Wildlife

Take Cover: Even a post-fire specialist needs a break from the burn for part of its life cycle: from BirdPop!

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A mix of low-severity and high-severity burn provides covered places for fledglings while adults forage for grubs in dead trees. Photo by Jean Hall.

Scientific information is conditional on the approach to the study (framing), discipline(s)involved, methodology used, and the specifics of time and place. The more information expands, the more we know, even though it might feel like we are the blind person dealing with the elephant. Yet there is a balance between accepting the conclusions and understanding that for most topics, what you know is a a function of the step you’re on and not the final story. And as the climate (and people and whatever) changes, there may never be a “final story.” Just note the ubiquity of the expression in scientific papers “previous studies concluded x, but we have found y.”

Here’s one example of Stillman et al.’s work from Bird Pop!. There a link to the paper on the blog site.

But the simple assumption that more fire always equals good news for a post-fire specialist wasn’t holding up. Stillman’s earlier work, in collaboration with IBP, his PhD advisor UCLA Professor Morgan Tingley, and the US Forest Service, showed that Black-backed Woodpeckers prefer to nest near the edge of severely burned patches. Now fledgling woodpeckers, hatched in nests within burned forests, were moving out of the burn and into adjacent forest that burned at low severity or sometimes hadn’t burned at all.

A new story began to emerge. Perhaps Black-backed Woodpeckers nest close to the edges of burned patches so that, upon fledging, their young can take cover in unburned or less severely burned patches nearby — presumably to take advantage of greater vegetation cover and avoid predation. “We started thinking of the food-rich high severity burn as a grocery store and the high-cover low severity burn as a nursery,” says Stillman. “If you’re going to build a home, you want to place it close to both the food source and the nursery!” But if this was indeed what was going on, you’d expect survival of juvenile woodpeckers to be higher in the less severely burned areas with more live vegetation.

To test this prediction, Stillman and collaborators tracked the habitat use and survival of 84 fledgling Black-backed Woodpeckers from 39 nests in seven different recently burned areas in the Sierra Nevada and Cascade Mountains of Washington and California. Tracking during the first 35 days was done the hard way — hiking many rugged miles with handheld receivers. As the juveniles got older and dispersed, tracking was done by driving and with the generous help of the skilled volunteer pilots of LightHawk Conservation Flying. “We expected survival to be lower in the high-severity patches compared to low-severity patches — and that’s what we show in this paper. However, it was surprising to us just how much of a difference it made,” says Stillman. “If you’re a fledgling Black-backed Woodpecker, you have a 53% chance of surviving 35 days if you spend your time in low-severity burned patches — about average for a baby bird. But if you instead choose to spend all your time in the high-severity burn (which is good habitat for adults), your chance of surviving 35 days plummets to just 13%.” Most fledgling deaths were due to predation.

Another surprise: the identity of the predators. Most juvenile Black-backed Woodpecker deaths could be attributed to birds of prey including Cooper’s Hawks, Northern Goshawks, Red-tailed Hawks, and even a Western Screech-owl. Apparently if you are a bird of prey, fledgling woodpeckers in open stands of burned snags are the easy-to-grab, juicy hamburgers.

Previous research has shown that increased pyrodiversity yields more diverse habitat types across the landscape, which in turn increases diversity in the bird community. But this study and Stillman’s other dissertation research shows that pyrodiversity can be a good thing even for a single species. This is an example of habitat complementation: when a species has different habitat requirements for different parts of its life history. Forest managers can support and enhance pyrodiversity through management practices before fire, and by protecting pyrodiverse areas after fire.

Science Friday: The Sierra Club, Science and Politics: Wolves in Colorado and Elk Feedgrounds in Wyoming

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https://wgfd.wyo.gov/Get-Involved/elk-feedgrounds

As some may have been following, we had an initiative in Colorado to reintroduce wolves. It was voted in; the vote was fairly close and mostly urban counties voted for wolves to be reintroduced on the Western Slope. Here’s the process, but the decision was made by initiative and the hearings and input are about “how” and not “if”. And Governor Polis recently challenged the commission to get the wolves here ahead of the schedule voted on in the initiative.

