Action Alert
Letters Needed to Protect the Fisher - Comments due Feb. 20, 2009 - Sample Letter Below
“The lives of the animals that will be released – and the future of subsequent, scientifically credible reintroduction efforts – are jeopardized by allowing a private landowner dictate to the government the terms of the reintroduction.”-- Forest Service fisher expert Dr. William Zielinski.
The California Department of Fish and Game has released a Notice of Intent (Jan. 9) to adopt a controversial and precedent-setting plan to move 40 Pacific fisher – captured from public and private lands in northwestern California – and release them onto heavily logged lands owned by Sierra Pacific Industries (SPI) in the northern Sierra Nevada. The region where the fisher will be released is known as SPI’s “Stirling Management Area” and includes approximately 160,000 acres between Highway 32 in Tehama County, and the North Fork of the Feather River in Butte and Plumas Counties, and Highway 70. (Location is shown in black area in map, see below).
The project is the result of a joint venture between the Schwarzenegger and Bush administrations, designed to give landowner SPI protection from future restrictions on its environmentally devastating logging practices--restrictions that may be necessary to protect at-risk wildlife.
The proposal violates state and federal environmental laws because of the significance of the potential harmful impacts, the failure to examine alternatives as required by CEQA and NEPA, and because it could establish a harmful and scientifically baseless precedent that SPI’s clearcutting practices are beneficial to the fisher and other forest-dependent wildlife.
Last year, the Yreka office of the U.S. Fish and Wildlife Service entered into a “Candidate Conservation Agreement with Assurances” (CCAA) with SPI, which pledges that SPI will not be held accountable for the next 20 years for “incidental take” of Pacific fisher resulting from any of its activities. The accompanying permit states “no additional conservation measures or additional land, water, or resource use restrictions, beyond those voluntarily agreed to and described in the CCAA, will be required should the fisher become listed as a threatened or endangered species for the duration of the permit period.”
Incredibly, the purported conservation measures “voluntarily agreed to” are nothing more than business as usual for SPI, which is to convert through clearcutting native forest into uniform tree plantations across nearly 2 million acres of its land ownership in California. This massive conversion currently underway is one of the most under-reported, yet among the most environmentally destructive, legacies of our time.
The 20-year CCAA and permit gives SPI a free pass to continue logging the region without any modifications to their current management regime, regardless of the impacts upon the fisher. The fisher is considered warranted for listing as threatened with extinction by the U.S. Fish and Wildlife Service. Experts conservatively estimate that the Pacific fisher will become extinct in the Sierra Nevada, within the next 50 years.
Take Action: Please send a letter to the California Department of Fish and Game to protest the decision to adopt a “Negative Declaration of Significant Impacts” for the proposal. The agency, at the minimum, must conduct a full environmental impact report (EIR) as required under the California Environmental Quality Act and consider a range of alternatives to the singular proposal to release 40 imperiled Pacific fisher on devastated SPI timber lands. Comments should be faxed or mailed to the address below. Personal letters are always more effective than mass mailings, so to have the greatest impact, tailor the letter to make it reflect your personal view. All the supporting documents can be downloaded from this website. See the column at the upper right, under Resources.
The close of comments is February 20, 2009. Comments must be postmarked or faxed by February 20, 2009. Comments should be faxed or mailed to:
Eric Loft
Department of Fish and Game Wildlife Branch
1812 Ninth Street Sacramento, CA 95811
Fax: 916-445-4048
SAMPLE LETTER
YOUR ADDRESS
Eric Loft, Chief of Wildlife Branch
Department of Fish and Game Wildlife Branch
1812 Ninth Street
Sacramento, CA 95811
Dear Sir,
I am writing to express my concerns and opposition to your issuance on January 9, 2009 of a Notice of Intent to Adopt a Negative Declaration, signifying that there are no significant environmental impacts from the SPI proposal to reintroduce fishers to Sierra Pacific Industries’ Stirling Management Area located between Quincy and Chico in the northern Sierra Nevada. The proposal would release 40 Pacific fisher, captured from private and public lands in northwestern California, over a period of three years. At the same time, Sierra Pacific Industries (SPI) would be issued a permit from the U.S. Fish and Wildlife Service, assuring the company that if the fisher is listed under the Endangered Species Act, as expected, SPI will be granted immunity from any additional conservation measures resulting from the listing for a period of 20 years.
