Defenders submits formal comments on Obama’s forest rule

Today our staff has submitted a full set of comments to the Forest Service on the National Forest Management Act planning rule, which we have been blogging about for several months now.  Our comments provide workable fixes to the proposed rule’s primary problem areas, mainly in the areas of assessment, species diversity management, and monitoring, which are the key components of adaptive, science-based land management planning and decision-making.  We provide the agency with meaningful recommendations to better align the rule’s aspirations with its words.  Generally, we offer suggestions on how to better facilitate adaptive management and effective decision-making.  In many cases this requires clarification and better prescription of process.  We do not feel that enhanced clarity in any way detracts from the ability of the rule to facilitate efficient planning, in fact we strongly believe that clarity and prescription of process ensures that the rule will be applied as it is intended.

We offer clear suggestions for improving the critically important diversity provisions.  The agency has proposed a management strategy that is strong in concept, yet poor in design.  Our recommendations to improve the design include:

1)  Clarifying that the purpose of the coarse-filter species diversity protection is to provide for the long-term persistence of individual species

2)  Providing “focal species” with a more robust role in validating the resiliency and health of ecosystems

3)  Prescribing a process to identify and develop targeted plan components for species of conservation concern

4)  Clarifying the definition of a “viable population” of a species of wildlife

5)  Providing a means to determine when conditions outside the authority of the agency make it impossible to meet the rule’s species diversity requirements

Similar recommendations are made for other key areas of the rule – including climate change, watersheds, and public process – with the intent of giving this rule the structure that it will need to long remain the cornerstone of forest planning and management.

Read the full letter on our website.  You can also read a statement regarding the proposed rule and the close of the public comment period from Defenders’ Vice President, Jamie Rappaport Clark, and media stories from around the country.

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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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