewording as follows: “By 2050, the American population is expected to reach nearly 400 million and the American economy nearly $40 trillion. Supporting the additional economic activity would require approximately 200% more (all else equal) land and natural resources than the current GDP of $13 trillion. Even supporting the population growth alone, with no growth in GDP per capita, would require approximately 30% more land and natural resources (all else equal) than the current population of 307 million.”
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Page 11, lines 2-8. “Moving forward, the Service’s attention to strategic growth will be on a scale commensurate with the seriousness of the development trends that threaten to undermine more than a century’s worth of conservation efforts. In the context of land acquisition and other on-the-ground conservation strategies, the people of the Service will act with a sense of urgency, as critical pieces of the conservation estate are disappearing with each passing day. The Service must move quickly toward a collaborative landscape-level strategy that can effectively address the most challenging and pervasive 21st century threats to biodiversity.”

As noted above, “development” is a vague term and it is helpful to reserve the word for advances in human wellbeing. The word “economic” is clearer and more policy-relevant.

I suggest rewording as follows: “Moving forward, the Service’s attention to strategic growth will be on a scale commensurate with the seriousness of the economic trends that threaten to undermine more than a century’s worth of conservation efforts… [leaving the next two sentences as they are] ”

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Page 11, lines 15-20. “The Refuge System will develop an adaptive prioritization model that considers the various and oft-changing factors that affect the most important conservation targets. This need, which is currently filled by the Land Acquisition Prioritization System (LAPS), will be better met by including evaluations of a potential acquisition parcel’s role in a regional and ecological context, analyses of the changes an area may experience due to climatic shifts, and a sort of “urgency index,” or how imminent the threat is to any particular parcel.”

The logic and sentiment behind promoting an “urgency index” is understandable and intuitive. Unfortunately, it backfires over the long term if the goal is biodiversity conservation (Czech 2002). That is because the urgency of a conservation need is largely a function of how much economic activity has taken place in the area, which greatly influences land prices. For example, many of our ESA refuges are in or among urban areas, where economic activities have usurped or degraded habitats, resulting in urgency to conserve remaining habitat that may otherwise be imminently transformed. Not only are land prices and administrative costs far higher (all else equal) where there is conservation urgency, but the probabilities of success decline.

These are the conditions, at least, in the context of a growing economy, in which conservation urgency spreads across the landscape in concert with economic activity. Under these conditions, the optimal long-term conservation strategy is land acquisition in less-developed areas (all else equal) where land prices are lower and more ecological integrity remains. Urgency will “come” to these areas too, as the economy encroaches, but conservation needs will have been met prior to land prices becoming prohibitive. More species and other ecosystem components are conserved in the long run using this approach.

Furthermore, in the cases of threatened and endangered species, conservation urgency can be addressed to some degree with enforcement of the ESA (and state regulations) rather than land acquisition.

Finally, “urgency” is already captured in LAPS with a 200-point threatened and endangered species component and an imperiled ecosystems subcomponent (in the landscape conservation component). Therefore, if an “urgency index” were added to LAPS, a form of double-counting would result. See also the comments pertaining to page 11, lines 30-32.

I suggest rewording as follows: “The Refuge System will develop an adaptive prioritization model that considers the various and oft-changing factors that affect the most important conservation targets. This need, which is currently filled by the Land Acquisition Prioritization System (LAPS), will be better met by including evaluations of a potential acquisition parcel’s role in a regional and ecological context, analyses of the changes an area may experience due to climatic shifts, and a balancing of urgent needs with the need to acquire lands with longer-term ecological integrity prospects.

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Page 11, line 27. “Species, water, fire, and other crucial ecological services…”

Fire may be classified as an ecological service. Species and water are ecosystem goods and may also constitute funds from which ecological services are derived. Therefore, they could be correctly referred to as “natural capital” but not ecological services. There are perhaps three easy ways to fix this sentence. One is “Species, water, fire, and other natural capital …” Another is to drop the third comma: “Species, water, fire and other ecological services…” However, I think the following approach is best:

I suggest rewording as follows: “Species, water, and various ecological services…”

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Page 11, lines 30-32. “Minimizing threats to species of conservation concern and key ecosystem processes requires strategies of preserving large areas and maintaining landscape connectivity, in addition to creating and maintaining biological redundancies throughout the system.”

I concur, but “preserving large areas and maintaining landscape connectivity, in addition to creating and maintaining biological redundancies” is not consistent with establishing an “urgency index” for the reasons explained pertaining to page 11, lines 15-20 (see above).

I suggest retaining the wording in lines 30-32, but rewording lines 15-20 as noted above.

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Page 11, lines 39-42. “Recommendation: Complete an overhaul to the Land Acquisition Prioritization System to develop an adaptive prioritization model that helps determine the relative importance of potential land acquisition projects, both in completing existing acquisition projects and in beginning new ones.”

I concur with overhauling LAPS, but this recommendation needs something more about the type of outcome expected because LAPS has always been a “prioritization model that helps determine the relative importance of potential land acquisition projects, both in completing existing acquisition projects and in beginning new ones.” Readers will question the need for or the intent of this recommendation unless something new is recommended.

