A White Paper Discussing Management Indicator Species (MIS)

Introduction
A White Paper Discussing Management Indicators (MI)
Leading to the Development of a Strategy for Change
for the National Forests & Grasslands in Texas (NFGT)
November 2009
The National Forests and Grasslands in Texas (NFGT) selected Management Indicators
(MI) to represent its planning area in the 1996 Revised Forest Land and Resource
Management Plan (the Plan.) Management Indicators (MI) were selected in compliance
with applicable laws and regulations in effect at the time the Plan was developed and are
“used to assess the effects of management on habitats and ecosystems.” 1 The intent is
for selected species and ecological communities to be used as indicators of the impact of
NFGT forest management on overall forest health. Emphasis was placed on selecting
Federally-listed endangered or threatened species, sensitive species, as well as species in
demand for recreational, commercial, or subsistence use. In addition, indicators
representing special habitat, habitat components, or plant and animal communities were
added along with ecological indicators.
Since publishing the 2002-
2003 Monitoring and
Evaluation Report, NFGT
resource specialists have
determined that:
1. Some of the selections
are not serving the
purpose as originally
intended, and
2. Monitoring methods for
some species and
communities are
impractical.
Species and communities were chosen because
monitoring and evaluation of the status of each should
indicate the effects of management activities. Using the
MI concept should provide management with the
ability to determine whether the NFGT is maintaining
and conserving biological diversity (as required by the
National Forest Management Act of 1976) or whether
activities are causing detrimental effects on plant and
animal species or communities. Since the Plan was
signed in 1996, monitoring and evaluation of adopted
species and communities has proven to be difficult.
When the findings with the 2002-2003 report were
presented to the Forest Leadership Team (FLT) in
2003, a proposal for preparing a Plan Amendment was
recommended. The FLT, however, agreed to postpone
the amendment for MI because of lack of personnel, time, and funding to support the
effort as well as the fact that they expected Plan Revision efforts to begin in 2009. (Plan
revision is now scheduled to begin in 2012).
According to NFGT resource specialists, problems with monitoring the existing MI list
have continued. Since “effective forest monitoring programs should be able to generate
the qualitative and quantitative information needed to evaluate resource management
1 USDA Forest Service-National Forests and Grasslands in Texas. 1996. Final Environmental Impact
Statement, Appendix F. Lufkin, TX.

activities and detect change in the status of forest resources,” 2 changes are still needed.
In order to decide what needs to be done to resolve problems with monitoring the existing
MI, the planning staff has done several things. First, current laws and other direction
were reviewed along with relevant publications and/or research articles. Next, court
rulings where MI were an issue were considered and assessments were made of how
other forests are dealing with this issue – both nationally and in Region 8.
A general recap of the information that was evaluated and recommendations for strategies
for promoting needed changes are provided in the following text.
Laws and Other Direction
The National Forest Management Act of 1976 [NFMA at 16 United States Code (U.S.C.)
1604] directed that management of wildlife habitats “maintain viable populations of
existing native and desired non-native vertebrate species in the planning area.” The
NFMA, however, did not specify a method for monitoring Forest Service activity to
determine its performance toward achieving these goals.
A committee of scientists recommended the Management Indicator Species (MIS)
approach and Forest Service regulations dated September 30, 1982 (36 CFR 219 – also
known as the 1982 Planning Rule) adopted the committee’s recommendations. Under
this MIS approach, forest managers identify and select a limited number of species that
are then tracked as means of making broader assessments of the overall ecological
conditions of the forest’s wildlife habitat and the other species dwelling in the habitat, as
well as the effects of Forest Service management activities. Population changes in the
indicator species being monitored are interpreted as a signal of changes in the health of
the ecosystem.
In a 1991 Government Accounting Office (GAO) report to the Secretary of Agriculture,
the reviewing office determined that, “The Forest Service MIS approach to monitoring
appeared to have several practical drawbacks (Table 1).” The report also noted that,
“…substantial additional funds would be needed to support the carefully designed
research essential to help identify and judge the efficacy of MIS as ecological
indicators.” 3
Forest Service Washington Office (WO) acknowledged the problems; however, it was
felt “that the difficulties stemmed from the way the MIS principles were applied.”
National direction was then revised to a management indicators (MI) concept that would
include not only species, but also special habitats and unique biological communities
identified in the forest planning area. The intent was for monitoring to focus on habitat
capability and to relate changes in habitat capability to associated effects on species
populations.
2
USDA Forest Service-Resource Information Group. 2009. Draft Technical Guide: Developing a
Monitoring Guide. Fort Collins, CO.
3
General Accounting Office (GAO). 1991. Wildlife Management: Problems Being Experienced with
Current Monitoring Approach. Washington, D.C.

