Pew et al. Full Page Ad on Roadless

NOTE: THERE IS A DISCUSSION ON THIS SAME TOPIC ON THE HCN RANGE BLOG HERE. Some different kinds of comments than for NCFP readers.

In the Denver Post this morning, I saw the full page ad you see here to your right. I couldn’t figure out how to link to it, since it was an advertisement, but I did find out this on the web at Pew Environment.

Note that the Pew Charitable Trusts has on its webpage:
“The Pew Charitable Trusts is driven by the power of knowledge to solve today’s most challenging problems. Pew applies a rigorous, analytical approach to improve public policy, inform the public and stimulate civic life.”

What I found questionable about “knowledge” was the statement:

Yet your administration is considering a plan that would open up many of these areas to new drilling, expanded logging, and coal mining.

New drilling

No one has yet explained how the proposed Colorado rule opens new areas to drilling.. it would be interesting to have that discussion here, if someone can explain the thinking.

“Expanded logging”

Is the “logging” intended to mean fuel treatments in the WUI?

If so, many may be interested to know that individuals from some of the same groups named in the advertisement (when arguing why state rules were not needed) have said that the 2001 allows the same “logging” under the exception:

To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic
wildfire effects, within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period.”

It seems intellectually inconsistent to say, on the one hand, that fuels treatments are allowed under 2001, and then to later claim that fuels treatments are “expanded logging” and only allowed under the Colorado Rule.

Aside : under 2001, “maintain or restore” fuels treatments are not restricted to 1/2 mile from communities, so it could be argued that the 2001 Rule, in fact, allows “expanded logging” compared to the Colorado Rule.

AND coal mining

Finally, the exception that allows temporary roads (2-3 years) to vent methane from underground coal mines (not exactly the same image as “coal mining”, but.. OK..) was allowed in the proposal on 16-20K or so more acres than allowed under the 2001 Rule on (I think) one roadless area.

The way the statement is made “open up many to drilling, logging and coal mining” without an “or” instead of an “and” would indicate (as the English language is commonly used) that temporary roads for methane venting would be allowed on “many” roadless areas. Since the usual idea is that it takes more than one to be “many”, this is also not a fact.

So there are three assertions and 0/3 are, strictly speaking,true. Doesn’t seem very like a very “rigorous and analytical” approach to me. Just sayin’ ;).

PS the Pew website refers to ” A letter from 520 leading scientists expressing concern about the Colorado proposal went to the administration in December 2009.” I remember one that was sent April 14, 2010.. (I wonder if there are really two?) that I posted this blog post about on Roger Pielke, Jrs.’ blog here.

18 Comments

  1. I think the fairest way to contrast the two rules would be to do a section-by-section comparison of specific rule language. There have to be some differences in the national roadless rule versus the proposed Colorado rule; otherwise, Colorado would not have gone through all the effort. We need an independent, dispassionate analysis from someone who does not have a vested interest in either outcome to really know for sure.

    • That’s a great point, Terry. There is a structural problem, though. No one who is not invested in some way is paid to do that kind of work. I like blogging and will do it as a hobby, but actually doing the section by section analysis is something that I would expect to be paid to do. You’ve gotta draw the line somewhere! Maybe there is a not-for- profit somewhere that would fund people to analyze issues in an objective and dispassionate way.

      If anyone finds an NGO with a grant program that supports this kind of objective analysis, and you think actually walks the talk, please let me know.

      P.S. Maybe it’s not possible to be “objective.” It is possible to have coherent, respectful discussions about the facts and our differing interpretations.

      • I will confess that it is probably impossible to be totally objective. I do not claim to be objective or dispassionate;)
        I worked at one point on discussions between USFS and the state of North Carolina on a possible state petition roadless rule. They eventually opted to wait for court decision on national rule but we had several iterations of a draft state rule that were crafted in a sectiom by section manner directly contrasting clinton rule with draft state rule. I have to elieve something like that (without analysis or bias) is already somewhere in the agency record on the Colorado rule.

