Secretary Perdue Talks Trees

Yesterday USDA Secretary Sonny Perdue made an unprecedented and necessary appearance before the House Appropriations Subcommittee on Interior, Environment and Related Agencies (the Forest Service is a “related agency”) to explain the Forest Service’s proposed FY 2018 budget. “Unprecedented” because never before had a USDA Secretary appeared before this subcommittee. “Necessary” because never before did a new administration have only one USDA political appointee in place by budget time.

Here are my takeaways from the hearing.

1) Secretary Perdue is glib and personable. He’s also an experienced and crafty politician who is not above fudging the numbers. When committee members challenged him on proposed steep cuts in the Forest Service’s budget, he replied that money to manage the national forest system would go up 16%. What he didn’t say is that this increase is due entirely to shifting over $350 million in fuels treatment from the wildland fire account to the national forest system account. Compared to FY 2017, the national forest system budget actually takes a 7.5% cut, as shown below:

2) Chief Tidwell will be looking for a new job. If Perdue’s body language towards the Chief wasn’t enough of a hint, a committee member thanked him for his years of service at the hearing’s end.

3) Senator Hubert Humphrey is feeling unsettled in his grave. Humphrey, the key architect of the National Forest Management Act, exhorted in 1976 that “The days have ended when the forest may be viewed only as trees and trees viewed only as timber.” Perdue said national forest trees are “crops.”

4) Congress doesn’t understand why or how the Forest Service got into its profligate wildfire spending mess. “Why” is because timber money dried up 25 years ago. “How” is because it can. The bureaucracy needs fire money to pay the agency’s overhead, aka, “cost pools.” Does Perdue get it? No. So far, he’s parroting former Secretary Vilsack’s plea for even more firefighting dollars.

A Deeper Dive into Trump’s Forest Service Budget

The take-homes from Trump’s first Forest Service budget suggest a significant shift in how this administration views the Forest Service.

Timber sale levels will go down modestly. With the Forest Products line item funded at a no-change level of $360 million, I predict sale levels will remain below 3 billion board feet (notwithstanding a stated “target” of 3.2 bbf) and the increases under the Obama administration (from 2.5 bbf in 2008 to 2.9 bbf in 2016) will reverse due to cost inflation.

Former Secretary Vilsack’s “all lands” approach is dead. “All lands” called for “using all USDA resources and authorities, in collaboration with NRCS, to sustain the entire matrix of federal, state, tribal, county, municipal, and private forests.” Trump’s vision is narrower. To justify zeroing out Urban Forestry, Open Space Conservation, Forest Legacy, and the Collaborative Forest Restoration program, USDA’s “focus will be on the maintenance of the existing National Forest System lands.”

Law enforcement,, which is small potatoes in the Forest Service, is the only program area that sees a budget increase (2%) over last year. Most everything else (e.g., fish and wildlife, livestock, minerals) faces an 11% cut. Forest planning will slow even further, hard as that is to believe, as planning not only faces the same 11% cut, but has to fight with inventory and monitoring functions (which spend almost four times as much money) for its piece of a smaller pie. Insofar as planning makes policy, don’t expect any new ones anytime soon.

Hazardous fuels treatment faces a 7% cut and a sharper focus to treat “priority areas near communities that reduce risk to communities and firefighters and increase resilience of forests to catastrophic fire.” It’ll be interesting to see if managers get the message to stop wasting money treating fuels in the backcountry.

Whatever rebuilding the nation’s infrastructure may mean to Trump, the Forest Service isn’t going to have a seat at that table. The budget calls for a 73% cut in capital improvement and maintenance, including zeroing out the Legacy Roads and Trails program that pays for replacing fish-blocking culverts. Trail maintenance will drop from $77 million to $12 million, so visitors should be prepared to scramble over downed trees and be proficient with maps and GPS as disappearing trail signs are not replaced.

As for roads, which are slated for a 56% funding cut, the budget’s nostalgia for the good-old-days envisions timber sales, salvage no less, paying for road up-keep. Maybe the reimposition of tariffs on Canadian lumber will boost Forest Service stumpage prices, but I wouldn’t bet my house on it.

Last, but not least, Forest Service research is slated for a 16% budget cut from FY 2017 levels. The only logic to the specific cuts I can see is that the Forest Service will spend a little more on counting things like trees, i.e., inventory, and a lot less on basic science.

