Thursday, April 26, 2012

Proposal Threatens to Lower the Bar on Northwest Forest Protection

This is a guest blog post by Steve Holmer, Senior Policy Advisor for the American Bird Conservancy.

The Obama administration has unveiled a draft critical habitat proposal for the Northern Spotted Owl which the public may comment on until June 6. The proposal marks a significant departure from the standards and guidelines of the Northwest Forest Plan, weakens habitat protection for the threatened owl, and does not reflect the best available science.

The draft critical habitat rule notes that the Northwest Forest Plan “…has been successful in the conservation and recruitment of late-successional forest and associated species on Federal lands (Thomas et al. 2006. P. 283) (p.52), but then proceeds to recommend its dismantling based on two main justifications, that commercial timber harvest from matrix lands was insufficient, and the lack of active restoration in areas that may contain “uncharacteristically high risk of severe fire,” or in moist forests where early seral habitats are lacking.

A number of recent studies and timber sale data raise serious questions about these justifications. The final Northwest Forest Plan was a political compromise that under-delivered on old-growth protection by placing 42% of the remaining acres in the matrix, and overpromised on timber volume. The plan’s billion board foot estimate was never realistic because it is predicated on logging old-growth, which is not supported by the public and that in practical terms has generally been ruled in violation of wildlife protection laws. The estimate was also completed prior to the designation of the riparian reserve network which turned out larger than anticipated. The Bush Administration recognized these factors to a degree, and lowered the estimate to 800 million board feet.

A look at timber sale output in the Northwest Forest Plan region reveals the agency is at a sustainable level and meeting the volume targets budgeted by Congress. Since 2003, the budget approved by Congress and the Administration has called for 4,668 million board feet from the Northwest Forest Plan area. The agencies have offered 4,507 board feet, or 96% of the planned budget. In addition, exports from the region are skyrocketing. In 2010 over 2 billion board feet of logs and lumber were exported from the West Coast. In 2011 it topped 3 billion. There is no shortage of logging in the Pacific Northwest.

While early- seral habitats are desirable for some species, logging is not the best means to establish early-seral habitat. We recommend that agency utilize natural disturbances. Simply refraining from post-fire logging has the potential to create abundant high-quality early-successional habitats.  It is not acceptable to convert nesting, roosting, and foraging habitat of the Northern Spotted Owl to early-seral. Under the Northwest Forest Plan restoration of owl habitat, when it occurs, should hasten creation of owl habitat, not set it back by many decades.  This provision is unrelated to owl recovery or sound forest management and should be removed from the final designation.

Active Management in Critical Habitat

The draft Critical Habitat rule includes extensive language supporting active management in all areas of owl Critical Habitat, including regeneration harvest in moist Westside forests.  The draft goes so far as to suggest that forest management goals can take precedence over owl conservation, and that the conservation of this endangered species must be “compatible with broader landscape management goals”:

This approach has raised the concern of Society for Conservation Biology, The Wildlife Society, and American Ornithologists’ Union who wrote:

“These proposed policy changes have the potential to adversely impact federal lands in the Pacific Northwest to the detriment of spotted owls and other federally threatened and endangered species….we are especially concerned about the potential habitat impacts of adopting untested “active management” forestry technique.”

 The groups are asking the Department of the Interior to prepare an Environmental Impact Statement to prepare a scientific approach to test active management forestry’s impact on spotted owl prior to being used at a commercial or landscape scale.

Adverse Modification of Habitat

The draft Critical Habitat rule further states that if projects have considered ecological forestry principles, that in general these activities would not be considered adverse modification of owl habitat by FWS. As a result of this provision, the normal protections provided by critical habitat to address adverse modification may not apply at the discretion of FWS.

Presidential Memorandum

President Barack Obama issued a memorandum to Secretary of the Interior Ken Salazar stating that logging should be allowed and considered an acceptable practice in all owl Critical Habitat.
Importantly, the proposed rule recommends, on the basis of extensive scientific analysis, that areas identified as critical habitat should be subject to active management, including logging, in order to produce the variety of stands of trees required for healthy forests. The proposal rejects the traditional view that land managers should take a "hands off" approach to forest habitat in order to promote species health; on-going logging activity may be needed to enhance forest resilience.

