[PCA] Center For Biological Diversity NPCC ACTION ALERT: !!COMMENTS NEEDED BY AUGUST 24 Forest Service Policy to Use Native Plants in Revegetation

[Emily Roberson]

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 

ACTION: 

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  <mailto:nativeplant at fs.fed.us>
nativeplant at fs.fed.us  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.

 

 

BACKGROUND

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. 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

 

NPCC COMMENTS: 

 

 

Native Plant Materials Proposed Directive

Rangeland Management Staff, MAIL STOP 1103

Forest Service, USDA

1400 Independence Avenue, SW.

Washington, DC 20250

nativeplant at fs.fed.us

 

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. 

 

Sincerely,

 



Emily B. Roberson, Ph.D.

Director

Native Plant Conservation Campaign

 

 

____________________________

Emily B. Roberson, Ph.D.

Director

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 

 

Email:  eroberson at biologicaldiversity.org 

Web:    <http://www.plantsocieties.org/> http://www.plantsocieties.org 

          www.biologicaldiversity.org 

 

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.

 

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