In sum, this budget narrows the Forest Service focus to taking minimal care of its own land. The Heritage Foundation is happy. Is anyone else?

TRUMP’S FOREST SERVICE DENIES CLIMATE CHANGE!!!

The smoking gun that proves Trump’s Forest Service now denies climate change! Compare Obama’s FY 2017 Budget Justification:

“Agency operations and assets must become more resilient to the impacts of a changing climate so we can continue to provide a high level of service while caring for the National Forest System lands.”

With Trump’s FY 2018 Budget Justification:

“Agency operations and assets must become more resilient to extreme weather so the agency can continue to provide a high level of service while caring for the National Forest System (NFS) lands.”

Gotcha!

A Steady Hand in the Storm

Flying under the radar, especially when piloted by a savvy and experienced hand, is the key to financial survival in the Trump administration. Although OMB’s new FY 2018 budget is dead on arrival in Congress, much of the Forest Service may wish it isn’t. The Forest Service’s bottom-line is slated for a $1 billion cut compared to FY 2017, but $800 million of that cut comes from zeroing out the FLAME wildfire suppression reserve fund. The Forest Service knows that Congress always makes up the difference in subsequent appropriations if it overspends on firefighting.

Trump’s budget calls for increasing national forest system spending by 6%. Challenge for the reader — Is there another domestic, discretionary federal agency that receives such generous treatment in this most fiscally conservative budget in modern history?

The balance of the cuts comes from the expected sources. Forest Service Research and State and Private Forestry each get hammered by 20%. Rounding things out, Capital Improvement & Maintenance, aka “infrastructure,” gets slashed; and, predictably, so, too, does land acquisition.

Bottom line? In this new era of savaging discretionary domestic spending, the Forest Service makes out like a bandit. Corollary — who needs a permanent Undersecretary of Agriculture when you’ve got D.C. at the helm?

Wood Stoves, Pollution and Climate Change from the New Scientist

This article in New Scientist (UK-based) is a bit of a public service announcement, or item of curiousity, for wood stove owners. It’s also interesting how they look at the climate effects.

The New Scientist article is mostly about pollution from wood burning in cities (London), but also speaks about indoor pollution.

The trendy log-burning stoves producing much of this pollution are marketed as a source of renewable energy that can cut fuel bills while helping reduce global warming. But recent findings suggest they pose a serious threat to the health of their owners, and are also accelerating climate change in the short term.

If nothing is done to discourage log burning in homes, it could become the biggest source of air pollution in cities like London. In the UK as a whole, wood burning is already officially the single biggest source of an especially nasty form of air pollution.

Indoor smog
Press-Kristensen has been measuring that pollution inside homes in Copenhagen. In three out of seven tests done so far, he has found very high levels. In one home with a modern log-burning stove, he found particulate levels several times higher than the highest ever recorded outdoors there (see diagram, above).

So do the health impacts outweigh any climate benefits? Astonishingly, there might not be any climate benefits, at least in the short term.

Burning logs is often touted as being carbon-neutral. The idea is that trees soak up as much carbon dioxide when growing as they release when burned.

In fact, numerous studies show that wood burning is not carbon-neutral, and can sometimes be worse than burning coal. There are emissions from transport and processing. Logs are often pre-dried in kilns, for instance.

Burning wood also emits black carbon – soot – that warms the atmosphere during the short time it remains in the air. Most studies ignore this, but Mitchell and Forster calculate that over 20 years – the timescale that matters if we don’t want the world to go too far above 2°C of warming – soot cancels out half the carbon benefits of all wood burning.

For home wood burning, the figures are even worse. “On a 20-year timescale, wood stoves provide little or no benefit, but they do on the 100-year timescale as they remove some of the long-term warming effect of CO2 emissions,” says Forster.

Press-Kristensen’s calculations show much the same thing. And both sets of findings almost certainly underestimate the problem, because they assume wood burning is carbon-neutral.

Defenders of wood stoves point out that there is a lot of uncertainty about how much black carbon is emitted when wood is burned and how large its effect is. Patricia Thornley of the University of Manchester, UK, thinks we need more real-world measurements before coming to conclusions.