The proposal has the potential for significant long-term impacts, and should be withdrawn until a suitable site for fisher reintroduction can be determined. The SPI lands that are proposed for the transplantation are not suitable for fisher. Other lands—on national forest lands adjacent to the proposed area to the east—are much more suitable, and would not require sacrificing the requirements of the Endangered Species Act to accommodate SPI.
A new proposal should be developed with the input and approval of a broader team of known fisher science experts, including those who are already engaged in leading research on fisher biology in the Sierra Nevada such as William Zielinski, Richard Truex, David Graber, Reginald Barrett, and the fisher team at the Conservation Biology Institute. We agree with the opinion of Dr. Zielinski:
“If the case can be made that reintroduction is justified, logic and the precedent set by most other reintroductions dictates that it should occur at sites with the best probability of success. The proposed reintroduction plan is in direct conflict with the best available science in this regard. The models of Carroll and Davis et al. identify areas with highest landscape habitat suitability, yet these were not considered. Thus, the proposed project entails unnecessary risks to the individual fishers that will be moved, without justifying how this reintroduction will enhance sustainable fisher populations in California.”
According to the U.S. Fish and Wildlife Service, “Adjacent Federal lands contain higher quality fisher habitat than adjacent non-Federal lands; therefore, movement of fishers off of the enrolled [SPI] lands could be anticipated to the Federal rather than non-Federal lands.” (FWS 2008 Conference Opinion and Findings and Recommendations on Issuance of an Enhancement of Survival Permit for the Fisher (Martes pennanti) to Sierra Pacific Industries, Inc. (Permit Number: TE166855-0)).
Why then would CDFG consider releasing fisher onto SPI lands, when adjacent Federal lands with higher quality habitat are readily available? SPI lands uniformly lack the habitat characteristics needed by fisher for survival: dense, structurally complex forests with high canopy cover. Structural diversity refers to large snags and logs with large cavities and platforms for denning and resting. Fisher also require large quantities of old black oaks to provide for denning, resting, and food for the small prey species that are the mainstay of the fisher’s diet.
SPI plans to convert at least 70 percent of its nearly 2 million acres of forest lands in the state to evenaged forests which lack all of these characteristics. The rate and intensity of this conversion now occurring on SPI lands throughout the state is not sustainable. The company has already clearcut approximately 250,000 acres of its ownership in the last decade. The resulting landscapes do not resemble native forest, and are lacking in all of the structural and ecological elements required by fisher and the associated plants and animals that are part of the forest food web necessary to support wildlife.
SPI’s “snag and habitat retention areas” are described by the company as beneficial. However, their paltry commitment to conserving habitat is limited to saving a tree or two in each clearcut unit--while clearcutting more than 99 percent of each unit. How could this be perceived as a benefit? Certainly, one tree is better than none, but this doesn’t equate to a net benefit. Taken cumulatively, as required by CEQA, the net effect of SPI’s clearcutting and habitat modification is highly detrimental. The effects are long term, they may be irreversible, and they are certainly significant.
There is no evidence that SPI’s management will preserve sufficient habitat for fisher or any other species, or that their plantations will produce quality habitat over time. In any event, the trees will be cut again within 80 years from planting, and cannot therefore be considered to provide benefits to wildlife at any time in the present or future.
Please reconsider the Neg Dec decision, withdraw this proposal, and reconvene with a new goal for reintroduction of fisher on Federal lands in the northern Sierra Nevada region as recommended by the leading fisher scientist in the Sierra Nevada, William Zielinski.
Thank you for your consideration of my concerns.
Sincerely,
YOUR NAME