March 3, 2023

Dr. Chris Avery
Chief of Staff
U.S. Global Change Research Program
1800 G Street, NW
Suite 9100
Washington, DC 20006

Subject: Comments on Framing the National Nature Assessment

Dear Dr. Avery:

I am writing on behalf of the Coalition to Protect America’s National Parks, which represents over 2,300 current, former, and retired employees and volunteers of the National Park Service. Collectively, our membership represents over 45,000 years of national park management and stewardship experience. Our membership includes former National Park Service directors, deputy directors, regional directors, and park superintendents. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System and mission-related programs of the National Park Service.

As described in the Federal Register Notice published on October 31, 2022, the United States Global Change Research Program (USGCRP) seeks to create a National Nature Assessment (NNA) that is broadly relevant and provides useful information on nature to all people living or residing in the United States. In creating the NNA, USGCRP is also abiding by the following principles: to create an assessment that is authoritative, credible, timely, and concise; fully compliant with relevant laws and policies; policy relevant but not policy prescriptive; transparent, accurate and reproducible with well-documented methods; inclusive; use-inspired; and accessible to the widest possible audience. USGCRP invites members of the public to share perspectives on how the scope and principles set forth should be addressed in the NNA.

We offer the following comments in response to questions identified in the Federal Register Notice. 

Questions To Inform Development of a Use-Inspired Assessment

  1. Assessments can be tailored to inform a wide range of audiences. Who are the key audiences for, or users of, the NNA? Who should find the information that the NNA provides useful?

Audiences should include decision-makers, policy makers, and planners as well as the general public. Assessments need to be made available at the federal, state, and county level to be used in applying land management goals and objectives. These should include, but are not limited to, the following:

  • National level congressional elected officials and their staff
  • The U.S. Department of Interior (DOI), directors, associate directors, and staff
  • The U.S. Department of Agriculture (DOA) directors, associate directors, and staff
  • The Boise Fire Center and other wildland fire agencies completing fuel treatments in habitats
  • All public land managers, including local, county, state, and federal land management agencies that are responsible for public trust lands
  • Ranchers, farmers, companies, nongovernmental organizations (NGOs), and homeowners who are protecting nature
  • All consultants, NGOs, agencies, and organizations monitoring climate change effects
  • General public, particularly diverse populations who may have various objectives for wanting to know information. 
  1. USGCRP understands that creation of a use-inspired assessment will require ongoing engagement with the potential users of the NNA.

    a. What engagement processes should be used so that the audiences identified above are best able to participate in the development process?

In general, web-based approaches are likely to reach the greatest number of people. However, they may exclude underserved communities and elderly individuals who may have limited access to electronic media. As a result, the engagement process should include in-person and web-based approaches, including but not limited to the following:

  • Establishment of an informative and well-maintained website
  • Active use of social media
  • Newsletters by agencies, non-profit partners, environmental groups, cities, counties, states
  • Periodic media releases for print and television
  • Offering in-person workshops and webinars
  • Coordination and collaboration with nature focused groups to capture the attention of their members

In looking ahead to when the NNA will be rolled out, it would very helpful if the USGCRP worked in collaboration with other organizations to develop a “NNA awareness” training module for interpretive naturalists who work in federal, state, local, and nonprofit-managed parks and conservation areas. The naturalists could then incorporate information about the NNA into their respective walks, talks, and other programs presented to the public, which would serve as a “force magnifier” to help elevate awareness of the NNA across the country. We recommend that USGCRP consider partnering with the National Association for Interpretation in the development and distribution of such training.

b. What forms or formats of engagement (e.g., in-person town hall meetings, virtual conversations, community workshops, social media events, calls for stories or art) are likely to help USGCRP meet its principle of inclusivity and best inform the assessment? Assessments can be tailored to inform a wide range of audiences. For example, assessments can be created for use by the general public, government decision makers (at any scale from Federal to state to local, territorial or Tribal), researchers and practitioners, non-profit organizations, private sector companies, individuals, different generational groups, or other audiences. Who are the key audiences for, or users of, the NNA? Who should find the information that the NNA provides useful?  

