Table Of ContentDecember
10,
2015
Forest
Plan
Revision
Team
Santa
Fe
National
Forest
11
Forest
Lane
Santa
Fe,
New
Mexico
Submitted
via
email
to:
[email protected]
Re:
COMMENTS
REGARDING
OCTOBER
2015
FINDINGS
FROM
THE
DRAFT
ASSESSMENT:
TWELVE
FOCUS
AREAS
AND
PRELIMINARY
NEED
FOR
CHANGE
STATEMENTS
Dear
Forest
Plan
Revision
Team:
We
appreciate
the
opportunity
to
comment
on
the
Santa
Fe
National
Forest’s
(“Santa
Fe
NF’s”)
Plan
Revision.
Revision
of
the
Santa
Fe
Forest
Plan
provides
an
invaluable
opportunity
to
foster
landscape-‐scale
ecological
and
community
resiliency
across
northern
New
Mexico.
We
offer
the
following
constructive
comments
in
this
context
and
with
the
intent
of
ensuring
the
strongest
possible
Forest
Plan
revision
and,
specifically,
the
strongest
possible
Need
for
Change
Statements.
Our
comments
are
structured
as
follows:
§ Section
I:
Recommends
that
the
Santa
Fe
NF
foster
landscape-‐scale
ecological
and
community
resiliency
as
a
central
organizing
principle
for
the
Forest
Plan
revision,
providing
four
core
recommendations
in
furtherance
of
that
principle.
§ Section
II:
Details
and
substantiates
our
recommendation
that
the
Santa
Fe
NF
consider
and
create
“Wetland
Gem”
designated
areas.
§ Section
III:
Recommends
that
the
Santa
Fe
NF
account
for
the
full
value
of
ecological
and
community
services
provided
by
the
forest
in
its
socioeconomic
analysis
through
use
of
a
Total
Economic
Valuation
framework,
inclusive
of
the
use
of
the
Social
Cost
of
Carbon.
§ Section
IV:
Recommends
that
the
Santa
Fe
effectively
protect
Canada
lynx,
including
through
action
to
protect
and
restore
the
necessary
physical
and
biological
features
necessary
to
sustain
a
resident
lynx
population
settling
the
area
from
Colorado.
In
each
section,
we
have
provided
specific
recommended
changes
to
the
October
2015
Draft
Needs
for
Change
Statements
appropriate
to
this
stage
of
the
planning
process.
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I.
THE
SANTA
FE
FOREST
PLAN
SHOULD
FOSTER
LANDSCAPE-‐SCALE
ECOLOGICAL
AND
COMMUNITY
RESILIENCY
A.
Resiliency
Overview
We
recommend
that
the
Santa
Fe
Forest
Plan
foster
landscape-‐scale
ecological
and
community
resiliency
and
use
resiliency
as
a
central
organizing
principle.
This
is
particularly
critical
given
that
the
existing
Santa
Fe
Forest
Plan
was
originally
crafted
in
1987
and
is
showing
its
age.
While
the
Preliminary
Need
for
Change
Statements
does
emphasize
resiliency,
our
comments
are
designed
to
strengthen
and
further
this
direction
and
ensure
that
resiliency
permeates
all
plan
components
and,
specifically,
the
Santa
Fe’s
underlying
Needs
for
Change
Statements.
Resiliency
provides
a
positive,
constructive
frame
to
optimize
and
balance
interconnected
social,
economic,
and
ecological
systems
and
to
thereby
satisfy
the
agency’s
duty
to
“provide
for
social,
economic,
and
ecological
sustainability”
in
light
of
the
challenges
and
opportunities
presented
by
the
reasonably
foreseeable
impacts
of
climate
change
to
the
Santa
Fe
and
the
broader
landscape
within
which
the
Santa
Fe
NF
rests.
36
C.F.R.
§
219.8.
Resiliency,
for
us,
consists
of
two
parts.
First,
resiliency
is
the
capacity
of
an
ecological
or
community
system
to
maintain
its
function
in
the
face
of
stress.
A
system
with
high
resiliency
withstands
and
bounces
back
from
stress
better
than
a
system
with
low
resiliency.
