Blast From the Past: Heritage Forest Campaign Yesterday, Climate Forest Campaign Today

One of the points I like to make about our forest policy world is that it is a great space for folks raising families and with other commitments. You can take a few years off (or possibly decades) and come back and not really miss much.  Thanks to the TSW reader who found this hearing from the year 2000.  If you swapped out “Climate Forest Campaign” for “Heritage Forest Campaign” and OG for Roadless, and  Biden for Clinton-Gore, and probably increased the budget figures, it sounds like the same thing, and I think the questions asked are still worth pursuing.  Sorry about the formatting.  This is just Chenoweth-Hage’s introductory statement, I didn’t read the rest, there are 128 pages. Might be other interesting stuff there.

Recently , one of the lead stories in Philanthropy magazine was about foundation funding of environmental organizations . Now , the article said that today foundations have much of the public agenda , and nowhere more so than in the area of environmentalism , where foundations collectively spend upwards of $ 500 million per year that we know of . 

Today we are here to analyze the relationship among large foundations , environmental groups , and the Federal Government in Federal public land management policy , in regards to recreation , timber harvests , mining , and other public lands issues . We will also explore the impacts of these policies on local communities . Environmental groups are relying more and more on a core of wealthy , nonprofit foundations to fund their operations . 

The largest environmental grantmaker  the $ 4.9 billion Pew Charitable Trusts gives more than $ 35 million annually to environmental groups . Other large wealthy foundations such as the Turner Foundation , W. Alton Jones , and Lucile and David Packard Foundations , are not far behind Pew in their grantmaking to environmental groups . 

Foundations have funded environmental advocacy campaigns for more wilderness , curtailing timber harvests , and mining , breaching dams , and Federal control of ecosystem planning . An example of this type of activity is the Heritage Forest Campaign , the subject of an oversight hearing on February 15 , 2000 , by the Subcommittee on Forests and Forest Health .

The Heritage Forest Campaign , a coalition whose sole purpose appears to be lobbying the Clinton- Gore administration to implement the Roadless Initiative , which would withdraw up to 60 million acres of national forest lands from multiple use . This campaign is largely organized and funded by tax free grants from charitable foundations such as the Philadelphia based Pew Charitable Trusts , with $ 4.9 billion in assets the fifth largest U.S. charitable foundation . 

Now , since September 1998 , Pew has given the National Audubon Society more than $ 3.5 million in tax  free grants to organize the Heritage Forest Campaign , a coalition of about a dozen  environmental groups . The sole objective of the campaign appears to be the creation of widespread public support for the Clinton –  Gore administration’s initiative to restrict access on 60 million acres of national forest lands . 

The Heritage Forest Campaign illustrates several potential problems with foundation  financed environmental political advocacy , namely the lack of fair , broad based representation , and the absence of accountability . Particularly disturbing is this administration’s acquiescence to the campaign in the setting of policy . 

At a recent hearing on the Roadless Initiative , I asked George Frampton , Director of the Council on Environmental Quality , for the names of all those attending any meetings he had held regardinging the development of the Roadless Initiative . The list he sent in response is a who is who in the environmental community . Even more telling is that not one individual representing recreation , industry , academia , county commissioners , or local schools were in attendance . Only representatives of the national environmental groups participated . 

Not only was the public excluded during these meetings , but so was Congress . The administration’s Roadless Initiative appears to be an attempt to bypass the role of Congress . Under Article IV , Section 3 , of the United States Constitution , Congress possesses the ultimate power over management and use of lands belonging to the United States . 

If the Roadless Initiative is universally popular , why can’t the Heritage Forest Campaign get it enacted by Congress through the normal legislative process ? Administrative directives , such as the Roadless Initiative , bypass Congress and centralize policymaking authority within the hands of unelected bureaucrats in the execu- tive branch . 

Foundation-funded advocacy groups make backroom deals , thus denying the average citizen a voice and input into the policy through their elected representatives in Congress . As a result , our Government becomes more remote and unresponsive to the needs of the average citizen . 

To whom is the Heritage Forest Campaign accountable? This campaign is put together by foundations, not the participants . The grantees are accountable to the foundations that fund them , not their own members . Foundations have no voters , no customers , and no investors . The people who run big foundations are part of an elite and insulated group . They are typically located hundreds or even thousands of miles from the communities affected by policies they advocate .

They receive little or no feedback from those affected by their decisions , nor are they accountable to anyone for promoting policies which adversely affect the well  being of rural people and local economies . Today’s witnesses will tell us how their communities are being crushed by an inaccessible and faceless movement , wielding great power and influence . 

The role of large foundations in funding environmental advocacy raises some fundamental questions . Foundation wealth shapes public policy at the expense of all counter views . Even worse , those skeptical of foundation  supported policies are often smeared by foundation funded media campaigns in an attempt to marginalize them in the debate . Even alternative environmental solutions are rejected out of hand as environmental groups mold their programs and their agenda to please the large grantmakers . 

Does foundation financed advocacy prevent full and fair public debate on public lands issues ? Is the average citizen’s voice and input in the government decisionmaking process drowned out by foundation  funded advocacy groups ? 

The most fundamental question of all is , what happens to the towns and communities affected by policies resulting from foundation  funded advocacy ? The people living in these communities are left with a ruined local economy . Their towns lack the income to provide even basic services . Their schools have no revenue to teach their children. 

The important issue here is whether the foundation strategies used to fund the environmental movement are buying undue influence for those groups on public lands policy . I believe it will become very clear during this hearing that this isn’t an issue concerning the environment , but rather one concerning power and its use for political ends , with rural communities being trampled in the process.

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Now, Rep. Chenoweth-Hage was appropriately concerned for rural communities as she represented Idaho.  At the same time, today, these policies influence all kinds of communities near Federal lands.  Another difference between then and now is our interest in the voices of Tribes, ethnic minorities and the poor and working class- marginalized communities.  How are these folks (say folks from poor rural communities)  represented on Boards and decision-making in these foundations?