Society for Conservation Biology, The Wildlife Society, and American Ornithologists’ Union raised concern about the President’s memo stating:

“We are concerned that this memorandum overstates the quality and quantity of scientific research on the potential benefits of active forest management, especially in the Pacific Northwest on a federally threatened species. In particular, we are unaware of any substantial or significant scientific literature that demonstrates that active forest management enhances the recovery of spotted owls.”
Changes are needed to modify the draft as follows:

Active management in owl habitat should be considered experimental, conducted on a small scale, and monitored to determine its impact on Northern Spotted Owls. The necessity and benefits of active management in owl habitat remains in dispute. We recommend FWS develop an environmental impact statement to devise a research strategy that addresses this question. The Northwest Forest Plan allows for management experiments in the designated Adaptive Management Areas; we recommend that these projects be limited to those areas.

The proposed definition of adverse modification of habitat is not supported by the best available science. We recommend that the standards and guidelines of the Northwest Forest Plan be used to preclude inappropriate or unsustainable management practices.  The Northwest Forest Plan allows for restoration and provides standards and guidelines that are more protective of owls and better suited to experiments in ecological restoration.

Friday, April 13, 2012

Shoot Down Polar Bear Trophy Hunts and Other Radical Proposals

This post is a guest blog from Michael Markarian, President of the Humane Society Legislative Fund.

As early as next week, the U.S. House of Representatives may consider H.R. 4089, the so-called “Sportsmen’s Heritage Act of 2012,” a highly controversial omnibus bill that combines several radical hunting proposals into one awful package. Among other things, the legislation seeks to allow importation of polar bear trophies taken in sport hunts in Canada; mandate that the Department of Interior and the U.S. Forest Service open nearly all federal public lands to hunting without regard to the impact on wildlife and other resources; and strip the Environmental Protection Agency of its ability to regulate toxic lead. Each one of these component parts would warrant our vigorous opposition, but to combine all of them into one package, is a disgrace and the House should reject it.
 The measure would undermine several current federal wildlife protection and environmental laws, further imperil already threatened species and the environment, and undermine federal agencies’ ability to carry out their wildlife and public lands management obligations.  I want to demonstrate why this bill, in all of its component parts, is such a disaster:

POLAR BEARS: H.R. 4089 would amend the Marine Mammal Protection Act to allow the importation of two classes of polar bear trophies taken in sport hunts in Canada. First, it would allow import of polar bear trophies taken in Canada before February 18, 1997, regardless of whether the polar bear was taken from an approved or unapproved population. Since prior to 1997 there were approved populations from which U.S. trophy hunters could take bears and import their trophies, only trophy hunters who killed polar bears from unapproved populations would benefit under this provision. We shouldn’t reward these trophy hunters who killed polar bears in contravention of the MMPA and now seek to benefit from their unlawful behavior.

Bear_polar_bear_and_cub_270x224Second, H.R. 4089 would allow import of polar bear trophies taken in Canada and only from bears hunted from approved populations before the May 2008 Endangered Species Act listing took effect. In practice, it would treat trophy hunters who killed their bears before the ESA listing took effect as though the listing had never taken effect. The trophy hunting community was aware that the ESA listing would take place for over 16 months prior to its effective date, and trophy hunters were repeatedly warned by federal agencies and hunting associations that the final listing would cut off imports immediately. These individuals knowingly assumed the risk that their trophies might not be approved for importation, and allowing them to import those trophies now would constitute an unfair bailout.

The MMPA prohibits the sport hunting of polar bears in the U.S. and it prohibits the import of any marine mammal, including dolphins, whales, seals, sea lions, and walruses. The law should be consistently applied, and we should not have a special carve-out for a few trophy hunters who shot polar bears in Canada, knowing full well that they may not be able to import the trophies under U.S. law. While some argue this is just a small number of trophies, it encourages hunters to continue killing protected species in other countries, store the trophies in warehouses, and simply wait for their allies in Congress to get them a waiver on the imports. It sets a dangerous precedent, and encourages more killing of threatened species and protected marine mammals, which flies in the face of the ESA and MMPA.

