Documentation of interference in the draft recovery plan of the Northern Spotted Owl by the "Washington Oversight Committee" and the Forest Service and BLM
It was brought to the attention of the House Natural Resources Committee that the US Forest Service did not agree with my claims that they had disproportionate influence in the drafting of the owl recovery plan. To respond to the agencies' assertion, this exhibit includes some of the documents that were submitted to the recovery team at recovery team meetings (emails and meeting notes) by the U.S. Fish & Wildlife Service detailing the level of influence the Washington oversight committee, Forest Service, and BLM had in directing the draft recovery plan.
Source 1 (Northern Spotted Owl Recovery Plan Options): notes taken by the Interagency Support Team (IST) at the October 18 meeting of the recovery team and distributed to the recovery team. Items 1A-3 below, in particular, are based on direction from the Washington Oversight Committee requesting a redo of an earlier draft submitted under consensus by the recovery team on September 29. Also note the request to eliminate the "MOCA" concept, which eventually became the basis for Option 2, which is not based on fixed reserves.
Northern Spotted Owl Recovery Plan Options
October 18, 2006
General concept
The Recovery Team will develop 2 options that tier off the existing draft recovery plan. Each of the options may require revision of the introduction section (though we could write a generic one for each option), recovery strategy, criteria, and actions, and implementation schedule and cost estimates. The current concept is to have one larger document with the background section unchanged, and include the current option along with the 2 new options. The options would need to develop the recovery strategies, criteria and actions.
We also need to do a "reorganization and emphasis" rewrite of the existing draft - which would not be a new option. A separate group can likely do this task with approval by the recovery team.
The time we have to do these tasks is undefined, but we need to assume time will be short. From the perspective of the team, this may be acceptable since many team members are pressed for time.
Also, the options below do not build in time for conducting a risk assessment. Such a risk assessment, though, could be conducted during the public comment period.
Decision process
Consensus: It will need to be decided if the team continues with consensus decision-making. This decision will obviously be influenced by our given timeline.
Coordination with decision-makers: Reasonable coordination with decision-makers will help ensure the team is having the desired discussions. The method and timing of coordination should be outlined as early as possible.
Options
1: Keep plan as submitted September 29, 2006
1A: Reorganize the September 29, 2006 plan
* Emphasize the new science indicating habitat variability across the range, and de-emphasize the past
* Reorganize the plan to bring the habitat targets to the fore
* Clarify language relating to the Northwest Forest Plan, with emphasis on Forest Service and BLM land and resource management plan (LRMPs) revisions
* Clarify language relating to barred owl and fire
* More clearly state the plan's recognition of management flexibility, including the potential for a mosaic approach (should also provide some context here - fact that this effort has not been undertaken before)
* Retain the Managed Owl Conservation Areas (MOCAs) - Note change of name from "Mapped" to "Managed"
Timeline: 2 weeks, no new analysis would be included
2: Provincial habitat targets
* Eliminate the MOCA concept (emphasis added) and instead establish provincial habitat targets
* Describe in narrative the rule set for distribution and size of either habitat or the spotted owl population
* Revise the habitat criterion to describe provincial targets
* Would require revision of the population distribution recovery criterion
* Would require revision of some of the recovery actions
Timeline: Minimum of 4 weeks. It is unclear if new analysis is required, or can we just build off of the information existing in the September 29th plan. For example, can we just aggregate the MOCA acreage within each province, set a provincial habitat target and eliminate the individual MOCA boundaries, and then describe a habitat distribution and size rule set? If this is what needs to be done, do we need new analysis?
3: Range-wide habitat targets with some sub-range-wide delineations
* Eliminate the MOCAs (emphasis added) and provincial boundaries and establish range-wide habitat targets
* Establish some sub-range-wide delineations (e.g., north, south, east and west) that will allow us to discuss variation across the range
* Would require revision of the population distribution and habitat recovery criteria
* Would require revision of some of the recovery actions
Timeline: Minimum of 8 weeks. It is unclear what this option fully entails, yet it is assumed new analysis will be required given the option's scope.
