An interview with Principal for Habitat Conservation Paola Bernazzani
Bat populations are on the decline in the 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 the face of this rapid downturn, species like the Northern long-eared bat face an unpredictable future. In response, the U.S. Fish and Wildlife Service recently announced a proposal to reclassify the Northern long-eared bat from threatened to endangered under the Endangered Species Act (ESA). This “uplisting” will have numerous impacts on agencies and organizations implementing habitat conservation plans (HCPs) throughout the United States.
As organizations invest in Environmental, Social, and Governance initiatives, the 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 the curve and place themselves in the best position for the 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 the rapid decline of bat species—and their anticipated ESA uplisting—means for agencies across the U.S.
Q: What is the impact of the plummeting population of some species of bats?
An overarching impact is the 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 the 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 the ecology of a system—we don't really understand all of the ways that bats might be contributing to forest ecology, for example. They eat an enormous amount of insects, so their 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?
For companies and state agencies that want to demonstrate that they’re good stewards for the environment, it will be important that they plan for this change.
The closer a species gets to extinction, the tougher the regulations are going to be in terms of what can and can’t be done, and whether 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, the Northern 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 the regulated community, whether it’s foresters or people who are working for utilities, developers, wind, or energy—all of these sectors had certain exemptions in place that allowed them to continue with their projects at least at some level with this regulatory carve-out. When that goes away, it’s very hard to predict the regulatory landscape. This is a very widely distributed bat—we know it’s in many forested areas throughout the East and Midwest, so the species’ uplisting is going to change who gets regulated, and their compliance requirements are going to change dramatically.
Q. With this in mind, what should agencies consider when creating an HCP?
At ICF, my group specializes in ESA compliance and that often means drafting an HCP. HCPs are comprehensive documents that include analyses of the level of impact and recommendations for effective mitigation; these components provide the foundation for dialogue with the 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 the species.
For all the bat HCPs I’ve worked on, we focus on what the impacts are to species—how we can avoid and minimize those impacts. Then, for the part of the impact that’s not addressed through avoidance and minimization, we focus on how we can offset that impact—whether it’s through enhancing hibernacula, putting extra protections around roost trees, creating safe havens for bats during the maternity season, creating habitats that are beneficial for bats through snag creation…all of these types of things we hope will help stabilize and increase the bat population in the long run.
Q. Why should an agency, organization, or developer work with a partner to develop such plans?
I’ve spent the 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 the Fish and Wildlife Service, and to help our clients understand their obligations. We know how to do the analytics, write the chapters, and move through the 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 the process done, and that’s incredibly important to keep the momentum going. Once you get through the plan, you receive considerable predictability because you’ve invested in the planning up-front. For companies that want to be risk-averse, these are wonderful insurance policies to make sure you’re in compliance for decades.
Additionally, it’s important for organizations to understand that there 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 these grants to practical use.
Learn more about how your organization can prepare for the uplisting of the Northern long-eared bat.