• Considering the landscape scale context of the Worcester Range is an essential starting point for management, and should guide all decision-making during development of the plan. 
• This land has been designated as “Highest Priority Habitat Block” and “Highest Priority Interior Forest Block” and it is a regionally significant  area for habitat connectivity. 
• We commend ANR for bringing some of the best available science, including inventories of natural communities, to bear in making management decisions. In particular, we found the natural communities inventory and associated descriptions to be incredibly helpful and we applaud the ANR for basing management decisions around the ecological significance of natural communities.

• The existing 4,057 acre Natural Area in the WRMU and the newly proposed 5,512 Highly Sensitive Management Area (HSMU) are both important designations that support natural conditions, headwater protection and old forest conditions.  
• Act 59, or the 30×30 conservation bill passed last legislative session, identifies Ecological Reserves as a conservation strategy to achieve community resilience and biodiversity protection. 
• We believe the plan’s newly proposed 5,512 acre Highly Sensitive Management Area should be consistent with the Ecological Reserve category in Act 59, but in order to support durable protection, we recommend designating the HSMU as a Natural Area.

• Active management outlined in the plan amounts to an average of 139 acres per year, over a 20 year period. 
• We believe that showcasing ecologically-based silvicultural treatments – specifically uneven-aged silvicultural systems – can promote ecological value and ecosystem services, while also supporting locally sourced forest products. 
• Forest gap sizes should be kept to less than ½ an acre, timing of harvests should be outside of songbird breeding season, and there should be additional detail on invasive species management scenarios. 
• We believe ANR should provide more detailed management plan information on specific harvesting areas within the WRMU to help support understanding of management and better inform public input.

• We appreciate that the plan would manage 15,600 acres of uninterrupted forest and recommend management practices that would maintain habitat connectivity and work to restore forest complexity and species diversity. 
• We commend forest management efforts that would maintain the current mosaic of unfragmented interior forest across the landscape, and from there, where lacking and opportunity exists, work to restore forest complexity and species diversity at various resolutions and scale.
• We value a balanced approach that works to protect diverse and rare conditions, where they exist, through passive management, but also feel that in some cases, active management (specifically, forest manipulation through timber harvests) can serve as an effective strategy that restores forest complexity vital for improved forest bird habitat and overall biodiversity. 
• We see an opportunity for ANR to demonstrate this balance and show the role that well thought out, science-based, active management can play in artificially accelerating the development of old forest conditions in the places where these conditions once existed. There is a need for accelerating the creation of old forest conditions because the climate is changing and birds are disappearing at a rate faster than the forest has time to naturally develop into old forest and the conditions necessary to address and respond to these more immediate existential threats. 
• Young forest, or early-successional habitat that occurs 1-20 years after a disturbance, is vital habitat for encouraging biodiversity and we appreciate the plan’s goal to increase the current amount; however, young forest areas that are greater than 1 acre should account for less than 312 acres total / no more than 2% of the total WRMU at any given time.

• The plan should provide more specific information about how land management would address the importance of maintaining water quality and supporting stream function for climate resilience. 
• The plan should also include more specificity around how it will address pollution requirements for Lake Champlain, mitigate impacts to stream health, restore water quality and reduce flood risk to downstream communities.

• We do not support the development of new permanent roads in the  WRMU. 
• If new roads are being proposed, the public should have an opportunity to weigh in on the location and extent of road building.

We support efforts in the plan to disperse some of the recreational impacts and contain growth in areas that already have a density of trails.