“The important issue here is whether the foundation strategies used to fund the environmental movement are buying undue influence for those groups on public lands policy.” IMHO this question is still valid.

Finally, what is the endgame of these foundations, if they have one? Is it the same old “no oil and gas drilling, no mining, no grazing, no commercial logging, no OHV’s”?  I don’t know that we know, nor can I imagine who would have the political power to have that conversation.

Does the Old Growth Amendment Supplant or Redefine NRV?

Old growth LPP

First of all, let me say that there are probably people in the Forest Service who have thought all this through.  I’m hoping that they will help out with their explanations in the comments.

If old growth is old growth, and mature forests are on their way to old growth, and young forests are on their way to mature forests.. then it seems like there is no ceiling on the amount of old-growth needed, and no reason to ever have openings other than “natural” ones.  This can be problematic, conceptually, as some groups believe that today’s wildfires and wind events are all unnatural or caused or “supercharged by” the anthropogenic part of climate change.

And if you believe that, then does any ecosystem have “integrity”?   Or is the key thing to promote resilience (including biodiversity) in the face of climate change and protect key values of ecosystems and people from these and other dangers?  To keep diverse living trees alive on the landscape, and to protect water, wildlife and other values?  Perhaps some will say “it’s the same thing” and if it is, then perhaps the use of plain English would save time and misunderstanding.

Let’s go back to the 2012 Planning Rule Handbook:

Assessing the status of ecosystems—their level of ecological integrity—is difficult. There is no guide that provides a comprehensive protocol, and each ecosystem has a unique body of scientific information relevant to the ecological assessment. The planning rule and supporting handbook identify departure from the natural range of variation as a criterion to assess ecological integrity. The natural range of variation refers to the variation in key ecosystem characteristics produced by dominant natural disturbance regimes, usually in a pre-European influenced reference period. This method works well for ecosystems that are relatively well-studied and their natural range of variation can be estimated through ecological modeling or other methodology.

(my bold).  Now, as most readers know, I wasn’t a fan of this approach at the time.  At that time,  my thinking went along these lines… (1) there’s a great deal of pre-European time and yet a certain time has to be selected, humans have been around since glaciation;  (2) animals and plants move around and hybridize- and evolution is part of Nature, after all;  (3)  time’s arrow only goes one way, at least genetically;  and (4)  if climate is changing faster than usual, then there is no reason to think that the past is well adapted to the future. And don’t we want forests that are adapted to the future? As described in the Handbook, it unintentionally downplays the role of Indigenous fire management and the idea “natural= pre-European” only fits if Indigenous folks are part of Nature, which some now consider to be racist. It would perhaps be clearer and more accurate to say “we want to go back to Indigenous ways of managing the landscape,” if that’s really the case, but again we’d need more Indigenous people and give them authority over federal forests plus make them do not what they think best but what they think their ancestors did.  And the importance of Indigenous management and climate have only become clearer or perhaps “supercharged” in more recent discourse.

Many forests have done vegetation modeling and historic research, and came up with desired conditions of say, certain amounts of habitat with certain characteristics.  For example, x acres of early successional habitat, or y acres of  western white pine or oaks, or even the historic densities of some species.  So logically, to recreate these conditions, we may need to thin trees for density reduction and create openings for some pine and oak species to regenerate.  There are different ways of getting openings.  Depending on where you are, openings could occur due to wildfire, wind events, volcanoes, floods, trees dying from old age and/or native or introduced diseases and pests, and so on. With or without attribution to anthropogenic factors of climate change, some of these are more natural than others (fire suppression and non-native species obviously not).

Generally, the only other way is to manage is via prescribed fire or some combo of mechanical treatments (aka “logging” or “tree-cutting”) and prescribed fire.  So do we still want those carefully arrived at NRV distributions or not?  According to some, if the opening-treatments  would occur in currently mature or old-growth forests, then not.  So that leaves “natural” disturbances (affected by AGW, so then unnatural, except for volcanos?) and hoping that they get to the desired ratios; or alternatively, doing openings over and over in younger forests but not mature ones, so that they don’t go through their successional stages, which seems also unnatural.   Look who wrote about the importance of early successional  ecosystems in this 2011 paper (abstract)

Different disturbances contrast markedly in terms of biological legacies, and this will influence the resultant physical and biological conditions, thus affecting successional pathways. Management activities, such as post-disturbance logging and dense tree planting, can reduce the richness within and the duration of early-successional ecosystems . Where maintenance of biodiversity is an objective, the importance and value of these natural early-successional ecosystems are underappreciated.

So will the new OG amendment effectively replace the concept of “pre-European conditions” with “creating as much old growth as possible”?  Because we can imagine quite a possible tension between “maximizing old growth” and “ensuring diversity of tree species”,  and the latter  would be important to fulfill certain requirements of NFMA, specifically.

“provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives, and within the multiple-use objectives of a land management plan adopted pursuant to this section, provide, where appropriate, to the degree practicable, for steps to be taken to preserve the diversity of tree species similar to that existing in the region controlled by the plan;”

My bold, Of course, trees and bark beetles, do their own things, unbothered by humans’ desire for shade or carbon credits, or even plan amendments, forest-specific or national. From the Fire Effects website:

The average lifespan of Rocky Mountain lodgepole pine is 150 to 200 years [37,170], though some Rocky Mountain lodgepole pine trees live more than 400 years

OG:- White House Announcement; More NGO Comments and Some Concern About FS Bandwidth from AFRC

Thanks to SJ for adding these ..  the White House Announcement is of particular interest. Here’s a copy of the letter to forests.  It reminds me a bit of the old “reviewing roadless projects in the WO” effort. As they say:

This letter only affects the process by which such activities are authorized. It does not alter or prescribe any substantive standards for the management of old growth forests

I always wondered about the legality of these kinds of   review processes, it seems they are designed to provide an outcome before there is a legal reason to do so.  Just saying it doesn’t prescribe anything different (perhaps on the advice of OGC?) has not, in the past, been accurate. Perhaps our legal TSW friends can clarify.