But the uncertainties cut both ways. For instance, the effects of black carbon can be amplified if it is deposited on snow and melts it, exposing dark land that absorbs more heat. It’s possible soot from wood burning is contributing to the fall in spring snow cover in Europe, but it’s very hard to study.

More research is needed to pin down the precise climatic effects of wood burning, which can vary hugely depending on factors such as the source of wood and where the pollution goes. What is clear, however, is that burning logs in homes in towns and cities is not the best use of the wood we have.

It produces more pollution than wood-burning power plants that can be fitted with expensive filters, it produces that harmful pollution where lots of people live, and it has the least climate benefits, if any. “If we are going to burn biomass to meet climate targets, then we ought to do it in big, remote power stations,” says Martin Williams of King’s College London, who is studying the health impacts of the ways the UK could meet its climate targets.

Most researchers say it isn’t their role to make policy recommendations, but it would be best if cities like London discourage private wood burning before it becomes an even bigger health problem. At the moment, all the focus is on diesel vehicles.

Press-Kristensen doubts governments will ban wood-burning; France recently backtracked on a proposed ban on open fires, for example. Instead, he proposes installing heat sensors in chimneys and taxing people when they burn wood, with the level of tax depending on how polluting the appliance is.

Most importantly, governments must not ignore health impacts when deciding climate policies, says Press-Kristensen. “I like fires, but I have to say they are as polluting as hell,” he says.

Thinking of getting a wood-burner?

Wood-burning stoves are touted as an eco-friendly way to heat your house cheaply. But tests now show that even new, properly installed stoves can produce dangerous levels of outdoor and indoor pollution (see main story). What other options are there?

Consider instead

Stick with gas or oil for heating, and spend your money on insulation. Get a heat pump if you can afford it

Fake it

You can get the same cosy feeling from a log-effect electric or gas fireplace, the best of which are hard to distinguish from the real thing

Already have a wood-burner?
Here’s how to minimise its effects:

Don’t burn scrap wood

Scrap wood or painted wood can release highly toxic substances such as arsenic when burned

Burn wood that’s just right

Burning dry wood with a moisture content of about 20 per cent minimises pollution. But if wood is wetter or drier than that, pollution increases

The italics are mine, since these folks are arguing for big filtered biomass plants instead. Also note that the better health and climate choices promoted here are natural gas- yes, natural gas, which we discussed in the previous post. Most of us probably get our wood from not too far away, so the climate impacts of our wood include driving our truck there and using our chainsaw, and possibly increased food and alcohol consumption to replace the personal energy used. Most of us probably live in rural areas, so are not contributing to city pollution. But the indoor pollution observations are interesting and potentially scary. For those who are interested, this EPA site called Burnwise looks like it has just about as much information as anyone could want. Including this Q&A:

Are gas stoves cleaner than wood stoves or pellet stoves?
Gas (whether you use natural gas or propane) emits less soot and other air pollution.

I’d be interested in any experts out there who could related our EPA wood stove air quality standards to the European ones.

Locals Short-Changed by Stewardship Contracts?

Greenwire article today:

Localities feel short-changed by program to thin overgrowth

A program that awards federal contracts to companies to thin overgrown forests has won praise from timber interests but is leaving localities feeling empty-handed.

Unlike most federal timber-harvesting operations, the stewardship contracts used by the national Forest Service and the Bureau of Land Management don’t devote any proceeds to the counties where the forests are located.

That may change with the 2018 farm bill, as counties and some forest advocates press Congress to add a provision giving counties what they’ve requested since the program became permanent in 2014: a quarter of the revenue from timber sales.

A 25 percent share would match the portion counties receive from most harvesting in federal forests.

“We believe this proposal will have widespread support,” said Steve Brink, vice president for public resources at the California Forestry Association, a trade group.

Counties with federal forests have seen sharp declines in timber revenue over the years, as the Forest Service takes down fewer trees. To help make up some of that revenue, Congress created the Secure Rural Schools program in 2000, which distributed funds to 4,400 schools in 775 forest counties, according to Sen. Maria Cantwell (D-Wash.).

The program expired in 2015, and Cantwell has urged the Trump administration to support its renewal. When it expired, the government returned to the old formula of giving counties 25 percent of timber proceeds.

Most of the affected counties are in California, Idaho, Montana, Oregon, Washington and Alaska.