Second,
resiliency
is
the
capacity
of
an
ecological
or
community
system
to
adapt
to
changing
circumstances
and
conditions.
Accordingly,
a
system
with
high
adaptive
capacity
adjusts
to
changing
circumstances
and
conditions
better
than
a
system
with
low
adaptive
capacity.
These
themes—and
acknowledging
the
interconnected
nature
of
ecological
and
community
systems—are
echoed
in
Aldo
Leopold’s
1949
classic,
A
Sand
County
Almanac,
where
Leopold
eloquently
states,
“[t]hat
land
is
a
community
is
the
basic
concept
of
ecology,
but
that
land
is
to
be
loved
and
respected
is
an
extension
of
ethics.
That
land
yields
a
cultural
harvest
is
a
fact
long
known,
but
latterly
often
forgotten.”
Resiliency
can
help
account
for
the
interconnected
nature
of
natural
and
human-‐built
infrastructure
and
provide
a
basis
for
effectively
identifying
management
challenges
and
opportunities
in
world
suffering
from
climate
change.
For
example,
water
falls
as
rain
in
the
Sangre
de
Cristo
Mountains
to
nurture
forests
and
wet
meadows
and
then
collects
into
rivers
and
streams
that
provide
habitat
for
Rio
Grande
cutthroat
trout
and—with
acequias—clean
water
for
New
Mexican
farms,
ranches,
and
communities.
Yet,
with
climate
change,
the
quality
and
quantity
of
water
resources,
because
of
drought
and
other
stressors,
will
change
for
the
worse
over
in
the
coming
decades.
The
Santa
Fe
Forest
Plan
can
help
optimize
and
balance
how
resources,
such
as
water,
are
used
across
this
interconnected
landscape-‐scale
mosaic
of
natural
and
human-‐built
infrastructure
given
the
impacts
of
climate
change.
In
so
doing,
the
Santa
Fe
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Forest
Plan
can
create
opportunities
to
protect
and
restore
ecological
and
community
resiliency.
Climate
change,
as
we
note
above,
elevates
the
importance
of
resiliency
and
understanding
the
interconnected
nature
of
ecological
and
community
systems.
Indeed,
this
is
at
the
root
of
the
Forest
Service’s
2012
Planning
Rules,
which
direct
the
Forest
Service
to
“provide
for
social,
economic,
and
ecological
sustainability.”
36
C.F.R.
§
219.8.
Climate
change
exacerbates
impacts
caused
by
existing
ecological
and
community
stressors,
such
as
poorly
managed
road
systems
and
livestock
grazing.
Climate
change
is
also
a
persistent,
intensifying,
and
non-‐linear
stressor,
changing
precipitation
and
snowmelt
patterns.
Actions
adequate
to
guard
against
a
particular
impact
in
a
world
that
has
warmed
by
2°C
may
therefore
be
completely
inadequate
in
a
world
that
has
warmed
by
3°C.
Thus,
in
the
absence
of
robust
action
by
the
Santa
Fe
NF
to
build
resiliency,
climate
change
may
unravel
and
catastrophically
degrade
existing
ecological
and
community
systems
in
the
broader
landscape.
We
emphasize
this
reality
because
the
Intended
Nationally
Determined
Contributions
(“INDCs”)
provided
in
advance
of
the
upcoming
U.N.
Framework
Convention
on
Climate
Change
Conference
of
the
Parties
in
Paris
in
December
2015
are
presently
insufficient
to
constrain
warming
below
the
internationally
agreed
upon
target
to
constrain
warming
to
2°C
above
pre-‐
industrial
levels.1
The
2°C
target
is
generally
viewed
as
a
threshold—if
imperfect—to
ameliorate
the
risk
of
catastrophic
climate
impacts.
Notably,
there
are
intense
efforts
underway
in
Paris,
this
very
moment,
to
lower
the
threshold
to
1.5°C
to
improve
climate
security
and
to
protect
the
most
vulnerable—efforts
we
support.2
While
projections
vary,
the
INDCs,
even
if
implemented
successfully
(a
very
big
if),
would
still
put
the
world
for
warming
greater
than
2°C.3
This
should
provide
a
sobering
reality
check
to
us
all
and
underscore
the
importance
of
a
meaningful,
impactful
Forest
Plan
revision.
