Discussion

Let us know what you think about any topic related to the Sierra Nevada Adaptive Management Project in the forums below. The Principal Investigators on the UC Science Team cannot answer every post, but they will read all comments in their areas, and respond to comments as a group at each quarterly meeting. We greatly value your input!

John Battles said at 8:26 p.m. on 3 March 2006 ,

1) There were several comments regarding the scale of the study and the coordination of this research effort with ongoing efforts.

Given the magnitude and diversity of the Sierra Nevada bioregion, we needed to identify a smaller, more homogeneous subset of this space in order to obtain information that was relevant to the management issues, that was credible in terms of its scientific justification, and that was timely. When exploring potential sites across, it was clear that treatments that span an area much larger than 10,000 to 15,000 acres were not feasible given the time frame. We were charged to design a plan that would provide some information within 5-7 years. Such a short turn-around in necessary if any adaptive management is going to occur. The scientific challenges of scaling-up to a larger fireshed are also daunting. We have tools and experience working at the stand and small watershed level. There are many fewer guides to studying multiple processes in larger landscapes. We have proposed some novel approaches to addressing forest response at the fireshed scale that we hope will meet the scrutiny of scientific peer review. We have also emphasized the role of meta-replication in this workplan. Given the urgency of the questions and the paucity of the information, we need to collect, collate, and integrate all the available information.

2) Our focus on the mixed conifer forests on the westside of the Sierra Nevada was also related to this need to focus on a manageable subset of the Sierra Nevada. Thus the selection was another prioritization exercise. We choose the westside mixed conifer because it was the forest region most at risk of catastrophic fire.

3) Another comment requested we supply a budget.

Our current workplan (Feb 28) does include cost-estimates summarized by category, research theme, and year.

4) Finally we tried in the revised Feb 28 workplan to more explicitly identify the steps in the application of adaptive management plan and the role that the UC research team could play in this process.

Specifically, we defined the available decision-space and how we would integrate new knowledge. Throughou,t all research themes we tried to make clear how the UC research team would contribute to the “Learn and Think” phases of adaptive management. We also explicitly listed the sort of deliverable we expect to provide. For example, we proposed developing and holding small workshops to engage the UC research team with Forest Service decision-makers. The workshops would be theme-based with an emphasis on hands-on and field-based learning to keep them focused and productive. Similar small workshops will be offered to the interested publics. The goals of these workshops go beyond information sharing. They seek to better understand how new information can impact the “DO” phase of the adaptive management process.

We agree that prey populations are of paramount importance for species of higher trophic levels. However, it is those higher-level species that are of most public, administrative, legal, and conservation concern. What we know of the ecology of these species leads to the supposition that they may respond negatively to the proposed management. Our study plan is designed to determine how they will respond; responses by prey populations will show up in the survival and reproduction of the predators. If the predators (e.g., fishers) do indeed respond positively to the treatments, we will know it.

We discuss the reason that we rejected a guild or biodiversity approach to addressing wildlife in the program. Based on modeling efforts, there is reason to think that more species may benefit from the treatments than will be negatively affected. However, those that may benefit are not the ones impeding forest management.

We are aware of and apologize for the very short time line allowed for the production of the draft work plan. We realize it is less than ideal.

We have not addressed the issue that the wildlife species selected for study in this project be “a valid indicator for the response of a wide variety of other species,” nor argued that any particular species can “Indicate” the ecological status or trend of others. The “indicator species” or “species guild” concepts are controversial and not of demonstrated utility. We selected species for inclusion in this project and prioritized them according to the criteria in the work plan. We do not claim that the results from the work as proposed can necessarily be generalized to other species.

We anticipate the ability to evaluate some of the landscape issues of fisher viability through monitoring dispersal from and detecting new individuals dispersing into the study area(s). Other insights will come from analyses of reproduction and mortality. However, a large-scale landscape or metapopulation analysis of the fisher population in the Sierra Nevada, as valuable as that would be, is beyond the scope of the proposed work.

We are aware of the current thought and evaluation of fisher reintroductions, and the issue regarding the viability of any proposed source population. If such a reintroduction program were to be adopted in the present project, it would be consistent with current standards and methodologies.

Susan Britting, said at 11:50 p.m. on 2 March 2006 ,

The Sierra Nevada Forest Protection Campaign is a coalition of 98 conservation organizations united in our focus on land management planning and implementation on national forest lands in the Sierra Nevada. We are seriously concerned about management on national forest lands that compromises species and ecosystem needs.

It is our intention to provide detailed comments on the work plan in the near future. At this point, we seek to highlight the need to fully meet the budgetary requirements of the proposed work plan. To address the scientific and management questions posed in the work plan, the research must be fully funded. Anything short of full funding will not produce credible or useful results.

The work plan clearly identifies that fisher in the Sierra Nevada are highly vulnerable to population losses and further extirpation. The US Fish and Wildlife recently found that the listing of fisher under the Endangered Species Act may be warranted and cited habitat destruction and modification from timber harvest as factors of concern. We agree with these conclusions. The high vulnerability of fisher and the current threats to its habitat are precisely the reasons why a robust and meaningful assessment of the effects of management on fisher must be completed regardless of the cost. Beyond this, if funding for the fisher element of the work plan is reduced to the extent that the monitoring component is inadequate, the adaptive management plan will not be legitimate.

Susan Britting Science and Policy Advisor Sierra Nevada Forest Protection Campaign

Please accept the our following comments on this study proposal.