All of those mentioned above should be used, as well as special TV reports, library events, and local environmental and group newsletters. Additionally, land grant universities could be engaged with the development of outreach programs and hold engagement sessions in under-represented communities. 

  1. Use-inspired assessments are tailored to their intended use.

    a. What decisions should the NNA help inform, and what information is needed for those decisions?

The NNA should identify areas that need further protection, such as wildlife corridors, nature buffer areas, or areas of biodiversity, so that decisions can be made to enhance stewardship and protection of these existing critical areas. The use of NNA sensitive data (e.g., location of endangered species) for decision making should be cautiously approached and used only as a primer to the more detailed information available to managing agencies and jurisdictions. As the climate continues to change, nature will change – and the NNA will need to be flexible in order to respond. The NNA should recommend conservative management approaches to allow for unknown threats.

b. What needs can the assessment fill, and how should information be provided to fill them?

The assessment can provide awareness of nature’s value through language, maps, and photos. It can ensure benefits that include passive uses, such as bird watching and botanizing, as well as more intangible health benefits such as mental health, tranquility, and spiritual connection. In addition, the assessment can provide educational value on the topic of climate change. We recommend the information be provided through electronic and written methods, via television, speeches, and education opportunities for the public, including members of Congress and other elected officials.

c. What questions should the NNA answer? What do you wish you knew about nature in the United States?

The assessment should help inform a range of decisions on trends and issues of common concern from the local to the national scale. It would be helpful to incorporate many existing assessments, such as those that address water and air quality, the status of threatened species and habitats, and the amount and condition of protected areas and human use patterns and trends in and adjacent to them. Rather than duplicate those assessments the NNA should aim to consolidate key themes and trends to help users identify opportunities to celebrate, maintain, and improve where necessary the amount and condition of refugia to preserve nature and for humans to enjoy.


  1. The scope of the NNA includes assessment of the observed trends and future projections of nature and the benefits it provides to people. Given this:

    a. How far back in time should the NNA explore observed trends, and why?

The NNA should explore observed trends over the last 100 years to take into account fire suppression vegetation change and changes since the industrial revolution. The National Park Service provided an inventory of park wildlife in the 1930s, which should be included. This also will identify changes due to the many laws intended to protect or improve the environment in the past half century.

b. What kinds of questions about the future should the NNA aim to answer? How far into the future should projections extend, and why?

The NNA should help answer questions and prompt honest debate about the effectiveness of conservation programs and policies, as well as their costs, not solely economic but also ecological and experiential; and prompt ways to improve programs and policies intended to benefit nature and human use and appreciation of it.

The assessment should project several decades into the future using or referencing existing climate change models and assessments, with clear explanation of potential outcomes.

c. What types of future scenarios would best support the recommended uses (e.g., quantitative time series, directional changes, stories)?

Success stories can and should be used to highlight examples of nature benefiting humans and/or environmental quality. Clear presentation of directional changes and changes over time will be most powerful to users, especially if scaled with some utility at the state or local level.

  1. Assessments can create a wide variety of products that help users access, understand and use the information that is provided. These can include large written reports, a series of shorter reports, online interactive settings, artistic expressions (paintings, poems, etc.), infographics, virtual or augmented reality tools, phone or tablet apps, presentations, data resources, films, podcasts, social media, events, entertainment products, and many others.

    a. What kinds of products can best communicate the findings of the NNA?

Online interactive maps with brief accompanying narratives or links to references and other relevant information are especially valuable to users at the local and state level. More creative presentations (films, events, entertainment products) should be tied to the objectives of the outreach and carefully monitored. We are mindful of the NPS’ previous ‘Find Your Park’ campaign which, while intended to encourage public use across a broader array of parks and natural spaces, also increased pressure on already heavily used areas.

b. How would you like to use the findings of the NNA?

