24 February 2014

The Friends of the Migratory Bird/Duck Stamp appreciates the opportunity to make comments on a strategic approach to the growth of the National Wildlife Refuge System.

The approach presented in the assessment of land protection project and the accompanying draft chapter 5 of the Service Manual is thoughtful as far as it goes. The approach emphasizes that the way that the USFWS adds lands for the Refuge System is "unsustainable and may not reflect the highest priority acquisitions that contribute to landscape conservation," adding that there are over "five million acres of fee lands for refuge purchase at a projected cost of $10 to $25 billion, that would take several decades to complete."

This asserts that what is sought is a strategy to make the right choices "on behalf of the American people,” and embraces a "scientific, landscape-level approach" to acquisition and "works to facilitate conservation benefits beyond our boundaries."

It also makes clear that priorities will be guided by:

• The recovery of Endangered and Threatened species,
• The North American Waterfowl Management Plan, and
• The other migratory bird conservation plans (e.g., PIF, shorebird, and waterbird).

In light of these particular stated approaches, we have some comments, especially drawing attention to ten elements – in no particular order – that we feel are important and that are not covered or emphasized in the draft documents:

1. The approach recognizes that cost of land has risen dramatically over the last decade and that it would take 101.5 years to finish all desired fee-title acquisition and 75.1 years to finish all easement acquisition if 50,000 acres per year in each case could be secured. This is deemed unsustainable, without clarifying why. What metrics are not being met and why? Furthermore, if a strategy to acquire roughly 50 percent of all desired fee title and easement will take 50 years, why might that add up to a failed or unsustainable approach?
2. If funding for growth relies on two traditional sources – Land and Water Conservation Fund (LWCF) and the Migratory Bird Conservation Fund (MBCF) – why must planning assume that these funds are static? Since 1977, the LWCF has had an authorized limit of $900 million yearly, a figure that has rarely been close to being realized. That $900 million today would be equal in value to almost $3.5 billion, a fact that needs to be addressed when considering reauthorization of LWCF in 2015.
3. Most importantly for our Friends group, the other assumption is that the funding for the MBCF is also static. Growth, however, can occur – even at smaller levels – if the MBCF is expanded. Beyond the obvious method of raising the price of the individual Stamp, increasing income could occur in a number of ways. For example, more Stamps would be sold to newly recruited waterfowl hunters; Stamps could be required for other kinds of waterbird hunters (e.g., those hunting cranes, snipe, etc.). Possession of a Stamp could also be required as an expanded entrance fee or to engage in other specific activities on – and perhaps off – the Refuge System. Finally, more MBCF money would come to the Refuge System simply if more Americans were won over to the grand conservation functions of the Stamp, the vital role of the MBCF/MBCC, and if there were a complementary organized Refuge System campaign to sell more Stamps.
4. While the American people (and future generations) are mentioned a few times – including in the "mission" of the System – there is nothing presented on the intersection of the needs of the American people (in terms of outdoor activities and appreciation) and the Refuge System’s approach to growth. Where do "landscape-level conservation" and legitimate outdoor recreations (e.g., The Big Six) intersect when it comes to Refuge System growth?
5. Likewise, the July 2011 NWRS "Vision Conference," held in Madison, Wisconsin, and corresponding “Conserving the Future” guiding vision document, identified an urban-refuge emphasis and the importance of reaching youth. The draft growth documents are silent on how those sorts of audiences blend into, or at least influence, the growth planning process. Yes, there are wildlife-and-habitat priorities, but where are the social-growth-and-people priorities? And where do they fit in an approach to growth?
6. The strategy wisely brings up the use of easements in growth. (One large example is the new Dakota Grassland Conservation Area with a goal to protect 1.94 million acres in prairie easements.) This is excellent. However, there is no explanation of relative weight that easements may have within the system, especially in light of new directions being assumed in the Dakotas, Florida (e.g., Everglades Headwaters), or other focus areas. The use of easements may receive considerable acceptance from Congress, a factor that gives it added strength today and that may come into play when discussing the reauthorization of LWCF (see #2, above).
7. Similarly, while alternate growth is considered with refuges viewed as “anchor points and portals… in collaboration with communities and partners,” little is made of the creative partnership implications of this approach. There are additional innovative ways to view partnerships "beyond the boundary" that will create corridors and buffers to protect essential habitat (e.g., Farm Bill conservation, local government land partnerships, migratory bird joint venture work, growing land trusts, etc.). These partnerships and connections have great success and great promise. They are mentioned, however, with only one example (Rappahannock River Valley in Virginia), yet the broader implications of partnerships for watersheds, for landscapes, and for people are not explored. This could have a real impact on how the Refuge System continues to “do business,” especially when considering associated costs and staffing.
8. State wildlife and conservation agencies are given special status in the approach to strategic growth, which is appropriate, to “interact, coordinate, cooperate, and collaborate.” But few other parties (see, for example, #7, above) are given a role as legitimate partners or consultant institutions in the future.
9. Also in the area of funding for growth, the strategy points to "mitigation funds" (e.g., on the Gulf Coast) as a way to contribute new funding to the NWRS. This is excellent. But, besides saying that this sort of funding "must be factored into the decision-making process" there is nothing more mentioned on how such funding might be accessed. Where is the call to insert mitigation/penalty funding directly into the MBCF as a way to supplement Stamp funds and a way to direct those funds into land-and-wildlife conservation through the decisions of the MBCC? Each Region has its own list of properties and the associated bird/wildlife that would benefit, and it would be relatively easy to identify “mitigation properties” in anticipation of these crises and incidents. What is missing here is the direct connection between the needs and the means.
10. While the draft approach states that priorities will be guided by the recovery of Endangered and Threatened species, the North American Waterfowl Management Plan, and the other migratory bird conservation plans (including step-down plans), no prioritization among goals within the plans are mentioned. This is of course, not simple, but even the statement that “any overlap of wetland priorities” in NAWMP, the shorebird plan, and the waterbird plan should be sought and maximized (especially in terms of cost savings) would have been helpful.

In short, there isn’t an overarching growth strategy proposed in the documents. They constitute more of a status quo description. While that sort of description is very important, and while the assessment is excellent, there is little in the way of solid direction for the next steps or for the “right choices” that the National Wildlife Refuge System has to make. There is little in the documents of how much to grow the system; there is little that might serve as a roadmap for the system. There are hard decisions and shifting priorities that face the National Wildlife Refuge System, but in many ways, particularly those ten listed above, this growth approach lacks a broader vision for addressing the system’s pressing biological and human needs in the 21st century.