Figure 1. Twenty-four pages of mostly greenwashing. Source: The Biden Administration.
While running for the job, now-president Biden pledged support for “30x30.” He followed up on his campaign pledge with an executive order on January 27, 2021, that committed his administration “to achieve the goal of conserving at least 30 percent of our lands and waters by 2030.” In 2020, his now-secretary of the interior had introduced a resolution into the US House of Representatives expressing the sense of the House that the federal government “should establish a national goal of conserving at least 30 percent of the land and ocean of the United States by 2030.”
It sounded great, especially since—at the time and in the intent of the resolution—30 percent by 2030 (30x30) meant that 18 percent more of the nation’s lands and waters above the 12 percent already “conserved” would need to be protected. In the context of 30x30, 30 percent “conserved” unequivocally means that by 2030, 30 percent of the nation’s lands and waters will have qualified for either GAP 1 or GAP 2 status in the US Geological Survey’s Protected Area Database (meaning that they have permanent protection and mandated management plans that do not allow extractive uses). That commitment is a big lift. 30x30 means that 1.3 times as much acreage must achieve GAP 1 or GAP 2 status in this decade as has merited that designation since 1872, when Yellowstone National Park was established.
Another comparable big lift is the Biden administration’s effort to effectively end the use of fossil fuels by 2050. The first US oil well was drilled in 1859, just thirteen years before the establishment of the nation’s first national park. The climate crisis and the extinction crisis equally need our attention, and solving both can be as complementary as they are critical.
In his executive order, Biden specified that his secretaries of agriculture, commerce, and interior, as well as his chair of the White House Council on Environmental Quality, were to report back to him on the question of what qualified to be counted in the 30 percent by 2030. The result is a report entitled “Conserving and Restoring America the Beautiful” and subtitled “A preliminary report to the National Climate Task Force recommending a ten-year, locally led campaign to conserve and restore the lands and waters upon which we all depend, and that bind us together as Americans” (whew…).
Unfortunately, “America the Beautiful” represents a gross dereliction of the duty of the Biden administration to future generations.
Figure 2. Falls Park in Sioux Falls, South Dakota: an example of urban conservation that the Biden administration would like to count toward 30x30. The nonnative lawn is closely mowed and likely treated with herbicides to maintain its monoculture. The trees may, or may not, be native. All those lights on at night keep wildlife as well as muggers away.Source: Center for Western Priorities.
Conservation-Lite
In the twenty-four-page report, the cabinet-level officials have taken advantage of the propensity of English words to have several different meanings. Here is my Mac dictionary’s entry for conservation:
con•ser•va•tion | ˌkänsərˈvāSH(ə)n |
1 prevention of wasteful use of a resource: the government must take action to promote energy conservation.
• preservation, protection, or restoration of the natural environment and of wildlife: [with modifier]: nature conservation.
• preservation and repair of archaeological, historical, and cultural sites and artifacts: the artworks in the collection need indexing and conservation.
(Definition 2 has to do with Newtonian physics and therefore is not included here.)
Biden’s campaign pledge (and Interior Secretary Deb Haaland’s congressional resolution) unambiguously committed our nation to “preservation, protection, or restoration of the natural environment and of wildlife.” The “America the Beautiful” report has switched the meaning of conservation to something closer to “prevention of wasteful use of a resource.” The report says:
Notably, the President’s challenge specifically emphasizes the notion of “conservation” of the nation’s natural resources (rather than the related but different concept of “protection” or “preservation”),recognizing that many uses of our lands and waters, including of working lands, can be consistent with the long-term health and sustainability of natural systems. [emphasis added]
The report accurately summarizes the two basic choices about what should count (and then chooses the wrong one):
The question of what should “count” came up regularly in the early listening sessions, followed by various perspectives on how to define conservation on the land and in the ocean. Many stakeholders recommended that a continuum of effective conservation measures be acknowledged, departing from stricter definitions of “protection” that do not recognize the co-benefits that working lands or areas managed for multiple use may offer. Other feedback encouraged the administration to focus on the quality and durability of conservation outcomes, noting that not every parcel of land or water is equal when it comes to enhancing nature’s contributions to people, ecosystem health, biodiversity, or the sequestration of carbon. [emphasis added]
The report goes on to embrace as “conservation” almost anything that has even a scintilla of something that is not profit-maximizing exploitation.