This workshop sounds interesting, and that it is joint by BLM and FS is good; after all, PJ is  the most abundant old-growth and traditionally disagreements have not been timber-war-ish.

Collaborative Efforts to Conserve Pinyon Juniper: Pinyon and juniper woodlands encompass tens of millions of acres of federal lands across the West, and have significant biodiversity, climate, and cultural values. Pinyon-juniper woodlands are the most abundant forest type in the federally managed inventory of mature and old-growth forests, and are the majority of mature and old-growth forests managed by the BLM. While much management focus has been rightly placed on pinyon-juniper encroachment onto sagebrush ecosystems, less attention has been paid to the importance of mature and old-growth pinyon-juniper ecosystems. The Forest Service and the BLM will co-host a public workshop focused on the conservation of these ecosystems in 2024. Through this effort, the Forest Service and the BLM will engage the public, Tribes, land managers, experts, and stakeholders in informed discussion around management issues, threats, trends, and opportunities for climate-smart management and conservation of mature and old-growth pinyon-juniper woodlands on federal lands.

Susan also linked to this group of ENGO’s quotes.

It seems like some of the quotes focused on  consistency across the country (Sam Evans) and a seat at the table for developing national policy (The Wilderness Society, Defenders of Wildlife), while EDF uses that other “f” word (flexibility) and notes the role of local folks:

The proposed forest plan amendment creates a rigorous, science-based process that will both protect old-growth forests and provide flexibility for managers, local communities, and tribal nations to recommend management actions to improve resilience to catastrophic wildfire and other climate change-induced threats.”

Meanwhile our friends at AFRC also have a press release. Perhaps oddly, so far they are the only ones who seem to be concerned about loading more paperworky processes on already-overburdened and difficult-to-hire federal employees. Excerpts:

 “The Forest Service’s data confirms logging poses a negligible threat to old growth forests, and existing federal environmental laws and forest plans provide direction on managing and protecting old growth. Yet the agency is now being directed to embark on a new, massive bureaucratic process – during a wildfire and forest health crisis – that will likely make forest management more complex, costly, and contentious.

 “Protecting old growth requires intentional, thoughtful action on the ground – not more paperwork.  It’s not clear how amending every single Forest Plan will help the Forest Service implement the Biden Administration’s own 10-year wildfire strategy that calls for a threefold increase in forest health treatments. Rather than giving our public lands managers the policy tools and support they need to sustain our forests and all the values they provide, this policy will force them to focus limited time and resources on more process and that will do nothing to address the real risks on the ground..

Some Groups Want the M Back in OG; WaPo Gets Five Smokeys for NOGPA Coverage

Interesting stories about the National Old Growth Plan Amendment (NOGPA). Now at this point, I haven’t seen anything the FS has written about it, and The Smokey Wire was not granted an interview with the Secretary, but what can we pick up from these stories?

First a story from the Washington Post.

I give them 5 Smokeys (out of 5) for detailed description, not characterizing it as “timber vs. enviros” and pointing out the timing problem via Chris Wood, also what’s the immediate effect.  All the things I wanted to know without any extraneous editorializing.  If you agree, consider sending the reporter a nice note:

In a phone interview, Agriculture Secretary Tom Vilsack said the effort is the first time the U.S. Forest Service has proposed simultaneously revising all 128 of its forest plans, which dictate how all 193 million acres of forests and grasslands are managed. The plan would prohibit cutting down old-growth trees for economic reasons, preventing carbon-rich forests from being clearcut at a time when scientists say they are most needed. These trees, most of which are well over 100 years old, store vast amounts of carbon. They also provide an essential habitat for hundreds of species of wildlife and are more likely to survive wildfires.

Having examine the projects alluded to in the Carbon Forests initiative, I don’t think the FS was cutting down any old growth for economic reasons. Again, as I’ve asked many NGO’s, please send me a link to the project documents where this is occurring and we can have that discussion in detail.

But it leaves open the possibility of continued cutting under certain conditions. Forest Service Deputy Chief Chris French said forest treatments the agency uses to reduce wildfire risk, such as thinning understory trees, would still be allowed in old-growth stands to protect them from out-of-control fire. In the Southeast, where the Forest Service is trying to restore the longleaf pine forests that used to blanket coastal areas, the agency could still cut down large, old loblolly pines, the main tree grown for the timber industry.

Some environmental advocates also questioned whether the policy will last, as a future administration could easily undo it. The new language about protecting old growth also won’t be finalized until the agency has completed an environmental impact statement, which it expects to finish in early 2025. “I wish they’d initiated this earlier. I wish they were doing a rulemaking,” said Chris Wood, president of the conservation group Trout Unlimited. Still, he said: “This is a big deal. This is a different agency than it was 20 years ago. The Forest Service’s appetite for going in and liquidating old growth is pretty much retired.”

It’s unclear how the new proposal will affect the agency’s planned timber sales, some of which include forest lands dotted with mature and old-growth trees.
In a letter sent to forest managers Monday, French informed them of the agency’s plans and wrote that “effective immediately” any forest management activities planned for old-growth stands in national forests would need to be reviewed and approved.

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Here’s the AP story.

I give them two Smokeys.
Apparently they had an interview with the Secretary as well.

Agriculture Sec. Tom Vilsack said the agency was adopting an “ecologically-driven” approach to older forests — an arena where logging interests have historically predominated

Does anyone remember New Perspectives and Ecosystem Management?

Past protections for older trees have come indirectly, such as the 2001 “roadless rule” adopted under former President Bill Clinton in 2001 that blocked logging on about one quarter of all federal forests.

As we know, the roadless rule didn’t actually “block logging.”

Under former President Donald Trump, federal officials sought to open up millions of acres of West Coast forests to potential logging. Federal wildlife officials reversed the move in 2021 after determining political appointees under Trump relied on faulty science to justify drastically shrinking areas of forest that are considered crucial habitats for the imperiled northern spotted owl.

Trump.. really?
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Here’s a press release from various ENGO groups (thanks for sending!).

