Old Growth

Lotsa New Stuff from Admin: MOG Inventory, Reforestation, ANPR for Resilience, Climate Risk Viewer and Field Guidance

by

These are all of interest. Please take a look and let us know what you think! Here’s the press release. My first few thoughts are in italics.

“WASHINGTON, April 20, 2023 – Today, in anticipation of the upcoming Earth Day celebrations, the U.S. Department of Agriculture (USDA) and the Department of the Interior (DOI) announced actions to foster forest conservation, enhance forest resilience to climate change, and inform policymaking on ensuring healthy forests on federally managed lands administered by the USDA Forest Service and the Bureau of Land Management (BLM).

To support these actions, USDA and DOI worked together to develop several reports, as directed by President Biden’s Executive Order on Strengthening the Nation’s Forests, Communities, and Local Economies (E.O. 14072), which he signed on Earth Day 2022. The Executive Order calls for inventorying mature and old-growth forests, setting reforestation targets on federally managed lands, and analyzing reforestation opportunities on state, Tribal and private lands. In addition, the Forest Service is releasing a new tool that illustrates the risks and vulnerabilities of climate change across the landscape along with a call for public input on how national forests and grasslands should be managed for climate resilience.

These actions represent concrete progress on the goals and priorities outlined one year ago in President Biden’s Executive Order, Secretary Vilsack’s Memorandum on Climate Resilience and Carbon Stewardship, as well as in the USDA Forest Service’s Wildfire Crisis Strategy, Climate Adaptation Plan (PDF, 26.1 MB), and Reforestation Strategy (PDF, 7 MB).

“Our forest ecosystems and communities are struggling to keep up with the stresses of climate change, whether it’s fire, drought, or insect infestations, it is clear that we must adapt quickly,” said USDA Under Secretary for Natural Resources and the Environment Homer Wilkes. “The USDA and our federal, tribal, state, local and community partners are working together to meet these challenges, pooling knowledge, sharing resources and discovering new ways to conserve resources, protect communities and ensure future generations can enjoy the countless benefits our forests provide.”

“Healthy, resilient forests are critical to helping us respond to the climate impacts being felt by communities across the country, because they store carbon, provide clean air and water, and sustain biodiversity,” said BLM Director Tracy Stone-Manning. “The reports released today will help enhance our work to protect and grow forests by creating a scientific framework for further study and public engagement for effective forest management and protection.”

Newly Released Joint Reports on Forest Conservation

The Mature and Old-Growth Forest report defines what mature and old growth forests are, establishes the first-ever initial inventory of those forests, and shows their distribution across lands managed by the USDA Forest Service and the Department of the Interior’s Bureau of Land Management. The initial inventory identified more than 32 million acres of old-growth and around 80 million acres of mature forest across 200 types of forests. The initial inventory found that old-growth forest represents 18% and mature forest another 45% of all forested land managed by the two agencies. Recognizing the many values of mature and old-growth forests, both agencies conducted significant outreach to gather public input from communities, tribes, scientists, and agency professionals in the report’s development.

Like all the nation’s forests, mature and old-growth forests are threatened by climate change and associated stressors. The initial inventory and definitions for mature and old-growth forests are part of an overarching climate-informed strategy to help retain carbon, reduce wildfire risk, and address climate-related impacts, including increased insects and disease.

As directed in President Biden’s Executive Order and laid out in the report, the USDA Forest Service and the Interior Department’s Bureau of Land Management will use these definitions and initial inventory to continue to refine results, assess threats to old growth and mature forest stands, and conduct public engagement. In the near future, the USDA and BLM also plan to incorporate information gathered from the National Aeronautics and Space Administration’s (NASA) Global Ecosystem Dynamics Investigation mission, which will provide forest inventory and analysis plots using space-based laser measurements. These efforts will help the agencies meet the science-based approach required in the executive order as well as develop management policy and strategies to recruit, sustain, and restore mature and old-growth forests.

Pinyon and juniper woodlands are the most abundant forest type in the federally managed inventory of mature and old-growth forests, with nine million acres of old-growth pinyon-juniper across BLM and Forest Service lands and an additional 14 million acres of mature pinyon-juniper. This summer, the Forest Service and the BLM will be co-hosting public workshops focused on sustaining resilient pinyon-juniper ecosystems. The workshops are intended to ensure robust public engagement and scientific expertise and knowledge are underpinning the approaches taken to fulfill the Executive Order and other management strategies for ensuring healthy, resilient pinyon and juniper woodlands.

Interesting because as I’ve pointed out, previous forest policy issues and debates have always had a mesic/timber framing.  “Robust public engagement” might mean with those inhabiting those ecoystems- perhaps a different set of folks than the usual suspects.

