[PCA] SL Trib 9/18/07 article - ongoing discussion re:fire/reseeding issues

[Harper-Lore, Bonnie]

Unless you have research showing forage kochia does not spread; I would err on the side of caution and not use it!!!
We used to plant kudzu for all the right reasons, too!
Bonnie 

-----Original Message-----
From: native-plants-bounces at lists.plantconservation.org [mailto:native-plants-bounces at lists.plantconservation.org] On Behalf Of Addsum-Tony Frates
Sent: Monday, September 24, 2007 1:11 PM
To: native-plants at lists.plantconservation.org
Subject: Re: [PCA] SL Trib 9/18/07 article - ongoing discussion re:fire/reseeding issues



Craig - thanks for your post.  

Locally the BLM is being criticized, unfairly, for not having previously added Kochia prostrata in the mix.

One further reference:

http://kochiaseed.com/whatisit.html

(note it encourages crested wheatgrass as a companion species) 


Its "native" status aside, we have concerns about a widespread 
introduction of this species.   In light of the huge Milford Flats 
fire, the BLM will be under great pressure to "do something."   
Sufficient quantities of native seed will not exist (nor is it clear that should be the approach even if sufficient supplies of 
local/appropriate seed were available).   Research thus far seems to 
favor use of the exotic forage kochia, and some see it as the magic 
solution.   So, I would be interested to hear the views of others 
with respect to forage kochia specifically, and whether they feel its use should be encouraged at some level.

Hopefully the dialog on this topic will continue.


Tony Frates
Utah Native Plant Society









Date sent:      	Mon, 24 Sep 2007 07:44:41 -0700
From:           	Craig Dremann <craig at astreet.com>
To:             	Addsum-Tony Frates <afrates at addsuminc.com>
Copies to:      	native-plants at lists.plantconservation.org, craig at astreet.com,
  	dpatterson at biologicaldiversity.org, ksuckling at biologicaldiversity.org
Subject:        	Re: [PCA] SL Trib 9/18/07 article - ongoing discussion re:
 	fire/reseeding issues

> Dear Tony and All,
> 
> Thanks for your mention of the Salt Lake Tribune 9/18/07 article on 
> the BLM reseeding after fires.  I love the quote that:
> 
> "Richard Mayol, spokesman for the environmental group Grand Canyon 
> Trust, said land mangers should use extreme caution in planting 
> nonnative species such as forage kochia and the approved [exotic 
> perennial invasive] grasses, 'because there could be unintended 
> consequences.' "
> 
> Could one of the consequences, be that the seeding of exotic invasive 
> seeds is illegal under NEPA and FLPMA?
> 
> When BLM sows exotic perennial invasive seeds onto public lands, 
> without ever writing the legally required NEPA documents---it might be 
> useful to point out to that Tribune reporter, that the agency when it 
> sows millions of pounds of exotic invasive seeds annually onto public 
> lands, has been just challenging some environmental in the West to 
> file a huge hairy lawsuit about the exotic invasive seeding.
> 
> I write about this problem at
> http://www.ecoseeds.com/juicy.gossip.six.html about how sowing exotic 
> invasive seeds after fires without writing the NEPA documents.
> 
> Whenever a government agency sows millions of pounds annually of 
> persistent exotics that would permanently convert Endangered, 
> Threatened and sensitive species habitat to exotic plants that only 
> domesticated grazing animals can utilize, and would permanently 
> interfere with native ecosystem functions, would be defined as a 
> "project" under the National Environmental Policy Act ("NEPA").
> 
> BLM has violated NEPA, by failing to prepare an Environmental Impact 
> Statement ("EIS") for their Great Basin exotic invasive seeding 
> projects.
> 
> The law requires that the BLM examine and assess the significant 
> environmental impacts which the exotic invasive seeding projects will 
> have, individually and cumulatively. NEPA requires that federal 
> agencies conduct a complete and objective evaluation of beneficial and 
> ADVERSE environmental impacts resulting from a proposed action, and 
> all reasonable alternatives.
> 
> Of course, the reasonable alternative to the use of persistant 
> invasive exotics, or even cultivars of native plants, is to only use 
> local native seeds.
> 
> Additionally, BLM's implementation of the exotic invasive seeding 
> projects, violates the mandate of the Federal Land Policy and 
> Management Act ("FLPMA"), that BLM must manage the public lands for 
> multiple use and sustained yield, and will further violate the 
> applicable land use plans for the affected BLM lands.
> 
> It has been argued in previous court cases, that the Administrative 
> Procedure Act ("APA"), 5 U.S.C. ß 701 et seq. allows plaintiffs to 
> seek judicial relief, reversing and remanding BLM's approval for this 
> type of project.
> 
> In addition, because BLM intends to imminently proceed with the 
> seeding projects after fires without preparing any NEPA documents, 
> causing irreparable ecological and other harms to plaintiffs and the 
> public, plaintiffs could seek immediate injunctive relief preventing 
> implementation of the projects until the Court has heard the case.
> 
> Sincerely,  Craig Dremann, Redwood City, CA (650) 325-7333




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