Short summary.. this is a good first step but they would prefer to include mature trees.  Or “put the M back in OG.”

According to reports, the Biden administration will announce Tuesday a proposed nationwide forest plan amendment to advance protections for the last remaining old-growth trees in U.S. national forests. President Joe Biden has said these trees are critical components of the nation’s fight against the climate and extinction crises. The proposal, if adopted, would add new restrictions on logging and is a step toward fulfilling the promise of the president’s April 2022 Executive Order, which directs the Departments of Agriculture and the Interior to address threats to mature and old-growth forests on federal lands as a natural climate solution and develop policies to conserve them.

Members of the Climate Forests Campaign, a coalition of more than 120 organizations working to protect mature and old-growth trees and forests on federal land, welcomed the announcement as an important step forward while urging the Forest Service to pursue steps to protect mature trees. Both old-growth and mature forests are essential to removing climate-warming carbon pollution from the air and storing it, safeguarding wildlife, and providing clean drinking water for our communities.

The vast majority of old-growth forests have already been logged. Most that are left are largely on federally-managed public lands. As of November 2022, the Climate Forests Campaign had identified numerous timber sales targeting at least 370,000 acres of mature and old-growth forests for logging on federal land.

In addition to storing huge amounts of carbon and keeping it out of the atmosphere, mature and old-growth forests also provide essential wildlife habitats and are the most fire-resilient trees in the forest. As the world experiences record-shattering heat and widespread climate disasters, protecting these forests is critical to prevent the worst consequences of climate change.

The public will have an opportunity to weigh in on the proposal in a public comment period.

In response, environmental advocates issued the following statements:

“Protecting our old growth trees from logging is an important first step to ensure these giants continue to store vast amounts of carbon, but other older forests also need protection,” said Randi Spivak, public lands policy director with the Center for Biological Diversity. “To fulfill President Biden’s executive order and address the magnitude of the climate crisis, the Forest Service also needs to protect our mature forests, which if allowed to grow will become the old growth of tomorrow.”

“The Biden administration’s proposed plan to protect old-growth trees across the country is an important milestone for forest conservation and U.S. progress in addressing the climate crisis,” said Earthjustice senior legislative representative Blaine Miller-McFeeley. “Even as it works to complete this proposal, the Forest Service must take steps to fulfill President Biden’s executive order by also developing protections for mature trees, which are our future old-growth and exist in much greater numbers than old-growth, storing vast amounts of carbon. We look forward to working with the Forest Service to help it safeguard mature and old-growth forests. Conservation of these forests goes hand in hand with addressing the threat of wildfires as older and larger trees tend to be the most fire-resistant.”

“Americans love our forests. They’re natural playgrounds for people and wildlife alike. That’s why more than half a million people this summer asked the Forest Service to protect mature and old-growth trees and forests,” said Ellen Montgomery, Public Lands Campaign Director with Environment America. “Our mature and old-growth trees provide critical wildlife habitats, filter drinking water for communities and absorb and store tons of carbon. We’re really pleased that the Forest Service has taken this unprecedented step and we urge them to take actions to protect mature forests. To have a future where we have more old-growth, not less, it is critical to protect mature forests as well.”

“The Administration has rightly recognized that protecting America’s mature and old-growth trees and forests must be a core part of America’s conservation vision and playbook to combat the climate crisis,” said Garett Rose, senior attorney at NRDC. “This announcement is an important step toward meeting these goals. The Forest Service should move forward to develop the strongest possible safeguards for these forests.”

“Oregon Wild has been working to protect old-growth forests for 50 years. With today’s action, President Biden is taking a major step forward in protecting these national treasures,” said Lauren Anderson, Climate Forest Program Manager with Oregon Wild. “We look forward to working with his administration to implement this policy, and to ensure that mature and old-growth forests across the country are protected.”

“Our ancient forests are some of the most powerful resources we have for taking on the climate crisis and preserving ecosystems,” said Sierra Club Forests Campaign Manager Alex Craven. “We are pleased to see that the Biden administration continues to embrace forest conservation as the critical opportunity that it is. This amendment is a meaningful step towards averting climate catastrophe, safeguarding vulnerable ecosystems, and fulfilling President Biden’s commitment to preserve old-growth and mature trees across federal lands.”

“We applaud the Biden Administration for taking a significant step towards increasing protections for our nation’s endangered old-growth forests,” said Zack Porter, Executive Director of Standing Trees, an organization that works to protect and restore public lands in the six-state New England region. “But the reality is that more than 99.9% of old-growth forests in New England have already been cut down. For the climate and biodiversity, the Forest Service must put an end to destructive mature forest logging that prevents the recovery and expansion of old-growth forests across the US. We are buoyed by today’s announcement, and remain optimistic that the Forest Service will take further action to secure protections for America’s future old-growth forests.”

“Mature and old- growth forests are an essential component of a broader climate-crisis solution – but only if we protect them from logging,” said Adam Rissien, Rewilding Manager with WildEarth Guardians.  “Today’s announcement by the Forest Service establishes necessary and long-overdue protections for old growth forests, limiting when they can be cut and sold commercially. Taking the next step and developing a national rule covering both mature and old-growth would deliver on the Biden administration’s commitment to protect these trees once and for all.”

A Revisit with Chief Thomas on the Eve of a New Journey Down the Old-Growth Trail

Jack Thomas in the Eagle Cap Wilderness, Oregon, August 1996.

 

Since this could be 2023’s Old Growth Week, based on a stakeholder update planned for tomorrow with news of some MOG policy, I thought it might be fun to go back in time to the 90’s, 92, to be exact, and see how far we’ve come on the Old Growth issue. We can revisit Chief Jack Ward Thomas’s 1992 Albright Lecture. It’s interesting to think about what has or has not changed, with the increased focus on climate change, carbon and wildfire- and what hasn’t, in the last thirty years.  And to think about where the issue will be in the next thirty years.  Will we still be fighting about it?  Will old growth be dead from climate change or burned up or …? Or will we have finally reached some kind of peace, in the direction that Chief Thomas describes.