USDA and DOI are also releasing a joint reforestation report (PDF, 471 KB) which includes reforestation targets, assessments and recommendations for increased capacity for seeds and nurseries.

In response to feedback from stakeholder engagement, the report offers recommendations to conduct seed and nursery operations, improve coordination with non-federal partners, leverage opportunities for innovation with the private sector, and build a reforestation workforce with partners like the Conservation Corps.

To develop targets for reforestation on public lands by 2030, USDA and DOI evaluated recent peer-reviewed assessments and datasets conducted on public lands and identified more than 2.3 million acres in need of reforestation. This report also includes an assessment of more than 70 million acres of possible reforestation opportunities with state, tribal and private landowners, providing valuable insight on how existing partnerships and programs could be focused where they are needed most.

Advanced Notice of Public Rulemaking to Build Climate Resilience

With climate change and related stressors causing rapid, variable change on national forests and grasslands, the Forest Service is asking for public input on how the agency should adapt current policies to protect, conserve, and manage national forests and grasslands for climate resilience. This Advanced Notice of Proposed Rulemaking for National Forest and Grassland Climate Resilience will be published in the Federal Register and publication will begin a 60-day public comment period. The Forest Service is also consulting with tribes and requesting feedback on current issues and considerations related to relying on the best available science including indigenous knowledge, as well as climate adaptation, mature and old-growth forests, and considerations for social and economic resilience.

I wonder why the BLM isn’t doing this also?  They don’t need a comment period, as they already know how to build climate resilience?  One could argue the FS also has a pretty good idea.  So, what is this really about?

Climate Risk Viewer

As part of today’s announcement, the USDA Forest Service is sharing the beta version of a new tool to assess climate risks and vulnerabilities called the Forest Service Climate Risk Viewer. Developed with 28 high-quality datasets, it shows how resources overlap with climate exposure and vulnerability. This allows for more localized analysis of how climate adaptation can maintain, restore and expand forest ecosystems and watersheds. The viewer includes the new mature and old-growth forest inventory data for the Forest Service as well as datasets to identify gaps between current management and potential conservation and adaptation practices.

Bipartisan Infrastructure Law Field Guidance

In keeping with the spirit of President Biden’s Executive Order, earlier this week Forest Service Deputy Chief Chris French sent a letter to Forest Service Regional Foresters outlining leadership direction related to implementation of section 40803(g) of the Bipartisan Infrastructure Law regarding, which requires the consideration of how to manage for among other things, large trees and old growth stands in forest health projects.”

I’m not sure how this last one might fit with legislative intent, but if it’s not, I’m sure that Congressional folks will point it out.

 

Nantahala-Pisgah forest plan revision – done

by

 

The Nantahala-Pisgah National Forest has completed revising its forest plan.  The final plan was released on February 16 and implementation began last week.  The revision website is here, and the response to the objections is here.

Said Sam Evans, leader of the National Forests and Parks Program for the Southern Environmental Law Center (and Smokey Wire contributor) “A big disappointment for me here at the end of the process is that it is more of the same. It’s going to drive a wedge between stakeholders that had found consensus.” “We can sue over the plan,” Evans said. “We can oppose projects as they come up under the new plan. I would say the only thing that’s not an option for us is letting this plan roll out and be implemented in a way that continues to degrade those same resources — unroaded areas, healthy, intact forests like the state Natural Heritage Areas and existing old growth.”  The ”stakeholders” would be the Nantahala-Pisgah Forest Partnership of 20 interested organizations.  This article continues to discuss these disappointments in more detail (though apparently not all of the stakeholders are unhappy).

The Partnership wanted to see various tier objectives tied together so that, for instance, the Forest Service couldn’t move on to Tier 2 timber harvest goals without first meeting Tier 1 goals in other areas, such as invasive species management and watershed protection. Additionally, the Partnership said, the plan should require ecological restoration treatments to be paired with any commercial timber harvest occurring on the forest landscape.

The group was also concerned that 54,000 acres of state Natural Heritage Natural Areas were placed in management areas open to commercial logging and road building, and that the plan didn’t allow for protection of old growth patches found during timber projects. The group wanted to see a “cap and trade” approach to the 265,000-acre Old Growth Network identified in the plan, so that lower-quality patches in the network could be swapped out for higher-quality patches encountered during projects.

According to Evans, only 30,000 acres of the 265,000 acres is at the minimum age level to qualify as old growth, and the remainder is middle-aged forest of 60-100 years. Meanwhile, known old growth stands were not included in the network. The Forest Service does not have a figure for the number of acres in the network that currently qualify as old growth. “We’re trading young forest that maybe will become older one day for existing old growth now,” Evans said, “and that isn’t a good trade for the species that live in old growth forests and don’t move around.”