FEDERAL LANDS: H.R. 4089 would open sensitive and primitive wilderness areas to recreational hunting and shooting activities, despite the fact that these areas have been long protected from invasive human recreational pursuits. Further, H.R. 4089 would open up national park lands to recreational hunting even though such activity is generally prohibited by law.

H.R. 4089 would also exempt all federal agency decisions concerning recreational hunting or shooting activities from environmental review under the National Environmental Policy Act. No analysis of the impacts of these activities to target and non-target wildlife, habitats, or any other aspect of the environment would be permitted. These provisions of H.R. 4089 are entirely antithetical to the science-based principles of sound wildlife and federal lands management. 

H.R. 4089 explicitly requires federal agencies to facilitate recreational hunting opportunities on all federal lands. This will raise serious safety concerns, and create significant conflicts with the non-consumptive activities, such as hiking and wildlife watching, of other public lands visitors who contribute significantly more to the U.S. economy than hunters. If H.R. 4089 passes, virtually every decision by federal agencies to restrict hunting and shooting activities would be subject to expensive lawsuits as to whether the decision is “necessary and reasonable.”

There are millions of acres of federal lands currently open to sport hunters who have the opportunity to participate in recreational hunting on many national wildlife refuges, national forests, and other federal properties. The activities mandated in H.R. 4089 are already disproportionately favored against the interests of other larger outdoor user-groups.

LEAD AMMUNITION: H.R. 4089 would also eliminate the jurisdiction of the U.S. Environmental Protection Agency to regulate ammunition, under the Toxic Substances Control Act. The U.S. Fish and Wildlife Service has already banned the use of lead ammunition for waterfowl hunting—a policy which has been in place for more than two decades yet waterfowl hunting still thrives in this country due to the many forms of non-toxic ammunition available—and the National Park Service prohibits the use of lead ammunition by agency staff and contractors, with both agencies’ decisions being based on the known deleterious effects of lead. Such decisions should be left to the discretion of federal agencies based solely on the best available science on the impacts of toxic substances such as lead.

This omnibus measure includes several highly controversial pieces of legislation that would severely roll back federal conservation laws and set a dangerous precedent for the management of wildlife and the environment. Please call your U.S. Representative today at (202) 225-3121, and follow up with an email, asking him or her to vote “No” on H.R. 4089.

This post originally appeared on Animals & Politics, a blog by the Humane Society Legislative Fund. 


Friday, April 6, 2012

Motivation in Washington

“Without inspiration the best powers of the mind remain dormant. There is a fuel in us which needs to be ignited with sparks.”
Johann Gottfried Von Herder

Sometimes you need a jolt to fire you up – a little motivation so you can continue to do the work you do.  

I got that jolt last week when I had the pleasure of running around the U.S. Capitol with 26 other wildlife advocates to talk with our members of Congress about the importance of wildlife funding.

Federal spending on all land, water and ocean and wildlife programs comprise less than 1% of the federal budget.  Yet, wildlife and habitat conservation programs are threatened by draconian cuts.   Cutting these modest but important programs will not address the problems with the federal budget but will have real and severe impacts on our nation's fish and wildlife,millions of outdoor enthusiasts, and the economies of local communities around the country.  

I have to admit, I've been doing this work for over 25 years and sometimes I forget how important it is for our Representatives to hear from their constituents and how empowering it is for the constituents to meet with their member and share their personal stories.  The participants that came to DC represented small businesses, bird watchers, refuge and zoo volunteers, hunters and anglers, and local conservation groups.  And their stories were powerful!  

The schedule we had was a bit grueling.  A half a day of preparation and training and then we hit the ground running.   In one day 27 participants of our wildlife funding fly-in, representing 17 states, visited over 70 Congressional offices!!  That evening we celebrated with a wildlife reception at the Capitol Visitor Center.  Special thanks go out to Senator Cardin (D-VA), Senator Collins (R-ME), Representative Fitzpatrick(R-PA) and Representative Moran (D-VA) for hosting the reception.  And to Representative Heinrich (D-NM), the Director of the US Fish and Wildlife Service- Dan Ashe, and other officials from the Bureau of Land Management and the US Forest Service for also attending..  It was great way to wrap up the fly-in and it provided a nice opportunity for all of us to come together, share our stories from the day, celebrate with our champions on the Hill and talk with members of the Administration. 

