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Sage-grouse, Grazing Management, and Voluntary Permit Retirement

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Livestock grazing can negatively affect riparian areas that are important to sage-grouse and other wildlife in the West. Oregon Natural Desert Association

At least 26 land uses and related effects threaten sage-grouse, none more pervasive than domestic livestock grazing. The Bureau of Land Management (BLM), the largest landowner in the American West, administers approximately 18,000 grazing permits and leases to graze almost 13 million animal unit months on 160 million acres of public lands, including large swaths of sage-grouse habitat. The U.S. Forest Service also permits grazing on millions of acres of sage-grouse range. More than 99 percent of remaining sagebrush steppe has been affected by livestock and approximately 30 percent has been heavily grazed.

Grazing can negatively affect sage-grouse in a variety of ways1 and livestock management was an identified planning issue in each of the fifteen draft plan amendments and sub-regional environmental impact statements (plans) developed under the federal National Greater Sage-Grouse Planning Strategy.

In March, conservation organizations sent a letter to the Departments of the Interior and Agriculture urging the BLM and the Forest Service to adopt adequate regulatory mechanisms in the final plans to manage grazing to avoid harming sage-grouse—and to immediately incorporate them into grazing permits as terms and conditions for grazing use on associated grazing allotments. Current law allows both agencies to update grazing permits in the land use planning process, rather than wait to implement the new measures over many years as each 10-year permit comes up for renewal.

The organizations also recommended that federal agencies adopt measures to facilitate voluntary grazing permit retirement on allotments in sage-grouse habitat. While every one of the draft plans developed under the planning strategy would continue livestock grazing in sage-grouse range, most of them also recognized the benefits of eliminating grazing to conserve the species.2

In fact, all fifteen draft plans analyzed voluntary grazing permit retirement as a mechanism for conserving the species in at least one management alternative. Nine of them included some form of voluntary grazing permit retirement in their preferred alternatives (typically limited to priority habitat areas),3 including the now final Resource Management Plan for the Lander Field Office.4

Federal agencies are increasingly using voluntary grazing permit retirement to resolve grazing conflicts on public lands. Willing permittees are usually compensated by a third party to relinquish their grazing permits for retirement, typically by a conservation or sporting organization or other public lands user group.

Voluntary grazing permit retirement may be a particularly useful tool in sagebrush habitat mitigation programs, which could also provide the funds needed to facilitate retirement. Permit retirement offers measureable, and durable conservation benefits that comport with the U.S. Fish and Wildlife Service’s Greater Sage-Grouse Range-Wide Mitigation Framework (2014) and the Department of the Interior’s A Strategy for Improving the Mitigation Policies and Practices of The Department of the Interior (2014).

The BLM and Forest Service can improve voluntary grazing permit retirement provisions in the final sage-grouse plans. Many of the preferred alternatives in draft plans that would allow for grazing permit retirement also imposed extra conditions that could hinder retiring permits in practice. For example, some plans would require land managers to prepare additional (and unnecessary) analysis before determining whether to retire permits voluntarily relinquished by grazing permittees. Others would allow managers to accept permits for retirement, but then convert the associated grazing allotments into reserve allotments or grass banks for future grazing use, potentially diminishing their conservation value.

The BLM and Forest Service should adopt a simple, straight-forward provision in the Records of Decision for sage-grouse plans that would immediately retire grazing permits in priority habitat for sage-grouse wherever and whenever ranchers might decide to relinquish them. Doing so would be a win-win for wildlife and willing grazing permittees alike.


1 Livestock grazing is considered the single most important influence on sagebrush habitats and fire regimes throughout the Intermountain West in the past 140 years (Knick et al. 2005: 68). Grazing remains the most widespread use of sagebrush steppe and almost all sagebrush habitat is managed for grazing (Connelly et al. 2004; Knick et al. 2003; Knick et al. 2011). Livestock grazing disturbs the soil, removes native vegetation, spreads invasive species and limits productivity in sagebrush steppe (Knick et al. 2005; Knick et al. 2003; Reisner et al. 2013; West 1983). Cattle or sheep grazing in sage-grouse nesting and brood-rearing habitat can negatively affect habitat quality; nutrition for gravid hens; clutch size; nesting success; and/or chick survival (Connelly and Braun 1997; Beck and Mitchell 2000; Barnett and Crawford 1994; Coggins 1998; Aldridge and Brigham 2003). Livestock may directly compete with sage-grouse for grasses, forbs and shrub species; trample vegetation and sage-grouse nests; disturb individual birds and cause nest abandonment (Vallentine 1990; Pederson et al. 2003; Call and Maser 1985; Holloran and Anderson 2005; Coates 2007).

