# Sierra Club Comments on the Northern Spotted Owl Recovery Plan

# August, 16, 2006

Northern Spotted Owl Recovery Team

Attn: Dave Wesley, Team Leader

U.S. Fish and Wildlife Service

911 NE 11th Ave.

Portland, OR 97232

Dear Mr. Wesley and Recovery Team Members,

Please accept the following informational comments from the Sierra Club
on the recovery plan being developed for the northern spotted owl. The
Sierra Club has tens of thousands of members in Oregon, Washington, and
northern California and over 700,000 members nationwide who have a
strong interest in ancient forest protection and the full recovery of
the northern spotted owl. These comments are a supplement to remarks
from the Sierra Club delivered at the stakeholder session held in
Portland, OR on August 9, 2006.

In January 1991 the Board of Directors of the Sierra Club adopted a
policy calling for the complete protection of the ancient forests of the
United States. The Sierra Club's standing policy on ancient forests
states that:

> 'The ancient forests of the United States are among the Earth\'s most
> treasured resources. However, decades of logging have reduced these
> magnificent forests to a mere fraction of their past majesty, and the
> biological diversity of the very ecosystem they comprise is severely
> threatened. All levels of government must take immediate action to
> curb this tragic loss of our ancient forest heritage. We consider the
> protection of these ancient forests as one of our basic goals. We
> believe that those remaining ancient forests which are capable of
> surviving, as well as the surrounding areas that contribute to the
> preservation of a vital, functioning ancient forest ecosystem in the
> United States, should be saved and not logged.' Adopted by the Sierra
> Club Board of Directors, January 12-13, 1991; amended February 23-24,
> 2002.

It is in the spirit of calling for immediate action to protect all
remaining ancient forests from logging as well as the surrounding
forests necessary for the recovery of functioning ancient forest
ecosystems that these comments are submitted. As you know, the northern
spotted owl is an indicator species for the health of ancient forests
ecosystems and functioning mature and old growth forest habitat across
its range. It could not be more clear that a plan to fully recover the
northern spotted owl so that it can ultimately be removed from the list
of threatened and endangered species must include not only the complete
protection of all remaining suitable northern spotted owl habitat, but
also the development of new contiguous suitable habitat to connect these
areas. This cannot be limited solely to federal land, but must include
spotted owl habitat on state, private and other ownerships as well.
Spotted owls do not know ownership boundaries, and across much of its
range, land ownership is often fragmented. Immediately preventing the
further logging of all critical and suitable habitat for the northern
spotted owl, as well as preventing additional harm to individuals and
populations of this species, must be the recovery team's highest
priority.

Continued logging of mature and old growth forests on federal land since
the 1994 adoption of the Northwest Forest Plan, plus the lack of
commitment from state departments of forestry and private industrial
forestland owners to help in a meaningful way to recover the species
have contributed to the predictable, continued decline of northern
spotted owl populations. The steady rise in numbers of barred owls have
placed an additional threat on spotted owl populations, not previously
anticipated when the Northwest Forest Plan was developed. Recent human
activities also were not anticipated during the development of the
Northwest Forest Plan but arguably provide a set-back spotted owl
recovery, prominently including the clear-cut logging of habitat within
Late Successional Reserves and roadless areas during post-fire logging.
It is simplistic and not scientifically defensible to simply state that
spotted owl habitat is 'destroyed' when a fire burns through an area.
The developers of the Northwest Forest Plan did not anticipate
aggressive post-fire logging in the reserves. Even after stand
replacement fires in older forest habitat, many legacy elements useful
to spotted owls are left behind including large snags, damaged live
trees, and large downed logs all of which create habitat diversity and
which can not be replaced for hundreds of years once removed from forest
ecosystems.

In recent years, another disturbing trend has emerged which the recovery
team should take into account when outlining the steps necessary to
fully recover the northern spotted owl: logging levels in spotted owl
habitat have been increasing, and further plans are in the works to
increase cutting despite a continued reduction in spotted owl numbers.
This is happening throughout spotted owl habitat in the Pacific
Northwest, and will be exacerbated by plans under currently under
development, including the Bureau of Land Management's Western Oregon
Plan Revision which proposes to do away with all reserves, increased
cutting proposed for Oregon's Elliot State Forest, and the potential
unraveling of the management plan for the Tillamook and Clatsop state
forests in favor of more annual cutting..

