TAKE ACTION - Last, Best Chance to Speak up for a Principled, Science-based Vermont Conservation Plan

Right now, the “comprehensive strategy” to implement Vermont’s 30x30/50x50 conservation law is neither comprehensive nor visionary. Join us on March 18 in Middlebury or online, and submit comments by March 31, to make sure wild public lands are at the heart of biodiversity conservation in Vermont.

Act 59 has enormous potential to foster biodiversity conservation on Vermont State Lands like this corner of Groton State Forest, but the draft “Vermont Conservation Plan” that is supposed to implement this law is a recipe for the status quo. Join us on March 18 in Middlebury or on Zoom for an official Act 59 Stakeholder-Led Listening Session, and submit written comments by March 31 on the draft plan — it’ may be the public’s last official chance to weigh in.

The Vermont Conservation Plan is supposed to be the “comprehensive strategy” to implement Act 59, Vermont’s 30x30/50x50 biodiversity conservation law. Developed primarily in closed-door meetings by two hand-picked groups, the public now has what could be its final chance to weigh in on the Plan, and we need your help. Scroll down for a guide on how to speak up, our top concerns, and more background on the Act 59 process.

How to Weigh In

1. Attend our Stakeholder-Led Listening Session.March 18, 5 - 7pm at Middlebury College, and on Zoom. We are hosting an official “listening session” on the draft Vermont Conservation Plan in partnership with the Middlebury College Sunday Night Environmental Club. This event is your chance to learn more about Act 59, then share spoken and/or written comments that will be submitted to VHCB to guide the final Vermont Conservation Plan. Event is free — and includes dinner — but RSVPs are required at this link.

2. Submit a written comment by March 31. This is your chance to submit detailed, written feedback, on the record, about the draft Vermont Conservation Plan. The best way to submit your comments is simply by emailing vcpadmin@vhcb.org by March 31. VHCB and Future iQ are also providing survey questions that that the public can submit in response to each of the three draft “objectives” in the plan, but we recommend sending your comments directly via email, both to make sure that the “Project Management Team” sees your comment, and to give you a fair, full opportunity to express your thoughts rather than just respond to prescriptive statements and prompts.
   

Read VHCB’s introduction to the draft Plan at this link, the full draft Plan here, and scroll down for our top concerns.

Our top-line message is this: Right now, the draft “Vermont Conservation Plan” is unlikely to lead to a lawful, science-based, or ambitious outcome for Act 59. The Plan needs to be amended to bring the focus back to biodiversity conservation, with a discussion of alternatives and fair consideration of the need to protect large wild areas, especially on public lands.

Below are the key concerns that we hope to convey about the Vermont Conservation Plan. Feel free to use or borrow this language as much as you’d like, or just consider it helpful context for your own comments. And don’t forget to share why wild places and Wildlands conservation matter to you! 

Our Concerns

1. The Plan needs to get back to biodiversity conservation science — the substance of Act 59 and Vermont Conservation Design (VCD). Act 59 is a statute focused on biodiversity conservation. This is made clear in the text of the law itself, and in subsequent communications from the House committee that drafted the bill, who wrote that “the intent and words of the General Assembly in Act 59 are...clear: that biodiversity conservation is the focus of this statute.” Right now, only one of the three draft Plan objectives is focused on biodiversity conservation. The other two objectives focus on things that are compatible with biodiversity conservation and should be considered during Act 59 implementation, but are not the focus of the law. Vermont already has a Farm-to-Plate Investment Program, a State Emergency Management Plan, a Climate Action Plan, a Statewide Comprehensive Recreation Plan, and a Forest Future Strategic Roadmap. The Vermont Conservation Plan does not need to be any of these other plans or programs  — it just needs to provide clear, science-based options to meet Vermont’s biodiversity conservation goals. The Plan should use the three conservation categories defined in Act 59 (Ecological Reserves, Biodiversity Conservation Areas, and Natural Resource Management Areas), and the quantitative and qualitative guidelines in Vermont Conservation Design, to organize its recommendations, rather than three “objectives” that differ from the focus of Act 59 itself.The Conservation Plan also needs to include substantive guidance from biodiversity conservation science, including Vermont Conservation Design (VCD), a 2018 report from the Agency of Natural Resources outlining how to recover an “ecologically functional” landscape across Vermont. According to Act 59, “reaching 30 percent by 2030 and 50 percent by 2050…shall be guided by the principles of conservation science and the conservation targets within Vermont Conservation Design.” Despite this clear directive, the draft Plan does not include any of the specific, quantitative recommendations from VCD, such as goals for recovering old forests across at least 10% of Vermont, or the recommendation that old forest recovery be prioritized in large patch sizes and within mapped highest priority forest blocks. Instead, the draft Plan relies on an “Implementing Vermont Conservation Design” report developed last year in a closed-door, private process that selectively pulls from Vermont Conservation Design and obscures the need to protect more ecological reserves on public lands. Act 59 calls for its implementation to be guided by  conservation science. The Plan needs to listen to that directive — both by incorporating the specific recommendations of Vermont Conservation Design (not a subsequent report developed after the fact in a closed-door process neither legislators nor the public had access to), and by referencing the most up-to-date conservation science, which has advanced markedly since VCD was published and shows clearly that large, wild forests are the “backbone” of biodiversity conservation.
   

