On the Failure of The Northwest Forest Plan To Protect Species
12/4/98
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RELAYED TEXT STARTS HERE:
Title: On The Failure Of The Northwest Forest Plan To Protect Species
Source: Doug Heiken
Oregon Natural Resources Council
PO Box 11648, Eugene OR 97440
ph 541/344-0675, fax 541/343-0996
Status: Distribute freely with proper credit to source
Date: 12/4/98
The Forest Service and Bureau of Land Management are failing to implement
the "survey and manage" requirements of the Northwest Forest Plan which
are intended to help ensure the viability of species associated with old-
growth forests in the Pacific northwest. The survey and manage strategy
calls for surveys of at-risk species and management of the species'
habitat to maintain viable populations as required by federal law and
policy. Because the required surveys are not being done, the viability of
hundreds of species is threatened.
The old-growth forests of the Pacific northwest not only harbor fantastic
biodiversity but they are also some of the most commercially exploited
forests in the world. The Northwest Forest Plan, (also known as Option 9,
FEMAT, or the Clinton Forest Plan) represents a dangerous compromise that
allows continued clearcutting of old-growth on federal lands at
significant risk to hundreds of species. The basic design of the plan is a
system of large forest "reserves" made up of old-growth (which will be
mostly protected from harvest) interspersed with extensive clearcuts
(which it is hoped will someday regrow to become old-growth). The forests
between the reserves are called "matrix" where old-growth logging will
continue for 25-35 years when virtually all unprotected old-growth will be
gone. An aquatic conservation strategy is also included in the plan to
protect water quality and contribute to the viability of species
associated with streams and stream-side forests.
HOW THE NORTHWEST FORET PLAN PROTECTS BIODIVERSITY
In 1993, President Clinton convened the Federal Ecosystem Management
Assessment Team (FEMAT) which identified 1,084 species associated with
old-growth forests west of the Cascade Range in Washington, Oregon and
northwestern California. The plan approved in 1994 includes two main
strategies for maintaining species diversity: the reserve/matrix system
and the survey and manage strategy.
Reserve/Matrix System for Species That Can Disperse
The system of forest reserves with extensive clearcutting allowed between
the reserves (described above) is intended to provide habitat for viable
populations of species that have the capacity to disperse from the area
where they were born and successfully breed at another locale. About half
of the 1,084 species analyzed by the Species Analysis Team were predicted
to remain viable for the next 60-100 years under the plan (mostly because
these species have the capacity to disperse). Populations of species such
as the spotted owl and American marten are expected to thrive in the
reserves and occasionally disperse among them to maintain long-term
genetic links between populations.
The theory behind this reserve/matrix strategy may be sound, but there are
problems in its practical application. The forests of the Pacific
northwest are so heavily fragmented by past clearcutting that the reserves
are full of clearcuts which are inhospitable to old-growth species, and
the matrix leaves open for clearcutting a significant portion of the
remaining old-growth.
Species such as the spotted owl remain at great risk because the old-
growth habitat in the matrix (habitat which currently supports about half
of all the spotted owl pairs) will be liquidated within 25-35 years under
current levels of cutting, yet the clearcuts in the reserves will not
regrow to become owl habitat for 150-300 years. The owl and many other
species dependent upon old-growth clearly face a very long and uncertain
window of vulnerability.
Survey and Manage Strategy for Species Less Able to Disperse
The experts predicted that the other half of the 1,084 species analyzed
were likely to not do well under the reserve/matrix design established by
the Northwest Forest Plan because they are less able to disperse between
the reserves. For these species, the Northwest Forest Plan requires the
agencies to conduct species surveys and protect species habitat, even in
the matrix. Species such as the arboreal red tree vole and various
salamanders fall in this category. In order to protect all the species
that remain at-risk, the authors of the plan developed four survey
strategies.
PROBLEMS WITH THE SURVEY AND MANAGE PROGRAM
There are four interrelated "survey and manage" strategies that work in
concert to help ensure the viability of about 400 species that remain at-
risk from continued harvest of old-growth. Any given species can be
covered by one or more of the survey strategies. Unfortunately, there are
implementation problems with all four survey strategies.
Strategy One
Immediately Protect Known Sites Where the Species are Located. (Applies
mostly to fungi, lichen, bryophytes, mollusks, amphibians, and vascular
plants.) This strategy requires protection of the all known locations of
260 species most at-risk. This strategy went into effect immediately upon
approval of the plan in 1994. The intent was to collect data under
relatively "inclusive" criteria and if necessary do surveys to better
define sites in need of protection. Unfortunately, the agencies defined
"known site" so narrowly that many sites were excluded from protection.
Another problem is that the agencies refused to do ANY surveys to refine
site locations that are known with less specificity. The locations of many
sites that should be included in the known sites database are identified
in the records of museums and herbariums. These collections' usually did
not describe locations to a scale finer than 1/4 mile (1320 feet), but the
agencies excluded most known sites unless they were known within 150 feet!
This level of site-specificity is difficult to achieve in the rugged
forested landscape of the west. The result is that too few known sites are
protected and very many known sites will be logged and destroyed.
Strategy Two-
Conduct Site-Specific Surveys Prior To Ground-Disturbing Activities.
(Applies mostly to amphibians, mollusks, mammals, and vascular plants.)