By supporting and accounting for existing and future conservation of public lands and waters, as well as collaborative and voluntary conservation efforts on working lands, Tribal lands, and State, local, and private lands, the U.S. is well positioned to achieve a 30 percent goal over the next decade. [emphasis added]
Figure 3. Klyde Warren Park in Dallas, Texas: another example of urban conservation that the Biden administration would like to count toward 30x30. Perhaps a few birds might nest in the trees. Source: Center for Western Priorities.
Mind the GAP
Twelve times, the report mentions “working lands” as being, or having the potential to be, model “conservation” lands. By “working lands,” the report means lands “that give our nation food and fiber”—in other words, lands that are logged, grazed, and farmed. This is a canard. All forestlands, tundra lands, desert lands, alpine lands, grasslands, shrublands, scablands, and wetlands are working lands. The extraction of forage, food, or fiber is not a prerequisite for “working” lands. As the authors of the nation’s premier forestry textbook note: “All forests are working ecosystems in that they carry out ecological functions or processes of value to humankind.”
The factor that determines whether a parcel of land should be counted as “conserved” in the context of 30x30 is not whether it is in public or private ownership but rather the quality of protections the land is afforded as indicated by the USGS GAP coding system. To qualify for either GAP 1 or GAP 2 status, the parcel must be “dedicated to the preservation of biological diversity” with “permanent protection from conversion of natural land cover and a mandated management plan in operation” to maintain either
• “a natural state within which disturbance events (of natural type, frequency, intensity, and legacy) are allowed to proceed without interference or are mimicked through management” (GAP 1), or
• “a primarily natural state, but which may receive uses or management practices that degrade the quality of existing natural communities, including suppression of natural disturbance” (for example, wildland fire or native insect outbreaks) (GAP 2).
Of course, for obvious reasons, almost all GAP 1 and GAP 2 lands are public lands.
So what qualifies or does not qualify for GAP 1 or GAP 2 status? Here are some examples:
• Many holdings of the private nonprofit Nature Conservancy qualify for GAP 2 status. However, many others —for example, their Dugout Ranch near Canyonlands National Park in Utah—have been assigned “default” GAP 2 status by the USGS. A closer examination of the management of the area would show that it does not qualify for GAP 2 status.
• If a wetland easement on private land (usually obtained with farm bill money) is permanent, the easement qualifies for GAP 2 status. If it is a term-limited easement, it does not (and would probably be designated GAP 4).
• Depending on how it is written, a conservation easement can qualify as nature preservation or not. If it requires the land to be managed in a natural state without extraction and in perpetuity, then yes. If the “conservation” easement merely prevents private land from being subdivided while continuing to allow the land to be cow-bombed and/or clear-cut, then no.
• An easement on private timberland that limits the size of the clear-cut or extends the period of time before it can be clear-cut is of very marginal conservation value and certainly should not count toward 30x30.
• An easement on a ranch that requires wildlife-friendly fences while all possible forage is consumed by domestic livestock—and not native wildlife—is of very marginal conservation value and certainly should not count toward 30x30. An easement on a ranch that gives over the land to native wildlife and takes away the domestic livestock could qualify it to count toward 30x30.
Confusing Recreation with Conservation
To “unlock access to the millions of acres of public lands that are currently inaccessible to the public,” as suggested in the “America the Beautiful” report, may well be a good thing (or may not, if you are looking at it from the point of view of wildlife), but it should certainly not qualify those millions of acres as counting toward 30x30. Increasing recreation access to a parcel usually diminishes its conservation value.