Source 2 (What is meant by additional flexibility?): meeting notes distributed to the recovery team on October 27 by USFWS staff summarizing direction from the Washington Oversight Committee, including the identity of the oversight committee members and the role of Deputy Secretary Lynn Scarlett. Note the request to the recovery team regarding additional "flexibility" and the need for a non-reserve based option (Option 2). The conservation science literature, including scientific assessments of the Northwest Forest Plan (see Courtney et al. 2004 cited in my testimony), strongly support fixed (mapped) reserve approaches for conserving declining species; shifting mosaic approaches that do not rely on fixed reserves have never been tested or modeled, particularly at the scale of range of the Northern Spotted Owl, and are unlikely to provide regulatory assurances for eventually delisting the owl (the owl was listed in 1990 because of declining populations attributed to logging of old-growth forests and "inadequacy of regulatory mechanisms").
What is meant by additional flexibility?
Desire to explore alternatives to reserve-based approach (emphasis added)
Why is there political sensitivity to this document as it does not have regulatory authority?
Concern is that it would provide material for lawsuits (emphasis added)
Does the provincial option focus only on federal lands?
There was no discussion of this issue, though it is assumed we would still focus on federal lands
If we are asked to produce an option, what are the ground rules for supporting/not
supporting an option?
We have the option to say the RT does not want to pursue an option
We need an explanation about why an option would not work
Are we required to do new population modeling given the desire not to look backwards? There is not the assumption that we need new modeling, maybe we need to discuss certainty/uncertainty
Describe amount, quality and distribution of habitat
Oversight Committee
Jim Cason - Asst to the Dep Secretary,
Lynn Scarlett Lynn Scarlett - Dep Sec of DOI
David Verhy - Asst Sec of Parks and FW
Julie McDonald - Dep Asst of Parks and FW DOI
Julie Jacobson - DOI BLM
Kathleen Clarke - Director, BLM
Dale Hall- Director, FWS
Jim Hughes - Dept Director, BLM
Mark Rey - Under Sec of Ag
Dave Tenney - Dept to Rey
David Bernhardt - Solicitor to Sec of DOI
Fred Norburry - Associate Dep Chief Forest Service
Ed Shepard - Vice Elaine Brong, BLM
Can we modify the options?
- After multiple approaches are described and commented upon, there may be the option to combine approaches
Do we go out to the public with multiple options or just to the decision makers? What do we gain with giving the public multiple options?
- According to the oversight committee, what is the purpose of the public comment?
- Could we outline our process of exploring the options in the intro or NOA?
Should the team identify a preferred alternative?
-Delay this question .
-Develop options to a similar level, discuss with oversight committee
How do we integrate BDOW management and monitoring into these different alternatives?
Are we going to conduct a d (sic) of the options? If so, when would we do this? What are the performance measures?
What are the performance measures
- management flexibility
- risk vs. cost
- likelihood of achieving recovery - is it implementable?
Option 2 should entail:
Points from Dep Sec Scarlett (emphasis added)
* Start with newer science, how it works, de-emphasize the reference to the NWFP
* Presentation, framework, and process issues (i.e., should we provide options or
variations on a theme rather than a single approach, we should look at the opposite approach)
* More outcome focused, less focused on habitat preservation (emphasis added)- this is a
presentation issue, the substance does not change
Points made to the Oversight Committee
. 80% of MOCAs allow 20% flexibility
. 50-70% of habitat-capable acres provides flexibility
. Should the R T just describe these as intended and see what feedback we get
Questions from the RT
. Is there new science that applies across the range?
How will we make decisions?
- Resurrect original decision document
- Uncertainties/weaknesses/pros/cons noted
- Greater/lesser confidence
Source 3 (NSO Recovery Team Meeting October 26-27, 2006): notes taken by USFWS staff at October 26-27 meeting of the recovery team. Note the reference to the BLM WOPR. The BLM is currently revising its forest plans under the settle agreements reached with the timber industry by the administration whereby the agency must consider an alternative that minimizes reserves providing that the alternative complies with the ESA and Clean Water Act (see Exhibit B of my testimony). These notes also illustrate the shift from consensus to responding to direction from the Washington Oversight Committee.
NSO Recovery Team Meeting October 26-27, 2006
Key Points
1) The RT will attempt to draft a concept paper (see Draft Concept Paper) for review by the oversight committee by December 15, 2006. The intent is to provide some useful information to the BLM's Western Oregon Plan Revision process (emphasis added).
2) The concept paper will outline the options, what they would entail, if new analysis is needed, and the pros and cons of each option.