      • Sorry for the typos in the previous post. I should know better than to post anything before my first cup of coffee in the morning. What I meant to add to my previous comment was that once everyone agrees on the specific differences in rule let’s by all means have a spirited values laden debate on the interpretations of that language, This discussion should then rightly include both environmental effects on resources as well and social and economic effects on potentially competing individual interests, both of which are valid considerations.

  2. Sharon, you have to remember there is a technical side to this and an emotional and political side.

    The emotional and political side of it equates to a propaganda war, in the crudest terms. The ad is a manifestation of that side of the debate, designed to sway and mobilize public opinion. In my mind, that doesn’t justify inaccuracies, but I’m just sayin …

    I haven’t read through all the technical and legal analysis that Pew has done on the roadless rule, but I’ve seen enough to know that there is a lot of information compiled by citizens and environmental groups that is equally valid as the data compiled by the FS on the roadless rule. There is certainly room for genuine disagreement on a lot of the remaining questions.

    • I wasn’t questioning that there is room for disagreement. I’m just saying if you state that things are facts, and you state that your organization is rigorous and analytical, then you should be questioned on the accuracy of your statements (even if you are emotional and political). If you are a propagandist, just be upfront about it :). I’m all for truth in advertising.

  3. Once again, we see a battle between the preservationists and the conservationists. For some, Roadless status is hopefully a short stop on the way to Wilderness status, as only that is adequate protection for wildlands, in their point of view. Does rigidity offer more “protections” and benefits than flexibility? If the forests in those areas are already dead lodgepoles, how can “expanded logging” in Roadless Areas even make a buck for the evil corporate tree murderers?? (How’s that for sarcastic rhetoric?)

  4. Pew’s ad is correct to criticize the “many” roadless areas that will be degraded through the coal mining loophole in the proposed Colorado “Roadless” Rule.

    The 20,000 acres of roadless lands likely to be open to coal mining in the Colorado rule include the following four roadless areas as identified on the Forest Service’s own maps: Sunset and Flatirons (both West of Paonia), Pilot Knob (northwest of Paonia and a across a state highway from the previous two), and Falttops/Elk Park (north of Paonia). You can check this by downloading the 2011 Colorado Draft Roadless Rule map packet and looking at the map entitled “Statewide and Other Maps – North Fork Coal Mining Area.” Bill Koch’s Oxbow Mining company is also pushing hard for the rule to allow road-building in a fifth roadless area (Currant Creek), and Oxbow may get what it wants. So “many” is accurate.

    And regardless of the number of roadless areas at stake, these places will be hammered. The Forest Service has already approved a coal lease in the Sunset roadless area that will result in 6.5 miles of new road in a 1,450 acre area under the Colorado Rule – more than 2 miles of road for every square mile. Add to that the 48 one-acre well pads bulldozed for methane drainage wells – or 16 wells per square mile. These impacts will be spread so that the entire 1,450 acre will be criss-crossed with a spider-web of roads and development, and those developed areas will be denuded of vegetation.

    If West Elk’s activities just outside the roadless area are any indicator, this is not a light-on-the-landscape operation. Hill-sides are carved out as well as ridge-tops. See http://www.flickr.com/photos/wildearth_guardians/sets/72157628013512966/.

    The draft Colorado rule does not limit the roads to 2-3 years on the landscape. When you add in the time roads will be built and maintained for coal exploration, and the roads may be in existence for years longer.

    And reclamation will take years if not decades, especially where (as in the Sunset roadless area), road bulldozing for coal mines will occur in mature aspen and conifer forests at 8,000 feet elevation where growing seasons are short. Pre-mining conditions won’t be restored for many decades.

    These types of impacts are why the Forest Service itself concluded in the 2001 Rule that the impacts of temporary roads were about the same as those for permanent and barred both temp and permanent roads in roadless areas.