Stewardship contracting appeared as a pilot program in 1999, with 28 projects around the country. Initially, lawmakers figured that the economic benefit of timber operations would reach localities and that revenue sharing wasn’t necessary, Brink said.

The government contracts for up to 10 years with companies for forest management projects that also include prescribed burns. The federal government receives some of the proceeds of sales, and that money goes back into future stewardship contracts.

The contracting program has had support from timber companies and forestry groups such as the National Association of State Foresters and the Pinchot Institute for Conservation, which monitors and evaluates the role of communities in stewardship contracting.

Most stewardship contracting is through the Forest Service, rather than BLM.

In 2013, the Forest Service issued 195 contracts, which allowed for the production of 865,000 tons of biofuel from the thinning of 171,000 acres and the reduction of hazardous fuels on 69,000 acres, the group American Forests reported. In total, 36,000 acres of forest vegetation and 72,000 acres of wildlife habitat were improved through these contracts.

More than one-fourth of all timber harvested from national forests was through stewardship contracting that year, American Forests reported, citing Forest Service data.

Uncertainty over the Secure Rural Schools program may be sparking the drive for a change to stewardship contracting, Brink said.

The program lapsed for a period in 2014 also, leading to an 80 percent decline in payments to counties, the National Association of Counties said in a letter to leaders on the Senate Energy and Natural Resources Committee in 2016.

NACo is lobbying for revenue sharing, as well as for renewal of the schools program. That’s one reason the group supports broader forest management legislation proposed by Rep. Bruce Westerman (R-Ark.), the “Resilient Federal Forests Act,” which devotes revenue to counties, said a NACo spokesman, David Jackson.

Revenue from stewardship contracting supports a wide range of county services, NACo said.

“NACo supports stewardship end results contracting projects as a tool to manage federal forests and rangelands, but only if they retain the historical receipts sharing with counties,” the group said in its platform of issues for 2016 and 2017.

Good Industry, Bad Industry: Colorado’s Oil and Gas Legal Case

Photo is from this article
https://collectively.org/article/weed-who-cares-if-its-legal-its-how-they-grow-it-that-matters/

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I’m posting this as an example of a court case that doesn’t involve the FS nor public land management but does relate to environmental policy. In some respects, it’s even odder than our FS cases as it apparently is looking to re-regulate an industry with new criteria.

This case, taken as reported by Colorado Politics here, is interesting in the light of environmental requirements for industrial activities.

In the 2013 request, the group of teenagers asked the state to deny drilling permits “unless the best available science demonstrates, and an independent third party organization confirms, that drilling can occur in a manner that does not cumulatively, with other actions, impair Colorado’s atmosphere, water, wildlife, and land resources, does not adversely impact human health and does not contribute to climate change.

The group of teenagers – with help from attorneys that represent environmental groups – took the case to Denver District Court, which sided with the state. The case was appealed, with attorneys arguing that the lower court misinterpreted the mission of the COGCC.

But why stop with the oil and gas industry? It seems to me that independent third party organizations could certify.. the outdoor industry (think of all that driving to outdoor sites), craft breweries, and so on. Perhaps Colorado should not have legalized marijuana until it met the same bar- but of course the marijuana industry uses lots of energy provided by … electrical utilities..using coal, natural gas, and renewable sources. Here’s an article about the environmental impacts of growing operations. And here’s one on the marijuana industry pushing back on control over pesticides -with potential serious harm to workers and users. Here’s another one on energy use of the developing industry- it’s really just getting started in many states.

The curious thing is that natural gas a better bridge to lower carbon energy sources than coal. It seems to me and many other that a bridge is necessary- and there are no obvious other contenders around. Energy is necessary, to raise cannabis and brew beer, and for a variety of other uses like running computers, growing crops, heating your house, and so on and I don’t see us transitioning immediately to carbon-free sources.

I guess that’s what’s odd about court cases as a method for policy development- individual cases tend to be discrete and unique (and in this case related to the mission of the Oil and Gas Commission), whereas “what kind of activities will Colorado allow that impact the environment” is a much broader question. It’s one, in my mind, better settled by open dialogue among the people and their elected officials.

