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Comments on the Santa Fe National Forest Draft Land Management Plan and Draft Environmental Impact S

Dominick A. DellaSala, Ph. D, Conservation Scientist

September 30, 2019

Please accept these comments for the public record regarding the Santa Fe National Forest Draft Land Management Plan and DEIS. I am a conservation scientist with over 30 years experience in forest ecosystems, including documenting the importance of fire mediated biodiversity in dry pine and mixed conifer forests of the West (DellaSala and Hanson 2015). My relevant expertise also includes developing robust conservation strategies for land managers to accommodate wildfires for ecosystem benefits while reducing fire risks to communities.

Summary of recommendations:

I am requesting that the Forest Service modify or include a new alternative that meets the following requirements:


  • Identification and protection of specific connectivity areas (e.g., roadless areas, intact riparian and watersheds) for achieving viable populations of focal species, species of conservation concern, and at-risk species in a changing climate (see Noon et al. 2003, Schulz et al. 2013, Haber and Nelson 2015, especially Table 1). Such areas should be protected from mechanical treatments especially habitat of at risk species (e.g., MSO).


  • Consistent with the guidelines for connectivity in Haber and Nelson (2015:Tables 1 and 2), it is essential for the forest plan to identify key characteristics of connectivity (also Haber and Nelson 2015:Table 3), including composition, structure, process/function at scale: site, landscape, corridors, riparian areas, and wildlife travel routes.


  • An analysis and mitigation of how conditions on the SFNF and surrounding areas (roads, development, grazing especially in riparian areas) affect connectivity (cumulative effects analysis).


  • Substantial reduction in livestock AUMs and increase in riparian, native meadows, and aspen grove protections, restoration and invasive species containment. This should include opportunities for local conservation groups to purchase grazing leases from willing sellers with the allotments and AUMs permanently retired by the Forest Service. Livestock should be removed from riparian areas and curtailed in areas with native plant communities.


  • Accuracy determination and field verification (and error correction) of LANDFIRE and forest canopy determinations, particularly in relation to site specific reference conditions and ecologically appropriate definitions of closed canopy fo rests; the >30% closed canopy definition in the DEIS is arbitrary and has resulted in excessive canopy reduction measures to achieve "open" conditions.


  • Use of multiple lines of evidence (e.g., see Odion et al. 2014 a Moritz et al. 2018) in estimating historic fire regimes and recognition/ analysis of the importance of mixed severity fire effects on plant and wildlife diversity, including small and large patches of high severity fire effects characteristic of drought cycles, fire flare ups, and upper elevation forests.


  • A substantial reduction in mechanical treatments that are otherwise resulting in novel forest conditions that lack integrity and climate resilience because of the over emphasis on open forest conditions that retain few trees. Forests opened by excessive thinning lack understory shrubs, forbs and small trees that contribute to climate resilience (see Baker and Williams 2015, Baker 2018); small trees may also have mature/old growth characteristics because of slow growth rates and more of them ne ed to be maintained as an important understory cohort for future old growth development (e.g., by creating small gaps and leaving many more tree cohorts).


  • A focus on community wildfire risk reduction through partnerships with private landowners that emphasize defensible space measures for homes instead of extensive thinning in the backcountry.


  • A substantial reduction in livestock grazing including large no grazing zones that more aptly address cumulative effects of livestock, infrastructure, and climate change (see Beschta et al. 2012).


  • A reduction in project related carbon dioxide emissions by a project level comparison of emissions alternatives.


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