“I think next year is that sweet spot where you have plenty of time, you get a plan out this fall, you socialize it, we’ll be able to do in-person meetings this fall, the COVID thing will be out so you’ll be able to do listening sessions, there will be comments on the plan, it will be refined, amended probably early the following year,” Polis said. “We can get it done. Colorado Parks and Wildlife has risen to this challenge time and time again.”

Proposition 114 directs the Colorado Parks and Wildlife Commission to:

Develop a plan to reintroduce and manage gray wolves in Colorado by December 31, 2023, on designated lands west of the Continental Divide;
Hold statewide hearings about scientific, economic, and social considerations;
Periodically obtain public input to update the plan; and
Use state funds to assist livestock owners in preventing conflicts with gray wolves and pay fair compensation for livestock losses.

According to RMEF (which I grant, is not an unbiased source, “CPW addressed wolf introduction in 1982, 1989, 2004 & 2016 and opposed an introduction each time.”). Note for those not following this: wolves are coming into Colorado on their own. In this case, the Sierra Club thought using an initiative process when the CPW (wildlife experts or not?) was against it was OK.

At the time, Greg Walcher, former director of the Colorado Department of Natural Resources wrote in an op-ed:

Savor the irony of the Sierra Club’s website boasting, “For the first time, Coloradans – not politicians, not bureaucrats – We, The People, may decide whether to reintroduce gray wolves to Colorado.”

In other words, one of the harshest groups that insists politics has no place in wildlife management, now dismisses wildlife professionals as nothing more than “bureaucrats,” whose flawed judgment must be overruled by the political process. Now, who is declaring war on scientists?

BUT in Wyoming, Angus Thuermer of WyoFile has an interesting story today on wildlife feedgrounds and a new legislative initiative.

The bill establishes a transparent process for what would be a high-impact decision affecting more than just wildlife, said lead sponsor and cattleman Rep. Albert Sommers (R-Pinedale). “I want to make sure this is a discussion with all agencies that are involved,” he said

“Let’s call it a multi-species decision,” Sommers said, noting that feedground closures would impact stockgrowers. “That’s not just a Game and Fish issue.”

Wyoming’s Sierra Club chapter director called the measure “a pretty terrible idea.”

The bill is “a classic case of legislators trying to micromanage in areas where they have no expertise,” said Connie Wilbert, Wyoming chapter director of the group. “They’re not wildlife experts, they’re not wildlife disease experts — nor is the governor.”

Note that in this case, the decision making process will be open with affected parties weighing in.. arguably more democratic with more opportunities for the relevant sciences to be brought to bear, than a non-open initiative process.

Sidestepping science?
Any recommendation to close a feedground today would likely find its way to the governor’s desk in any case, Sommers said. The bill creates a process for “all to be heard” before “the big dog decision-maker makes the call,” he said.

“I think it rises to the level of having a more thorough process,” Sommers said of elk feedground closures. “It just increases public participation” and provides “a clear decision-making tree.”

For Wilbert, the measure sidesteps science.

“The Legislature doesn’t like the information they’re getting from the scientists and wildlife experts,” she said, “and they think they can do a better job. They’re politicizing an issue that shouldn’t be politicized.”

CWD has arrived in a feedground herd and urgent action is necessary, she said.

“I’m really disappointed in this approach,” she said. “We should leave wildlife management to wildlife management experts and it should be based on the best available science.”

I’d argue that the “best available science” can’t be known without an open process, without different disciplines (including social sciences) weighing in, and without practitioner,Tribal and local on-the-ground knowledge also being taken into consideration.

How to get rid of non-native fish in wilderness

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Utah Division of Wildlife

Since we had such fun discussing use of chainsaws in wilderness and eliminating wolves from wilderness, here’s another example of challenges to managing under the Wilderness Act. The Lolo National Forest is seeking comments on the North Fork Blackfoot River Native Fish Restoration Project which is located in the Scapegoat Wilderness.  They have prepared an Environmental Assessment.

