Old Growth

Open Forest Service MOG Engagement Session Monday at 2PM ET

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Here’s the link:

The public is invited to attend a virtual informational engagement session about the mature and old-growth forests initiative on Monday, July 24 at 2pm ET. Information will be shared about where we were, where we are, and what is next. The session will be an opportunity for you to share your thoughts, concerns and to ask questions. We value your time and aim to make the 2-hour session informational, interactive, and worthwhile!

To attend, please register for the virtual Zoom meeting. After registering, you will receive a confirmation with a meeting link.

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Several of us attended one today for specific kinds of partners.  It was very helpful to understand where the FS is coming from.   I’m still confused about how data that is not ground-truthed (not actually true) can be used to make national and regional decisions, but that’s kind of a more epistemological question.  Also I’m getting fairly leery of mapping exercieses.. data has confidence intervals associated with it… map colors not so much.  Anyway, I think it’s well worth it. It’s also interesting to hear others’ points of view and realize how very different different parts of the country are and how hard it will be for the FS to develop a regional or national policy that makes any sense.

 

Last Day for ANPR Comments: II. How Can the FS Respond to Rapidly Changing Conditions? (Associated with Climate-Amplified Impacts)

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The comments requested in the ANPR seem to me to be pretty much about everything the FS does.  Which is great, in a sense, because I think it’s an open door to make any comments you think would improve the FS.  For example, you could make an argument …. unknown climate changes=changing quickly=flexibility for FS to respond=more trust= better data for the public and more transparency= the People’s Database.

I copied the questions from the ANPR so you can check them out in this post.

Some of it seems like the same old problems.. like adaptive management. Remember Chief Thomas and the inception of the Inventory and Monitoring Institute?  And I think many TSW readers have had their own experiences and ideas which you could write up and send in today, if you haven’t. For me adaptive management always goes down to “how structured? and by whom, to what end?”  We also have examples like the Watershed Condition Framework- how did that work out? Some of us were on the front ends of these efforts.. some seem to have fizzled out and maybe we never hear what happened. Michael Ligquri had an interesting comment on that here when I first posted about the ANPR questions.

Two comments:

1) we tend to bog ourselves down with these kinds of open-ended, subjective, and unanswerable questions. All great questions, no doubt. But they tend to promote more “analysis paralysis”, and often fail to advance any significant “adaptation” to management. I’ve participated on several multi-year committees assigned to resolve these types of questions, and while we end up wordsmithing complex answers, little changes. To anyone who understands design theory, such “overconstrained, over-complex problem sets” is an inherently poor frame for solutions.

2) An effective approach that I’ve used to inform “adaptive management” is using performance-based monitoring/research approaches. This starts with structured working hypotheses that are both measurable and testable. It also includes specific targets and action thresholds based on objectively measurable existing conditions and trends analysis. Ideally, such approaches must include an understanding of geographic diversity. Watershed Analysis was originally designed to help inform such standards, but failed in its implementation (for many reasons, too complex to elaborate here).

And the more structured the framework, the less able to adapt to “rapidly changing” concerns and impacts. Not easy. But here are some quotes from the front end of the ANPR:

Climate change and related stressors, such as wildfire, drought, insects and disease, extreme weather events, and chronic stress on ecosystems are resulting in increasing impacts with rapid and variable rates of change on national forests and grasslands. These impacts can be compounded by fire suppression, development in the Wildland Urban Interface (WUI), and non-climate informed timber harvest and reforestation practices.

Multiple Forest Service plans, policies, and regulations already include direction on climate adaptation. However, given (1) increasing rates of change, and (2) new information and ways of assessing and visualizing risk, USDA and the Forest Service are issuing this ANPRM to seek input on how we can develop new policies or build on current policies to improve our ability to foster climate resilience, recognizing that impacts are different in different places across the country.

There’s a couple of interesting things about this framing.  First of all, apparently according to this, everything bad is climate or climate-related that needs to be adapted to.  So.. if we have a new introduced invasive insect, does that only require attention if it’s “climate-related”? If that’s the case, you can see people making the argument why it is climate-related, even when it isn’t.  Pretty soon everything is climate-related.  Even Covid-related recreation pressure (if it’s hotter in the cities, then more people will go to the mountains?).  If we keep going, then, all resilience is climate resilience, and we’re gone from multiple-use to ecological sustainability to ecosystem integrity to climate resilience, and at the end of the day it’s all the same stuff the FS has been doing with different words. You might also notice that after multiple use in this line-up, people and the social sciences seem to take a backseat. And yes, I understand that “without ecosystem/climate resilience, there would be no recreation” that’s kind of the “ecological sustainability is primary” 2001ish argument. But do all these definitional meanderings actually help any employees and users and neighbors make better decisions about the problems that confront them every day?

