Conserving the Future: Wildlife Refuges and the Next Generation

I have two minor comments on the Recommendations on page 8:

1) ”Reduce the number of facilities and other assets we own and maintain.”

I disagree with a blanket statement like the one given in that it implies without reservation that we have too many facilities and assets. While we certainly must have some excess facilities, a blanket statement to reduce the number without a given reason is not a good recommendation in my opinion. I would rather see a broader statement that acknowledges that we should identify those facilites and assets that may be surplus and then work to remove them. Alternatively, if the statement is suggested as a means solely to reduce our carbon footprint, moving from Service owned facilities to rental space is not necessarily an improvement from an energy perspective. Bottom line: without really understanding the intent of the suggestion, it leaves it open to too broad an interpretation.

2) Reduce fuel consumption; I agree with the goal of moving to more effecient vehicles, equipment, etc. Choices in the area of heavy equipment are limited in terms of effeciency. I have seen programs lately that showed equipment fleets converted to propane as a means of reducing pollution. This may be something the Service should consider and it would allow conversion of existing equipment (in some cases) as opposed to waiting for new purchases to make progress. Just a thought.

Comments on Planning.Draft.Outline

I. 4. b. Communities & refuges grow into the future together

comments: The term “refuges” is undefined in this document. One would have to assume that the intended implication of the term “refuges” is probably what are considered to be the 553 “refuges” with the implied exclusion of everything else in the land base.

By law and regulations the actual units included in the term “National Wildlife Refuge” is everything in tables 3 and 4 of the annual report of lands. That includes every Farm Services Administration unit and every waterfowl production area.

This statement implies that the part of the Refuge System known as coordination areas are excluded from consideration in the shared vision of the future

II. 2. a. – Refuges and wetland mgmt districts are the land base for FWS

comments: The statement is incorrect. It is the individual units of the National Wildlife Refuge System form the primary land base for FWS not “refuges and wetland mgmt districts.” Wetland Management Districts are not a part of the Refuge System. The WMDs are only administrative offices, no different in function than any complex office. The legally identified units of the Refuge System specifically includes waterfowl production areas.

This statement also overlooks the fact that some refuge complex office administer WMDs and some WMDs administer named refuges that are part of the 553.

Refuges, WPA’s, Coordination Areas are resource units. Refuge complex offices and WMD’s are only administrative units. The comparison is similar to plants/animals as resources and farmers/ranchers being administrators.

The statement is also phrased so as to exclude Coordination Areas. By definition the NWRS includes Coordination Areas. If you exclude Coordination Areas, by definition, you have reduced this discussion to just NWRs (the broad definition, not the 553).

You either plan to manage the NWRS as a system or you focus on managing NWRs only as a system (with the little “s”)

III. Perspectives on Conservation Planning and Design

general comment: CCP’s are not focused on the NWRS but on NWRs. It is not a comprehensive NWRS system wide planning process. FWS has never had any intention of doing any sort of planning or integration of planning efforts with Coordination Areas.

V. 1. A. Strategic growth of the Refuge System.

comments: Although this implies NWRS, what is really being said here is NWRs. The Service currently has no intention to deal with Coordination Areas. You either plan to manage the NWRS as a system or you focus on managing NWRs only as a system (with the little “s”)

V. 2. c. Evaluate each refuge’s potential to contribute to the overall goals of the NWRS.

comments: The reference to “refuge’s” here is essentially a reference to the 553 not to all the units legally within the definition of NWR nor to the entire NWRS.

V. 3. A. refuge performance and Refuge System’s performance management system

comments: The reference to refuge and Refuge System here are essentially a reference to the 553, with possible inclusion of the WMD offices, not to all the units legally within the definition of NWR nor to the entire NWRS.

V. 3. D. Improve how the Refuge System collects data.

comment: Although lacking any precise definition as to just what is meant by “Refuge System” here, it is probably reasonable to assume that this is an implied reference to the 553 and the WMD’s. That being the case, it would be incorrect to consider this as a data collection issue of the NWRS.