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Defenders Comments on New Forest Planning Directives

Defenders Comments on New Forest Planning Directives

As long time followers know, Defenders has been working hard to shape National Forest conservation policy for decades, including non-stop campaigning for the last several years to make sure new forest planning regulations conserve and recover forest dependent wildlife.  To ensure that these new rules translate into real on-the-ground protections for wildlife and forest ecosystems, Defenders kicked off our Forests for Wildlife Initiative.  The goal of the initiative is to transform how the Forest Service manages forests for wildlife, and to protect and restore national forest landscapes through on-the-ground conservation projects and actions.

The Forests for Wildlife Initiative takes us from the policymaking world of Washington D.C., to the majestic landscapes of Alaska and California.  Last year, I was appointed by the Secretary of Agriculture to a Federal Advisory Committee charged with overseeing implementation of the new planning rule.  One of the committee’s first tasks was to work with the Forest Service to craft policy “directives” that will guide how the new regulation is interpreted and applied to individual national forests.  Our comments on the draft directives can be found here.  The complex forest policy world is like an onion trapped in a spider’s web.  Numerous statutes govern the management of National Forests, including the National Forest Management Act, as well as associated federal rules and regulations.  Keep peeling and one finally gets down to the highly technical internal agency policies that tell forest managers how to navigate and implement all of the various rules and regulations.  The directives tell managers “how” to do the “what”— the requirements that are spelled out in the regulations.  Good planning directives provide strong, clear direction to managers on how to identify, conserve and monitor species of conservation concern; account for ecosystem services; or manage in the face of climate change.  Poor directives can lead to inconsistent conservation decisions that could lessen protections and raise risks for forests and wildlife.

The current draft directives need some work to provide forest managers a clear path to effectively conserving forest integrity and wildlife.  The advisory committee will be working with the Forest Service all summer to make recommendations on how to improve them.  Stay tuned for more updates and campaign reports from the Forests for Wildlife Initiative.

Posted in Climate Change, Federal Policy, National Forests, Public Lands0 Comments

Defenders offers recommendations for sage-grouse conservation

Defenders offers recommendations for sage-grouse conservation

Photo: C. Robert Smith Elk Meadow ImagesNational Geographic Stock

Defenders submitted comments today to the Bureau of Land Management and the Forest Service highlighting important issues as the agencies undertake to revise their land use plans to conserve and recover the greater sage-grouse. A few key points from our comments:

  • A scientific panel selected by the BLM outlined conservation measures that are an important starting point for this process in the 2011 ‘Report on National Greater Sage-Grouse Conservation Measures’These conservation measures should be put into practice to the fullest extent possible throughout the greater sage-grouse range.
  • The agencies indicate that they plan to use “adaptive management”. In order to do so effectively, we urge them to develop a scientifically legitimate adaptive management strategy that commits to reduce uncertainty and improve conservation through the use of ecologically grounded quantitative triggers rather than simply providing the agencies with flexibility and discretion that result in “trial and error” management.
  • BLM and the Forest Service should not assume that as long as “some” regulatory mechanisms are put in place, they will be adequate to avoid listing under the ESA.  There are other factors that will go into a decision whether to list the greater sage-grouse, and these two agencies represent only part of the picture.  Instead, they should approach this process understanding that listing could still occur, and use this analysis and planning to both try to avoid listing and to be better prepared if listing is unavoidable.
  • A targeted multispecies approach is more efficient than a narrow single-species approach; by looking at what other wildlife species can benefit from sagebrush ecosystem conservation, the agencies take advantage of the opportunity at hand, and gain additional benefits from work already being done.
  • The agencies should develop a mitigation framework and policies that achieve a measurable “net conservation benefit” standard.  It is necessary that any development within the sage-grouse range leave the bird better off than it was – holding steady at the status quo will not be enough to recover the species.
  • The Forest Service should play a key role.  They operate under wildlife protection regulations and policies that are unique from those that govern the BLM.  They must meet all of their existing statutory, regulatory and policy obligations in this conservation and decision making process.  In addition, the Forest Service must strive to embrace emerging conservation policy goals found in the new National Forest Management Act planning regulations.
  • We encourage BLM and FS to fully consider the risks caused by renewable energy development to sage-grouse and the sagebrush steppe ecosystem and to err on the side of caution in the development of new management standards and conservation measures.