The NFGT utilized the 1982 Planning Rule during most of the revision process. Direction
for MI (as published in the July 1, 1988 Code of Federal Regulations at 36 CFR 219.19.)
was also used in the development of the Plan. The NFGT chose to use the broader MI
concept because: (1) staff was advised that newer regulations were expected to be
published soon; and (2) the Management Indicator (MI) concept included consideration
of ecological communities as well as individual species. In the Plan, the NFGT selected
18 wildlife species, 9 habitat communities, 8 fish, 2 guilds and a habitat constituent as MI
to represent the habitat needs for the fauna and flora present in the planning area. Per
direction in the Plan, the NFGT has been responsible for providing actual population
estimates and, where possible, trends for management indicators.
Many changes to the planning regulations have been proposed by the U.S. Forest Service
(USFS) since 1982, with the latest changes published in 2008. These changes in
regulations provided different methods for monitoring forest health and viability of
species. As a result, Forest Service Manual (FSM) and Forest Service Handbook (FSH)
direction for planning and monitoring has also changed several times. All of these
proposed changes have met strong opposition in courtrooms across the nation. Most
recently, the 2008 Planning Rule was vacated and remanded by the District Court in
California on June 30, 2009. Currently, the NFGT has been directed to follow the 1982
Planning Regulations for proposing any Plan Amendment.
The NFGT should identify available protocols in existing databases as some of the first
steps that need to be taken to solve existing problems and in order to streamline the
monitoring and evaluation process.
Additional information and guidance can be found in an April 2007 Forest Service report
that considered ecological, social and economic attributes of desired conditions.” 4
Publications and Research
A literature review was conducted to determine if relevant publications and research exist
concerning MI. A number of the documents discussed individual management indicator
species, their relationships to habitats, actual monitoring details and findings for the
specific species, while a few discussed the general use of MI as a whole to evaluate the
effects of management activities on ecosystems.
In a critique written by Landres, et al. 5 , the authors determined that, “Plant and animal
species have been used for decades as indicators of air and water quality and agricultural
and range conditions. Increasingly, vertebrates are used to assess population trends and
habitat quality for other species.” The conceptual bases, assumptions, and published
4 USDA-Forest Service. 2007. LMP Monitoring and Evaluation-A Monitoring Framework to Support
Land Management Planning. Washington, D.C.
5 Landres, P.B., J. Verner, and J.W. Thomas. 1988. Ecological Uses of Vertebrate Indicator Species: A
Critique. Conservation Biology, Volume 2, No. 4.

guidelines for selection and use of vertebrates as ecological indicators were analyzed.
The conclusion was, “that an absence of precise definitions and procedures, confounded
criteria used to select species, and discordance with ecological literature severely
weakens the effectiveness and credibility of using vertebrates as ecological indicators. In
many cases, the use of ecological indicator species is inappropriate…” They then
provide eight recommendations to make the use of indicators more rigorous.
1. clearly state assessment goals,
2. use indicators only when other assessment options are unavailable,
3. choose indicator species by explicitly defined criteria that are in accord with
assessment goals,
4. include all species that fulfill stated selection criteria,
5. know the biology of the indicator in detail and treat the indicator as a formal
estimator in conceptual and statistical models,
6. identify and define sources of subjectivity when selecting monitoring and
interpreting indicator species,
7. submit assessment design, methods of data collection and statistical analysis,
interpretations, and recommendations to peer review, and
8. direct research at developing an over-all strategy for monitoring wildlife that
accounts for natural variability in population attributes and incorporates concepts
from landscape ecology.”
Although written several years ago and several of the above criteria are probably more
intense than we would want to implement, some of the recommendations are still
applicable today and are good direction to address the problems the NFGT is
experiencing.
In an article titled “Adaptive Monitoring: a new paradigm for long-term research and
monitoring.” 6 Lindenmayer and Likens (2009) outlined the current problems with
monitoring programs:
1. Monitoring programs are driven by short-term funding or political directive rather
than carefully posed questions and objectives,
2. Monitoring programs have been poorly designed from the beginning, and
3. Monitoring often includes a large number of species (laundry list), but resource
and time constraints mean that this approach is done badly.
Lindenmayer and Likens contend that asking questions to drive monitoring efforts is the
most efficient and effective strategy to obtain meaningful ecological results.
Dale and Beyeler 7 (2001) listed three concerns that hamper the use of ecological
indicators are a resource management tool:
6 Lindenmayer, D.B. and G.E. Likens. 2009. Adaptive Monitoring: a new paradigm for long-term research
and monitoring. Trends Ecol. Evol. 24 (9):482-486.
7 Dale, V. H. and S.C. Beyeler. 2001. Challenges in the development and use of ecological indicators.
Published by Elsevier Science ltd.

