BLM

Public Testimony: Pathogen Response Process

What happens when a member of the public raises a concern about ecological pathogens to conservation lands managers during a public testimony process? This is a story that unfolded not long ago on the North Coast of Santa Cruz County concerning BLM’s management planning for Cotoni Coast Dairies.

Recall Last Week’s Column

If you haven’t already read my column from last week, it would be best to give it a quick read to put this essay into context. In brief, I outlined the devastation caused by reckless human movement of invasive, non-native pathogens affecting native plants and wildlife. The process introducing and spreading such pathogens is ongoing, despite the dangers being common knowledge. At the end of the essay, I pointed to the root cause of this issue, human greed, and outlined the common knowledge about the solution: slowing global trade enough so that we can take the time to be more careful. What I didn’t outline is what we can do more locally to address already introduced pathogens that have yet to spread across our conservation lands.

Conservation Lands Managers’ Pathogen Abatement Responsibilities

What responsibilities do conservation lands managers have for the wildlife and plants that occur on the lands they oversee? I’m betting you can guess one of those managers’ responsibilities…but not to wildlife and plants. Public access is often a conservation lands manager’s ‘responsibility.’ Consider the term ‘conservation lands’ for a moment and know that public access comes at a cost to conservation. So, part of those managers’ responsibilities is mitigating and avoiding the impacts of public visitors on wildlife and plants. And, those public visitors bring with them a variety of pathogens that can have grave negative impacts. While planning for public access at Cotoni Coast Dairies, unknown BLM staff wrote many statements acknowledging the danger of proposed recreational use and the spread of pathogens.

BLM Staff List Public Access Pathogen Dangers

Unknown BLM staff wrote extensively in the management plan for Cotoni Coast Dairies about the dangers of recreational use increasing plant and wildlife pathogens. They noted that recreational users “increase introduction of pathogens” (Chapter 4, pp. 5 and 11), which “pose risks to sensitive species,” impact native wildlife, and are “anticipated to impact aquatic species including special status fish species” (Chapter 3, p. 22; Chapter 4, pp. 18, and 32). BLM staff also addressed introduced plant pathogens using sudden oak death as an example. They noted that recreational trail use has been documented as being a significant source of the spread of plant pathogens (Chapter 4, p. 6). In addition, BLM staff also specifically addressed the spread of pathogens to wildlife from domesticated animals, warning that bobcats, grey foxes, dusky footed woodrat, and badgers are all known from Cotoni Coast Dairies and could all be negatively impacted by such diseases (Chapter 4, p. 19). The BLM staff went on to note that domestic dogs carry ‘hundreds’ of pathogens that can be spread to wildlife, including rabies, canine distemper, and canine parvovirus (Chapter 4. p. 21). Finally, the anonymous BLM staff also noted the dangers of introduced amphibian pathogens, including chytrid that is a major concern for California red-legged frog conservation (Chapter 4, p. 30), noting that recreational users spread such diseases (Chapter 4, pp. 35 and 36).

In sum, the BLM staff who wrote the governing management plan for Cotoni Coast Dairies articulated many of the concerns about introduced pathogens affecting the biota of that high-value conservation property. But, how did that knowledge affect their management? Very, very little.

BLM’s Management Response to Environmental Pathogens

After that litany of concerns, one might expect BLM staff to write appropriate management responses. Here are the two responses:

In response to the danger of domestic animals spreading pathogens to wildlife, they state:

“Therefore, BLM will not authorize or condone free-ranging dogs, or any other free-ranging domesticated animals or pets to utilize C-CD. (Chapter 4, p. 21)”

In response to the danger of recreationists spreading pathogens into the freshwater systems, they state:

“Therefore, BLM will seek to educate members of the public on this topic whenever possible. Appropriate signage may aid in reducing the potential for this to happen at C-CD. (Chapter 4, p. 36)

Note that the BLM staff avoided producing management measures that address the majority of the impacts of pathogens spread through the recreational activities they propose. This is particularly troubling because the foundational principle governing management of Cotoni Coast Dairies is not providing recreation, it is conserving the ecology of the property. Instead of outlining management to avoid or mitigate the spread of the pathogens, BLM staff favor recreational uses that they document increasing pathogen risk.

