To whom it may concern:

The following text is a response to the DSEIS which I received for review. The handling of arthropods causes me great anxiety.

The greatest causes of my concern are what I take to be: (1) a basic lack of understanding about arthropod diversity; and (2) a misperception/misrepresentation of the concerns voiced by the panel of experts at the original planning meetings for the NW Forest Plan (in which I took part).

In the process of formulating the NW Forest Plan the advisory specialists did NOT conclude "that arthropods will have a high likelihood of being stable and well-distributed with gaps in their distribution" (as quoted in DSEIS p 86).  Rather, it was the reverse; MANY species (not listed) are of sensitive concern, in fact SO many that whole functional groups were of potential concern in the southern part of the region.  The lack of specific listings on the part of specialists reflected the fact that regional surveys (of literature AND the field) were necessary to appropriately list candidate taxa before they became "written in stone". It was ABSOLUTELY NOT the opinion that arthropods as a group could be relegated to a status of irrelevance. There was also a realization that a one-by-one species approach was both theoretically and practically not an appropriate method to proceed in an "ecosystem management" context.

1) To address the issues of basic arthropod diversity patterns: I expect that the following statements would receive general agreement amongst nearly any consulted scientific party with experience in entomology:

 1.     There is an extreme paucity of organized information on the distribution and abundance of arthropod species in the region covered by the Northwest Forest Plan.

 2.     The number of species encompassed within this group is enormous, perhaps as many as 10,000+.

 The vast majority of these species are relatively widespread (i.e. with distributions >10,000 mi2), occurring throughout the cismontane region from southern British Columbia to northern California. As such, the effect of individual timber sales is not likely to have major consequences on the majority of species. However, region-wide policies of the Northwest Forest Plan which include Late Seral Reserves and riparian buffers will affect ALL the species to some extent, generally benefiting those species which prefer late-seral forest conditions and riparian species which prefer closed canopies, and generally decreasing populations of species requiring early seral conditions. Since previous forest policies have tended to decrease populations of the former and increase populations of the latter, such a change in direction is probably for the "Greater Good".

 3.     However, neither widespread species which require specialized habitats (the spotted owls of the insect world), nor the species with very limited endemic distributions are directly addressed (whether common or rare) within the scope of the NW Forest Plan.  These species of concern clearly do exist; but as scientists: (1) we could not unequivocally testify that any specific individual species would become extinct over the multiple-District-sized areas (the requirement as defined during the Specialist Panel hearings); and (2) a single centralized list of all "sensitive" taxa could not be prepared by the panel members without considerable funding and outside research support. The intellectual resources on arthropod distribution are far more scattered, and the species quantities far higher than those of bryophytes or mollusks, rendering equivalent treatment impossible.

 4.     If we were to prioritize a region where (1) the threats were greatest; (2) the species richness was highest; (3) the endemicity likely to be greatest; (4) the presence of known exemplars highest -- this region would be the Klamath/Siskiyou. (This message was embodied to some degree in the ROD.)

Now, everyone realizes that the management agencies are in a no-win situation. They are asked to do all things for all people.  However, the principal reason that there are no citations of arthropod research (Survey & Manage) listed in the DSEIS, is that there has been little attention paid to them. The fact there has been little attention has been the result of a prioritization decision by the agencies. That's water under the bridge; now let's correct the situation.

A. Information that already exists must be collated. Sandquist has initiated a beginning in that direction; this approach will have limited results unless encompassed within a larger framework focusing on new information as well.

B. Field experiments examining the response of functional groups to management protocols have to be documented. The two studies by Niwa (examination of the effects of cool underburning in southern Oregon and the Blue Mts) are excellent starts in this direction), however, these studies need to be broadened in terms of the variables examined and the geographic sites examined (I expect there are some by Rappaport as well ADD). Neither one is specifically designed to quantify old-growth issues, the specific topic of major concern for the NW Forest Plan. The current studies closest to this aspect are one by Marcot, and one recently concluded by Madson, Moldenke, Tappeiner and Thompson. Fresh-water entomology issues (including the terrestrial riparian fauna) are also of critical concern, were glossed over in the original panel meetings, and need to be addressed in the long-term issue of riparian buffer management.