  1. The Tahoe National Forest remains committed and excited about hosting this study. We believe that the proposal will improve the design and effectiveness of our projects currently planned for the area, and will also provide important insight that can be used elsewhere on the forest.

  2. We would like to discuss further the anticipated impacts on Water Quantity and Quality. At the scale and intensity that we are working at, we would not anticipate changes in flow regime. We would actually expect greater negative changes in water quality by not managing our watersheds. We need to compare any effects of our management with the anticipated effects of not managing the ecosystem.

  3. In examining wildlife responses to treatments, we hope that your assumptions will include "growing out" the landscape in and around treatments, so as to recognize the dynamic nature of our forests and "suitable habitat".

  4. The proposal will leverage and will likely capitalize on past investments the Region has made in the area. This includes intensive vegetation plots and mapping and Fire Regime Condition Class Mapping, all of which are central to designing effective, integrated vegetation projects.

  5. This draft workplan follows the American River Ranger District outyear vegetation management program. We are very supportive of any effort to learn more about potential treatments for the Manila Canyon design project area. We are also looking forward to learning more about implementation of the Sierra Nevada Forest Plan Amendment 2004 and the adaptive management strategies available to us.

Thank you for the opportunity to participate in this effort.

Jan Cutts District Ranger American River RD/Tahoe NF jcutts@fs.fed.us 530-367-2224

Erika Lovejoy said at 4:40 p.m. on 27 February 2006 ,

The Draft Workplan was not available at the web link we were originally given, and was also not released until February 21st, thus these comments will be brief.

Thank you for the opportunity to comment on the SNAMP workplan. Please consider the following questions and comments:

(1) Is an external scientific peer review proposed? A scientific peer review is critical to ensure: 1) management questions are clearly articulated, and 2) the study design is adequate to answer the management questions posed. "Adaptive management" can only work if the study designs are capable of truly answering the management questions. We recommend peer review be conducted by a panel of at least three external scientists with no connection to the USFS (i.e., not using current consultants or those with financial or other potentially conflicting interests) and be incorporated in to the workplan.

(2) Our understanding is that your on-the-ground projects will not be conducted within the Lahontan Region, however the results will be extrapolated to this Region. It would be very useful if your study design considered Lake Tahoe conditions, and those of other sensitive Sierra Nevada ecosystems. Note that the Lake Tahoe Basin is a highly sensitive area and not all management approaches may be appropriate for this area in terms of both potential negative environmental impacts and related regulatory restrictions. However, resources managers are very interested in what management strategies could be applied in the Tahoe Basin for fuels hazard reduction projects, while still protecting water quality and habitat. SPLATS can be especially problematic. While they provide for fire protection, they do not allow for wildlife habitat and have bare soils, which maximize erosion potential. They are essentially barren land. Are other methods being explored that can restore forests in a way that can be beneficial to water quality, fire protection, biodiversity, and overall forest health? The study focus on SPLATS seems to be very limiting. Given the amount of fuels hazard reduction work that is expected to occur over the next decade (playing “catch-up” for work that hasn’t been done yet), it would be very useful if the study examined other techniques that will allow for a more balanced set of “future desired conditions”, which is a stated goal mentioned in your study proposal.

(3) Models are being proposed as an evaluation tool. It will be critically important that the limitations of these models be clearly presented, so the study results do not initiate the use of inappropriate management strategies, especially in sensitive regions like the Lake Tahoe Basin.

(4) It would be useful for the study to clearly define soil types and conditions where treatments were conducted, so the study results can be appropriately extrapolated to other geographic areas in the Sierra Nevada. For example, for the portions of the project area treated with mastication, we would be interested in knowing what soil types and conditions (slope, moisture, vegetation) were present, in addition to the overall study results showing the impacts to soils, water quality, vegetation, forest health, and fire protection.

Erika Lovejoy Environmental Scientist Lahontan Regional Water Quality Control Board 2501 Lake Tahoe Blvd South Lake Tahoe, CA 96150

Cynthia Wilkerson said at 5:39 p.m. on 26 February 2006 ,

Please note: I sent a copy of my full letter directly to UC Davis and am now posting the entire letter in each section as it contains reference to each section and should be read in its entirety as opposed to piecemeal.

February 26, 2006

Comments on February 20, 2006 Draft Workplan “Learning how to apply adaptive management to land management in the Sierra Nevada.”

Defenders of Wildlife (“Defenders”) is pleased to submit these comments on the above document (heretofore “Draft Workplan”). Defenders is a national, non-profit wildlife advocacy organization committed to the protection of wild, native plants and animals in their natural communities. We represent over 400,000 members throughout the United States, nearly 100,000 of which reside in California.

Defenders, California Program has a programmatic focus on the Sierra Nevada, with current programs focused on forest carnivores (primarily the Pacific fisher) and impacts of grazing on biodiversity. We were unable to make the initial December 9, 2005 public meeting on the focus of the Draft Workplan, but have submitted some input into that process to date and remain committed to engaging in this process as it moves forward.

Our first comments relates to the unreasonable timeline imposed on public comments to this draft. We were originally informed that we would have one week between February 10th and the 17th to review this draft. The draft was not released until February 21st with a due date of February 26th. We understand that there are tight timelines that the authors are working under, but this should not allow extensions on their part to necessitate unreasonable and unrealistic timelines for public input. At the very minimum, the public should be allowed 2 full working weeks to provide substantive input. In this case, only 4 working days were allotted. Because of this, the only possible way to provide input in our case is to conduct a cursory review over the weekend. This is not an acceptable regime for functional public input.

