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November 14, 2002
Wayne Elmore
National Riparian Service Team
3050 NE 3rd Street
Prineville, OR 97754
Re: Riparian Ecosystem Evaluation: A Review and Test of BLM
Proper Functioning Condition Assessment Guidelines
We have reviewed the May, 2002 "Riparian Ecosystem Evaluation:
A Review and Test of BLM Proper Functioning Condition Assessment
Guidelines" by Stevens et al. As scientists, we are concerned
with the objective and accurate assessment of resource conditions
and management by BLM. We believe the modifications to BLM's
current Proper Functioning Condition (PFC) assessment protocol
that are proposed will provide the necessary improvements
to ensure that riparian ecosystem assessment is applied in
a systematic and efficient manner that allows comparison between
observers and over time for evaluating long-term trends.
The evaluation documents several major flaws in the current
PFC protocol. These include failure to consider: data management,
site scoring, water quality, fish and wildlife habitat, species
of concern, and direct human impacts. The current protocol
also fails to provide any means for quantitative comparisons
between locations such as between reference and study reaches,
between study reaches over time or for consistent record-keeping
and data analysis. Only "yes" or "no" responses are solicited
for the parameters included in the current protocol used by
BLM. Perhaps most disturbing is the fact that the BLM's current
PFC evaluation method fails to strictly abide by the letter
and the spirit of the National Standards and Guidelines for
Healthy Rangelands. Thus, using the BLM's current PFC method
can result in streams being labeled as Properly Functioning,
but not in compliance with the Standards and Guidelines.
The evaluation protocol proposed by Stevens et al. corrects
these deficiencies and demonstrates its application in a series
of comparisons between sites assessed by BLM using the existing
protocol and those same sites assessed by the new protocol.
The inclusion of factors that are not considered in the current
protocol such as wildlife and fisheries, water quality, and
others prevents the possibility of an error whereby a stream/riparian
ecosystem is rated as "functional" when an important element
that could render it "non-functional" is not considered. It
further provides a numerical ranking or site-scoring system
that allows the observer(s) to place the parameter observed
into each of five categories, ranging from fully functional
to non-functional (which is the same ranking framework used
in the BLM's upland rangeland health assessment protocol).
This numerical ranking is then available for more quantitative
comparison using statistics to evaluate differences over time,
between locations and between different elements of the evaluation.
This has great value in assessing the results of changes in
management over time. It moves the rapid visual assessment
technique into the realm of quantitative measures that require
much more time and equipment intensive efforts to characterize,
yet can be performed easily and in a relatively short time.
The emphasis of the proposed evaluation protocol is on "monitoring"
in the true sense as opposed to casual, one-time observation.
As such, we, the undersigned, urge the National Riparian
Service Team to 1) incorporate these improvements into an
updated version of the national PFC protocol, and 2) to urge
BLM Field Offices to incorporate the updated PFC protocol
into monitoring and range management decisions. We also urge
the directors of the 4-corners State Offices of the BLM to
direct their Colorado Plateau Field Offices to adopt all or
parts of this alternative protocol as an addendum (as has
recently been done in the Grand Staircase Escalante National
Monument), as this proposed evaluation method is tailored
to the low-elevation stream systems of the Plateau.
Please keep us, the undersigned, informed of how the NRST
and various BLM Field Offices in the Colorado Plateau choose
to use the valuable research provided to you by Stevens et
al. earlier this year. Correspondences should be addressed
to myself at the address below. As scientists active in the
fields of stream assessment and management, and conservation
research, we are interested to hear how you think we can best
collaborate with the NRST and BLM as we, together, work to
improve the methods that are used to assess and monitor these
critical lowland riparian and stream resources.
Sincerely,
Thomas L. Fleischner, Ph.D.
President, Colorado Plateau Chapter, Society for Conservation
Biology
Professor of Environmental Studies, Prescott College
220 Grove Avenue
Prescott, Arizona 86301
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