While board feet is clearly not an exact measure of impacts to suitable
spotted owl habitat, it is an indicator of trends in logging activities,
particularly on federal and state lands where the bulk of volume likely
is coming from older forests that either are suitable spotted owl
habitat, or are developing into suitable owl habitat. On August 7, 2006
the Oregon Department of Forestry released timber harvest data for
Oregon for 2005. ODF reports that logging on state lands in Oregon,
which exist primarily within the range of the northern spotted owl,
increased 17% between 2004 and 2005, up to 341 million board feet.
During the same period, logging on Forest Service land in western Oregon
also increased. BLM saw a 26% increase in logging, where the bulk of
their land is within the range of the northern spotted owl. According to
ODF, 'the trend toward increasing concentration of timber harvest in
western Oregon continued in 2005, with 87% of the statewide harvest now
occurring on the Westside.' Though federal and state logging west of the
Cascades is increasing, private industrial forestland owners made up the
bulk of the logging in Oregon, accounting for 68% of the state's total
logging.

This trend of increased concentration of logging in western Oregon does
not bode well for the recovery of the northern spotted owl, nor do
management plans such as BLM's Western Oregon Plan Revision, or WOPR.
The WOPR is a very substantial threat to the integrity of the Northwest
Forest Plan, with its strategy of reserves and other land management
allocations. The WOPR is a reasonably foreseeable action that must be
considered in this recovery planning process. Southwest Oregon, where
much the BLM's forestland is concentrated, has a substantial fraction of
the remaining population of northern spotted owls and their habitat.
While the population of spotted owls has been relatively stable in
southwest Oregon, spotted owl habitat has been disappearing here faster
than other federal ownerships in the region. By continuing to propose
logging projects that clearcut spotted owl habitat, and proposing a plan
to do away with Late Successional and other reserves, the BLM appears to
not understand that the northern spotted owl is still in decline or that
the federal government's obligation is to work to recover the species
until it is stable enough to be removed from the list of threatened and
endangered species. It is our opinion that the recovery plan for the
northern spotted owl must include complete protection of all remaining
spotted owl habitat on BLM lands, whether in Late Successional reserves,
riparian reserves or the Matrix land allocation. Because much of BLM's
land ownership is fragmented in a checkerboard pattern, protection of
remaining owl habitat on these lands is particularly critical given the
overall landscape is at greater risk of fragmentation than areas where
federal land is more contiguous.

Further, southwest Oregon and northwestern California forests are
ecologically different from the Westsern Cascades and Coast Ranges.
Southwest Oregon and northwestern California are perhaps the best hope
for northern spotted owl metapopulation survival and recovery, and the
recovery plan needs to include a careful review of the factors affecting
northern spotted owl survival and recovery in the region, including the
upcoming WOPR, and issues such as stand replacement forest fire, which
indicate a need to protect all existing spotted owl habitat in the
region from logging and allowing surrounding forests to develop suitable
habitat. Additionally, other factors are important, such as sudden oak
death and global climate change, which is very likely to affect fire
regimes and annual fire behavior.

Climate change, in fact, is a huge issue across the northern spotted
owl's range. A recovery plan must include an anticipation of loss of
spotted owl habitat to climate change related factors such as stand
replacement fire and changes to forest composition. This needs to be
considered up and down the Cascades, in the Coast Ranges, and from the
Olympic Range to the Klamath-Siskiyou Mountains. It seems that caution
would again speak to the need to preserve all remaining spotted owl
habitat and focus also on recovering and developing surrounding habitat
to act as a buffer so that the species can absorb losses in individual
populations. The threats of climate change and disturbance factors such
as large scale fire strongly suggest that larger reserves than currently
exist need to be established across the owl's range, with additional
suitable habitat allowed to develop in order to connect these reserves.
Larger reserves with protected buffer and dispersal habitats also will
allow spotted owl populations to be better able to withstand large-scale
disturbances.