As for the content of the Draft Workplan itself, we are appreciative of the concerted attempt to design a course of action that is true to the precepts of Adaptive Management and Monitoring to the extent that the proposal incorporates a priori research questions designed to be tested by the management practices which will in turn be responsive to the results of the research.

One main question that we have is why is the approach limited to the west side of the Sierra Nevada only? As the Sierra Nevada Forest Plan Amendment covers both west and east side forest management, it would appear that this would be a major omission.

We are generally supportive of the conceptual framework of using a landscape planning approach at the fireshed level, and incorporating elements of Fire and Forest Health, Public Participation, Water Quality and Quantity, and Wildlife. The following includes our specific comments on each of these sections of the Draft Workplan:

Public Participation:

We appreciate that Public Participation is given equal consideration in this process. It is a critical element to effective development and implementation of an adaptive management approach. In particular, we are pleased to see the call for staff to be wholly responsible for this portion of the Workplan and for the focus on increasing opportunities for input from local stakeholders. We support the general model that the participatory process section lays out. One concern is that the “community of learning” approach may not allow for direct input from the public. This may already be the plan, but we specifically request that direct input be allowed in both the “community of learning” and “community of collaboration” cases.

We support the use of web-based tools, but they must be accompanied by sufficient advertising and instructional outreach to inform people of their availability and how to use them. We also suggest that there be outreach via the public library system to capture the input of publics that may not have to the internet via a personal computer. An outreach element that include public instructional workshops at public libraries could facilitate informed participation to those with and without personal access to the internet. As mentioned previously, the public input time period should be reasonable. Depending on the level of analysis required, this time period should range from a minimum of 2 working weeks for shorter products (such as the 27 page workplan) to up to 3 months for larger documents (on the scale of a traditional NEPA or CEQA document). In addition to the geographically-based web comments, there must also be a section for general comments that are relevant to the entire geographic scope and the process itself.

We also suggest that regional workshops be developed throughout the life of this process where the public can be shown various simulated results of management options being considered. This has been done in regional transportation planning efforts (e.g. SACOG’s Regional Blueprint outreach workshops) and is a very effective educational and participatory tool that would apply to this situation.

For evaluation purposes, we suggest that options for gathering feedback at the time of input on the web system. This could provide general feedback on how long it took to get the input registered, if they felt they had effectively registered their comments, options of improvement, and the ability to capture instances where someone wanted to input something and was unable to do so for stated reasons. This could be done in the form of a pop-up window that folks could choose to complete or not, with response rates also reported.

Water Quality and Quantity: We are generally supportive of the approach outlined under this section. Defenders is particularly pleased to see that standard macro invertebrate indices will be used to determine the biological impacts of the management treatments.

Wildlife: We support the decision to prioritize which species should be the focus of the wildlife impacts analysis. It is not feasible to monitor all potentially affected species. We support the criteria laid out in the Draft Workplan as scientifically sound and would like to ask for one additional criteria. There must be some evidence that the focal species is a valid indicator for the response of a wide variety of other species in order for one or a few species to be used as a proxy for the response of several hundred. We believe that this can be demonstrated for the species currently prioritized by the Draft Workplan.

Additionally, it is important that the impacts to wildlife species also incorporate information regarding the landscape context of management actions. It may very well be that an individual treatment will have a negative impact on the ability of that area to sustain fisher populations. However, of more importance to the larger management throughout the Sierra Nevada is the ability of the entire landscape to provide for the sustainability of the species as a whole. It is possible that small, localized effects can be absorbed by the population if the entire landscape level management allows for viable populations. The authors make reference to this concept when they mention that treatments may very well lead to population sinks for a species. The availability of nearby population sources/ refugia and their ability to allow ultimate persistence of the species should be the focus of the wildlife analysis.

Defenders strongly agrees with the assertion that “simply documenting that some species will respond favorably [to the proposed treatment] will not solve the management dilemma we are attempting to resolve.” Beyond the implications of the public needing to understand and support the process and management results of the monitoring, we submit that all monitoring must be targeted at asking a question that is relevant to and result in direction to the management program.

Defenders is very concerned over the issue of the local extirpation in the northern study site. We do support the suggestion by the document that reintroduction could provide insight into the adaptive management process. We caution that the use of standards set by other successful fisher reintroductions be followed, and are specifically concerned about the ability of a source population from California to maintain the level of removals needed to establish a viable population. We have conducted a workshop on criteria for successful fisher reintroductions and ask that these guidelines be used as well as the methodology of a detailed and considered feasibility assessment and implementation plan that are both available for public review be included in any reintroduction efforts. These efforts must be conducted in the context of fisher conservation efforts throughout the west and in California. That said, we assert that a well-designed reintroduction to the northern Sierra would provide substantial conservation benefits to the species as well as critical information for the overall goals of the Draft Workplan.

Conclusion: Finally, we support the ambitious and reasoned scientific approach that the Draft Workplan lays out and caution that cost not be used an excuse for complete inaction. We look forward to continued participation in the on-going program of Adaptive Management and Monitoring in the Sierra Nevada. Should you have any questions, I can be contacted directly at: 916-313-5800 ext. 110 or cwilkerson@defenders.org.

Sincerely,

Cynthia Wilkerson California Representative

Defenders of Wildlife 1303 J Street, Suite 270 Sacramento, CA 95814

Cynthia Wilkerson said at 5:39 p.m. on 26 February 2006 ,

Please note: I sent a copy of my full letter directly to UC Davis and am now posting the entire letter in each section as it contains reference to each section and should be read in its entirety as opposed to piecemeal.

