Aldo Leopold would be taking a deep breath if he could with the news that the USFWS is enhancing mitigation guidelines to include a landscape-scale approach instead of a project by project approach. This means that reviewing agencies for requests to destroy precious environments with mitigation have now to take into consideration continuing biodiversity for the entire landscape and not just the project.
DOI has for the past several years been trying to get the approach changed, but with President Obama’s recent memo Mitigating Impacts on Natural Resources from Development and Encouraging Related Private Investment, they and other related agencies finally got a big boost toward helping our environment.
This means that “the mitigation goal is not necessarily based on habitat area, but on numbers of individuals, size and distribution of populations, the quality and carrying capacity of habitat, or the capacity of the landscape to support stable or increasing populations of the affected species after the action (including all proposed conservation measures) is implemented. In other words, it is based on those factors that determine the ability of the species to be conserved.”
Further, “offsetting impacts to designated or proposed critical habitat through the use of compensatory mitigation should target the maintenance, restoration, or improvement of the recovery support function of the affected critical habitat as described in the relevant biological or conference opinion, conservation or mitigation plan, mitigation instrument, permit, or conference report. Recovery plans, 5-year reviews, proposed and final critical habitat rules, and the best available science on species status, threats, and needs should be relied on to inform the selection of habitat types subject to compensatory mitigation actions for unavoidable adverse impacts to species or critical habitat.”
If you’d like to share your thoughts about this new approach to mitigation go to Endangered and Threatened Wildlife and Plants; Endangered Species Act Compensatory Mitigation Policy and submit a formal comment by October 17, 2016.
To read a simpler version of this guideline, go to The Presidential Memorandum and Interior Department Policy on Mitigation: Their Content and Implications by Holland & Hart.
In case you’re wondering what I wrote to the FWS, here it is:
Mitigation –- The Business Dictionary defines it as “the elimination or reduction of the frequency, magnitude, or severity of exposure to risks, or minimization of the potential impact of a threat or warning.” Read more: http://www.businessdictionary.com/definition/mitigation.html I chose this definition because mitigation of our environment is related to the business of our existence. Mitigation never equals the original ecological site, regardless of the intent. It never reduces the severity of the risk of losing the biodiversity. It is a costly undertaking not just for the economics of it, but for the cost to our environment. There is no monetary value equal to the loss of the biodiversity of the site with which the endangered species dwells. Mitigating based on project rather than landscape always leads to unsuccessful results. A true mitigation would provide for the same biodiversified surroundings found in the original site, but just like snowflakes, no two are evolved alike so no two can be made to be alike. Project-by-project provides too small a footprint to include the biodiversity required to truly provide the habitat necessary for a successfully mitigated displacement of an endangered species. Landscape-scale mitigation, though not perfect, allows for a broader scope in attempting more successful mitigation results. Compensation measures should require the recreation of a complete biodiversified site equal to the lost habitat; buying credits from a conservation bank or paying into an in-lieu fee fund definitely do not accomplish the same thing. Once the ecological web is broken, life can never be as it was. An added note about climate change – as climate change continues to take its toll, truer mitigation will be more difficult. Not only will we not have hundreds, thousands, millions of years to accommodate adaptive evolution, but the days will be filled with unknowns. Preserving landscape and endangered species based on what we know now will be vitally important to our continued existence. The web of life was not made up of mitigation, but of biodiversity.” rel=”nofollow”>Business Dictionary defines it as “the elimination or reduction of the frequency, magnitude, or severity of exposure to risks, or minimization of the potential impact of a threat or warning.”
I chose this definition because mitigation of our environment is related to the business of our existence. Mitigation never equals the original ecological site, regardless of the intent. It never reduces the severity of the risk of losing the biodiversity. It is a costly undertaking not just for the economics of it, but for the cost to our environment. There is no monetary value equal to the loss of the biodiversity of the site with which the endangered species dwells.
Mitigating based on project rather than landscape always leads to unsuccessful results. A true mitigation would provide for the same biodiversified surroundings found in the original site, but just like snowflakes, no two are evolved alike so no two can be made to be alike. Project-by-project provides too small a footprint to include the biodiversity required to truly provide the habitat necessary for a successfully mitigated displacement of an endangered species. Landscape-scale mitigation, though not perfect, allows for a broader scope in attempting more successful mitigation results. Compensation measures should require the recreation of a complete biodiversified site equal to the lost habitat; buying credits from a conservation bank or paying into an in-lieu fee fund definitely do not accomplish the same thing. Once the ecological web is broken, life can never be as it was.
An added note about climate change – as climate change continues to take its toll, truer mitigation will be more difficult. Not only will we not have hundreds, thousands, millions of years to accommodate adaptive evolution, but the days will be filled with unknowns. Preserving landscape and endangered species based on what we know now will be vitally important to our continued existence. The web of life was not made up of mitigation, but of biodiversity.