3) The Recovery Team would first assess which options it thinks are doable within the timeframe and which have at least a reasonable likelihood of achieving recovery. The team would only pursue those options it believes are doable, describing how it came to this decision.
4) The team discussed moving away from consensus decision making in order to meet our timeline and more fully capture scientific uncertainty associated with the options.
5) The team will meet again in November and December, and has tasked the support team to begin drafting elements of the concept paper.
6) After December 15 our next key deadline is February 1st. By the 1st we would like to have all the agreed to options described to a similar level of detail and submitted to the FWS.
Key Remaining Questions
1) Finalize how the team makes decisions
2) Will we be asking the public to review multiple options or will the oversight choose a single option for public review?
3) Can we describe sufficient options using the population modeling assumptions of the 1992 Draft Recovery Plan? If not, do we need to create a new model to assess whatever approaches we describe? Do we have the time to create a new model?
4) Do we have the time and desire to conduct (or have someone conduct) an analysis of the different options in relation to some agreed to performance measures?
Schedule and tasks
- Comments on options, including pros and cons, to IST by November 3
- Review decision document for next meeting
- Provide any questions for Ren ASAP
- Face-to-face meetings:
o Nov 15 (4-6pm), Nov 16, 17 (8-12pm)
o Finalize concept paper by the large group
o Draft concept paper from the IST to the RT by Nov 9
o Discussion of pros and cons of each option
o Dec 6 (4-6pm), 7, 8 (8-12pm) on calendars
o Keep January dates on the calendar, 8 (4-6pm), 9, 10, 11 (8-12pm)
o Face-to-face January 23 (4-6pm), 24, 25 (8-12pm)
- Teleconferences:
o December 15 (10-12pm)
o January 18 (10-12pm)
Source 4 (Changes made to make (sic) Option 1 of the Draft NSO Recovery Plan November 15, 2006): Interagency Support Team notes of recovery team meeting on November 15- note reference to limit habitat discussion to a single page and eliminate references to the Northwest Forest Plan. Also note the reference to "shifting mosaic models," which became the foundation for Option 2.
Changes made to make (sic) Option 1 of the Draft NSO Recovery Plan November 15, 2006
The following are the instructions given to make Option 1. The Option 1 you have as of today includes these changes.
Maintain all essential elements of the current draft (e.g., the MOCAs) and clean up any
editorial mistakes. This is reformatting with no new analysis.
Including:
1) Move recovery criteria and actions up front, right after the introduction.
2) Move all of the background section, except the threats discussion into an appendix. Clarify
the significance of the BDOW threat (e.g., indicate it was only threat given priority number 1) and summarize the habitat threats discussion into less than a page (emphasis added). Add all of the threats discussion into the appropriate listing factors (so there won't be a separate threats discussion in the main body, only in the appendix).
3) Revise how we reference the NWFP throughout the document. For example, use this language up front -
"The plan uses the science underlying the Northwest Forest Plan (NWFP), which was published in 1994, as the federal contribution to the recovery of the spotted owl. The NWFP amended the 19 national forest and 7 BLM district land and resource management plans (LRMPs) that guide management of individual national forests and BLM districts. The LRMPs adopted a set of reserves and standards and guidelines described in the Record of Decision (ROD) for the NWFP. The plan uses the guidance from the existing LRMPs as the baseline of existing management direction for the conservation of the spotted owl.
Throughout this plan, use of the term "LRMPs" references the entire 18 LRMPs that were amended by the NWFP."
And then eliminate reference to the NWFP (emphasis added) and put in something like "In accordance with the LRMPs..." throughout the rest of the document.
4) Revise intro to highlight our incorporation of new science and importance of BDOW threat. Also quote SEI 9-20, 2nd paragraph, "shifting mosaic models for owls persistence on the landscape are less well-developed than reserve based models. There has been no analysis evaluating the efficacy of the shifting mosaic model. However, we have no reason at this point to feel the scientific evidence negates this as a plausible conservation strategy." Also state we chose to follow the conservation strategy more fully analyzed in existing peer-reviewed literature.
5) Include list of flexibility to modify the MOCAs -- put into sentences these ideas
o Asking for input on draft boundaries
o 5% loss of habitat-capable acres is OK
o Only need to have 80% of MOCAs in habitat condition by province
o Habitat target in MOCAs is 50-70%, not 100% as in LSRs
o Only 10 of 12 provinces with MOCAs
6) Change "mapped" to "managed" in MOCA
7) Insert paragraph indicating the variability of fire across the range as either a threat or
benefit to the owl. Where it is a threat, indicate the support for efforts to reduce risk.