February 26, 2006

Comments on February 20, 2006 Draft Workplan “Learning how to apply adaptive management to land management in the Sierra Nevada.”

Defenders of Wildlife (“Defenders”) is pleased to submit these comments on the above document (heretofore “Draft Workplan”). Defenders is a national, non-profit wildlife advocacy organization committed to the protection of wild, native plants and animals in their natural communities. We represent over 400,000 members throughout the United States, nearly 100,000 of which reside in California.

Defenders, California Program has a programmatic focus on the Sierra Nevada, with current programs focused on forest carnivores (primarily the Pacific fisher) and impacts of grazing on biodiversity. We were unable to make the initial December 9, 2005 public meeting on the focus of the Draft Workplan, but have submitted some input into that process to date and remain committed to engaging in this process as it moves forward.

Our first comments relates to the unreasonable timeline imposed on public comments to this draft. We were originally informed that we would have one week between February 10th and the 17th to review this draft. The draft was not released until February 21st with a due date of February 26th. We understand that there are tight timelines that the authors are working under, but this should not allow extensions on their part to necessitate unreasonable and unrealistic timelines for public input. At the very minimum, the public should be allowed 2 full working weeks to provide substantive input. In this case, only 4 working days were allotted. Because of this, the only possible way to provide input in our case is to conduct a cursory review over the weekend. This is not an acceptable regime for functional public input.

As for the content of the Draft Workplan itself, we are appreciative of the concerted attempt to design a course of action that is true to the precepts of Adaptive Management and Monitoring to the extent that the proposal incorporates a priori research questions designed to be tested by the management practices which will in turn be responsive to the results of the research.

One main question that we have is why is the approach limited to the west side of the Sierra Nevada only? As the Sierra Nevada Forest Plan Amendment covers both west and east side forest management, it would appear that this would be a major omission.

We are generally supportive of the conceptual framework of using a landscape planning approach at the fireshed level, and incorporating elements of Fire and Forest Health, Public Participation, Water Quality and Quantity, and Wildlife. The following includes our specific comments on each of these sections of the Draft Workplan:

Public Participation:

We appreciate that Public Participation is given equal consideration in this process. It is a critical element to effective development and implementation of an adaptive management approach. In particular, we are pleased to see the call for staff to be wholly responsible for this portion of the Workplan and for the focus on increasing opportunities for input from local stakeholders. We support the general model that the participatory process section lays out. One concern is that the “community of learning” approach may not allow for direct input from the public. This may already be the plan, but we specifically request that direct input be allowed in both the “community of learning” and “community of collaboration” cases.

We support the use of web-based tools, but they must be accompanied by sufficient advertising and instructional outreach to inform people of their availability and how to use them. We also suggest that there be outreach via the public library system to capture the input of publics that may not have to the internet via a personal computer. An outreach element that include public instructional workshops at public libraries could facilitate informed participation to those with and without personal access to the internet. As mentioned previously, the public input time period should be reasonable. Depending on the level of analysis required, this time period should range from a minimum of 2 working weeks for shorter products (such as the 27 page workplan) to up to 3 months for larger documents (on the scale of a traditional NEPA or CEQA document). In addition to the geographically-based web comments, there must also be a section for general comments that are relevant to the entire geographic scope and the process itself.

We also suggest that regional workshops be developed throughout the life of this process where the public can be shown various simulated results of management options being considered. This has been done in regional transportation planning efforts (e.g. SACOG’s Regional Blueprint outreach workshops) and is a very effective educational and participatory tool that would apply to this situation.

For evaluation purposes, we suggest that options for gathering feedback at the time of input on the web system. This could provide general feedback on how long it took to get the input registered, if they felt they had effectively registered their comments, options of improvement, and the ability to capture instances where someone wanted to input something and was unable to do so for stated reasons. This could be done in the form of a pop-up window that folks could choose to complete or not, with response rates also reported.

Water Quality and Quantity: We are generally supportive of the approach outlined under this section. Defenders is particularly pleased to see that standard macro invertebrate indices will be used to determine the biological impacts of the management treatments.

Wildlife: We support the decision to prioritize which species should be the focus of the wildlife impacts analysis. It is not feasible to monitor all potentially affected species. We support the criteria laid out in the Draft Workplan as scientifically sound and would like to ask for one additional criteria. There must be some evidence that the focal species is a valid indicator for the response of a wide variety of other species in order for one or a few species to be used as a proxy for the response of several hundred. We believe that this can be demonstrated for the species currently prioritized by the Draft Workplan.

Additionally, it is important that the impacts to wildlife species also incorporate information regarding the landscape context of management actions. It may very well be that an individual treatment will have a negative impact on the ability of that area to sustain fisher populations. However, of more importance to the larger management throughout the Sierra Nevada is the ability of the entire landscape to provide for the sustainability of the species as a whole. It is possible that small, localized effects can be absorbed by the population if the entire landscape level management allows for viable populations. The authors make reference to this concept when they mention that treatments may very well lead to population sinks for a species. The availability of nearby population sources/ refugia and their ability to allow ultimate persistence of the species should be the focus of the wildlife analysis.

Defenders strongly agrees with the assertion that “simply documenting that some species will respond favorably [to the proposed treatment] will not solve the management dilemma we are attempting to resolve.” Beyond the implications of the public needing to understand and support the process and management results of the monitoring, we submit that all monitoring must be targeted at asking a question that is relevant to and result in direction to the management program.