B.
Recommended
Resiliency
Actions
We
recommend
that
the
Santa
Fe
NF
take
the
following
four
core
actions
through
its
Forest
Plan
revision
and
reflect
these
actions
in
its
Needs
for
Change
Statements.
First,
the
Santa
Fe
should
forthrightly
acknowledge
and
assess
the
predicted
and
reasonably
foreseeable
impacts
of
climate
change
and
consider
alternatives
to
ameliorate
those
impacts
through
the
National
Environmental
Policy
Act
(“NEPA”)
review
for
the
Plan
Revision.
These
alternatives
should
assess
different
means
of
fostering
resiliency
to
satisfy
the
2012
Planning
Rule’s
directive
to
“provide
for
social,
economic,
and
ecological
sustainability”
36
C.F.R.
§
219.8.
1
See
http://www.wri.org/indc-‐definition
(explaining
INDCs).
2
http://www.thenation.com/article/with-‐1-‐5-‐degrees-‐celsius-‐target-‐climate-‐justice-‐movement-‐poised-‐to-‐score-‐
surprise-‐win/
3
http://climateactiontracker.org/global.html
(last
visited
Dec.
8,
2015).
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Each
alternative
should
detail
the
specific
plan
components,
i.e.,
desired
conditions,
objectives,
standards,
guidelines,
and
determinations
regarding
the
suitability
of
lands
for
various
multiple
uses
and
how
those
plan
components
will
or
will
not
foster
resiliency
to
provide
for
social,
economic,
and
ecological
sustainability.
This
is
particularly
critical
in
the
context
of
wildfire
management,
where
ecological
and
community
resiliency
should
drive
wildlife
risk
management.
Put
differently
wildlife
risk
management
should
maximize
resiliency
benefits.
Without
considering
broad-‐scale
resiliency
benefits,
we
are
concerned
that
too
much
emphasis
will
be
placed
on
logging
to
the
exclusion
of
other
activities
and
the
broader
need
to
manage
for
landscape-‐scale
forest
resiliency
that
holistically
addresses
interconnected
ecological
and
community
systems.
Climate
change
must
be
directly
and
consciously
infused
into
all
plan
components,
whether
desired
conditions,
objectives,
standards,
guidelines,
or
determinations
regarding
the
suitability
of
lands
for
various
multiple
uses.
This
is
particularly
important
in
terms
of
plan
components
that
ensure
proactive
(rather
than
reactive
adaptive)
planning,
management,
and
decision-‐
making
to
account
for
and
ameliorate
climate
change
impacts
before
those
impacts
occur
or
decisions
are
made.
The
Forest
Plan
revision
should
thus
ensure
that
climate
change
is
directly
and
consciously
incorporated
into
the
overarching
Forest
Plan
revision
and
the
prioritization
and
design
of
project-‐level
action
that
implements
the
Forest
Plan
revision.
See
36
C.F.R.
§
219.15
(mandating
“consistency”
between
Forest
Plan
and
project-‐level
action).
Proactive
action
at
the
Forest
Plan
level
sets
the
stage
for
effective,
meaningful
project-‐level
action.
Isolating
climate
change
action
within
reactive
adaptive
management
schemes
would,
conversely,
undermine
the
ability
of
the
Santa
Fe
NF
to
effectively
prioritize
and
design
project-‐
level
action
and,
moreover,
reduce
the
efficacy
of
any
agency
action
the
Santa
Fe
NF
decides
to
take.
This,
in
turn,
would
also
raise
the
risk
that
the
agency
action
the
Santa
Fe
NF
decides
to
take
is
arbitrary
and
capricious
for
omitting
a
factor—i.e.,
climate
change—essential
to
reasoned
and
informed
agency
action.
5
U.S.C.
§
706(2)(A).
Climate
change
is,
fundamentally,
a
factor
for
consideration
in
all
plan
elements,
not
just
adaptive
management.
Second,
the
Santa
Fe
NF
should
place
special
emphasis
on
the
protection
and
restoration
of
water
resource
resiliency.
Rivers,
streams,
wetlands
and
other
waters
originating
on
the
Santa
Fe
NF
function
as
core,
essential
ecological
elements
of
the
broader
Rio
Grande
watershed.