A priority of the “America the Beautiful” report is providing more recreation, especially in urban areas so that urbanites have more access to “nature.” This may be good public policy, but urban parks generally do not significantly contribute to the conservation of nature. (One exception might be Forest Park in Portland, Oregon, but the intensity of recreation there has an inverse effect on its conservation value.) Counting as “nature” an urban park that is mostly planted in a monoculture mowed lawn with some exotic ornamental trees is like counting a person with a mask hanging from one ear as “masked.”
All of the photos in this Public Lands Blog post are from the “Road to 30: Urban Conservation” storyboard published in November 2020 by the Center for Western Priorities (CWP), “a nonpartisan conservation and advocacy organization that serves as a source of accurate information, promotes responsible policies and practices, and ensures accountability at all levels to protect land, water, and communities in the American West.” Unfortunately, the CWP is not the only conservation organization that is suggesting that urban parks should count toward 30x30. Such lands should not.
Figure 4. The Platte River Greenway in Denver, Colorado: another example of urban conservation that the Biden administration would count toward 30x30. The concrete riparian area, though offering excellent loafing habitat for people, has no habitat value for wildlife. Source: Center for Western Priorities.
Bowing to Political Correctness
The “America the Beautiful” report reeks of political correctness. I shall pounce upon only one sentence of it here:
While the U.S. has a remarkable record of success in safeguarding iconic lands, species-rich waters, and at-risk wildlife, the Federal Government has also caused pain along the way: . . . [by] evicting private landowners to create national parks.
Perhaps the authors were thinking of Shenandoah, a national park established by Congress in 1935. The National Park Service was willing to have a national park in Virginia, but since the state wasn’t a “public land state” in the West, a new national park could not be reserved from existing federal public lands. If the Commonwealth of Virginia wanted a national park, it would have to acquire the land and give it to the United States.
The National Park Service and Virginia drew a proposed boundary, and the Commonwealth—using, when necessary, its power of eminent domain (condemnation)—then acquired what was mostly cutover, burned-off, mined-out, grazed-down, plowed-up mountains (those “working lands” I keep hearing about). Yes, there were “evictions,” but the evicted received just compensation as required by the Fifth Amendment. The power of eminent domain is routinely used (and always with just compensation) to acquire lands or rights-of-way for public purposes, such as highways and utility corridors found to be in the public interest. Are not natural areas at least equally in the the public interest?
Upon the establishment of Shenandoah National Park, the National Park Service announced it was “inviting nature back.” Today, much of the national park is also part of the National Wilderness Preservation System. It was a radical idea, but the creation of Shenandoah National Park is considered to be a very reasonable thing to have done. Until now, I guess.
Kowtowing to Locals and Cowtowing to Cowboys
A recurring theme in the “America the Beautiful” report is that local is best. The Biden administration is conflating urban locals with rural locals. The urban locals that it most cares about are persons who have been affected by systemic racism, economic inequality, and environmental injustice. These people are part of the Democratic base.
The rural locals the Biden administration most cares about are the opposite. Ranchers, for example, are land barons who own or control much of the American West. Ranchers—together with timber barons, mining magnates, and absentee owners of the local means of production—control local rural governments. These people are not part of the Democratic base.
If conservation means anything, it should mean choosing the long-term national interest over short-term local self-interest. Until now, I guess.
The report calls for the federal government to defer to locals (unless a check is being written in which the money comes from the federal taxpayer through the farm bill or from the Land and Water Conservation Fund or other federal source) in “leading and designing conservation efforts.” Local, enduring conservation efforts are more the exception than the rule. It is unwise to have a national conservation strategy that limits national leadership. Such is not leadership but kowtowing.
Or cowtowing. The “American the Beautiful” report is replete with assertions, unsupported by evidence, that ranching is good for conservation. The most egregious is this one:
This commitment includes a clear recognition that maintaining ranching in the West—on both public lands and private lands—is essential to maintaining the health of wildlife, the prosperity of local economies, and an important and proud way of life.