Pride, Prejudice, Ignorance, Overwork, or Institutional Policy?

Given the perplexing approach to increasing the danger of recreationists spreading pathogens that endanger the plants and wildlife of Cotoni Coast Dairies, it is reasonable to ask: WHY? The answer to that question seems to be ‘we will never know.’ Let’s examine some of the potential explanations.

On my documentation of planning shortcomings, one BLM staff person passionately and confidently proclaimed that their team had completely and professionally addressed all comments raised during the public comment period on the management plan. It could be that they were proud of their work and it could be that they were proud of the work of the other staff in their agency. And, given the clear shortcomings of the responses to my concerns about pathogen spread, it also appears that they might be prejudiced about the professionality of their agency. It might be that they are ignorant of the many solutions and mitigations available to stem the spread of pathogens on conservation lands. Another possibility is that staff are so overburdened with a multitude of responsibilities that they are unable to adequately address their planning responsibilities. Or, it might be institutional policy to avoid committing to certain types of management measures, whether due to cost, ease, or interference with recreation or other management preferences of prejudiced staff within the institution.

But, again, we will likely never know the reasons for these oversights. It is likely that BLM staff writing such plans will remain anonymous, so we won’t be able to ask individuals. When I’ve asked staff to refer me to the individuals responsible for decisions so that I could ask them about their rationale, they’ve refused. When BLM suggests that they ‘welcome public input,’ or are ‘seeking public input,’ such as with their latest proposal for a parking lot at Cotoni Coast Dairies, you have to wonder if your time is being well spent providing that input, given the hypotheses presented here. All we can do meanwhile is investigate and hypothesize: is it pride, prejudice, ignorance, overwork, or institutional policy that will lead to recreationists spreading the pathogens  that will kill the wildlife and plants at Cotoni Coast Dairies?

– this essay slightly modified from that which was presented by the esteemed Bruce Bratton at his laudable BrattonOnline.com weekly blog.

An Extra-Special Gift this Holiday Season

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-this post originally appeared in my regular column for Bruce Bratton’s BrattonOnline.com – why not subscribe and never miss another!


[1] Or opt for our minor injury packages with requisite waivers and insurance, still a bargain! This is a popular option for those who regularly injure themselves at the sport and so might otherwise feel something missing. Injuries created by padded devices in controlled settings still carry risk.

Good Roach Stewards: Shifting Baselines

“Shifting baselines” is a term used to illustrate how humans acculturate to reduced wildlife, thinking that what they experience is normal and good. “Good enough” is perhaps a better term. Too many people measure success by saying ‘good enough!’ With species diversity in general and wildlife population health specifically, ‘good enough’ for some people is probably not what most people deserve and ‘shifting baselines’ is the problem at hand for large areas of Santa Cruz County.

Current Baseline: Shift Happened

Fifteen thousand years ago, a combination of poor human stewardship and climate change created a mass extinction event in California. Dire wolf, mastodon, mammoth, lion and other big cats, camel and horse relatives, the California turkey, a flightless duck in the lagoon at Laguna Creek, ground sloth, short-faced bear, and a host of other critters disappeared in a very short period of time. We don’t miss those species – they aren’t part of our cultural memory. But, we do seem to reminisce about beaver, gray wolf, tule elk, the California grizzly, badger and pronghorn…species that disappeared from the Central Coast more recently. Well, I’m not sure how many people really think about those species and ‘miss’ them. I do. The miracle recovery of some whale species seems to excite people, but those same people generally don’t consider the vastly reduced numbers of those species. In sum, our current wildlife situation is what is known as ‘depauperate’ – much reduced from historical numbers. And yet, most people think that what occurs today is ‘normal’ and they don’t much think about the opportunities to recover wildlife to more healthy populations on at least public lands in the Central Coast. Our experience of our “biological baseline” is greatly different than humans 15,000 years ago.

What will future generations of humans come to think of as normal? Will they one day realize that California is down to three species of wildlife, all cockroaches, and form some sort of cultural pride to recover the last remaining wild species? This is the trajectory we are moving towards because no one seems to care about the situation with the Central Coast’s wildlife, right now. If they did, local parks managers would hear about it and politicians would hold them accountable.