Defenders is very concerned over the issue of the local extirpation in the northern study site. We do support the suggestion by the document that reintroduction could provide insight into the adaptive management process. We caution that the use of standards set by other successful fisher reintroductions be followed, and are specifically concerned about the ability of a source population from California to maintain the level of removals needed to establish a viable population. We have conducted a workshop on criteria for successful fisher reintroductions and ask that these guidelines be used as well as the methodology of a detailed and considered feasibility assessment and implementation plan that are both available for public review be included in any reintroduction efforts. These efforts must be conducted in the context of fisher conservation efforts throughout the west and in California. That said, we assert that a well-designed reintroduction to the northern Sierra would provide substantial conservation benefits to the species as well as critical information for the overall goals of the Draft Workplan.

Conclusion: Finally, we support the ambitious and reasoned scientific approach that the Draft Workplan lays out and caution that cost not be used an excuse for complete inaction. We look forward to continued participation in the on-going program of Adaptive Management and Monitoring in the Sierra Nevada. Should you have any questions, I can be contacted directly at: 916-313-5800 ext. 110 or cwilkerson@defenders.org.

Sincerely,

Cynthia Wilkerson California Representative

Defenders of Wildlife 1303 J Street, Suite 270 Sacramento, CA 95814

Cynthia Wilkerson said at 5:39 p.m. on 26 February 2006 ,

Please note: I sent a copy of my full letter directly to UC Davis and am now posting the entire letter in each section as it contains reference to each section and should be read in its entirety as opposed to piecemeal.

February 26, 2006

Comments on February 20, 2006 Draft Workplan “Learning how to apply adaptive management to land management in the Sierra Nevada.”

Defenders of Wildlife (“Defenders”) is pleased to submit these comments on the above document (heretofore “Draft Workplan”). Defenders is a national, non-profit wildlife advocacy organization committed to the protection of wild, native plants and animals in their natural communities. We represent over 400,000 members throughout the United States, nearly 100,000 of which reside in California.

Defenders, California Program has a programmatic focus on the Sierra Nevada, with current programs focused on forest carnivores (primarily the Pacific fisher) and impacts of grazing on biodiversity. We were unable to make the initial December 9, 2005 public meeting on the focus of the Draft Workplan, but have submitted some input into that process to date and remain committed to engaging in this process as it moves forward.

Our first comments relates to the unreasonable timeline imposed on public comments to this draft. We were originally informed that we would have one week between February 10th and the 17th to review this draft. The draft was not released until February 21st with a due date of February 26th. We understand that there are tight timelines that the authors are working under, but this should not allow extensions on their part to necessitate unreasonable and unrealistic timelines for public input. At the very minimum, the public should be allowed 2 full working weeks to provide substantive input. In this case, only 4 working days were allotted. Because of this, the only possible way to provide input in our case is to conduct a cursory review over the weekend. This is not an acceptable regime for functional public input.

As for the content of the Draft Workplan itself, we are appreciative of the concerted attempt to design a course of action that is true to the precepts of Adaptive Management and Monitoring to the extent that the proposal incorporates a priori research questions designed to be tested by the management practices which will in turn be responsive to the results of the research.

One main question that we have is why is the approach limited to the west side of the Sierra Nevada only? As the Sierra Nevada Forest Plan Amendment covers both west and east side forest management, it would appear that this would be a major omission.

We are generally supportive of the conceptual framework of using a landscape planning approach at the fireshed level, and incorporating elements of Fire and Forest Health, Public Participation, Water Quality and Quantity, and Wildlife. The following includes our specific comments on each of these sections of the Draft Workplan:

Public Participation:

We appreciate that Public Participation is given equal consideration in this process. It is a critical element to effective development and implementation of an adaptive management approach. In particular, we are pleased to see the call for staff to be wholly responsible for this portion of the Workplan and for the focus on increasing opportunities for input from local stakeholders. We support the general model that the participatory process section lays out. One concern is that the “community of learning” approach may not allow for direct input from the public. This may already be the plan, but we specifically request that direct input be allowed in both the “community of learning” and “community of collaboration” cases.

We support the use of web-based tools, but they must be accompanied by sufficient advertising and instructional outreach to inform people of their availability and how to use them. We also suggest that there be outreach via the public library system to capture the input of publics that may not have to the internet via a personal computer. An outreach element that include public instructional workshops at public libraries could facilitate informed participation to those with and without personal access to the internet. As mentioned previously, the public input time period should be reasonable. Depending on the level of analysis required, this time period should range from a minimum of 2 working weeks for shorter products (such as the 27 page workplan) to up to 3 months for larger documents (on the scale of a traditional NEPA or CEQA document). In addition to the geographically-based web comments, there must also be a section for general comments that are relevant to the entire geographic scope and the process itself.

We also suggest that regional workshops be developed throughout the life of this process where the public can be shown various simulated results of management options being considered. This has been done in regional transportation planning efforts (e.g. SACOG’s Regional Blueprint outreach workshops) and is a very effective educational and participatory tool that would apply to this situation.

For evaluation purposes, we suggest that options for gathering feedback at the time of input on the web system. This could provide general feedback on how long it took to get the input registered, if they felt they had effectively registered their comments, options of improvement, and the ability to capture instances where someone wanted to input something and was unable to do so for stated reasons. This could be done in the form of a pop-up window that folks could choose to complete or not, with response rates also reported.

Water Quality and Quantity: We are generally supportive of the approach outlined under this section. Defenders is particularly pleased to see that standard macro invertebrate indices will be used to determine the biological impacts of the management treatments.

