Do elk need trees? Maybe.

This is an update to a September 12 post “Do elk need trees?”  The Forest punted the issue to its forest plan revision:

The first draft of the proposed Helena-Lewis and Clark revised forest plan punts elk security to project-level decision making. Here’s the draft guideline: “In order to influence elk distribution on NFS lands, management actions should not reduce the amount of elk security available during the archery and rifle hunting seasons over the long-term (generally ten or more years). Short-term reductions in elk security may occur when needed to achieve other resource management objectives. Elk security should be defined and applied at a scale that is informed by interagency recommendations if available, knowledge of the specific area, and the best available scientific information.”

The Forest Service is back to writing 1970s-era “plans” that left everything up to the local ranger. I foresee lots of litigation about the validity of these individual security interpretations on each project (instead of just determining if the project is consistent with the forest plan).


  1. Here’s a snip from Secretary Wilson’s iconic letter of Feb. 1, 1905 to Gifford Pinchot, 1st chief . Read it and weep.
    “In the management of each reserve local questions will be decided upon local grounds; the dominant industry will be considered first, but with as little restriction to minor industries as may be possible; sudden changes in industrial conditions will be avoided by gradual adjustment after due notice; and where conflicting interests must be reconciled the question will always be decided from the standpoint of the greatest good of the greatest number in the long run. These general principles will govern in the protection and use of the water supply, in the disposal of timber and wood, in the use of the range, and in all other matters connected with the management of the reserves. They can be successfully applied only when the administration of each reserve is left very largely in the hands of the local officers, under the eye of thoroughly trained and competent inspectors.”

    • Management of forest reserves “can be successfully applied only …. under the eye of thoroughly trained and competent inspectors”

      For better or worse, that critical function has been largely delegated to environmental NGOs and federal courts.

      • And we have people like Chad Hanson publishing pictures of private lands logging, passing them off as Forest Service projects. “Competent” is not the right word, there. When it takes me less than 5 minutes to locate the site of the picture, verifying that the picture is not Forest Service lands, “competent” is not the word I would use.

        • Hi Larry, Haven’t you made a lot of factual errors on this blog over the years? I’ve encouraged you before to set up a public debate with Dr. Chad Hanson and see what happens. I have a prediction.

          • Matthew

            You have no room to disdain others for factual errors! A debate with Dr. Hanson would certainly not be a fair debate since Hanson is prone to not let established science get in his way.

                • Excuse me Harrell. I ain’t nobody’s ‘lackey” and nobody sent me. Dr. Hanson would mop the floor with you in a debate, that much I’m positive of. Please also provide actual evidence that Dr. Hanson has a “Golden Goose’ of litigation dollars. In the past you took to this blog to call Dr. Hanson an “extremist EAJA addict.” Seriously, provide some damn evidence Harrell or I’ll simply use my moderator privileges on this blog to remove any of your comments in which you make allegations that you can’t support with actual evidence and documentation. Thanks.

                  • Methinks I have struck a nerve, eh?!? I’ve seen multiple times where you responded for Hanson, about the Power Fire, where he gleaned $175,000, from the Ninth Circuit Court. He’s on the downhill slide, losing his loopholes, and the Forest Service is very happy about it, too! Remember, I am also a moderator, as well. I doubt that Sharon will support your abuse of power.

                    • Methinks you called me a “lackey” and methinks you have made up stuff about Dr. Chad Hanson. Please provide evidence and documentation to back up your allegation that Dr. Hanson “gleaned $175,000, from the Ninth Circuit Court.” Maybe it’s about time for you to take your bat and go home again Harrell. “Abuse of power?” Whatever. You are clearly in violation of the comment policy established on this blog and as a moderator I will act accordingly. I’m pretty sure Sharon won’t mind. Thanks.

              • Thanks Steve, but I’m pretty sure I haven’t called anyone a name in this comment string. Larry Harrell is the one doing that, so please direct your comment just to him. As always I’m more than willing to stick to the issues. Thanks.

  2. Especially “the dominant industry will be considered first.” Fortunately we have evolved in the last hundred years, and NFMA recognized the failure of that system. But The Forest Service is still fighting NFMA.

  3. The elk security language from the Helena-Lewis and Clark revised forest plan appears to be an example of “standardless management.” See generally Michael C. Blumm, Public Choice Theory and Public Lands: Why “Multiple Use” Failed, 18 HARV. ENVTL. L. REV. 405, 407 (1994) (“Since multiple use is founded upon a standardless delegation of authority to managers of public lands and waters, congressional endorsement of multiple use has created the archetypal ‘special interest’ legislation.”) Blumm argues that “public choice theory supports the proposition that multiple use cannot fulfill its promise because it is inherently biased toward commodity users” and that “[s]ince multiple use is founded upon a standardless delegation of authority to managers of public lands and waters, congressional endorsement of multiple use has created the archetypal ‘special interest’ legislation.”