The other thing that struck me about this is the “development in the WUI and non-climate informed timber harvest and reforestation practices”.  I retired quite a while ago, and even then silviculturists, fuels practitioners and reforestation folks were considering climate in their work.  And one of the first papers on reforestation strategies and climate was in 1992, over 30 years ago. I also don’t see how “development in the WUI” contributes to “wildfire, drought, insects and disease, extreme weather events, and chronic stress on ecosystems” except for the obvious way that people who live in the area may start fires (but maybe homeowners are more careful than recreationists because it’s their properties.. do we know?), and neighbors not treating their trees could lead to more insects and disease? But why WUI folks and not other neighbors?

The concern about matching adaptation to “rapid and variable rates of change” reminds me of Chief Jack Ward Thomas on forest plans:

“Land use planning should be a meaningful – a guide to management action and funding – achieved within a year at much less costs. Before embarking on new efforts in planning it is critical to determine why such planning has failed so miserably and short comings rectified. Flexibility should be a component so as to deal sudden alteration in conditions – fires, markets, economics, and, insect and disease outbreaks.”

I think he said this about 30 years ago.. but note he mentions fire and insect and disease outbreaks.  Anyway, perhaps this is a good time to consider amending NFMA to help the FS be able to  respond to “rapid and variable rates of change”  and use the latest science at the period a project is proposed.

Recreation doesn’t play much of a role in this ANPR for some reason and it’s probably the #1 important use of National Forests now, so that’s also interesting.  Anyway, if you think they are asking “hey climate resilience is a new and different thing, how should we manage it?,” it seems like an opportunity to respond with any ideas you have for improvement in general.

You can post parts of your comments below or email me.  I’m curious about what people come up with.

 

Last Day for ANPR Comments I. The MOG Thing

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Today is the last day for comments on what I used to call the Mature and Old Growth ANPR.  First let’s give the Forest Service some kudos for the differences between it and the BLM proposed rule.  Like the IMBA letter suggests, the BLM could have benefited from collecting ideas (through an ANPR) and then further honing the proposal in a proposed regulation as the next step. Also when time periods were extended the BLM’s were shorter and the BLM had the close on July 5, right after when most people had a holiday weekend.  The BLM had a few public meetings and some online..the Forest Service approach was different, but then there is not a proposed rule yet, they’re collecting ideas in the ANPR.

Since I first posted on the ANPR, I’ve had much time to reread the Federal Register notice and look at some individual and group responses.  It remains puzzling to me as there seem to be two basic threads.  One is the mature and old growth question.. should some regulation be promulgated about not cutting trees in mature and old growth, as recommended by many ENGO’s?  Check out the Climate Forests Campaign here.

There are many ENGO heavy hitters (in the Biden Admin) like Earthjustice, NRDC, and the Sierra Club among the group. Their argument seems to be.. this is the rationale folks are sending in based on  the “take action” letter:

In addition, older forests and trees are far more adaptable to the impacts of climate change, especially compared to industrial tree plantations. Nationally, carbon losses from clearcuts and other logging are up to 5 times higher than emissions from fire and other natural forest disturbances combined. Logging older forests grossly undercuts these benefits.

We urge you to include in any future administrative rules an end to ecologically harmful logging of mature and old growth forests and trees on federal land. While there are certainly other threats to our older forests, including wildfire and drought, the threat of logging is fully under your control and can be quickly acted on.

The first few sentences appears to conflate federal and private lands (I can’t get their link to check it), and the alternative on national forests is not “industrial tree plantations.”

The second is that however tiny the proportion of disturbance due to timber harvest (regardless of purpose, including ecological restoration and fire risk reduction) that is what can be controlled so you should stop.  Presumably even for fire risk reduction and ecological restoration.

The ANPR has some interesting tables for those who haven’t read it, so I thought I’d put them in this post.