Grazing management was identified as a threat to sage-grouse by three expert panels and in recent reviews (Connelly et al. 2011b: 555-556, Tables 24.1, 24.2). Impacts attributable to historic or heavy grazing in sage-grouse habitat have not been remedied because plant communities are still not given rest from grazing, even under ecologically oriented grazing schemes (Connelly et al. 2004: 7-30 – 7-31, citing others). Furthermore, water developments have increased the area that can be grazed, increasing the distribution and often the intensity of grazing, so that even where livestock numbers have been reduced, they still exert a significant influence on those habitats (Connelly et al. 2004: 7-33). “Even though livestock numbers [are] considerably [reduced from historic use], and management across the West has steadily improved, acres continue to transition away from reference (historic, potential, and [or] desired) conditions” (Manier et al. 2013, citing Cagney et al. 2010). Federal government scientists have suggested that “livestock grazing across the public lands of western landscapes … will continue to impact the quality of those habitats and their ability to support source populations of sagebrush bird species” (Rich et al. 2005: 592).

2 The BLM has identified multiple benefits of eliminating livestock grazing in draft sage-grouse plans, including in the draft Northwest Colorado plan: “[e]limination of livestock grazing…would maintain or improve overall watershed health and water quality…decrease hoof compaction of soil surfaces. When combined with the annual freeze-thaw cycle, this may decrease soil bulk density and improve soil moisture conditions, which facilitates vegetation germination and root development. Removing livestock would also increase plant litter and live vegetative ground cover, which would provide more protection from wind and water erosion. Eliminating livestock grazing…would also eliminate water quality impacts associated with the deposition of manure and urine into surface water (Northwest Colorado: 776). As the agency stated in its draft supplement to the Bighorn Basin plan, “even where sagebrush steppe evolved with some herbivory, removing livestock from the landscape would be a net benefit for sage-grouse” (Bighorn Basin Supplemental ES-9, 4-76, emphasis added).

3 The draft Billings and Pompey’s Pillar National Monument (2-116 – 2-117, Table 2-6.2), HiLine (68), Idaho and Southwestern Montana (alternative D, vol. 2, 2-137, Table 2-18, D-LG/RM-7), Miles City (2-50, Table 2.1, Action 24), Nevada and Northeastern California (ch. 2, 207, Table 2-5, Action D-LG 23), Oregon (2-86, Table 2-6, D-LG/RM 26), South Dakota (37) and Wyoming (2-182, Table 2-5) plans include some form of voluntary grazing permit retirement in their preferred alternatives. Six plans considered voluntary grazing permit retirement in management alternatives other than the preferred alternative, including the Bighorn (Bighorn Basin Supplemental EIS: 2-35, Alternatives E and F); Lewistown (2-35, Table 2-4, Alternatives B and C); North Dakota (2-29, Table 2-3 (Alternatives B and C); Northwest Colorado (159, Table 2-4, Alternatives B and C); and Utah (2-83, Table 2-1, Alternatives B and C2) plans. The draft Buffalo plan proposed designating and managing “resource reserve” allotments in the preferred alternative (169, Table 2.31, Grazing-6020), which the BLM indicated in the draft Northwest Colorado plan could be created through voluntary grazing permit retirement (736).

4 Lander ROD: 98, Record 606. The Record of Decision for the Lander plan also defines grazing permit “retirement” as “[e]nding livestock grazing on a specific area of land” (i.e., the associated grazing allotment) (Lander ROD: 175).

Posted in Federal Policy, Imperiled Wildlife, National Forests, Public Lands0 Comments

Climate Change and NEPA: Getting it Right

Climate Change and NEPA: Getting it Right

The National Environmental Policy Act (NEPA) was signed into law in 1969 and has gone on to be one of our country’s most important environmental laws. The law creates a framework and process by which federal agencies must consider the impacts of their actions on the environment – including natural resources, human health, infrastructure, and land use. Since climate change is one of the most important environmental issues to emerge in the past few decades, and promises to remain so for the foreseeable future, it is clear that NEPA has an important role to play in how agencies consider the effects of climate change both on their investments, and also on the resources that their projects affect. It is increasingly critical for agencies to thoughtfully and thoroughly consider climate change, from both an emissions and adaptation standpoint, as part of NEPA analysis, particularly in the most detailed and through decision documents, Environmental Impact Statements.