U.S. Forest Service’s Northern Region has met 89% of their timber sale volume target over the past 15 years

If you listen to most western politicians – regardless of political party – talk about the U.S. Forest Service’s timber sale program you’ve likely heard them describe it as a failure. Many of these same politicians give the general public the impression that next to zero logging is taking place on America’s national forests because of countless lawsuits from “extremists” and “obstructionists.”

The other day, to dig a little deeper into this issue, I contacted the U.S. Forest Service Northern Region’s public affairs officer. I told her I wanted to compare the annual timber sale volume attained by the U.S. Forest Service in Montana and north Idaho with the timber sale volume targets set by the U.S. Forest Service, which are based on the funding the agency receives from Congress.

After the Forest Service’s public affairs officer and myself shared a chuckle about how terrible the U.S. Forest Service’s websites are, especially if you want to explore some of these issues in more detail, I was directed to this website.

I was told, “Look at the Periodic Timber Sale Accomplishment Report (PTSAR) reports. The 4th quarter of each year is the final report for that particular fiscal year. Line T and Line U give the planned and completed targets.”

So, that’s what I did to come up with the chart above. There’s lots of ways to look at those numbers I suppose. One way is to say that overall, during the past 15 years, the U.S. Service in the Northern Region has attained 89% of their timber sale volume targets, which again are based on funding from Congress. 89% seems like a B+, if we were grading papers in school, and far from a failing grade.

Another way to look at those numbers is that in 7 of the past 15 years the U.S. Forest Service has attained between 94% and 117% of their timber sale volume targets. When is the last time you heard a U.S. senator or representative from Montana or Idaho celebrate and share numbers like this with the general public?

Also at the link provide by the Forest Service, there’s a section about “Uncut Volume Under Contract” and “Timber Sale Program Statistics.” That information was also very interesting to me, but I noticed that no link was provided. I was told by the Forest Service public affairs officer “Those links are disabled right now as the reports contained errors so we removed them.” I have to wonder what errors those reports contained and how long the errors were in those reports. I also have a sneaking suspicion that the timber industry objected to not only the specifics of what was contained in that “Uncut Volume Under Contract” report, but also perhaps objected to its presence in the first place. Hopefully the errors are corrected soon and the links go back up on the Forest Service website.

In March of 2015, the Flathead National Forest’s Joe Krueger was interviewed on Montana Public Radio about their on-going forest plan revision process. One question was specifically about the Flathead National Forest’s projected timber sale volume in their new forest plan. Krueger had this to say:

A big factor that constrains how much wood products is coming off the [Flathead National Forest] is our existing budget. So that number of 28 million board feet of timber that we’re projecting as our timber sale quantity is constrained by budgets.”

Which brings us back to those western politicians, especially the ones who hold the U.S. taxpayer’s purse-strings and divvy up the federal budget. While practically every time any of these politicians talk about logging on National Forests they will blame lawsuits from “extremists” and “obstructionists” environmentalists for the (supposed) lack of logging, when is the last time you heard the Montana or Idaho congressional delegation call on the rest of Congress to greatly increase the U.S. Forest Service’s timber sale budget?

Seems to me that since the U.S. Forest Service in the Northern Region has managed to attain 89% of their targeted timber sale volume over the past 15 years that our political leaders should be much more honest and share this fact with the general public, and perhaps if they want to increase logging on National Forests the politicians should look in the mirror and put money where their mouth is.

NOTE: This post has been updated to include the total annual timber sale volume target in CCF, in addition to the percentage of that volume that was attained in any given year. As you can see, the timber volume targets themselves have changed over time.

In fact, the 2016 target is 72% higher than the 2002 target. And in general, the target has increased steadily over the past 15 years. This should put the 89% attainment in even greater focus, as the U.S. Forest Service’s Northern Region has attained 89% of their steadily increasing timber sale volume targets over the past 15 years.

Also, corrected was incorrect date for FY 2006. Originally, I listed 44%, but upon further review that 44% was only the attainment for one national forest in the U.S. Forest Service’s Northern Region, not the total attainment for the region, which in FY 2006 was actually 76%. I apologize for the error, which was in part caused by the fact that for some reason the Forest Service chart for FY 2006 lead with the individual national forests, not the region-wide totals, as all the charts from the other years did.

Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States?

A new study recently published in ECOSPHERE, an open access journal, found “found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading.”

Here’s the Abstract, and again the full study can be viewed here.