You can read our full comments here.

Posted in Imperiled Wildlife, Public Lands0 Comments

Greater sage-grouse the focus of a new conservation planning effort

Greater sage-grouse the focus of a new conservation planning effort

Photo: C. Robert Smith/Elk Meadow Images/National Geographic Stock

This week the Bureau of Land Management and the Forest Service have initiated an effort to develop new conservation measures for greater sage-grouse, a sage brush ecosystem dependent species that has faced a dramatic decline, losing more than half its population since the late 1960s as a result of development across the western United States.  The greater sage-grouse is famous for its elaborate mating dances, but their significance goes much further – the decline of sage-grouse indicates a downward trend in the fragile sage brush ecosystems of the west, in which many species depend on the greater sage-grouse.  If the sage-grouse is in trouble, so are many other species.

Threats to the greater sage-grouse identified by the agencies include minerals development (oil and gas, coal, hard rock etc.), energy transmission, renewable energy development, fire, invasive species, grazing and off highway vehicle use.  Impacts from climate change only amplify these stressors.  Cumulatively, these threats have lead to a decline of greater sage-grouse on public lands at the same time that development and land use change has impacted populations that depend on private lands.  Between the BLM and Forest Service, 59% of the greater sage-grouse range occurs on public lands.

Since April 2010 the greater sage-grouse has been considered “warranted but precluded” from Endangered Species Act (ESA) listing, meaning the Fish and Wildlife Service (FWS) considers the species potentially in need of listing as endangered, but has higher priority species that need to be dealt with in the near term.  A recent settlement has put the FWS on track to make a final listing decision on the greater sage-grouse in 2015.

It is in response to this ramped up timeline that the BLM and FS have jumped into action.  The FWS pointed to deficient land use plans as a primary reason that greater sage-grouse do not have adequate regulatory mechanisms to stop the species decline.  The agencies hope that this process will put regulatory mechanisms in place that are strong enough to preclude ESA listing.

The new process will split the sage-grouse range into east and west regions and split even further into smaller regional environmental impact statements.  The planning process will look at 77 planning areas on BLM and Forest Service lands and seek to amend those plans that need enhanced greater sage-grouse conservation measures to protect the species.  It will also envelop planning process currently underway, including Wyoming’s great sage-grouse plan, and should incorporate emerging sources of information, like climate change impacts studied in the BLM’s Rapid Ecoregional Assessments, as they become available.

Scoping comments on the greater sage-grouse planning process are due February 7, 2012.

Posted in Imperiled Wildlife, Public Lands0 Comments

Forest rule receives national interest

Forest rule receives national interest

As the public comment period on the Forest Service proposed planning rule came to an end last week, newspapers around the country provided extensive coverage of the concerns brought forth by the public and weighed in on the proposed rule through editorials.  Some clips and highlights are provided below.

From The Los Angeles Times:

Hundreds of conservationists, scientists and federal lawmakers have called the proposed new rules a big improvement but say it’s crucial that the Forest Service go several steps further in spelling out protections for watersheds and wildlife to ensure that the national forest system remains a bulwark to guarantee healthy wildlife populations and clean water.

“We have always maintained that our federal lands, our public lands, should be the front lines of healthy landscapes. They should be the front line of species conservation,” Jamie Rappaport Clark, former U.S. Fish and Wildlife Service director, now with the Defenders of Wildlife, told reporters in a briefing organized by the Pew Environment Group. “But the rule is actually far weaker than the almost 30-year-old rule it would replace.”

From The AP:

. . . Jamie Rappaport Clark, a Defenders of Wildlife executive and former U.S. Fish and Wildlife Service director . . . said forest supervisors being given unprecedented discretion under the new rules need strong standards and guidelines to resist the political pressure they regularly face in making decisions on managing their lands.