There are difficulties though, with the argument of stopping any tree-cutting in mature and old growth forests.  For one thing,  the bipartisan Congress has asked the Forest Service to cut some mature trees for fuels reduction, in part to increase the possibility of protecting old growth trees and stands.  Then there is the need for early successional habitat for diverse tree (species like some oaks and pines) and wildlife species, as biodiversity is thought to be a good thing, and is in the 2012 Planning Rule.

Given the desire and appropriations by a bipartisan majority in Congress for fuel treatments, I don’t see how any such no-cutting mature and old trees rule would end well (except for work for litigators). And for environmental lawyers here at TSW, no, I don’t think that making more work for you all is why these ENGOs are doing this.  Sure, you can say that the Sierra Club has wanted to end commercial logging since 1986 -ish, so perhaps climate is just the latest justification for this same point of view.  And the Biden Admin may seem like a good opportunity to run this up the flagpole.  But I can’t see an endgame where no-cutting trumps fuel reduction treatments and openings for biodiversity at the end of the “separation of powers” day.  And I know that folks in the ENGOs  know more than I do about this, and for sure are smarter and more politically astute than I am.  So what is this really about?

On the other hand,  some Forest Service folks have told me that the “no-cutting rule” idea isn’t going anywhere and the ANPR is really about how the FS should respond to climate adaptation.   But based on the FOIAs I’ve received, the FS isn’t necessarily calling the shots with regard to forest policy in this Admin (nor is USDA).  So I would be inclined to include your thoughts on MOG in any comments you want to send in today.  Next post: the rest of the questions in the ANPR.

 

Court vacates Colville NF project and parts of its revised forest plan

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This was going to be a “featured” case in a litigation summary post, but it turned out to be long enough for its own post.  Besides, forest plan litigation is rare, especially Forest Service losses, and this case covers a number of NFMA and NEPA issues that are frequent topics on this blog.  (And, full disclosure, I had something to do with it.)

  • Court decision in Kettle Range Conservation Group v. U. S. Forest Service (E.D. Wash):  Sanpoil clean

On the first day of summer, the district court vacated the decision for the Sanpoil Project on the Colville National Forest, and also vacated the relevant portions of the 2019 revised forest plan.  The portions of the revised plan at issue replaced the Eastside Screens 21-inch diameter limit with a guideline to protect large trees, but included many exceptions.  It also did not designate a minimum amount of old growth habitat to retain.

The court held that, “the agency failed to explain how the 2019 Forest Plan maintains the viability of old-growth-dependent species.”  More specifically, “the agency erred by failing to demonstrate that its data and methodology reliably and accurately supported its conclusions about the viability of old-growth dependent species under each planning alternative, and depicted the amount and quality of habitat.”  (Note that the Colville plan was revised under the 1982 planning regulations, which had somewhat different language describing wildlife viability.  However, this court did not rule on substantive compliance with the NFMA requirement, but rather found a failure to demonstrate compliance due to an inadequate administrative record based on the APA.)

The Forest stated that the selected alternative, Alternative P, provided a “high” viability outcome for these species and that the no-action alternative would not improve viability outcomes.  However, in the EIS, the data showed that “the No Action alternative provides more habitat than the selected alternative for three of the surrogate species,” and “creates the most late structure of any alternative.”  The Forest relied instead on an appendix in an associated Wildlife Report that employed a Bayesian belief model to assign letter grades to viability, which supported the rationale for selecting Alternative P.  The court explained:

Neither the EIS nor the Wildlife Report describe how the agency came to these scores for each species and action alternative. The agency did not define its methodology for assessing the letter grades, such as what factors it considered and the weight they were given. The grades assigned to each planning alternative lack explanation…  the agency acted arbitrarily and capriciously when it offered explanations that ran counter to the evidence before the agency and failed to satisfy the requirements of the NFMA.

The court also found that the Forest failed to discuss the amount and quality of habitat and population trends (a requirement of the 1982 regulations).

The court also held that the forest plan EIS violated NEPA by failing to meaningfully address the original Eastside Screens Report.  The Forest simply argued that it needed more flexibility to achieve the desired conditions, including avoiding numerous site-specific amendments to deviate from the diameter limit in the Eastside Screens.  The Forest failed to include the original Eastside Screens Report in its administrative record, and did not adequately respond to public comments about the Eastside Screens.  The court stated:

Its absence demonstrates that the agency failed consider the scientific rationale for adopting the 21-inch rule before deciding to discard it. The agency did not respond to viewpoints that directly challenged the scientific basis upon which the final EIS rests…  In doing so, the agency violated the NEPA. The absence of the Eastside Screens Report also demonstrates that the agency did not consider an important aspect of the issue, as required by the APA.

