Comments on Grassland Ecosystem Management Plan

Comments by Friends of Boulder Open Space
Dec 5th, 2008

Friends of Boulder Open Space commends the Open Space and Mountain Parks staff for this excellent document and for its well supported methodology for evaluating the OSMP grassland resources, and for setting targets for achieving and managing healthy ecosystems, based on a solid, scientifically based suite of measurements and practical long-term monitoring.

The Executive Summary states that the “Grassland Ecosystem Management Plan (Grassland Plan) focuses upon the conservation of the 24,000 acres of OSMP lands dominated by mixedgrass and xeric tallgrass prairie.” This is completely appropriate and should not be watered down. Some have advocated that the plan should incorporate methods for balancing recreation needs in the plan. The Executive Summary places the Grassland Plan in the context of the other plans that have been adopted to govern other objectives, including recreation, as does the background material on pages 5-7. Chapter 1, page 5 clearly states its relation to the Visitor Master Plan. This is a Grasslands Ecosystem Management Plan, and it quite properly focuses on managing the grasslands ecosystem.

The right way to deal with conflicting proposed uses of open space lands is with the VMP process, which is intended to do the balancing. The only way OSMP can appropriately balance conflicting demands is to have a clear methodology for managing the resource that carefully identifies the components of the natural systems and defines a healthy state for each, along with ways to determine how various uses would impact that state. This is what allows a land manager to determine whether a particular location is especially important or not, what activities might degrade its health, quality, and value, and, finally, to measure the effects of use over time, in order to practice adaptive management.

Consideration of competing uses has no place in the evaluation of the resources, nor in measuring their health. Good evaluation and measurement are the tools that are needed to determine the potential effects of competing uses and then to evaluate the effects if trails are built, if livestock is grazed, if fires are allowed to burn, etc.

Planning Approach
The use of the CAP approach is an excellent methodology: disciplined, scientifically based, and transparent. As you know, FOBOS has long advocated a clearly defined approach to monitor and manage the system resources. CAP, and the department’s implementation of it in this plan should provide an excellent structure for properly managing the resources, and the 24,000 acres of grassland in the system are urgently in need of such management, as the overall “Fair” state indicates. Moving that state to “Good,” and avoiding degradation will pose a significant challenge over the next few decades, particularly in light of demands for various kinds of use, the continuing effects of past land-use practices. Existing problems with invasive weeds already pose a significant threat, and research indicates that the effects of global warming and excess nitrogen load are likely to exacerbate that threat.

FOBOS has three concerns about the implementation of the CAP approach: Appropriate funding of implementation, particularly for monitoring and mitigation actions, will be particularly difficult in an environment that will become significantly more difficult, rather than remaining relatively static.

  • Appropriate funding of implementation, particularly for monitoring and mitigation actions, will be particularly difficult in an environment that will become significantly more difficult, rather than remaining relatively static.
  • Given the granularity of the approach, there is a significant danger that a set of actions and judgment of their success or failure will be taken in isolation, whereas they will occur in conjunction with a number of other factors operating on the same target. Managing this complexity effectively will require significant discipline.
  • Any tradeoffs that allow uses that may degrade the quality of the resource need to be made without changing target states or ignoring potential effects. On the contrary, when tradeoffs are made, it is critical that potential effects be documented, that planning include potential actions when degradation is greater than anticipated, and that monitoring be done to measure the effects. Note that tradeoffs must take into account all effects on the plan and its implementation.  For example, the criticality of large habitat blocks is well documented in the plan. Hence, a proposed trail’s effect on such a large habitat block would have impacts extending far beyond those immediately along the corridor, and it is vital to take them into account.

Focal Conservation Targets
The selection, definition, and mapping of the focal conservation targets is an admirable synthesis of what we know about the resources and about specific goals for which we need to manage, including ecosystems, specific unique enclaves like White Rocks, and non-ecosystem goals and aggregations of issues, such as the prairie dog associates and agricultural operations.

We hope that there is a continuing long-term effort to refine the nested targets, attributes, and suites of actions in each of the focal conservation targets. The current plan is an excellent first draft, but it is inevitable that it will require constant refinement to achieve its goals.

Strategic Initiatives
The initial list of strategic initiatives is excellent. With respect to Initiative 1 (Large Block Habitat Effectiveness), we would urge you to attempt to increase the number of blocks (Table 21, pages 66-68) of both Mixed Prairie Mosaic and Xeric Tallgrass Prairie that are maintained at good/fair condition, in cooperation with other agencies as appropriate (Strategic Action 26). Because of the importance of blocks of continuous habitat for ecosystem health and species viability, this would be one of the most effective ways to improve our management of the system.

Under Initiative 3, Aquatic Systems Management, Action #17, Evaluating dog restrictions in selective riparian areas to protect sensitive species, should be implemented. Benefits are high and actual impact on dog guardians would be modest. Stating that it has low feasibility because it is “not likely to be appealing to dog guardians” is unpersuasive. Strategic action #21 should aim a little higher in its goal. We should be able to achieve more than three bullfrog-free ponds supporting leopard frogs by 2015.

We note the statement under goal #3 that “Often times maintaining a target in the Good condition is easier and less expensive than trying to improve its condition once it becomes degraded. Monitoring the key attributes of targets that are already within an acceptable range of variability will help ensure targets in Good condition stay that way.” We heartily concur and emphasize that careful monitoring of new trails and appropriate adaptive management are therefore critical. Slow degradation of resources that goes unnoticed causes important ecological losses and is expensive to remedy after the fact.

The strategy of explicitly prioritizing monitoring activities is exactly right. The practical effectiveness of this strategy will, of course, be dependent on budgetary and staffing considerations over time. We hope that the department will place a high priority on these activities, in spite of conflicting demands.

One critical problem in achieving this goal is the neglect in the planning process to budget this necessary monitoring in the cost of new trails or additional access points. Judging the impact of new trails in the system requires the monitoring described, as does doing adaptive management of those trails. But these costs are typically ignored. This results in bad planning, because the additional costs are a “surprise,” and bad management, because the necessary monitoring and adaptive management are not done, resulting in a buildup of needed compensatory maintenance.

The staff ranking of monitoring priority “Very High” to “the indicators associated with grassland vegetation composition and structure, grassland nesting birds…” is an excellent evaluation. Rare plants and individual species monitoring are important, but they are likely to be improved if adequate attention is paid to the vegetation composition and structure, together with a few indicator species, while the reverse is not true.

Our review of the detailed monitoring table of indicators, priority, and methods has been necessarily cursory. In general the list of attributes and their prioritization is excellent.

For both the exotic species assessments using RAM (page L-3), we would suggest that it is critical both that pattern analysis be done, and that particular attention be paid to correlations both with established trails and with new trails. Neither is mentioned in the methods. Control methodology, trail suitability analyses, and best practices for trail building are all dependent on building better understanding of the patterns of establishment of exotic species.

This is a superficial reaction to a monumental plan, but after a one-month review, the superficiality is inescapable. The scope of the plan is (and should be) comprehensive and overwhelming. Its general structure and thrust are focused exactly where they should be—on a careful understanding of the resource and a detailed methodology for its preservation and management.

Once again, FOBOS congratulates the staff on a job well done. Implementation will be challenging, and we encourage OSMP to do the necessary follow-up to actually achieve the goals that the plan sets our so well.