The Georgia Forestry Association’s (GFA) Environmental Committee recently sent a letter to the U.S. Fish & Wildlife Service (FWS) to advise the agency on certain silvicultural exemptions that should be considered in the “threatened” listing of Northern Long Eared Bat (NLEB) under the Endangered Species Act (ESA).
The NLEB is a forest dwelling bat species whose range includes 39 states. The FWS has acknowledged that the primary threat to the NLEB is not loss of suitable forest habitat, but rather “white nose syndrome”, a fungal disease which affects cave hibernating bats.
FWS released a statement on April 1, listing the Northern Long-eared Bat as “threatened.” In addition, FWS proposed a section 4(d) interim rule, which would lighten the regulatory burden on lands under “forest management,” essentially permitting “incidental take” of the NLEB except within 128-acre zone containing NLEB hibernacula or occupied NLEB roost trees during the pup-rearing season.
On March 17, 2015, GFA submitted comments on the supplemental 4(d) rule, which the FWS will respond to during the review of the comments on the final rule. GFA supported FWS exempting forest management from take and advised the agency on the issue of pine plantation establishment and other proposed management restrictions that would severely limit the ability of private forest landowners to effectively manage their timber.
“We are encouraged that the Service is considering 4(d) rule exemptions for forest management. The best available science points to the benefits of active forest management in maintaining habitat for forest dwelling bats,” GFA Environmental Committee Chair Kyla Cheynet, Plum Creek, said. “However, we are very concerned about the Service’s exclusion of certain silvicultural techniques, such as establishment of new pine plantations from incidental take protection.”
According to the National Alliance of Forest Owners (NAFO), elements of the section 4(d) interim rule include:
- No prohibitions on forest management outside the white-nose syndrome buffer zone;
- No prohibitions on forest management outside 0.25 mile (0.4 kilometer) from a known, occupied hibernacula;
- Avoid clearcuts (and similar harvest methods, e.g., seed tree, shelterwood, and coppice) within 0.25 mile (0.4 kilometer) of known, occupied roost trees during the pup season (June 1-July 31); and
- Avoid cutting or destroying known, occupied roost trees during the pup season (June 1-July 31)
The rule preamble has retained the exclusion of converted “mature hardwood, or mixed, forest into intensively managed monoculture pine plantation stands” from the 4(d) exemption. However, the preamble also states: “Continued forest management and silviculture is vital to the conservation and recovery of the northern long-eared bat.”
FWS will take comments on the interim 4(d) rule until July 1, 2015 and will make a final decision by the end of the year. GFA will continue to monitor and report on this issue as it moves through the regulatory process. For more information on the NLEB, visit http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0JE.