Opinion piece from The Olympian:

The Forest Service is proposing a new set of management rules. The new proposal has some laudable features. It acknowledges the crucial importance of maintaining federal forests in good ecological condition. And it’s full of sound concepts and helpful guidance for managers.

Where the rubber meets the road, though, it falls naively short.

It fails to deliver the kind of strong direction that saved Washington’s forests the last time around. Instead, it leaves the tough choices to local decision makers. It counts on them to make the right call no matter how much pressure they’re under from commercial interests and politicians, how little time and budget they have to track down and learn the relevant facts and science.

That’s not the kind of uncertainty we need for these forests. We need to take harmful options off the table. We need strong rules that will keep local agency officials out of trouble. We need something we can rely on to restore and maintain thriving fish and wildlife populations, clear-running rivers, and old growth forests.

Editorial from The Santa Fe New Mexican:

Suddenly, science’s role is reduced; the managers of 155 national forests and grasslands still will need to nod in its direction — but may feel free to ignore scientific findings as they consider industrial impact on clean water, fish and wildlife habitat and endangered-species protection. Hint, hint: If a developer sells a bill of goods about his project’s economic impact, well maybe biologists’ and geologists’ concerns about environmental effects aren’t that important after all …

Editorial from The Missoulian:

The proposed rule contains a number of changes, many of them word substitutions whose importance may be difficult to discern without deeper research. What, for instance, are the ramifications of re-naming “indicator species” to “species of concern” when it comes to endangered species management? Or of placing greater emphasis on the impacts of climate change? Or of emphasizing the importance of science in decision-making??

Posted in National Forests, Public Lands0 Comments

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.

Posted in National Forests, Public Lands0 Comments

Experts call for stronger forest rule

In recent weeks, news coverage of the National Forest Management Act planning rule has been increasing as the public comment period comes to a close.  Here are just two excerpts from guest opinion pieces that have been published around the country:

In the Arizona Daily Star, U.S. Representative Raul Grijalva (D, AZ) wrote:

The current rule is built on the notion that the health of our national forests and their waters and wildlife are as important as other uses such as timber harvests. And the way to ensure that the Forest Service lives up to this standard is to require forest managers to protect and maintain healthy watersheds and wildlife populations. When the fish and wildlife are doing well, it means our national forests are being responsibly managed.

The Obama administration’s proposed rule, however, is muddy on which animals – and how many – will be protected and monitored. It also lacks clear direction and binding, enforceable standards to ensure the protection of watersheds and wildlife in our nation’s forests.

Instead, the new rule gives nearly complete discretion to forest managers to decide which animals are deserving of protection and which are not – potentially limiting the role of science and scientific experts in management decisions.

In the Denver Post, scientists Barry Noon and Dominick DellaSala wrote:

The Forest Services’ planning rule sets a bold vision but is short on particulars. It acknowledges the need for public input on forest planning and, because National Forests differ from place to place, maintains that forest plans should reflect some local differences. The agency also recognizes that management decisions need to be grounded in sound science. But the devil is in the details. A closer look reveals that science only has to be considered, not actually used in forest plans. And while forests differ, the rule should ensure that clean drinking water and fish and wildlife have solid protections on all Forest Service lands.

These articles and others (including this N.Y. Times editorial) all come to the same conclusion:  The proposed forest planning rules needs strengthening so that it can effectively protect wildlife, water, and other resources into the future.  Defenders of Wildlife will be submitting detailed comments next month laying out our vision for strengthening the planning rule – look for more information here.

Posted in National Forests, Public Lands0 Comments

Our Questions on the Forest Planning Rule

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:


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?

Posted in National Forests, Public Lands2 Comments

Wildlife in the proposed Forest Rule

Wildlife in the proposed Forest Rule

Here at Defenders we’ve spent the last week reading, thinking about, and evaluating the new Forest Service planning rule.  We’ve previously publicized our expectations for the rule, but as you can see from our initial response, our expectations have not been met.  Here are the key problems for wildlife in the proposed rule:

The American marten depends on national forest land to survive.