C. Regional field surveys need to be undertaken. Habitat associations of the arthropod fauna need to be established. Nothing is possible from a conservation perspective unless (1) ranges are documented; (2) microhabitat preferences are known; and (3) user-friendly identification procedures are available. These 3 requirements must be accomplished BEFORE protocols for management of sensitive species can be evaluated.  Such protocols are just as important whether the species in question are old-growth associates, aquatic associates or would be encompassed under the “agency special status species program”.

Make no mistake, there are many arthropods that should be considered  "sensitive". No one in his/her right mind wants to make a list that breaks the back of the Endangered Species Act. Most bugs will have to take care of themselves. However, if there are regions of special concern, microhabitats of special concern, groups of taxa of special concern, then we should know about them in order to prioritize limited resources. The bottom-line is still the need to assemble information which has practical utility.

Arthropods are treated logically in the DSEIS, relative to category assignment. Given the structure of the possible categorizations (imposed by the authors), there are no other listing alternatives possible. However, the problem remains that an insufficient level of attention was generated by the first categorization in the NWFP – "How will this be any different?" I define "insufficient level of attention" to mean that answers to the major defined questions put to the original advisory panels were not obtained, even though lots of advice on possible means to obtain the answers was forthcoming.  Listing as 2D in alternative 2 implies that they might ultimately simply vanish from the radar screen entirely  -- perhaps not intentionally or programmatically, but just as surely. Perhaps arthropods should have a high priority category entirely of their own, not one that automatically downgrades the importance of this issue. It is not logical to shoehorn all topics into the same arbitrary set of categories. Arthropods are obviously near and dear to Mother Nature; as a manager, one does not want to make Mother Nature mad. Arthropods do run the world; the common and ecologically more important ones may not appreciate having their rare cousins programmatically ignored.

          

1. What are the arthropod species characteristic of old-growth? What are the ecological functions they participate in? Are there any significant groups of species characteristic of old-growth that are unique to old-growth and not adequately encompassed within the system of LSR reserves?
2. Since there is an enormously diverse terrestrial arthropod fauna characteristic of riparian zones, what width(s) of riparian buffer is sufficient to adequately insure their continued success?
3. Since a large percentage of the 'sensitive' (if a listing were ever to be prepared) species of arthropods are associated with specialized microenvironments that are not necessarily evident for vertebrate conservation concerns and often not part of the timber base, how do we insure that these taxa are also provided with adequate protection?  --- these were the most basic questions put to the panel. I don't see that they have answered, nor do I detect any attempt to address them.

NWFP: Since many of the issues of concern revolve on what was actually said during the advisory panel meetings, let me revisit the major points to the best of my knowledge. The following represents my best recollection of the concerns the panel expressed at the original meetings in Portland. (Items marked with an * are relevant issues of more recent vintage.)

There are at least 3 major points of view concerning "arthropod biodiversity" in the Klamath/Siskiyous. (How to best please everybody with prioritized information gathering in a response-limited world.) Everything was considered from a point of view broader than just an old-growth perspective.

Current information on arthropods in PNW is/was, at one and the same time, both limiting (most data has not been collected directly to answer the following concerns) and too vast to easily deal with (data that do exist have to be interpreted by the entire academic community) because it is too disparate for any one limited team to encompass and the biodiversity of arthropods too great.

Therefore: (1) data that do exist must be mined in an appropriate manner,        

 (2) new data have to be collected (field inventory) that directly address specific concerns.

Limited resources require innovation to attain goals.

No study on biodiversity by management personnel will be believed by anyone (conflict of interest). Studies by academics or jointly by academics and management are almost as futile (*since everyone knows a scientist will say anything for continued research funding). The only type of information that can be believed has to be attained through a process intimately involving all 3 interested stakeholder points of view (academia, environmentalists, and managers -- panel members spoke from all 3 points of view).

