Classification and funding of stewardship projects/activities57
Funding continues to be the weakest part of INRMP implementation and appears to be the major impediment to effective INRMP implementation. In spite of this, many installation natural resources managers are succeeding in implementing the INRMPs. Typically, it is a patchwork of projects that are undertaken. Compliance related projects, which for natural resources are almost always driven by the Endangered Species Act (ESA) (also the Clean Water Act or other regulations), are programmed as such, approved, and funded. In her analysis of INRMP implementation across the military services, Gibb (2005) concluded that these ESA driven projects and activities do reach the intended programs and are used for the intended purposes. This, however, is not the case with noncompliance-related projects, and the situation can vary markedly among installations. Services’ budget systems, such as the Army’s Environmental Program Requirements Module (EPRM), were designed for engineering projects with known start and end points, and they are tied to compliance with federal and state laws. Although the Sikes Act Improvement Act of 1997 requires INRMPs to be implemented, many projects are continuous or opportunistic “stewardship” in nature and are not easy to define under the strict legal compliance drivers that are applied to the military services’ environmental budgeting process.
Despite the need for flexibility and fluidity for natural resources projects, including the need to support a variety of stewardship projects that are not tied to compliance, EPRM and other systems are tied to compliance with laws, resulting in many valid INRMP projects being screened out of the budget process. The programming and funding of INRMP projects can hit obstacles throughout the programming process. Projects may initially be appropriately classified for budgeting purposes, but as they pass through the review steps, some may be reclassified to a lower level or dropped from the process entirely. The DoD guidance for classifying projects is not consistently adhered to and, in many cases, only projects that have a legal driver or involve human safety issues are being considered as “must fund.”
A related issue is that although detailed information and justification are required on the front end of the budget requests, once budgets are funded, there is no equivalent tracking of awarded funds back to approved projects. In many cases, Gibb (2005) found that projects were budgeted, approved, and funded, but the funds were either not received or not applied to the projects for which they were intended. As a result, the same projects had to be resubmitted in subsequent budget requests. This “misuse” of the budgeting process may have since been addressed to some degree by the military services. Various measures of merit used by the military services also attempt to get at funding problems by requiring annual reporting of INRMP implementation. Gibb (2005) felt it was unclear whether measures of merit being applied reflect an accurate picture of INRMP implementation because of how projects are classified for budgeting purposes. Although INRMP implementation is required by the SAIA, many do not consider it to be a legal driver for individual INRMP projects.
The strict classifying of projects based on legal drivers that has occurred in the military services has the effect of budgets showing only class 0 or class 1 projects, and these will likely be more critical from a compliance or legal standpoint. The bias towards class 0 and class 1 projects in the budget process has the effect of reducing or eliminating the overall number of unfunded projects that will show in the annual reporting for INRMP implementation. Most influence seems to be at the installation level. Because class 2 and 3 projects fail to be funded and are frequently no longer included in budgeting, they may no longer be included in INRMPs and may be eliminated as installations prepare the INRMP updates. Gibb (2005) found several installations where the only projects included in the current INRMP were “must funds” (i.e., class 0 or 1).
Pooling funds among federal agencies
The following recommendation regarding DoD’s conservation strategy is from Li and Male (2020): “DoD needs more tools that allow pooling of funds across federal agencies to effectively manage natural resources on a landscape scale, because DoD will rarely have the resources to fund this work on its own. What do we mean by pooling? It is the ability to obligate funds from multiple agencies or U.S. Treasury accounts through single funding mechanisms (e.g., contracts, cooperative agreements, interagency agreements) without having to track and account separately for each agency’s allocation.
The White House Council on Environmental Quality or the Congressionally chartered National Fish and Wildlife Foundation already have limited authorities that could help pool funds. The Sentinel Landscapes Partnership and other initiatives have made inroads within current policy and fiscal constraints toward this end.” Li and Mali argue that DoD needs much more ambitious use of those authorities or new legislative authority to establish more expansive pooling authority for DoD.
Building staff capacity in partnership with state and Federal agencies
While there are many examples of successful involvement and engagement by state and federal agencies in planning and implementation of activities that favor biodiversity conservation, more funding/capacity is needed to enable federal and state natural resources and wildlife agencies to engage more effectively in plan development (Gibb 2005, Li and Male 2020, Benton et al. 2008).
Consistency and compliance with policies and legislation are key elements of INRMPs, so effective engagement and involvement during key points such as ESA consultation, INRMP revision and partnership development is paramount. Improvements to the planning process are likely without additional capacity at FWS to fully participate in conservation planning through INRMPS and other instruments (Li and Male 2020). Gibb (2005) noted that in some instances, “[Fish and Wildlife Service] staff is clearly overextended and unable to meet many of its responsibilities”.
Fifteen years later, similar observations and concerns were voiced by Li and Male (2020): “Some FWS offices appear to engage minimally or not at all in plan revisions due to inadequate staff capacity.” Limited state agency engagement results in missed opportunities to implement regional partnering and other projects that might mutually benefit state Wildlife Action Plans and INRMP goals. A lack of interaction with state natural resources agencies is sometimes due to staff shortages at state agencies rather than a lack of need for ongoing state involvement (Gibb 2005).
Solutions to the above issues may involve a combination of two related elements: supplementing staffing in agency offices using DoD funds, and establishing and regularly maintaining relationships with these agencies. With respect to FWS consultations and coordination needs, although DoD has funded service and DoD level FWS liaison positions, supplemental effort at local and regional FWS offices is still needed. There are examples of DoD funding local FWS staff to support the demands of installations with monumental consultation needs (e.g., Camp Pendleton) (Gibb 2005). Support for these types of positions is especially helpful, as staff turnover at FWS can make for inefficient and extended consultations.
57 Adapted from Gibb (2005), Best Practices for INRMP Implementation.
Next Page: Literature Cited
Author
David S. Jones, RA IV, Ecologist/Project Manager
Center for Environmental Management of Military Lands
Warner College of Natural Resources
Colorado State University