Emphasizing
protection
and
restoration
of
these
water
resources
can
improve
resiliency
and
thereby
have
significant,
positive
impacts
on
social,
economic,
and
ecological
sustainability
across
the
watershed
and
broader
landscape.
To
provide
this
emphasis,
the
Santa
Fe
NF
should:
§ Protect
certain
“Wetland
Gems”
as
“designated
areas.”
See
36
C.F.R.
§
219.19
and
detailed
in
Section
III,
below.
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§ Take
broad-‐scale
action
to
identify
and
mitigate
the
causes
contributing
to
non-‐attainment
of
Clean
Water
Act
surface
water
quality
standards.
Given
that
the
Santa
Fe’s
October
2015
Need
for
Change
Statements
notes
that
approximately
24%
of
the
perennial
stream
miles
on
the
forest
are
impaired
and
that
87%
of
the
forest’s
sub-‐watersheds
are
either
impaired
or
functioning
at
risk,
and
given
the
intensified
stress
predicted
and
reasonably
foreseeable
from
climate
change,
action
to
protect
and
restore
water
quality
is
an
imperative.
See
33
U.S.C.
§
1323(a)
(requiring
that
federal
agencies
comply
with
the
Clean
Water
Act,
which
includes
compliance
with
water
quality
standards).
The
Santa
Fe
should
specifically
identify
these
stream
segments
and
sub-‐watersheds
and
identify
with
precision
how
and
by
when
the
Forest
Plan
will
achieve
compliance
with
water
quality
standards
and
ensure
sub-‐
watershed
functionality
given
predicted
and
reasonably
foreseeable
changes
to
reference
conditions
caused,
e.g.,
by
climate
change.
§ Evaluate
and
significantly
improve
the
efficacy
of
plan
components—in
particular
standards,
guidelines,
adaptive
management
systems,
and
best
management
practices—intended
to
mitigate
pollution
caused
by
system
and
non-‐system
roads
and
commercial
activities
such
as
livestock
grazing.
This
is
particularly
important
given
the
current
level
of
impairment
in
the
context
of
the
added
stress
caused
by
climate
change.
Third,
the
Santa
Fe
NF
should
better
conserve
wildlife
by
protecting
and
restoring
intact
wildlife
habitat,
improving
the
connectivity
and
permeability
of
wildlife
habitat
between
wildlife
habitat
core
areas,
and
maximizing
the
widest
possible
altitudinal
range
within
protected
areas.
Each
of
these
three
elements
works
together
to
maximize
the
resiliency
of
the
Santa
Fe
NF’s
diverse
wildlife
species
in
the
face
of
a
warming
climate,
providing,
as
the
Santa
Fe
NF
is
required
to
do,
an
“ecosystem
and
species-‐specific
approach”
to
protect
wildlife
(and
plants).
36
C.F.R.
§
219.9.
This
entails
consideration
to
new,
administrative-‐level
designated
areas
that
protect
wildlife
populations
and
the
connectivity
and
permeability
of
their
habitats
across
the
landscape
and
in
core,
resilient
refugia.
36
C.F.R.
§
219.19.
In
this
context,
we
note
that
protection
and
restoration
of
Wetland
Gems
as
Special
Designated
Areas
in
the
Forest
Plan
operates
to
also
protect
and
restore
intact
wildlife
habitat,
the
connectivity
and
permeability
of
that
habitat,
and,
potentially,
altitudinal
range.
Fourth,
the
Forest
Plan
should
optimize
the
Santa
Fe’s
carbon
sequestration
capacity,
ensuring,
as
much
as
possible,
that
the
forest
functions
as
a
carbon
sink.
Unexploited
federal
lands
can
and
should
function
as
a
carbon
sink
to
help
reduce
net
greenhouse
gas
emissions
and
thereby
mitigate
climate
change.
We
recommend
that
the
Santa
Fe
NF
achieve
this
objective
by
prohibiting
activities,
like
fossil
fuels
exploitation,
that
release
greenhouse
gas
emissions.
