Incorporating Climate Change into the New Forest Planning Rule

For much of the past two years, Defenders has been actively engaged in the Forest Service’s development of a new rule to guide planning within the National Forest System. We submitted extensive comments on last year’s proposed rule, but that was hardly the end of our involvement.  The Forest Service is now in the process of drafting “directives” to guide the implementation of the 2012 planning rule. As with the rule itself, we have quite a few suggestions for making it stronger, better and more clear (our full comments on the directives can be found here). This week’s blog installment focuses on incorporation of climate change.

The Forest Service has been a leader in understanding, researching, and developing policy mechanisms to deal with the impacts of climate change.  The planning rule itself broke new ground in directing forests to take into account the effects of climate change on ecosystem integrity and to incorporate climate change resilience into forest planning. We had expected, therefore, that the Directives would build on that track record and provide forest managers with clear direction on how to integrate assessment and response to climate change impacts into all phases of forest planning.  Unfortunately, the Directives don’t do much more than repeat some of the language from the planning rule itself.

Virtually absent from the directives is any clear description of the particular exposure factors associated with climate change, such as higher mean temperatures, hotter high temperatures, reduction in frost-free days, changing proportions of precipitation falling as rain vs. snow,  occurrences of extreme precipitation events, alterations in snowpack, and lengthier periods of drought (to name a few). Many species and habitats will be sensitive to one or more of these specific types of exposures, but there is no guidance on how select, evaluate or rank these. Climate-related stressors will also interact with other stressors (for instance, warmer winters may facilitate spread of invasive or noxious species that are held in check by winter die-off). Societal responses to climate change will also likely compound stresses to species and ecosystems (some examples include increased water withdrawals from stream systems in response to drought and heat, and habitat modification to reduce fire risk at the wildland-urban interface). Nowhere do the directives recommend how to find, evaluate, and use this information in forest planning.

The directives also fail to give forest managers a path for selecting appropriate responses. This is a pretty glaring omission, given that the Forest Service has already published extensive resources on various adaptation response options: resistance, resilience, response, and re-alignment. We had hoped that the directives would provide managers with a means to choose among these responses and select plan components to achieve those aims, but it does not do so.

Even worse, the directives at times seem to give managers an easy way out of doing the hard thinking about responding to climate change. For instance, the “Ecosystem Integrity” section of the assessment language says, “Where information is available, the responsible official should consider the influence of climate change. . .” (emphasis added). Later, the directives use climate change as an example of “factors outside of the agency’s control.” We are concerned that conditional language like this is tantamount to allowing planners an excuse to avoid the sometimes difficult task of finding and evaluating climate change information that may be applicable to the situation at hand. We see a high potential for this kind of omission to occur, given that the directives have provided so little guidance on where to find climate change information and how to incorporate it into assessment.

Defenders has submitted comments to the Forest Service pointing out these and other flaws in the directives, which will make it difficult for forest planners to realize the planning rule’s potential benefits to biodiversity over time. Stay tuned to find out if they take our recommendations into account.

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- who has written 22 posts on dotWild.

Aimee Delach is a Senior Policy Analyst at Defenders of Wildlife. Aimee develops policies to help land managers and decision-makers incorporate climate change threats into efforts to protect wildlife and habitats.

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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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