The project would authorize Montana Fish, Wildlife & Parks (FWP) to implement fish management and stocking actions within the wilderness that would establish a secure population of native trout, replacing an existing hybrid population.

To restore and secure this population, the project proposes the following actions; application of a piscicide, rotenone, to eradicate the non-native fish species; use of motorized equipment such as a boat motor, generator, and a helicopter to transport equipment, supplies, and fish for stocking; temporary development of structures or installations; and use of chemicals (pesticides or herbicides). Additionally, public access in the area would be closed for 7-10 days during the late summer of 2021 to reduce user conflicts with management actions.

The Forest Service has assessed the suitability of the proposed activities in the Scapegoat Wilderness through a process called a “minimum requirements analysis.” This is a process used to identify, analyze, and recommend management actions that are the minimum necessary for wilderness administration, as directed by the Wilderness Act of 1964.

From the linked article:

Opponents challenged the plan’s use of motorized equipment in a federal wilderness area where such machinery is typically prohibited, the idea of stocking otherwise fishless waters in wilderness, use of fish poison and the potential of harming non-target fish in the area.

There doesn’t seem to be much disagreement with the project purpose, but resistance to how they would do it.  The exception where “mechanical transport” and “structure or installation” would be allowed by the Wilderness Act is:  “except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act.”  It seems like their argument that they need motorized access is weak (see photo), but if chemicals are the only way to remove the non-native species, should they not do it?

Then there is the requirement to maintain viable populations of native species on national forests, which might for some species (maybe amphibians that evolved without fish predators) require them to do it.

 

New Wyo Game and Fish guidelines aim to reduce renewable energy impact

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This wind development-environmental conflict map can be found here https://wgfd.wyo.gov/Habitat/Habitat-Information/Wind-Energy-Development. You can click on it to make it larger.

A story by Angus Thuermer in Wyofile:  I like how G&F used their experience with existing installations to develop a process; maybe other states can benefit? I also like the pre-monitoring and possible ongoing adaptive management.

The guidelines seek early engagement with developers and at least two years of wildlife monitoring before they break ground. By working with developers even when they’re selecting a location, impacts can be minimized, said Amanda Losch, the agency habitat protection program supervisor.

“We really wanted to clarify a process where we had a lot of communication and touch points … so there’s constantly a back and forth,” she said. “For us, it’s all about having open lines of communication.”…

A new section fleshes out what the agency wants in post-construction monitoring plans. The new guidelines also expand on the role of technical advisory panels for each project.

“In this document, there’s more information on who should be on it, what should they be doing,” Losch said.

Thuermer also had a round-up of some impacts with links to studies:

Development of industrial-scale renewable energy projects could be wildlife managers’ next challenge as consumer demand and federal policies favor them over fossil fuels. Wyoming is the top state for potential wind development, the Wyoming Energy Authority states.

Energy companies have developed 1,816 megawatts of wind power production capacity in Wyoming and are building another 4,341, according to the American Wind Energy Association. The wind farms are affecting wildlife.

Recent research suggests pronghorn antelope shy away from turbines on their winter range. “We found evidence that pronghorn avoided wind turbines in winters after development within their winter home ranges,” authors stated in the abstract of a 2020 scientific paper. They acknowledged the topic needs more study.

Before adoption of the new guidelines, Game and Fish already was recommending that the Industrial Siting Council allow no wind development in critical “core” greater sage grouse areas “without clear demonstration … that the activity will not cause a decline in sage grouse populations.”

A five-year study of 346 telemetry-tagged female grouse comparing undeveloped area to a wind farm detected that they were less likely to select brood-rearing and summer habitat in disturbed areas.

There’s also worry about turbine blades killing birds and bats. The first phase of the Chokecherry and Sierra Madre Wind Energy Project south of Rawlins, for example, is expected to kill two bald eagles and 14 golden eagles a year, according to the U.S. Fish and Wildlife Service.

