Tag Archive | "National Forests"

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 LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

Tongass

Bills to “give away” public lands move forward despite harms to wildlife and water

Congressman McCarthy’s Wilderness and Roadless Area Release Act seeks to give away some of the last best places on our public lands, and allow private industrial development to move forward in these valuable areas.  The bill would reverse protections on up to 55 million acres of Inventoried Roadless Areas (IRAs) in National Forests and 6.7 million acres of Wilderness Study Areas (WSAs).

However, a timely report from the Geos Institute shows that there is a great deal of value in protecting unroaded areas, like IRAs and WSAs, throughout our public lands.  The report indicates that the roadless areas in our national forests alone are responsible for approximately $490 million in water purification services.  These benefits go beyond the dollar value of clean water – they provide healthy aquatic ecosystems and vital habitat for endangered and imperiled species.

The Tongass National Forest is threatened by a new Alaska-specific bill.

Despite these benefits, McCarthy’s bill to undo protections on as much as 60 million acres of our public lands has been scheduled for a hearing this Tuesday, and it will be interesting to find out what arguments bill supporters use to try and explain away the vast reach of the bill.  No doubt their primary message will be that lands currently designated as Roadless and Wilderness Study Areas are “locked up” and cannot be used by industry.  This argument truly misses the mark, as I’ve discussed before, and as the Geos report indicates regarding water, just one of many valuable services provided by undeveloped lands.  Defenders of Wildlife has developed a Wilderness and Roadless Area Release Act fact sheet with additional information on its potential impacts, as have some of our partners.

While McCarthy’s bill is attacking Wilderness Study and Inventoried Roadless Areas nationwide, some members of the Congressional delegation from Alaska have put forth their own, Alaska-specific bill that would exempt the Tongass and the Chugach National Forests from roadless protections.  This means that all of the designated roadless areas in Alaska would be released and be on the table for development.  Roadless areas in Alaska cover about 15 million acres and contain some of the largest intact areas of old growth temperate rainforest on the planet.  The radical move of exposing these vast areas to development would deliver a setback to the Tongass National Forest where a transition from damaging and controversial roadless and old growth logging toward more sustainable economic development promises to support communities and maintain the healthy and unique ecosystems of southeast Alaska.

Posted in National Forests, Public LandsComments (0)

Defenders fights coal to protect wildlife and the Powder River Basin

Defenders fights coal to protect wildlife and the Powder River Basin

Thunder Basin National Grassland

The Thunder Basin National Grassland (photo from the U.S. Forest Service)

There are many environmental impacts from coal production and use, from safety threats to miners, to the landscape-level impacts of mountaintop removal and strip mining, to the resulting carbon emissions that cause global climate change.  Wildlife is one of them.

Coal mining occurs on our public lands throughout the country, especially in the West.  Some mines literally consume thousands of acres of land and require a great deal of infrastructure and resource consumption (especially and most notably, water).  These land uses destroy habitat, kill individual plants and animals, drive away local populations of wildlife, and force wildlife to compete with each other for less space and less food.  These mines also create huge barriers between areas of healthy habitat, leading to a loss of connectivity that prevents wildlife from moving through the landscape in search of food and mates.

Unfortunately, even as the public and Defenders urge our leaders toward a clean energy future, the threat of mining is far from over.  Secretary Salazar recently announced that the Department of Interior and the Bureau of Land Management would seek to expand coal leasing in the Powder River Basin of Wyoming and Montana with the addition of at least 2.35 billion tons of coal available for mining.

As part of our ongoing work on coal mining in the Powder River Basin, Defenders recently worked with a  coalition of local, regional, and national groups to develop comments on several large coal leases that will have large-scale impacts on the Thunder Basin National Grassland (TBNG).  These leases—collectively called the “Wright Area Coal Lease”—would result in the strip mining and otherwise degradation or destruction of more than 29,000 acres, 11,677 of which are on the TBNG.  The areas at risk, though close to coal mines that have already been developed, support a thriving grassland ecosystem, home to species like prairie dogs, mule deer, antelope, mountain plover, sage-grouse, and various raptors.  Sagebrush and grassland ecosystems like this are incredibly sensitive and can take hundreds of years to recover from disturbance, sometimes failing to ever reach their original state again—an unfortunate reality acknowledged by the agencies analyzing this lease.