In order to facilitate agencies’ consideration of climate change, the administration released Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions in 2010. The Draft Guidance clearly indicated that relevant climate information includes both greenhouse gas emissions information, and also climate change impacts and adaptation. To date, however, most of the attention paid to the guidance has been from the point of view of emissions analysis.

To get a better understanding of whether and how well agencies were incorporating the adaptation recommendations, we analyzed 154 Final Environmental Impact Statements released between July 2011 and April 2012. To our dismay, we found that very few incorporated the climate adaptation elements of the 2010 draft guidance. Even the best-performing EISs tended to incorporate climate change into a limited number of the elements of the affected environment, failed to make a full comparison between the various alternatives, or used short and qualitative statements rather than full analysis based on the best available science. We explore the possible reasons for this and present recommendations for overcoming these obstacles in our new report Reasonably Foreseeable Futures

The Chiracahua Mountains in the Coronado National Forest support the sky island ecosystems of the southwest, some of the most unique and biodiverse areas on our public lands.  Portions of the sky islands would be put at risk by this bill.

The Chiracahua Mountains in the Coronado National Forest support the sky island ecosystems of the southwest, some of the most unique and biodiverse areas on our public lands. These ecosystems are severely threatened by climate change, and climate-smart management will be key to their survival.


Posted in Climate Change, Federal Policy, National Forests, National Wildlife Refuges, NEPA, Public Lands, Smart from the Start, Uncategorized0 Comments

Spawning salmon

Oregon’s O&C Public Lands: Legacy, Legislation and the Future of these Federal Forests

Railroad companies interested in westward expansion in the 1800s got a great deal from the federal government. To spur development of rail lines, Congress regularly granted companies public land that they could then sell or develop as an economic incentive for their investment in building railroad infrastructure. These land grants were often conferred in a checkerboard pattern, with  alternating blocks of land given to the railroad companies and retained by the government, which has resulted in endless management challenges ever since.

Speed forward several decades. In 1916, Congress determined that the Oregon and California, or O&C, railroad project had failed to meet its commitments for rail development from, you guessed it, Oregon to California, and took back, or “revested” the land the government had granted the company. Congress subsequently enacted special legislation in 1937, the O&C Act, reclaiming the lands, which now comprise about 2.1 million acres in western Oregon. These O&C lands were to be managed by the Department of the Interior’s Bureau of Land Management, or BLM:

…for permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with the principal of sustained yield for the purpose of providing a permanent source of timber supply, protecting watersheds, regulating stream flow, and contributing to the economic stability of local communities and industries, and providing recreational facilities . . . 

Old-growth forest

Old-growth forest on O&C lands.
Credit: Chandra LaGue, Oregon Wild.

The O&C Act also granted the 18 Oregon counties where O&C lands are located 75 percent of revenues generated from timber sales on the these lands. The counties still collect at least 50 percent of timber revenues today.

Zip forward a few more decades, when technology allowed for massive clearcutting of forests throughout the Northwest, including on O&C lands. Huge volumes of timber came off public forests in the 1970s and 80s, producing huge amounts of revenue to the O&C counties (which also began to take the federal revenue for granted and kept their own property taxes among the lowest in Oregon). But that harvest was unsustainable and in the early 90’s it came to a head, as species like the spotted owl and marbled murrelet, dependent on complex old-growth forests, showed precipitous declines—indicators of the ecological problems created by unsustainable logging of ancient forests.

Old-growth logging and its environmental consequences ultimately became a political issue in the 1992 presidential election. Candidate Bill Clinton promised to do something about it, and soon after he was elected he convened a forest summit in the Northwest and established a science-based process for developing a plan to conserve forest ecosystems while supporting a sustainable timber supply and rural jobs. The “Northwest Forest Plan,” finalized in 1994, adopted a system of conservation reserves, created a “matrix” for managing forests outside reserves, and established management standards to ensure the persistence of the northern spotted owl and other old-growth dependent species, protect watersheds and salmon, and provide a sustainable timber supply.  O&C lands became a core part of the Northwest Forest Plan, and for the past twenty years, those lands have been managed under the standards and guidelines of the plan.

Spawning salmon

Threatened salmon spawn in streams that flow through O&C lands. Credit: Bureau of Land Management.