Power Company of Wyoming LLC is developing that 1,000-turbine, 3,000-megawatt field across 320,000 acres on the private Overland Trail Cattle Company Ranch. The USFWS calculation of the turbines’ toll on eagles applied to the development of only the first 500 turbines, expected to be erected starting in 2022.

Sounds like the next act in the Sage Grouse Drama may introduce new characters…

Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington

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One of the many things that went into the Trump dump the last couple of weeks was the amendment of the Forest Service Eastside Screens old growth protection standard:  “Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington.”    We discussed that at length here.  The Forest Service documentation for the amendment is here. The standard prohibiting harvest of trees >21” dbh has been replaced by this guideline (“LOS” is late and old structure, and it refers to “multi-stratum with large trees” and “single-stratum with large trees”):

Outside of LOS, many types of timber sale activities are allowed. The intent is still to maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible, by adhering to the following plan components: Managers should retain and generally emphasize recruitment of old trees and large trees, including clumps of old trees. Management activities should first prioritize old trees for retention and recruitment. If there are not enough old trees to develop LOS conditions, large trees should be retained, favoring fire tolerant species where appropriate. Old trees are defined as having external morphological characteristics that suggest an age ≥ 150 years. Large trees are defined as grand fir or white fir ≥ 30 inches dbh or trees of any other species ≥ 21 inches dbh. Old and large trees will be identified through best available science. Management activities should consider appropriate species composition for biophysical environment, topographical position, stand density, historical diameter distributions, and Adapting the Wildlife Standard of the Eastside Screens 5 spatial arrangements within stands and across the landscape in order to develop stands that are resistant and resilient to disturbance.

The proper way to read a guideline is that its purpose is a standard: “Managers must maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible.”  It’s not clear to me how you maintain LOS “outside of LOS,” so maybe only “enhance” is applicable, but even that term assumes what you are enhancing is already there to a degree.  This is also weakened by the qualifier “as much as possible.”  This could be interpreted to allow timber harvest even if enhancing LOS conditions is not possible.

The rest of the boldface language should be interpreted as actions that would always be allowed because they would always promote the LOS purpose.  This means that a decision to NOT retain all old and large trees could only be made if it is demonstrated that LOS is enhanced.  “Generally emphasize” allows probably unlimited discretion regarding recruitment.  A decision to NOT prioritize old trees (i.e. to log any old tree before logging large trees) could also only be made if it is demonstrated that LOS is enhanced.  This could be reasonably effective, but it puts a significant burden on project analysis and documentation to deviate from the terms of the guideline.  This is as it should be.  The last part of the guideline lists things that “should be considered,” which shouldn’t be given much weight.

There are also changes in standards and guidelines for snags, green tree replacement and down logs.

The last part of the “decision” is to adopt an “Adaptive Management Strategy.”  This strategy proposes monitoring and thresholds intended to trigger additional restrictions on large tree removal:

  1. If large trees are not increasing in number with appropriate composition, the Regional Forester will impose the Age Standard Alternative across the whole analysis area or by national forest or potential vegetation zone.

  2. If effectiveness monitoring does not occur, the Regional Forester will impose the Age Standard Alternative across all six national forests.

However, under the Planning Rule, these are not plan components and are not mandatory.  While there are “requirements” for regional forester review every five years, this is not a plan component either.  Since none of this “strategy” is enforceable it is of much less benefit than if it had been included as plan components like standards.

(For those interested in how the “natural range of variation” (NRV) is used in forest planning, there is a desired condition for the amounts of LOS in different habitat groups and it is based on NRV.  These new amendments leave in place the desired conditions for LOS previously determined in accordance with the original amendments in 1995.   An appendix in the decision notice includes a “Table 3” that is “only an example” of NRV because, “The number and kind of biophysical environments and the historic and current distribution of structural conditions vary by landscape.”  In order to fully understand the effects of this amendment on a particular landscape, we would need to see the definitions of LOS and actual desired conditions for LOS incorporated into a plan for that landscape.  I didn’t find them in or see them referred to in the amendment documentation, I suppose because they are not changing).