Wildlife: We support the decision to prioritize which species should be the focus of the wildlife impacts analysis. It is not feasible to monitor all potentially affected species. We support the criteria laid out in the Draft Workplan as scientifically sound and would like to ask for one additional criteria. There must be some evidence that the focal species is a valid indicator for the response of a wide variety of other species in order for one or a few species to be used as a proxy for the response of several hundred. We believe that this can be demonstrated for the species currently prioritized by the Draft Workplan.

Additionally, it is important that the impacts to wildlife species also incorporate information regarding the landscape context of management actions. It may very well be that an individual treatment will have a negative impact on the ability of that area to sustain fisher populations. However, of more importance to the larger management throughout the Sierra Nevada is the ability of the entire landscape to provide for the sustainability of the species as a whole. It is possible that small, localized effects can be absorbed by the population if the entire landscape level management allows for viable populations. The authors make reference to this concept when they mention that treatments may very well lead to population sinks for a species. The availability of nearby population sources/ refugia and their ability to allow ultimate persistence of the species should be the focus of the wildlife analysis.

Defenders strongly agrees with the assertion that “simply documenting that some species will respond favorably [to the proposed treatment] will not solve the management dilemma we are attempting to resolve.” Beyond the implications of the public needing to understand and support the process and management results of the monitoring, we submit that all monitoring must be targeted at asking a question that is relevant to and result in direction to the management program.

Defenders is very concerned over the issue of the local extirpation in the northern study site. We do support the suggestion by the document that reintroduction could provide insight into the adaptive management process. We caution that the use of standards set by other successful fisher reintroductions be followed, and are specifically concerned about the ability of a source population from California to maintain the level of removals needed to establish a viable population. We have conducted a workshop on criteria for successful fisher reintroductions and ask that these guidelines be used as well as the methodology of a detailed and considered feasibility assessment and implementation plan that are both available for public review be included in any reintroduction efforts. These efforts must be conducted in the context of fisher conservation efforts throughout the west and in California. That said, we assert that a well-designed reintroduction to the northern Sierra would provide substantial conservation benefits to the species as well as critical information for the overall goals of the Draft Workplan.

Conclusion: Finally, we support the ambitious and reasoned scientific approach that the Draft Workplan lays out and caution that cost not be used an excuse for complete inaction. We look forward to continued participation in the on-going program of Adaptive Management and Monitoring in the Sierra Nevada. Should you have any questions, I can be contacted directly at: 916-313-5800 ext. 110 or cwilkerson@defenders.org.

Sincerely,

Cynthia Wilkerson California Representative

Defenders of Wildlife 1303 J Street, Suite 270 Sacramento, CA 95814

Cynthia Wilkerson said at 5:38 p.m. on 26 February 2006 ,

Please note: I sent a copy of my full letter directly to UC Davis and am now posting the entire letter in each section as it contains reference to each section and should be read in its entirety as opposed to piecemeal.

February 26, 2006

Comments on February 20, 2006 Draft Workplan “Learning how to apply adaptive management to land management in the Sierra Nevada.”

Defenders of Wildlife (“Defenders”) is pleased to submit these comments on the above document (heretofore “Draft Workplan”). Defenders is a national, non-profit wildlife advocacy organization committed to the protection of wild, native plants and animals in their natural communities. We represent over 400,000 members throughout the United States, nearly 100,000 of which reside in California.

Defenders, California Program has a programmatic focus on the Sierra Nevada, with current programs focused on forest carnivores (primarily the Pacific fisher) and impacts of grazing on biodiversity. We were unable to make the initial December 9, 2005 public meeting on the focus of the Draft Workplan, but have submitted some input into that process to date and remain committed to engaging in this process as it moves forward.

Our first comments relates to the unreasonable timeline imposed on public comments to this draft. We were originally informed that we would have one week between February 10th and the 17th to review this draft. The draft was not released until February 21st with a due date of February 26th. We understand that there are tight timelines that the authors are working under, but this should not allow extensions on their part to necessitate unreasonable and unrealistic timelines for public input. At the very minimum, the public should be allowed 2 full working weeks to provide substantive input. In this case, only 4 working days were allotted. Because of this, the only possible way to provide input in our case is to conduct a cursory review over the weekend. This is not an acceptable regime for functional public input.

As for the content of the Draft Workplan itself, we are appreciative of the concerted attempt to design a course of action that is true to the precepts of Adaptive Management and Monitoring to the extent that the proposal incorporates a priori research questions designed to be tested by the management practices which will in turn be responsive to the results of the research.

One main question that we have is why is the approach limited to the west side of the Sierra Nevada only? As the Sierra Nevada Forest Plan Amendment covers both west and east side forest management, it would appear that this would be a major omission.

We are generally supportive of the conceptual framework of using a landscape planning approach at the fireshed level, and incorporating elements of Fire and Forest Health, Public Participation, Water Quality and Quantity, and Wildlife. The following includes our specific comments on each of these sections of the Draft Workplan:

Public Participation:

We appreciate that Public Participation is given equal consideration in this process. It is a critical element to effective development and implementation of an adaptive management approach. In particular, we are pleased to see the call for staff to be wholly responsible for this portion of the Workplan and for the focus on increasing opportunities for input from local stakeholders. We support the general model that the participatory process section lays out. One concern is that the “community of learning” approach may not allow for direct input from the public. This may already be the plan, but we specifically request that direct input be allowed in both the “community of learning” and “community of collaboration” cases.