It’s got a bit about planning and is worth rereading in its entirety, but I picked out a few excerpts below.

HA! Things Are Not What They Seem

Perhaps, further down line, it will be possible to discern exactly the attributes of owl habitat. If so, perhaps such habitat can be provided through innovative silviculture (Thomas et al. 1990).

Aha! So it is simply a question of habitat for spotted owls. If we can provide for owls with appropriate silviculture, there will be no need for reserving mature and old-growth forests. But, on the other hand, other species of plants and animals have evolved with or are disproportionately associated with old-growth. Some of these species will, almost certainly, end up in threatened status.

Aha! This is not only a question about owl habitat. It is, really, a question of old-growth management. But, the attributes of old-growth that provide the niches that support the animal species interact in mysterious ways to make up a forest ecosystem.

Aha! So, it is not really an old-growth question. It is an ecosystem question.

But, increasing knowledge indicates that the sizes, distribution, and connectivity between habitat patches are critical variables to consider in ensuring that the peculiar ecosystem retains the full inherent complement of species and ecological processes (Thomas 1979, Nass 1983, Harris 1984, and Probst and Crow 1991).

Aha! The issue is not just an ecosystem question. It is an ecosystem question and at landscape scale.

But, some people devoted to the preservation of old growth know or care little about the biological aspects of the issue. They simply see great beauty in the old-growth forests. Some perceive a spiritual value in the contact with and the existence of such forests.

Aha! So, it is not only a question of biological attributes but also of aesthetic and spiritual values.

But, if it is an ecosystem question that must be addressed at the landscape scale, what must this landscape accommodate? There are people in that landscape – part and parcel along with the plantations, the “ancient cathedral” forests, clearcuts, the elk and owls, and the streams and fish.

These people have desires, differing values, and untold aspirations that demand satisfaction. Each sees and wants different things from the landscape of which they too are part. And, they want their children and grandchildren to have these same things.

Aha! Then it really is an ecosystem sustainability question at a geographic scale where protection of nature, the production of goods and services for people, and the lifestyles of forest users must strike an enduring balance.

How do we do that?

And this..

Will the path we have been on for 50 years take us and our forests to a desired future state?

Consider the following. The first word in the pairs of words is where we have been and are. The second word is what we need to cultivate within ourselves to do a better collaborative job of stewardship. These word pairs are:

functional-interdisciplinary;
competitive-cooperative;
reductionist-holistic;
deterministic-stochastic;
use-value;
linear-interdependent;
rain in g-education;
simplify-diversify;
short term-long term;
site-landscape;
individuals-communities;
gladiator-diplomat;
rigid-flexible;
clever-wise; and
narrow-broad.
But, the fighting goes on and accelerates infrequency and intensity. The people, our sense of community, and the forest are bruised and battered in the process. The gladiators never tire of the fight – it is what they do. The fight itself provides their sustenance. I detect, however, that many concerned about forests we collectively own have long since approached exhaustion.

That may be good news, for with exhaustion, there may come a willingness to seek an answer to the statement made earlier, “There must be a better way.”

That better way can be built on new knowledge and past experiences and on changes in personal and societal concepts. And, that better way can be embraced because the old way has led us to a place where we cannot stand for long.

Shakespeare said (Julius Caesar, Act 1, Scene 2) “…the fault, dear Brutus, is not in our stars, but in ourselves…”

If the fault lies within us, the solution also resides in us as well.

Jack, .. we’re still on the path you laid out.. still looking for the diplomats. If you and your upstairs associates can help, we’d like to put in a request for more of these.

MOG Proposal-Soon To Come Out as Plan Amendments Not Regulation

Despite MOG not being on the regulatory agenda as I posted yesterday, within minutes I heard that it is coming out soon. Because it won’t be a regulation but rather a bunch of plan amendments, so that explains it, I guess.  I was hoping, based on climate and wildfire emergencies  for each forest to do a fire plan amendment focusing on delineating and maintaining PODs and fuelbreaks, plus fire use, so maybe there is some of that in there.

Here’s a story from E&E News.

The Biden administration is closing in on a proposal to protect old-growth forests on federal land while allowing some tree thinning and timber harvesting, groups familiar with the basic outlines of the plan said.

While the fine details of the proposal, to be published in the Federal Register within days, are closely guarded, policy groups said they expect the Forest Service to pursue forest plan amendments across the 193 million-acre national forest system that would limit — but not necessarily eliminate — logging in remaining old-growth stands.

The Forest Service referred questions to the Department of Agriculture, which didn’t immediately return a request for comment. The actions stem from an April 2022 executive order from President Joe Biden directing an inventory of mature and old-growth forest on federal land and measures to protect those areas for carbon sequestration and other purposes.
By amending forest plans — which are the guiding documents for managing each forest — the USDA would avoid the more lengthy route of proposing a formal rulemaking that would go past the current Biden administration. Still, forest plan amendments are subject to public comment periods that would stretch a few months, and there’s no guarantee that they’ll
proceed free of legal challenges that could delay or derail the process.
The environmental impact statement associated with a forest plan amendment would also take considerable staff time for an agency that’s already acknowledged being stretched.
Groups in contact with the Forest Service said they don’t expect the administration to address “mature” forests — or those that haven’t quite reached old-growth status — at length in this proposal, which would be a disappointment to environmental organizations that say those forests, too, deserve greater protections.
The administration’s actions could bring more consistency to managing old growth around the country, said Sam Evans, senior attorney with the Southern Environmental Law Center in Asheville, N.C.
“Protecting and restoring older forests is mission critical for the Forest Service. Across the board, it’s the single best way to protect rare species, store carbon, provide clean water and increase resilience to wildfire,” said Evans, who leads the organization’s national forests and parks program. Evans said forest plans are “wildly inconsistent” in how they treat areas of old growth, which can be areas that were never logged or have over time taken on similar characteristics.
The plan for the Nantahala and Pisgah national forests in North Carolina allows for logging old growth to encourage the creation of younger forest, for instance, while the Custer Gallatin National Forest in Montana requires projects to “retain old growth characteristics” while allowing projects in old-growth areas as part of meeting that objective, he said.
“There’s really no excuse for the lack of consistency. Cutting old growth in some places while protecting it in others will never make any real progress toward restoring our forests,” Evans said.
Seeking a consistent approach from one end of the country to the other presents its own challenges, advocates of a more intensive management approach say, because protecting an old-growth forest in fire- and drought-prone California, for instance, may require different approaches from protecting old growth in the rainforests of Alaska or the hardwood forests of the eastern U.S. And while some environmental groups say logging is the greatest threat to old-growth forests, the Forest Service is casting threats such as climate change and associated drought, wildfire, disease and pests as the main dangers — which can be addressed through a more intensive approach to managing forests.