Apparently ranching in the East is neither important nor a proud way of life. In so many ways, this statement is untrue. Any forage that is eaten by domestic livestock is not available to native wildlife, be it elk, deer, pronghorn, bighorn sheep, sage grouse, or butterflies. Bovine bulldozers are twice the extinction-drivers that clear-cutting and strip-mining are. As a peer-reviewed article in BioScience notes, “Among extractive land uses, logging, mining, and grazing have contributed to the demise of 12%, 11%, and 22%, respectively, of the endangered species we analyzed.” Not only is public lands ranching subsidized by the taxpayer (so that it costs more to feed a house cat at home than a cow on public lands), but also ranchers pay lower property taxes than other residents of a county and are thereby a suck on local economies. I could go on.
Recommendations to the Biden Administration
Please don’t misread me. I love open spaces. Some of my best friends are open spaces. However, open spaces—even if they have relic or reintroduced elements of nature—do not equate to nature.
Yes, Biden administration, you should do most of things you outline in the “America the Beautiful” report. They are generally in the public interest. However, you should not count as “nature conservation” things that are not adequate nature conservation on the ground. Just as the climate doesn’t appreciate carbon reduction programs and credits that don’t actually reduce the amount of carbon dioxide going into or already in the atmosphere, nature doesn’t appreciate conservation on paper that is not also conservation on the ground.
Yes, do build an American Conservation and Stewardship Atlas to provide “a clear baseline of information on lands and waters that have already been conserved or restored,” as you recommend in the report. Count everything that has even a scintilla of conservation value. But don’t count areas dedicated to the furtherance of recreation rather than protection of biological diversity as “conservation.” Maybe you can count it as “stewardship,” but why not just count it as the “recreation” it is? Such an atlas should depict the multitude of distinctive kinds of conservation, stewardship, and recreation, but it should indicate the GAP status of each kind of land depicted: 1 (managed for biodiversity—disturbance events proceed or are mimicked), 2 (managed for biodiversity—disturbance events suppressed), 3 (managed for multiple [ab]uses), or 4 (no known mandate for biodiversity protection).
Do not renounce the use of conservation measures that have a proven history of effectiveness—that is, designating more national parks, national wildlife refuges, national monuments, wilderness areas, wild and scenic rivers, national conservation areas, national recreation areas, and such.
Turning over the authority and responsibility to address the extinction crisis to state, local, and tribal governments is a recipe for disaster. Biden administration, you are not deferring to and relying on local and voluntary efforts to address climate change, health care, border security, civil rights, and COVID, but you are throwing biodiversity under the bus. Perhaps the campaign bus.
Many mid-level Biden administration officials (and one cabinet officer who oversees the Forest Service) are retreads from the Obama administration. Other than Obamacare, what is the great legacy of the Obama administration? Other than some national monuments, what is the great conservation legacy of the Obama administration?
Officials, consider how history will treat you. In the present, you can simply point to the extraordinarily low bar of the Trump administration and feel good. However, history will judge you not against Trump but against all the rest. Did you step up and do what needed to be done, or did you polish your resume so as to land again in a later Democratic administration or a university teaching job? What will you be remembered for? As for the conservation and restoration of nature, will the Biden administration be compared favorably to the F. D. Roosevelt, L. Johnson, and R. Nixon administrations, or will it be unfavorably compared to the W. G. Harding administration?
Nature Bats Last
If society wants functioning ecosystems both across the landscape and over time (it does), 30 percent of our lands must be—in fact and on the ground—dedicated to the preservation of biological diversity by 2030. 30x30. Full stop.
Figure 5. Gas Works Park in Seattle, Washington: another example of urban conservation that the Biden administration would count toward 30x30. Frisbee habitat is not wildlife habitat. Source: Center for Western Priorities.