8) Modify actions accordingly, e.g., Recovery Action 9 would be modified as such (underlined text is new)¬
"In the MOCAs, apply the implement the applicable silviculture principles/guidelines for Late-successional Reserves listed in the NVIFP to accelerate development of spotted owl habitat to achieve Recovery Criterion A.l."
9) Recommend to target key areas-if BDOW experiments show negative effects
10) Emphasize that 50-70% are not habitat targets to cut down to
11) Identify questions for Alan Franklin regarding his new information and note in text that
the information needs to be analyzed during our peer review
Source 5 (January 16 email from Dave Wesley detailing direction from Deputy Secretary Lynn Scarlett): email from Paul Phifer, USFWS, to the recovery team summarizing direction from Lynn Scarlett, Deputy Secretary of Interior. Note - Option 2 was not a product of the recovery team but was specifically designed by the IST in response to the Washington Oversight Committee and direction coming especially from the BLM and Forest Service (also see sources 6 and 7).
From: Paul_Phifer@fws.gov [mailto:Paul_Phifer@fws.gov]
Sent: Tuesday, January 16, 2007 9:00 AM
To: cullinant@olympus.net
Subject: Fw: NSO Recovery Team Information
----- Forwarded by Paul Phifer/RO/R1/FWS/DOI on 01/16/2007 11:58 AM -----
Dave Wesley/RO/R1/FWS/DOI
01/12/2007 07:07 PM
To
Dave Wesley/RO/R1/FWS/DOI@FWS, Michael Haske/ORSO/OR/BLM/DOI@BLM, Calvin
Joyner/R6/USDAFS@FSNOTES, Scott Gremel/OLYM/NPS@NPS,
tcullinan@audubon.org, ldiller@greendiamond.com,
john.mankowski@ofm.wa.gov, jpaul@odf.state.or.us, jsiperek@dfg.ca.gov, dwooten@softcom.net, Paul Phifer/RO/R1/FWS/DOI@FWS, emurphy@spi-ind.com, Lenny.young@wadnr.gov, dominick@nccsp.org, lori@nccsp.org, Ren Lohoefener/RO/R1/FWS/DOI@FWS, Mike.J.Cafferata@state.or.uscc, Kent Livezey/WWO/R1/FWS/DOI@FWS, Brendan White/OSO/R1/FWS/DOI@FWS, Joseph Lint/RBFO/OR/BLM/DOI@BLM,
Kath Collier/ORSO/OR/BLM/DOI@BLM, Elaine N Rybak/R6/USDAFS@FSNOTES, Kristi Young/RO/R1/FWS/DOI@FWS
Subject: NSO Recovery Team Information
All:
Happy New Year! I hope everyone had a great holiday season and the new year has been a joyous one so far!
We just received new direction from Lynn Scarlett, Deputy Secretary of the Interior concerning the NSO Recovery Plan. We have been asked to provide 2 independent options of the Recovery Plan. Option 1 is the reformatted Sept 29 version we have discussed on several occasions and Option 2 is the provincial goals version (emphasis added). Both options are due in Washington by February 5. These options are to address the recent direction we received from DC (there are 2 Word files attached below) (emphasis added).
Given the short timeframe, we are canceling the Jan 23-25 Recovery Team meeting. We are still planning on having the 1/18 telecon (10-12 pm PST) to discuss these issues.
I apologize for canceling another meeting with little notice. I understand some of you may incur cancellation fees. If this is the case, let Paul know and we will see what we can do to reimburse you those fees.
Here is our plan -- the IST will 'delink' Option 1 from the combined draft as it exists now and review it to insure it represents the Teams' best efforts as of September 29th, including the organizational modifications and changes we previously discussed. The IST will also draft the
provincial Option, Option 2, using the best information from our last meeting and the guidance (direction/questions) we have received from DC.
As there is a bit of ambiguity in these directions/questions, the IST will be consulting with the FS and BLM to ensure we address their concerns (emphasis added).