In some places, the Forest Service continues to pursue timber sales in old-growth stands even though Biden pledged through an executive order to protect old-growth forests as a pillar of his climate policy.

I keep hearing this on various webinars and have asked the individuals for names of projects.  With regard to ones I’ve looked at, thinning in old forests, it’s intended to protect old trees in old-growth forests.

A lobbyist who works with the wood products industry said revising forest plans to reduce management — which can include thinning to reduce the spread of wildfire as well as larger-scale logging — misses an industry point: that healthy forests and such projects go hand in hand. “Millions of acres of forests of all ages are vulnerable to fires, insects and disease — which the Forest Service says are the leading causes of forest loss across the National Forest System,” said the lobbyist, who was granted anonymity to protect relationships with the administration. “Yet the administration is forcing the Forest Service to revise over 120 forest plans to impose further restrictions on management. This is an intentional distraction from the mission Congress has assigned to the Forest Service, which is reducing hazardous fuels and protecting communities from wildfires.”

There are lots of us out here that, again, don’t have a timber industry, but still want fuel reduction projects to go ahead.  Maybe we need to start an interest group (Wildfire Resilience Forever?) so we’ll get interviewed?

Forest plans have already become a battleground on the mature and old-growth issue, as critics of large-scale logging say the Forest Service is taking an overly permissive approach that collides with Biden’s executive order, which promised to “institutionalize climate-smart management and conservation strategies that address threats to mature and old-growth forests on Federal lands,” and will be the basis for how the Forest Service determines how and where trees can still be cut to meet the goal.

In October, for instance, the Center for Biological Diversity filed an objection to the new forest plan for the Grand Mesa, Uncompahgre and Gunnison national forests in Colorado. Among other complaints, the CBD said the forest plan — which was being developed at the time Biden issued the executive order — doesn’t do much to protect old-growth areas, although it does discuss retaining areas for wildlife habitat and says older trees store the most carbon.

On the other hand, the CBD said, the forest plan doesn’t include an accounting of how much old growth is present on the forests, and it specifically calls for removal of larger trees that the agency said may be most susceptible to beetle infestation. The Forest Service said in the forest plan, “This will temporarily reduce the live tree carbon pool but may increase the rate of carbon uptake and resilience to future disturbance.”

The idea that the GMUG didn’t count the old-growth seems unlikely to me but I will check.

However the administration proceeds, Congress will be tracking the issue as it crafts a new five-year farm bill in 2024, delayed from this year. That legislation’s forestry provisions will protect broad uses of national forests, including for timber production, House Agriculture Chair Glenn “G.T.” Thompson (R-Pa.) told E&E News on Tuesday.
“We want healthy forests, and that means regular harvesting and replanting,” Thompson said. “We’ll see what they say, and then we’ll tell them what they need to do with the farm bill.”

Can’t wait to see what they came up with!

MOG Update and Reporting: The 80’s Are Calling and They Want Their Controversies Back

Here’s a link to the webinar and they have more stuff posted on their website.

Our friends at E&E News had a piece on it. What was interesting to me is the framing.

The Forest Service’s approach has rankled opponents of old-growth logging and those who say even forests that aren’t quite that old shouldn’t be heavily harvested. But the timber industry and its allies in Congress say the findings underscore a point they’ve made for years: that cutting down trees for wood products from time to time is a part of keeping forests healthy.

Coming from what we might call the areas with much need for fuel treatments and little timber industry (like much of the interior west), it seems like our voices aren’t heard in this debate. I don’t think the timber industry is looking for “heavy” harvests.. I think they are saying that they can use some of this stuff that is removed. This is the old dichotomy.. “logging” supported by “timber industry” and leaving things alone. I feel like the discussion could be back in the 80’s. The other people that aren’t heard in this framing are all those collaborative folks working on zones of agreement and trying to find common ground.

I’m going to quote from the E&E news summary which I think is good (but haven’t double-checked numbers).

1. Logging for timber is not as big a threat to old growth and mature forests as are wildfires, insects and disease.

In slides shared with forest industry representatives and provided to E&E News, the Forest Service said wildfires have eliminated 2.6 million acres of mature forest and 689,000 acres of old growth since 2000 on lands managed by that agency and the Bureau of Land Management. The agency defines old growth as areas that haven’t been logged, for instance, and mature forest as areas that may have been logged in the past and have grown back substantially on the way to becoming old growth again.

In the same period, 1.9 million acres of mature forest was lost to insects and disease, while 134,000 acres of old growth suffered that fate.
“Tree cutting,” which the agency said includes logging but might include other actions, took 214,000 acres of mature forest and 10,000 acres of old growth on Forest Service and BLM lands, the agency said. “Currently, wildfire exacerbated by climate change and fire exclusion is the leading threat, followed by insects/disease,” the Forest Service said in the slides. “Tree
cutting (any removal of trees) is a third relatively minor threat.”

But is, say thinning, a “threat” or is it “protection” from climate-change exacerbated drought or wildfires?
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Sidenote:

Meanwhile, this was not explicitly stated by anyone, but reminds me of an argument I’ve heard in different contexts.

Even if certain activities have only a little impact, those are the ones we can control, so we should further reduce them. Something like bats and white-nosed syndrome, or or many species and climate. It tends to be the same old activities that need to be reduced, based on this argument.