… the agency did not consider negative impacts, if any, from (1) elimination of the 21-inch rule or (2) retention of the exceptions in the new guideline. The NEPA requires the agency to discuss and not improperly minimize negative effects of a proposed action…  In this case, the EIS did not assess how often the new guideline’s exceptions will be invoked and how the exceptions may impact the agency’s conclusions about the environmental effects and species viability.”

The Sanpoil Project also violated NEPA.  The EA simply assumed that the new forest plan guideline would protect old-growth trees.  The court held:

This conclusion was contrary to the evidence. The Sanpoil Project EA did not specify the frequency of which the new guideline’s exceptions would be invoked, despite the 2019 Forest Plan’s stated objective of preserving old-growth trees. The agency is not required to catalogue specific trees that will be removed, but in this case, the agency was required to provide site-specific details at the project planning stage to provide a sufficient picture of the Sanpoil Project’s cumulative effects… Without sufficiently specific information about site impacts, the Sanpoil Project’s impact to old-growth trees and their dependent species is speculative.”

(This overlaps to some degree the issues surrounding “condition-based NEPA.”  The court even cites the Forest Service Handbook: “If the Agency does not know where or when an activity will occur or if it will occur at all[,] then the effects of that action cannot be meaningfully evaluated.”  It also is difficult to demonstrate consistency with the forest plan if the project documentation does not provide information about how a project is meeting forest plan requirements.)

The project also violated NEPA and NFMA by conducting “cursory analysis” of the effects of the project on gray wolves, wolverine, sensitive bat species, northern goshawk, and the western bumblebee.  Finally, the court found that NEPA requires an EIS for the Sanpoil Project because it “creates uncertain risks to old-growth forests and the wildlife dependent on them, and “sets a precedent for future actions that utilize the new old-growth guideline, each of which may be individually insignificant, but create a cumulatively significant impact when applying the new guideline.”  Moreover, the lack of quantified or detailed information about the Sanpoil Project’s impacts in this respect “is also highly controversial due to the same questions about its size and nature and effect of the action on old-growth dependent species.”

The court found that this “case” was ripe for judicial review “when the agency issued RODs for both agency actions” “because the Sanpoil Project is a site-specific action governed by the 2019 Forest Plan.”  The plaintiff had argued that forest plan decision challenge was ripe because it dealt with a forest-wide viability requirement rather than timber sale requirements found not ripe by the Supreme Court in its Ohio Forestry decision.  However, the plaintiff also argued that ripeness of forest plan issues could be based on this project decision implementing the plan.  It is not completely clear which rationale the court is employing.  The court also found that the plaintiff had exhausted administrative remedies by identifying large, old trees, wildlife viability and the Eastside Screens “thoroughly and consistently during the public comment process.”

Comment Period Extended For MOG ANPR (July 20)- Opportunity to Post Your Comments Here

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The comment period for what I call the Mature and Old Growth Advanced Notice of Proposed Rulemaking (the MOG ANPR) has been extended to July 20th. A nice gentleman at the Forest Service told me that it’s really called the ANPR on “climate-informed forestry” which would be different from the actual title at the Federal Register (Forest Service Functions). Anyway, it could be confusing if you just look at the main page which shows the old date and the number of days is wrong (see second screenshot above). This seems needlessly confusing IMHO.

If you’re interested in finding out about extensions, you can always subscribe for updates. Here’s where the the extension is posted.

As a non-paid person who often is asked to write or help with letters, I like to browse other people’s comments and see if they have interesting ideas. It would be handy if there were a search box that would not bring up form letters, or perhaps if you could set it to only include letters from organizations. Maybe more experienced people know if there’s a search possibility to do that?

Anyway, if you or your organization has submitted comments on either rule you would like to share, please link below.

Thanks!

Let’s Discuss: the Norm-and-Jerry MOG Op-ed in Politico

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Side note: whatever your thoughts, please comment on the MOG ANPR here. That is Mature and Old Growth Advanced Notice of Proposed Rulemaking.  Some people have had trouble finding the link, perhaps due to the bizarre title “Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions.”  Comments are due June 20th. We appear to be in the middle of a major media campaign on the MOG, so this seems like a good time to discuss some concepts.

