Action Alert

Act Now!!! Forest Service releases their final MIS plan - dismantling wildlife monitoring in the Sierra

Appeal their decision by February 4th and help protect a robust species monitoring program.

American martenOn December 14th, 2007 Region 5 of the U.S Forest Service released the Record of Decision regarding their proposed Sierra Nevada Management Indicator (MIS) Species Amendment. This decision minimizes the Forest Service’s forest monitoring requirements by significantly reducing the management indicator species lists that are tracked across all Sierra Nevada National Forests. The 2001 and 2004 Framework required the Forest Service to monitor impacts that Forest Service projects have on the long-term viability of these species and the long-term health of the habitats that they depend upon for survival.

The revision of existing monitoring requirements will have significant environmental consequences and will weaken existing protection for species and the biological diversity of the Sierra Nevada. Unfortunately the needs of forest health, ecosystem integrity, and species survival are not regarded as a primary purpose of this proposed amendment to the existing monitoring program. A program that has never been acted upon as the 2001 Framework required, which if it had, would have ensured that there would be monitoring data available addressing the impacts of Forest Service management on species of importance and the habitats they depend upon. The new MIS Amendment is more about short-cutting cost and escaping recent legal opinions from the 9th Cir. Court of Appeals (Earth Island Institute v. Forest Service 2006) regarding the Forest Service’s negligence in meeting their monitoring requirements.

Appendix E of the 2001 Sierra Nevada Framework required that the Forest Service develop a monitoring program for a wide variety of essential and important wildlife species within the National Forests of the Sierra Nevada. This important list of MIS within Appendix E survived the Bush Administration's dismantling of the 2001 Sierra Nevada Framework. The existing monitoring requirements for MIS and related species are an essential part of land management plans and provide a valuable safety net to reduce the likelihood of plan implementation having significant adverse environmental impacts.

We can not allow the Forest Service to weaken protections for vitally important MIS or the habitat and population monitoring requirements. Without a robust, scientifically valid and enforceable monitoring program in place there is virtually no way to measure the effects of Forest Service actions within areas of important habitat that serve as the last bastions of hope for the survival of many of the species and the ecosystem they depend on.

Points to make in your appeal


  • Existing monitoring requirements for MIS and related species are an integral and essential part of Forest Service land management plans and provide a valuable safety net to reduce the likelihood of plan implementation having significant though unintended adverse environmental impacts.

  • The Forest Service should be implementing Appendix E as it was intended in the 2001 Framework and upheld in the 2004 Framework Amendment, rather than weakening those thoughtfully created requirements before they have actually been tried and tested. Forest monitoring is the foundation of robust and visionary planning and will greatly advance the agency's credibility as well as meet its stewardship responsibilities.

  • In adopting the 2004 Framework Amendment, the Forest Service unfortunately significantly increased both the amount and intensity of planned logging throughout the Sierra Nevada. This highly irresponsible change to the ground breaking 2001 Framework provisions increased the risk to the viability of numerous species, particularly species associated with old forests. The 2004 Framework also weakened the 2001 Framework's protection for watersheds, streams, meadows, and riparian areas, increasing the risk to the viability of species associated with aquatic habitats. Weakening of monitoring standards added to the weakened protection for these vital ecosystems is inconsistent with applicable Federal laws or the Forest Service stated mission.

  • The Forest Service failed to establish clear "triggers" that will be put in place which define the response pathway for changes in management when the goals set by monitoring and the responses to these monitoring efforts clearly indicate a immediate need to change management due to management activities that are negatively impacting species and habitats.

  • There are important indicator species that do not presently inhabit all national forests of the Sierra Nevada, such as the Pacific fisher, the Yosemite toad, and the Mt. Lyell salamander. These species are important indicators of the health of sensitive habitats within some, but not all, of the national forests. Therefore, they should continue to be listed as MIS for those forests. Reducing the volume of MIS while not taking into consideration the basic notion that wildlife species and ecological habitats do not recognize the man-made delineations of agency jurisdictional boundaries, county lines, or any other territorial delineation created by man is irresponsible and short-sighted.

  • The monitoring program that the Forest Service is proposing to change is an integral part of adaptive management, and therefore a central component of the Forest Service's conservation strategy for MIS and related species. This proposal to substantially weaken the existing monitoring requirements will negate the effectiveness of this early warning system, with potentially grave environmental consequences.

    • How to appeal this decision:

    NOTE: previous standing on the MIS Amendment is not required to appeal. Regulations for appealing this amendment are: 36 C.F.R. 217 located on the Forest Service website.

    Appeals must be filed by February 4, 2008. Appeals may be filed by mail, fax or email at the following addresses and numbers.

    USDA Forest Service
    Attn: EMC Appeals
    Mailstop 1104
    1400 Independence Avenue, SW
    Washington, D.C. 20250-1104
    Fax: (202) 205-1012
    Email: appeals-chief@fs.fed.us

    Be sure to put Sierra Nevada Forests MIS Amendment in the RE: line of your written letter or the Subject Line of your email. Emailed appeals must be submitted in rich text format (.rtf) or Word (.doc).

    Appeals must be post-marked (a clear, visible postmark) or emailed by February 4, 2008.

    For more information regarding the appeals process contact Sierra Forest Legacy:

    Jason Swartz
    Forest Organizer

    Craig Thomas
    Executive Director


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