The Northwest Forest Plan was also paired with additional assistance to rural communities to provide job training and other measures to transition to a new economy less dependent on old-growth forest logging. These federal resources were of considerable benefit to individuals and communities who chose to avail themselves of them.

Zoom forward another two decades, and now we’ve arrived to our situation today. Some O&C counties have failed to diversify their economies, and a number of timber mills have not adapted to the market conditions of 2013. In addition, federal appropriations to counties that were part of the earlier transition package are drying up, leaving some O&C counties with major budget shortfalls. This is why there is intense political interest to “solve” the problems facing rural western Oregon.

Representative Peter DeFazio of Oregon has proposed disastrous legislation that would carve out over a million acres of the O&C lands, de-federalizing them by creating a timber “trust” managed by local counties, timber industry representatives and others for the sole purpose of expediting and increasing timber production. This proposal would essentially privatize lands belonging to all Americans for the narrow and exclusive financial benefit of local counties and the timber industry.

But the real action is with Oregon’s Senator Ron Wyden, chair of the Senate Energy and Natural Resources Committee. In June he released a framework for legislation to address the issues facing O&C counties which:

  • …sets aside a “substantial” but undefined portion of the 2.1 million acres of O&C lands for accelerated and expanded commercial logging at an uninterrupted rate—a rate that can only be ensured by restricting the application of federal environmental laws.
  • …calls for limiting environmental review to “an initial review of all lands set aside” for timber harvest. This so-called “modernization” of federal land management planning would require an override of consultation requirements under the Endangered Species Act (ESA), which are the heart of the ESA’s protection for imperiled species.
  • …is silent on the conservation of mature forests—stands aged 80-120 years—which are vital to the survival of salmon, spotted owls, and other imperiled fish and wildlife. While his framework takes no position on stands of this age class, it will be impossible to meet the elevated harvest targets that Senator Wyden is promoting without aggressive harvesting in these forests.
  • …re-links county revenue generation to logging on federal public lands creating a powerful constituency for unsustainable high levels of extraction.

Senator Wyden’s framework envisions significantly increasing timber harvest on hundreds of thousands of acres of federal forests above the allowable levels set by the Northwest Forest Plan. Intensive logging at this scale with only the barest, one-time programmatic environmental review would contribute to the serious decline or loss of many imperiled plant and animal species from Northwest forests. (Consider, for example, that in 1991, BLM sought approval to proceed with 44 timber sales on just 4,500 acres of old-growth forests, even though this logging would have put the continued existence of the northern spotted owl in jeopardy.) Plus, O&C lands are the heart of the Northwest Forest Plan and aggressive harvests will inevitably undermine conservation strategies for imperiled species like the spotted owl, marbled murrelet, and salmon, and necessitate greater mitigating harvest restrictions in California and Washington.

O&C lands are key to the success of the Northwest Forest Plan.

O&C lands are key to the success of the Northwest Forest Plan.

The framework put forth by Senator Wyden would also establish a negative precedent for managing public lands and resources. O&C lands are federal public lands that benefit all Americans, and narrow, special interest legislation that limits environmental review and dedicates large areas to a single extractive use is counter to both existing law and our modern values for administering the public domain. Unlike fun times in Las Vegas, what happens on O&C lands will not stay on O&C lands and will affect federal forest management in California and Washington, and beyond.

Finally, the Wyden framework is not a path to a healthy environment and a vibrant economy. Unsustainable logging is…unsustainable. The timber industry and affected counties must adapt to a reduced timber supply from public lands and O&C counties must finally raise their property tax rates so they are comparable to rates for other Oregon counties. Logging conducted with only cursory environmental review and planning would threaten a host of imperiled species and other values public forests provide, including clean water, wildlife habitat, recreation and sustainable economic opportunities that are the foundation of the new economy in the New West. Congress should provide support to O&C communities to transition to stronger economies, but without linking federal payments to arbitrary and fixed timber production targets.

Senator Wyden is expected to introduce legislation based on his framework later this summer. Defenders of Wildlife and partners have already signaled our concerns about the framework that he has offered in multiple communications to his office. We will continue to engage in the legislative debate on O&C lands to ensure that any future management scheme for O&C lands—public forests that support a breadth of public values—supports and reflects the broader public interest of all Americans.