The viability standard is discretionary

A viability standard requires that the long-term persistence of all fish and wildlife be provided for.  The version of the standard proposed in the rule, however, only applies to those “species of conservation concern” for which the local forest determines there is “evidence demonstrating significant concern about its capability to persist.” The proposal does not set out clear criteria for how local forests are to make the critical determination of whether a species does or does not receive protection under the viability standard. Formal mechanisms for determining the long-term persistence of a species, such as population viability analysis, are not required. Criteria will instead be relegated to the FS Directive System.

Protections are not clearly defined

It is not clear what level of protection the standard affords a species. Under the proposed rule, a population’s viability is based on an undetermined relationship between the population’s distribution and the population’s ability to be “resilient and adaptable”. Because the terms “resilient and adaptable” are not defined, it appears that a local forest could determine at its discretion when a population is sufficiently distributed to meet the standard.

The “external factors” clause is ambiguous

Local forests are not obligated to meet the viability standard if the forest manager decides that the forest is incapable of supporting a viable population. While a reasonable “external factors” clause is good policy, the proposal introduces a non-standardized approach that would allow each forest to determine when the “inherent capability” of a forest precludes the obligation to maintain viable populations of species of conservation concern

The results of applying the standard are not evaluated through monitoring

In addition to the above weaknesses, there is no requirement to monitor the actual species of conservation concern to determine if the viability standard is being met.

The Forest Service justifies the narrow and discretionary viability standard by assuming that “healthy and resilient” ecosystems will “maintain species diversity.”

Unfortunately, no clear mechanism is provided to verify that ecosystems are in fact meeting species diversity objectives.  It is not clear how the local forest will define and interpret their obligations, and monitor their achievements under the “healthy and resilient” ecosystem standard.

The assumption that healthy and resilient ecosystems support species diversity could be verified if the rule required population monitoring of focal species to demonstrate that species diversity objectives are actually being met.  Unfortunately, the rule only requires a local forest to monitor the “status” of focal species to “gauge progress” toward achievement of planning objectives.  The failure to establish a management standard for focal species makes monitoring a paper exercise and fails to provide for any accountability.

You can learn more about what Defenders is doing to strengthen the rule here.

Posted in National Forests, Public Lands, Uncategorized2 Comments

Obama’s Forest Rule: Seeing the Forest for the Wildlife

Obama’s Forest Rule: Seeing the Forest for the Wildlife

President Obama’s draft forest rule is coming soon, and here at Defenders we’ve been thinking a lot about what a successful rule will look like (see our full report here).  This rule will be about so much more than just forests – it’s about the wildlife that depend on our national forests, the water that millions of Americans drink every day that is sourced from national forests, and creating resilient ecosystems that can stay vibrant in the face of climate change.  For us, of course, the protection of wildlife is job number one.  Here are the three key components of wildlife protection that we’ll be looking for in the forest rule:

The American marten depends on national forest land to survive.

Mandatory Species Viability Standard

The Forest Service has a duty to protect biodiversity on the national forests.  For decades, a clear and nondiscretionary species viability standard has been in place as a measure to live up to this duty, and we want to see this standard carried forward.  A viability standard works by requiring that management actions provide for the long-term persistence of fish and wildlife on our national forests.  This means that as the Forest Service plans for the future, the impacts that actions will have on fish and wildlife must be weighed and considered to be sure we aren’t hurting their chance to survive and thrive on our public lands.

Scientists suggest that the viability standard should allow a small loophole – an exception for “external factors” – so that the Forest Service isn’t held responsible when factors beyond its control (like activities on neighboring land) cause a species to decline.  We support the use of such an exception, however, it will only work if applied only when absolutely necessary, and we will be looking for a clear definition.

Assessments of risk to wildlife and habitat

The rule must establish a process for assessing and responding to threats to fish, wildlife and habitat in the development and implementation of forest plans.  The Forest Service cannot maintain the viability of species if it is unaware of what threats to viability exist.  By assessing the likely impacts of climate change on sensitive species, for example, forest managers can take actions to help those species withstand future changes.  We will be looking for strong assessments to inform smart forest management.