We support the use of web-based tools, but they must be accompanied by sufficient advertising and instructional outreach to inform people of their availability and how to use them. We also suggest that there be outreach via the public library system to capture the input of publics that may not have to the internet via a personal computer. An outreach element that include public instructional workshops at public libraries could facilitate informed participation to those with and without personal access to the internet. As mentioned previously, the public input time period should be reasonable. Depending on the level of analysis required, this time period should range from a minimum of 2 working weeks for shorter products (such as the 27 page workplan) to up to 3 months for larger documents (on the scale of a traditional NEPA or CEQA document). In addition to the geographically-based web comments, there must also be a section for general comments that are relevant to the entire geographic scope and the process itself.

We also suggest that regional workshops be developed throughout the life of this process where the public can be shown various simulated results of management options being considered. This has been done in regional transportation planning efforts (e.g. SACOG’s Regional Blueprint outreach workshops) and is a very effective educational and participatory tool that would apply to this situation.

For evaluation purposes, we suggest that options for gathering feedback at the time of input on the web system. This could provide general feedback on how long it took to get the input registered, if they felt they had effectively registered their comments, options of improvement, and the ability to capture instances where someone wanted to input something and was unable to do so for stated reasons. This could be done in the form of a pop-up window that folks could choose to complete or not, with response rates also reported.

Water Quality and Quantity: We are generally supportive of the approach outlined under this section. Defenders is particularly pleased to see that standard macro invertebrate indices will be used to determine the biological impacts of the management treatments.

Wildlife: We support the decision to prioritize which species should be the focus of the wildlife impacts analysis. It is not feasible to monitor all potentially affected species. We support the criteria laid out in the Draft Workplan as scientifically sound and would like to ask for one additional criteria. There must be some evidence that the focal species is a valid indicator for the response of a wide variety of other species in order for one or a few species to be used as a proxy for the response of several hundred. We believe that this can be demonstrated for the species currently prioritized by the Draft Workplan.

Additionally, it is important that the impacts to wildlife species also incorporate information regarding the landscape context of management actions. It may very well be that an individual treatment will have a negative impact on the ability of that area to sustain fisher populations. However, of more importance to the larger management throughout the Sierra Nevada is the ability of the entire landscape to provide for the sustainability of the species as a whole. It is possible that small, localized effects can be absorbed by the population if the entire landscape level management allows for viable populations. The authors make reference to this concept when they mention that treatments may very well lead to population sinks for a species. The availability of nearby population sources/ refugia and their ability to allow ultimate persistence of the species should be the focus of the wildlife analysis.

Defenders strongly agrees with the assertion that “simply documenting that some species will respond favorably [to the proposed treatment] will not solve the management dilemma we are attempting to resolve.” Beyond the implications of the public needing to understand and support the process and management results of the monitoring, we submit that all monitoring must be targeted at asking a question that is relevant to and result in direction to the management program.

Defenders is very concerned over the issue of the local extirpation in the northern study site. We do support the suggestion by the document that reintroduction could provide insight into the adaptive management process. We caution that the use of standards set by other successful fisher reintroductions be followed, and are specifically concerned about the ability of a source population from California to maintain the level of removals needed to establish a viable population. We have conducted a workshop on criteria for successful fisher reintroductions and ask that these guidelines be used as well as the methodology of a detailed and considered feasibility assessment and implementation plan that are both available for public review be included in any reintroduction efforts. These efforts must be conducted in the context of fisher conservation efforts throughout the west and in California. That said, we assert that a well-designed reintroduction to the northern Sierra would provide substantial conservation benefits to the species as well as critical information for the overall goals of the Draft Workplan.

Conclusion: Finally, we support the ambitious and reasoned scientific approach that the Draft Workplan lays out and caution that cost not be used an excuse for complete inaction. We look forward to continued participation in the on-going program of Adaptive Management and Monitoring in the Sierra Nevada. Should you have any questions, I can be contacted directly at: 916-313-5800 ext. 110 or cwilkerson@defenders.org.

Sincerely,

Cynthia Wilkerson California Representative

Defenders of Wildlife 1303 J Street, Suite 270 Sacramento, CA 95814

Cynthia Wilkerson said at 5:37 p.m. on 26 February 2006 ,

Please note: I sent a copy of my full letter directly to UC Davis and am now posting the entire letter in each section as it contains reference to each section and should be read in its entirety as opposed to piecemeal.

February 26, 2006

Comments on February 20, 2006 Draft Workplan “Learning how to apply adaptive management to land management in the Sierra Nevada.”

Defenders of Wildlife (“Defenders”) is pleased to submit these comments on the above document (heretofore “Draft Workplan”). Defenders is a national, non-profit wildlife advocacy organization committed to the protection of wild, native plants and animals in their natural communities. We represent over 400,000 members throughout the United States, nearly 100,000 of which reside in California.

Defenders, California Program has a programmatic focus on the Sierra Nevada, with current programs focused on forest carnivores (primarily the Pacific fisher) and impacts of grazing on biodiversity. We were unable to make the initial December 9, 2005 public meeting on the focus of the Draft Workplan, but have submitted some input into that process to date and remain committed to engaging in this process as it moves forward.

Our first comments relates to the unreasonable timeline imposed on public comments to this draft. We were originally informed that we would have one week between February 10th and the 17th to review this draft. The draft was not released until February 21st with a due date of February 26th. We understand that there are tight timelines that the authors are working under, but this should not allow extensions on their part to necessitate unreasonable and unrealistic timelines for public input. At the very minimum, the public should be allowed 2 full working weeks to provide substantive input. In this case, only 4 working days were allotted. Because of this, the only possible way to provide input in our case is to conduct a cursory review over the weekend. This is not an acceptable regime for functional public input.