Parks Manager Responsibility

Whether we are thinking about State Parks or land managed by the Bureau of Land Management (BLM), the officials in charge of more than 20% of Santa Cruz County have a responsibility to monitor the impact of their management choices and to maintain wildlife populations for future generations. Specifically, all State Parks are required to have a General Plan and, in those plans, to outline how they will manage responsibly to maintain healthy wildlife populations. Similarly, the BLM is required to manage Cotoni Coast Dairies first and foremost for conservation, which requires wildlife surveys be conducted that can inform the agency’s management of livestock, ecosystems, and recreation.

Cotoni Coast Dairies: A Singularly Special Opportunity

What makes BLM’s management of Cotoni Coast Dairies a grandly special opportunity is that the property has not yet been opened to the public, so BLM can collect wildlife data before recreational activities begin to impact species. The wildlife of all other parks has already been negatively impacted by recreational use and so we can’t as easily understand how to improve the management of recreation in those places. Perhaps trail use on the trails BLM has already built will have no impact on wildlife – that would be extremely unusual! Chances are good that recreational use will negatively affect wildlife even hundreds of feet away from the trails. We won’t know how significant those effects will be unless data are collected before recreational use of the trails. And, we won’t learn which species are impacted by what numbers, timing and types of recreational use: those things would be very relevant to BLM and other regional parks managers in order to accomplish their mandates.

Illustration compliments of Steven DeCinzo

On the Other Hand: ‘Good Enough!’

Here’s some of the things I’ve heard about biological baselines to inform land management in Santa Cruz County. Mostly, land managers say that they have enough information to make good decisions. This is important for them to say because they are required to use the best available science. If they say that they don’t have sufficient science, they are admitting fault and might be held liable, so they can’t say anything but that they have enough science already.

When pressed, they say something akin to “Just look! Habitat!” You dare not suggest species are a better measure of management success because they have a world of arguments against that approach. Their argument goes…if you have a grassland, you have done all you can to protect grassland species…a redwood forest! Violà! Redwood forest species all taken care of! If the species aren’t there, they say something like “well, that’s beyond our control” or “they’ll show up some day.” In short…some vague habitat description and a map of the presence of said habitat is ‘good enough.’ The fact is that species are much more sensitive to management of those habitats than manager’s broad brush would suggest. The problem is…any more refined monitoring might be either expensive and/or could hold managers accountable.

Accountability

What if you had rare wildlife species on the land you managed, what would you do? Might you consult with the agency that is responsible for recovering those species? The California Department of Fish and Wildlife has good wildlife biologists, and they have survey protocols that are useful in documenting a species’ presence/abundance. Same with the US Fish and Wildlife Service and the National Marine Fisheries Service.

Would you want to make the public aware of the conservation work you are performing, and how successful it has been? Would you be worried about negative publicity?

Do you think lands managers feel accountable about more than their conservation mandates? Do you think that they feel accountable to certain recreational user groups? How would you know which type of accountability they feel more concerned about?

Your Role

I hope that you have joined a pro-wildlife advocacy group. Working together, we can make sure that the wildlife our children’s children experience is more diverse, and more plentiful, than what we experience now. The alternative is bleak: children fascinated by the last species, raising cockroaches in cages and hoping that their offspring might live in the impoverished ecology resulting from a world of shifting baselines. I don’t think that is good enough.

– this article published in Bruce Bratton’s fabulous weekly blog BrattonOnline.com Sign up at that site to get the alert that it is out and then enjoy some quality time reflecting on news that matters…as well as excellent film/media reviews.

BLM Overlooking Precious Wildlife Conservation

Santa Cruz County’s newest conservation land managers are supposed to conserve the wildlife prioritized by the State of California, but are failing to acknowledge their obligations, which means some of our area’s iconic wildlife species will disappear faster due to lack of Federal cooperation at Cotoni Coast Dairies.