    • Exactly. And for species like elk, NFMA didn’t change the multiple-use rules much. It just requires that decisions about elk be integrated with decisions about logging and roads (so that the Forest Service doesn’t promise everything to everybody) – and that these decisions be made through a visible public process with public participation. For a species like elk, in many places there is strong constituency that will demand that the Forest Service make commitments in its forest plans to protect elk, using plan components like standards for elk security.

      It is important to recognize that the situation is different for at-risk species. NFMA did establish a minimum requirement for multiple-use that it provide for diversity of plant and animal communities. That means that “standardless management” is not going to work for these species. NFMA requires forest plans to make a commitment to diversity, and that does not occur when a forest plan puts no sideboards on project decisions.

  4. The elk around here seem to do best down in the valleys, where there are roads, fields, people, and lots of logging. Just an observation.
    Hopefully Dr. Chad Hanson and his philosophy that is it ok to burn up our forests will soon be out of vogue.

  5. The method to provide sideboards is debatable. What is at issue here is accountability and whether the local official executing their delegated authority is doing so in a manner that is transparent to all interests. “Greater good” implies that a minority interest may not benefit from an official’s decision. This is the difficulty in balancing “multiple use” – which interest will not be accounted for? Jon’s point help us understand that “diversity” should not be pushed aside in the interest of managing the “dominant industry”.

  6. Politicians manage our public forests and write very specific prescriptions! What they should be doing on behalf of the true owners of these forests, the public, is determine what the public wants from their lands; what are the desired goals and objectives. With that in hand, it should be left to the people on the ground to attain those goals and objectives. Where they fail, they should be replaced.

    I see current public land management as being a lot like a politician determining that a new bridge must be built but then they go on to determine the placement, design, and construction of that bridge. I doubt there are many politicians with that kind of engineering knowledge just as I doubt there are many politicians with similar knowledge of forest management.

    I think, for example, a politician determining that the public wants cold, clear, clean water that provides good fish habitat is a reasonable outcome. But then, they have to go on to prescribe the widths to stream buffers. People on the ground who actually know and understand their forest might actually know that, given the soils, a buffer a hundred yards wide is necessary. Likewise, a 20-foot buffer might do the trick in another situation and attain the same, desired goals.

    Of course, a politician’s one-size-fits-all prescription is easier to write and it is a lot easier to enforce (anyone hear litigation?) as any decision-making has been taken out of the hands of those who actually know and understand the forest. In the real world, things are simply not so black and white that they fit one-size-fits-all rules.

    As for the elk, I recall all the hand-wringing about the terrible loss of elk habitat when Mt. St. Helens blew up. It turns out that the elk were back in force a very short time later.

    Mac – great article in the Forestry Source.

  7. I agree with Dick’s comments in principle – that there is a point at which we should defer to an agency’s expertise. But we may not agree where that point is. Sometimes the variability on the ground makes it more challenging, but a plan can provide guidance specific to different circumstances.

    I agree that focusing on the desired outcome is a good thing to do in the forest planning process, but NFMA requires a degree of commitment and certainty that those conditions would occur (or at least that management actions would not impair them) for at-risk species. And elk hunters may want some commitment in the forest plan to protecting elk.

    Elk/cover relationships are also a case where there is a lot of science that supports more standardized approaches that could be included in forest plans. I think the same has also become true of forest plan strategies to provide aquatic ecosystems for at-risk salmonids and conservation strategies for listed terrestrial species. These include mandatory standards, which also simplify the ESA consultation process by providing more certainty to the consulting agencies.

    One of the assumptions behind the 2012 Planning Rule was that putting more detailed desired conditions in plans (and adding a requirement to be consistent with them) would make standards less necessary for providing certainty in minimizing effects on at-risk species. What we’re seeing in revised plans is vague desired conditions, a weak consistency requirement for them, and a compulsion (a policy?) to not include standards in forest plans. I don’t think this is going to be enough for some plans for some species.

  8. For Matt, revisiting a previous article where Hanson was proven to be totally wrong about salvage clearcutting. He used a picture of SPI land, mistaking it for Forest Service lands.

    “Hi Larry, The photos I posted at the bottom of the article I got directly from Dr. Chad Hanson. Sooooo if Dr. Hanson says those photos are of post-fire logging units on the Stanislaus National Forest from within the Rim Fire area I’m going to take his word for it, rather than rely on someone sewing seeds of doubt from in front of a computer. Thanks.”

    Why couldn’t HE come here and defend himself?!?!?!?!?

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