Searchable inventories would permit users to find natural resources, types of refugia or land ownership, and human use or occupancy levels at the local or state scale to inform planning and protection efforts. For example, in many areas adjacent land management agencies (BLM, NPS, USFS, state) shared booming user demands during the pandemic, but their individual computer systems and databases impeded coordination and sharing of basic information, such as alternate spots to camp, picnic, and hike in areas more resilient to higher use. 

  1. Past assessments have used various approaches to organizing findings. The NNA is tasked to assess the connections between nature and the benefits it provides, and so findings could also be organized by benefit (e.g., public health, equity, economy) or by sector (e.g., agriculture, transportation, health, housing, energy).

    a. Given that the scope of the NNA is quite broad, how should information in the assessment be organized?

Our national parks and Congressionally designated Wilderness Areas should serve as core conservation areas, that anchor the 30 x 30 initiative. Inventory landscape systems across the nation should conduct a gap analysis of ecosystems and identify underrepresented terrestrial and marine ecosystems and biodiversity hot spots. The NNA needs to display maps of species, habitats, migration routes, and ecosystems, regardless of land ownership. It also needs to identify and map what species and ecosystems are at risk and what threatens their existence. Additionally, future development pressures and federally permitted activities that threaten any of the above should be identified and mapped. The NNA needs to propose conservation priorities and communicate why these steps are needed to gain public support. The NNA should identify and establish connectivity between conservation units to prevent fragmentation and improve the horizontal and vertical movement of species.

b. What format would best match the ways you think the NNA should be used?

For conservation professionals, digital maps and arcgGIS would be the best formats. We recommend that as products are produced they should be made readily available at universities, colleges, and ESRI. All information needs to be included into the American Conservation and Stewardship Atlas. For the general public, maps and basic inventory information about natural areas should be readily available on-line or through a new NNA application. 

Questions To Inform a Definition of Nature – USGCRP is aware that there are many different definitions of nature and many ways of coming to know and understand nature. With this in mind, USGCRP seeks responses to the following questions:

  1. What does nature mean to you?

The definition of nature has been an elusive and a moving target. The American Heritage Dictionary defines nature as “the physical world, usually outdoors, including all living things.” Others have defined nature as excluding human species. We suggest a hybrid definition with three designations identified in our response to Question 8 below. It considers, for example, the International Union for Conservation of Nature (IUCN) protected areas categories and UNESCO Biosphere Reserves, yet also considers human presence that has shifted environmental foundations due to climate change and other manipulations that have caused biological adaptations towards less protected yet still ecologically functioning areas Finally, it includes urban and working land nature sites that are not made up of entirely native species.

  1. What should the definition of nature used in the NNA be sure to address or include, and why?

The definition of nature should be identified with three distinctions:

  1. The first must consider the original ecosystems of a site and their evolutionary counterparts. The values of these habitats for the future of the human species may not be understood at this time and they should be kept as intact as possible. This first distinction should include the core protected areas such as national parks – these should be critical to inclusion in the NNA.
  2. The second distinction should reflect the contribution or impact of post-contact humans on its function. This second distinction would include National Conservation Areas such as Research Natural Areas (used not only by the NPS, but also the USFS and BLM). These areas provide connectivity across the conservation landscape where more manipulated management may occur. The second distinction also includes recovering wildfire footprints and open space reserves closer to urban areas. These lands serve as possibly altered, yet ecologically functioning landscapes for wildlife movement. This is especially the case in areas of human encroachment on previously more natural systems. The NNA should identify these more impacted areas accordingly.
  3. The third distinction would include urban parks and working lands such as agriculture and ranching. These lands are used for a consumptive purpose that purposefully removed the original landscape for post contact human uses. However, they still could be restored or vegetated with native plants to improve biodiversity.
  1. What should the definition of nature used in the NNA be sure to leave out or exclude, and why? 

