NCASI submits comments to the North Carolina Wildlife Resource Commission

Recently, the North Carolina Wildlife Resources Commission (NCWRC) requested: (1) public review and comment of draft species conservation plans for aquatic species listed on the agency’s website and (2) comments on a draft conservation plan for the gopher frog (Rana capito). NCASI staff drafted and submitted comments to NCWRC addressing these conservation plans.

Comments on the aquatic species conservation plans centered around effectiveness of BMPs to protect water quality and in-stream habitat conditions for aquatic species. Comments on gopher frogs were focused on the ability of gopher frogs to inhabit forest types other than unfragmented longleaf pine, including working forests, if appropriate habitat structure exists.

Summary of comments on aquatic species:

The North Carolina Wildlife Resources Commission has invited public comment on three draft conservation plans for aquatic species. Potential conservation actions are an important aspect of each. However, the plans do not discuss protection of water quality and in-stream habitat conditions by forestry best management practices (BMPs). Managed forests represent a major land use in the southeastern United States, and within the range of the aquatic species addressed by the draft NCWRC conservation plans. Forestry activities in North Carolina, and other states, are conducted under a comprehensive program of state-approved BMPs designed to protect water quality and habitat for aquatic organisms. Rigorous, ongoing efforts to monitor forestry BMPs indicate that implementation rates are high so that risks to water quality from forestry activities are low both nationally and in North Carolina. A large body of scientific literature confirms that properly implemented forestry BMPs are effective at protecting water quality and in-stream habitat conditions. Considerable research also indicates that silvicultural practices implemented with BMPs protect aquatic species. Finally, although BMPs are voluntary standards, they are required for landowners that are certified under various forest certification stands, such as The Sustainable Forestry Initiative and Forest Stewardship Council. Thus, contribution of forestry BMPs to conservation of aquatic species has been recognized for watersheds in similar settings within the southeastern U.S. Draft conservation plans for aquatic species in North Carolina could be strengthened by recognizing conservation benefits of forestry BMPs for those species.

Summary of comments on the gopher frog:

Recently, the North Carolina Wildlife Resources Commission requested public review and comment on a draft species conservation plan for the gopher frog (Rana capito) in North Carolina. The draft plan describes the gopher frog as closely associated with longleaf pine (Pinus palustris) and indicates that unfragmented longleaf pine ecosystems are required for the species’ survival. However, gopher frogs have been documented in a variety of forest types and land uses, including managed forests. In modern working forest landscapes, a relatively large proportion of stands have open canopies and other characteristics that may benefit the species. Thus, the draft conservation plan could be strengthened by recognizing conservation benefits provided to the gopher frog by managed forest landscapes in North Carolina.