1. The academic point of view.

Concern: Analysis of basic ecologic principals

1.1  Who is there?

A species list for region must be generated (and for entire PNW as well; but equally pertinent for rest of text). Such a list can never be complete (like there is no end to adaptive management); some groups will by practical necessity become working surrogates for "total diversity". Data available to the non-specialist is not usually in a form with an appropriate spatial resolution (i.e., state records in most catalogues). Though not a simple process, it is a sine qua non.

1.2  How to distinguish/identify any species from all the rest?

Current information is not in a useful consolidated form. Many new species wait to be discovered and named (probably hundreds!); most such species probably have very widespread distributions and in no way constitute a threat to the timber base). Discovering new species means both new collecting and more importantly centralizing user-friendly identification methods and building an outreach network with professional taxonomists. (You can't tell it's different, if you can't distinguish it; you can't manage for it, if you can't identify it). Predicted outcome: the vast majority of new species will be associated with non-timbered lands.

1.3  What is microhabitat association/requirement of each species?

This issue will usually require new survey implementation. Careful design of surveys will simultaneously gather both basic biological requirements on a species level as well as be able to answer functional guild responses to management protocols. Habitats most critical to assess are: (1) the most unique (botanically and geologically), and (2) the most isolated/insular. This generally means high-altitude "islands"; low-altitude riparian corridors; serpentine, marble/limestone outcrops, etc. Predicted outcome: most "sensitive" species live either in already established wilderness set-asides, areas where soil chemistry limits tree growth, or oak savannas largely in private in-holdings.

1.4  Who is rare/sensitive?

There is a large volume of published information available on specific species, but this represents only a small percentage of likely 'sensitive' taxa.

Predicted outcome: The vast majority of taxa are either widespread geographically and hence "protected" or, if localized within the K/S, are already in set-asides or non-timber producing sites. Even if true, it must be unequivocally documented that such is, in fact, the case.

2. The environmental/conservation point of view.

Concern: Preservation of endangered taxa

2.1  How do we keep Man (management) from mucking everything up?

Not a question subject to scientific analysis.

2.2  Can we use arthropods as examples to bolster any set-aside arguments already in place?

The co-occurrence of sensitive arthropods in localities with other threatened taxa would help set-aside categorization and aid in prioritization. Though there may be no correlation whatever, some field monitoring must focus on known sensitive plant/animal hotspots. Predicted outcome: endemic arthropods will largely correlate with sensitive plants on a community scale of resolution-- poor soils and delimited geological sites (hi- and lo-altitude) will support ecosystems with both endemic arthropods and endemic plants. Actual occurrence of individual “endangered” species of plants and individual "endangered" species of arthropods will NOT be correlated (though inventory design may artificially make it appear to).

2.3  Are there ways to prioritize sensitive regions/plant associations/etc?

     good question – many ways in use currently.  But since all the current techniques deal only with a small fraction of total biodiversity, adding arthropod diversity (or any part of it) should assist the ultimate goal of protecting function. (Bugs do rule the world, after all.)

2.4  Who is rare/sensitive? How can one mitigate total biodiversity (or threatened species) in a practical fashion?

     It is impossible to conserve or mitigate, unless you know: (1) "Who is there, where?" and (2) "Who needs attention?" Mitigating for one species, almost by definition, does mean negatively impacting other co-occurring sensitive taxa that aren't recognized as such.

3. The enlightened land manager point of view.

     Concern: Preservation of ecological function and community integrity

3.1  How well does the present system of set-asides (e.g., wilderness, late seral reserves LSR, other acronyms) preserve biodiversity?

     Unless we know basic information on species listing, how to identify, and who lives where -- there is NO way to analyze how efficient current set-asides are for the vast majority of biodiversity and functional controls within ecosystems. The current system is ripe with touchy-feely assessments like: "I think this is working; seems like a good idea to me". The conventional knee-jerk way to examine this issue is to examine the relative proportions of different "plant community types" within preserves (*Vance-Borland thesis on Klamath/Siskiyou region). (There are of course, different levels of protection within differing types of set-asides -- even wilderness area endangered species might well need mitigation ultimately especially with issues of fire management).

