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From: native-plants-bounces@... [mailto:native-plants-bounces@...]
Sent: Tuesday, August 15, 2006 5:10 PM
To: Emily Roberson
Subject: [PCA] Center For Biological Diversity NPCC ACTION ALERT: !!COMMENTSNEEDED BY AUGUST 24 Forest Service Policy to Use NativePlants in Revegetation
Center for Biological Diversity
NATIVE PLANT CONSERVATION CAMPAIGN
**ACTION ALERT **
! We need native plant supporters to speak out !
please e mail your support for the new forest service proposal to encourage use of ecologically appropriate native plants in revegetation and rehabilition projects
Several people have asked for brief talking points for preparing their own comments on the Forest Service proposed Native Plants Policy. Some thoughts are below.
The Native Plant Conservation Campaign's comment letter is also pasted in full in the BACKGROUND section for those wishing for more detailed information.
****Comments may be sent by e mail to nativeplant@... and are due by AUGUST 24.****
The Forest Service needs to hear that we commend the agency for their landmark proposal to use native plants in these projects (the USFS is the first agency to propose a native plant policy nationwide) BUT
(i) The definitions of "native plant" and "genetically appropriate" plant materials are INADEQUATE in the under the current proposal.
(ii) The agency must select native plant materials based, not on the proposed definitions, but on the best available scientific definitions of "native" or "genetically appropriate"
(iii) Determinations of ecological or genetic "appropriateness" of a particular plant for a particular site or project must be made after thorough scientific review by qualified and trained journey-level plant scientists
(iv) The Forest Service must provide sufficient training (based on best available science) to botanists, plant geneticists and other plant scientists who will be making such determinations
(v) It may be helpful for the agency to provide guidance regarding what is NOT "native" or "genetically appropriate" rather than attempting to create one-size-fits-all definitions of these terms.
(vi) Finally, the agency must ensure adequate staffing in botany and plant science programs so that qualified agency staff are available to participate in revegetation and rehabilitation planning. Currently the agency is severely understaffing in botany.
The Forest Service has proposed new Forest Service Manual (FSM) rules directing that "genetically appropriate" native plants be used in rehabilitation and revegetation of areas damaged by fire, roadbuilding, logging or other activities.
The USFS is the first agency to propose a native plant policy at the national level; however several Forest Service regions including Region 6 (Pacific Northwest), Region 5 ( California ), and Region 8 ( Southeast US ) already have some version of this policy. Making the policy uniform across all regions will help the FS better to work with nurseries and other native plant seed and materials providers. One of the key benefits of this policy should be a boost to this already expanding industry. Unlike other activities and industries subsidized by the Forest Service and other federal agencies, such as livestock grazing, logging and roadbuilding, encouraging propagation of native plants should be ecologically beneficial to the public as well as economically beneficial to the (generally small) nurseries and other businesses involved.
The most problematic section of the policy centers on its definitions of "noxious weed", "native plant", and "genetically appropriate". The proposed definitions are inadequate in the policy's current form. NPCC has proposed some possible definitions in our comments (see below). However, because "native plant" and "genetically appropriate" are extremely difficult - if not impossible - to define correctly for all species and all ecosystems, we have also proposed that qualified and trained botanists, familiar with the site and the local flora, are critical to selecting plant materials that are appropriate for each project.
The Forest Service may also wish to provide further guidance regarding appropriate native plant materials in the Forest Service Handbook. Such guidance should be subject to public review.
Native Plant Materials Proposed Directive
Rangeland Management Staff, MAIL STOP 1103
Forest Service, USDA
1400 Independence Avenue, SW.
Washington, DC 20250
July 17, 2006
Re: Proposed Amendment to Forest Service Manual regarding native plant materials.
To Whom It May Concern:
These comments are submitted on behalf of the Native Plant Conservation Campaign (NPCC) regarding the proposed amendment to Forest Service Manual (FSM) Chapter 2070 concerning native plant materials (Proposal).
The NPCC is a project of the Center for Biological Diversity. We are a nationwide network of native plant science and conservation organizations. Currently the NPCC includes 34 affiliate native plant societies, botanic gardens, museums, and arboreta, representing more than 75,000 scientists and laypersons nationwide. NPCC members rely on National Forests, other public lands and botanical resources for enjoyment, education, research, and recreation. NPCC affiliate organizations and their members work closely with state and federal agencies to manage and conserve native plants and ecosystems. We provide volunteer labor, botanical expertise and scientific information to help public and private land managers to conserve our nation's unique flora.