    In sum, the Colorado Roadless Rule EIS projects 34 more miles of road will be built for coal mines in roadless areas than under the 2001 National Roadless Rule.

    And that’s why the 2001 Roadless Rule is better for roadless areas than the weaker Colorado Rule, and why President Obama should nix the Colorado Rule.

  5. Here’s my response to Ted’s and other comments on the HCN blog.

    Jeremy, and Ted- It’s great to have these kinds of discussions out in the open in public. Thanks for participating.

    Jeremy- I didn’t say it wouldn’t impact any given roadless area. I said it wasn’t impacting MANY roadless areas.
    You stated that “These are not 2-3 year impacts. Methane venting literally turns the land above the mine into a gas field.” I don’t know what you mean by a “gas field” but there are temporary roads, as on the video, and well pads. Those are reclaimed after they are used.
    I have a photo of a reclaimed well pad..here on the NCFP blog.. if the roads and wellpads are reclaimed after their use for 2-3 years, how long does it take to get back to this state? The point is that roadless areas are impacted but through time they will return to their previous condition.

    Ted- I don’t think four is usually considered to be “many”. The actual statement from the advertisement was ” open up many of these areas to new drilling, expanded logging, and coal mining.“ Here’s the definition of “many” from Merriam –Webster:
    1. consisting of or amounting to a large but indefinite number
    2. being one of a large but indefinite number

    Now, in this case, the number is certainly not “indefinite.” Of course, perhaps if it were a total of 7 roadless areas, you could say “many of the 7” and mean 4.

    However, as it says in the proposed Rule, Section 294.49 List of Designated
    Colorado Roadless Areas There are 363 Colorado Roadless Areas in the proposed rule; an increase
    of 18 CRAs from the July 2008 Proposed Rule.

    I don’t think most people would think 4/363 is “many.”
    You also said “These types of impacts are why the Forest Service itself concluded in the 2001 Rule that the impacts of temporary roads were about the same as those for permanent and barred both temp and permanent roads in roadless areas.”
    But your organization has also argued that pipelines, such as the Bull Mountain pipeline, were the same in environmental impacts as temporary roads. Yet, the courts seem to think that those (pipelines) are allowed by the 2001 Rule, and the Colorado Rule places restrictions on them. So here it seems that the Colorado Rule is more protective against these impacts of what you argued were, in fact, “temporary roads” .
    You also stated that:
    “In sum, the Colorado Roadless Rule EIS projects 34 more miles of road will be built for coal mines in roadless areas than under the 2001 National Roadless Rule. And that’s why the 2001 Roadless Rule is better for roadless areas than the weaker Colorado Rule, and why President Obama should nix the Colorado Rule.”
    According to your statement, of all prohibitions and restrictions in the Colorado Rule, the only one of importance are the miles of road in the North Fork Coal Area. Somehow allowing temporary methane drainage wells and roads on 20,000 acres outweighs including in Colorado roadless 409,500 acres left “unprotected” in the 2001 Rule.

    Peter Hart-

    The question is not “will there be more drilling” but “will there be more drilling than that allowed under the provisions of the 2001 Rule?”. That is a key distinction. When the advertisement states:

    “Yet your administration is considering a plan that would open up many of these areas to new drilling,”

    It implies that there will be more drilling than allowed under the 2001 Rule.
    The fact is that the Colorado Rule does not allow roads for development of new leases.

    If the italicized statement is intended to be about the so-called “gap leases” issued during the time period that the 2001 was not in effect (enjoined or other reason), then the legal question is simply if those leases were issued legally with the stipulations they had at the time or not. This is how I think about it. I’d like to know where your views differ.

    If the courts decide that a specific lease that allowed roads was issued legally, then they are grandfathered in under both rules.

    If the courts decide that a specific lease should have been issued with no-roads stipulations then the lease is allowed no roads under either rule.

    If the lease were issued with the stipulation that “current regulatory restrictions apply with regard to roads” then both 2001 and Colorado are the same in saying “no roads.”

