The Chesapeake Bay Foundation (CBF) urged the White House not to limit the guidance it is drafting on valuing the benefits of healthy ecosystems just to regulatory decisions in comments CBF recently submitted to the Office of Management and Budget.
OMB published draft guidance on August 2 to improve and standardize how federal agencies evaluate the “ecosystem services” that nature provides when analyzing the costs and benefits of proposed regulations.
CBF expressed its support of the guidance and recommended that federal agencies apply it to other government decisions besides regulations, such as funding for major infrastructure projects that affect ecosystems and grant programs that support ecosystem development or restoration.
CBF also applauded the guidance for directing agencies to consider how regulatory decisions affect ecosystem services for historically underserved communities, as well as past inequities that have disadvantaged these communities, and how to prevent further disproportionate harm.
Based on its experience evaluating the ecosystem services provided by the Bay, CBF recommended specific analytical tools and resources OMB could include to strengthen the section on ways agencies can quantify or monetize ecosystem services.
CBF also drew on its regenerative agriculture and oyster restoration work to caution OMB against undervaluing the ancillary benefits of ecosystem services. CBF noted that the healthier soil produced by regenerative agricultural practices offers multiple ecosystem benefits, such as drought resilience, carbon sequestration, and water quality improvements, that are completely separate from crop production.
Similarly, CBF pointed out that its work restoring reefs in Maryland and Virginia oyster sanctuaries goes beyond rebuilding oyster stocks to include increasing biodiversity and water filtration, and providing larvae to support wild oyster populations outside the sanctuaries where CBF works.
CBF Maryland Senior Scientist Doug Myers issued the following statement on the guidance:
“From water quality that supports abundant fisheries to wetlands that reduce storm impacts, healthy ecosystems provide our communities numerous benefits. CBF applauds the White House for recognizing the importance of properly valuing ecosystem services in federal decision making.
“As OMB refines this guidance, we recommend it lean on science-based organizations such as CBF that have decades of experience valuing the complex effects of government decisions on ecosystem services. CBF looks forward to supporting more robust accounting for ecosystem services and stands ready to help advance this effort.”