Most high-altitude community types ARE represented in wilderness, a large fraction of rare/endemic/sensitive species of arthropods will occur in these sites. Even if sensitive high-altitude arthropod species are not in wilderness areas, if a critical number of them co-occur it is likely that the sites are characterized by no merchantable timber anyway.

Low-altitude oak savannas will also be characterized by unique taxa; this area will of course be of greatest concern, since anthropogenic influences have already reduced it drastically, it is largely in non government holdings, and (even in the best of all worlds) it is most likely to be affected adversely by introduced species, etc.

Palaeohistorically an important aspect of the K/S region is the inclusion of many isolated islands of vegetation without a tree canopy (e.g., chaparral, balds, poisonous soils, etc). The vast majority of the known sensitive plant diversity is associated within these sites; these sites are not part of the timber base.

However, it is insufficient to say that sensitive arthropods are likely to inhabit these regions. Establishing the identity of these taxa is prerequisite to determining how they should be managed. (There is no such thing as 'no-management'.)  Presumably, maintaining the plant community health is a viable first strategy, but one cannot simply assume that this is so.

3.2 Are there any species excluded from present management set-asides that should be considered?

           This is THE crucial question, of course. The quick answer is clearly: "Yes, a majority of them probably are." Most such "sensitive" species are probably restricted to natural sites without a forest canopy. As long as certain exemplar meadows, balds, et cetera can be put into a category that provides long-term protection, the first step will be achieved and without any great threat to the timber base. (NOT -- "Just ignore them, and then the issue may go away.") However, there still exists the question of what sensitive taxa might be restricted to forested habitats with commercial potential; hence the requirement to inventory in a systematic fashion.

3.3 Are there old-growth associates? Who are they? Is there an island biogeography threshold effect of patch size?

           Old-growth-- the real moving force behind the NW Forest Plan. The only way to find out if there are old-growth endemics is to look for them. The crucial corollary is how big does the old-growth patch have to be to support the species. *The Marcot study is the template to use here; critical management issues can be addressed even though a pre-existing 'old-growth' species list does not exist. This research quantifies which species prefer interior forest, which prefer clearcut regeneration, and which are edge-dwellers (results are keyed to the size of the relict forest stand diameter). This type of study plan needs to be supplemented by side-by-side comparisons of the fauna of old-growth and the fauna of mature merchantable forests. *Schowalter's studies of the canopy fauna associated with adjacent stands of old-growth and regrowth Douglas-fir have documented differences at the species-level, but no functional guild difference.

Predicted outcome: lots of taxa (thousands) prefer canopy-covered sites, but of these true forest dwellers only a tiny number at most are restricted to old-growth. *In my judgement, time has shown that there are few species of plants and vertebrates restricted to old-growth. The same is likely to be true of arthropods. The existence of two species of birds that nest only in old-growth related habitat is unlikely to be the pattern for arthropods. This is just a personal judgment; other entomologists do not share it – it needs to be tested. Species 'characteristic' of old-growth, but not absolutely restricted to it, need to be identified and highlighted as a group of special concern as well. Of the species restricted, or virtually restricted, to old-growth, their microhabitat requirements/associations must be determined (likely to be cortical moss/lichen canopy-dwellers, class 5 CWD-dwellers, and deep soil/high organic matter associates).

3.4 Do riparian zone buffers adequately protect riparian/aquatic species? Do different order streams require different protective measures?

A large percentage of the land base is/will be tied up in riparian buffers. How wide do buffers have to be to protect aquatic and terrestrial-riparian invertebrates (>1,000 species)? How do requirements of these individual species (and patterns of total diversity) differ between headwater/first-order, 3^rd-order and 5^th-order/rivers? *More studies like Furnish/Progar/Moldenke need to be initiated that have documented for central western Oregon that: (1) temporary headwater streams produce higher densities of invertebrates (i.e., migratory bird food) than continuous-flow primary streams; (2) continuous-flow primary streams have higher levels of diversity/species richness than temporary ones; (3) the unique species in the temporary streams are not true aquatic species, but are related to terrestrial-riparian species – whether they are unique or widespread in terrestrial habitats is unknown.