Or wildfire smoke and other sources of pollution.. “Smoke, Screened: The Clean Air Act’s Dirty Secret” as per this article, or this one.

The wildfires, though, could force the EPA’s hand. They could compel the agency to bump Chicago and East St. Louis to a higher nonattainment level and, as a result, trigger tougher remedial actions.

But obviously the remedial actions wouldn’t involve stopping the Canadian wildfires, it would involve ratcheting down the usual PM 2.5 suspects in that state.
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2. Back to the E&E news article:

In total, the inventory shows the 193 million-acre national forest system has about 25 million acres of old growth, 70 million acres of mature forest and a little more than 50 million acres of younger forest. The system includes grasslands and other landscapes.

Older forest is likely to increase over time as younger areas age, the Forest Service said. The increase, estimated at 5.5 percent by 2070 on Forest Service and BLM lands, will slow after that point, officials said, based on agency modeling.

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3. Timber Wars Redux…

To logging critics, the Forest Service’s analysis doesn’t offer much relief. “Current rates of logging are not the only indicator of the precarious state of older forests in the nation,” said Dominick DellaSala, chief scientist at Wild Heritage, a Berkeley, Calif., project of the nonprofit Earth Island Institute.
DellaSala said less old growth is being lost recently because harvests in decades past “nearly liquidated the entire ecosystem.”

Barely a quarter of the nation’s old forests are in protected areas, as in designated wilderness, said DellaSala, who’s called for a halt to logging in old-growth areas. The U.S. needs a “national rulemaking process that protects all remaining older forests and large trees from logging as they are not safe from ongoing or future threats,” he said.

But about 30% are in Roadless, which are not apparently protected to DellaSala. Some people say this because they are not “permanent”. To my mind, as a person who has worked on a tediously litigated (no offense to readers who litigated) Roadless Rule, this is not a meaningful distinction. And 18% of NFS is Wilderness. So that adds up to 48%.

*************

4. “As much as 81 percent of mature and old growth is in areas with little logging capacity, according to the agency.”

This is an interesting number. It could be interpreted as:
1. The timber industry wouldn’t have that much of an impact if we let them have at the 20 percent (not a popular interpretation, I grant you).
2. Folks who want to thin for mature and old growth protection (either fuel reduction or increasing drought resistance) are going to need megabucks,  because currently there are not markets and viable substitutes for burning into the atmosphere. (We know this)
3. Maybe this isn’t really about logging? So maybe the controversy is between dry forest folks who want thinning (even with no industry available) and wet forest folks who don’t? It’s interesting that the article mentions the Tongass and not the millions of acres of MOG pinyon juniper from this fact sheet.

Pinyon and juniper woodlands are the most abundant forest type in the federal inventory of mature and old-growth forests, with 9 million acres of old-growth pinyon-juniper across BLM and Forest Service lands and an additional 14 million acres of mature pinyon-juniper.

4. Another framing than the aged and decrepit Timber Wars would possibly that Some Mesic/Coastal ENGOs exert an outsized influence over dry forest policy in their quest for a national MOG rule.

Other interpretations welcome.

ANPR Climate Resilient Forests and Grasslands- Update Webinar Link

I know, I know. A person could get confused because “climate resilience” sounds like its about adaptation, and the MOG discussion seems to be mostly about carbon, or at least the arguments for not cutting trees.. which we have been listening to for 40 years or thereabouts.. are now centered about carbon.  And of course, every little thing the FS does on the landscape needs to have some kind of climate considerations, and has for at least 15 years or so. So the ANPR seems to be asking for “suggestions about anything that the FS does.” I wonder how many other agencies have had a rule making that opens up “everything it does.”

In fact, the FS has what I consider to be an excellent document about climate adaptation.   And many of the people on these calls talk about MOG.  But I’ve been told by internal and external People Who Should Know that it’s really about resilience and not about MOG. Meanwhile ENGOs are working on a MOG policy solution with CEQ, the FS and others.

I’m a general fan of the FS, as you all know, but I would point out a couple of my concerns.   They used an abstraction in the webinar-  “active management” -regularly without defining it.  Fire suppression is active management, prescribed fire, planting trees, timber harvest and so on are all active.  Based on the views of the form letters I read in response to the ANPR and the views of people on our webinars, I’d say that most people with concerns did not want commercial timber harvest, although they said “logging”, which is not exactly well defined at the project level.  Tree cutting, or tree cutting and removal using heavy equipment, or tree cutting and pile burning, or  just commercial timber harvest but maybe not commercial firewood.. So that’s one thing.

My other quibble was with analyzing comments using AI (in this case, natural language processing).  I recently had a bad experience with AI so perhaps am a bit grumpy about it.  You’ll remember I FOIAd both CEQ and USDA for documents with “fire retardant” in them.  USDA gave me the documents they had, as far as I know,  including messages from key people at CEQ.  CEQ did not give me those messages, but did give me a DOE annual report and a mass of unrelated material.  Apparently, that was due to their AI, or perhaps someone did not type in exactly the right search term. It seems to me that using AI is not necessarily increasing transparency nor trust.  I’d argue that to build citizen confidence, each AI application during a test period should have the standard human approach run concurrently and both sets of results published and open for comment (aka Lessons Learned).  I have noticed that contractors and I didn’t always pick the same way of analyzing comments either, so perhaps there’s not one “human” way.  But the results would then be compared in one document that the public could view.   I would see this as needed only for rule making; in my experience, projects are not as complex for content analysis. Also the decision makers for projects and even plans tend to be close enough to the disagreements that they have a base understanding of them.  I am not so sure that’s true of the politicals involved in rule-making.. if they only listen to their friends, then the public comment summaries are key element of their understanding of opposing views.

I’d bet that “double coverage” would be expected and required, say, in fire suppression applications. To increase trust, accountability is also important.  AI, without careful management, could also be an escape valve for accountability, as in “Sorry, folks, the AI did it.” Similar to “it’s not our fault, it’s climate change.”

Anyway,  here’s a link to the presentation. I’m curious what strikes you about it.