Norm Christenson and Jerry Franklin had a an op-ed in Politico yesterday.  I’m a big Jerry Franklin fan, based on my personal interactions with him since the 80’s. I’ve told some of the stories before, so I won’t bore you with them again. Mostly our disagreements have been about west-side vs. east-side practices, ecology and experience.

I like how they tagged on the wildfires in Canada to “underscore the need to let our current mature forest grow old.”  You could also argue that the wildfires in Canada underscore the fact that wildfires are a danger when trying to use forests to mitigate climate change.  Because if you believe that climate change will cause forests not to grow back, you’ve just blown your last tree sequestration opportunity plus released much carbon (and PM2.5).

“It turns out the age and composition of forests makes a big difference in what role they play in preventing wildfires and storing carbon. Old growth forest is the best at both, but there is very little old growth left in either the western or eastern United States.”

I would argue that old growth forest in some species/places is not the best in “preventing” wildfires (what does “preventing” even mean in this context?).  Take a mixed ponderosa/true fir understory stand with large old pp.. how exactly does that “prevent” wildfires? I won’t go into carbon because the sequestering/storage burning up all depends on assumptions which may differ.

As part of the MOG effort, the FS counted the BLM and FS Old Growth acres and you can see them in the above table. It looks like 33 mill acres or thereabouts, or about 18% of the total. Note that this is just FS and BLM, there is probably OG on other state and country and private lands as well. So.. are 33 ish mill acres plus other unknown acres “very little” or not? How would we know what the “right” amount is?

But a large amount of the forests on public lands is what foresters call “mature” forest, which is nearly as good as old growth and in fact is on the brink of becoming old growth. It is these older forests that will help us prevent future forest fires and will do the most to reduce climate change, and its these forests that we need to protect at all costs.

I’m still interested in the mechanism of older forests helping us “prevent” fires.  I have to admit, the old forests in my neck of the wood seem to be slacking off on this.

Then there’s  the “p” word.. protect- the question is “protect from what?” This op-ed seems to mean “protect from removing any trees”.. but you can in the chart below (in the ANPR) see the timber harvest acres (including ecological restoration and fire risk reduction) are relatively tiny compared to fire and bugs and diseases.  I guess I can see the argument “we can’t affect wildfire, and insects and diseases, so let’s focus on timber”; except that we can affect acres impacted by wildfire by thinning.  Unless you believe that fuel treatments, PODs, etc. don’t help protect mature and older forests.  Which isn’t the view of the fire science community nor practitioners.  In fact, that isn’t addressed in this op-ed.

Within a few years, tree seedlings grow quickly, and their canopies expand to form a continuous green “solar panel.” The time it takes for this growth depends on the site’s fertility and the number of pioneer trees in the environment. The result is an immature forest composed of trees of small stature and similar age. These immature forests pose a high risk of wildfire due to the abundance of fine fuel, small branches and leaves, near the ground.

This reminds me of our 1980’s Central Oregon silviculture workshop with Bruce Larsen and Chad Oliver- when trees compete for water, they don’t grow the same way as the standard models and thinking based on competition for light.  The old mesic forest bias.  And when water is limiting, then thinning can increase vigor of trees and reduce beetle outbreaks in some cases. This isn’t scientifically controversial. There’s probably a literature review out there;  here’s one example from the Northern Rockies

Our results show treatments designed to increase resistance to high-severity fire in ponderosa pine-dominated forests in the Northern Rockies can also increase resistance to MPB, even during an outbreak.

So “protecting”  increases risks from pine beetles and wildfire, which doesn’t actually sound, in those cases, very protective.

As to the green “solar panel” well..that kind of implies an even-aged stand, which many stands that I observer are not. And then there are forests that never form continuous crowns due to competition for water.

I can understand if some don’t want to count pinyon-juniper as forests, but then maybe each kind of forest should be considered separately,  including mesic and dry forests.

 

Here are some interesting and relevant Q&As from the ANPR.

Q. What restoration options are available to restore old-growth forest structure in frequent fire forests?
Mechanical thinning and prescribed fire represent the primary approaches to active restoration of frequent-fire mature and old-growth forest areas to reduce their vulnerability to wildfire. Reduction in tree density often increases resilience to the climate-driven impacts of droughts, insects and wildfire.
Restoration prescriptions generally aim to increase the diversity of trees – age, size, and species – and retain the largest trees of the most fire-resistant species in the area. Diverse forests are more resilient because threats are less likely to impact trees species, ages and sizes at once.

