Species Research and Analysis:
In the last five years, ecosystem management has emerged as a
major objective of public agencies that manage fish and wildlife resources. An ecosystem approach to overall agency performance
was formally adopted by the United States Fish and Wildlife Service in 1994 and
reaffirmed, recently, despite a rather negative
independent evaluation of
implementation. A philosophical commitment, at least, to ecosystem management has occurred in
various forms among other federal and state resource management agencies, too.
As a practical matter, ecosystem management for threatened and endangered species of
fish, wildlife, and plants finds its most telling application in the development of
conservation plans (HCPs) and their counterparts in southern California authorized by the
state's Natural Communities Conservation Planning (NCCP) Act. These plans stretch the
limits of science and strain the
capacities of agency decision
Although the HCP/NCCP process is staunchly defended and even lauded in the 1997 issue
of the Ecology Law Quarterly devoted to ecosystem management (and used as a text
for this course -- see the articles by Ebbin, Bosselman, and Zedler), the process also has
a fair share of vigorous critics. A former UC Davis student,
Hall, is one of these critics and keeps a
watching brief on the process from the offices of the Western Ancient Forests Campaign and the
American Lands Alliance in Portland, Oregon. A less
harsh but still analytical assessment of the
HCP/NCCP process comes from the detailed
case studies recently completed by the National Center for Environmental Decision
The impetus for the kind of species and habitat conservation planning that now preoccupies fish and wildlife agencies was provided by the strong political reaction to the
United States Supreme Court decision in TVA v. Hill (1978) and the
subsequent inclusion by Congress in the 1982 Endangered Species Act Amendments of
section 10(a) [16 USC
1539(a)(2)(B)]. This permits incidental takings of listed species as a result of private
actions, provided an HCP is prepared and provided assurance is given that the survival
and recovery of the species in the wild will not be appreciably reduced if the private
project goes forward.
Research and Analysis
Using the research resources cited, above, the balance of this
Web page addresses three major questions:
1. What are the principal scientific deficiencies of the HCP/NCCP
process revealed by recent research?
2. What are the major bureaucratic reasons why the U.S. Fish and
Wildlife Service has been unsuccessful in implementing an ecosystem approach to species management?
3. What concrete steps can be taken to improve the HCP/NCCP process, given that it
has scientific deficiencies and faces bureaucratic constraints?
HCP Process and Science
HCP's standers should be based on knowledge of the basic population
biology of all species, ecological requirements and a quantitative
estimate of the impact of take on population viability. HCP would
evaluate the cumulative effects of multiple plans and activities on
covered species and potential interactions among effects. To
achieve these foundation, HCP is lacking in data which is to support
documents. Their are mainly three aspects of data missing to be
sufficiently managed. The three insufficient aspects are
1)existence of the data, 2)standards of data, and 3)all sources of
formally documented data. These deficiency should be improved
|1) data should be available for
2) explicitly summarized data on each covered species which
include overall distribution, abundance, population trends,
ecological requirements, basic life history, and the nature of the
causes of endangerment should be standardized to be scientifically
3) an explicit acknowledgement of what data is available and
not should be formally documented to allow accurate
assessment of uncertainty and risk in the planning process.
Science in habitat conservation plans
HCP Process and Bureaucracy
The major bureaucratic reasons why the U.S. Fish and
Wildlife Service has been unsuccessful in implementing an ecosystem approach to species
management is revealed clearly in "An Assessment"
published in January 1998. This points out that US Fish and Wildlife Service is in the preliminary stages of implementing the Ecosystem
Approach, despite three years of activity. The reasons why FWS is
in this stage is as follows:
|1) the concept of the Ecosystem
Approach is unclear and not widespread.
2) Washington officials have not changed the way they did business in light of the
Ecosystem Approach efforts.
3) lack of integration of EA into normal business
4) internal operations are insufficient
5) technical expertise is week
6) leadership of EA and the agency is insufficient
7) programmatic consistency is insufficient
SOURCE: Ecosystem Approach to Fish and
Substantial net losses of habitat are
resulting from most ITPs and HCPs, particularly those which fail to use
credible scientific assessments, alternate land management practices,
and/or meaningful mitigation measures.
From Habitat Destruction to Habitat Conservation)
There are many dimensions of objectives which habitat conservation plans
(HCPs) need to deal with, such as political, economic, social and
scientific objectives to improve its quality and effectiveness.
The lack of the scientific process can lead to a critical problem.
Here are the steps that can be taken to improve the HCP/NCCP process:
|1) Explicit scientific standards
which are flexible enough to distinguish low impact HCPs and high
impact HCPs needs to be studied.
2) Explicit summary of available data on covered species,
including distribution, abundance, population trend, ecological
requirements and causes of endangerment should be included
in HCPs which have potentially large impact.
3) HCPs should be more quantitative in stating their biological
goals and in predicting their impact on listed species.
4) In case of information deficiencies, estimate the
uncertainties associated with impact, mitigation and monitoring,
and go forward, if risks are acknowledged and minimized.
5) Flexibility should be built into mitigation plans which enables
managers to be responsive to the results of monitoring during the
period of the HCP
6) When highly critical information is missing, the agencies
should be willing to withhold permits until the information is
7) Information about listed species should be maintained in
accessible, centralized locations, and that monitoring data should
be made accessible to others.
8) Scientific advisory committee and increased use of independent
peer review should be established during the early stages of the
design of potentially high-impact HCPs and stages that are
likely to lack important information.
These steps require major agency initiatives and policy alterations that are
1) The coordination of efforts to protect and recover threatened and
endangered species must be improved and will be essential to the accurate
estimation of the cumulative impacts of various management efforts for
threatened and endangered species. This does not require any
legislative changes, but require a funding commitment to put a centralized data
base in place
2) Academic and agency scientists should become more involved in
the HCP process.
3) U.S. Fish & Wildlife Service and NMFS should conduct their
own review of the HCP process from the perspective of identifying mechanisms
for making the job of their agency scientists more clearly defined.
Science in habitat conservation plans
Also 12 recommendations regarding 1)Planning and Definition,
2)Leadership and Accountability, 3)Boundaries, Teams and Partnering, and
4)Structure and Budget. are listed in Ecosystem Approach to Fish and