• U.S. Fish and Wildlife Service Seeks Public Comment on Proposed Strategic Climate Change Plan
  • December 4, 2009 | Author: Robert J. Uram
  • Law Firm: Sheppard, Mullin, Richter & Hampton LLP - San Francisco Office
  • The United States Fish and Wildlife Service (the "Service") is accepting public comments through November 23, 2009, on its proposed Strategic Plan for Climate Change ("Strategic Plan") and accompanying 5-Year Action Plan ("Action Plan"). Both Plans are part of the Department of the Interior's (the "Department's") commitment to organizing a Department-wide effort to protect the country's water, land, fish and wildlife against the effects of global warming. The Service developed the Plans to provide the basic framework for and specific details of its overall strategy for working with others to "ensure the sustainability of fish, wildlife and habitats in the face of climate change." The Strategic Plan lays out the Service's general climate change goals whereas the Action Plan identifies specific actions the Service will take to accomplish those goals.
     
    The Service recognizes that addressing global warming is a challenge of extraordinary proportions but sees it as an opportunity to "galvanize" the conservation community. The cornerstone of the Strategic Plan is collaboration. The Service understands that collaboration is imperative to success and accepts a leadership role in organizing an "unprecedented cooperation and partnership" among public, private and government entities to formulate a collective response to climate change. This partnership will be lead by a National Climate Team and several Regional Climate Teams (the "Teams") that will operate under the guidance of the Agency through its Climate Change Working Group and, ultimately, the Department's Climate Change Response Council. Once formed, the Teams will undertake the challenge of addressing the effects of climate change on fish, wildlife and their habitats using three overall strategies of Adaptation, Mitigation and Engagement.

    The Service's adaptation strategy - planned management actions to help reduce the impacts of climate change - forms the "core" of the Strategic Plan. Over the next five years, the Service will form Regional Climate Change Partnerships that will work to develop a National Fish and Wildlife Adaptation Strategy that focuses on species and habitats that are most vulnerable to climate change. The Adaptation Strategy will utilize both reactive (maintaining current conditions) and anticipatory (managing toward future conditions) responses to climate change. Reactive responses may be utilized in the short-term to build resilience in ecosystems and "buy time" whereas anticipatory responses are long-term solutions to biological planning and conservation design and will be used as certainty about future conditions grows.

    The second strategy employed by the Service is mitigation. Mitigation will be effectuated through the reduction of the Service's own carbon footprint with the goal of achieving carbon neutrality by the Year 2020. Carbon neutrality will be effectuated by changing business practices and employing carbon sequestration and carbon credits to offset the balance. The Service sees its mitigation efforts as a model to influence organizational behaviors as well as local, regional, national and international land use and energy policies and actions.

    The final strategy found in the Plan is engagement. The Service will reach out - both internally and externally - to join forces in seeking solutions to climate change and its effects on fish and wildlife. The Service will start internally - informing, educating and training its staff on climate change issues - before reaching out to share information with external audiences. The Service will also forge climate change alliances with the goal of exchanging information and influencing global climate change policy.

    The Service is seeking "substantive comments, factual information and other constructive criticism" which will help improve the Plans. The Service is particularly interested in feedback on its overall approach to climate change (i.e., the three strategies of adaptation, mitigation and engagement) and the partnership tactic and leadership role the Service envisions in organizing the approach. Comments suggesting improvements to the Plans, pointing to possible inaccuracies or any other related issues are also encouraged.

    While the proposed Strategic and Action Plans are stated in general terms, adoption of the Plans could eventually have on the ground impacts for landowners, farmers, ranchers and others whose land management practices could be changed to address climate change concerns.

    To see the full Strategic and Action Plans, please visit http://www.fws.gov/home/climatechange/strategic&under;plan.html. Commenters may use the Service's online response form (http://www.fws.gov/home/climatechange/onlineresponseCC.cfm) or, may mail comments to: Kurt A. Johnson, National Climate Change Scientist, Office of the Science Advisor, U.S. Fish and Wildlife Service, 4401 N. Fairfax Drive, Room 700d, Arlington, VA 22203. Comments must be received by Monday, November 23, 2009.