Q. Are old-growth forests climate resilient?
Many old-growth forests have resilient characteristics like thick bark, high canopies, and deep roots. Some, like coastal redwoods, require moderate year-round temperatures and abundant moisture to thrive. As such, they are highly vulnerable to shifting conditions. As climate continues to deviate from historical
norms, even otherwise resilient forests are expected to be at increasing risk from acute and chronic disturbances such as drought, wildfires, disease, and insect outbreaks. These threats heighten the vulnerability of mature and old-growth forests resulting in higher chance of forest loss.

Your thoughts?

 

Are large, eastside grand firs friend or foe?

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Large-diameter grand fir (Abies grandis) in a mesic, mixed-conifer forest of northeast Oregon. Credit: Conservation Science and Practice (2023).

A new release from a some of our favorite authors about the proposed amendment to the Oregon and Washington Eastside Screens forest plan requirements – the “21-inch rule.”  The primary focus is summarized here (and there is a link to the research paper):

“Interest is growing in policy opportunities that align biodiversity conservation and recovery with climate change mitigation and adaptation priorities. The authors conclude that “21-inch rule” provides an excellent example of such a policy initiated for wildlife and habitat protection that has also provided significant climate mitigation values across extensive forests of the PNW Region.”

Until I saw this photo, I had imagined an army of evil grand fir trees sneaking up under pines and larch, and stealing their water and threatening to burn them up.  They seem to be the Forest Service’s Enemy #1 these days in eastern Oregon and Washington.  So dangerous, in fact, that the agency undertook another dreaded forest plan amendment process to give the agency more weapons to fight off this scourge.

This paper portrays them in a much different light, as providing benefits to both carbon storage and resilience to fire (along with their original wildlife protection benefits targeted by the original Eastside Screens amendment) – and NOT posing a substantial barrier to fuel treatment.

“The key rationale for amending the 21-inch rule is that increased cutting of large-diameter fir trees (≥53 cm DBH and <150 years) is needed to facilitate the conservation and recruitment of early-seral, shade-intolerant old ponderosa pine (Pinus ponderosa) and western larch (Larix occidentalis) by reducing competition from shade-tolerant large grand fir (Abies grandis) (USDA, 2021).

This represents a major shift in management of large trees across the region, highlighting escalating tradeoffs between goals for carbon sequestration to mitigate climate change, and efforts to increase the pace, scale, and intensity of cutting across national forest lands. The potential impacts of removal of large grand fir on wildfire are unclear, although a trait-based approach to assess fire resistance found that the grand fir forest type had the second highest fire resistance score, and one of the lowest fire severity values among forest types of the Inland Northwest USA (Moris et al., 2022).

Large ponderosa pine co-mingle with large grand fir about 14% of the time (259 plots), leaving 86% of plots with large ponderosa pine without large grand fir (1616 plots). Similarly, large western larch co-mingle with large grand fir about 56% of the time. Large ponderosa pine and grand fir are found together on only 8% of all plots in the region, while large larch and grand fir are found together on only 4% of all plots in the region.  (I added the emphasis for clarity.)

Enhancing forest resilience does not necessitate widespread cutting of any large-diameter tree species. Favoring early-seral species can be achieved with a focus on smaller trees and restoring surface fire, while retaining the existing large tree population.”

If nothing else, these conclusions clearly refute the Forest Service argument that reducing fire risk is “impossible” without logging the few (but important) large grand fir trees.

A First Look at MOGgie ANPR. II. Let’s Ground Truth the New FS Climate Risk Viewer!

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The Secretary’s Memo directs the Forest Service to spatially identify wildfire and climate change-driven threats and risks to key resources and values in the National Forest System, including water and watersheds, biodiversity and species at risk, forest carbon, and reforestation. Further, section 2 of E.O. 14072 specifically directs Federal agencies to identify mature and old forests on Forest Service and Bureau of Land Management (BLM) lands.