Specifically,
we
recommend
that
the
Santa
Fe
NF:
§ Impose
a
moratorium
on
any
future
fossil
fuel
leasing
and
development
pending
completion
of
the
Forest
Plan
revision;
§ Forbid
all
future
fossil
fuel
leasing
and
development
through
the
Forest
Plan
revision
by
designating
all
un-‐leased
lands
as
unsuitable
for
fossil
fuels
leasing
and
development;
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§ Prevent
the
extension
of
any
non-‐producing
leases
existing
on
the
Santa
Fe
NF.
§ Subject
any
valid
existing
fossil
fuel
leases
or
development
projects
to
stringent
management
protections
to
minimize
the
release
of
climate
pollution
to
the
atmosphere
and
the
impact
of
any
development
on
ecological
and
community
resiliency.
§ Adopt
plan
elements
to
protect
ecological
resources
with
high
carbon
sequestration
capacity;
§ Incorporate
carbon
sequestration
capacity
as
a
criterion
in
the
design
and
prioritization
of
project-‐level
action
with
the
express
intent
to
protect
and
optimize
the
forest’s
carbon
sequestration
capacity.
To
help
inform
the
Santa
Fe’s
actions
to
mandate
and
optimize
the
Santa
Fe’s
carbon
sequestration
capacity,
we
refer
you
to
and
ask
you
to
assess
the
recommendations
crafted
by
the
Federal
Forest
Carbon
Coalition.4
We
also
emphasize
here
our
deep
concern
regarding
the
potential
for
oil
and
gas
leasing
and
development.
We
were
particularly
disturbed
by
the
BLM
Farmington
Field
Office’s
decision
to
reject
an
administrative
protest
to
the
sale
of
20,000-‐acres
of
new
federal
oil
and
gas
leases
on
the
western
edge
of
the
Santa
Fe
National
Forest
in
the
Cuba
Ranger
District.
Sadly,
this
is
not
an
isolated
problem.
Across
the
entire
San
Juan
Basin,
nearly
90%
of
all
federal
minerals
have
been
leased
for
oil
and
gas
drilling
and
fracking
by
BLM’s
Farmington
Field
Office
and
horizontal,
multi-‐stage
drilling
and
fracking
is
ongoing,
despite
concessions
by
BLM
that
it
has
never
properly
planned
for
this
sort
of
development
in
the
southern
reaches
of
the
basin,
in
particular
around
Chaco
Canyon,
and
must
therefore
complete
a
Resource
Management
Plan
Amendment.
In
our
candid
view,
this
raises
a
legitimate
question
whether
the
BLM
Farmington
Field
Office
has
the
to
balance
multiple
uses,
to
promote
sustainability,
and
to
respect
local
communities.
Indeed,
and
we
do
not
say
this
lightly,
the
BLM
Farmington
Field
Office
appears
to
have
been
effectively
co-‐opted
by
oil
and
gas
industry
interests.
To
prevent
the
resultant
ills
that
this
has
created
to
the
San
Juan
Basin
from
threatening
the
resiliency
of
the
Santa
Fe
National
Forest,
Forest
Plan-‐level
action
is
necessary.
Finally,
we
note
that
while
the
Santa
Fe’s
carbon
sequestration
capacity
may
appear
small
relative
to
the
entire
world,
individual
actions,
cumulatively,
can
prove
quite
positive
and,
indeed,
are
essential.
As
the
Supreme
Court
teaches:
Agencies,
like
legislatures,
do
not
generally
resolve
massive
problems
in
one
fell
swoop,
see
Williamson
v.
Lee
Optical
of
Okla.,
Inc.,
348
U.S.
483,
489,
75
S.Ct.
461,
99
L.Ed.
563,
but
instead
whittle
away
over
time,
refining
their
approach
as
circumstances
change
and
they
develop
a
more
nuanced
understanding
of
how
best
to
proceed,
cf.
SEC
v.
Chenery
Corp.,
332
U.S.
194,
202–203,
67
S.Ct.
1575,
91
L.Ed.
1995.
4
See
http://www.forestcc.org/recs
(link
to
PDF
of
recommendations
on
this
page).
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Mass.
v.
EPA,
549
U.S.
497,
499
(2007).