I was truly inspired by all of the advocates that took time out of their daily lives, left their work and families, to travel to Washington DC to help raise awareness about why wildlife is important to them. 

The feedback we've received has been overwhelmingly positive from both the offices we visited and from the advocates themselves.

I want to personally thank all of the team that came in to DC – your enthusiasm and motivation fired me up!!


Tara Thornton
Program Director
Endangered Species Coalition

Monday, April 2, 2012

Making a Difference

This is a guest blog post by Maggie Howell from the Wolf Conservation Center.

Wildlife and its habitat are valuable national assets. Wildlife-related recreation is an industry that generates $122 billion a year in the U.S. Protecting wildlife and its habitat also supports healthy natural systems that provide clean air and water, food, medicines and other products. The value of benefits provided by natural habitats in the U.S. is estimated at more than $2 trillion per year. (The Economics Associated with Outdoor Recreation, Natural Resources Conservation and Historic Preservation in the United States)

As a member of the Wolf Conservation Center’s education team, road trips are not an uncommon part of my job. I’m often on the road traveling throughout the northeast to educate young and old about the importance of wild wolves. My adventure earlier this week, however, was different from most. I was traveling solo without my most impressive co-workers including Atka the wolf!

Defenders of Wildlife, American Bird Conservancy, Endangered Species Coalition, Bat Conservation International, National Resources Defense Council, National Wildlife Refuge Association, Sierra Club, The Wildlife Society, and WWF invited over two dozen U.S. citizens representing seventeen states to participate in a two-day advocacy marathon to help secure funding for wildlife programs. My fellow participants hailed from all walks of life. I joined hunters, anglers, bird watchers, paddlers, hikers, wildlife lovers, and business owners to meet with our Congressional representatives about the importance of funding for wildlife programs in the Fish and Wildlife Service and other agencies.

Our diverse group met at Defenders of Wildlife’s Washington DC Headquarters to meet our cohorts and for an overview of the current status of wildlife appropriations. We reviewed crucial programs that support wildlife and habitat conservation within the U.S. Fish and Wildlife Service, Bureau of Land Management, Forest Service, U.S. Geological Survey, National Oceanic and Atmospheric Administration, and Multinational Species Conservation Funds. Several members of the host organizations delivered compelling and educational presentations re: the severe cuts that threaten many federal wildlife and habitat conservation programs. We then split into teams and were assigned “Sherpas” to help us navigate the though the halls of Congress.

I was paired with James Brumm, a fascinating fellow and the Chair of the American Bird Conservancy, and together with our super Defenders of Wildlife Sherpa, Marcia Lesky, we prepared for the mission. Our team was the busiest of the bunch, Marcia scheduled seven meetings in all with representatives from both New York and Connecticut.

During all the meetings, the focus of my message was the importance of keeping the Endangered Species Act (ESA) strong. The ESA is one of our nation’s cornerstone environmental laws and has helped prevent the extinction of treasured wildlife including the bald eagle, Florida manatee, and California condor. It exists because of the citizens of this country and a bi-partisan Congress almost 40 years ago had a vision of responsible stewardship of the Earth. Thanks to the ESA, the reintroduction of wolves to our Nation’s landscape has helped to restore vital ecological processes and continues to impact our environment in positive ways scientists are only now beginning to realize. Wolves and other wildlife supported by the ESA have also proven to have great economic value. The wildlife-related recreation industry generates $122 billion annually here in the U.S.. Seems to me that wildlife is a great investment on many fronts.

At day’s end we gathered for a nice reception with all the amazing staff from the hosting organizations, some Congressional staffers, their bosses and more. It was an educational experience that I would welcome to repeat and I hope that our personal stories will have a positive impact on the future of our Nation’s natural treasures. Do you have a story you would like to share with your representative?  

Visit to contact your Senator and to contact your Congressperson.  Please remember that we all have a voice and the right to use it in order to safeguard our planet for generations to come.