Salvage: 250 Acres

The NCFP blog has been quiet of late. Maybe a discussion of salvage logging will stir things up. This brief article notes that 250 acres of 5,607 acres burned on the Gifford Pinchot National Forest are proposed for salvage. Instead of debating the pros and cons of salvage, I’d like to hear your thoughts on the size of the project. Does 250 acres — the maximum that qualify for a a categorical exclusion under HFRA — justify more than a year of project scoping and planning? And the inevitable objections, etc.?

Excerpt and link to scoping letter below….

Fire salvage logging proposed at Mount Adams

By The Columbian

Published: December 1, 2015, 9:12 AM

TROUT LAKE — Comments are being sought by Dec. 20 on a proposal by the Gifford Pinchot National Forest to do salvage logging on approximately 250 acres that burned in this summer’s Cougar Creek Fire.

The five proposed salvage units are roughly between Aiken Lava Bed on the west and Snipes Mountain and Bunnell Butte on the east.

The fire burned 54,000 acres of which 5,607 were on the Gifford Pinchot National Forest. Almost 3,000 acres of mature forest burned on Forest Service land.

A Forest Service team will evaluate the proposal during this winter. A decision in expected by late winter 2016.

For more information, call Ben Hoppus, team leader of the project, at 509-395-3405 or email him at bhoppus@fs.fed.us.

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From the scoping letter:

Purpose and Need

The primary purpose of this project is to recover the commercial value in the dead and dying trees and to offer them as wood products. Revenue from those wood products would support local jobs and the economy. Following fire, wood quality can degrade rapidly, and trees lose their value as lumber. For this reason, any commercially viable harvest needs to occur as soon as possible. This project would also enable the acceleration of reforestation to promote an assemblage of tree species that is more resilient to natural disturbances.

Proposed Action

The proposed action is to salvage dead and dying trees on 250 acres of the area burned by the Cougar Creek Fire. To fit the salvage definition under the NWFP ROD, stands were chosen that were greater than 10 acres and experienced a stand-replacing disturbance. Most of the trees in these stands have died or will die as a result of the fire.

Trees expected to survive and existing large downed logs would be left. A portion of the standing dead and dying trees, including all ponderosa pine snags, would be left at levels to be determined to provide habitat for snag-dependent wildlife. Snags may be left in patches to better emulate natural conditions.

15 Comments

  1. How do we know that there will be “inevitable objections?” [Inevitable means “certain to happen; unavoidable.”]

    Do we know what percentage of timber sales on the Gifford Pinchot National Forest in recent years were met with official objections? How about nationally across the entire U.S. Forest Service system? To use the word “inevitable” one would have to assume that 90% to 100% of all proposed timber sales get an official objection, right? Is that even close to reality?

    Also, keep in mind that Congress changed from a post-decision ‘appeal’ process to a pre-decision ‘objection’ process. So, for those who complain about a pre-decisional objection being filed, what would your suggested solution be? That members of the public should simply stop following the public participation procedures set up by Congress? Thanks.

  2. I personally believe the “purpose and need” statement was a good approach, but, not at all adequate. A needs statement should always start by describing the forest needs, health and diversity, not the economic benefits. Secondly, you need to define the results of the “do nothing” alternative. What can we expect if we don’t treat the area? The purposed action or treatment must improve the forest conditions when compared to the “do nothing” action. Describe the improvements in the needs statement. Economic benefits should be added at the end if they are important.

  3. As is the norm for comments, Steve’s request to focus on the justification (rationality) of taking a year for the presale action on a 250 acre sale has been ignored. Instead we have a debate on “inevitability” and on the relative importance of impacts.

    To respond to Steve’s question – this Forest Service scoping letter (comments will be considered by a Forest Service interdisciplinary team”over the winter”) for a 250 acre salvage sale reveals the total imbecility of the Forest Service’s (mandated by congress) decision making process. The 2015 fire season resulted in about 10 million acres burned nationwide. Nearly a million of these acres were in the state of Washington. Here we have a forest that launches an investigation as to desirability of salvaging 250 acres!

    This paralysis by analysis (aka rearranging the deck chairs) is typical of a system that has resulted in a proud 10 year record of harvesting 5% of the annual growth on national forest unreserved timberlands in Montana while 6 times that volume died (not including the Okanogan & Carlton Complex incidents, and other 2015 large fires) .

  4. The old limit for salvage CEs was 1 million board feet. A court determined that limit to be arbitrary and illegal, so the FS changed it to a 250 acre limit, which ironically usually results in more than 1 mmbf of volume AND it’s just as arbitrary. Wacky world!

  5. For whatever it’s worth….

    I just spent some time on the US Forest Service’s official “Objection Responses” page and looked at the official page for the Gifford Pinchot National Forest.

