Department of Fish and Wildlife Stategic Plan

November 3, 2003

Wayne A. Laroche
Commissioner, Department of Fish and Wildlife
103 South Main Street, 10 South
Waterbury, VT 05671-0501

Dear Commissioner Laroche:

Thank you for the opportunity to participate in the recent focus group to review the draft Department Strategic Plan. Please accept the following comments from the Vermont Natural Resources Council, which will coincide with feedback that was provided at the focus group meeting.

We are concerned that adequate need for the current revision process has not been demonstrated. At the focus group meeting, it was explained that there is nothing deficient with the current plan (2001-2005 Strategic Plan). At the meeting, Tom Wiggens stated that the Department has enjoyed high effectiveness ratings employing the current plan.

Our impression of the existing Strategic Plan is that it is an excellent and well balanced working document that presents a good road map for fisheries and wildlife management, habitat conservation planning, WMA management planning, and public education. The document is clear and understandable with substantive pictures and graphs.

We question whether the time and resources that have gone into updating the current plan could have been better spent implementing the nut and bolts of fish and wildlife management in the state. Furthermore, considering budget concerns within the Department, we question whether the cost associated with drafting a new plan, and presumably printing a new plan makes sense at the current time.

There seems to be a desire to rewrite the Strategic Plan two years in advance of the current deadline to allow the Administration to put its imprint on the Strategic Plan. We question whether this imprinting exercise is the most efficient use of the Department's time?

Upon review of the draft plan, VNRC is concerned about certain changes between the existing plan and the draft plan. A side by side comparison of the two plans offers small, but distinguishing policy changes that are of serious concern to our organization. The following is an overview of our concerns and comments regarding the draft plan:

In general, the draft plan does not provide a core activities section. The current plan has a core activities section that provides an excellent bulleted overview of issues needing particular attention by the Department. The draft plan should strive to offer a core activities section.

Program Goal I: Conserve, restore, and enhance natural communities and habitats that have high wildlife and ecological value in Vermont, and conserve ecosystem integrity.

In regards to Program Goal I, the slight change of one word highlights a distinct philosophical change in the strategic plans. The current plan states that it is a goal to "preserve ecosystem integrity." The draft plan changes this goal to "conserve ecosystem integrity." While this is a slight change in terminology, it raises the question of whether there is a desire to tweak the degree to which ecosystem integrity will be protected in Vermont. Does the Department feel it is no longer reasonable to preserve the integrity of ecosystems under its jurisdiction? Why does the Department feel it is necessary to distinguish between the conservation of ecosystem integrity and the preservation of ecosystem integrity?

Under Goal I, there are other subtle changes that are problematic. For starters, the current plan's indicator 1.7 states that there shall be an increase in the number of wildlife management areas with biodiversity assessments and management plans. The draft plan offers that there shall be an increase in the number of acres of wildlife management areas actively managed in accord with duly adopted plans. We are concerned that a new emphasis is placed on increasing the number of acres on wildlife management areas actively managed without any mention of increasing or implementing biodiversity assessments for these acres. VNRC believes the Department should strive to incorporate a performance measure that recognizes that comprehensive planning and management is needed for wildlife management areas which is based on both active and passive management. The Department should include an increase in the performance of biodiversity assessments in the performance measure treating wildlife management areas.

Furthermore, the draft plan eliminates indicators 1.1 and 1.2 from the current plan. Both of these indicators speak to the need for increasing attention to impaired waters. Indicator 1.1 recognizes that more river and stream miles should support Aquatic Habitat designations. Indicator 1.2 recognizes that more stream and river miles should be spared from impairment due to flow alterations or obstructions in Vermont. Both of these indicators should be reincorporated into the draft plan.

In addition, both the current and draft plan recognize that the Department should increase efforts to inventory and monitor wildlife habitats and natural communities. However, the draft plan offers that inventorying and monitoring shall "provide baseline information for conservation efforts", while the current plan states that inventorying and monitoring efforts shall be increased to "maintain ecological integrity and viable populations of native species." The Department should reincorporate the current standard of maintaining viable populations of native species. Without this standard, the draft plan does not recognize the importance of collecting data to maintain ecological integrity and viable populations of species.

Finally, we support the inclusion of Performance Measure 1.5 under Program Goal I. The benefits of maintaining contiguous forest in an unfragmented state are well documented. We support the Department's goal of enhancing the numbers of contiguous forest it manages.

Program Goal II: Conserve and restore Vermont's fish, wildlife, and plant species to maintain ecosystem integrity for the benefit of the public.

In regards to Program Goal II, Performance Measure 2.2 states that the Department will "maintain and enhance key wildlife populations at healthy and sustainable levels." Without further definition of the word "key", this performance measure seems hard to understand and measure. For example, what are key wildlife populations? Is the Department considering employing the concept of management indicator species? The Department should consider eliminating the word "key" so that all species are maintained and enhanced at healthy and sustainable levels.