Lastly, there is a need to address the threat that the barred owl poses
to the northern spotted owl. As has become clear, in many parts of the
spotted owl's range, barred owl populations are steadily increasing.
These owls tend to be on average larger than spotted owls and are less
specialized in their use of mature and old growth forests as well as
fragmented habitats. Barred owls are more aggressive and competitive for
territory. They will predate on dispersing young spotted owls, and can
displace spotted owls and prevent them from recovering in otherwise
suitable habitat. There are numerous scientific studies documenting the
barred owl threat, including a 24-year case study in the Cowlitz Valley
Ranger District on the Gifford Pinchot National Forest in Washington,
published in the December 2003 issue of the *Journal of Raptor Research*
by spotted owl surveyor Robert Pierson, and the US Fish and Wildlife
Service's Kent Livezey. This study suggested that barred owls were
displacing spotted owls, appropriating vacated spotted owl territories
and negatively affecting spotted owl dispersal by making areas between
spotted owl territories inhospitable to juvenile spotted owls. The human
caused loss of old growth forest through logging also appeared to reduce
the ability of spotted owls to compete successfully with barred owls.
One of the strategies for dealing with the presence of barred owls must
be to create larger reserves for the purpose of both protect existing
habitat and allowing the development of additional habitat to help
ensure the security of the spotted owl. The recovery plan should use
existing fragments of suitable habitat to provide the basis for the
creation of larger blocks of contiguous habitat that are more favorable
to northern spotted owl survival and healthy reproduction than those
which currently exist. To create these, all existing older forest,
whether it currently supports spotted owls or not, no matter where it
exists should be protected and additional habitat surrounding these
areas and connecting them to other older forest habitats should be
allowed to develop and be protected. Spotted owl survival in the future
will depend on areas where owls can disperse and find new suitable
habitats.

To reiterate, the recovery plan needs to focus on protecting all
remaining northern spotted owl habitat from logging, whether on public,
private, state or other lands. Further, across all of these land
ownerships, steps need to be taken to grow and protect additional
spotted owl habitat to help create contiguous blocks of habitat over
time, promoting connectivity to help the survival of the species. This
is particularly important where fragmentation of land ownership exists,
such as in southwest Oregon or the northern Washington Cascades. The
fragmented land ownership pattern in southwest Oregon in particular must
be addressed as the BLM is currently planning to actively reduce
northern spotted owl habitat on its lands through its existing timber
sale program and also in the future through the Western Oregon Plan
Revision. Further, much of the BLM land affected is in southwest Oregon
where, together with surrounding private industrial and Forest Service
land, is situated in an important corridor for populations and
individuals migrating between the Siskiyou mountains and southern
Cascades. Generally, there should also be a prohibition on post-fire
logging in Late Successional Reserves, Matrix areas and suitable or
critical habitat wherever it exists. The focus on removing legacy
elements such as large diameter snags and damaged trees in post-fire
logging operations presents a grave threat to owls and their habitat.
Owls can survive in and return to burned forests if they have been
displaced. Spotted owl nesting on Medford BLM land after the Timbered
Rock fire is one area where this has been shown to the case.

The ultimate goal of the recovery team's efforts should be to optimize
prospects for northern spotted owl recovery until its populations are
healthy enough to be removed from the list of threatened and endangered
species. What spotted owl recovery will require is the protection of
large trees and snags across the landscape and the protection of not
only classic old growth forest conditions -- including a multilayered
canopy, large diameter trees, large diameter snags, and large downed
trees -- but also the natural processes which develop these conditions.
This habitat needs to be maintained where it exists and allowed to
develop into continuous unfragmented landscapes that may need to cross
ownership boundaries. Restoration activities that involve tree removal
to help turn monoculture tree plantations into more structurally diverse
older forest should be concentrated on private lands. On public lands,
restoration activity should be limited to areas that have been
previously clearcut and should not be conducted through commercial
logging, to help ensure abusive timber sales do not move forward under
the guise of 'spotted owl restoration' or another similar justification.

Thank you for the opportunity to comment on the recovery plan for the
northern spotted owl. We look forward to providing additional
constructive comments as the draft recovery plan becomes available.

Sincerely,

Ivan Maluski

Conservation Coordinator

Sierra Club, Oregon Chapter

2950 SE Stark, #110

Portland, OR 97214