Page 11: Introduction, par 1, sentence 2
If this sentence is going to cite the CFR, it should do so completely; otherwise, confusion will result. The CFR says that the goal is “to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area.” The focus on “native” is absent from the introduction. The aspect of “sustainability” is absent from the introduction. The limitation of “within their ranges” is absent from the rule. If this introductory section does not reflect what is in the rule, the field will have difficult when it comes to implementing.
o Suggest that the second sentence of the introduction be replaced with the following ”The primary focus is at the scale of the ecosystem, in developing plan components to provide a framework to contribute to sustaining native ecological systems by providing conditions to support diversity of native plant and animal species in the plan area (36 CFR 219.109(b)).”
Page 11: Introduction, par 1, last sentence
This sentence states that a species-specific approach “may be necessary”; however, FSM 1921.7 states that for the federally listed species, species-of-concern, and species-of-interest, existing information “should be assessed. . . .” Which is it?
o Suggest the terminology match.
43.1 – Ecosystem Diversity
Page 12: 43.11 Spatial Scales for Ecosystem Diversity
The paragraph below the list is confusing. We need to “determine appropriate scales for evaluation.” Because the “area of analysis” discussion pertains to more than just the ecological sustainability discussion and can be larger than what is covered by the ecological sustainability section, it probably belongs elsewhere than in this part of the handbook. It may also be more helpful if, rather than naming a specific hierarchical level, the directives were to provide guidance on how to select a hierarchical level. The suggested “subregion” level, for an aquatic example, will provide very little zoogeographic information, the basics of which are the defining criteria for the “river” level (Maxwell et al.) and for which several characteristics are listed in Exhibit 01.
o Suggest deleting “the area of analyses. . . Use ecoregion or subregion levels of the National hierarchy for these analyses.” [If it is moved instead of deleted, make sure the citation “36 CFR 219.15” is corrected to read “36 CFR 219.16”]
o Suggest inserting the following before the second to last sentence: “For the plan area scale, first establish the hierarchical level that generally has a spatial extent that covers most of the plan area of analysis and consider using that level to set context for the niche of the plan area and at least one lower hierarchical level to identify characteristics of ecosystem diversity.”
o Suggest replacing “use” with “the starting level will generally be the . . .” in the second to the last sentence.
Page 12, 43.12, Characteristics of Ecosystem Diversity
Par 1, sentences 2 and 3. Together these sentences form circular direction. “. . . develop a list of those characteristics that are key to establishing . . . plan components. . . [which] establish a framework to provide characteristics. . . .” I believe the intent is to identify characteristics whose maintenance or attainment needs to be provided for by plan components to result in ecological sustainability. In short, the list should be those characteristics that are needed for ecosystem diversity and those on which management (viz., under plan components) have or could have an influence.
o Suggest replacing sentences 2 and 3 with “The intent is not to catalogue all possible characteristics of ecosystems but to identify ecosystem characteristics that must be maintained or attained to achieve ecological sustainability and that are or could be influenced by management under the plan components.”
Par 1, sentence 5. Because requirements for organisms such as listed species may be more restrictive and out of our control, the converse of the sentence regarding “ecosystem characteristics should . . . serve as descriptors” is probably needed. I also feel there are two separate concepts presented – one is to try to provide rationale for the first level of the hierarchical approach by addressing “habitat conditions for species,” and the other is to shorten the second level of the hierarchical approach (species-specific) by using descriptors for habitat conditions for “listed species….” when possible. For example, if we felt there was a need to address the characteristic of stream temperature regimes, the argument that this would serve as a surrogate for species habitats would be better made if we used categories for those regimes that may be recognized as general regimes that could be grouped to categories of warm-water vs cold-water fish assemblages, general spawning temperatures for frogs, or temperature ranges of invertebrate communities. Furthermore, if one of those fish happens to be Lahontan cutthroat trout (federal threatened), then at least for the appropriate geographic area, we may also want to make sure the set of temperature ranges include a range that matches the optimal range of the cutthroat per its recovery plan. With luck, other ecosystem diversity characteristics can cross over to Lahontan cutthroat habitat requirements, making any further species-specific characterization unnecessary or at least reduced.
o Suggest replacing the last sentence of par 1 with the following. “To make the link between ecosystem diversity and species diversity, consider using species habitat descriptors as ecosystem characteristics as much as possible. Furthermore, to make the ecosystem level of the framework address the requirements for federally-listed, species-of-concern, and species-of-interest as much as possible, consider using habitat descriptors for those species as ecosystem characteristics whenever possible.” [Note, this suggestion also eliminates the problem of using the term “ecosystem condition” or “habitat condition” when still discussing what characteristics need to be addressed.]
