We need your help now to advocate for a strong Habitat Conservation Plan (HCP) for the Elliott. The HCP is a legally binding plan put forth by the State and approved by Federal Agencies (US Fish and Wildlife Service and National Marine Fisheries Service). It outlines the specific protections for federally listed Endangered Species. The Elliott State Research Forest HCP put forth by the State of Oregon builds on all of the work done to date but adds a lot more detail and analysis. In general, the HCP is consistent with what we expected to see and substantively advances this process forward. However there are several specific areas where the HCP could be stronger and clearer. By submitting comments you can help ensure that the HCP continues to build and expand upon the work done to date.
Please write to the US Fish and Wildlife Services by end of the day on January 10, 2023. They must be submitted through the USFWS Portal (see talking points below). Be sure to note that you are commenting on Elliott State Research Forest Habitat Conservation Plan and Draft Environmental Impact Statement (Document ID FWS-R1-ES-2022-0029-0081).Submit Comments
Please consider making the following recommendations. It is fine to cut and paste these talking points but please add a short personal touch to your comments.
- The HCP must include accurate mapping of occupied and potential Marbled Murrelet habitat on the Elliott. All occupied habitat must include 100 meter buffers and all modeled potential habitat should include complete intact stands that are capable of supporting Marbled Murrelets. Accurate mapping is essential to ensure protection for this species and to accurately assess and mitigate any potential take caused by human activities.
- The USFWS should require Equipment Limitation Zones (ELZs) on all seasonal streams. Allowing heavy equipment in or immediately adjacent to seasonal streams is inconsistent with protection of listed fish species, stream dwelling amphibians and other species, as well as good forestry techniques. An ELZ will be required on seasonal streams on private forest lands under the State’s updated forest practices act and it should be required on the Elliott, as well.
- The HCP should include a commitment to a substantial net reduction of road density from the existing baseline on the ESRF over the life of the permit term. Ongoing reduction should be demonstrated in ten year increments throughout the term of the permit.
- The USFWS should provide more detailed analysis of visual and recreational impacts of forestry activities on the Elliott especially in highly active subwatersheds such as the Lower Millicoma, Salander and Little Salander.
- Only one entry for timber harvest should be allowed for stands designated for “extensive harvest” during the term of the permit. This is consistent with assurances made by the Department of State Lands (DSL) and Oregon State University (OSU) and should be made clear in the HCP.
- Estimates by USFWS and the State of new Marbled Murrelet and Spotted Owl habitat created over the permit term appear to differ, with USFWS estimates substantially lower than the State’s estimates. These estimates must be reconciled and the State should be held to meeting the higher estimates of 14,000 acres of new Northern Spotted Owl habitat and 21,000 acres of new Marbled Murrelet habitat by the end of the permit term as delineated in their HCP.
- No research in occupied Marbled Murrelet habitat should be allowed to proceed unless OSU can demonstrate ability (finding and study design) to assess potential changes in occupancy, nesting success, and presentation. USFWS should have final approval prior to any research commencing.
- USFWS should require replacement of 12 impassable and 22 partial barriers to fish passage identified in the permit area over the course of the permit term.
Thank you for your continued support for the Elliott State Research Forest. It has been a long road, but we have made huge progress. The HCP/DEIS is one more step along this road and, with your help, we can make it even stronger. During the next year we will start moving toward actual implementation.
As a final note, after 30 years with Audubon, this is likely to be my last action alert. Thank you for speaking out so many times for our wildlife and wild places!