A scientifically defensible monitoring program

Forest plans are really all about implementation, and investments in assessments and planning must pay off in good on the ground decisions.  To determine if forest plans are effectively doing the things they say they will, including providing for the long-term persistence of fish and wildlife, the rule must include a science-based monitoring strategy that can be applied to every forest.  Successful monitoring and strategic evaluation is all about collecting the right bits of information that tell you a lot about your effectiveness without wasting time and money.  To evaluate an ecosystem, you need to look at its key components, the elements that make the system tick.  To ignore critical components is to deprive oneself of invaluable information, at the risk of not realizing when the condition of a forest may be collapsing.  For that reason, evaluating a forest’s entire condition based only on the status of it’s trees, and not actual wildlife populations, is like a doctor telling a patient their heart is healthy because they “appear to look good” while ignoring their blood pressure.  We will be looking for a monitoring program in which targeted population surveys for a small group of key wildlife species are used to validate that forest plans are effectively making forests healthier.

Those are our expectations; what are yours?  We welcome your questions and comments!

Posted in National Forests, Public Lands2 Comments

Obama’s Forest Rule:  A checklist for success from Defenders of Wildlife

Obama’s Forest Rule: A checklist for success from Defenders of Wildlife

Cover of the Obama's Forest Rule reportA new report from Defenders of Wildlife provides a checklist for evaluating President Obama’s 2011 forest planning rule, likely to be released in draft form later this month.  The forest planning rule drives planning and management on every acre of our 190 million acre National Forest system, and impacts the lives and livelihoods of millions of Americans.  The report introduces a step by step grading system for the new planning rule in four critical categories: wildlife and watershed protection, climate change response, the use of science, and consistency of approach.

See our checklist below and read the full report to learn more.

Image of checklist from Obama's Forest Rule report

Posted in National Forests, Public Lands1 Comment

“To put it bluntly, we have a mess on our hands.”

No, these words were not uttered by Nancy Pelosi on November 4th, but by the late Senator Hubert Humphrey in response to major mismanagement of our national forests in the 1970s, including controversial clearcutting on West Virginia’s Monongahela National Forest. Congress responded by passing  the National Forest Management Act (NFMA) in 1976, which required the Forest Service to draft comprehensive plans for individual forests and to “provide for diversity of plant and animal communities” when managing those forests.  This provision is considered to be the strongest mandate in federal land law to conserve biodiversity.

Rules for implementing the NFMA were created during the Reagan administration.  Those regulations put a finer point on the plant and animal diversity provisions and required the Forest Service to “maintain viable populations” of native species in the national forests.  A viable wildlife population is a distinct group of animals that are likely to persist over time because they have sufficient numbers and habitat to reproduce and survive.  Loss of individual wildlife populations contributes to the epidemic of species extinctions.

The Reagan-era regulations have stood the test of time, despite attempts by the Clinton and both Bush administrations to revise the forest planning rules.  The Clinton rules, drafted with the support of an advisory Committee of Scientists, were abandoned by the incoming Bush administration who found them to be a bit too scientific, yet Bush’s attempts to rollback the rules were judged illegal by the courts.  As a result of all this confusion, the Forest Service is in regulatory no man’s land, operating under the ambiguous “transition provisions” of the Clinton planning rule.

So here we go again. The Obama administration has proposed yet another rewrite of the forest rules.  Why the need for change you ask?  Good question.  While many of the fads of the 1980s have gone out of style, certainly the commitment to conserving wildlife and their habitat on our public lands has not.  The forest rules do need to be modernized to address emerging conservation challenges, such as the impact of climate change on forest ecosystems.  However, this administration should resist the urge to weaken wildlife diversity provisions by inserting undue discretion into the new rules.  While it may be rational for agencies to seek to maximize their discretion, the results can be less than optimal in terms of the public interest. When it comes to managing the people’s lands, discretion cannot trump accountability.  To that end, Defenders of Wildlife is working to ensure that the new Forest Service regulations are held to a high conservation standard.  Stay tuned to this blog for insight into the NFMA rulewriting process.  The Forest Service intends to release a proposed rule along with a draft environmental impact statement early in 2011.

Posted in National Forests, Public Lands1 Comment

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.