This strategy requires site-specific surveys for 77 species prior to
habitat-altering activities such as road-building and timber sales.
The authors of the Northwest Forest Plan recognized that it would take
time to develop survey protocols, so this survey requirement was phased in
over the course of several years at some risk to the species. Species
within this strategy are to be protected on sites where they are found and
most sites will be added to the "known sites database" developed to
accomplish strategy one.
The implementation of survey strategy two has many problems including: (1)
failure to allocate agency resources to timely develop survey protocols
and habitat management standards, (2) program-wide delay of surveys beyond
the timelines established in the Record of Decision, (3) exclusion of up
to 90% of the range of the species from the survey requirement (e.g., red
tree vole), (4) failure to protect species on sites where they are found
(overly discretionary habitat management prescriptions), (5) failure to
implement surveys as required in regional protocols (e.g., salamanders),
(6) development of an EA to delay surveys for 32 at-risk invertebrates
until FY 2000, and (7) failure to follow procedures for accountability and
public involvement in making changes to the Record of Decision. The
cumulative result of all these problems is that tens of thousands of acres
of old-growth forests are being destroyed annually without regard to
whether these 77 at-risk species may be present or how they might be
impacted.
Strategy Three-
Conduct Extensive Regional Surveys to Find High Priority Sites for Species
Management. (Applies mostly to fungi, lichens, and bryophytes.) This
strategy requires regional surveys to be underway by 1996 for 284 species
that are a little more difficult to survey. This strategy will result in
many species locations being added to the "known sites" database developed
under strategy one. Strategy three was developed to accommodate the timber
program. Since many species in this strategy are a little more difficult
to survey for, the authors of the plan did not want to hold up timber
sales while surveys for these species were conducted.
There is a recognized risk to the species in not requiring surveys prior
to timber harvest or other ground-disturbing activity so this strategy
requires that the surveys for all these species be "underway by 1996."
Richard Holthausen's undated paper on the intent of the survey and manage
requirements indicate that the intent was to have surveys underway for all
species in 1996 (not just some portion of the entire strategy 3 effort
underway in 1996).
The agencies are using a "research approach" for the strategy 3 species.
This approach is inconsistent with the intent of the program. Holthausen's
paper indicates that the intent was to focus strategy 3 surveys not
randomly or regionally where species were most likely to be found, but
"the surveys would initially be targeted to areas where disturbances or
other risks to sites were expected in the near future."
The agencies unfortunately have not allocated sufficient resources to this
survey effort. The surveys are not underway for all species nor are the
surveys targeted toward proposed timber sales. Very few strategy three
species surveys were underway by 1996 as required, so while the timber
sale program moves forward, the sites where these species may be located
are being destroyed and little progress is being made to build the known
sites database.
Strategy Four-
Conduct General Regional Surveys to Acquire Additional Information.
(Applies mostly to fungi, lichens, and arthropods.) These surveys are
intended to provide information on 72 species about which little is known.
Surveys were to be initiated no later than FY 1996 and completed within 10
years, but it appears that very little effort is being made to initiate
and complete surveys within the required timeframe.
These surveys were also intended to be underway for each species beginning
in 1996, but they were not.
Other problems with the Survey and Manage Program:
Richard Holthausen's paper indicates, "As with all of the survey and
manage measures, the intent of `managing' sites is to provide for a very
high likelihood that the species will persist on the site . . . to
maintain viable populations of the species." Unfortunately the agencies
are in many cases destroying known sites while protecting off-site
habitat.
The Northwest Forest Plan requires annual status reports on the survey and
manage program but these are not being done, so accountability and
oversight are seriously lacking. Information from these status reports is
intended to form the basis for changes in the survey and manage program,
such as changes in survey schedules and moving species from one survey
strategy to another. But these types of changes are occurring without the
benefit of status reports and they are being approved by agency line
officers without the concurrence of the Regional Interagency Executive
Committee as required by the Record of Decision. Such changes are highly
questionable until proper procedures are followed.
What has been accomplished.
As of mid-1998 the agencies have accomplished the following: chartered a
survey and manage "core team," 8 taxa-specific groups, and two "component
groups" for strategies 3 and 4; initiated surveys of 5 out of 74 strategy
two species; drafted 14 out of 73 required survey protocols, drafted 163
out of 258 required management recommendations; wrote memos to delay
surveys; developed a process to remove species from the list or move
species from strategy two to a more "convenient" strategy (so far
affecting 3 species and one guild of arthropods); developed and maintained
the "known sites database"; and evaluated and prioritized species in
strategies 3 and 4 so that some are deferred.
CONCLUSION
The survey and manage program is falling short of its objective of
protecting habitat for hundreds of species that are expected to suffer
under the reserve/matrix system established by the Northwest Forest Plan.
In 1994, when Judge Dwyer declared the Northwest Forest Plan to be lawful,
he said if the plan was to remain lawful it must be implemented in its
entirety. In order to protect the incredible diversity of species
associated with old-growth forests, the survey and manage program needs to
be implemented as described in the Northwest Forest Plan.
For more information please contact Doug Heiken, Western Oregon Field
Representative, Oregon Natural Resources Council, PO Box 11648, Eugene OR
97440, 541/344-0675, ONRCdoug@efn.org. The survey and manage program is
officially set forth in the April 1994 Record of Decision for the
Northwest Forest Plan at pages 36, C-4, and C-49.