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.


Cynthia Wilkerson California Representative

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

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