           The bottom line, drawing from the mollusk example, is that the listing of all the 'sensitive' taxa must be followed with ecological studies to see if the listed taxa actually require mitigation, and if so, what. Lots of non-mobile taxa show some form of regional differentiation ("=subspeciation"); just because some populations are 'isolated' doesn't mean that 'reasonably appropriate' measures for their protection aren't already in place. Examples of localized endemic species of PNW arthropod distributions were provided (i.e., Caseyid millipedes, Pleocoma beetles, Amaurobiid spiders).

3.5 Are there forest-floor dwellers (non-old growth restricted species) that are not protected by LSR and riparian buffer set-asides?

           To what extent do extent do riparian buffers actually contain/preserve the upland forest floor taxa? The Furnish/Moldenke studies have shown that terrestrial-riparian zones are twice as species rich as upland forest-floor, and that nearly 100% of the true forest-floor species occur within the terrestrial-riparian zone (>75% of them are actually more abundant within the terrestrial-riparian zone). Therefore does protection of the riparian buffers actually protect the entire the forest floor fauna? However, studies by Chan/Olson at the same sites have shown that this diversity of terrestrial-riparian fauna is positively related to increased frequency and amplitude of natural disturbance; future management of riparian zones needs to address this aspect of habitat. Literature reveals that in Europe and eastern N Am the terrestrial riparian fauna varies by stream-order, canopy cover and disturbance regime -- how does the K/S riparian fauna sort out? Get data!

3.6 Precisely how do the most common management practices affect invertebrate biodiversity?

           What about quantification of typical forest management protocols on soil fauna? A priori we know they all have strong effects, either directly on species (i.e., by crushing them) or indirectly through initiating successional changes (i.e., there are open-canopy taxa and closed-canopy taxa). *Studies by Niwa & Rappaport are an excellent start to understanding the role of controlled underburning on soil macro- and micro-fauna. *Niwa's studies have revealed either no detectable effect area-wide of either spring- or fall-underburning or small quantitative effects which rapidly return to pre-burn conditions in contrast to Miller/Moldenke's previous studies which showed legacies lasting 35+ years from "hot" site-prep burns. What are some other management protocols? -- prioritize and document.

3.7 Functionally, how is biodiversity related to tree growth in these lands of "limiting" soils?

           Silviculture and soil science common knowledge acknowledges that much of this region is characterized by soils low in organic matter, nitrogen and (often) calcium, but high in heavy metals. Rapid cycling and retention of C and N is of critical importance in most of these environments. The long dry season and associated fire and erosion are pivotal. Functionally, how does soil foodweb biodiversity act to buffer (if it does!?) the cycling of limiting nutrients in the Klamath/Siskiyou region? If biodiversity-linked controls are critical anywhere, they must be critical here.

Sincerely yours,

RESPONSE TO THE AMENDMENT OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT

I expect that the following statements would receive general agreement amongst nearly any consulted scientific party with experience in entomology:

1.      There is an extreme paucity of information on the distribution and abundance of arthropod species in the region covered by the Northwest Forest Plan.

2.      The number of species encompassed within this group is enormous, perhaps as many as 10,000+. The majority of these species are relatively widespread, occurring throughout the cismontane region from southern British Columbia to northern California. As such, the effect of individual timber sales is not likely to have major consequences on the majority of species. However, region-wide policies of the Northwest Forest plan which include Late Seral Reserves and riparian buffers will affect all the species to some extent, generally benefiting those species which prefer late-seral forest conditions and riparian species which prefer closed canopies, and generally decreasing populations of species requiring early seral conditions. Since previous forest policies have tended to decrease populations of the former and increase populations of the latter, such a change in direction is probably for the “Greater Good”.