    If the Forest Service information in their own Objection Response database in correct, the entire Gifford Pinchot National Forest had:

    • “No responses available” for 2015

    • One “Objection Response” for 2014, for the Nisqually Thin project. Ironically, one of three Objections filed for that timber sale was from Tom Partin, President of the American Forest Resource Council.

    • “No responses available” for 2013

    I’m not sure if this means that the Gifford Pinchot National Forest has had a total of one project that faced an official Objection in the past 3 years, since Forest Service websites are famous for being out of date, lacking accurate information, etc.

    Certainly if anyone else has specific information, I’d be curious to see it. Thanks.

    Finally, to sort of address Steve’s original questions, perhaps the Forest Service doesn’t get adequate funding from Congress to complete a larger post-fire timber sale, beyond the 250 acre CE. Or perhaps current global economic forces and conditions means that the Forest Service is reluctant to conduct a bigger timber sale.

  6. Re-read the purpose and need statement after reading this background information that preceded it:

    “The area being evaluated for salvage is allocated as a Late-Successional Reserve under the NWFP.
    Salvage is permissible in the Late-Successional Reserve allocation under certain guidelines. Guidelines
    for salvage are described in the NWFP Record of Decision, Standards and Guidelines, pages C-13
    through C-16. The guidelines state that salvage should be “intended to prevent negative effects on late successional habitat, while permitting some commercial wood volume removal” (C-13). The ROD makes
    it clear that “planning for salvage should focus on long-range objectives, which are based on desired
    future condition of the forest. Because late-successional reserves have been established to provide high
    quality habitat for species associated with late-successional forest conditions, management following a
    stand-replacing event should be designed to accelerate or not impede the development of those
    conditions” (C-14).”

    Looks like a major a disconnect there, so I don’t think this is even a good candidate for a CE. It doesn’t appear to be consistent with the forest plan (at least under the 1982 regulations, subsequent activities “must be based on the plan”).

    The purpose and need also left out the most important purpose to the Forest Service – to meet the 250 acre requirement to qualify for a CE (which also has nothing to do with what the forest plan says). How about another example without all of these procedural problems?

  7. 250 acres out of 6,000 and the Forest Service is still afraid of litigation, or should I say very interested in following the law. It usually goes like this;
    First thing the FS has “Baer”, fire restoration money and are busy running around closing roads, some permanently, for the “publics” and for the Forests safety and health. Then maybe of field trip to the proposed area with the people of interests. Then scoping by the “team” at the FS. Then a opinion by the FS biologist resulting in over half of the project or more being eliminated and often resulting in a roadside hazard tree removal only. Then it goes for an opinion from F&W and gets sold maybe year or two or three later. (There are currently over 15 sales and over 100 million feet, on the Klamath NF, which represents maybe 1% of what burned in 2014, waiting for a opinion from F&W since early August.) This means that much of the second growth and white wood has become unmerchantable because of decay and insects damage by the time the timber is sold. The sale is then sold for hardly anything because of the risk of unmerchantable wood and all the other FS restrictions and requirements. Since a year or two or three has gone by and is of such small scope the enviros then don’t seem to object to much.
    These sales are so limited in the lay out, with all the snags, riparian and other restrictions that the biggest, best and most valuable trees are often off limits. And in general it is wondered if it is really worth anybody’s time and effort.
    Meantime billions are dollars are spent fighting these fires that destroy billions of dollars worth of resource and the surrounding rural communities remain backwaters watching their forests burn and rot away.
    Whether or not it is beneficial to the forest to salvage dead trees I don’t know. I do know that it does no harm to the forest. I know this by visiting sites of previous harvests. I do know that it helps in keeping the roads open and forests safer so we can manage and enjoy our National Forests. I do know that it make sense to the economic and social health of our communities to aggressively harvest these dead trees. I do know that some of these dead trees can live on as homes and the beautiful wood products that people can enjoy for generations.

  8. The FS should be given nominal credit for being honest — ie 250 acres to avoid NEPA analysis and harvesting to supply industry, regardless of what the plan says. It’s hard to connect the “urgency” dots when only 250 out of 5,400 GPNF acres are scheduled for salvage. This project would have greater validity of they were trying something new or doing actual research. Like Haber, I can’t get past the basic flaws in premise and procedures to consider the merits.

    • To me, it seems like this project is “something new” but, it also serves as a “token project” to show the locals that they are “doing something” for the local economy. I’m sure that much of those other 5000 burned acres have issues with economics and environmental issues conflicting. It sure seems like the Forest Service has cut back on using helicopters for salvage. If it was my decision, I would probably select the 250 acres with the highest mortality on ground that skidders and dozers can operate on. It’s probably very worthwhile to see how well this categorical exclusion can work (or be fraught with more analysis paralysis, which it was supposed to bypass).

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