Through this ANPRM, USDA is sharing the beta version of a new Forest Service Climate Risk Viewer ( https://storymaps.arcgis.com/​collections/​87744e6b06c74e82916b9b11da218d28) for public feedback (see Section 1 below). This beta version was developed with 38 high-quality datasets and begins to illustrate the overlap of multiple resource values with climate exposure and vulnerability. The viewer also includes current management direction on National Forest System lands. The viewer allows for a place-based analysis of the need for climate adaptation to maintain, restore, and expand valued forest ecosystem and watershed characteristics. Additionally, the viewer supports identification of gaps between current management and potential conservation and adaptation practices. The beta version of the mature and old-growth (MOG) inventory that is being developed pursuant to E.O. 14072 and the RFI for MOG is also being released to help inform policy and decision-making on how best to conserve, foster, and expand the values of mature and old-growth forests on our Federal lands. Core information from the MOG inventory has been integrated into the viewer.

I took a brief look and it was very complex.  With a lot of RCP 8.5. So I will take some time and dig in for my own area, and hope others will do the same.

Synchronistically, Roger Pielke Jr. just posted a piece on his Substack this AM on another topic, but I think his thoughts are relevant to these maps.

Question 1: What scenarios are used to produce the estimates?

As frequent readers here will well know, the choice of scenario used in a climate projection can make the difference between an apocalyptic-looking future and one that appears much more manageable. You won’t be surprised to learn that many, if not most, studies that project future public health impacts of climate change rely on extreme, implausible or even impossible scenarios.

Question 2: How your analysis factor in adaptation?

One of the most incredible success stories of science, technology and policy over the past century has been the incredible progress around the world in improving adaptative capacity to weather and climate. This success story rarely gets reported on but that makes it no less real. There is of course more to do and continuing efforts are needed to maintain the progress made to date.

One dirty little secret in most studies of the future impacts of climate change (and not just on the effects of changes in extreme temperatures) in that future adaptation to climate variability and change is simply left out of projections. Assumptions are made that the climate will change, but people’s behavior will not. This is not how the real world works.

Adaptation- that’s the world of the natural resource professional.  Wildland fire technologies and people, and so on.  That’s us. We’re not included.

Note:  I am absolutely not criticizing the FS nor the USDA for doing it this way. They have to do what they are told, and use existing stuff. They have to go with the flow.

At the same time, in our quest to understand whether that information has any value, we need to take Roger’s points into consideration. And as I’ve said before, no one understands how populations of organisms will respond to any changes. So there’s that.

A First Look at the MOGgie ANPR – I. Up to Timber and Reforestation

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Thanks to a TSW reader for this working link to the MOG ANPR!  Mature and Old Growth, Advanced Notice of Proposed Rulemaking, that is. It has the funniest and possibly least helpful title of any ANPR I’ve seen.. at least what the Federal Register has posted.

Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions

Ok, then.

Climate Resilience is a Thing Worthy of Note

My favorite part is

Uses the Planning Rule’s definitions of ecological integrity and social and economic sustainability to structure the concept of climate resilience. Climate resilience is essential for ecological integrity and social and economic sustainability.

Aside from the future Land Management Agency abstraction Smackdown with BLM on “intactness”, one wonders what it to use a “definition” to “structure” a “concept”.    As everyone knows, I have not been a fan of “ecological integrity” as a concept.  But I definitely like the idea of the essentialness (apparently not a word) of climate resilience.  Underlying these are ideas that “leaving alone is always best” (intactness) versus “to get things people, wildlife and fish like,  management can be necessary.”

Note that these ideas are not at their base scientific at all- they are philosophical differences.  And the importance of Native American tools and uses runs into philosophical problems with the Garden of Eden-y school of intactitude.

And so, what will be the role of HRV or NRV?  Will we be able to give the historic vegetation ecologists a well-deserved break (for whom, as I commented at the time, the 2001 and later rules were a full employment program) from their tedious (to me)  infighting about what used to be, the roles of Native Americans and so on.

I live in hope that the ideas of dynamic systems will root out the old forms of “return to equilibrium” “balance of nature” or a return to the past.. at least for the Forest Service. But maybe that’s too much to expect from this peculiarly named ANPR.

Timber Harvesting

“To put this evolution of National Forest System management into context, currently the Forest Service commercially harvests one tenth of one percent of acres within the National Forest System each year. Harvests designed to improve stand health and resilience by reducing forest density or removing trees damaged by insect or disease make up 86 percent of those acres. The remainder are final or regeneration harvests that are designed to be followed by reforestation.”