In
Section
I.C,
immediately
below,
we
summarize
key
elements
of
the
policy
and
legal
framework
underpinning
these
four
recommendations.
C.
Resiliency
Policy
and
Legal
Framework
Resiliency—and
carbon
sequestration—is
expressly
called
for
by
Executive
Order
13,653,
“Preparing
the
United
States
for
the
Impacts
of
Climate
Change.”
Section
1
of
the
order
explains
that:
The
impacts
of
climate
change—including
an
increase
in
prolonged
periods
of
excessively
high
temperatures,
more
heavy
downpours,
an
increase
in
wildfires,
more
severe
droughts,
permafrost
thawing,
ocean
acidification,
and
sea-‐level
rise—are
already
affecting
communities,
natural
resources,
ecosystems,
economies,
and
public
health
across
the
Nation.
These
impacts
are
often
most
significant
for
communities
that
already
face
economic
or
health-‐related
challenges,
and
for
species
and
habitats
that
are
already
facing
other
pressures.
Managing
these
risks
requires
deliberate
preparation,
close
cooperation,
and
coordinated
planning
by
the
Federal
Government,
as
well
as
by
stakeholders,
to
facilitate
Federal,
State,
local,
tribal,
private-‐sector,
and
nonprofit-‐sector
efforts
to
improve
climate
preparedness
and
resilience;
help
safeguard
our
economy,
infrastructure,
environment,
and
natural
resources;
and
provide
for
the
continuity
of
executive
department
and
agency
(agency)
operations,
services,
and
programs.
Section
3
of
the
Order
reinforces
this
policy
direction,
mandating
that
agencies
take
action
to
make
“watersheds,
natural
resources,
and
ecosystems,
and
the
communities
and
economies
that
depend
on
them,
more
resilient
in
the
face
of
a
changing
climate.”
Section
3
further
states
that,
“recognizing
the
many
benefits
the
Nation’s
natural
infrastructure
provides,
agencies
shall,
where
possible,
focus
on
program
and
policy
adjustments
that
promote
the
dual
goals
of
greater
climate
resilience
and
carbon
sequestration.”
Executive
Order
13,653
should
be
understood
in
the
context
of
two
new
White
House
memoranda,
which
the
Santa
Fe
NF
should
review
to
inform
its
Forest
Plan
revision.
In
October
2015,
the
White
House
directed
federal
agencies
to
account
for
ecosystem
services
in
federal
planning
and
decision-‐making.5
In
November
2015,
the
White
House
strengthened
federal
ecological
resource
protection
and
restoration
efforts.6
These
memoranda
complement
the
5
https://www.whitehouse.gov/blog/2015/10/07/incorporating-‐natural-‐infrastructure-‐and-‐ecosystem-‐services-‐
federal-‐decision-‐making.
6
https://www.whitehouse.gov/the-‐press-‐office/2015/11/03/mitigating-‐impacts-‐natural-‐resources-‐development-‐
and-‐encouraging-‐related.
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Council
on
Environmental
Quality’s
work
to
develop
guidance
for
federal
agencies
as
they
strive
to
account
for
climate
change
through
National
Environmental
Policy
Act
(“NEPA”)
reviews.7
While
that
guidance
remains
in
draft
form,
it
is
nonetheless
helpful
to
inform
the
Santa
Fe
NF
Forest
Plan
revision’s
NEPA
process
and
how
that
process
can
properly
account
for
climate
pollution
and
climate
change.
This
policy
direction
from
the
White
House
and
CEQ
overlays
the
2012
Planning
Rule’s
purpose
“to
guide
the
collaborative
and
science-‐based
development,
amendment,
and
revision
of
land
management
plans
that
promote
the
ecological
integrity
of
national
forests
and
grasslands
and
other
administrative
units
of
the
NFS.
36
C.F.R.
§
219.1.
More
specifically,
the
2012
Planning
Rule
states
that
Forest
Plans
“must
provide
for
social,
economic,
and
ecological
sustainability….”
36
C.F.R.
§
219.8.
Social
sustainability
is
defined
as
“the
capability
of
society
to
support
the
network
of
relationships,
traditions,
culture,
and
activities
that
connect
people
to
the
land
and
to
one
another,
and
support
vibrant
communities.”