Background

The Bureau of Land Management oversees management of Cotoni Coast Dairies, but it is following much-outdated wildlife conservation guidance. Land management agencies like the BLM are guided by policies and procedures that guarantee that they do a good job of managing wildlife. For instance, BLM has its 6840 Manual “Sensitive Species Management,” which notes:

“The objectives of the BLM special status species policy are:

A. To conserve and/or recover ESA-listed species and the ecosystems on which they depend so that ESA protections are no longer needed for these species.

B. To initiate proactive conservation measures that reduce or eliminate threats to Bureau sensitive species to minimize the likelihood of and need for listing of these species under the ESA.”

In other words, BLM recognizes that the agency should not be contributing to wildlife species becoming rarer and so receiving more regulatory protection, which would impact private landowners by restricting the uses of their property.

Mouritsen’s Duty, Neglected

To avoid that, BLM California’s State Director Karen Mouritsen is required to, “at least once every 5 years,” review and update the BLM-maintained list of sensitive species in coordination with the California Department of Fish and Wildlife (CDFW). It is unusual for such policy guidance to lay out a specific timeline, which adds clarity to expectations. The last time California BLM’s sensitive wildlife list was updated was in 2010, before Director Mouritsen’s tenure: 13 years ago! A lot has changed in those intervening years, and scientists have recognized that many more wildlife species are in need of protection by BLM.

Repercussions at Cotoni Coast Dairies

What happens when BLM’s sensitive wildlife species list isn’t updated? Let’s look at the Cotoni Coast Dairies example. BLM has already completed a Resource Management Plan that is meant to guide wildlife conservation on the property. Under the guidance and environmental review provided by the RMP, the agency is building miles of trails and parking lots, implementing a cattle grazing program, and allocating funding to other prioritized activities. BLM will soon embark on a Science Plan for the property. The RMP didn’t and the Science Plan will not consider conservation of wildlife species that do not appear on the BLM’s sensitive species list. And so, the following 10 rare wildlife species will receive no attention, pushing them further towards extinction: ferruginous hawk, grasshopper sparrow, Northern harrier, olive-sided flycatcher, American badger, San Francisco dusky-footed woodrat, Western pond turtle, California red-legged frog, American peregrine falcon, and short-eared owl.

A Deeper Dive – Grasshopper Sparrow

Let’s consider one of those species with a little more detail, the grasshopper sparrow. If this species is nesting in an area, under California law they are protected and our state wildlife agency, CDFW, has been charged with their conservation. According to BLM guidance, Director Mouritsen is 13 years overdue in updating the agency’s sensitive wildlife list for California to include this species. As their name suggests, grasshopper sparrows are grassland-dependent organisms. There is an abundance of nesting grasshopper sparrows at Cotoni Coast Dairies.

Without active management such as with carefully planned livestock grazing or fire, all of the grasslands at Cotoni Coast Dairies will disappear, being invaded first by brush and then by trees. This is already happening with extensive French broom and coyote brush invasion.

Already, BLM has planned its livestock grazing and recreational trail uses without consideration of preferred habitat for nesting grasshopper sparrows. Livestock grazing could be taking place to the detriment of the species, already. The construction of recreational trails and parking lots may have already destroyed important nesting habitat. When recreational visitors start using those facilities, it may occur before BLM has a baseline study of the density and location of nesting grasshopper sparrows. So, the agency will be unable to understand how land uses are impacting the species and so will be unable in an informed way to adjust its recreational or livestock management to better conserve the species.

It may well be that BLM’s management of Cotoni Coast Dairies will further reduce nesting populations of grasshopper sparrow, pushing the species closer to the point where they will need to be listed as threatened or endangered. When that occurs, private landowners whose land supports nesting grasshopper sparrows will see increased regulation and oversight by the State and/or Federal government. Their property values will be reduced and their ability to develop homes, farms, or other uses will be diminished.

An Alternative

On the other hand, if the California BLM State Director Mouritsen were to meet her regulatory obligation and update the BLM State Sensitive Wildlife Species List in the near future, a bunch of good would result. First, Cotoni Coast Dairies’ Science Plan could provide guidance for conserving those species. Second, because BLM funding is tied to the number of sensitive species on each property, Cotoni Coast Dairies would be better situated for increased conservation funding. If the Science Plan succeeded in moving forward the conservation of sensitive species like the grasshopper sparrow, BLM’s leadership on these issues could help many other land managers do the right thing for species, contributing to the potentiality of ‘delisting’ species, reducing the potential for increased regulatory burden and loss of private property values.

