Policy Statements » Letters from the President:
February 23, 2005
Content Analysis Team—Planning CE
USDA Forest Service
P.O. Box 22777
Salt Lake City, UT 84122
Dear Forest Service Content Analysis Team:
As President of the Ecological Society of America (ESA), the nation's premier society of professional ecologists, I write to offer comments on the Forest Service's 2004 National Forest System Land Management Planning Final Rule. The Final Rule would replace the proposed rule promulgated in 2002. When the 2002 rule was proposed, ESA recommended an emphasis on ecological integrity and on the role of science and scientists in planning. Regarding the final rule, we offer the following considerations:
Management should give first priority to ecological sustainability.
Long-term ecological sustainability is essential to the continuation of the provision of goods and services from the land. We recognize the importance of multiple land uses to healthy economies and communities; those many uses fundamentally depend on the sustainability of our forest and grassland ecosystems. Emphasis on ecological sustainability ensures that the nation’s lands are preserved for future generations.
For the national forests and grasslands to be both ecologically and economically sustainable, the numerous, and typically poorly quantified, benefits provided by intact ecological systems must be incorporated. These ecological services often have monetary values equal to or exceeding the commodity values of forest ecosystems. It is critical that value of ecological services be included in any cost-benefit analyses in the design of management and in management decisions.
High standards of scientific credibility are essential to effective
Scientific credibility is key both to management plans in which all concerned parties have confidence and to consistent implementation of plans without sacrificing local flexibility. The Ecological Society is concerned that this credibility may be compromised if:
- Procedural decisions in the Forest Service’s internal directive system are removed from the scrutiny of outside scientists.
- Independent auditors of Environmental Management System (EMS) plans have little scientific expertise to the review of complex ecological analyses.
To ensure the best available science in these and other planning procedures, we recommend:
- Consistent use of internal and external scientific peer review of Service directives, EMS and local plans, and ecosystem monitoring strategies.
- Inclusion of scientific analyses of ecological sustainability in management plans.
- Inclusion of scientists in the design and evaluation of monitoring strategies.
Impacts of local decisions must be examined in a regional context.
Local ecological dynamics often influence, and are influenced by, broad-scale attributes of the landscape or region. For example, animal populations must be viewed in the context of their prey and predators’, as well as their own, habitat distributions. Additionally, the temporal and spatial pattern of disturbance regimes can influence sustainability. Continued coordination of monitoring strategies and of Environmental Impact Statements will be necessary to address the cumulative and broad impacts and effects of individual plans. Incorporation of both local and regional scales ensures that management of our forest and grassland systems is consistent with strategic Forest Service goals.
Finally, we acknowledge the budget constraints faced by many federal agencies, including the Forest Service, may limit the agency's ability to perform the requisite analysis and monitoring. We offer our assistance to federal agencies to help ensure adequate support for the science needed to make effective management decisions.
ESA's 9,000 members are scientific experts in a host of relevant areas. If ESA can be of assistance, please contact our Policy Analyst, Laura Lipps (202.833.8773, extension 224; Laura@esa.org).
Jerry M. Melillo