Tag Archive | "National Forest Management Act"

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??

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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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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.

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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?

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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.

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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!

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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

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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.