Par 2, more guidance is probably needed on selecting characteristics appropriate to scale.
o Suggest inserting as a second sentence: “Consider using at least those characteristics that are identified as defining criteria for the hierarchical level or levels being used for the analysis.”
Page 14-15: 43.12, Exhibit 01, Characteristics of Ecosystem Diversity
This exhibit makes a good attempt at trying to categorize the vast number of possible elements that could be used to characterize ecosystems; however, it does not quite make things easier to understand. Perhaps if the three major categories of characteristics were thought about in terms of “description of pieces,” “layout of pieces,” and “things that change pieces or layout,” how the characteristics fit into the categories may be a little more straightforward.
For example, “density of large diameter trees per acre” is a description of a piece of the picture, so would be part of “composition.” The amount and location of those acres of particular densities of large diameter trees is what would be a characteristic of “structure.” Disturbance, such as fire, would fall under “process.”
As another example, the “stream and lake temperature regimes” that show up under “process” are again a description of pieces, so are part of the “composition” (several temperature regimes present – they are…). How they are laid out (warm bays in the north end of the lake or cold stream reaches in the upper elevations) are the “structure.” Solar radiation input (surface area exposed to sun over the summer months) is the “process.”
o Suggest setting up the exhibit with a few examples that relate to each other (such as examples above) so that the reader can understand the relationship and differences between the 3 categories. Include a statement rationalizing selection of the characteristic (i.e., what it has to do with FS management, for example, solar radiation input can be affected by Forest Service management of streamside vegetation).
Page 16: 43.13 Range of Variation
The introductory paragraph jumps right in as if everyone knows about “range of variation” and why we care. It also talks about the range of variation as if nothing is currently within range.
o Suggest changing the paragraph as follows: “The range of variation for ecosystem characteristics provides important context for evaluating current and desired conditions. It would not necessarily be used to describe the desired condition, because achieving or maintaining it may not be possible due to climatic, cultural, and ecological changes that have occurred or are expected to occur over time.”
Page 16: 43.13(1) Determine the reference period
For clarity, it would help if this section were split into 2 paragraphs. The first is limited to things to consider in determining the reference period that are relative to ecological (dynamic) stability. The second can go into explanation or rationale. Also suggest including references pertinent to aquatic systems. [The whole handbook seems a bit terrestrially oriented.]
o Suggest splitting the paragraph between sentences 3 and 4.
o Suggest for sentence 2 replacing “focus on the period . . .” with “focus on the period when the rate and intensity of human influences were not at levels that caused ecological instability.” [or . . . “caused major changes in ecological characteristics”]
o Suggest adding to sentence 2 “. . . and hydrologic systems” after “major vegetation types”
o Suggest adding to sentence 3 “. . . and drought” after “such as fire”
o Suggest the new second paragraph be as follows: “By focusing on several centuries . . . generally be obtained. This period includes the time of indigenous settlement but prior to the influence of European-American settlement, when the rate and intensity of human influences increased dramatically.”
o Suggest moving the last sentence, “Describe . . . “ to Section 43.14,, because it involves describing the current condition.
Page 16: 43.13(2) Provide estimates of the range of variation …
Sentence 1 talks about “distribution of . . . characteristics”; however, distribution is a characteristic (see Exhibit 01). In the same sentence, the word “selected” will cause confusion, because it is unclear if this is a selection from within the characteristics of ecosystem diversity or it encompasses all of those characteristics, which by direction are already a selected group. I think it means the latter.
o Suggest replacing “distribution of selected ecosystem characteristics” with “changes over time and space in characteristics of ecosystem diversity”
o For clarity, suggest replacing “selected reference period” with “determined reference period” [Determine is the word used in 43.13.]
The list of approaches should be shortened to what could be done. Phrases such as “conclusions reached…” are true for any analysis done and for any type of limitation or bias to the analysis.
o Suggest rephrasing as follows:
o Use knowledge about organisms, such as relationships with physical parameters, to estimate condition of organisms in the past.
o Simulate and estimate past variation by using an ecological understanding of how disturbance regimes influence the structure and composition of vegetation.
o Analyze historic records, such as pollen records, midden analysis, tree rings, documents from early explorers, and early surveys and inventories.
o Use knowledge obtained from studies on the long-term dynamics of ecosystems in modern reference areas, such as those wilderness areas and national parks that have not been heavily influenced by humans.
Page 16: 43.13(2)(c) Provide estimates of the range of variation . . .
