Our Questions on the Forest Planning Rule

We’ve been blogging about the Obama administration’s proposed forest planning rule for the past few weeks.  After attending the Forest Service national roundtable on the rule last week, Defenders continues to have unanswered questions about what the proposed forest planning rule will mean for wildlife on our national forests.  We’ve attempted to distill those questions down to a few that we hope the public will keep asking throughout the comment period and at the upcoming regional roundtables:

Wildlife

1. Under the current planning rule, the Forest Service is required to manage habitat to maintain viable populations of native wildlife in the planning area. For most species on the national forests, the proposed rule replaces this clear requirement with vague instructions to manage for ecosystem health. How will this ensure that the Forest Service is able to “keep common species common” and maintain viable populations of all wildlife?

2. The proposed rule limits the viability requirement only to “species of conservation concern,” and then lets local forest officials decide which those are. It also allows the agency to absolve itself from the responsibility for protecting the species it does identify by claiming impossibility. Yet at the same time, the Forest Service claims the proposed rule gives “equal or greater levels of protection” than the existing rule. How can the Forest Service assert that unlimited discretion to exempt species from protection results in “equal or greater protections”?

3. The proposal is extremely vague on how wildlife monitoring will be used to inform management. The proposed rule requires that each forest provide for viable populations of “species of conservation concern” selected by the responsible officials, BUT the rule doesn’t require that those species be monitored. How will the public know if the viability standard is being met when species of conservation concern aren’t monitored? Additionally, what is the role of focal species in the monitoring program, and what happens if the status of focal species is “not good”?

4. The proposal appears to allow the agency to absolve itself from the responsibility of protecting all wildlife on the national forests if “the inherent capability of the land” prohibits it, but this key term is never defined. How can the public be confident that this determination won’t be used to avoid species protection measures when there is no basis for determining the “inherent capability of the land?”

Clear Accountability

1. Under the current forest rule, the public can hold the Forest Service accountable when it fails to uphold the requirements of the rule. The proposed rule seems to be much more focused on what the Forest Service “wants to” or “intends to” rather than what the American public says it “must” do to manage the national forests. The practical result is a sharp curb on public accountability. What are the wildlife and water standards in the rule that the public can use to hold the agency accountable?

2. The Forest Service has said that the rule explains “what” the Forest Service should do with planning on the national forests, but that the “how to” will be reserved for the Forest Service directive system. As such, it will not be subject to the same level of environmental analysis and public participation, and it will be easier to change. How can the Service justify leaving fundamental aspects of the rule – including criteria for selecting “species of conservation concern” – to be decided without full environmental review and public participation?

Best Available Science

1. The proposed rule requires forest managers to consider the best available science, but does not require them to base their decisions on it. They are simply required to write a description of the science that is available and describe why they decided to go a different way. By not requiring managers to base their decisions on science, what assurances are there that political pressure won’t trump sound science and that wildlife, water quality and healthy forests won’t pay the price as various special interests put pressure on forest managers?

2. Even if the best available science finds that a species is imperiled, a forest official is not required to recognize the animal as a “species of conservation concern.” This enables the agency to ignore best available science indicating that a species should be considered a species of conservation concern. What recourse exists for the public when poor decision-making leaves out a species that the best available science identifies as a species of conservation concern?

A Changing Climate

1. For the first time, the proposed rule addresses the threat of climate change on our national forests. There are references to climate change in the rule’s three main components: assessment, plan revision, and monitoring. However, all of the language is discretionary. There is no mandatory program to analyze the effects of climate change or to develop strategies to address those threats. Given the profound changes we are already seeing in forest ecosystems due to a changing climate, why aren’t the requirements for addressing these changes more explicit?

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2 Responses to “Our Questions on the Forest Planning Rule”

  1. ann wait says:

    Slowly, slowly, our environment is being eroded away by new government rules and procedures and regulations. Taking away protection for various species such as bears and wolves, etc. Cutting down forests, and therefore eroding stream beds, no longer protecting forests and land from man’s intrusion thereby taking away habitat for species, endangered and others.

    When are our legislators going to concentrate on the underlying problems such as employment, health (not fiddling with medicare by the way), ending our involvement in overseas battles, caring for the elderly and the ill, health care for wounded military personnel etc.

    Meddling with “mother nature” is taking away the environmental health of this country. Clean air and clean water are vital and not infinite.

    Please, please stop pilfering our environment. Ann Wait

  2. Amy Chance says:

    Our nation’s parks & resources must be preserved for the generations that follow us to enjoy.

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dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.

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