This is kind of a duh for most TSW readers.  So I can see the philosophical argument already. “Even though it’s only a little bit, it’s something we can control.” I’ve heard this argument about PM 2.5.. “we can’t control wildfires so we need to ratchet down fossil fuel use.” And of course, the idea that wildfires can’t be managed runs against folks’ lived experience, the Wildfire Commission, various Congressional large chunks of money, and so on.  It seems like no matter what the problem is .. diseases, wildfire, climate change.. the answer is always to reduce uses some key constituencies don’t prefer.

“At the same time, over the past 15 years data shows that disturbance driven primarily by wildfire and insect and disease has adversely impacted more than 25 percent of the 193 million acres across the National Forest System (see Figure 2). This rapidly changing environment is now the primary driver of forest loss and type conversion. Wildfire alone causes approximately 80 percent of reforestation needs on National Forest System lands, and we expect those needs to continue to grow: More than half of the 4 million acres of potential reforestation needs on National Forest System lands stems from wildfires in 2020 and 2021 (see Figure 3).

E&E News Story on OG Forests and NASA

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The Coconino National Forest in Arizona contains forests of pinyon pine and juniper. | Deborah Lee Soltesz/Coconino National Forest/Flickr
This one is now not paywalled.  I didn’t see the ANPR… can someone send a link?

“The Forest Service’s most recent science shows that fire, insects and other factors are leading to large-scale losses in mature forests, not timber harvest. Reforestation needs similarly are being driven by large fires,” said Bill Imbergamo, executive director of the Federal Forest Resource Coalition (FFRC), which represents companies that harvest timber on federal land.

In it advanced notice of proposed rulemaking and request for comment to be published in the Federal Register, the Forest Service said the changed environment from wildfire, disease and insect pests is the “primary driver” of forest loss in the past 15 years, with wildfire accounting for more than 80 percent of reforestation needs. Most timber harvesting in national forests, which has declined sharply over the years, isn’t designed for commercial purposes, the agency said.

“To put this evolution of National Forest System management into context, currently the Forest Service commercially harvests one tenth of one percent of acres within the National Forest System each year. Harvests designed to improve stand health and resilience by reducing forest density or removing trees damaged by insect or disease make up 86 percent of those acres. The remainder are final or regeneration harvests that are designed to be followed by reforestation,” the Forest Service said.

Also this from NASA:

The nation’s old-growth forests encompass different tree species in different regions, from towering redwoods and 5,000-year-old bristlecone pines to diminutive pinyon junipers whose age and grandeur are less immediately obvious. For decades the U.S. Forest Service has studied such trees in hundreds of thousands of plots across the country, but the agency has never issued a formal accounting until now. To identify and define such forests, the team analyzed decades of field-gathered data from a wide variety of forest types and ecological zones, while also collecting public input in the process.

 

America’s forests help absorb more than 10% of our annual greenhouse gas emissions. While younger vegetation accumulates carbon more rapidly, old-growth forests contain more biomass overall and store more carbon. Not only are these ecosystems essential to the country’s clean air and water, they hold special significance to Tribal Nations, they sustain local economies, and they conserve biodiversity.

 

Complementing the Forest Service’s boots-on-the-ground research, some NASA-funded scientists are using a space-based instrument called GEDI (Global Ecosystem Dynamics Investigation) to provide a detailed picture of these forests. From its perch on the International Space Station, GEDI’s laser imager (lidar) is able to peer through dense canopies to observe nearly all of Earth’s temperate and tropical forests. By recording the way the laser pulses are reflected by the ground and by plant material (stems, branches, and leaves) at different heights, GEDI makes detailed measurements of the three-dimensional structure of the planet’s forests and fields. It can even estimate the weight, height, and vertical structure of trees.

 

“The partnership with NASA will help us do analyses we have not been able to do in the past,” said Jamie Barbour, who leads the old-growth initiative for the U.S. Forest Service. “From space, we’ll be able to drill down and learn about so many more places.”

……….

GEDI collected four years of forest observations around the world, before recently entering hibernation on the International Space Station.  Extension of the GEDI mission is currently under discussion, and if the extension is approved, it is expected that monitoring of mature and old-growth forests will resume when it returns to service within two years.

This reminds me of the public forum I attended on MOG with the Forest Service, where many people wondered how useful an inventory is, and for what purposes, if not updated frequently.. like after wildfires take out old growth and mature trees.  But maybe the point is to do “monitoring” over longer periods of time, perhaps with scientific but not direct policy relevance to local/regional forest management? It does seem to be a feature of our age.. collecting info and using it are not necessarily connected.