The following essay is an excerpt from William S. Devick, “Environmental Impact Assessment. DJ Job Progress Report F-15-T-18,” State of Hawai`i, Division of Aquatic Resources (1994).
The emphasis on ‘threatened’ or ‘endangered’ species in environmental assessments or surveys continued to skew outside evaluation of the biological significance of a given stream. If no such categorized species are present, the implication is that there is therefore no special reason for concern about the potential impacts of a proposal on other species. To infer that we must wait until species are threatened or endangered before concerns are noted and corrective actions are taken is a strategy for failure. Especially in Hawai`i, the emphasis should be shifted from individual species to habitat or ecosystem protection with a diversity of native species, threatened or not, serving as a major indicator of the biological value of a given area.
The consequences of this attitude have been exemplified in the Makaleha Springs and Stream water development proposal. Although the area is by unanimous agreement among qualified biologists too valuable as habitat for native species to justify a development that would inevitably degrade the area, especially since less environmentally destructive alternatives for development exist, the response of the engineers supporting the development has been that there are no listed threatened or endangered species present. Despite the fact that the Water Code mandates protection of native species and habitats without reference to threatened or endangered status, and despite the fact that the opinion of the most knowledgeable stream biologists supports this view, the environmental justification for the project is based solely on the absence of threatened or endangered species.
The paucity of this notion is emphasized by Dr. Dieter Mueller-Dombois in a recent article, where he objects to the loss of a given tract of dry forest to development based on the absence of threatened or endangered species. Although many native plant species were found in the area in definable native communities, all were deemed fairly common. Mueller-Dombois notes the following:
“The issue is not the native flora, but the native vegetation. What is the difference? A ‘flora’ is a list of species, the ‘vegetation’ is the plant cover of an area. The latter can be divided into communities, such as native or alien communities. Communities are much more unique than are regional floras. Communities and ecosystems provide the home for the wild-growing plants and associated biota, including the native plant populations. A flora doesn’t do that, it is just a list.”
Mueller-Dombois concludes that, “It is obvious from the above analysis that the Endangered Species Act, which was a milestone progress in biological conservation, is not protecting unique communities and ecosystems. Protection of natural communities and ecosystems, however, is the essence of an enlightened conservation policy.”
Mueller-Dombois’ comments represent a principle that applies equally well to fisheries. It parallels the Division of Aquatic Resources’ position on the issue and in fact is consistent with the new “ecosystem approach” being espoused as central policy by the U.S. Fish and Wildlife Service. That policy has identified the following as its first three targets for implementation of that policy:
* Focus and management on natural communities of plants and animals;
* Incorporate needs of rare and ecologically important species;
* Minimize habitat fragmentation.
Clearly, the USFWS intends that threatened and endangered species should be viewed as part of a community, not separate entities unto themselves.
The Makaleha issue represents a classic confrontation between biologically inadequate species-oriented planning and decision-making and genuine acceptance of responsibility for habitat protection. The former is anchored legally in the Endangered Species Act and the latter in the State Water Code. Because at present there are no listed species associated with Makaleha, and biological opinion is solidly on the side of the value of the Makaleha Springs area as habitat, the outcome will determine whether the State Water Code does in fact provide protection for unique habitat that is targeted for development. The seed of this confrontation, it should be emphasized again, was planted by the emphasis on threatened and endangered species in environmental planning, assessment, and decision-making.
William Devick, administrator
Division of Aquatic Resources
Department of Land and Natural Resources
Volume 5, Number 9 March 1995
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