Posted in ESA, Federal Policy, Legislation, National Forests, NEPA, Public Lands, Uncategorized0 Comments

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

Incorporating Climate Change into the New Forest Planning Rule

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.

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

How Will the Forest Service Address Ecosystem Services in Forest Planning?

How Will the Forest Service Address Ecosystem Services in Forest Planning?

The Forest Service recently adopted new planning rule that will guide the agency’s process for forest planning for the next decade or so. For the first time, the planning rule directs the staff to consider ecosystem services when deciding what management actions to implement on the public lands. Following the adoption of the new rule, the Service issued 500+ pages of detailed “directives” to guide implementation of the new planning rule.

What are ecosystem services?  According to a recent article authored by several researchers with the Forest Service in the Pacific Northwest Research Station, In the context of public land management, ecosystem services are beneficial outcomes that derive from landscape conditions (e.g., forest structures, species compositions) and ecological processes as they are altered by both natural disturbance and management activities.

Though the draft directives mention ecosystem services multiple times, what effect this relatively new term will have on the planning process remains somewhat of a mystery. On the positive side, addressing ecosystem services may lead to the consideration of a much broader spectrum of values, including some tangible benefits like improved water and air quality, more and better fish and wildlife habitat, improvement in the condition of endangered species, and additional opportunities for nature-based recreation. The new emphasis may also lead to improved integration across programs, a reconsideration of management “targets” to include an assessment of ecological conditions and trends, and an improved understanding of context implied in the new “all lands approach” to management.  Ecosystem services assessments can also be a powerful tool for collaboration with stakeholders. Ideally, incorporating ecosystem services into forest planning will add value without overly complicating the assessment and decision process, raising the costs, or delaying implementation.

On the flip side, even a great idea can go astray if it is implemented in a manner that simply applies a new idea or term to an old way of doing business. The Forest Service staff will always be under political pressure from Congress and some interest groups to increase the output of commodities at the expense of protecting the ecological values on the land. Framed entirely as a utilitarian, anthropocentric concept, some interpret ecosystem services to include only benefits to human communities. Others extend the construct even further to emphasize only those values that can be quantified, and a cottage industry has emerged among economists offering tools and methods to assign monetary value to selected services. While it is sometimes very useful to calculate the monetary costs and benefits of different management options, it is neither necessary nor appropriate to apply dollar values to relatively intangible attributes like biodiversity.  Agencies can and do make decisions every day based on society’s evolving values and preferences, expressed in a variety of ways including the adoption of federal laws like the Endangered Species Act and National Forest Management Act. Meaningful engagement with the public during the decision process – including local, state, regional, and national interests – can lead to decisions that balance human needs for products like timber, forage and fuel against the need to sustain the lands and waters on public lands for future generations.

Given the attention that ecosystem services have received within academic and some government circles, there is also a risk that instead of adding value to the complex process of evaluating the potential benefits an ecosystem will provide over time, an entirely new process will be established.  If this new process focuses primarily on the benefits that ecosystems provide to people, without giving adequate consideration to the underlying ecological attributes and processes that create these services in the first place, then management to maximize certain ecosystem services ends up competing with, rather than enhancing values that are especially challenging to measure, like biodiversity. If ecosystem services offer a way of viewing the world in which the intrinsic values of nature are acknowledged along with utilitarian outputs, it could serve as a uniting rather than divisive force.  However, there will always be tradeoffs between services, human beneficiaries, and the needs of present vs. future generations.

There are a few important steps that the Forest Service can take to ensure that the ecosystem services requirement in the new directives has a positive influence on forest planning.

  1. Adopt the definition of ecosystem services quoted above in place of the narrower definition limited by utility to humans, thereby explicitly including biodiversity – either as a service, necessary support for services, or both.
  2. Integrate ecosystem service assessments with ecological assessments rather than creating a separate process.
  3. Ensure that the planning process is as interdisciplinary as possible, taking advantage of the expertise of natural and social scientists, practitioners, and stakeholders, working across traditional boundaries and engaging people with diverse perspectives.
  4. Working with other agencies and organizations, invest in the development of more consistent measures of ecological integrity and biodiversity across jurisdictions and at multiple scales to improve our collective capacity understand ecological conditions and trends.
  5. Integrate the ecosystem services assessments with the “all lands” approach by engaging private landowners and other agencies in the process, before attempting to quantify and/or monetize ecosystem services at the project or site scale.