“Range of conditions” is probably in error.
o Suggest replacing “range of conditions” with “range of variation”
Page 17: 43.13(2), last paragraph
The usefulness of “comprehensively described by …” is not limited to just “broad spatial extents.” Also, the second sentence is a suggested approach.
o Suggest moving sentence 1 of this paragraph in as sentence 2 of the opening paragraph and deleting “at broad spatial extents”: “. . . reference period. The range of variation for an ecosystem characteristic is most comprehensively . . . extreme conditions as well. A number of approaches. . . “
o Suggest changing sentence 2 of this paragraph to be approach (e), “e. Use models or field methods, such as dendrochronology or time series of landslide inventories, to assess frequency, duration, spatial extent, and magnitude of ecosystem processes.”
Page 17: 43.13(3): Characterize range of variation of disturbance regimes.
The whole discussion about disturbance is confusing – Sentences 1 and 2 refer to the disturbances as characteristics (processes), creating the circular discussion of characterizing a characteristic. Sentences 3 refers to the disturbances as influences on other characteristics. Mostly, this paragraph is about spatial scale, the discussion of which is already covered in 43.11.
o Suggest deleting 43.13(3)
Page 17: 43.13a Alternatives to the Range of Variation Approach
This section is not needed. The opening paragraph of 43.13 says that range of variation provides an important context. It does not say that it is the only way to do so. In later sections, when the context is important, whether it’s by range of variation or not, is when this information should come in. It does show up where pertinent, in Section 43.16.
o Suggest deleting this section.
Page 17: 43.14 Current Condition of the Selected Characteristics
Confusion is created by the term “selected” in the title. The ecosystem characteristics being addressed are already “selected,” because they are not to be a laundry list.
o Suggest changing “Selected” to “Ecosystem”
Page 18: 43.14 Current Condition . . . (cont)
The examples of characteristics is only of composition, not structure or process. The examples from 43.15 (Current condition of disturbance regimes) should be part of this list. This entire list (examples) should be part of 43.12 if included at all. Examples in this section should be limited to those that can address current condition. The statement about “error” is applicable to any analysis done for planning, not just ecological, and so belongs other than here. Suggest setting up examples that address composition, structure, and process in Section 43.12.
o In this section, suggest deleting “characteristics likely . . richness.”
o Suggest deleting the word “selected” from the first sentence.
o Suggest replacing “Develop” with “Assemble and, if needed, develop” in the first sentence
o Suggest looking at chapter 20 or wherever a more detailed description of the comprehensive evaluation (perhaps FSM 1921.74 or even somewhere broader)will be covered for the discussion about error as well as uncertainty
o Suggest changing paragraphs 2 and 3 into a list of examples of methods that can be used to assess current condition
“Current conditions can be assessed by a variety of approaches, such as the following:
1. Use forest Inventory and Analysis or the Continuous Vegetation Survey inventory plot data for information about forested stand composition and liver and dead structure.
2. Use aerial photo mapping and satellite remote sensing for spatial information about vegetation composition/structure classes, water bodies, and human infrastructure.
3. Use mid to broad-scale assessments, such as sub-basin or ecosystem-level assessments and watershed assessments, to provide information on the condition of aquatic, terrestrial, and riparian habitat, potential areas of high productivity, and overall distribution of aquatic and terrestrial organisms.
4. Use recent fire history data to describe current fire disturbance regimes.
5. Use invasive species data for current and possible levels of disturbance to native species distribution.”
Page 18: 43.15 (see above, 43.14)
Page 19: 43.16 Status of Ecosystem Diversity
Up to this point, discussion has been about conditions of characteristics of ecosystems, no synthesis of “ecosystems” as entities. The approach seems to be to look at the various characteristics of ecosystem diversity, the totality of which would hopefully address a diverse group of ecosystems and species dependent on them (per page 11, intro of Section 43, par 1, sentence 2.) Paragraph 1 should continue to reflect this approach. In sentence 2, the phrase “parts of the system” is confusing and does not match previous discussion. In general, this section needs to keep bringing its focus back to the type of information that would be needed for planning (Section 43.17).
This first paragraph should just set up generally what would be evaluated relative to current condition and range of variation. Set up paragraph 2 to address what the evaluation should include (sentence 3). Sentence 4 is not always true – some rare characteristics may be rare because they have been invulnerable to environmental change or management influence.
Section 43.13 says that the range of variation is determined because it is important as context for evaluating the current condition; therefore, this is one of the sections that should use of the range of variation as part of the analysis. The opening phrase of paragraph 2, sentence 1, ‘One way to accomplish this” is unnecessary. Sentence 2 implies that change has been constant since the time of European settlement, which is not the case for all characteristics, for example, the damming of rivers in the west a century after initial European settlement. The extra discussion on disturbance regimes in sentence 3 is unnecessary, because disturbance is one of the characteristics of ecosystem diversity. Sentence 4 (as elsewhere) creates confusion because of the use of “distribution” with a statistical connotation as opposed to “distribution” with a spatial connotation. Sentence 6 is misleading, indicating only that “the dynamic nature of systems” and not the appropriate dynamic nature of systems is important to persistence of species and communities. It would probably help if sentences about interpretation (e.g. sentences 5 and 6) rather than evaluation were put into a separate paragraph.
