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E-M:/ MNFI still threatened by state appropriations bills

Enviro-Mich message from Barbara Jean Madsen <bjmadsen@biology.lsa.umich.edu>

Many of you are already aware of the potential problems posed for the
continued existence of the Michigan Natural Features Inventory by recent
amendments to state appropriations bills.  Anne Woiwode has reported on
this issue earlier on enviro-mich (3/17/99 and 3/25/99).  It's not too
late to have some influence on the legislative process on this issue; I've
included below a summary of the problem and a letter I wrote to
Representative William Byl, chair of the House Appropriations Subcommitte
handling this legislation.  Write Representative Byl and your own
representative this week!

	--Barbara J. Madsen

The Michigan Natural Features Inventory (MNFI) is THE source for
information on endangered, threatened, and sensitive species, communities,
and ecosystems in our state; it has spent twenty years amassing and
maintaining an enormous, integrated database on these topics.  MNFI is
consulted by everyone from scientific researchers looking for sites at
which to study rare species, to state and federal agencies reviewing
permit applications, to agencies trying to gauge the probable effects of
their own proposed actions.  MNFI's core contract with the Michigan DNR
calls for it to "survey, research, and inventory the most important
biological resources of the state," and it has done, and continues to do,
an admirable job of this.  In addition, MNFI has carried out many other
important studies on the biota and ecology of our state, from analyses of
the great variety of lakeshore wetland types to maps of the presettlement
vegetation of the state-studies done by no other group, that are of
immense value to all those interested in understanding and preserving the
natural features and values of Michigan.

MNFI is a part of The Nature Conservancy (TNC), but is housed within the
Wildlife Division of the Michigan DNR, with whom it works most closely (on
the core contract work mentioned above).  This arrangement has worked well
(and has prevented undue political pressure or influence on MNFI), but a
state senator's misinterpretation of the relationships among MNFI, the
DNR, and TNC has now endangered not only MNFI, but also the integrity of
many state and federal agency processes.  Senator Loren Bennett perceives
a conflict of interest between TNC operating the MNFI and also buying land
for preservation, because he mistakenly believes that MNFI has the power
to approve or deny permits (thus affecting the value of land that TNC
could buy).  This is not now and has never been the case.  MNFI simply
reviews permits and provides relevant information about rare species and
habitats to state and federal agencies; the agencies approve or deny the
permits without any regard for TNC or its interests.  However, Senator
Bennett has attached an amendment to the DNR FY00 Budget Bill (SB 370)
that would prohibit the DNR from signing any contracts with TNC (MNFI) for
inventories or permit reviews, as of September 30, 2000.

Both TNC and the DNR have long considered that MNFI would someday become
independent of TNC-that it would become a full-fledged part of the DNR, or
be integrated into a university or some other appropriate agency.  Sixteen
months, however, is simply not sufficient time for such a transition to
take place.   Nor is it possible to break up MNFI's work and farm it out
to isolated individuals at other agencies or universities; it is the
integration of botanical, zoological, ecological, GIS, and other expertise
that makes MNFI so effective and so valuable.  Without the resources of
MNFI, the state would experience massive difficulties in reviewing
thousands of permits every year for possible effects on sensitive species,
as required by law, and would undoubtedly fall far behind in processing
permit applications.  In addition, any doubts about the accuracy of
information obtained from elsewhere could result in legal challenges to
those permits.

MNFI's database is also crucial to the integrity of the state's Threatened
and Endangered Species Program.  As the US Fish & Wildlife Service
explained to Anne Woiwode of the Sierra Club, the state must maintain an
"accurate and active" database of threatened and endangered species
occurrences in order to retain delegation of authority through the
Endangered Species Act.