Defenders’ contribution to the coalition comments on the leases focused on the need for the Forest Service (the agency in charge of our National Grasslands, in addition to National Forests) to follow its own policy to protect wildlife.  This policy requires the Forest Service to “[e]nsure that exploration, development, and production of mineral and energy resources are conducted in an environmentally sound manner and that these activities are integrated with the planning and management of other National Forest resources.”  This is a lofty challenge for coal mining operations that can have devastating and wide-ranging environmental effects.   Accordingly, complying with this policy would require the Forest Service either to reject the lease outright or at the very least to place limits on the lease, called stipulations, which require developers to take precautions and avoid damaging environmental resources.  Specific stipulations we requested for the Wright Area leases include avoiding sensitive species habitat and limiting activities during seasons when animals are breeding or migrating.

You can learn more from our Federal Lands program and our partners at the Powder River Basin Resource Council and WildEarth Guardians.

Posted in Energy, Fossil Fuels, Public LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

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 LandsComments (0)

lynx

Too Special to Drill?

Earlier this month Defenders, along with some of our partners, submitted a letter calling for greater conservation measures to be incorporated into a proposed drilling project on the Bridger-Teton National Forest in eastern Wyoming, near Yellowstone National Park.  Our very own Dave Gaillard provided his expertise on lynx in an effort to show the Forest Service that this area may be, simply put, too special to drill.

lynxOne of the key issues that makes this project so important (and frightening) to Defenders of Wildlife is habitat connectivity – full field development of more than 300 acres in this area will lead to further fragmentation of habitat for lynx, as well as other iconic species in the region like elk.  Fragmentation is a problem because not only does it lead to less habitat for lynx and (as important) lynx prey, it also contributes to the separation of remaining lynx populations from each other.  This leads to a shallower gene pool and to difficulty moving through the landscape and escaping threats – wide ranging animals like lynx need space if they’re going to survive, and drilling dozens of oil wells in their way certainly won’t help efforts to recover the species.

As Dave puts it: “We are aware of no better documented travel corridor for lynx in the contiguous U.S. than the Hoback Rim, or “Bondurant Corridor” that passes directly through the project area.”  The challenges that lynx and other resources will face if this project moves forward as designed inspired a number of organizations to come together and seek out a solution (from our letter):

“The best solution to protecting these natural values from the development of these leases is to negotiate a buy-out and retirement of the leases . . . . Yet we understand the Forest Service lacks the authority to select this alternative without the consent of the lease holder. Thus we urge the Forest Service to create a new ‘conservation’ alternative for the exploration and development of these leases that can serve as a showcase for drilling in areas of extraordinary value to wildlife and recreation.”

As we state, our first and foremost priority is to see the negotiation of a buy-out of the leases, but this solution requires a great deal of cooperation, and isn’t one the Forest Service necessarily has control over.  The Forest Service does have the ability to influence what the project looks like if it moves forward.  The types of things we would expect out of a “conservation” alternative include project phasing, which would allow only one well pad to be built and operated at a time.  Each well pad would have to be disassembled and the location would be restored before the next pad could be built and drilled.  Such an alternative, along with other mitigation measures, would lay out a realistic way forward in which leases that have given private oil companies certain rights can be honored without permanent damage to the public lands that we all have ownership over.

Though we worry about the lynx, at its core this is a human problem.  Citizens for the Wyoming Range has put together a great video of local residents who attended the Forest Service public meeting on this project, and shared their own concerns.

We look forward to seeing the Forest Service do the right thing for the Hoback basin of Wyoming, as well as the people and wildlife that call it home.

Posted in Public LandsComments (0)

dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.

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