I suggest rewording as follows: “Recommendation: Overhaul the Land Acquisition Prioritization System to balance the needs for conserving migratory birds, threatened and endangered species, and fisheries and aquatic resources (all current LAPS components) with the need to conserve large landscapes, to conserve ecosystem types not represented in the conservation estate, and to incorporate climate change concerns.”

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Page 12, lines 9-11. “Refuge Law Enforcement Officers enforce the law, regulations, and policy first and foremost, but also look for teachable moments and educate the public on the importance and relevance of conservation.”

This is true, and note that it adds to the rationale for developing basic knowledge Service-wide about the trade-off between economic growth and wildlife conservation. For example, given a short segment on this topic at Refuge Academy or in other all-Service training venues, law enforcement officers would acquire the knowledge to relay this crucial message to the public when the occasion arises in the appropriate venues.

I suggest rewording as follows: “Refuge Law Enforcement Officers enforce the law, regulations, and policy first and foremost, but also look for teachable moments and educate the public on the importance of conservation and its relationship to other public concerns .”

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Page 13, lines 25-28. “The policy also tells managers of wildlife refuges to address threats and stressors that originate from beyond their boundaries. Explicitly recognized in the policy is the reality that many wildlife refuges are islands in highly fragmented landscapes…”

This too adds to the rationale for dealing deliberately and clearly with the trade-off between economic growth and wildlife conservation. It is worth asking ourselves why a national wildlife “refuge” is called such. Why is a refuge an “island” and what is it a “refuge” from? Essentially a refuge is an island in a sea of economic activity. The “threats and stressors” resemble a list of economic sectors, infrastructure, byproducts, and incidental effects (Czech et al. 2000). As noted in the Draft Vision, these threats and stressors “originate from beyond” refuge boundaries. What is often overlooked is that a significant share of the “origination” includes fiscal and monetary policies developed in statehouses, federal agencies, and monetary authorities.

This does not mean the vision document should describe all the fiscal and monetary policies that result in intensified economic activity and therefore threats and stressors to wildlife and refuges. Rather, the vision document should help demonstrate that there is a trade-off between economic growth and wildlife conservation, and should contribute to Refuge System efforts, moving forward, to raise awareness of the trade-off. To the extent such awareness grows, policy makers will consider this trade-off when they develop fiscal and monetary (and trade) policy.

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Page 14, lines 42-44. “Maintaining biological integrity, diversity and environmental health on national wildlife refuges and contributing to ecological resilience and climate change adaptation will require innovation, flexibility and adapting policy to changing conditions.”

This is true, and the innovation, flexibility, and adaptation should also apply to the breadth of issues we address. It should be noted that, in the draft biological integrity, diversity and environmental health policy (or “ecological integrity policy” as it was called when issued for public review), the trade-off between economic growth and wildlife conservation was partly addressed as follows: “During the industrial era, the use of intensive energy sources such as fossil fuels allowed the scale of the economy to grow to degrading proportions, eliminating habitats and species and creating a need for refuges and other conservation efforts.” This language and all reference to economic growth (and even the phrase “ecological integrity”) was dropped for political reasons in the final “Biological Integrity, Diversity, and Environmental Health” policy. However, since then the political environment has been transformed in the context of oil prices, climate change, the BP oil spill, and financial and fiscal crises, all of which point to “uneconomic growth” (i.e., growth beyond optimum scale, or growth costing society more than it benefits). Also since then, “changing conditions” have included a much larger GDP, leading to the “unprecedented” levels of habitat fragmentation, climate change, and invasive species noted earlier in the Draft Vision. The vision should reclaim what was lost from the ecological integrity policy; that is, the explicit linkage between economic scale and the loss of ecological integrity.

I suggest building upon the statement as follows: “Maintaining biological integrity, diversity and environmental health on national wildlife refuges and contributing to ecological resilience and climate change adaptation will require innovation, flexibility and adapting policy to changing conditions. Such innovation and flexibility also entails addressing subject matter previously taken for granted, such as demographic trends, economic growth, and evolving technological regimes.”

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Page 15, lines 5-8. “Recommendation: Review and update policy for managing biological integrity, diversity, and environmental health on wildlife refuges. The benchmark for desired conditions must anticipate that climate-changed ecological conditions may preclude managing for historic conditions.”

601 FW 3 was crafted with climate change in mind. Please note Step C for implementing the policy as provided in Section 3.9:

“C. Assess historic conditions and compare them to current conditions. This will provide a benchmark of comparison for the relative intactness of ecosystems’ functions and processes. This assessment should include the opportunities and limitations to maintaining and restoring biological integrity, diversity, and environmental health.’

The full implementation framework may be summarized as:

• Ascertain purposes of refuge.
• Assess current conditions.
• (C) Ascertain historic conditions and compare.
• Consider issues of geographic scale.
• Integrate the application of concepts.
• Modify management as necessary.
• Evaluate and adjust.

