Stanislaus spotted owl plan amendment

Photo of female and juvenile California spotted owl courtesy of University of California Cooperative Extension (

We recently looked at the Biological Assessment of Northwest Forests, and the options for proceeding with revising forest plans currently governed by the Northwest Forest Plan. Some of those options involved amendments to existing plans prior to plan revision. I voiced support for amendments that would provide the ecological conditions needed for at-risk species. I thought this might be an example to look at for how that might go.

The Stanislaus National Forest is not in the area covered by this assessment. Its forest plan was originally completed in 1991, but it was amended by the Sierra Nevada Forest Plan Amendment (or Framework) in 2004, which is roughly analogous to the Northwest Forest Plan in that it had its origins in the work done to protect the California spotted owl (it has its own complicated political and legal history). Now the Stanislaus is proposing an amendment for a part of the Forest in conjunction with what it calls the Social and Ecological Resilience Across the Landscape (SERAL) project.

The Forest has identified a need to change the forest plan based on new information about the California spotted owl, as published in 2019 by the Forest Service in the “Conservation Strategy for the California Spotted Owl in the Sierra Nevada.”

In order to fully adopt and implement the management direction described in the Conservation Strategy and increase landscape resiliency as guided by NRV the Stanislaus National Forest’s forest LRMP must be amended. The proposed forest plan amendments would allow the SERAL project’s proposed landscape restoration treatments to best meet the purpose and need of the project and implement the guiding principles of the 2019 California Spotted Owl Conservation Strategy. The proposed amendments include standards and guidelines which will provide some immediate stability for individual owls while allowing forest management the ability to conduct treatments designed to help develop resilient habitat conditions that provide CSO conservation in the long term.

Unfortunately, the CSO Conservation Strategy was apparently written for a narrower purpose than its name implies:

The California spotted owl (Strix occidentalis occidentalis) Conservation Strategy is a strategic framework for active conservation of the California spotted owl on National Forest System lands in the Sierra Nevada.

It appears to be something less than a scientific strategy. By limiting the focus to “active conservation” it has failed to address the central debate about managing spotted owl habitat regarding when active management should even be used. Passive management is one obvious alternative to this amendment that the Forest is going to have to address in its amendment process. But I looked at some of the proposed changes in the forest plan.

The current plan designates spotted owl Protected Activity Centers (PACs) as management areas in the forest plan (which could be changed only by amending the forest plan). This proposed amendment would replace current management areas with guidelines to designate PACs later “in advance of any management activities that would reduce CSO nesting and roosting habitat quality.” The guidelines include criteria for delineating and changing PAC boundaries.

My opinion: This is not a coarse filter management strategy based on vegetation because it depends on actual owl presence based on surveys, or one might call it “condition-based.”  If owl presence is the kind of thing that changes frequently, this may be a reason to not designate permanent management areas at the plan level.  However, this creates the risk of cutting the public out of the part of the process that actually determines the locations for management.  The plan is no longer saying, “here is where we’ll manage for owls,” but instead, “we’ll manage for owls where we think we need to manage for owls, trust us.”  The criteria must be explicit and objective enough to fully evaluate at the plan level, and the decisions about whether and how to apply them at the project level must include the public. Given the importance that surveying would take on, there is no excuse for these being guidelines rather than standards. It seems to me that the certainty of owl protection, and therefore the viability of the species, is going to be reduced.

There are a lot of new plan components in the amendment, and the CSO Conservation Strategy is page-referenced for most of them. That’s how any conservation strategy should be used, so maybe this is a good example of that. Except that it strikes me that this “conservation strategy” may have actually been written as a “drop-in” amendment to be used this way (which makes that kind of cross-referencing a lot easier). This is similar to what would happen if plan amendments were developed that could be later “dropped in” to forest plan revisions. The problem is that if the “conservation strategy” is already a management-influenced document and not a science document, there would still need to be a reference to the actual scientific basis for these conservation recommendations that are being adopted.

Anyway, this project/amendment will be worth watching as it applies the 2012 Planning Rule diversity requirements to California spotted owls. And it may be setting some precedents for what could happen regarding how to plan for management of spotted owl habitat on other national forests.

7 thoughts on “Stanislaus spotted owl plan amendment”

  1. The Stanislaus NF is notorious for underperforming towards their volume targets. For decades, they’ve asked, (and sometimes received) extra money to produce extra timber volume. I’d be willing to bet that this is a test to see if they can boost timber harvest, and reduce red tape. The Stanislaus National Forest has difficult ground, with plenty of granite around. They also have the Groveland RD mostly burned-over, and over again. It should be noted that there is a local small log mill, in addition to the historic Standard big log mill.

    Yes, we do need better ways to deal with the owls but, I don’t see one. There is still plenty of thinning projects that can be done, under existing rules, laws and policies. There is also a need to try and ‘recruit’ new areas as nesting habitat, to replace the acres expected to burn to a crisp in the next 30 years. There may be an opportunity to re-enter crowded stands that were harvested since 1993. Most of those thinning projects did not reduce the basal area to optimum levels.