As for the content of the Draft Workplan itself, we are appreciative of the concerted attempt to design a course of action that is true to the precepts of Adaptive Management and Monitoring to the extent that the proposal incorporates a priori research questions designed to be tested by the management practices which will in turn be responsive to the results of the research.

One main question that we have is why is the approach limited to the west side of the Sierra Nevada only? As the Sierra Nevada Forest Plan Amendment covers both west and east side forest management, it would appear that this would be a major omission.

We are generally supportive of the conceptual framework of using a landscape planning approach at the fireshed level, and incorporating elements of Fire and Forest Health, Public Participation, Water Quality and Quantity, and Wildlife. The following includes our specific comments on each of these sections of the Draft Workplan:

Public Participation:

We appreciate that Public Participation is given equal consideration in this process. It is a critical element to effective development and implementation of an adaptive management approach. In particular, we are pleased to see the call for staff to be wholly responsible for this portion of the Workplan and for the focus on increasing opportunities for input from local stakeholders. We support the general model that the participatory process section lays out. One concern is that the “community of learning” approach may not allow for direct input from the public. This may already be the plan, but we specifically request that direct input be allowed in both the “community of learning” and “community of collaboration” cases.

We support the use of web-based tools, but they must be accompanied by sufficient advertising and instructional outreach to inform people of their availability and how to use them. We also suggest that there be outreach via the public library system to capture the input of publics that may not have to the internet via a personal computer. An outreach element that include public instructional workshops at public libraries could facilitate informed participation to those with and without personal access to the internet. As mentioned previously, the public input time period should be reasonable. Depending on the level of analysis required, this time period should range from a minimum of 2 working weeks for shorter products (such as the 27 page workplan) to up to 3 months for larger documents (on the scale of a traditional NEPA or CEQA document). In addition to the geographically-based web comments, there must also be a section for general comments that are relevant to the entire geographic scope and the process itself.

We also suggest that regional workshops be developed throughout the life of this process where the public can be shown various simulated results of management options being considered. This has been done in regional transportation planning efforts (e.g. SACOG’s Regional Blueprint outreach workshops) and is a very effective educational and participatory tool that would apply to this situation.

For evaluation purposes, we suggest that options for gathering feedback at the time of input on the web system. This could provide general feedback on how long it took to get the input registered, if they felt they had effectively registered their comments, options of improvement, and the ability to capture instances where someone wanted to input something and was unable to do so for stated reasons. This could be done in the form of a pop-up window that folks could choose to complete or not, with response rates also reported.

Water Quality and Quantity: We are generally supportive of the approach outlined under this section. Defenders is particularly pleased to see that standard macro invertebrate indices will be used to determine the biological impacts of the management treatments.

Wildlife: We support the decision to prioritize which species should be the focus of the wildlife impacts analysis. It is not feasible to monitor all potentially affected species. We support the criteria laid out in the Draft Workplan as scientifically sound and would like to ask for one additional criteria. There must be some evidence that the focal species is a valid indicator for the response of a wide variety of other species in order for one or a few species to be used as a proxy for the response of several hundred. We believe that this can be demonstrated for the species currently prioritized by the Draft Workplan.

Additionally, it is important that the impacts to wildlife species also incorporate information regarding the landscape context of management actions. It may very well be that an individual treatment will have a negative impact on the ability of that area to sustain fisher populations. However, of more importance to the larger management throughout the Sierra Nevada is the ability of the entire landscape to provide for the sustainability of the species as a whole. It is possible that small, localized effects can be absorbed by the population if the entire landscape level management allows for viable populations. The authors make reference to this concept when they mention that treatments may very well lead to population sinks for a species. The availability of nearby population sources/ refugia and their ability to allow ultimate persistence of the species should be the focus of the wildlife analysis.

Defenders strongly agrees with the assertion that “simply documenting that some species will respond favorably [to the proposed treatment] will not solve the management dilemma we are attempting to resolve.” Beyond the implications of the public needing to understand and support the process and management results of the monitoring, we submit that all monitoring must be targeted at asking a question that is relevant to and result in direction to the management program.

Defenders is very concerned over the issue of the local extirpation in the northern study site. We do support the suggestion by the document that reintroduction could provide insight into the adaptive management process. We caution that the use of standards set by other successful fisher reintroductions be followed, and are specifically concerned about the ability of a source population from California to maintain the level of removals needed to establish a viable population. We have conducted a workshop on criteria for successful fisher reintroductions and ask that these guidelines be used as well as the methodology of a detailed and considered feasibility assessment and implementation plan that are both available for public review be included in any reintroduction efforts. These efforts must be conducted in the context of fisher conservation efforts throughout the west and in California. That said, we assert that a well-designed reintroduction to the northern Sierra would provide substantial conservation benefits to the species as well as critical information for the overall goals of the Draft Workplan.

Conclusion: Finally, we support the ambitious and reasoned scientific approach that the Draft Workplan lays out and caution that cost not be used an excuse for complete inaction. We look forward to continued participation in the on-going program of Adaptive Management and Monitoring in the Sierra Nevada. Should you have any questions, I can be contacted directly at: 916-313-5800 ext. 110 or cwilkerson@defenders.org.

Sincerely,

Cynthia Wilkerson California Representative

Defenders of Wildlife 1303 J Street, Suite 270 Sacramento, CA 95814

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