36
C.F.R.
§
219.19.
Economic
sustainability
is
defined
as
“the
capability
of
society
to
produce
and
consume
or
otherwise
benefit
from
goods
and
services
including
contributions
to
jobs
and
market
and
nonmarket
benefits.”
36
C.F.R.
§
219.19.
We
emphasize,
in
particular,
that
these
social
and
economic
benefits
include
“ecosystem
services,”
or
the
“[b]enefits
people
obtain
from
ecosystems,”
which
include
“clean
air
and
fresh
water,”
“long
term
storage
of
carbon,”
“pollination,
seed
dispersal,
soil
formation,
and
nutrient
cycling,”
and
“educational,
aesthetic,
spiritual
and
cultural
heritage
values….”
36
C.F.R.
§
219.19.
Ecological
sustainability
is
defined
as
“the
capability
of
ecosystems
to
maintain
ecological
integrity.”
36
C.F.R.
§
219.19.
Ecological
integrity
is
an
underlying
driver
of
planning,
as
the
Forest
Plan
must
include
“plan
components,
including
standards
or
guidelines,
to
maintain
or
restore
the
ecological
integrity
of
terrestrial
and
aquatic
ecosystems
and
watersheds
in
the
plan
area,
including
plan
components
to
maintain
or
restore
structure,
function,
composition,
and
connectivity….”
36
C.F.R.
§
219.8.
Ecological
integrity
is
achieved
when
specific
ecological
characteristics—“structure,
function,
composition,
and
connectivity,”
36
C.F.R.
§
219—fall
within
a
natural
range
of
variation
that
allows
these
characteristics
to
withstand
and
to
bounce
back
from
stress
and,
moreover,
have
the
capacity
to
adapt
to
changing
circumstances
and
conditions,
such
as
those
caused
by
climate
change.
Landscape-‐scale
thinking,
management,
and
analysis
is
crucial
to
resiliency
in
the
face
of
climate
change
risks,
impacts,
and
vulnerabilities.
By
taking
a
landscape-‐scale
approach,
the
Santa
Fe
can
best
identify
and
prioritize
opportunities
to
take
Forest
Plan
and
project
level
action
to
ameliorate
climate
change
and
to
complement
non-‐federal
resource
protection
and
restoration
efforts.
See
36
CF.R.
§
219.10(a)(1),
(4),
(6)
(providing
for
coordination
with
neighboring
landowners
and
consideration
of
land
status
and
ownership
relevant
to
plan
area);
7
https://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/ghg-‐guidance.
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FSH
1909.12,
§
23.23m
(same).
D.
Recommended
Changes
to
the
Preliminary
Need
for
Change
Statements
to
Foster
Ecological
and
Community
Resiliency
Reflecting
our
above
recommended
focus
on
resiliency,
we
strongly
recommend
that
the
Santa
Fe
NF
elevate
the
“Restoration
of
Ecosystem
Resiliency”
component
of
the
Need
for
Change
Statements
on
page
8
of
the
draft
to
encompass
not
just
vegetation,
but
all
plan
Focus
Areas.
We
further
recommend
that
the
Santa
Fe
NF
revise
this
component
to
encompass
community,
not
just
ecological,
resiliency
to
emphasize
the
critical
role
that
communities
play
as
part
of
the
broader
landscape
within
which
the
Santa
Fe
NF
rests.
Specifically,
we
recommend
the
inclusion
of
the
following
italicized
Need
for
Change
statement
in
the
section
currently
entitled
“Overall
Resources”
on
pages
4-‐5
of
the
draft:
Ecological
and
Community
Resiliency
Resiliency
provides
a
positive,
constructive
frame
to
optimize
and
balance
interconnected
ecological,
social,
and
economic
systems
and
to
thereby
satisfy
the
agency’s
duty
to
“provide
for
social,
economic,
and
ecological
sustainability”
in
light
of
the
challenges
and
opportunities
presented
by
the
reasonably
foreseeable
impacts
of
climate
change
to
the
Santa
Fe
and
the
broader
landscape
within
which
the
Santa
Fe
NF
rests.
36
C.F.R.
§
219.8.
Resiliency
consists
of
two
parts.