It is thus essential that MNFI be maintained intact, and that sufficient
time be allowed to transfer it to a suitable agency, university, or other
home, or to make some other acceptable arrangement for its continued
existence.  The next legislative step is for the House Appropriations
Committee to consider the DNR appropriations bill (and also the DEQ and
Supplemental Appropriations Bills).  Anyone who is concerned about the
protection of sensitive species and habitats in Michigan, and the
essential role played  by the MNFI in this endeavor, should write NOW to
Representative William Byl, the chair of the House Appropriations
Subcommittee that will deal with these issues.   Representative Byl is an
ally who understands the importance of MNFI; what is needed are letters
explaining and affirming the scientific value of MNFI's work, and
supporting Rep. Byl in the effort to protect the integrity of MNFI.  Below
is a letter that I have written to Rep. Byl; feel free to use or adapt it
as you will.  The Subcommittee is likely to take up this issue during the
first week of May, so time is of the essence.

--Barbara J. Madsen, Adj. Ass't. Prof., U. of Michigan

Representative William Byl
State Capitol
P.O. Box 30014
Lansing, MI 48909-7514

Dear Representative Byl,

	For the last twenty years, the Michigan Natural Features Inventory
(MNFI) has maintained a superb database on the natural features of
Michigan, especially occurrences of threatened and endangered species.
Its work has been the foundation of much of the protection and management
of sensitive species and habitats throughout the state.  It participates
in the review of thousands of permit applications each year, supplying
information on sensitive species to the DNR and DEQ--information that is
essential to the responsible and lawful review of these applications.  In
addition, MNFI also provides this kind of information to federal agencies
responsible for land management, such as  the U.S. Forest Service and U.S.
Fish & Wildlife Service.  The federal government also delegates funds and
authority to the state's Threatened and Endangered Species Program based
on the existence of MNFI's "accurate and active" database on these
species.  In addition, MNFI has used outside grant money to conduct other
important studies on the biota and ecology of our state, from analyses of
lakeshore wetlands to maps of the presettlement vegetation of the
state-studies done by no other group, that are of immense value to all
those interested in understanding, preserving, and managing the natural
features and values of Michigan.

	MNFI is not just a data-processing organization, simply keeping
mindless lists of species.  It is a team of dedicated scientists with the
expertise to evaluate the validity of information reported to them, to
field-check the accuracy of such reports,  to conduct intensive surveys of
important areas, and to assess the applicability of their data to specific
permit applications and other project proposals. It is an integrated team
of botanists, zoologists, ecologists, GIS (Geographic Information System)
specialists, and information-technology experts, all working together to
provide unparalleled expertise on the natural features of our state.
MNFI is a great deal more than the sum of its parts; no collection of
individual consultants or personnel scattered through various agencies
could produce the integrated understanding of natural systems and species
that makes MNFI so valuable and so efficient.  In addition, MNFI has
always operated with complete scientific integrity, influenced  neither by
other policies or interests of The Nature Conservancy (its parent
organization) nor by political influences within state government (its
primary customer).  If MNFI were to be disbanded, trying to reconstruct
its functions would be inefficient, ineffective, and extremely expensive;
and no substitute would have the credibility or respect that have been
earned by MNFI.  

	The amendments to SB 370 and SB 364, prohibiting the DNR and DEQ
from contracting with MNFI for threatened and endangered species
inventories or permit reviews after 9/30/00, would endanger not only MNFI,
but also the integrity of many state programs and permitting processes.
Without the active database of MNFI or its review of permits, the state
could lose delegation of authority under the federal Endangered Species
Act, would fall woefully behind in permit reviews, and could find itself
open to legal challenges of any such permits it grants. The Nature
Conservancy, MNFI, and the DNR are all open to the idea of moving the
MNFI, intact, from its current administrative home within TNC to the DNR
or some other agency or institution, in order to avoid any perception of
possible conflict of interest.

	I strongly encourage you, therefore, to support the continued
existence of MNFI, and to support legislative language allowing sufficient
time for the transfer of MNFI from The Nature Conservancy to some other
appropriate home, whether that be a state agency, a university, or some
other organization.  It is essential that adequate transition time be
allowed and a careful plan drawn up to ensure the integrity of MNFI's
database, expertise, and integration of knowledge and services.  The
ecological information collected, processed, and provided by MNFI to
numerous governmental agencies is essential to the responsible and lawful
protection and management of the environment and  natural resources of
Michigan; it must not be lost or compromised.


	Dr. Barbara J. Madsen
	University of Michigan

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