We commend the Forest Service for taking this step towards the increased use of native plants in revegetation and rehabilitation projects. Revegetation of damaged areas with local, ecologically appropriate native plants restores habitat for native fish and wildlife, including threatened, endangered, sensitive and other rare and imperiled plants and wildlife; maintains critical ecosystem processes such as hydrologic and fire regimes, and guards against infestations by exotic noxious weeds, pest, and disease organisms. Use of native plants can hasten the re-establishment recreation opportunities for the public. Finally, as the Proposal's "Objectives" section states, increased federal use of local native plant materials will encourage businesses (nurseries, seed producers) that produce such materials and increase availability of local natives to other agencies and the public.
All of these are extremely desirable outcomes. Again, we commend the Forest Service for this step to improve plant selection policy in this way.
However, we do have some concerns about the policy section of the Proposal:
1. Proposed FSM § 2070.45 states that Forest and Grassland Supervisors may "delegate the authority to use genetically appropriate native and non-native plant materials in revegetation projects."
This direction fails to designate criteria or qualifications for staff delegated to decide what plants are suitable for use. The Proposal should be amended to require that all plant material decisions should be made by a qualified journey-level (generally defined in the FSM as GS-11 or higher) botanist or other plant scientist. Further, all NEPA documents associated with projects using the Proposal should contain documentation of the facts and reasoning underlying the choice of plant material.
We also have concerns in the "Definitions" Section
2. Proposed §2070.5 defines "Genetically appropriate" as
"A plant adapted to target site conditions (e.g., has good establishment, vigor, and reproductive capabilities); sufficiently diverse to respond and adapt to changing climates and environment conditions; unlikely to cause genetic contamination and undermine local adaptations, community interactions, and function of resident native species within the ecosystem; unlikely to become (unnaturally or inappropriately) invasive and displace other native species; unlikely to be a source of non-native invasive pathogens; likely to maintain critical connections with pollinators."
This definition should be strengthened. The proposed definition sets no limits on whether "appropriate plants" should be considered generally native, much less native to the project area. This section should (i) refer back to Proposed FSM § 2070.3 to reinforce the direction that native plants should be preferentially used and sets limits on when and what type of non-native plants may be used under this Proposal; and (ii) add language giving preference to "local native species" (see below for suggested definitions for local native).
3. "Native plant" is defined as "All indigenous, terrestrial, and aquatic plant species that evolved naturally in an ecosystem."
This should be strengthened to at least meet the standard set in the February 3, 1999 Presidential Executive Order:
""Native species" means, with respect to a particular ecosystem, a species that, other than as a result of an introduction, historically occurred or currently occurs in that ecosystem."
Other definitions under discussion in the botanical community include
"A plant species that occurs naturally in a particular area where only the biotic and non-human biotic factors determine its presence and evolution."
"a particular species which would have a reasonable probability of existing on a particular site without any past human intervention. [In this case, the determination of what constitutes a 'site'] would be the determining factor - it could be a mountain range or a single bog."
Under the last definition, site would be one of the factors to be determined by the qualified botanist referred to above.
These definitions all provide clearer and more specific direction regarding what constitutes "an ecosystem" under the Proposal. Specifically, all these definitions limit "native" species to those that occur or would occur in the "ecosystem" or "site" in the absence of human intervention.
4. Noxious weeds. This definition should be strengthened to include invasive species listed by state, regional or local Invasive Plant Councils such as the California Invasive Plant Council, the Florida Exotic Pest Plant Council, or the federal Plant Conservation Alliance Alien Plant Working Group. Official state and federal noxious weed lists often do not include all of the destructive invasive exotic plants that are of concern in a particular area.
5. Restoration is defined as "Assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed (including) the re-establishment of the pre-existing biotic integrity in terms of species composition and community structure.
As above, this should be strengthened and clarified to promote restoration of ecosystems to conditions that existed or would exist in the absence of human intervention.
We submit these comments fully understanding that the structure, processes or species composition of ecosystems "in the absence of human intervention" is not always known, in some cases cannot be known, and that some ecosystem damage prevents restoration to such a condition. However, scientific review, analysis, and documentation by qualified journey level botanists and ecologists are needed to determine when full restoration to pre-intervention condition can be achieved.
We hope these comments are useful. Please contact me at any time if I or the Native Plant Conservation Campaign can be of assistance.
Emily B. Roberson, Ph.D.
Native Plant Conservation Campaign
Emily B. Roberson, Ph.D.
Native Plant Conservation Campaign
A Program of the Center for Biological Diversity
PMB 151 (not p.o.b)
1459 18th St.
San Francisco, CA 94107
Phone: 415 970 0394
The mission of the NPCC is to promote appreciation and conservation of native plant species and communities through collaboration, education, law, policy, land use and management.