My research confirms the old adage that one should not put all one's eggs in one basket. Most endangered species have become endangered because we have forced them into a few "baskets"--a limited amount of space where they are now especially vulnerable to change, both natural and human-caused.
The first advantage of HCPs is their potential to minimize risk by protecting a species in more than a few places. Spreading a species' risk of extinction across many places will often be a better bet than intensive scientific study and visionary management in just one place. Most of us manage our financial investments by spreading risk in much the same way.
The second advantage is that at least 60% of endangered species need active habitat management to survive. Without control of alien weeds or without period, controlled fires some species will succumb if all we do is to put a fence around them. The HCP process can encourage appropriate habitat management and do so over increasingly large areas.
The experience to date on HCPs has been that some have been better than others--how could it be otherwise? The analysis of HCPs undertaken by the National Center for Ecological Analysis must surely be viewed in this light. The report's most serious criticism argues that many HCPs may be based on "the best available scientific data" but that those data may not be sufficient. To me, the report's most important omission is that it does not fully address this trade-off between having many good plans versus a few superb (and omniscient) ones. Limited resources will always mean that one cannot have many, perfect plans.
Of course, the NCEAS report raises the possibility that we may have many plans, but poor ones. While I may manage my investments by spreading risks across many stocks that does not mean I would accept a preponderance of poor ones. The report notices numerous deficiencies that need to be addressed by future plans. Its greatest strength is its unified assessment of the plans. Its most important recommendation is that there should be a central repository of plans to provide models and comparisons for those who will produce plans in the future.
Criticisms of inadequate data need to be viewed in the context of what is practical. I have no personal experience of HCPs, but I have extensive experience of the Section 7 Consultations between the Fish and Wildlife Service and other Federal agencies. I believe the parallels to be useful. Many of those consultations are informal, friendly, and the issues are quickly resolved.
I suspect that many HCPs may be relatively uncontroversial. One size does not fit all, however. Some Section 7 consultations are difficult, contentious, are require major investments of resources. Surely, some HCPs will be likewise.
It was to address different degrees of ecological uncertainty that Dr. Gary Meffe of the University of Florida and I wrote to you in January of last year. Our letter was co-signed by more than a dozen scientists all with extensive experience of conservation issues. We offered the following recommendations:
First, the scientific rigor underlying the plan should influence the relative length of accompanying assurances. Plans that rest upon a substantial scientific foundation, about which there is little serious disagreement as to their sufficiency or adequacy, should properly receive longer-term assurances than those that rest upon a more marginal scientific foundation and for which there is substantial disagreement regarding their sufficiency or accuracy.
For long-term assurances to accompany plans that encompass all or a very large portion of the range of a covered species, the rigor of the underlying science is especially important.
Second, any "no surprises" policy ought to be crafted in such a way as to encourage identification in the plan of possible future contingencies and a means of adapting management in response to them. One way to do so is to link the duration of assurances provided to the extent to which a plan identifies and allocates responsibility for future contingencies. Other things being equal, those plans that specifically address a variety of potential future contingencies and clearly identify how they will be handled warrant a longer term of assurances than plans that make little or no effort to do so.
Third, the potential conservation benefit of a plan ought to influence the extent and duration of the assurances provided.
Thank you for your attention.