    So there must be a specific situation that you are thinking of where you think that if the Colorado Rule were in place, existing leases would be treated differently than under 2001. It would be helpful to know which situations those are, and to how many acres that situation applies.

    All: here is a photo of a restored MDW. It could be argued that the grassy patch provides diversity in vegetation that leads to resilience..;) .

  6. Wow, the Forest Service is saying that we should hack out low elevation oak scrub forest in the North Fork Valley for methane drainage wells, in turn wasting millions of dollars of public minerals and releasing millions of tons of greenhouse gases, to provide “diversity.” This is a dark and disappointing day for public land and resource stewardship.

  7. If the point of this photo is to show that elk will graze in clearcuts, I’ll concede the point.

    If the point is to illustrate that grass will, in some places, eventually grow where methane drainage wells have previously been bulldozed, I’ll concede that too.

    But the question at hand is whether the draft Colorado Rule is as protective or more protective of roadless areas than the 2001 Roadless Rule, as the Agriculture Secretary promised it would be.

    No pretty picture can obscure the fact that the Colorado Rule is far less protective when it comes to coal mining.

    The Colorado Rule’s coal mine loophole will result in one such clearcut pictured above every 40 acres throughout 1,450 acres of the Sunset roadless area, and perhaps throughout the 20,000 acres of roadless lands open for new coal mines. Road construction and methane drainage well clearcuts will rip down mature conifer and aspen forest which will take decade upon decade to grow back. That’s not to mention the damage from 30+ miles of additional roads in the first 15 years that the coal loophole will permit on Colorado’s roadless lands.

    So, again, the Pew ad is truthful that the Colorado rule will open up roadless areas to coal mining.

  8. My point was that Pew got it wrong on the “many” roadless areas, not that “some” roadless areas or a “few roadless areas”. My point was that their website says they are rigorous and analytical, but that’s not what I observe.

    I never said that roads and methane drainage wells don’t have impacts. Of course they do, but the impacts are not permanent and ultimately it will look similar than the rest of the roadless area. Yes, it will take decades. But that affects 20K or less of the 4.2 million or so acres in the Rule.

    I think the difference in our thinking is that you are thinking if anything in the Rule is less protective than 2001, then the whole Rule is less protective. While I am thinking that there are some things that are more protective and some less protective, and the idea is that on the balance it is more protective than the 2001.

    The idea of “more protective” could mean either interpretation, I think.

  9. Here is what Pew says about itself
    “The Pew Charitable Trusts is driven by the power of knowledge to solve today’s most challenging problems. Pew applies a rigorous, analytical approach to improve public policy, inform the public and stimulate civic life.”

    I agree that a rigorous analytical approach can improve public policy, but it requires being careful (and accurate) with facts and words. Several would have been fine but not carried the same emotion; 4 out of 363 would have been accurate.

    I believe in carefully using the English language to illuminate points of view and differences in a respectful way. English-abuse is no more desirable than fact-abuse.

    PS I admitted I was wrong about the number of roadless areas (4 not 1, I thought the two divided by a road were actually one area, and I didn’t see the 500 acres in another 70,000 acre roadless area). Ted was helping me refine my thinking, and for that I am grateful. Not so clear the Pew is as willing to acknowledge inaccuracies.

  10. No one is asking the question of whether those 4 Roadless Areas actually have existing roads. Chances are, if they are rich in coal, they already have existing roads in them. Another question is, if they are rich in coal and already have roads, why were they included as “roadless”?

  11. Foto- I don’t know the answer to your question. I have heard (but don’t know it to be a fact) that some roads for coal were deemed “administrative” and not necessarily “system” roads so may not have been counted during the pre 2001 mapping (would appreciate hearing from anyone who knows more about this).

    However, a person could easily google-earth the areas in question and take a look for him or herself. The maps are on the web as far as I know and there is a google earth app here. I think it is way cool.

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