Do Your Part

I’ve said it before in this column, but I’ll say it again. NOW is the time to write Director Mouritsen to urge her to do her job. She hasn’t replied to any of the numerous letters she’s already received, so evidently she needs more pressure to take this seriously. Here’s some language to send to her via her email kmourits@blm.gov Please let me know (or cc me) if you send something.

Dear Director Mouritsen,

I care about wildlife and plant conservation on BLM’s Cotoni Coast Dairies property in Santa Cruz County. I write to urge you to help by adding sensitive species found on that property to the State BLM’s sensitive species lists. Only if those species are on the State’s lists will local administrators consider impacts of their management on those species in their analyses and planning for the property. So, I ask that you please:

  • Publish an updated State BLM sensitive wildlife list in collaboration with the California Department of Fish and Wildlife, as mandated by the BLM’s 6840 Special Status Species Manual.
    • This list was last updated in 2010, but you are required to update it at least every 5 years.
  • Publish an updated State BLM sensitive plant list to include the State ranked 1B plant species documented at Cotoni Coast Dairies, as mandated by the 6840 Manual.

I would appreciate a reply to this email with details about how you intend to address these issues.

Signed, xx (you!)

-this post originally appeared as part of Bruce Bratton’s amazing weekly blog at BrattonOnline.com You an sign up and receive it automatic-like if you visit this site. You will be rewarded by getting smart commentary and news that is very relevant to life in general and life on the Monterey Bay specifically.

Humanity

Compassion for others in a political setting is a challenge that, as citizens, we must all ponder. As citizens in a democracy, we are active participants in the global experiment on Nature and how future generations will fare based on our individual decisions in the moment. We purchase things, we vote, and we make thousands of choices that each has an impact on other species. Each of us has our way and our reasons. A compassionate approach to others may open the many stuck doors to create a more lasting environmental conservation movement. And, we must ponder how institutions and individuals interact to enact that compassion.

The Government

Our style of democratic government reflects the will of the Nation’s people, over time. We vote directly for one of the three branches of government – the Legislative branch – and the House directly reflects representation of the majority of the population. The Senate changes the ‘majority rules’ notion to evenness of geographic representation, no matter the population, giving small numbers in sparsely populated geographies more power. Election of the Executive branch has a system of election using delegates, which also reflects an intention to create more even geographic distribution of power, but also has aspects that embed extra-democratic power relationships including freedom of delegate choice into the equation. Judicial branch members are appointed by that Executive branch and seated when confirmed by the Senate and so also reflect the problems associated with the elections of those two portions of the government.

In short, we have a system of government designed to amalgamate the geographies, popular opinions, and existing power relations in order to make choices that we are meant to respect as ‘representative.’ The way this works is particularly challenging to issues that do not raise to prominence for voters. When votes matter, politicians and the power network that supports them sway government actions. Environmental conservation is one of those issues that the power structure never wants to see come to the fore, and citizens are easily swayed in other directions. News media and social media, which are easily manipulated, herd citizens towards issues that are both divisive and convenient for those in power. Environmental conservation threatens all members of those in power, no matter what the political persuasion.

The top issues that sway US citizens’ votes are the ones that the media focus on: the economy (always first), healthcare, and safety – e.g., police (local), military (global). Environmental concerns always rank Way Down the list, despite being the single greatest element to having a sustainable economy, healthy humans, and a safe society.

When considering environmental conservation, it is the will of those in power and the government they manifest that creates the challenges to having compassion on two factions of our society: your fellow citizen, who is in some way responsible for the government, and the employees of government institutions, who act within governmental decision frameworks.

The Citizen

How do we approach compassion, to see the humanity in our fellow citizens when the government does so little for environmental conservation? It is easy to blame governmental actions on the citizens of the country, but is it fair?

