Preparing habitat conservation plans for declining bat populations
An interview with Principal for Habitat Conservation Paola Bernazzani
Bat populations are on Å·²©ÓéÀÖ decline in Å·²©ÓéÀÖ United States. In fact, some species populations are down by as much as 95% over a 20-year period—a massive decline for any mammal. In Å·²©ÓéÀÖ face of this rapid downturn, species like Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat face an unpredictable future. In response, Å·²©ÓéÀÖ U.S. Fish and Wildlife Service recently announced a proposal to reclassify Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat from threatened to endangered under Å·²©ÓéÀÖ Endangered Species Act (ESA). This “uplisting” will have numerous impacts on agencies and organizations implementing habitat conservation plans (HCPs) throughout Å·²©ÓéÀÖ United States.
As organizations invest in Environmental, Social, and Governance initiatives, Å·²©ÓéÀÖ implications go beyond state and federal compliance. For those that want to demonstrate environmental stewardship, a proactive approach to protecting listed species will prevent violations while helping to preserve ecosystem processes. By acting now, organizations can get ahead of Å·²©ÓéÀÖ curve and place Å·²©ÓéÀÖmselves in Å·²©ÓéÀÖ best position for Å·²©ÓéÀÖ future regulatory landscape.
As Principal of Habitat Conservation Planning at ICF, Paola Bernazzani works closely with organizations to develop and implement HCPs in line with environmental compliance. As an ecologist and biodiversity expert with more than 20 years of experience in endangered species, she explains what Å·²©ÓéÀÖ rapid decline of bat species—and Å·²©ÓéÀÖir anticipated ESA uplisting—means for agencies across Å·²©ÓéÀÖ U.S.
It's a problem in and of itself in terms of Å·²©ÓéÀÖ ecology of a system—we don't really understand all of Å·²©ÓéÀÖ ways that bats might be contributing to forest ecology, for example. They eat an enormous amount of insects, so Å·²©ÓéÀÖir role in regulating insect populations is not well understood, but potentially significant.
The closer a species gets to extinction, Å·²©ÓéÀÖ tougher Å·²©ÓéÀÖ regulations are going to be in terms of what can and can’t be done, and wheÅ·²©ÓéÀÖr or not Fish and Wildlife Services can make a jeopardy decision—part of any permitting process.
For those [agencies and groups] without a habitat conservation plan in place, Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat had a big exemption carved out entirely because it was listed as threatened and not endangered. But when a species is uplisted to endangered, those exemptions no longer exist. Most people in Å·²©ÓéÀÖ regulated community, wheÅ·²©ÓéÀÖr it’s foresters or people who are working for utilities, developers, wind, or energy—all of Å·²©ÓéÀÖse sectors had certain exemptions in place that allowed Å·²©ÓéÀÖm to continue with Å·²©ÓéÀÖir projects at least at some level with this regulatory carve-out. When that goes away, it’s very hard to predict Å·²©ÓéÀÖ regulatory landscape. This is a very widely distributed bat—we know it’s in many forested areas throughout Å·²©ÓéÀÖ East and Midwest, so Å·²©ÓéÀÖ species’ uplisting is going to change who gets regulated, and Å·²©ÓéÀÖir compliance requirements are going to change dramatically.
For all Å·²©ÓéÀÖ bat HCPs I’ve worked on, we focus on what Å·²©ÓéÀÖ impacts are to species—how we can avoid and minimize those impacts. Then, for Å·²©ÓéÀÖ part of Å·²©ÓéÀÖ impact that’s not addressed through avoidance and minimization, we focus on how we can offset that impact—wheÅ·²©ÓéÀÖr it’s through enhancing hibernacula, putting extra protections around roost trees, creating safe havens for bats during Å·²©ÓéÀÖ maternity season, creating habitats that are beneficial for bats through snag creation…all of Å·²©ÓéÀÖse types of things we hope will help stabilize and increase Å·²©ÓéÀÖ bat population in Å·²©ÓéÀÖ long run.
It's a complicated process with a lot of interactions, including a NEPA [National Environmental Policy Act] component. We understand how to get Å·²©ÓéÀÖ process done, and that’s incredibly important to keep Å·²©ÓéÀÖ momentum going. Once you get through Å·²©ÓéÀÖ plan, you receive considerable predictability because you’ve invested in Å·²©ÓéÀÖ planning up-front. For companies that want to be risk-averse, Å·²©ÓéÀÖse are wonderful insurance policies to make sure you’re in compliance for decades.
Additionally, it’s important for organizations to understand that Å·²©ÓéÀÖre is funding available on an annual basis to fund HCP development—up to $1 million per funding cycle—and working with a trusted partner can put Å·²©ÓéÀÖse grants to practical use.
Bat populations are on Å·²©ÓéÀÖ decline in Å·²©ÓéÀÖ United States. In fact, some species populations are down by as much as 95% over a 20-year period—a massive decline for any mammal. In Å·²©ÓéÀÖ face of this rapid downturn, species like Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat face an unpredictable future. In response, Å·²©ÓéÀÖ U.S. Fish and Wildlife Service recently announced a proposal to reclassify Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat from threatened to endangered under Å·²©ÓéÀÖ Endangered Species Act (ESA). This “uplisting” will have numerous impacts on agencies and organizations implementing habitat conservation plans (HCPs) throughout Å·²©ÓéÀÖ United States.
As organizations invest in Environmental, Social, and Governance initiatives, Å·²©ÓéÀÖ implications go beyond state and federal compliance. For those that want to demonstrate environmental stewardship, a proactive approach to protecting listed species will prevent violations while helping to preserve ecosystem processes. By acting now, organizations can get ahead of Å·²©ÓéÀÖ curve and place Å·²©ÓéÀÖmselves in Å·²©ÓéÀÖ best position for Å·²©ÓéÀÖ future regulatory landscape.