The policy was never intended to compel managers to reproduce historic conditions; rather to use historic (or prehistoric) conditions as a “benchmark for comparison.” The main idea is to prevent significant further departure from those conditions and to restore a higher degree of ecological integrity where feasible, but in either case subject to the “limitations to maintaining and restoring” ecological integrity. Climate change is one such limitation that must be considered using sound professional judgment. See also Czech (2005) for further details on applying the policy that were not included in the condensed, final policy. It would be unnecessary and expensive to review and update 601 FW 3 for the sake of reconciling the policy with climate change.

I suggest deleting the recommendation.

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Page 16, lines 40-41. “Recommendation: Review the farming program and identify opportunities to reduce carbon emissions and sequester carbon by restoring native vegetation.”

It should be noted that the review of farming programs to identify opportunities to restore native vegetation was one of the original intentions of the ecological integrity policy. Linking to the policy or at least to the concept of ecological integrity will help to empower this recommendation and complement it with additional rationale.

I suggest building upon the statement as follows: “Review the farming program and identify opportunities to reduce carbon emissions, sequester carbon, and contribute to the ecological integrity of the Refuge System (as consistent with 601 FW 3) by restoring native vegetation.”

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Page 17, lines 43-46. “The era is over when the Refuge System could focus only on protecting land and water inside refuge boundaries, and leave to a roll of the dice what happened outside the boundaries. The emerging model focuses on conserving entire landscapes and connecting the stewardship of those landscapes to the livability and sustainability of local communities.”

Addressing what happens “outside the boundaries,” “conserving entire landscapes,” and “sustainability of local communities” will seem like wispy notions and wishful thinking without plain, explicit language about economic growth.

I suggest building upon the statement as follows: “These landscape and community objectives will not be attainable in the face of perpetual economic growth, however, so the emerging model engages the Refuge System in discussions of economic growth with local, state, and national economic interests, economic planners and, when appropriate, economic policy makers.”

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Page 18, line 13. I suggest replacing the phrase “efficiencies of scale” with “economies of scale.”

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Pages 18-19, lines 45-46 and 1-2. “Recommendation: Develop and provide collaboration and diplomacy skills training to employees to increase land management cooperatives among national wildlife refuges, local landowners, and other partners. The training should include educating private landowners on the benefits of conservation.”

I suggest building upon the statement as follows: “…local landowners, economic planners, and other partners. The training should include educating landowners on the benefits of conservation, informing economic planners of the costs to communities of habitat liquidation, and apprising all of the trade-off between economic growth and wildlife conservation.”

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Page 19, lines 4-25. “… The Farm Bill contains billions of dollars…”

The paragraph and recommendations pertaining to the Farm Bill seem out of place and scarcely appropriate for a “vision” statement. Although the ideas presented here are fine, is any of it new, bold, or visionary? Farm Bill conservation incentives have been hashed out in great detail by the wildlife profession for decades. These incentives tend to be short-term, and the reference to the “billions of dollars” gives the impression of financial calculating. Again, even short-term incentives and financial strategizing are important, but these considerations do not belong in a vision statement, and the recommendations would probably be pursued regardless of a vision statement.

I suggest condensing the Farm Bill portion by eliminating language pertaining to leveraging money and perhaps eliminating more as the authors see fit in attempting to keep this portion consistent with a long-term vision for the Refuge System.

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Page 20, lines 2-4. “Recommendation: Develop a comprehensive communications and outreach strategy regarding Refuge System’s coastal and ocean areas management paradigm to help land managers understand its place within the suite of options for conservation.”

Among ecologists and conservationists, those who deal with marine issues tend especially to recognize the ecological impacts of economic growth. This stems from the fact that the oceans are downstream from the rest of the planet, so that the waste products from the global economy tend to concentrate in the oceans. This then is a segment of the Draft Vision that especially calls for raising awareness of the issue.

I suggest revising the recommendation as follows: Develop a comprehensive communications and outreach strategy…to help land managers understand its place within the conservation community and to help the public and policy makers understand the trade-off between economic growth and marine conservation.”

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Page 21, lines 34-36. “In the face of such environmental stresses as climate change and a burgeoning worldwide population, effective communication of successful wildlife conservation across international boundaries is imperative.”

Effective communication is imperative, and not only of “successful wildlife conservation.” This sentence is clearly yet another instance where the lack of economic connection is glaring. Fortunately, this is easily remedied.

I suggest revising the recommendation as follows: “In the face of such environmental stresses as a burgeoning global population, an even more rapidly growing economy, and numerous resulting impacts including habitat loss, pollution, and climate change, effective communication for addressing these stressors across international boundaries is imperative.”

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Page 23, lines 2-4. “Recommendation: In new comprehensive conservation plans, describe how the Service can use all its conservation delivery tools to project conservation benefits beyond refuge boundaries across the landscape.”

This recommendation may seem trite to readers. One could summarize it, “Make new CCPs have good effects across the landscape.”

I suggest deleting the recommendation.