The Forest Service has struggled with communicating its mission over the past few decades. Creatively applying an ecosystem services approach to explain the benefits of the public lands to Congress and the public has great potential. Although different forests will likely approach this challenge differently, the new approach may create a pathway to a more harmonious and effective relationship with the public.  Or it may continue the divisive and antagonistic relationship under a new banner until the next shiny object comes into view. There isn’t much time to get it right.

You can find Defenders’ full comments on the proposed forest planning directives here.

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

Managing for the Unknowns: Adaptive Resource Management

I recently posted a guest blog on the Georgetown Public Policy Review discussing adaptive management.  Two key areas that can make or break the success of an adaptive management plan are the strength of the management triggers that frame future decisions, and the quality of information gathered through monitoring that forms the basis for management.  The blog discusses these potential risks and looks at the new Forest Service NFMA planning rule as an avenue for applying good adaptive management principles in practice.

Posted in National Forests, Public Lands0 Comments

Mining threatens important habitat on the Coronado National Forest

Mining threatens important habitat on the Coronado National Forest

Ocelot (photo: USFWS)

(Written with help from Matt Clark and Heather Murray.)

Defenders of Wildlife, along with a diverse set of partner groups, submitted comments this week on the Rosemont Mine proposal on the Coronado National Forest in Arizona.  The proposed open pit mine, just southeast of Tucson, would have a direct impact on 4,500 acres of the Santa Rita Mountain range, as well as impacts that would radiate far beyond the project’s footprint.

The Coronado NF provides vital recovery habitat for rare cats including the elusive jaguar and ocelot.  Last year a jaguar was spotted in the region for the first time in three years. In fact, this male jaguar was sighted roaming in a mountain range directly adjacent to the Santa Ritas, where Rosemont wants to dig its mine.  This come back story for jaguars can only carry on if intact, connected, suitable jaguar habitat is prioritized and protected in the region.  Projects of this size and scale on what is currently undisturbed suitable jaguar habitat give us great pause.

As the project proposal has been developed, some important species surveys needed to determine what wildlife would be impacted have not been completed.  Information related to biological resources has not been made available to the public, and impact analysis of key biological and hydrologic resources in the Rosemont area are lacking.  Similarly, analyses of the project’s potential contribution to climate change are completely inadequate.

As the comment letter states:  “The biological and ecological resources of the Rosemont area are unique and of both national and international significance. Hundreds of rare and regionally endemic species occur in the project area.  Neither the Proposed Action nor the Preferred Alternative . . . identify mitigation that is adequate to protect the Rosemont area’s biological resources.”

Groups highlighted a host of other concerns in the letter, from water quality impacts and water volume use to increased traffic and air pollution.  One key request from all groups is for the Forest Service to do its due diligence and provide a supplemental environmental review that fully analyzes the potential threats and impacts.  We will continue to push for additional information to be gathered and reviewed.

Similar issues have come up in other mining projects on the Coronado NF – major environmental impacts with insufficient review.  In fact, Defenders recently challenged an exploratory mining project in the region that was approved without NEPA review.

Last month, Defenders filed suit against the Forest Service in response to its approval of the Hardshell Minerals Exploration Project – located in the Patagonia Mountains approximately five miles south of the town of Patagonia, AZ – which would allow for the drilling of fifteen exploratory holes in an area known for its pristine natural landscapes and rich biological diversity.  The project as approved would involve around-the-clock drilling seven days a week, increase traffic to and from the area, and create significant noise and light impacts, among others.  Perhaps most alarming is that this mining company started a wildfire that burned almost 400 acres of the Coronado NF while conducting similar activities on their private in-holding adjacent to the proposed project area last May.

Despite the potential effects of this project on threatened and endangered species in the area – including the jaguar, ocelot, Mexican spotted owl, and lesser long-nosed bat – the Forest Service approved this project without NEPA environmental review.  Likewise, the Forest Service failed to consider the fact that two other similar exploration projects are currently proposed within just a few miles of the Hardshell project, greatly expanding the overall footprint of exploratory drilling in this area.  Defenders is concerned about the significant and cumulative environmental impacts of exploratory drilling at multiple sites in this Sky Island mountain range and the broader region.

It might not come as a surprise to learn that Rosemont Copper and Wildcat Silver, the two companies pushing for these mines to be permitted, are not only both Canadian-owned companies, but they also share some of the same board members. We are making sure that these companies follow the letter of the law to avoid undue harm to our precious wildlife, water and natural heritage.