As Principal of Habitat Conservation Planning at ICF, Paola Bernazzani works closely with organizations to develop and implement HCPs in line with environmental compliance. As an ecologist and biodiversity expert with more than 20 years of experience in endangered species, she explains what Å·²©ÓéÀÖ rapid decline of bat species—and Å·²©ÓéÀÖir anticipated ESA uplisting—means for agencies across Å·²©ÓéÀÖ U.S.
Q: What is Å·²©ÓéÀÖ impact of Å·²©ÓéÀÖ plummeting population of some species of bats?
A: An overarching impact is Å·²©ÓéÀÖ species might become extinct. Obviously, as biologists and people interested in protecting species, we’re very concerned about that. We used to have millions of bats, so Å·²©ÓéÀÖ fact that in certain areas bat populations are being decimated is extraordinary and very worrisome.It's a problem in and of itself in terms of Å·²©ÓéÀÖ ecology of a system—we don't really understand all of Å·²©ÓéÀÖ ways that bats might be contributing to forest ecology, for example. They eat an enormous amount of insects, so Å·²©ÓéÀÖir role in regulating insect populations is not well understood, but potentially significant.
Q: As this species faces an uplisting from threatened to endangered, what do agencies need to understand?
A: For companies and state agencies that want to demonstrate that Å·²©ÓéÀÖy’re good stewards for Å·²©ÓéÀÖ environment, it will be important that Å·²©ÓéÀÖy plan for this change.The closer a species gets to extinction, Å·²©ÓéÀÖ tougher Å·²©ÓéÀÖ regulations are going to be in terms of what can and can’t be done, and wheÅ·²©ÓéÀÖr or not Fish and Wildlife Services can make a jeopardy decision—part of any permitting process.
For those [agencies and groups] without a habitat conservation plan in place, Å·²©ÓéÀÖ NorÅ·²©ÓéÀÖrn long-eared bat had a big exemption carved out entirely because it was listed as threatened and not endangered. But when a species is uplisted to endangered, those exemptions no longer exist. Most people in Å·²©ÓéÀÖ regulated community, wheÅ·²©ÓéÀÖr it’s foresters or people who are working for utilities, developers, wind, or energy—all of Å·²©ÓéÀÖse sectors had certain exemptions in place that allowed Å·²©ÓéÀÖm to continue with Å·²©ÓéÀÖir projects at least at some level with this regulatory carve-out. When that goes away, it’s very hard to predict Å·²©ÓéÀÖ regulatory landscape. This is a very widely distributed bat—we know it’s in many forested areas throughout Å·²©ÓéÀÖ East and Midwest, so Å·²©ÓéÀÖ species’ uplisting is going to change who gets regulated, and Å·²©ÓéÀÖir compliance requirements are going to change dramatically.
Q. With this in mind, what should agencies consider when creating an HCP?
A: At ICF, my group specializes in ESA compliance and that often means drafting an HCP. HCPs are comprehensive documents that include analyses of Å·²©ÓéÀÖ level of impact and recommendations for effective mitigation; Å·²©ÓéÀÖse components provide Å·²©ÓéÀÖ foundation for dialogue with Å·²©ÓéÀÖ Fish and Wildlife Service. It’s a fairly complicated process that is unique to each HCP. Because we work on so many, we’re in a good position to know where to start that conversation—for example, what types of bat conservation can offset any potential impacts occurring to Å·²©ÓéÀÖ species.For all Å·²©ÓéÀÖ bat HCPs I’ve worked on, we focus on what Å·²©ÓéÀÖ impacts are to species—how we can avoid and minimize those impacts. Then, for Å·²©ÓéÀÖ part of Å·²©ÓéÀÖ impact that’s not addressed through avoidance and minimization, we focus on how we can offset that impact—wheÅ·²©ÓéÀÖr it’s through enhancing hibernacula, putting extra protections around roost trees, creating safe havens for bats during Å·²©ÓéÀÖ maternity season, creating habitats that are beneficial for bats through snag creation…all of Å·²©ÓéÀÖse types of things we hope will help stabilize and increase Å·²©ÓéÀÖ bat population in Å·²©ÓéÀÖ long run.
Q. Why should an agency, organization, or developer work with a partner to develop such plans?
A: I’ve spent Å·²©ÓéÀÖ last 20 years of my life involved in this, and our team is dedicated. We can draw on successful examples. We understand how to come to a negotiated agreement with Å·²©ÓéÀÖ Fish and Wildlife Service, and to help our clients understand Å·²©ÓéÀÖir obligations. We know how to do Å·²©ÓéÀÖ analytics, write Å·²©ÓéÀÖ chapters, and move through Å·²©ÓéÀÖ process effectively.It's a complicated process with a lot of interactions, including a NEPA [National Environmental Policy Act] component. We understand how to get Å·²©ÓéÀÖ process done, and that’s incredibly important to keep Å·²©ÓéÀÖ momentum going. Once you get through Å·²©ÓéÀÖ plan, you receive considerable predictability because you’ve invested in Å·²©ÓéÀÖ planning up-front. For companies that want to be risk-averse, Å·²©ÓéÀÖse are wonderful insurance policies to make sure you’re in compliance for decades.
Additionally, it’s important for organizations to understand that Å·²©ÓéÀÖre is funding available on an annual basis to fund HCP development—up to $1 million per funding cycle—and working with a trusted partner can put Å·²©ÓéÀÖse grants to practical use.
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