E&E News: Forest Service Flooded With Comments on MOG ANPR

As Jon noted earlier in a different thread, it’s hard to know what exactly groups mean by no “logging”.. so I’d like to bring this discussion to the forefront, because it seems important that we understand what words mean. We can’t even tell if we disagree or not if we don’t use the same definition.

It is confusing..from this Earthjustice press release:

“The public wants the nation’s mature forests and trees to be protected from the chainsaw, and with good reason,” said Garett Rose, senior attorney at the Natural Resources Defense Council (NRDC). “They store carbon. They protect imperiled species. They safeguard key waterways. It’s well past time for the federal land managers to adopt a rule that durably protects these climate-critical trees — and lets them be a key ally in the climate right.”

(I think Rose  meant “fight.”) But chainsaws can’t distinguish if felled trees are going to the sawmill or not.

So let’s look at an E&E story..

The agency reported that more than 495,000 comments came through regulations.gov, and environmental groups say they delivered additional comments in person Thursday as the comment period ended on an advance notice of proposed rulemaking.

**********************

“The primary threat to mature and older forests is logging, not wildfire or climate change,” the Pacific Northwest chapters of Great Old Broads for Wilderness said in a letter typical of advocates for limiting timber production. The organization called for a halt to logging on mature and old-growth forests while the service contemplates a formal rulemaking procedure.

So the GOB group made that claim. That’s not what the data show in the ANPR, though. Unless “primary” has another meaning.


************

Agency officials haven’t said how they’ll proceed on regulations or even whether they plan to offer new limits on timber production. But because the call for comments follows President Joe Biden’s executive order directing an inventory of mature and old-growth forest, the timber industry and advocates for more intensive forest management said they worry the latest moves are the first toward heavier restrictions.

At the other end of the spectrum, the Sierra Club and Environment America said preventing the logging of mature and old-growth forests on federal land should be a “cornerstone of U.S. climate policy.” While federal protections such as wilderness designations and roadless-area limits on timber operations prevent logging in many areas of national forests, as much as 50 million acres of mature and old-growth forest on federal land doesn’t have such designations, they said, referring to the recent Forest Service inventory. “If the government lets timber companies chop them down, it will eliminate one of the most effective tools for removing the atmospheric carbon that exacerbates climate change. In addition, it would eliminate essential habitats for countless species and degrade the land,” the groups said in a news release.

**********

Environment America’s public lands campaign director, Ellen Montgomery, said Friday that while it’s not clear how the Forest Service will proceed, she doubts the administration would put such effort into the matter without planning to propose specific regulations. Time is short, though, she acknowledged, with Biden facing reelection in 2024 and the outcome uncertain. Although the rulemaking could touch on many issues, limiting timber production from national forests is an obvious choice, Montgomery said. “Logging is pretty simple to address,” she said. “We have complete control over what trees get logged or don’t get logged.”

**************

From the discussion in this news article, it seems like this is the old “no commercial harvest” discussion. But in many places, there is no market or infrastructure and trees are burned in piles. So it’s not clear what these groups mean exactly (we’ll look into their actual comment letters); if a fuels reduction project/thinning is proposed, would it be OK  to fall the thinned material and burn it  in piles rather than allow feds to sell it and be used? And it seems to be about “timber” and perhaps not so much about use for fuelwood or bioenergy? Because the Forest Service and other parts of USDA are researching uses for small diameter heretofore unsaleable material from both private and public lands. So does it really mean no cutting, no using at all, no commercial use, or no using for sawtimber?

The confusion about what “logging” means led in the Colorado Roadless Rule to us using the term “tree-cutting” to clarify that trees can be cut without being removed.  So that gets us into details of the prescription and the harvesting (or not) plan.  Many years ago (fortyish?) the silviculturists in our area went on a field trip to Lake Tahoe, where they were removing fire-wood sized chunks  in wheelbarrows because residents didn’t want the smoke from burnpiles.  On the other hand, many of the people currently involved in MOG (in some interest groups)  don’t have backgrounds in on-the-ground practices, so maybe they’re not aware of all these possible complexities.

Heller also quotes NAFSR (the Forest Service Retirees’ Organization)

The National Association of Forest Service Retirees, in a comment letter, said retaining and expanding mature and old-growth forest isn’t a goal grounded in law.
The association cited the Multiple Use Sustained Yield Act of 1960, which established that all forest uses must be considered in planning and management of the land, and said further restrictions on harvest of mature and old-growth trees may go against parts of a 2012 planning rule that’s supposed to govern Forest Service policy.
Drawing on more recent legislation, the retirees group said the potential rulemaking could run against the bipartisan infrastructure law and the Inflation Reduction Act, which provided money for stepped-up thinning of federal forests to reduce wildfire threats, including creation of forest fuel breaks.

Now I can’t speak for NAFSR nor other retirees (remember Jon and Jim Furnish and so many more are all retirees!) but I will add my own perspective (and I hope other retirees and others) do as well.

The Congress, at least the House, is interested in spending fuel treatment dollars wisely and getting the funded work done. Remember this “counting fuel acres accountability” bill from spring this year?

As for me, I really don’t care if such a proposed rule would be against MUSYA except for the fact that it would likely be litigated on that basis.  What I mind is asking the agency and partners to revise or terminate the fuel reduction and resilience treatments they’ve been dutifully working on. We know that the Forest Service is having trouble finding skilled employees. It seems like setting them up for even more morale-busting confusion now and down the road.   I want the few of them available to be working on PODs and prescribed and managed fire plans on my neighboring forests, and giving recreation the attention it deserves.

And if such a “no logging” proposal were to go through, then they would be placed in the weird “maybe-yes we can, maybe-no we can’t” space when AFRC and others litigate and at the same time Congress reacts.  Which to my mind wouldn’t be good for employee nor partner morale.

Finally, where do the collaborative groups fit into such a proposed rule? Such a rule could potentially nationalize decisions and override agreements made with local and practitioner knowledge in specific places- as different as the Tongass and the Ocala.