SCB Calls for Full Valuation of Ecosystem Services
in Northern Spotted Owl Critical Habitat
On July 5th, the North America Section of SCB submitted formal COMMENTS on the economic analysis of the benefits and impacts of the revised critical habitat proposal for the Northern Spotted Owl (Strix occidentalis caurina). Despite the rapid advances in ecological economics to quantify environmental benefits and values, the U.S. Fish and Wildlife Service (FWS) has yet to develop methodologies for even general approximations of environmental benefits, commonly known as ecosystem services, when it makes decisions directly affecting the biodiversity such as the designation of critical habitat. By failing to even attempt to quantify ecosystem services, the FWS is not employing the best available economic science regarding the benefits that endangered species and their critical habitat provide. By failing to apply the best available economic science, FWS undervalues the economic benefits of critical habitat and overestimates the economic costs of designating such habitat, resulting in decisions that ultimately may lead to long-term harm to endangered species, the environment, and society. SCB’s comments address the shortcomings of the FWS’s draft economic analysis for the revised critical habitat proposal for the Northern Spotted Owl (NSO), and provide a road map for how FWS can improve future economic analyses on decisions relating to the protection of biological diversity.
Section 4(b)(2) of the ESA gives the FWS the discretion to exclude habitat from a final critical habitat designation if it determines that the benefits of exclusion outweigh the benefits of specifying an area as critical habitat. In the draft proposal, the FWS has identified nearly 14 million acres of potential critical habitat for the NSO. However, FWS is considering excluding some areas “impose the least burden on society, and on maintaining flexibility and freedom of choice for the public.” SCB believes that there are no economic data to support the underlying assumptions of this statement, and that a full assessment of the ecosystem services that the forest habitats of the NSO provide would clearly demonstrate the overwhelming benefits that inclusion within the critical habitat would entail over the relatively minimal benefits, if any, of excluding that critical habitat. Accordingly, SCB recommends that the FWS not exclude any acreage from the final critical habitat designation for the NSO based on its authority under Section 4(b)(2).
SCB’s comment letter on the FWS economic analysis can be found HERE.
The FWS’s proposed revision to the Northern Spotted Owl’s critical habitat is a particularly complex rulemaking. SCB is concurrently filing additional COMMENTS regarding other policy concerns relating to the revised critical habitat proposal, including (1) a proposal to utilize “active forestry” techniques to manage spotted owl critical habitat, and (2) a proposal regarding the size and scale of possible forestry activities that will trigger “adverse modification” of spotted owl critical habitat.