 

Sabelow Series in the Sacramento Bee. I. ‘We can’t just walk away.’ California’s wild places are under siege and dying:

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A sunrise over a flooded wheat field at Lower Klamath National Wildlife Refuge, the nation’s first federal sanctuary for waterfowl. RYAN SABALOW [email protected]
For those who aren’t familiar with NE California and Tulelake.

From Emily Dohlansky (many thanks!):

“The Sacramento Bee recently published a five-part series on Northeastern California that challenges the concept of “wild” places in the state. I found all of the articles fascinating and well-balanced. The one on wild horses garnered a lot of negative feedback from advocates, and wild horse management isn’t something that I see mentioned here often. I thought it would be interesting to have a discussion about the articles, their shortcomings, and a path forward in this “post-wild” world.”

I think each one is interesting enough to deserve a separate post, so let’s start with the first one:

WE’RE NOT GOING BACK TO THE STATE OF NATURE’
State and federal regulators and scientists, meanwhile, are largely paralyzed to do anything about any of it, thanks to a constantly growing array of regulatory demands that suck up their budgets and staff time. There is very little innovation in the public’s lands and wildlife management these days.

The threat of lawsuits from the competing interest groups makes restoring even a few acres of habitat a years-long process of expensive studies, planning and lawyering. Deviate one inch from a “management plan” that’s already been hashed out in the courts, the agency will almost certainly get sued again, or some politician loyal to a faction will come in and pass a law or change a rule to make the agency’s job even harder.

And the places I love are worse for it.

To try to save some of what’s left of these habitats, it will require a clear-eyed look at how we think about, fund and manage our lands and wildlife. It also will need to come with an acknowledgment from those living in major cities that these places aren’t truly “wild,” and they haven’t been for more than a century.

“We can’t just walk away,” former California Gov. Jerry Brown told me. “We’re not going back to the state of nature, but we should try to advance environmental goals, and at the same time we have to respect people, their livelihoods and their traditions. It’s a messy process.”

At their heart, these stories are about how the land-use decisions of the past have collided with divisive partisan politics, lack of funding, inattention and bureaucratic paralysis to create crises that are only going to get worse for both the ecosystems and the impoverished rural towns that make up my favorite corner of the state.

Planning for protection from recreation

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This blog has discussed the effects of recreational activities on wildlife (here’s one), and whether federal land managers should be doing something different (than basically reacting to overuse).  It might be worth looking at how planning for use of newly acquired land is being done by local governments and land trusts that are interested in wildlife, and there happen to be a couple of current examples from Colorado.

Fishers Peak is a new state park near Trinidad, Colorado.  It was formerly a private ranch with very little recreational use and no trails or other developments.

“This is a property that has not been loved to death,” Dreiling says. “It’s been pretty well protected, and it’s important to us that we put recreation on this property in a wise way, in a thoughtful way. It’s an important ball that we’re not going to drop, that balance of conservation and recreation.”

In practice, that means a trail won’t be built just because it accesses the prettiest views; instead, the project partners are, for example, assessing where wildlife corridors are located and what sorts of impacts motorized vehicles could have so the public can enjoy the land inside Colorado’s second-largest state park without worrying too much about the environmental consequences. The park’s full playbook is still being drawn up, so not all of these questions have been answered, but efforts to bridge the sometimes conflicting ambitions of recreation and preservation could set a new standard for future projects—here and across the country.

Pitkin County has purchased land and granted a conservation easement to the Aspen Valley Land Trust to protect wildlife habitat.

The easement language includes a nod to a 2016 policy adopted by the Pitkin County Open Space and Trails Board, which states that the county shall “rely on the best available science for property-specific study of natural habitat conditions, including the role of the property in the context of larger habitat and wildlife patterns in the Roaring Fork watershed.” That policy also states that “human uses, if any, will be planned and managed to minimize intrusion into breeding/nesting areas and migration corridors … (and) minimize intrusion into the time periods and/or places of special habitat concern.”