2. The draft Plan needs to emphasize protecting large wild areas, particularly on public lands. Currently, the draft Plan misinterprets and selectively draws from Vermont Conservation Design to minimize the need to protect wildlands on public lands. Objective One of the draft Plan (“Centering Vermont Conservation Design”) includes repeated calls for “strategically establishing Ecological Reserve Areas in biophysical regions outside the Northern and Southern Green Mountains,” and implicitly suggests that there is no need to protect more ecological reserves (i.e. Wildlands)  in the Green Mountains, particularly on public lands. This suggestion is false on numerous levels, and needs to be corrected in the final Plan. While no one would argue that there is no need to protect Wildlands in rare natural communities or under-represented regions, focusing only on these under-represented regions and natural communities misses many of the most important reasons to protect Wildlands, and some of Vermont’s best opportunities to do so. Simply put, there is no practical, near-term way to recover large wild places in the more developed parts of the state, like the Champlain Valley or the Valley of Vermont. Large, wild forest are the “backbone” of biodiversity conservation, and Vermont only has a practical opportunity to protect such places in the relatively large forest blocks of regions like the Green Mountains and Northeast Kingdom, with public lands playing an integral role. Focusing only on ‘ecological representation’ obscures all the other, equally important reasons to protect wildlands, including climate mitigation, flood control, social benefits, and the necessity of protecting ecosystems on a large enough scale to actually let natural processes play out. The draft Plan also omits any discussion of the current age and condition of future Wildlands, which is a critical consideration for any plan that wants to recover old forests and their functions. The Plan needs to emphasize the unique opportunity that Vermont’s public lands offer for biodiversity conservation, particularly by being designated as ecological reserves. Public forests make up many of Vermont’s largest forest blocks and in many cases are already notably old and well-developed, with relatively low levels of non-native species, making them ideal candidates for wildland protection. Additionally, designating ecological reserves on existing public lands can be done immediately and costs little or nothing to implement — as far as Standing Trees can tell, taxpayers would likely realize direct, net savings by designating more public Wildlands. As a starting place to make the most of the opportunity to protect, large, wild, public forests, the Plan needs to map all contiguous blocks of natural habitat that meet the minimum preferred patch sizes for Old Forest restoration in VCD (at least 4,000 acres across the Green Mountains and Northeast Kingdom and at least 500-1,000 acres in more developed regions like the Champlain Valley) particularly those that fall into VCD “highest priority forest blocks.” The Plan should list these mapped parcels as high priorities for ecological reserve protection.
   

3. ANR and VHCB need to correct the inventory so that conserved lands are properly counted. We have said this many times, both in-person to ANR and VHCB staff, and in previous rounds of written comments — the Act 59 inventory completed in 2024 gives Vermont ANR credit for Wildlands that lack any legal protection whatsoever, and also falsely counts agricultural land that does not contribute to biodiversity conservation. This accounting trick will detract from necessary policy changes and investments in Wildland protection, and needs to be corrected in the final Vermont Conservation Plan.
   

4. The Act 59 Conservation Plan must present alternatives and analyze the cost, benefits, and practicality of different ways to get to Act 59 goals. Currently, the draft Plan says nothing substantive about the cost, practicality, or timeliness of different ways of meeting the Act 59 goals. Some actions, like private lands acquisition, could proceed slowly and at a relatively high cost. Other actions to promote biodiversity, such as designating Wildlands on existing public lands, can be done almost immediately, with numerous co-benefits and at little to no cost to the public. As a starting point, the Plan should compare and contrast the economic benefits of extractive uses of public lands vs. the ecosystem service benefits of public lands, as we recently analyzed in an expert report. What are the benefits to Vermonters in terms of clean water, carbon sequestration and storage, biodiversity conservation, and recreation when public forests are allowed to grow old? The Plan should also include specific alternatives that expand Wildlands above the 10% minimum goal for old forests restoration established in VCD. VCD is clear that this 10% goal is just a minimum, and the Plan needs to explicitly acknowledge that fact, and discuss the benefits that would come from expanding Wildlands across as much of the landscape as possible. Old, natural forests are the habitat in which nearly all of Vermont’s native terrestrial species evolved, and continue to be able to provide unparalleled biodiversity, clean water, climate, and ecological resilience benefits. The Plan should acknowledge this scientific fact, and put forward alternatives that seek to maximize the extent and benefits of Wildlands conservation.

We hope you will join us in making sure that wild public lands get the attention they deserve in the Vermont Conservation Plan. Join us on March 18 in Middlebury or online, and submit written comments by March 31. 

Thanks as always for taking action for our public lands!

P.S. For more background on how we got to this point in the Act 59 process, check out our previous blog on this topic (with a link to the complete, detailed comments Standing Trees submitted to VHCB in November 2025) and this StoryMap made by Middlebury College students, which lays out the wonderful opportunity that Act 59 provides for public lands and old forest recovery.