First,
resiliency
is
the
capacity
of
an
ecological
or
community
system
to
maintain
its
function
in
the
face
of
stress.
A
system
with
high
resiliency
withstands
and
bounces
back
from
stress
better
than
a
system
with
low
resiliency.
Second,
resiliency
is
the
capacity
of
an
ecological
or
community
system
to
adapt
to
changing
circumstances
and
conditions.
Accordingly,
a
system
with
high
adaptive
capacity
adjusts
to
changing
circumstances
and
conditions
better
than
a
system
with
low
adaptive
capacity.
Resiliency
can
help
account
for
the
interconnected
nature
of
natural
and
human-‐
built
infrastructure
and
provide
a
basis
for
effectively
identifying
management
challenges
and
opportunities
in
world
suffering
from
climate
change.
Plan
Need
for
Change
1.
There
is
a
need
to
include
management
approaches
that
protect
and
restore
resiliency
across
focus
areas
given
existing
stressors
and
the
intensifying
role
that
climate
change
will
play
over
the
projected
life-‐time
of
the
forest
plan
revision
and
beyond.
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2.
There
is
a
need
to
include
management
approaches
that
better
reflect
the
interconnected
nature
of
natural
and
human-‐built
infrastructure
to
foster
social,
economic,
and
ecological
sustainability.
We
further
recommend
the
addition
of
the
following
italicized
Need
for
Change
statement
in
the
section
currently
entitled
“Other
Need
for
Change
Resources,”
specifically,
the
“Changes
throughout
the
Plan”
section,
on
page
14
of
the
draft:
4.
There
is
a
need
to
foster
social,
economic,
and
ecological
sustainability
through
the
development
of
plan
components
for
all
resources
that
provide
increased
certainty
that
resiliency
will
be
protected
and
restored
to
account
for
existing
stressors
and
the
intensifying
stress
caused
by
climate
change.
Finally,
we
recommend
that
the
Santa
Fe
NF
modify
the
“Minerals”
Need
for
Change
section
on
page
16
of
the
draft
to
read
“Energy
and
Minerals”
and
add
the
following
Need
for
Change
Statement:
3.
There
is
a
need
to
assess
the
need
for
and
impacts
of
energy
and
minerals
leasing
and
development
on
forest
resources
and
to
consider
options
to
avoid
the
impacts
of
energy
and
minerals
leasing
and
development,
including
through
an
assessment
to
gauge
whether
the
Santa
Fe
National
Forest
is
unsuitable
for
further
energy
and
minerals
leasing
and
development.
II.
THE
FOREST
PLAN
REVISION
SHOULD
CREATE
ADMINISTRATIVE-‐LEVEL
“WETLAND
GEM”
DESIGNATED
AREAS
TO
FOSTER
ECOLOGICAL
AND
COMMUNITY
RESILIENCY
A.
Overview
of
Wetland
Gem
Designated
Area
Recommendations
We
respectfully
ask
that
the
Santa
Fe
create
new
administrative-‐level
“Wetland
Gem”
special
designated
areas
and
include
this
possibility
in
its
Need
for
Change
Statements.
The
2012
Planning
Rules
define
a
“designated
area”
as
“[a]n
area
or
feature
identified
and
managed
to
maintain
its
unique
special
character
or
purpose.
36
C.F.R.
§
219.19.
The
Santa
Fe
NF
should
identify
and
designate
wetlands
to
protect
and
restore
water
resource
resiliency
in
a
changing
climate.
More
broadly,
we
recommend
identify
and
designate
areas
to
protect
and
restore
resiliency
for
forest
resources
in
a
changing
climate
including,
as
noted
above,
areas
that
foster
protection
of
wildlife
core
areas
and,
more
broadly,
the
connectivity
and
permeability
of
wildlife
habitat.
These
actions
should
be
considered
as
components
of
reasonable
alternatives
and
assessed
through
the
NEPA
process.
40
C.F.R.
§
1502.14.
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Description:by the reasonably foreseeable impacts of climate change to the Santa Fe and the broader landscape within resources, such as water, are used across this interconnected landscape-‐scale mosaic of natural through the National Environmental Policy Act (“NEPA”) review for the Plan Revision. Thes