In paragraph 3, the issue would not be that a “comparison to range of variation is not possible” but that the range of variation could not be determined. Rather than “build” criteria, which could be never-ending, establishment of the criteria to use for the evaluation at the time it is done is necessary. In concept example 1, the reference is the historical array used for comparison, not the array. Resiliency is not a matter of allowing disturbance as much as it is the ability to respond to disturbance either to the original characteristic or expected sequential characteristic
o Suggest the heading of this section be changed to “Status of Characteristics of Ecosystem Diversity”
o Suggest deleting sentence 2 (it’s in 43.1)
o Suggest replacing Sections 43.16 and 43.16a with the following:
Use information developed in the previous steps to evaluate the status of characteristics of ecosystem diversity. This is done by first determining which characteristics of ecosystem diversity that have been relatively stable and those that have been changing relative to pre-European settlement. The information is then interpreted relative to the potential for the effects of management practices on those characteristics.
The evaluation determines those characteristics of ecosystem diversity that are contributing to ecosystem stability and is based on the comparison of their current condition to their ranges of variation, if determined. The evaluation should identify characteristics of ecosystem diversity that are or are moving further outside of their range of variation. In doing these comparisons, consider the extent, rate, and patterns of change in the characteristics of ecosystem diversity post-European settlement rather than simply the mean or the extremes of the distribution.
Where a range of variation could not be determined, for example, due to lack of information, establish criteria that reflect the ability to maintain or return to the characteristics of ecosystem diversity over time. Compare current conditions to these criteria. Concepts behind criteria establishment could include the following:
1. Representativeness (for example, a time-specified historical array of characteristics of ecosystem diversity and their proportional occurrence)
2. Resiliency (for example, an array of conditions that will allow for return to those conditions after characteristic disturbance processes)
3. Redundancy (for example, multiple occurrences of specific ecological conditions such that all occurrences cannot be eliminated by a catastrophic event)
The evaluation also includes an interpretation of the comparisons relative to existing and potential management practices. Interpretations would include such things as follows:
1. Describe those changes in characteristics that are related to changes in other characteristics.
2. Identify associations or patterns of characteristics that could indicate distinct ecosystems, possibly at different scales.
3. Identify those characteristics and ecosystems that are or are moving outside of their ranges of variation because of changes outside of Forest Service control, e.g. global warming or expanding urbanization.
4. Identify those characteristics and ecosystems that are or are moving outside of their ranges of variation because of past but discontinued management practices.
5. Identify those characteristics and ecosystems that are or are moving outside of their ranges of variation because of current Forest Service management practice.
6. Identify those characteristics and ecosystems whose conditions are outside of their range of variation that can be restored to their range of variation through Forest Service management practice, describe what those practices could be.
7. Identify characteristics and ecosystems that are rare in the plan area, e.g. a low distribution of fens, whether or not their distribution is within its range of variation.
8. Estimate the level of risk to characteristics and ecosystems that are outside or moving outside their range of variation or that are rare by evaluating the likelihood that the source of the risk (threat) will continue.
9. Estimate the severity of risk to characteristics and ecosystems that are outside or moving outside their ranges of variation or that are rare by describing the geographic extent and duration of change.
Page 20: 43.17 Plan Components for Ecosystem Diversity
This section does not make use of everything that has been developed in the rest of 43.1. Item 2 references the evaluation but not what to do with it. It seems to jump straight to desired condition, but all that has been stated so far is that the range of variation is probably not going to be the same as the desired condition. The information from the evaluation could be used for the development of more than just the desired conditions and objectives. The phrase “guidelines that establish a design framework of all forms of resource management” is not helpful.
o Suggest expanding this section with something like the following:
Consider ecosystem diversity when developing plan components. The plan, plan amendment, or plan revision should address the conservation and restoration of ecosystem diversity. In conjunction with information provided by the social and economic sustainability evaluations, the following are examples of ways to use the ecological sustainability evaluation in developing plan components:
1. In establishing desired conditions, consider ranges of variation of characteristics of ecosystem diversity that could be attained under current climatic, cultural, and ecological conditions.
2. Establish desired conditions that address at least those characteristics of ecosystem diversity or ecosystems that can be influenced by Forest Service management practices.
3. Use differences between current conditions and ranges of variation or established criteria to set objectives for progressing towards desired conditions.
4. Consider the current condition of disturbance processes and management practices identified in the evaluation that can help move conditions of characteristics towards their ranges of variation in establishing objectives and suitability of uses.
5. Consider past management practices that contributed to conditions of characteristics being outside of their ranges of variation in establishing suitability of uses.