Although this new timeline will necessitate most of the additional work will be done by the IST, with agency oversight, we want to keep the Recovery Team involved as much as possible. Therefore, as soon as the drafts are completed, we will send them to the RT for review and comment. We aim to get the RT the draft of Option 1 by 1/18, and the draft of Option 2 by 1/26. This leaves us with an extremely short timeframe for review, so we will need your comments by close of business on 1/31 in order for us to make any final changes by the 2/5 deadline. I know this will be difficult, but we want to give you the opportunity to submit comments for FWS consideration before a final Draft is sent to the Washington office.
The Recovery Team obviously still has considerable ownership of this plan, especially of Option 1 as it best represents the RT's thinking on September 29th. We understand there are concerns about both options. Our plan is to have some type of structured review of both options during the public comment period. That's our goal.
We'll discuss these issues on the 1/18 call. Feel free to call me (503.231.6118) or Paul (503.724.1886) anytime before then.
DAVE
David J. Wesley
Deputy Regional Director
Source 6 (email from Paul Phifer with specific direction from the FS and BLM on the recovery plan): January 16, 2007 email from Paul Phifer, USFWS, to the recovery team including an unsigned memo (titled draft direction - see source) from the BLM State Director (Oregon) and Regional Forest Service Director (Portland) illustrating the level of inappropriate influence the Forest Service and BLM had in structuring the recovery plan.
From: Paul_Phifer@fws.gov [mailto:Paul_Phifer@fws.gov]
Sent: Tuesday, January 16, 2007 8:10 AM
To: Paul_Phifer@fws.gov
Cc: Brendan_White@fws.gov; cjoyner@fs.fed.us; Dave_Wesley@fws.gov;
dominick@nccsp.org; dwooten@softcom.net; erybak@fs.fed.us;
emurphy@spi-ind.com; john.mankowski@ofm.wa.gov; Joseph_Lint@or.blm.gov;
jpaul@odf.state.or.us; jsiperek@dfg.ca.gov; Kath_Collier@or.blm.gov;
Kent_Livezey@fws.gov; Kristi_Young@fws.gov; ldiller@greendiamond.com;
Lenny.young@wadnr.gov; lori@nccsp.org; Michael_Haske@or.blm.gov;
Mike.J.Cafferata@state.or.us; Ren_Lohoefener@fws.gov;
Scott_Gremel@nps.gov; Steven_Morey@fws.gov; tcullinan@audubon.org
Subject: Re: NSO questions from oversight committee
FROM BLM Staff in Oregon:
Attached is a draft set of directions to the recovery team that reflect the comments of the BLM State Director in coordination with the FS Regional Forester. (note - the attachment here refers to source 7 below)
Additional comments:
1. FWS should ensure the estimates for the cost of recovery reflect reasonable interagency contributions and that cost estimates include labor for federal agency personnel.
Source 7 (draft direction memo from the FS and BLM): Unsigned memo (received on January 16, 2007) from BLM State Director (Oregon) and Forest Service Regional Director (Portland) attached to the cover email from Paul Phifer in source 6. This memo, in particular, illustrates the degree of influence exerted on the recovery plan by the Forest Service and BLM (also see source 8 for additional Forest Service and BLM influence).
Draft Direction
We appreciate the continued commitment and hard work of the Recovery Team (RT). The Recovery Plan (RP) for the Northern Spotted Owl (NSO) will identify and prioritize recovery actions to guide monitoring, research, project planning and on-the-ground management actions by the federal agencies and describe recovery goals to be considered in developing future land use plans. The northwest forests are dynamic systems that will change considerably over the 30 year recovery period. Our knowledge of the Barred Owl, now the single biggest threat to NSO recovery, will improve dramatically over the same time.
Over the life of the RP, the BLM and US Forest Service will periodically revise the land use planning documents of the nineteen National Forests and six BLM districts covered by the Northwest Forest Plan (NWFP). The RP will provide long term goals for recovery, with both short and long term recovery actions, but it must also provide a reasonable level of flexibility to enable the agencies to continue to adapt and revise land use plans based on new information and observed results.
Therefore, we request the RT proceed as follows:
1. Fully develop Option 2 (province level rule set) independent of Option 1. Use the Interagency Scientific Committee (ISC) report, the 1992 Draft Recovery Plan, and more recent peer reviewed scientific publications, like the 10-Year Status Review, to develop the rule set. Drop rule #1 that carries over the MOCA acres by province from Option 1 and clarify rule #5 that calls for "as much high quality habitat as possible." Clearly describe the goals and objectives of each rule so the agencies can determine, in consultation with the FWS, how best to achieve the goals and objectives of the RP while providing for other goals identified in land use plans. The RP should place primary emphasis on identifying the quality and characteristics (size and spacing) of necessary habitat based on the best information available, including historic occurrence data and describe objective, measurable recovery criteria. Provide to the FWS a final draft by March 1, 2007 for public release by April 1, 2007.