1. Monitoring programs often depend on a small number of indicators and, as a
consequence, fail to consider the full complexity of the ecological system,
2. Choice of ecological indicators is often confounded in management programs that
have vague long-term goal and objectives,
3. Management and monitoring programs often lack scientific rigor because of their
failure to use a defined protocol for identifying ecological indicators.
“The Plan’s monitoring and evaluation is not rigorous scientific research, nor was it
intended to be. The level of research is not necessary for evaluating Plan
implementation.” 8
It would be worthwhile to involve the Research Unit nearby to assist us in developing
some protocols, if not national protocols for maintaining and evaluating monitoring data
for species and ecological communities we might choose are not readily available
elsewhere.
The Case For and Against Monitoring Programs
Table 1. Pros and Cons of Monitoring Programs
Pros 9 Cons 10
Monitoring programs provide a basis for Monitoring programs are prohibitively
learning and understanding
Monitoring program data can resolve
complicated resources issues.
Monitoring programs can provide new and
novel approaches to management
Monitoring programs can help us
understand the loss of ecological resilience.
Monitoring can provide insights into
cause-and-effect relations between
environmental stressors and anticipated
ecosystem responses.
expensive to implement
Relationships between indicator species
and habitat characteristics are often not
known
Changes in the population that are
detected could be due to habitat
changes beyond management control
Monitoring of indicator species may be
impractical because the large numbers
of skilled staff required may not be
available during the critical time
periods.
Selection of species is sometimes based
on factors other than their biological or
ecological representatives
Court Rulings Including Recent Sierra Club Settlement Agreement
8
National Forests and Grasslands in Texas. 1999. The NFGT 1997-1999 Monitoring and Evaluation
Report. Lufkin, Texas.
9
Busch, D. and J. Trexler. 2002. Monitoring Ecosystems. Island Press. 384 pp.
10
General Accounting Office (GAO). 1991. Wildlife Management: Problems Being Experienced with
Current Monitoring Approach. Washington, D.C.

On August 17, 1997, Judge Schell issued an order stating that the agency’s actions or
failure to act, have been “arbitrary, capricious, an abuse of discretion, and otherwise
not in accordance with law” i.e. the NFMA and regulations, and that the FS has
neither protected the key resources of soil and watershed nor adequately inventoried
and monitored for wildlife and diversity, and whether the FS is meeting objectives and
adhering to standards and guidelines of the regulations.
Cause No. 4:04-CV-00374 - Sierra Club, et al v. Jacobs, et al in the U.S. District
Court, Southern District of Texas, Houston Division involves four issues. In a partial
ruling, the court ruled in favor of Plaintiffs – and against the Forest Service – on two
counts. The court found that the NFGT was arbitrary and capricious when it issued two
projects and vacated Forest Plan Amendment #4. It also ordered that an evidentiary
hearing be held to consider the additional two counts concerning both MIS & PETS
(Protected, Endangered and Threatened Species).
MI or MIS and Other Forests
The White River National Forest (WRNF) in Colorado revised its MIS list in 2006 in order to
establish a revised MIS list that was better aligned with the applicable regulation, better
served to indicate the effects of management activities on the forest, and ensured monitoring
was conducted on species for which monitoring population trend is most feasible and useful.
The WRNF reduced its MIS list from 16 to 10 species as a result of this Forest Plan
Amendment.
The Hoosier National Forest (HNF) in the Revised Land and Resource Management
Plan, reduced the number of MIS to five species in 2006.
The National Forests in North Carolina amended the Land and Resource Management
Plan for the Nantahala and Pisgah National Forests in 2005. The Nantahala and Pisgah
National Forests reduced their MIS list from 63 species down to 18 species.
Conclusion/Strategies for Change
Relevant publications and research are mixed on the use of MI to determine
the effects of management activities on ecosystems. Courts nationally and
locally have varied in their rulings on the MI issue, with some finding the
Forest Service is doing an insufficient job of monitoring as planned and
others stating that the Forest Service is being held to an impossible standard.
It appears that MI are dealt with nationally and in Region 8 in a fairly consistent manner
because species are chosen as a result of their direct links to each forests’ available
habitat. However, many different varieties of mammals, reptiles, amphibians, fisheries
and biotic species, as well as biotic communities are chosen because of the differences in
the range for species and differences in ecological conditions available on each national
forest.
Good indicators
must be chosen to
provide beneficial
information.

After evaluating all of the available information, the NFGT FLT approved the
development of a Forest Plan Amendment to revise the NFGT’s current list of MI
(September 2009).
The Plan can be amended (by a Non-Significant Amendment) with a list that contains
more effective MI.
1. Either substitute a new MI species or community for existing MI for those that are
proposed to be dropped and/or look for opportunities to reduce the number of
species or communities where there may be duplications or overlap.
2. Public involvement (early and often) would be a key element to processing a
Non-Significant Amendment. A Public Involvement Plan should be developed
with detailed steps to be taken to involve interested and affected stakeholders.
3. The Non-Significant Amendment would require use of the National
Environmental Policy Act (NEPA) process.
With public involvement, a step-by-step strategy can be developed, documented, and
implemented in order to move the NFGT towards making changes needed to better
monitor its management actions. The strategy will address:
1. Why we are creating a monitoring program.
2. What we are going to measure.
3. Where we are going to put sampling points or where sources of data will be
obtained.
4. How we are going to measure and provide results.
By completing a Forest Plan Amendment, the NFGT can provide a list of MI that would
better assess whether we are sustaining forest health and the viability of species (as
required by NFMA).