3.      However, species which require specialized habitats are not directly addressed (whether common or rare). Most importantly, no direction is provided for the numerous taxa within the region that are just as rare and uncommon as are the listed taxa in better-studied groups. These species do exist; but as scientists: (1) we could not unequivocally testify that they would become extinct over the multiple-county sized areas defined during the Specialist Panel hearings; and (2) a single centralized list of all "sensitive" taxa could not be prepared by a single consultant without considerable funding and outside research support. The intellectual resources are far more scattered and the species quantities far higher than those of bryophytes or mollusks, rendering equivalent treatment impossible.

4.      If we were to prioritize a region where (1) the threats were greatest; (2) the species richness was highest; (3) the endemicity likely to be greatest; (4) the presence of known exemplars highest -- this region would be the Klamath/Siskiyou. (This message was embodied to some degree in the ROD.)

5.      In the process of formulating the NW Forest Plan the advisory specialists did NOT conclude "that arthropods will have a high likelihood of being stable and well-distributed with gaps in their distribution" (as quoted in DSEIS p. 86).  Rather, it was the reverse; MANY species (not listed) are of sensitive concern, in fact SO many that whole functional groups were of potential concern in the southern part of the region.  The lack of specific listings on the part of specialists required regional surveys (of literature AND the field) to appropriately list candidate taxa before they became "written in stone", it was ABSOLUTELY NOT the opinion that they could be relegated to a status of irrelevance.

Now, everyone realizes that the management agencies are in a no-win situation. They are asked to do all things for all people.  However, the principal reason that there are no citations of invertebrate research (survey & manage) listed in the DSEIS, is that there has been little attention paid to them. The fact there has been no attention, has been the result of a prioritization decision by the agencies. That's water under the bridge; now let's correct the situation.

A. Information that already exists must be collated. Sandquist has initiated a beginning in that direction; this approach will have limited results unless encompassed within a larger framework focusing on new information as well.

B. Field experiments examining the response of functional groups to management protocols has to be documented. The two studies by Niwa (I expect there are some by Rappaport as well) are excellent starts in this direction (examination of the effects of cool underburning in southern Oregon and the Blue Mts); however, these studies need to be broadened in terms of the variables examined and the geographic sites examined. Neither one is specifically designed to quantify old-growth issues. The current study closest to this aspect is one by Marcot.

C. Regional field surveys need to be undertaken. Habitat associations of the arthropod fauna need to be established. Nothing is possible from a conservation perspective unless (1) ranges are documented; (2) microhabitat preferences are known; and (3) user-friendly identification procedures are available. These 3 requirements must be accomplished BEFORE protocols for management of sensitive species can be designed.  Such protocols are just as important whether the species in question are old-growth associates, aquatic associates or would be encompassed under the “agency special status species program”.

Make no mistake; there are many arthropods that should be considered  "sensitive". No one in his/her right mind wants to make a list that breaks the back of the Endangered Species Act. Most bugs will have to take care of themselves. However, if there are regions of special concern, microhabitats of special concern groups of taxa of special concern, then we should know about them in order to prioritize limited resources. The bottom-line is still the practical need to get more information.

Arthropods are treated logically in the DSEIS, relative to category assignment, i.e. "1F", or "2D" or "3C". Given the structure of the possible categorizations (imposed by the authors), there are no other listing alternatives possible. However, the problem remains that an insufficient level of attention was generated by the first categorization in the NWFP --"How will this be any different?"  Listing as 2D in alternative 2 implies that they will ultimately simply vanish from the radar screen entirely  -- perhaps not intentionally or programmatically, but certainly just as surely. Perhaps arthropods should have a high priority category of their own, not one that automatically downgrades the importance of this issue; it is not logical to shoehorn all topics into the same arbitrary set of categories. Arthropods are obviously near and dear to Mother Nature; as a manager, one does not want to make Mother Nature mad. Arthropods do run the world; the common and ecologically more important ones may not appreciate having their rare cousins programmatically ignored.