Allowances for human use on the property are not guaranteed and would be made only after detailed studies are completed on site-specific conditions, identifying wildlife and habitat needs.

“You answer those questions first and then say what niches are left where you can integrate humans,” Will said in an interview. That could take the form of enacting seasonal closures or making specific areas of the property off-limits year-round. The management plan could take years to come together.

Of course federal lands are already developed to facilitate recreation.  This doesn’t mean they couldn’t be redeveloped (or undeveloped) where effects on wildlife have been identified.

North Versus Hanson

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Experts Frustrated by Stalled Efforts to Counter Megafires

“Use every damn tool you’ve got,” he said. “If we could have beavers on crack out there I’d be donating to that process — anything that will speed up the pace and scale of this thing.”

Dr. Malcolm North

A Bite of Western Wolfy Science Controversies

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from video of wolf pack observed in Colorado https://youtu.be/4xUVIs0ENXI

Appeals to “we need to follow the science” abound pretty much everywhere. But whose science exactly? Well, there’s nothing more contentious than wolves and wolf reintroduction, as we have seen on TSW previously. And so, as we’d expect there are different layers of science, approaches, modelling versus observation and so on. The fact that Colorado had a wolf reintroduction initiative on the 2020 ballot (that succeeded) caused much discussion within the state. Mostly I heard a simple claim that wolves will “restore balance.” But that’s more of a mystical idea than a scientific idea.

I ran across this op-ed from Mark Holyoak of the Rocky Mountain Elk Foundation in the Steamboat Pilot. It’s reply to another op-ed by Erik Molvar of Western Watersheds. It could present us with an opportunity to examine some of the research, which scientists/approaches count most, and where values and science intersect.

“He claims the initiative is science-based yet it circumvents the world’s foremost scientists on Colorado wildlife management at Colorado Parks and Wildlife and puts the decision into the hands of citizens unfamiliar with the issue’s intricacies. This “ballot box biology” flies in the face of nationwide professional scientific wildlife management practices.”

This is a very “whose science” and “who counts as a scientist” question.

Molvar claims wolves “provide a measure of defense against chronic wasting disease.” Absolutely untrue. Renowned wolf researcher David Mech warned against sanctifying the wolf and stated any claims wolves stop or slow the spread of CWD are merely speculation.

There are also approximately 30 wolf packs within 50 miles of the northwest Montana town of Libby where CWD was first detected in early 2019. By July, there were five confirmed samples. By January 2020, there were 64 CWD-positive samples, so despite the concentrated presence of wolves, CWD is spreading.

This is one of those things that has been stated in many news articles as if it were a proven fact, when many of claims were “thinking out loud by scientists”, with the criterion “it sounds plausible.”  CWD make ungulates sick. Wolves can more readily attack sick (or injured or pregnant or ??) ungulates, therefore they will keep CWD down.  It does sound plausible.  But what about Holyoak’s observation IRL?

Molvar claims wolves changed Yellowstone’s ecological landscape. Mech said, “…any such cascading effects of wolves found in National Parks would have little relevance to most of the wolf range.” 2010 research 
conducted at the same location as original trophic cascade studies refutes the theory. Arthur Middleton, UC Berkeley assistant professor of wildlife management and policy, said, “It’s
not true.” In addition, 2019 research  questions whether introducing predators has any effect whatsoever on ecosystems.

I guess we can imagine that introducing predators has some effects on some components of an ecosystem, and those effects interact with other effects, like human presence, livestock, roads and trails, size of herds and migration paths and so on. It doesn’t seem particularly predictable nor transferrable, and that’s what the Alston et al. 2019 paper says..
“Outcomes of apex predator reintroduction and removal are variable across systems, regardless of system complexity.”

Mexican wolf recovery scientists in Arizona/New Mexico fear a Colorado gray wolf introduction will lead to the genetic extinction of that species.