ABSTRACT:

There is a widespread view among land managers and others that the protected status of many forestlands in the western United States corresponds with higher fire severity levels due to historical restrictions on logging that contribute to greater amounts of biomass and fuel loading in less intensively managed areas, particularly after decades of fire suppression. This view has led to recent proposals—both administrative and legislative—to reduce or eliminate forest protections and increase some forms of logging based on the belief that restrictions on active management have increased fire severity. We investigated the relationship between protected status and fire severity using the Random Forests algorithm applied to 1500 fires affecting 9.5 million hectares between 1984 and 2014 in pine (Pinus ponderosa, Pinus jeffreyi) and mixed-conifer forests of western United States, accounting for key topographic and climate variables. We found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. Our results suggest a need to reconsider current overly simplistic assumptions about the relationship between forest protection and fire severity in fire management and policy.

Trump’s Interior Nominee Tied to Arctic National Wildlife Refuge Scientific Fraud Over Oil, Says PEER

In the spirit of the goal of this blog being “to solicit broad participation from a cross-section of interests in a respectful atmosphere of mutual learning on topics related to the Forest Service and public lands policy”, here’s a press release from Public Employees for Environmental Responsibility (PEER). – mk

Washington, DC —David Bernhardt, Trump’s nominee for Interior’s Deputy Secretary, abetted the doctoring of scientific findings about effects of oil development in the Arctic National Wildlife Refuge (ANWR) in his first stint at Interior, according to documents released today by Public Employees for Environmental Responsibility (PEER). Bernhardt was the key aide to then-Interior Secretary Gale Norton when her office substantially rewrote official biological assessments to falsely downplay impacts of drilling before she transmitted them to Congress.

Back in May 2001, Senator Frank Murkowski, then Chair of the Energy & Natural Resources Committee, asked Norton for Interior’s official evaluation of the impacts of oil drilling on the Porcupine caribou herd in ANWR. Norton tasked the U.S. Fish & Wildlife Service (FWS) with developing answers. The resulting FWS findings were then rewritten in Norton’s office when Bernhardt, one of the few political staff in her office, served as Counselor to the Secretary and Director of Congressional Affairs.

The extensive changes made by Norton’s shop were extensive and all skewed one way by:

• Changing Numbers. While FWS noted “there have been PCH [Porcupine caribou herd] calving concentrations within the 1002 Area in 27 of the last 30 years,” Interior changed that to say “Concentrated calving occurred primarily outside of the 1002 Area in 11 of the last 18 years.” [emphases added]

• Ignoring Key Data. FWS reported that calving reproductive “pauses” (years that females do not produce a calf) is higher in developed areas in Prudhoe Bay than in undisturbed areas. Interior left these data out and instead stated that “Parturition and recruitment data do not support the hypothesis that oil fields adversely affect caribou productivity.”

• Spinning Absence of Data. Norton stated that “There is no evidence that the seismic exploration activities or the drilling of the Kaktovik Inupiat Corporation exploratory well…have had any significant negative impact on the Porcupine caribou herd,” but she omitted the FWS disclaimer that “no studies were conducted to determine the effects of the above activities on the PCH.”

“It appears Mr. Bernhardt shares an unfortunate affinity for alternative facts,” stated PEER Executive Director Jeff Ruch, noting that Bernhardt was a point person on both Arctic and petroleum issues when he was at Interior. “The Senate needs to thoroughly investigate his role in this blatant political manipulation of science before considering his nomination.”

In letters Bernhardt sent to Senators to contain fallout from PEER’s revelation of these falsifications, he sought to minimize the discrepancies, writing “we made a mistake in the letter” as if there was only one alteration. He later wrote that the FWS assessment had been “edited for responsiveness.”

“Interior is largely a science-based agency, necessitating a Deputy Secretary dedicated to scientific integrity over political spin,” added Ruch, who is asking the Senate to hold up confirmation proceedings until Bernhardt’s exact role can be determined. “It is beyond ironic that Mr. Bernhardt resurfaces at Interior just as the status of safeguards for the Arctic Refuge is revisited.”

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Read PEER’s letter to the Senate Energy & Natural Resources Committee

View the changes Interior made to Arctic assessment

Look at Bernhardt’s damage control letters to Senators

See the letter FWS transmitted to Norton

Compare how it emerged from Norton