6. Consider characteristics and ecosystems that are rare or with high risk in establishing guidelines, suitability of uses, special areas.
43.2 Species Diversity
Page 21: 43.21 Ecosystem Context for Species
The statement of policy, paragraph 2, should open the section. The rest of the information is a general statement of the hierarchical approach. Specific information, such as paragraph 1, sentence 2, “Use projects …,” is a specific step that could be taken and does not belong in the introduction. Paragraph 2 is not a sentence as written.
o Suggest renaming this section as “Hierarchical Approach for Species Diversity”
o Suggest replacing the section with the following:
FSM 1921.7 policy is that management provides for appropriate ecological conditions to contribute to conserving federally-listed species, supporting self-sustaining populations of species-of-concern, and supporting species-of-interest, as deemed appropriate by the Responsible Official consistent with the limits of agency authorities the capability of the plan area, and overall multiple use objectives. Plan components for ecological conditions that provide for ecosystem diversity set the primary framework for doing so; however, ecological conditions necessary to support species diversity may or may not be completely provided by plan components for ecosystem diversity.
The evaluation of conditions supporting species diversity and any additional plan components to support species diversity should be focused on those species for which the Responsible Official determines that provisions in plan components in addition to those required by section 43.17 are needed.
Page 21: 43.22 Identification of Species
The caveat “taking into account limitations that exist at the edge of a species’ range” should not limit the initial identification of a species for possible consideration. Effects of this are possible reasons for considering or not considering a species for further detailed consideration, per page 23, 43.22c. Also, because this whole section includes the “screening” (43.22c), clarification in the title is needed.
o Suggest deleting “. . . taking into account limitations that exist at the edge of a species’ range.”
o Suggest inserting “listed” after “federally”
o Suggest changing the section title to “Species to be Considered for Species Diversity”
o Suggest adding a sentence: “From these species, the Responsible Official should identify those species that may require further detailed consideration.”
Page 21: 43.22XX
There should be a section, probably 43.22a with ensuing numbering adjusted, for federally listed species.
o Suggest inserting a new section, renumbering the subsequent sections. The new section would be as follows:
43.22a – Federally listed threatened and endangered species
The Responsible Official should request a list of federally listed threatened and endangered species from the U.S. Fish and Wildlife Service and, if appropriate, NOAA Fisheries.
[If for some reason we do not want our directives to require this, e.g. we can’t require USFWS or NOAA to send us a list for something they may or may not consider a major federal action, then the following alternative section is suggested:
43.22a – Federally listed threatened and endangered species
Species that are federally listed threatened and endangered species should be identified from the following:
1. Lists published in 50 CFR 17.11 and 17.12.
2. USFWS Threatened and Endangered Species System database
The Responsible Official should include any species with a “Historical Range,” per the database, that includes the state that includes part or all of the area of analysis, unless the specification in “Where Listed” per the database indicates the species would not occur in the area of analysis.
Page 21: 43.22a Species of Concern
Paragraph 1, sentence 2, the “as appropriate” is not needed. The categories listed seem to cover a wide range of status and knowledge base. At this stage, based on the purpose of the species-of-concern and the definitions of the different elements provides, those species fitting 1-3 (or at least G1, G2 and T1, T2) “should” be on the initial list. The G3, T3, and petitioned species may be more open for discussion. This section also reads as if it is limiting what the Responsible Official can consider, which I do not think was the intent.
o Suggest deleting “as appropriate”
o Suggest separating the list, as follows:
The Responsible Official should identify the following animal and plant species as potential species-of-concern:
1. Species identified as candidate and proposed under the Endangered Species Act.
2. Species with ranks of G-1 and G-2 on the NatureServe ranking system.
3. Infraspecific taxa with ranks of T-1 and T-2 on the NatureServe ranking system.
The Responsible Official may also identify animal and plant species as potential species-of-concern based on other sources, such as the following:
1. Species and infraspecific taxa with ranks of G-3 and T-3, respectively, on the NatureServe ranking system.
2. Species that have been petitioned for Federal listing and for which a positive “90 day finding” has been made.
The identified species-of-concern may include subsets that may be listed under the Endangered Species Act, such as distinct population segments or evolutionarily significant units.