Posted in Imperiled Wildlife, In the Field, National Forests, Public Lands, Southwest0 Comments

Dinkey Landscape Restoration Project Area

Defenders Focal Forests: the national forests of the Sierra Nevada

The Dinkey Landscape Restoration Project Area on the Sierra NF (Photo: Pamela Flick)

California’s Sierra Nevada region is rich in biodiversity and hosts an incredible array of plants and animals, with 572 vertebrate species that spend at least some point of their life cycle in this iconic mountain range, including critically imperiled species like Pacific fisher and California spotted owl.  In particular, the ten national forests of the Sierra provide rich habitat worth protecting and restoring for current and future generations.  From the Sequoia National Forest southeast of Fresno to the Lassen National Forest near Redding, nearly half of the land base in the Sierra Nevada is managed by the U.S. Forest Service as part of the National Forest System.

Defenders of Wildlife is engaged in a number of important processes happening now that will impact wildlife in the Sierra Nevada well into the future.

Over the next few years, most of the Sierra forests will undergo management plan revisions.  This means that new plans will be written, with public input and environmental review, to guide the management of the forests for the next few decades.  The development of ecologically sound plans will be of utmost importance, since the plans will impact all aspects of forest management for decades to come, including how key habitats will be managed to benefit the wide variety of wildlife found on national forest lands in the Sierra.

In addition, on the ground projects are enhancing wildlife habitat.  On the Sierra National Forest just south of Yosemite National Park, a pilot project is demonstrating how the restoration of forest ecosystems can improve habitat while creating jobs and protecting local communities.  The Dinkey Landscape Restoration Project was selected for funding under a new law, which established the Collaborative Forest Landscape Restoration Program (CFLRP).  Ten CFLRP projects around the country were selected, including the Dinkey Collaborative on the Sierra National Forest, to bring together local stakeholders to get restoration work done.  Over the course of ten years, thousands of acres of restoration treatments will be undertaken by the Forest Service with guidance from the Dinkey Collaborative, based on agreement and understanding among participants, leading to fewer conflicts and an increase in the amount of ecosystem restoration that can be accomplished.

Members of Congress are touting the success of the CFLRP model and are asking that the program continue to be fully funded, highlighting that the first ten CFLRP projects collectively created or sustained more than 1,500 jobs and reduced wildfire risk on 154,000 acres in just one year.

In a series of “Focal Forest” blogs, we will be highlighting the work we’re doing in the Sierra Nevada and the importance of protecting this special region for wildlife and for future generations.

Posted in California, In the Field, National Forests, Public Lands0 Comments

Bill to protect national forest roadless areas introduced

Bill to protect national forest roadless areas introduced

A bipartisan group of more than 130 members of Congress (House & Senate) have joined together in support of legislation to protect 58.5 million acres of wild national forest land in 38 states by codifying the Roadless Area Conservation Rule.  The roadless rule administratively identified areas on our national forests that have not been dissected by roads and established conservation based management guidelines for those areas.  This bill will ensure that the rule endures against efforts to open these lands to development and last through changing administrations.  The bill was introduced by Representative Jay Inslee (D, WA) and Senator Maria Cantwell (D, WA).

The roadless areas protected under the rule are fundamental to the recovery of imperiled species that need undeveloped and intact habitat to survive.  Testimony this week in Congress on the road and trail system on our national forests highlighted an increase in wildlife presence in the Carson National Forest in New Mexico once road system management was reevaluated and improved, leading to the closure of roads that were no longer necessary, that caused environmental harm, and that were too expensive to continue to effectively maintain.

Beyond wildlife, there are many additional benefits we gain from roadless areas.  National forest lands provide drinking water to tens of millions of Americans – high road density and poorly maintained roads lead to sedimentation and water quality degradation that directly affects downstream communities.  National forests also generate $100 billion in annual revenue, and support an estimated 223,000 jobs in rural communities.

The roadless areas established by the Forest Service ten years ago should not be confused with big “W” Wilderness areas, which can only be designated by Congress.  Wilderness areas are managed under strict rules that don’t allow any motorized uses or machinery.  Roadless designations are much more flexible; they require management for conservation but are not a complete ban on road building or economic utilization.  For instance, the rule allows new roads to be constructed in specified circumstances, such as to fight fires or when other natural events threaten public health and safety.  It also does not close any existing roads or trails and allows full access for recreational activities such as backpacking, camping, hunting and fishing.  The legislation would not affect the right of access to property owned by states or individuals, and would allow logging of certain timber to reduce the risk of wildfires and the expansion of oil and gas operations within existing or renewed leased areas.