  2. Jon:
    The new conservation owl strategy approach being considered by the SERAL project in the Stanislaus Forest is not connected with the Northwest Biological Assessment, but it is based on a multi-year science planning process by Region 5 for the CA spotted owl. Scientists – even within that planning process – saw different priorities as desirable, so although there was a final conservation strategy that provided regional direction, not all scientists or USFS line officers read it exactly the same way.

    Local forest stakeholders saw with some degree of concern how the Stanislaus Forest was originally considering ways to implement the revised Conservation Strategy policies and prescriptions for the owl. Through lots of back and forth discussions with agency scientists and local forest wildlife biologists, the stakeholders and the SERAL project interdisciplinary team ended up with proposed strategies that are intended to reflect what was spelled out in the 2019 Conservation Strategy for the CA Spotted Owl. And for prescriptions or implementation of the Strategy that were less explicit and more open to debate, the goal of those designing the SERAL project was to take a conservative approach that would best protect the owl from extreme events while creating the least controversy for all sides.

    It can be difficult to find the sweet spot of accurately interpreting science about the CA spotted owl while also considering how to implement on-the-ground forest treatment actions to not just protect existing owl habitat, but to also nudge forests toward being more resilient in the face of climate change. Those analyzing the SERAL project openly welcome suggestions and input that can best achieve those two important objectives.

    • It’s an ambitious idea to try and re-vamp spotted owl policies for such a small amount of timber volume, on the Stanislaus. The old system of losing nesting habitats through wildfire, then designating new acres as a replacement was doomed to fail, at least for the fire-prone Sierra Nevada. I’m not sure but, there used to be a restriction on re-entering stands that have been logged since 1993. That could be impacting some Ranger Districts.

      However, since protections were enacted in 1993, there should be a number of acres that have gone from marginal nesting habitat to occupied nesting habitat. There should also be more acres approaching the marginal level. Hell, it might even be useful for Wildlife Biologists to build actual nest sites, to help occupy the habitat. 😉

  3. John and Jon,
    I think it’s interesting that Jon seemed to think that it wasn’t a “scientific strategy” but John talks about the science and the involvement of scientists (who disagree, like all the scientists I’ve ever worked with), which raises the question “should a strategy be “based” in science?” if so “which scientists do you select to represent “science” if they disagree”? “who decides which views are more legitimately “science”? Or do you throw all the scientific info into in a pot with stakeholders and practitioner and local knowledge and stir? (given that opinions of scientists are not, in and of themselves, “science.)”

    • The Canada Lynx Conservation Assessment and Strategy produced what I would call a “science document.” It was produced by an interagency team of scientists who know a lot about lynx, and their purpose was to conserve lynx. Managers used this as a starting point to develop forest plan amendments for the northern and southern Rockies. They were able to make some changes that were within the legal requirements to conserve the species (at least nobody sued over that).

      The Northern Continental Divide Ecosystem Grizzly Bear Conservation Strategy included both scientists and managers, and the product included some compromises, but they were also expected to be within the legal requirements to conserve the species. This could get you to the same point, but the risk is in the agency’s ability to rely on a management-influenced document as the “best available scientific information” (which I have seen the FS try to do with regard to the NCDE strategy). They may be vulnerable to one of the failures of the Yellowstone grizzly delisting litigation, that the real reason some of the decisions were made was political pressure (rather than the ESA requirement of “best scientific and commercial data available”).

      There is probably a continuum between these approaches, but John’s description of the spotted owl strategy sounds more like the lynx process, where what the scientists recommended is worked into a management strategy. This process could work fine. My main concern is really that a “conservative” approach should not be one that amounts to trusting the Forest Service to figure it out on each project. It’s harder to show compliance with NFMA – that plan would provide necessary ecological conditions – if the plan doesn’t clearly say what they are and where they should occur, and under what circumstances they may be impaired.

      There should be a lot of interest here in this project because it should provide an actual analysis to answer questions about what the short-term adverse effects are and how they compare to long-term benefits for spotted owls, and whether that is good enough to maintain a viable population. There’s also the question of whether a “flexible” approach would be considered an adequate regulatory mechanism for consideration in an ESA listing process.

      • Jon, when you said “they were able to make some changes that were within the legal requirements to conserve the species (at least nobody sued over that).” The fact that nobody sued is interesting.. at least with SLRA with which I was peripherally involved. I don’t like to be cynical, but who knows what calculus the boards of LINs (litigatorily inclined NGOs) use to determine which projects they will litigate? It could have been that irritating a variety of other industries was fine, but too many friends with key connections were in the ski industry. Until we can FOIA those decision meetings, (which we can never do), we will never know. Remember that the former Undersecretary Harris Sherman (whom I think is a great public servant) was (just) previously a ski industry attorney.

  4. Here’s some background on the project:

    I didn’t realize it was a reworked version of the MOTOR M2K project we discussed here:

    Interesting that they apparently moved away from “condition-based” projects, and also tackled the necessary amendments head-on (both in line with some of our comments):

    “The project is a significant reduction from the Moving Toward Resiliency within the Mokelumne to Kings Landscape (MOTOR M2K) project, a proposal released last year that included the Stanislaus National Forest and Sierra National Forest south of Yosemite National Park.

    One feature of that proposal that drew criticism was the concept of conditions-based management, which would have reduced transparency and limited public involvement in planning specific projects, according to local environmental groups.”


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