Page 22: 43.22b Species-of-Interest
Again, the section sounds limiting, which it probably shouldn’t. Explanation for item 4 could be reworded to address the list on page 23. Also, this list should probably also include species for which the plan’s administrative unit is signatory on a conservation agreement or strategy or is identified as possibly being within the species’ range for a conservation agreement or strategy signed by a higher level of the organization. Item 5 is redundant to the definition unless reworded to focus on the “public interest” purpose.
o Suggest rephrasing the second sentence to “. . . may identify potential species-of-interest based on sources such as the following:”
o Suggest replacing item 4 with the following: “Species for which information indicates that its habitat or populations have declined significantly in the plan area or are not well-distributed in the plan area, its population numbers are low in the plan area, or it is dependent on a specialized habitat in the plan area.”
o Suggest starting item 5 at “Species of public interest, including. . . ”
o Suggest adding item 6: “Species for which a conservation agreement or conservation strategy has been developed to which the planning unit is a signatory or which addresses management in the planning unit but is signed at a Forest Service level that is higher than the planning unit.”
Page 22: 43.22c Screening…
In general, depending on whether or not the species can be addressed by the characteristics of ecosystem diversity addressed in 43.21, they may or may not be considered in “detail,” though there is still a need for some evaluation. The opening paragraph should not focus on rationale but state clearly that some of the identified species from the previous sections may not need to be considered further. The last phrase of the first sentence (changes in ecological conditions) is only pertinent if related to plan, plan amendment, or plan revision and so is unnecessary. As for what is listed for things to consider in screening for species-of-concern and species-of-interest, some of the discussion points would seem to apply to all categories.
It is confusing that the species-of-concern discussion is a combination of reason for continuing and not continuing evaluation, while the species-of-interest discussion is about reason for continuing evaluation. Items that are identified under species-of-interest would better serve as direction for what to use in the evaluation of species condition. [Items e and f are part of the evaluation. Item g is is already covered in 43.22.b.5] It would probably help if this section focused on those pieces of information that could be used as rationale for not needing further evaluation, and to be used by the Responsible Official at any time during the planning process to streamline it.
o Suggest deleting “detailed” from the section title
o Suggest replacing “consideration” with “evaluation” in the section title
o Suggest moving the information of 43.22c(2)(a-d) into 43.22b(4) (see above)
o Suggest replacing the opening paragraph with the following:
Some species identified using criteria in sections 43.22a, 43.22b (and my proposed new 43.22a) may not require additional provisions in plan components. These are species that are not influenced by the plan, plan amendment, or plan revision or whose requirements are met by the provisions for ecosystem diversity. The Responsible Official determines those species for which evaluation is necessary and the extent of their evaluations. As information is gathered and the evaluation for identified species proceeds, pursuant to sections 43.23ff, the Responsible Official may determine that the evaluation is sufficient for a given species or that no additional plan components are needed. This determination, which should be documented, may be based on criteria such as the following:
1. The species or taxonomic unit of interest does not exist in the plan area or area of analysis. For federally listed threatened and endangered species, this determination should be made in coordination with the U.S. Fish and Wildlife Service and, if applicable, NOAA Fisheries.
2. The species or taxonomic unit of interest is in the plan area, but its status is not influenced by Forest Service management.
3. The needs of the species or taxonomic unit of interest are provided by plan components developed for ecosystem diversity or for other species.
4. Evaluation of the species can be addressed by evaluation of the characteristics of ecosystem diversity or of other species.
Page 24: 43.23 Information Collection
The concept expressed in the opening sentence, “. . . To understand potential threats. . . the Responsible Official determines what additional provisions . . . may be needed,” is backwards.
o Suggest replacing the first sentence: “To determine if additional provisions in plan components may be needed for species diversity, the Responsible Official needs to understand the current status of the federally listed species, species-of-concern, and species-of-interest and their habitats.”
The list is somewhat confusing, because it includes conservation factors (e.g. habitat) and threats to them (e.g. dams). The former is status or condition, the latter part of evaluation of the information. The field may find it more helpful if these were kept distinct. The last paragraph, on existing and missing information, is applicable to more than just species information and belongs somewhere in an overview section.
o Suggest restructuring the section from “The Responsible Official may consider. . .” as follows:
The Responsible Official may consider information on the following factors that affect the condition or status of the species:
1. Taxonomy or genetic make-up
2. Distribution of individuals or populations
3. Abundance of individuals or populations
4. Life histories of the species
5. Distribution, amount, and quality of habitat for all life history requirements, including necessary biological interactions
6. Diversity of available habitat
7. Connectivity of populations (gene flow and recolonization)
8. Connectivity and accessibility of habitats
For all of these, the information that would aid the Responsible Official in making a determination about plan components also includes the following:
1. Current condition and trend inside plan area
2. Current condition and trend at scales larger than the plan area to establish context
3. Fluctuation patterns
4. Optimal condition, trend, and fluctuation levels
5. Condition, trend, and fluctuation levels known to be needed for sustaining populations
6. Influence from conditions or management practices outside of Forest Service control
7. Influence from past, present, and possible future Forest Service management practices
When possible, the characteristics of ecosystem diversity should be used to describe these conditions.