In the face of unprecedented attacks on our public lands by those that would sell them or open them up for unlimited development, to have more than 130 members of Congress stand up and declare their support for the continued protection of these valuable forests is a powerful statement.

Defenders is part of a conservation community press release announcing the introduction of the bill.

Posted in National Forests, Public Lands0 Comments

Report From the Public Land Law Conference

Report From the Public Land Law Conference

Two Defenders staff members are attending the Public Land Law Conference at the University of Montana Law School this week.  The theme this year is “Strengthening our Roots: Forest Law and Policy in a Changing World.”  The conference is covering subjects including the new forest planning regulations, climate change law and forests, forests in the media, and collaboration.

Professor Charles Wilkinson delivered the keynote for the conference, providing his assessment of the current state of the Forest Service.  His presentation covered most of the subjects of the conference, but he focused in on one very timely issue: species diversity in the new Forest Service forest planning rule

Professor Wilkinson started with the history of the species diversity mandate.  The incorporation of species diversity requirements into Forest Service regulations was a historic moment, no previous law had provided for species diversity, not even the Endangered Species Act.  The current proposed regulations, however, contain no species diversity requirements. Instead of Management Indicator Species, which have been used to monitor biodiversity since the 1980s, the new rule would require each forest to determine Species of Conservation Concern (species that are stressed, but don’t necessarily tell us about species diversity more broadly) and Focal Species (species that are monitored but are not necessarily linked to broader species diversity).

According to Wilkinson, refusal to adopt a modern and scientifically supported species diversity plan is the biggest problem with the proposed new rule.  This lack of species diversity mandates is exacerbated in the proposed rule for two reasons.  First, science need only be “taken into account,” a phrasing that Prof. Wilkinson compared to “taking into account” the grizzly in the corner.  Second, most decisions will be made at forest level with broad discretion, meaning that there will be little court review of these plans.  This is all the result of the Forest Service trying to stay clear of litigation, encouraged by lawyers that seek to make plans “bullet proof.”

Professor Wilkinson’s keynote is especially relevant now, as the Forest Service is set to release a finalized version of the planning rule later this year.

Posted in National Forests, Public Lands0 Comments

Climate change and Greater Yellowstone fire regimes

Last week’s issue of the Proceedings of the National Academy of Sciences  included a compelling article by western fire researcher Tony Westerling and colleagues. The title, “Continued warming could transform Greater Yellowstone fire regimes by mid-21st century,” caught the attention of a lot of blogs and other media outlets.

Westerling and his co-authors modeled changing fire regimes in the Greater Yellowstone ecosystem  by looking at past correlations between climate data and the size and occurrence of large fires, then projecting those trends forward to see how often fire could be expected to burn a given area under likely future climate conditions. Today the Greater Yellowstone area is dominated by conifer forests that are characterized by infrequent but severe fires. Every 100-300 years or so, major fires sweep through these ecosystems, killing a large proportion of trees in the affected area and starting the succession process over by providing shade-sensitive species with access to sunlight.

However, this new research suggests that an increase in temperatures of just a few degrees by mid-century could have profound effects both on patterns of fire in the Yellowstone area and on the ecosystems and species found there. All of the modeling results pointed to a more rapid fire cycle, with a given area burning every 30 years or less by 2050. As Westerling et al. point out, this kind of fire regime would also indicate a significant shift from the current mixed conifer forest type to something much different, something more like a dry woodland or unforested ecosystem. Such a complete shift in vegetation would obviously have dire impacts on many of the species that currently inhabit that area.

When we talk about helping ecosystems adapt to climate change, we often tend to imagine – and plan for – a gradual, almost imperceptible shift in conditions over long periods of time. But many scientists have shown that ecological systems can contain hidden transition points, thresholds beyond which rapid, extreme changes  in ecosystem structure and function may be unavoidable and virtually irreversible. Westerling’s paper shows us is in quite vivid terms what ecological thresholds might look like on the ground, and it gives us a frightening glimpse of how soon climate change might start pushing us across these thresholds. How would we go about managing the transition to an unforested Yellowstone?

Posted in Climate Change, Imperiled Wildlife, National Forests, Northern Rockies, Public Lands, Uncategorized0 Comments

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.