The Sierra Framework was designed to protect and restore old forests and habitat for species like the California spotted owl, Pacific fisher, and American marten, while allowing thinning of smaller trees to reduce the risk of stand-destroying wildfires

Wildlife at risk – The Sierra Framework and the SFEIS Revision

The Sierra Framework was designed to protect and restore old forests and habitat for species like the California spotted owl, Pacific fisher, and American marten, while allowing thinning of smaller trees to reduce the risk of stand-destroying wildfires. These documents also specified an aquatic, riparian, and meadow conservation strategy for species like the Willow Flycatcher and the Yosemite Toad.

Some of the key elements of the Framework that were designed to address concerns about old forests and associated wildlife include: designation of 4.25 million acres of old forest emphasis areas (OFEAs) that would be managed to promote old growth forests; protection of all old growth stands 1 acre or larger; protection of California spotted owl home range core areas (HRCAs) and protected activity centers (PACs); protection of the southern Sierra fisher conservation area (SSFCA); and standards and guidelines limiting removal of medium-large trees, reduction in forest canopy cover, and removal of large snags and down logs.

The new proposed SFEIS would weaken or eliminate all of these protections and would replace them with a one-size-fits-all strategy that applies the same standards and guidelines to all land allocations outside of the defense zone of the wildland urban intermix (WUI), where even more intensive logging would be allowed.

Given these changes, the U.S. EPA concluded in its comments that "the impacts of these management actions appear inconsistent with the underlying SNFPA purpose and need to address fuels, restore old forest habitat, and prevent listings of old forest-dependent species."

California Spotted Owl:

Research has documented that the California spotted owl utilizes and selects habitat at three different spatial scales: nest, roost, or foraging stand; home range or core area; and landscape. At all three scales, the owl is associated with forests characterized by large trees, large snags and down wood, and relatively dense, multi-storied canopies.

There is no new evidence since release of the Framework FEIS to modify these conclusions; rather, Blakesley (2003) provides additional confirmation of the owl's strong relationship to old forest structures. In conclusion, the results from the demographic analyses are interpreted by owl scientists to indicate there is substantial cause for concern regarding the stability of the California spotted owl population in the Sierra Nevada and that a conservative approach to management is warranted.

The Plan threatens the owl's viability and distribution in the Sierra Nevada by logging of medium and large trees, reduction in canopy cover and simplification of multi-layered canopies, removal of large snags and down wood, increased logging within PACs, weakening protection for owl home range core areas (HRCAs) and old forest emphasis areas (OFEAs), increased logging within geographic "areas of concern, and full implementation of the Quincy Library Group (QLG) pilot project.

The owl scientists have uniformly concluded that the plan would threaten the owl's distribution and viability, contrary to the agency's legal duty to ensure viability and avoid contributing to a trend towards federal listing under the Endangered Species Act. There is no new information that warrants a substantial departure from the existing owl conservation strategy including the owl meta-analysis that stated "all the demographic evidence available - such as estimated vital rates, rates of population change, and differences between paired studies - suggest substantial caution in owl conservation and management efforts."),

The Forest Service's decision to weaken the Framework pulls the legs out from under the Fish and Wildlife Service's listing decision and strengthens the case for listing the owl under the Endangered Species Act.

Finally, wildfires may have little short-term impact on survival, site fidelity, mate fidelity, and reproductive success of spotted owls.

Pacific Fisher

The new SFEIS poses a particular threat to the Pacific fisher, because the fisher is closely associated with late-successional, closed canopy forests characterized by large old trees, medium-large trees, large snags and downed wood, and dense, multi-storied canopy. The isolated fisher population in the southern Sierra Nevada is ecologically important and highly vulnerable to extirpation because they are long-lived, have low reproductive rates, large home ranges (for carnivores of their size), and exist in low densities throughout their range.

The proposed SFEIS weakens protection for currently occupied habitat and for old forest emphasis areas and smaller old growth stands. The proposed plan's standards and guidelines allow substantial degradation of fisher denning and resting habitat. Fragmentation of habitat by roads is a significant factor contributing to the loss of fishers from the central and northern Sierra Nevada and the fisher's failure to recolonize the area. The proposed plan weakens protection for fisher habitat in the central and northern Sierra, particularly within the QLG pilot project area; and the plan fails to protect eastside habitat.

American Marten

The American marten is closely associated with late-successional forests, which are generally depleted in the Sierra. There is a significant gap in the marten's distribution in the northern Sierra due to three factors: (1) low reproductive potential; (2) an affinity for overhead cover and avoidance of extensive open areas, especially in winter; and (3) very large home ranges, placing the viability of the species in the region at increased risk.

The proposed Plan threatens the Marten's distribution and viability in the Northern Sierra under the QLG pilot project due to reduction in suitable habitat, increase in forest openings, construction and maintenance of Defensible Fuel Profile Zones (DFPZs), DPFZs in red fir forests, and construction of new roads.

Willow Flycatcher

The willow flycatcher is closely associated with wet meadows which support riparian shrubs in the Sierra Nevada, and past and recent land management, primarily grazing, has likely reduced habitat capability of otherwise suitable meadows by reducing or eliminating the willow or woody shrub component and changing meadow hydrology.

The willow flycatcher is highly vulnerable to extirpation in the Sierra Nevada due to habitat and population conditions that currently restrict the potential distribution of this species, which is highly isolated. Potential abundance is very low and gaps (where the likelihood of population occurrence is low) are large enough that little or no possibility of interactions exist for recolonization.

The SFEIS threatens the viability of Willow flycatcher in the Sierra Nevada by increasing grazing season in presently occupied sites, allowing grazing all season long in historically occupied sites, shortening the end of grazing season, and allowing standard modification in site specific areas,

The site specific management plans and monitoring adopted in the ROD are inadequate because surveys of emphasis habitats are not likely to occur under the new Plan. The ROD does not take the appropriate steps to ensure recovery of Willow Flycatcher: first, meadow and habitat restoration is focused too narrowly; second, reference is made to the development of a conservation strategy, but no timeline is offered for completion of the conservation strategy and agreement, and finally there is no management direction for the control of cowbirds as there was in the 2001 ROD,

Yosemite Toad

The Yosemite toad is closely associated with wet meadows in the Sierra Nevada. The SFEIS Record of Decision and the Framework decision are similar in that both require that livestock be managed "by excluding livestock grazing from standing water, saturated soils in wet meadows, stream channels, and springs in occupied toad habitat" during the breeding and rearing period.

The new decision limits this standard to livestock whereas management of pack and saddle stock were included in the Framework. The failure of the ROD to include pack and saddle stock potentially exposes all life stages to impacts from grazing animals when there is no evidence to suggest that the approach to pack and saddle stock merits any difference.

The new decision adopts a definition of rearing that limits it to life stages up to the point where individuals emerge on to land. This exposes the life stage to mortality from such things as trampling and stranding in holes left by hoof prints.

A final significant weakening of the Framework is the failure of the new decision to adopt an adaptive management strategy that involves research scientists. Instead, the ROD requires that site specific management plans be implemented if the standard to excluded livestock is not adopted. Site specific management plans are deemed by the US Fish and Wildlife Service and experts to be inadequate to address the coordinated management required for this imperiled species.

The Yosemite toad warrants listing under the Endangered Species Act. The notice specifically cited livestock grazing as contributing to direct loss of toads and resulting in adverse modification of habitat. The management direction under the new plan specifically excludes the grazing of pack and saddle stock from the Yosemite toad standards and guidelines. The new plan also fails to establish any timeline for the completion of Yosemite toad surveys and more importantly removes any consequences of failing to complete the surveys.