The NNA should exclude heavily impacted consumptive use areas such as open pit mines and clear cuts. That said, mines where restoration has occurred or clear cuts where restorative planting has been successful should be labeled as such and part of the NNA. While it may be difficult or impossible to do, urban/suburban protected areas also serve as areas of refuge for bird species, for example. They are also important areas for the resident population to learn and appreciate nature. 

Questions To Inform Identification of Relevant Knowledge Sources

  1. Indigenous Knowledge (IK) is an important body of knowledge that contributes to the scientific, technical, social, and economic advancements of the United States and to our collective understanding of the natural world. Responsive to this recognition:

    a. How can USGCRP best engage with Tribes and Indigenous Peoples in the development of the NNA?

We strongly recommend that USGCRP consult directly with Tribes, Native American scholars, or other experts on this topic.

b. How should IK be woven together with other forms of knowing in the NNA?

We have no specific suggestion on how IK should be woven together with other forms of knowing in the NNA. However, we recommend that USGCRP conduct a literature review of scholarly works on integrating IK into conservation practices. There are several studies and articles on this topic, including many from other countries and continents. There may be lessons learned elsewhere that would be applicable to this new initiative in the United States. 

  1. There are many ongoing assessments, and existing quantitative and qualitative data and knowledge that relate to the many aspects of nature and the wide range of benefits the NNA is charged to assess. 

    a. What existing assessments and knowledge efforts should the NNA draw from to provide a comprehensive view of the status, observed trends and future projections of nature and its benefits in the United States, and why?

Federal and state land management plans need to include inventory and monitoring programs and Long Term Ecological Research (LTERs). These collectively can assist in defining ecosystem health on national, state, regional large-landscape stewardship collaboratives. Furthermore, many counties have developed geographic databases to help them track local nature inventories and assessments at the more local level. These also should be included.

b. How can USGCRP best engage with local communities to incorporate their lived experiences into the NNA?

USGCRP should establish a new free application similar to the Merlin app created by Cornell Ornithology or iNaturalist, which is a social network of naturalists, citizen scientists, and biologists built on the concept of mapping and sharing observations of biodiversity across the globe. iNaturalist may be accessed via its website or from its mobile applications.

Our recommended, “all nature” application, along with the Merlin and iNaturalist apps, could feed information back to the NNA and allow local citizens to gain a true appreciation of nature. We also recommend that USGCRP collaborate with national and state 30×30 programs, such as California’s 30X30 initiative, and collaborate with the Stewardship Network, which connects, equips, and mobilizes people and organizations to care for the land and water where they live.

c. What existing datasets, knowledge sources, information or stories should USGCRP draw from in creating the NNA, and why?

We recommend USGCRP consider the following datasets:

  • The Western Collaborative Conservation Network is launching a Geographic Information Systems (GIS) Working Group to share ideas and resources that can enhance collaboration through the use of geospatial technology. It is open to all participants in collaborative groups with any interest or skill level in mapping, and GIS.
  • Cornell Ornithology’s Ebird program is an online database of bird observations providing scientists, researchers, and amateur naturalists with real-time data about bird distribution and abundance.
  • iNaturalist is a social network of naturalists, citizen scientists, and biologists built on the concept of mapping and sharing observations of biodiversity across the globe. iNaturalist may be accessed via its website or from its mobile applications.
  • Local native plant societies, such as California Native Plant Society, seek to increase understanding of native flora and to preserve it for future generations and have much state and local information about nature and native plant assessments.
  • State academies such as the California Academy of Sciences have archives of scientific documentation of species from the past and continue currently.

 d. How should the NNA be designed to add value beyond what these existing efforts and sources already provide?

The development of a free “all nature” application similar to the Merlin birding app developed by Cornell Ornithology would allow local citizens to gain an additional appreciation of the nature around them. 

In closing, we are excited about the potential benefits of the NNA to elevate public awareness of the natural world and the importance of conserving native flora and fauna in our own backyards. We appreciate the opportunity to comment now and look forward to commenting on the next phase of its development.


Michael Murray signature



Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks