Best available science

BLM Great Basin fuel break EIS

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The BLM has released its final decision to implement 11,000 miles of fuel breaks in six states.  The figure is in miles because the fuel breaks would be constructed along roads and right-of-ways.  Given our discussion of the Forest Service trend towards large landscape “condition based” management decisions, this language from an article quoting the BLM piqued my curiosity (my emphasis added):

According to Jennifer Jones, a spokeswoman for the BLM, the program will help streamline the implementation process by reducing or eliminating the need for environmental analysis. Once the plan is finalized and funding available, said Jones, “offices will be able to use it immediately and for many years to come.”

The timeline for implementation and the location of fuel breaks will depend on what offices develop plans and apply for funding.

The BLM’s notice of availability added:

… these potential treatment areas cover approximately 38 million acres within the project area boundary.

The goal of these Programmatic EISs is to significantly minimize the subsequent National Environmental Policy Act (NEPA) work required to approve on-the-ground projects.

(A second EIS will address “fuel reduction and restoration” over the same area.)

These statements sound like the more conventional approach to programmatic NEPA analysis (such as has been done for the use of herbicides).  They are intended to provide context for subsequent site-specific analysis that will produce overall savings in planning efficiency.  They make no pretense that this large scale analysis would necessarily be a substitute for site-specific analysis as some Forest Service proposals have stated. This kind of “merely programmatic” analysis has sometimes been given more leeway by the courts because a subsequent site-specific analysis would follow that would address site-specific issues and effects that have not been addressed.

The BLM decided also to do an EIS, unlike some of the Forest Service efforts that used an EA.  This analysis of effects of fuel breaks is also probably more site-specific than area-wide, “condition-based” Forest Service proposals because they know where the candidate corridors are, and they know the area of BLM lands where no action would be taken (away from these corridors).   (The scientific validity of fuel breaks is also discussed.)

Carbon pollution and solution

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I’ve said I try to stay out of climate change debates, but I’m trying to learn more.  I’m taking a retired-person class from a retired person well-known in climate change circles, Steven Running (google him), and I thought I’d share a couple of his many slides that I think say a lot about the role of forests in saving the planet from dangerously unpredictable climate changes.

For any doubters, the first slide shows the the role of human activities in raising the world’s temperature.  It’s basically all about us, and CO2 is the biggest problem.  The second slide shows the role of land  in CO2 emissions and sequestration.  The point is that when the atmosphere and the ocean must absorb the new emissions it causes the serious problems we are starting to see today.  That means we have to attack the three parts of this equation we have control over, the human sources of emissions and land-based carbon sequestration.  I suspect the answer is mostly “reduce the use of carbon fuels,” but maximizing the carbon content of land is going to be important, too.  Regarding forests, he has already said that planting trees can’t be done at the necessary scale, and cultivated biofuels are a net carbon source (though converting organic residue to energy would help).

Modeling for Decisions IV. In Practice – Climate Change and the Rio Grande Cutthroat Trout (and Forest Planning)

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It’s fortuitous that we have this recent example of how a court viewed a population model for an at-risk wildlife species that addresses climate change. The court included the usual caveat that, “Deference to the agency “is especially strong where the challenged decisions involve technical or scientific matters within the agency’s area of expertise.”

It is undisputed that the Service attempted to estimate the effects of climate change by using both “moderate” and “severe” predictions of expected effects, and that for the severe model, it “increased the risk function over time by 20 percent for the 2040 forecast and 40 percent for the 2080 forecast.” 79 Fed. Reg. at 59,147–48. The Plaintiffs take issue with the Service’s observation that the differences in results from the moderate and severe climate change models were “not particularly large.” Disbelieving that this could be a correct conclusion, the Plaintiffs thus suggest that the models “are driven by the Service’s assumption that climate change will have relatively little influence on the threats to individual Trout populations.” (# 76 at 26.)

But the Plaintiffs’ argument begs its own question, assuming that the Service’s models are infected by false preexisting assumptions that climate change effects with be minimal. It is essential to note that the Plaintiffs have not gotten “under the hood” of the Service’s models and pointed out any methodological, programming, or data entry flaws with them. Rather, the Plaintiffs simply argue that the models must be flawed because they produced results with which the Plaintiffs disagree. It may be that the models are flawed, but it may also be that that Plaintiffs’ (and the Service’s as of 2008) expectations about climate change effects are misplaced. Ultimately, it is the Plaintiffs’ burden to demonstrate an error in the Service’s actions, and simply pointing out that two different methodological approaches to calculating the effects of climate change in the far future produced two different results, one of which the Plaintiffs disagree with, does not suffice to carry that burden.

The threatened inquiry takes a longer-term view, asking whether the species might become endangered in a more distant future. But the threatened inquiry is necessarily closed-ended; once the Court has reached the endpoint of the “foreseeable future” (a term found in ESA, and defined recently by regulation) — which the parties here agree is 2080 — the Court’s ability to prognosticate must also come to an end. After 2080, nothing can be foreseen, all is simply speculation. So it is meaningless to ask whether a species will be threatened as of 2080, because it is impossible in 2080 to engage in the long-term future examination that the threatened analysis requires. By 2080, a species must have either reached the level of endangered and be at immediate risk of extinction, or it never will.

As the Plaintiffs observe, it appears that the Trout is on a “slide towards extinction.” (# 76 at 35.) But if the Service’s models are correct — and in the absence of a challenge, the Court must assume that they are — that slide will not be completed as of or immediately following 2080. At that time, there will still be 50 populations of Trout remaining, a number that the Service believes (and the Plaintiffs have not disputed) is enough to ensure the species’ survival through some indeterminate point in the future. What might become of those 50 populations after 2080 is beyond our ability to foresee; the curtain has come down and the movie has ended. We could attempt to speculate about what might happen thereafter — the 50 populations could persist, they could perish, new populations could be discovered, old habitats could become viable again — but speculation is all it would be. Our ability to predict what might happen has come to an end.

This analysis and decision actually has some important implications for forest planning (from the 2013 Rio Grande Cutthroat Trout Conservation Strategy).

Of the total 1,110 km (690 mi) of occupied habitat, 698 km (434 mi) (63 percent) are under Federal jurisdiction, with the majority (59 percent) occurring within National Forests (Alves et al. 2008).

Range-wide, a large proportion of the watershed conditions within the forests that have Rio Grande cutthroat trout are rated as “functioning at risk,” which means that they exhibit moderate geomorphic, hydrologic, and biotic integrity relative to their natural potential condition (USFS 2011)

Land management activities are currently practiced according to the Carson, Santa Fe, and Rio Grande National Forest Land and Resource Management Plans, and BLM Resource Management Plans. During scheduled revisions, the forests and BLM field offices will evaluate the current Land and Resource Management Plans and update as necessary to provide adequate protection for Rio Grande cutthroat trout with current best management practices. Land management activities that would result in the loss of habitat or cause a reduction in long-term habitat quality will be avoided.

 

If the trout is a warranted for listing (even if precluded by higher priorities), it is a “candidate” species under ESA.   The Planning Rule requires that forest plan components conserve candidate species (which under ESA means the same thing as recover). Since this decision that listing is no longer warranted was reversed, that should mean the species is again a candidate species.

Of course, national forests where the trout is found have been revising their forest plans after 2014, when listing was no longer considered warranted. Consequently, the Rio Grande cutthroat was considered for inclusion as a species of conservation concern. The Rio Grande National Forest has identified the species as an SCC in its final plan (currently in the objection period). The requirement for forest plans for SCC is for plan components to maintain a viable population.

Logically, a species that is warranted for listing should warrant greater protection than one that is not. So it’s possible that the Rio Grande will need to reconsider plan components in areas that are important to this species, or to at least document why this change doesn’t make a difference.

Which could bring us back to the modeling question – how does the Forest Service show that it is meeting the NFMA requirement to provide ecological conditions necessary for this species?   If there is a working population model for a species, then those factors that may be influenced by national forest management should be examined to determine how they could change as a result of forest plan decisions, and whether or how that could affect the model results.

 

Trump Administration sage-grouse plans stopped

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The district court for Idaho has enjoined the Trump Administration’s attempt to cut back protection of sage-grouse on BLM lands in Idaho, Wyoming, Colorado, Utah, Nevada/Northeastern California, and Oregon from that provided by plan amendments in 2015. (A similar decision has been pending for national forest plans.) The changes made in the 2019 amendments to BLM land management plans can not be implemented, and the provisions in the 2015 amendments will apply (projects must be consistent with the 2015 amendments) until the case is decided on the merits.  (A link to the opinion is included with this news release.)

Moreover, the court telegraphed the merits pretty clearly:

“… the plaintiffs will likely succeed in showing that (1) the 2019 Plan Amendments contained substantial reductions in protections for the sage grouse (compared to the 2015 Plans) without justification; (2) The EISs failed to comply with NEPA’s requirement that reasonable alternatives be considered; (3) The EISs failed to contain a sufficient cumulative impacts analysis as required by NEPA; (4) The EISs failed to take the required “hard look” at the environmental consequences of the 2019 Plan Amendments; and (5) Supplemental Draft EISs should have been issued as required by NEPA when the BLM decided to eliminate mandatory compensatory mitigation.”

(1) “The stated purpose of the 2019 Plan Amendments was to enhance cooperation between the BLM and the States by modifying the BLM’s protections for sage grouse to better align with plans developed by the States. While this is a purpose well-within the agency’s discretion, the effect on the ground was to substantially reduce protections for sage grouse without any explanation that the reductions were justified by, say, changes in habitat, improvement in population numbers, or revisions to the best science contained in the NTT and CTO Reports.” The agencies did not fulfill their duty to explain why they are now making a different decision based on the same facts.

(2) The no-action alternative did not meet the purpose and need, and there was only one action alternative. “Common sense and this record demonstrate that mid-range alternatives were available that would contain more protections for sage grouse than this single proposal.”

(3) The BLM prepared six EISs based on state boundaries, but failed to provide the “robust” cumulative effects analysis this situation required. In particular, “connectivity of habitat – requires a large-scale analysis that transcends the boundaries of any single State.”

(4) “Certainly, the BLM is entitled to align its actions with the State plans, but when the BLM substantially reduces protections for sage grouse contrary to the best science and the concerns of other agencies, there must be some analysis and justification – a hard look – in the NEPA documents.” The court took particular note of the EPA comments that were ignored, and Fish and Wildlife Service endorsement of the 2015 amendments in deciding not to list the species under ESA because they adopted scientific recommendations (see below).

(5) Compensatory mitigation measures were eliminated after the draft EIS, which “appears to constitute both “substantial changes” to its proposed action and “significant new circumstances” requiring a supplemental EIS.

The case provides a good example of how science is considered by a court, which allowed declarations from outside experts to determine if relevant environmental consequences were ignored. The court relied heavily on earlier scientific reports that included normative “recommendations,” but the court focused on their scientific conclusions, such as “surface-disturbing energy or mineral development within priority sage-grouse habitats is not consistent with the goal to maintain or increase populations or distribution,” and “protecting even 75 to >80% of nesting hens would require a 4-mile radius buffer.” The Final EISs stated that there would be no measurable effects or they would be beneficial to sage-grouse, but the BLM either had no analysis or ignored this contrary information.

 

Midwest timber wars revisited

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For the first time in nearly three decades, the Shawnee National Forest in Illinois has proposed a commercial timber harvest of mostly native oaks and hickories. And environmental activists whose high-profile fight against logging in the 1990s led to a 17-year moratorium are once again raising alarms.

Lisa Helmig, acting forest supervisor with the Shawnee National Forest, said the plan is rooted in the best available science about how to maintain the keystone oak ecosystem that is native to the Shawnee foothills.  “The oak ecosystem has been in place here in the central hardwood region for 5,000 years,” she said. But Helmig said the ecosystem is at risk due to a lack of natural or man-made disturbances, such as fire, storms and, yes, even logging. Without these disturbances, non-native, shade-tolerant sugar maple and beech trees sprout up and fill in the forest’s midstory, she said.

The activists have filed an objection, based largely on their past experience with timber harvest on the Forest.

The trees that have grown up to replace the harvested oaks and hickories are mostly 28-year-old stands of “undesirable” beeches and maples.  “When you think about how many oaks were here, it’s heart-wrenching,” Wallace said “Had they not cut the oaks, we’d have oaks here,” Stearns added. In addition to the Farview site, in their letter they write that we also returned to the North End Ecological Restoration project logged in Pope County in the late 1990s. “Little to no oak and hickory have been visibly restored.” They cited other examples, as well.

This is the root of their concern: What the Shawnee National Forest’s leadership claims is happening isn’t.

Asked about their concerns, Helmig said that her “gut reaction” is that the Forest Service likely didn’t follow through with what should be a multiphase treatment. Helmig said she’s confident that the Forest Service is committed to seeing (this) project through… “We have a wonderful silviculturist on staff now,” Helmig said. “He’s been here five years and is absolutely fantastic.”

Hopefully we can assume that there has been a science-based determination that ecological integrity requires regenerating some young oaks and hickories.  But implementation unfortunately still boils down to “trust us,” and “we’re different now.”   (But then the Forest evicted the media from the objection meeting, wrongly according to the Washington Office.)

Research: eastern forest old growth more resilient to climate change

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“Analyzing large amounts of field data from 18,500 forest plots – from Minnesota to Maine, and Manitoba to Nova Scotia – the study identifies priority regions for forest climate adaption efforts.”

A study funded by the Forest Service found that older forests in eastern North America are less vulnerable to climate change than younger forests in terms of the sensitivity of carbon storage, timber volume and species richness.  From the abstract (linked to this news release):

We found the strongest association among the investigated ESB indicators (ecosystem services and biodiversity) in old forests (>170 years). These forests simultaneously support high levels of carbon storage, timber growth, and species richness. Older forests also exhibit low climate sensitivity of associations among ESB indicators as compared to younger forests. While regions with a currently low combined ESB performance benefitted from climate change, regions with a high ESB performance were particularly vulnerable to climate change. In particular, climate sensitivity was highest east and southeast of the Great Lakes, signaling potential priority areas for adaptive management. Our findings suggest that strategies aimed at enhancing the representation of older forest conditions at landscape scales will help sustain ESB in a changing world.

Some of this sounds a little contradictory (maybe someone with more expertise and/or who reads the full article could explain), and I wonder if it has any application at all to more fire-prone forests.  But it is a different way of looking at climate change adaptation that could be incorporated into forest planning.

New Forest Service research confirms that today’s wildfires moderate future fires

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“The research results clearly indicate that wildland fire regulated the ignition and spread of later wildfire in all study areas.” This might tend to produce a “duh” response, but apparently nobody had really studied it.  Here is the Forest Service overview of their research project.

Here is what I found most interesting – the Forest Service recognizes that, “Those responsible for managing wildland fires often face extreme pressure to quickly extinguish blazes due to short-term impacts such as smoke pollution or lost timber resources,” and “Parks’ research serves as a reminder that wildland fire, under the right fuel and weather conditions, can act as an effective fuel treatment to improve forest health and prevent future blazes from becoming large, costly and more dangerous” (my emphasis).

It should also be a reminder that when the Forest Service designates an area as suitable for timber production, and bases timber targets on that, it creates an incentive to put fires out, which increases the likelihood of more costly, dangerous fires.  This cause and effect relationship needs to be disclosed in the environmental analysis for forest planning, where the timber suitability decision is made.

Forest Management: “For a Warming World, A New Strategy for Protecting Watersheds”

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This article was prepared by Yale Environment 360. Although its focus is primarily on protecting watersheds, most of the well validated scientific principles that Sound Forest Management is based on are clearly demonstrated in a way that easily shows the value of human intervention in our federal forests for other site/situational specific prescribed purposes as well. Here are some highlights which have been the subject of many previous posts on this site.