It is also easy to understand why your neighbors, friends, and relatives do not prioritize environmental conservation with their actions. We are creatures of habit living in a difficult world. It is difficult to change our behaviors, even if they negatively affect the environment. It is difficult to see our individual choices as mattering and easier to blame the impacts on the environment on other people, other nations, or even evolution, fate, or a Deity. We all do these things. When we listen to the news or tune into social media, the messages there do not help us to understand elements of environmental conservation and what we can do about them. Even the supposed ‘neutral’ (really ‘centrist’) NPR rarely covers much of the breadth of environmental conservation import and then mostly with disempowering messages. Because the US has become so expensive and the pace so breakneck, citizens are afforded almost no leisure time to learn about environmental issues. And, with the decline in broad, critical thinking education, environmental conservation has become a tiny part of anything students are exposed to, favored by Science, Technology, Engineering, and Math (STEM) focus. The term ‘Science’ in STEM doesn’t mean organismal biology nor does it include any conservation elements. Highlighting this STEM education is a real success of the power structure in the US as they hope to create a (somewhat) skilled workforce.

In sum, citizens do not know, and cannot find a way to know, about environmental conservation and without such knowledge they act innocently and ignorantly in ways that collectively negatively impact the environment. Aren’t we all like that? Let’s have a little compassion for everyone and figure out where to go from there.

The Government Worker

Government workers are citizens who have even more burdens on their environmental conservation actions. Those people who work for governmental institutions that are supposed to protect the environment face all the challenges of the average citizen described above. While it is true that the government requires some of those workers to have higher levels of education to qualify for their jobs, the required bachelor’s or master’s degrees never train them for the environmental conservation elements of their jobs. The most relevant field is called ‘conservation biology.’ There are very few institutions of higher education that offer this focus, and the combined top ten programs in the US graduate fewer than 100 undergraduates, and far fewer graduate students, each year. Once out of school, these individuals have a high incentive to work in a lucrative field, environmental consulting where they can earn 5 times more than a government employee. And so, government institution personnel that are responsible for environmental conservation have not received the education they need for their jobs, have not been raised in a culture that supports inquiry, and are strained by economic and social situations that make it difficult to prioritize environmental conservation. And then they go to work in institutions with similar individuals under conditions of extreme political pressure exerted in contravention to environmental conservation.

Governmental Institutions

The government institutions that have responsibility for environmental conservation have never been designed to be effective with that responsibility. Because conservation rarely and briefly rises to the fore for politicians, consistent oversight and policy development is lacking. Instead, environmental conservation frameworks are weak and up to the interpretation of the agency. Locally, State Parks is required to have General Plans for all of their lands, but there is no required timeline for creating them, no mandate to update them (ever), and little guidance on key features of those plans such as what a ‘carrying capacity’ analysis might be. Locally, County and City Parks have no guidance at all about environmental conservation and there is none in the making. Locally, the Bureau of Land Management has guidance documents for environmental conservation, again with no timelines for enacting them and insufficient guidance to maintain the scientific integrity of those efforts.

Workers are Human, Too!

Even if they don’t recognize it and can’t hear it, the too few employees charged with environmental conservation at governmental institutions find themselves without sufficient means and support for substantive, science-based environmental conservation action. And so, they go about their jobs doing what little they can to try to make a difference. Most of them are proud of their accomplishments. Being social humans, they form bonds with their workmates and take their personal pride and form institutional pride. They are proud of the work of State Parks, they are proud of City and County Parks Department accomplishments, and they are proud to be part of the BLM team.

Many of us can relate. Many people find themselves in institutions that have elements of good and elements of bad (which sometimes we don’t want to see!); we choose to focus on the good work we are doing within those institutions. We make friendships at work and want to support those friends. Some of us work for institutions where the public believes that our work is good and just, and so it is easy to become proud of our institution and even to defend our institution when challenged. Let’s have a little compassion for the people we see who have ended up like that and figure out where to go from there so that there is better environmental conservation even by governmental institutions.

This post originally appeared in the important blog published by Bruce Bratton at BrattonOnline.com Subscribe Today!

BLM Cotoni Coast Dairies Biological Monitoring Plan and Updated Plan

This first one updated December 2021

This next one updated in October 2022