Page 24: 43.24 Species Groups and Surrogate Species
The opening paragraph takes too long to make its point. It also should focus on the purpose of using groups or surrogates and leave the possible ways of selecting them to a separate paragraph. Also, the list of “concepts” in sentence 7 is confusing, especially with the “keystone species,” which is not a surrogate but more of a driver for the community with which it is associated. The other conceptual possibilities are only useful if they serve the purpose being described. The instructions about documentation apply to all aspects of analysis, not just this one.
o Suggest deleting sentences 1-3.
o Suggest replacing “For this purpose” in sentence 4 with the following: “Because the list of identified federally listed species, species-of-concern, and species-of-interest may be too long for effective detailed analysis for each individual species, . . .”
o Suggest deleting sentence 5, “Such efficiencies . . . .”
o Suggest deleting sentence 6, “When the grouping …”
o Suggest deleting from “. . . or surrogate species may be selected. . . “ to the end of the paragraph.
On page 25, par 2, the discussion of the hierarchical approach is confusing and may not yield the most efficient set of groups. The stepwise aggregation does not account for possible overlapping of ecological requirements that could be addressed by a separate overlapping “group” rather than a subset of a group result from a particular branch of the hierarchy. Also, par 3, the example approach, makes groups and then goes into finer division, which is the opposite of the description of the approach in par. 2. It also seems as if to have efficient groups, the detail of information for each species is finer than what is being asked for in 43.23. The need is not to define a group and then select a species. For efficiency, the need is to find the smallest subset of species that represents the ecological requirements of others. There certainly does not have to be a single-species representative for each species (such would actually be contrary to theory about species and their habitats), and some species may be efficiently analyzed by looking at a combination of surrogates and direct analysis of un-surrogated ecological requirements.
o Suggest deleting paragraph 2.
o Suggest replacing “including both” with “such as the combinations of ” in par 3, sentence 1 [otherwise, it’s very terrestrially oriented]
o Suggest deleting sentence 2.
o Suggest replacing “further subdivide. . .” with “review macrohabitat group members for similarity or overlap in the factors affecting the condition of the species, per Section 43.23”
o Suggest replacing “above attributes” with “the overlapping factors,”
o Suggest adding, “Also consider direct analysis of a subset of species requirements to supplement analysis of surrogates rather than increasing the number of surrogates if this is more efficient.”
o Suggest adding at the end of the section, “If the Responsible Official determines that further analysis or plan component development for a surrogate species is not needed, alternative analysis or plan component development may be required for those species represented by that surrogate.”
Pages 26 and 27: 43.25 Plan Components for Species diversity and 43.26 Evaluation of Plan Components on Species
These two sections seem to be backwards in order. The evaluation should occur prior to and for the purpose of the development of plan components, similarly to what is done for ecosystem diversity in 43.1.
o Suggest reversing the order.
o Suggest deleting “Plan Components” and adding “Diversity” to the end of the 43.26 section title
Page 27: 43.26 Evaluation of Plan Components on Species
[As stated above, this section should precede the Plan Components section, and my discussion makes the assumption that this change will occur.] The opening paragraph seems to reflect an older version of the rule and should instead reflect the language of the published new rule. This paragraph is probably not needed, because the section should focus on what the evaluation should address. Paragraph 2, “Evaluations may actually be used . . . then require additional evaluation,” reflects how the evaluation is done, not what the evaluation is, and should probably become part of 43.25 “Plan Components for Species Diversity.” The focus information in par. 3, “Follow these guidelines…” should tie in better with the information from the preceding sections (43.23, 43.24) and provide guidance on the evaluation, not the parameters. The section, overall, is extremely disjointed, probably a victim of numerous versions and last minute cut-and-pasting.
o Suggest using the following re-organization of the section:
Use information from the previous steps to evaluate the status of species diversity. This is done by first determining which factors are affecting the condition and status of federally listed species, species-of-concern, and species-of-interest and how those factors are affected by Forest Service management practices.
The evaluation first identifies those factors of condition and status of the identified species, or surrogate species as applicable, and a projection of the results of trends or fluctuation levels in those conditions. This can be done by comparing current conditions with optimal conditions, if the information is available. If optimal conditions are not available, base the comparison upon general principles of population ecology, related taxon-specific ecology, and conservation biology. This first part of the evaluation should do the following:
1. Identify those conditions that are trending further from optimal.
2. Identify those species, including those represented by surrogate species, whose factors affecting condition and status are not at optimal or trending away from optimal.
3. Identify those species that are rare in the area of analysis and whether or not the ecological requirements for those species are being met.