2. Provide additional emphasis on actions to reduce the loss of important NSO habitat by wildfires and to address the threat of Barred Owls. To the extent possible, identify priority areas in need of treatment and describe the goals of such treatments.
3. Rather than assume continued management of the federal lands according to the NWFP, assume the federal agencies will continue to manage federal lands per a land use plan which will be based, in part, on the RP. Also, assume actions to implement federal land use plans will be accompanied with either plan or project level consultations to ensure management actions align with recovery goals.
4. As you prepare the RP, include applicable actions or strategies from the NWFP as specific goals, objectives or recovery actions when necessary to contribute to recovery, but de-link the action or strategy from the NWFP and describe it in independent terms. Any element of the 12 year-old NWFP brought forward into the RP should be re-evaluated based on current knowledge of threats to ensure continued applicability. For federal lands outside the areas to be managed for NSO, assume those lands will continue to represent habitat capable acres. Though nesting, roosting, foraging and dispersal habitat will continue to be available on federal lands outside the areas to be managed for owls, and will continue to contribute to recovery, the amount and locations of such habitats will vary over time based on implementation of land use plans and naturally occurring events.
4. Recognizing that size and spacing of habitat blocks will be a key element of any RP, a rule set that identifies either the minimum or a reasonable range for each variable will provide both the most flexibility and most responsive management direction. When a range of values is provided, explain the basis for the values that define the range.
Source 8 (response from USFWS to FS and BLM direction memo): January 25, 2007 response from Dave Wesley, USFWS, to the recovery team detailing a point-by-point description of how the USFWS followed direction from the Forest Service and BLM initially detailed in the "draft direction" document from January 16, 2007.
FS and BLM Draft Direction Ongoing Responses
January 25, 2007
1) Revise cost estimates and review inclusion of FWS into responsibility parties category.
* In cooperation with the FS/BLM we are currently deriving cost estimates for all "on-going" Recovery Plan actions and those "continuous" Recovery Plan actions without associated costs. Upon completion the updated Implementation Schedule will be incorporated into both options.
2) Fully develop Option 2 (emphasis added) (province level rule set) independent of Option 1. Clearly describe the goals and objectives of each rule so the agencies can determine, in consultation with the FWS, how best to achieve the goals and objectives of the RP while providing for other goals identified in land use plans.
* A fully-developed, stand-alone Option 2 Recovery Plan has been developed with a rule set for deriving habitat blocks that does not include a lower acreage limit. The IST has added purpose statements for each rule in the rule set.
* The rule set has been modified to include a better process for reaching an acceptable spatial extent by connecting most habitat blocks with three other habitat blocks.
* A new Recovery Action (now #35, both options) describing the spotted owl needs on those lands between MOCAs/Habitat Blocks has been created and incorporated into both options.
3) Provide additional emphasis on actions to reduce the loss of important NSO habitat by wildfires and to address the threat of Barred Owls. To the extent possible, identify priority areas in need of treatment and describe the goals of such treatments.
* In Recovery Action 6 a prioritization of where barred owl control efforts should be initiated has been added.
* In Recovery Action 25 a description of how to prioritize areas for fuel reduction based on spotted owl habitat values and fire risk has been added.
4) Rather than assume continued management of the federal lands according to the NWFP (emphasis added), assume the federal agencies will continue to manage federal lands per a land use plan which will be based, in part, on the RP. Also, assume actions to implement federal land use plans will be accompanied with either plan or project level consultations to ensure management actions align with recovery goals.
* Incorporated
5) As you prepare the RP, include applicable actions or strategies from the NWFP as specific goals, objectives or recovery actions when necessary to contribute to recovery, but de-link the action or strategy from the NWFP (emphasis added) and describe it in independent terms.
* Incorporated
6) Recognizing that size and spacing of habitat blocks will be a key element of any RP, a rule set that identifies either the minimum (emphasis added) or a reasonable range for each variable will provide both the most flexibility and most responsive management direction. When a range of values is provided, explain the basis for the values that define the range.
* Incorporated
