Consider signing onto this letter. http://www.geosinstitute.org/hidden-menu/letter-regarding-new-regulations-for-national-forest-planning.html
As scientists working in natural resource-related disciplines, we applaud the USDA Forest Service for setting a bold vision for the 193-million-acre National Forest System to guide the development, revision, and amendment of land management plans (36 CFR part 219). The agency’s emphasis on climate change, forest restoration, watershed protection, and wildlife conservation are laudable objectives that we fully support. The proposed rule places great emphasis on flexibility and local decision-making regarding forest planning decisions. We are concerned that the approach places too much authority in the hands of responsible officials at the unit level without providing guidance, including defined national standards for agency decisions. Without measurable standards and effective monitoring, forest planning will too often fail to comply with the broader purpose and intent of the National Forest System and the National Forest Management Act. While some tangible benefits may derive from planning at the local level, history shows that lack of national standards has resulted in significant losses to natural resource values important to the nation; historic examples include substantial degradation of intact areas prior to the Roadless Area Conservation Rule of 2001, ongoing loss of mature and old-growth forests, and degradation of watersheds. Our more detailed comments on the proposed draft rule (*see Attachment A below*) address four areas that must be strengthened if it is to achieve its stated objectives: (1) responsible officials should not merely “take into account” best science, but conform forest planning to best available science; (2) each planning unit should identify and protect watersheds; (3) management decisions should be grounded in robust viability standards to safeguard wildlife populations; and (4) forest plans should safeguard and protect ecosystems (e.g., mature and old-growth forests, sensitive soils, riparian areas) vital to the health and ecological sustainability of the National Forest System. We thank you for considering our views on this vitally important matter. Science-based management of our national forests is crucial if these systems are to continue to provide vital ecological services such as plentiful water supplies, habitat for wildlife and fish, storm and erosion control, and climate mitigation through carbon sequestration and storage. Please do not hesitate to contact us for further information or input. Sincerely,* Dominick A. DellaSala, Ph.D. President and Chief Scientist Geos Institute Ashland, Oregon Jim Karr, Ph.D. Professor Emeritus School of Aquatic and Fisheries Sciences University of Washington Seattle, Washington Barry Noon, Ph.D. Professor Dept. of Fish, Wildlife, and Conservation Biology Colorado State University Fort Collins, Colorado