4. Identify those species that are keystone species for community or ecosystem stability
The evaluation also includes an interpretation of the status and trend relative to existing and potential management practices. The interpretation could identify those factors affecting the condition and status of the species that are or are trending away from being able to support the evaluated species or their surrogates, as applicable. For these identified factors, the interpretation would also do the following:
1. Identify those that are affected solely by changes outside of Forest Service control, e.g. loss of winter habitat in South America
2. Identify those that are at least in part influenced by past but discontinued Forest Service management practices, e.g. removal of large woody debris from streams
3. Identify those that are at least in part influenced by current Forest Service management practices.
4. Identify any synergistic effects, e.g. limitations in habitat distribution that could result in higher levels of in-breeding and increased susceptibility to catastrophic event
5. Identify any smaller-scale conditions that will affect the species at the analysis scale, e.g. conditions affecting the status of a source population for recolonization
6. Identify possible management practices that could be taken for their active restoration
7. For species represented by surrogates, identify those factors affecting conditions and status that are not or are trending away from being able to support the surrogate or surrogates and pertinent to the rationale behind selection of the surrogate or surrogates.
8. Identify how they are influenced by or relate to characteristics of ecosystem diversity, per Section 43.1
The interpretation should also provide information on the risk to the species due to the factors affecting their condition and status.
1. Estimate the level of risk to the species by evaluating the likelihood that the source of the risk (threat) will continue
2. Estimate the severity of risk to the species by evaluating the geographic extent
3. Assess the level and severity of risk to the species relative to the duration. Base the assessment over projects on both the biology of the species, such as generation time or recolonization time, and on the time needed for the necessary ecological requirements to respond to the identified management practices.
Page 26: 43.25 Plan Components for Species Diversity
This section does not make use of all the information that has been developed up to this point. Rather than restate plan component requirements, the section should provide guidance on how the information relates to developing plan components. It should also provide guidance on how the Responsible Official can look at the provisions for ecosystem diversity to narrow the additional provisions needed for species diversity. It starts to do this in par. 3, sentence 2, but needs to go further. The section should also provide guidance on the need to take another look at any potential species for evaluation that was dropped from analysis, for example, if the event of later decisions to drop plan components relating to ecosystem diversity that were used in the rationale behind dropping a species from detailed evaluation.
o Suggest replacing the section with the following:
Using the evaluations for ecosystem diversity and species diversity, the Responsible Official should determine if additional provisions in plan components are needed for federally listed species, species-of-concern, and species-of interest. The best approach to do this would be to identify the key needs for species diversity that are within the management control of the Forest Service, identify those needs that are already addressed by the plan components for ecosystem diversity, then develop additional plan components as necessary.
From the evaluation for species diversity (Section 43.26 [which should precede this one]), the needs for species diversity could be focused on those identified conditions that meet the following:
1. Trend in conditions is influenced by Forest Service management
2. The condition or trend has either a high level of risk or high severity of risk for the species
Additional information that would be used to provide focus to the needs for species diversity is as follows:
1. The species being addressed is federally listed
2. The species being addressed is a surrogate for others
3. The species or the species being represented by a surrogate is rare or a keystone species
4. All of the conditions for a species that have a high severity of risk are not all outside of Forest Service influence.
Following the hierarchical approach set forth in the rule, the Responsible Official would determine if additional plan components are necessary. This may be done by doing the following:
1. Review the focused needs for species diversity to determine those that are addressed by plan components relating to ecosystem diversity.
2. Review plan components relating to ecosystem diversity to determine if any could be added or revised to address the focused needs for species diversity.
Those focused needs for species diversity that are or cannot be addressed by plan components for ecosystem diversity should be considered for development of additional plan components. The information from the evaluation may be used for this purpose as follows:
1. In establishing desired conditions, consider optimal, or presumed optimal, conditions for the remaining identified focused needs for species diversity
2. Establish desired conditions that address at least those remaining focused needs that can be influenced by Forest Service management practices
3. Use the differences between current and desired conditions to set objectives for progressing towards desired conditions
4. Consider the current condition of characteristics of ecosystem diversity and management practices identified in the evaluation that can help move conditions for focused needs towards desired conditions in establishing objectives and suitability of uses
5. Consider past management practices that have contributed to conditions of focused needs in establishing suitability of uses
6. Consider focused needs for federally listed species, rare species or surrogate species that represent listed or rare species and the management practices that influence them in establishing guidelines, suitability of uses, and special areas
7. Consider focused needs for conditions that are resulting in high severity of risk to species in establishing guidelines, suitability of uses, and special areas
Because of the dependence of species diversity on plan components for ecosystem diversity as well as any additional plan components for species diversity, and the possibility of addressing some species diversity requirements with surrogate species requirements, the Responsible Official will have to maintain vigilance in meeting the needs of all identified federally listed species, species-of-concern, and species-of-interest. This may require additional review beyond re-evaluation during option development.
Comments