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Letter to Dan Ashe, Director, U.S. Fish and Wildlife Service

Letter

By:
Date:
Location: Vancouver, BC

In a letter to the U.S. Fish and Wildlife Service (USFWS) sent this week, Jaime Herrera Beutler said that the agency's proposed critical habitat plan would "double down" on a forest management approach that for 20 years has failed to protect forests, the Northern Spotted Owl, and jobs.

The USFWS Revised Critical Habitat proposal would more than double the amount of land designated as critical habitat for the Northern Spotted Owl under the Northwest Forest Plan established in 1992, essentially grinding to a halt any economic activity generated from those lands.

In her letter that served as her formal comment on the proposal, Jaime points out that this approach has failed to preserve Spotted Owl populations: "Yet even with all that has been taken, we continue to see the decline of the [Northern Spotted Owl] at nearly 3% per year, and now the USFWS is proposing to double-down on a plan that has failed to achieve its desired goals."

She also highlights an increased threat of wildfires in northwest forests: "There has been an explosive fuel build up in our PNW forests over the last two decades and without bringing about rational management we stand to suffer the same fate that Colorado is experiencing. Doubling the critical habitat boundaries within our PNW forests will not only fail to serve the [Northern Spotted Owl], it will ensure future catastrophic wildfires that will threaten our clean water, our forests and the wildlife within them, and our communities."

Jaime also urges that the full economic impact be understood before any expanded plan moves forward, given the severe impact the Northwest Forest Plan has had on jobs throughout Southwest Washington: "The cumulative economic impacts that have been experienced by our rural communities must not be ignored, and must be taken into consideration. No changes to the Critical Habitat boundaries should be made without a full economic study of the cumulative impacts that have taken place since the listing of the NSO."

The full text of the letter is below:

Dan Ashe, Director
U.S. Fish and Wildlife Service
Department of the Interior
1849 C Street NW, Room 3331
Washington, DC 20240

Dear Director Ashe,

The Pacific Northwest is unique for its beauty, its way of life, and the richness of our resources. Unfortunately, since the listing of the Northern Spotted Owl (NSO) in 1990, many of our rural communities have lost much of what makes our region so special, and several, including some within my district, are struggling to survive. Yet even with all that has been taken, we continue to see the decline of the NSO at nearly 3% per year, and now the USFWS is proposing to double-down on a plan that has failed to achieve its desired goals.

State and Private Lands

In an unprecedented action, the USFWS is proposing to add significant amounts of state and private land under the revised critical habitat plan. The state of Washington Forests and Fish Law already provides the most environmentally protective standards of forestry in the nation. The forestry practices carried out on our state and private lands have yielded results that put our federal forests to shame. Our private and state lands, which have been managed to provide healthy, diverse forest acreage, are rich with a variety of wildlife, clean water, and much needed jobs for our communities. To further put these lands under the same strictures of mismanagement that our federal forests have experienced will lessen, not increase, the abundance that is found on these lands. The USFWS should exclude all private and state lands from the final rule.

Single Species Management

To its credit, the USFWS has acknowledged in the proposed rule the need to manage for a variety of habitats, and that management for a single species is harmful to the broader ecosystem. Regrettably, our federal forests are in serious decline and provide ample proof of that harm. Actions over the last two decades to develop a landscape of primarily Late Successional Reserves for the NSO, while virtually ignoring other species, has caused great harm to the wildlife that is dependent upon Early Seral habitat. My office has been approached by a variety of conservation organizations, academia, and wildlife biologists, including current and retired US Forest Service employees, who have seen the damage caused by the single species management approach that has been employed in our forests since the listing of the NSO. They have noted numerous species that are facing serious decline due to the forced creation of unnatural and unhistorical conditions within our forests. Our forests and the species within them are sounding the alarm. It is time to end single species management, and to adopt science-based, sustainable forestry that will benefit our forests, our wildlife, and our communities.

Forest Health/Fuel Load

The devastating fires currently taking place in Colorado provide a heartbreaking demonstration of the end result if we continue on the path of mismanagement we have chosen for our federal forests. There has been an explosive fuel build up in our PNW forests over the last two decades and without bringing about rational management we stand to suffer the same fate that Colorado is experiencing. Doubling the critical habitat boundaries within our PNW forests will not only fail to serve the NSO, it will ensure future catastrophic wildfires that will threaten our clean water, our forests and the wildlife within them, and our communities.

Impacts to Communities

The Endangered Species Act was never intended to decimate our rural communities, but it has been misused in a manner that has accomplished just that. Congress intended for economic impacts to be considered as part of the equation when considering the steps necessary to protect an impacted species. The cumulative economic impacts that have been experienced by our rural communities must not be ignored, and must be taken into consideration. No changes to the Critical Habitat boundaries should be made without a full economic study of the cumulative impacts that have taken place since the listing of the NSO.

With the declining state of the NSO, our forests, our wildlife, and our communities it is obvious that the NSO Recovery plan has failed. More specifically, it has failed to: protect the Northern Spotted Owl, enrich our ecosystems, sustain our wildlife, and promote forest health. It has also crippled the economies of our rural communities.

We have 22 years of results to show that the current plan is unworkable. Rather than double down on this approach, it is time to develop a plan that is science-based and takes all of our wildlife and our communities into account. Thank you for your time and consideration.

Sincerely,

Jaime Herrera Beutler
Member of Congress


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