Here’s something from the abstract of Odell et al.

If Northwestern wolves come to occupy Mexican wolf recovery areas, these physically larger wolves are likely to dominate smaller Mexican wolves and quickly occupy breeding positions, as will their hybrid offspring. Hybrid population(s) thus derived will not contribute towards recovery because they will significantly threaten integrity of the listed entity.
Directing Mexican wolf recovery northward outside historical range threatens the genetic integrity and recovery of the subspecies, is inconsistent with the current 10(j) regulations under the ESA, is unnecessary because large tracts of suitable habitat exist within historical range, is inconsistent with the concepts of restoration ecology, and disregards unique characteristics for which the Mexican wolf remains listed.

Is there one scientific answer to the question of wolf reintroduction in Colorado? I don’t think so.

And we have come full cycle, as Odell works for Colorado Parks and Wildlife.

Forest plans and legislation – Blackfoot-Clearwater wilderness proposal

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Blackfoot-Clearwater Stewardship Project map, Feb. 2018.

Wilderness designation has always been controversial in Montana.  No new wilderness areas have been established by Congress since I believe 1977, and unlike most states there has never been statewide wilderness legislation.  The Blackfoot-Clearwater proposal to designate 90,000 acres on the Lolo National Forest was locally developed and has been pending in Congress for several years.  Its development included addressing issues related to motorized and mechanized recreation that we have been discussing here, and designates areas for both.  This article provides some background, and includes a link to the written statement from the Forest Service regarding the proposed legislation.

The statement relates to forest planning in a couple of ways.  First, the Forest Service uses the Lolo National Forest forest plan as the foundation for its position on the legislation.

We also have concerns about implementing section 202, which establishes the Spread Mountain Recreation Area for the apparent purpose of enhancing mountain biking opportunities. The Lolo’s current land and resource management plan identifies this area as recommended wilderness. This area is characterized generally by steep topography, sensitive soils, and contains sensitive fish and wildlife habitat. Trail 166 is the main access into this area. This trail is not maintained, not passable by riders on horseback, and becomes difficult to locate after the first mile. While we acknowledge the interest in expanding opportunities for mountain biking on the Lolo, we are concerned that the site designated for the Spread Mountain Recreation Area is not well-suited for this use, and that this designation could create conflicts with wildlife and other recreation uses.

Two of the three wilderness designations in Title III are consistent with the recommendations made in the existing Lolo National Forest land and resource management plan. The third designation (West Fork Clearwater) was not recommended in the management plan to be Wilderness, it was allocated to be managed to optimize recovery of the Grizzly Bear.

One might argue that the 1986 forest plan is outdated, and recent local efforts should be given greater consideration.  However, those efforts have not been through any formal public process, so I commend the Forest Service for using its forest plan.  I’m not sure whether NFMA’s consistency requirement applies to taking positions on legislation, but it is probably the right place to start.  The proposal is also interesting in its legislative designation of two “recreation areas,” taking these decisions out of the forest planning process.

The Lolo is scheduled to begin its forest plan revision process in 2023, and the Forest Service is also concerned about the interaction between the revision process and this legislation.  It sounds like mostly a budgetary concern:

Our primary concerns pertain to Title II. Section 203 which would require the Forest Service to prepare a National Environmental Policy Act analysis for any collaboratively developed proposal to improve motorized and non-motorized recreational trail opportunities within the Ranger District within three years of receipt of the proposal… If passed in its current form, this bill could require recreation use allocation planning for site-specific portions of the Seeley Lake Ranger District ahead of the broader plan revision process, which would forestall the Lolo’s ability to broadly inform land use allocations across the forest through the plan revision process… If enacted, the explicit timeframes currently contained in the bill could result in prioritizing the analysis of a collaboratively developed proposal to expand the trail system over other emergent work.

But they might also be suggesting that the site-specific recreation planning would benefit from waiting until the forest plan is revised.  (Or maybe they just don’t like deadlines.)