It seems that the public would expect the Department to the best of its ability to strive to maintain all wildlife populations at sustainable levels. To this end, we strongly support Performance Measure 2.2, which recognizes that in order to manage populations at sustainable levels, species recovery plans shall be implemented to increase the number of species that are delisted as threatened and endangered.

VNRC questions why the Department has deleted indicators 2.1, 2.3, 2.5, and 2.6 from the current plan? We recommend that the Department continue to maintain the current level of bear habitat in Vermont (as stated in indicator 2.1). We also recommend that the Department successfully restore the Connecticut River American Shad and Atlantic Salmon populations (as stated in indicator 2.3), and monitor breeding bird survey trends (as stated in indicator 2.6). Finally we strongly recommend that the Department increase the amount of conserved lands that protect threatened and endangered species and significant natural communities (as stated in indicator 2.5). The draft plan suggests the Department shall "protect and manage habitats that are necessary for the conservation and restoration of specific species." This standard is more vague (use of the word "specific" does not provide guidance), and it fails to recognize that the department should increase conserved land for threatened and endangered species and significant natural communities.

Furthermore, we are curious about language inserted into Strategy 10 (third bullet). The draft proposal suggests that the Department will prepare management plans "in order to maintain sustainable species population levels within ecological limits while considering social implications." We fully support the preparation of species management plans to maintain sustainable species population levels, but we question the necessity for including language regarding the consideration of social implications. It is hard to understand whether this language means that social considerations might at times trump the maintenance of sustainable species populations. Wildlife professionals across the country often lament at the degree to which wildlife management is driven by social expectations rather than good science. The Department should clarify the meaning of considering social implications while maintaining sustainable species populations. VNRV believes the Department should promote a policy of drafting management plans based on the best available science.

Finally, we strongly support Strategies 11 - 12 and 14 - 16 in the draft plan. Species reintroduction programs are vital to the strength of biodiversity maintenance in Vermont, and we wholeheartedly support the development and implementation of recovery plans for threatened and endangered species.

Regarding Program Goal III, we are concerned about the elimination of previous indicators concerning the Nongame Wildlife Fund. Indicators 3.1 and 3.2 of the current plan are vitally important for the success of the Nongame and Natural Heritage Program (NNHP). The Department recognizes in the draft plan the importance of having a performance measure for the number of hunting and fishing license sales in the state (Performance Measure 4.1). However, the draft plan fails to mention the primary vehicle for funding nongame and natural heritage protection in the state - the conservation license plate and the taxpayer check off. We strongly encourage the Department to reinsert language into the draft plan concerning the need to increase donations to the Nongame Wildlife Fund. Overall funding for the Department as a whole is an important performance measure, but the Strategic Plan should specifically recognize the importance of increasing available funding for the NNHP.

Furthermore, Indicator 3.4 of the current plan recognizes the need to "increase the level of public knowledge about the relationship between human activities, conservation ethics, habitat loss, and biodiversity." The draft plan does suggest that the Department should maintain or increase the public's support for and knowledge of fish and wildlife conservation and stewardship." The draft plan also suggests that education efforts shall focus on issues such as habitat fragmentation and threats to fish and wildlife species and their habitats. However, the draft plan does not reiterate the importance of increasing the public's knowledge of biodiversity. The concept of managing and preserving for biodiversity (as defined in the glossary) is an important aspect of fish and wildlife management. The Department should embrace the importance of educating the public on biodiversity management and include this concept specifically in one of the existing strategies (such as #19). Moreover, educating the public about the relationship between human activities and habitat loss and biodiversity is vitally important, and we encourage the Department to state this more specifically in the Strategic Plan.

In addition, the current plan included a strategy to "define a department land stewardship message to promote the conservation and appropriate, ethical use of Vermont's terrestrial and aquatic communities." The draft plan offers more broadly that there shall be a strategy to "promote department land conservation and stewardship message." We support the current plan's strategy because it specifically outlines the stewardship message of the Department. The draft plan's stewardship message is too vague and broad.

Miscellaneous Strategy Comments

Finally, we offer several comments regarding other strategies in the draft plan. We strongly support strategy 55 and 56. Securing broader funding for the Department should be a high priority for the Department. The Department should consider partnering with organizations in the state that share a similar goal of acquiring national funding for Vermont. VNRC makes a concerted effort to track and support national legislation that increases conservation and wildlife grants in our region - as do many other groups, such as the broader Northern Forest Alliance. Partnering with such groups can help leverage successful federal dollars for wildlife and fisheries resources.

VNRC believes strategy 59 needs clarification. We are unsure if the strategy suggests that the Commissioner will determine how science should fit into employee decision-making philosophies. We realize that science and politics do cross-pollinate, but employees should be encouraged to utilize the best available science, and we encourage the Department to separate politics and science to the best of its ability to most effectively manage the fish and wildlife resources of our state.

Thank you for this opportunity to comment on the draft plan and we appreciate your consideration of these comments. We look forward to future opportunities to comment on this planning process.

Sincerely,

Jamey Fidel
Forest and Biodiversity Program Director
Vermont Natural Resources Council

cc Ron Regan
Tom Wiggins