  1. water managers are learning that careful management and restoration of watershed ecosystems, including thinning trees and conducting prescribed burns, are important tools in coping with a hotter, drier climate.
  2. New Mexico’s forests … areas that supported 40 trees per acre in the pre-European era now were blanketed with up to a hundred times as many. This profusion of trees — as many as one per square yard — weakened all of them, and rendered them defenseless against megafires.
  3. the Las Conchas Fire … consumed nearly an acre of forest per second … and left behind nearly 100 square miles so severely burned that even seeds to regenerate the forest were destroyed …
    two months later, when a thunderstorm in the Jemez Mountains washed tons of ash and debris into the Rio Grande River, the water source for half of New Mexico’s population and for a major agricultural area. Only an inch of rain fell, but the debris flows the storm generated turned the river black and dumped ash, sediment, and tree and shrub remnants into a major reservoir⁠, requiring a costly cleanup … a heavy rainstorm two years later generated enough sediment to entirely plug the Rio Grande
  4. In the last two decades, megafires in similarly dry and overgrown watersheds have ended up contaminating downstream water supplies in numerous areas throughout the western United States, including Phoenix; Denver; Flagstaff, Arizona; and Fort Collins, Colorado. Downstream water managers serving millions of urban residents have learned that the security of their water supplies is tied to the health of upland watersheds that may be hundreds of miles away.
  5. In the Western U.S., watershed restoration chiefly consists of two steps: thinning of trees and shrubs, and prescribed burns. In the Eastern U.S., it involves a bigger set of tools, including planting native trees, reducing the area of impervious surfaces, and slowing the speed of stormwater so that more water percolates into soil and aquifers. All these measures are designed to improve water quality.
  6. numerous pilot projects have shown the efficacy of restoration, agencies rarely have enough money to treat entire watersheds
  7. after the Las Conchas fire, residents in the Rio Grande watershed … in 2014 they launched a public-private partnership, the Rio Grande Water Fund, whose 73 contributing members⁠ include government agencies at all levels, foundations and other NGOs, local water utilities, and local businesses and residents. Together they raised enough money for a 20-year program to restore 600,000 forest acres — enough to support the resilience of the entire central and northern New Mexico portion of the Rio Grande watershed. They have already restored 108,000 acres, and are racing to complete the job before another megafire occurs.
  8. The Rio Grande Water Fund’s public-private partnership model has become official federal policy. Last August, the U.S. Forest Service published a landmark report called “Toward Shared Stewardship Across Landscapes” that outlined the agency’s intention to convene watershed stakeholders of all kinds to plan and fund watershed restoration. “Because fire crosses back and forth across land ownership boundaries, the risk is shared,” the report said. “Accordingly, land managers cannot achieve the fire-related outcomes people want… without shared stewardship of the wildland fire environment.”
  • The benefits of watershed restoration extend far beyond water security. Most obviously, healthy forests deter megafires. Laura McCarthy, the Rio Grande Water Fund’s executive director, says that in three instances since restoration work began in New Mexico, wildfires that ran up against restored zones immediately died down. Healthy forests can tolerate low-intensity fires: they possess diverse understories of grasses, sedges, and forbs and rich, microbe-laden soil, all of which supports wildlife, from insects to mammals. Watershed restoration can double the amount of carbon stored in the soil, which means that it’s a vital tool in fighting climate change. And watershed restoration creates jobs: In the case of the Rio Grande Water Fund, many of those jobs go to youths in traditional Hispanic and Native American communities where unemployment rates are 30 percent or higher.
  • In some regions, forest restoration even increases water supplies. Roger Bales, a hydrologist at the University of California, Merced, has shown that because watershed restoration requires the removal of vast numbers of young trees, loss of water into the atmosphere through evapotranspiration in those trees is eliminated. The water instead flows downward, into the soil, often on its way to the watershed’s rivers and reservoirs. Bales’ experiments in California’s Sierra Nevada show that restoration can increase water supplies in downstream reservoirs by 9 to 16 percent. That makes restoration a more cost effective (and vastly less destructive) water supply method in California than building dams. Restoration is also cheaper than fighting the megafires that are otherwise inevitable in the overgrown forests: last year’s Camp Fire in northern California alone caused $11 billion to $13 billion in damage.
  • unless it is followed by prescribed burns, undesirable trees and shrubs grow back. In that case, said Don Falk, a leading fire researcher at the University of Arizona, “You’re either committed to a perpetual Sisyphean cycle of thinning” every 10 or 15 years “or you’ve got to let fire back into the system.” Fire is an integral part of the functioning of many ecosystems: Blazes of less-than-megafire scale germinate seeds, keep native species in balance while warding off invasive species, and stimulate microbial activity that produces soil nutrients.

Oregon logging history map

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Oregon Wild has compiled an  interactive map of logged and thinned areas on public and private lands across the state of Oregon.  If nothing else, it’s hard to look at this and accuse anyone wanting to keep logging out of new parts of their public lands of being an “extremist.”

Oregon Wild intends to use this mapping tool to help advocate for forest conservation and demonstrate that while there have been temporal pulses of increased logging intensity over the years, logging is always very active on both public and private forests in Oregon. In fact, if anything, the analysis on this site underrepresents the true extent of logging taking place.

The tool is also a great visualization of the few Wilderness and roadless wild lands remaining in the state – while it does not highlight these areas, they are clearly visible by their noticeable lack of logging units. These last bastions of wild landscapes are far too rare in Oregon, a reason Oregon Wild is working to protect what is left.

We can also use the tool to push back on misinformation spouted by timber interests.

  • Many say that logging on public land was “shut-down” by the spotted owl and Northwest Forest Plan, first implemented in 1994, but the data shows that logging continued apace throughout the Northwest Forest Plan region after the plan was adopted.
  • Logging advocates also say we need the increase the “pace and scale” of logging to reduce fire hazard in the dry forests of eastern and southwest Oregon, but the data show that thinning has already occurred across vast portions of these forests.

Landsat Advisory Group undertakes a Landsat Cost Recovery Study

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Yellowstone burn recovery

“The Department of the Interior (DOI) and the U.S. Geological Survey (USGS) have requested a Federal Advisory Committee to review USGS’s current free-and-open policy for user access to Landsat data.  The following material provides a synopsis of frequently-asked questions and answers about the ongoing review.”

(Making the truth harder to find?)