EDF, Partners Support Biden Administration's New Guidance to Incorporate the Value of Nature into Federal Decision-making Processes

(WASHINGTON, D.C. - September 19, 2023) Environmental Defense Fund (EDF) and 16 partner organizations and experts have filed comments to the Office of Management and Budget supporting its proposed guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-cost Analysis. This is the first time the federal government has drafted guidance for all agencies to account for the benefits that nature provides to people, also referred to as ecosystem services, in the benefit-cost analyses (BCAs). BCAs are used to make decisions about federal regulations and infrastructure investments. 

The comments support the draft guidance’s core principles of ecosystem service valuation.  They also recommend expanding the guidance to provide more detail on the data, methodological tools and analytical procedures needed to conduct these analyses in practice. 

“We commend the Biden Administration for taking this pivotal step to, for the first time, consider the benefits that nature brings to people into federal decision-making across government. Incorporating and mainstreaming these guidelines holds the potential to improve policy-making that generates greater net benefits to society for generations to come.” said Dr. Natalie Snider, associate vice president for EDF’s Climate Resilient Coasts and Watersheds program. “For years, EDF has advocated for a more equitable approach to benefit-cost analyses that also incorporates ecosystem services. Accounting for these benefits will help advance nature-based solutions that build climate and flood resilience, improve water quality and public health, and provide quality habitat for wildlife and outdoor recreation.” 

For decades, federal agencies have been required to evaluate the costs and benefits of regulations and investments that are expected to have large economic effects, including large-scale infrastructure projects such as flood mitigation and ecosystem restoration projects. However, BCAs typically do not quantify and incorporate the multiple benefits generated by natural systems, or how losses to natural systems may have subsequent costs to society. Research has shown that ecosystem service benefits are often unevenly distributed among socioeconomic and demographic groups and among rural and urban communities. 

“Considering both how changes in the provision of ecosystem services influence the benefits and costs of a project, as well as to whom those benefits and costs are accruing, will help ensure that federal decision-making is more equitable and effective for future generations.” said Dr. Jesse Gourevitch, post-doctoral economics fellow at EDF. “This draft guidance is an important step towards operationalizing and mainstreaming the value of nature in federal decision-making processes and investments.” 

Agencies including the U.S. Army Corps of Engineers (USACE), the Department of Transportation, the Department of Energy and the Federal Emergency Management Agency utilize BCAs to determine the location, size, and scope of infrastructure investments that can have detrimental impacts on the landscape and adjacent communities without proper accounting of the loss and gain of ecosystem services. 

EDF was joined on the letter by American Rivers, Association of State Floodplain Managers, Audubon Society of Northern Virginia, Columbia Climate School – Center for Sustainable Urban Development, Coney Island Beautification Project, Inc., Friends of Dyke Marsh, JF Environmental Trust Foundation, Lynnhaven River NOW, Miami Waterkeeper, National Audubon Society, Newtown Creek Alliance, NYC H2O, RETI Center, Southern Environmental Law Center. The Nature Conservancy, Theodore Roosevelt Conservation Partnership and Virginia Conservation Network. 

Read the full comments here.