Forestry Habitat Conservation Plan for Bats on Pennsylvania State Game Lands, State Forests, and State Parks


Coming to an agreement on decisions internally and with USFWS is the foundation of the HCP process. Early on in the HCP’s development, we identified who the decision makers were for each party involved as well as how decisions were going to be made.  However, the development of the HCP is and continues to take much longer than anticipated due to several factors. During this time period there had been considerable turnover within the USFWS.  As a result, when new USFWS staff came onboard, each had to be brought up to speed as to what our HCP entailed as well as what decisions had been made up to that point.  For example, USFWS recommended that we make major changes to the way that information was presented in in the Conservation Program chapter of the draft HCP.  We agreed to make this change to the document; however, staff changes led to new USFWS reviewers that requested reorganization of the information. In this way, project delays and associated staff turnover created unforeseen issue with plan development.


Considerable time was spent by the applicant and their consultant via memos, webinars, and/or meetings with USFWS to provide documentation regarding why and when past decisions were made during the HCP’s development.  Although we identified who the decision makers were and what the decision-making process would for our HCP be early on, we never anticipated that the project would take this many years to develop, that a great deal of turnover would occur within the USFWS during that same time period, and that limited transfer of knowledge would occur for decisions that were previously made regarding our HCP.


Both the applicant(s) and USFWS should be held accountable for their decisions during HCP development.  The HCP Handbook recommends that the Service does so but we would strongly recommend that the applicant document all decisions made along the way to include who made it, when the decision occurred, and what the result of the decision was.  Such decision documentation should occur regardless of the HCP’s complexity as it is imperative that the applicant have this record due to unforeseen delays in HCP development, turnover within the various entities involved, etc.

It is more work along the way to document all decisions, but it could potentially save considerable time in the long run for projects that take years to get permitted, are delayed for assorted reasons, when there is turnover within the various entities involved, or other unforeseen circumstances arise.  In addition, this documentation can save time in the future when the same issues resurface or when the applicant is questioned by the USFWS or public as to why things were done a certain way.

Tracey Librandi Mumma,
Pennsylvania Game Commission