The forest supervisor had an interesting response to this old growth issue:  “Because of the complexity of the forest, there’s always going to be places that we might find a particular stand that is in that older forest type, and we can say, ‘You know what, that’s an area that’s special, and that we want to favor for those types, and that’s part of a larger project that’s holistic in a given area,’” he said.  They CAN say that project-by-project, but by allowing that flexibility, does the PLAN comply with the requirements for it to affirmatively provide habitat for at-risk species?

There is also disagreement about whether it does what it should to address climate change.  It apparently pits carbon storage (mitigation) vs “resilience” (adaptation).  Shouldn’t carbon storage projections include any additional risk of having less “resilient” forests?  There was a recent question on this blog about how forest plans are dealing with climate change.  This article (which also highlights the criticisms of the plan) lists the Forest Service’s seven main goals for “dealing with the impacts of climate change” (which are about adaptation rather than mitigation)

  • “Where there are species at risk that are susceptible to the effects of climate change, promote activities that support suitable habitat enhancement.
  • “Consider and address future climate and potential species range shifts when planning restoration projects, facilitating species migration and adaptation when possible.
  • “Monitor for new invasive species moving into areas where they were traditionally not found, especially in high-elevation communities. Utilize the monitoring information to assess threats and prioritize treating highly invasive infestations.
  • “Restore native vegetation in streamside zones to help moderate changes in water temperature and stream flow and enhance habitat.
  • “Anticipate and plan for changes in natural disturbance patterns.
  • “Prepare for intense storms and fluctuations in base flow using methods that maintain forest health and diversity, including controlling soil erosion, relocating high risk roads and trails, and constructing appropriately sized culverts and stream crossings while retaining stream connectivity.
  • “To maintain genetic resiliency, consider locally adapted genotypes for use in restoration projects.”

What’s next?  Will Harlan, a scientist for the Center for Biological Diversity said (here) communities still  not satisfied with the decision will “use every tool possible” including “public engagement, community involvement (and) litigation” to push back against what the plan could do to forests.

However, the Eastern Band of Cherokee Indians was “pleased.”

“Using our nation’s forest inventory to open carbon markets to family forest owners”

by

Here’s an announcement from the Forest Service about a program designed to promote use of small, private forests for carbon offsets.  In particular, it’s about the the use of Forest Service FIA data in this program, but I’m always interested in what management practices are considered to be worth getting paid for, and I don’t think I’ve seen them this clearly specified.  The program website says, “When you enroll, you’ll receive payments for implementing forest management practices that increase the carbon sequestered and stored on your land.”  This program seems to be only available in the eastern U. S., but if you track through the links you can find the specific “management requirements” for several states under the “Practice Overview” documents here.   The three groups of states are each a little different.

Michigan/Minnesota/Wisconsin (Payments are higher for “growing mature forests” than for “promoting diverse forests;” these are requirements for the former, while the latter allows more intensive logging, but has requirements for reserve areas.)

  • Harvests may not remove more than 25% of the basal area at the time of the harvest.
  • Harvests may not reduce the average stand diameter by more than 10%.

Maryland/Pennsylvania/West Virginia (Payment is for “growing mature forests” only)

  • If you choose to conduct a timber harvest, it must not remove more than 25% of the basal area per acre
  • High-grading is prohibited during the contract period. High-grading is defined as a reduction in quadratic mean tree diameter of more than 10% from the pre-harvest condition.

Vermont/eastern New York (Payments are higher for “grow older forests” than for “enhance your woodland.”  The former generally requires deferment of commercial logging for 20 years.  The latter restricts timber harvest based on basal area, diameter, trees per acre, snags and opening size.)

Would something like this make sense in the west?  For federal lands (as a best management practice, since they couldn’t be paid for it)?  (I know we’ve had some discussions about thinning requirements based on basal area vs other metrics.)

 

 

“Proforestation” It Aint What It Claims To Be

by

‘Proforestation’ separates people from forests

AKA: Ignorance and Arrogance Still Reign Supreme at the Sierra Club.

I picked this up from Nick Smith’s Newsletter (sign up here)
Emphasis added by myself as follows:
1)  Brown Text for items NOT SUPPORTED by science with long term and geographically extensive validation.                                                                                                                                                        2) Bold Green Text for items SUPPORTED by science with long term and geographically extensive validation.
3) >>>Bracketed Italics for my added thoughts based on 59 years of experience and review of a vast range of literature going back to way before the internet.<<<

“Proforestation” is a relatively new term in the environmental community. The Sierra Club defines it as: “extending protections so as to allow areas of previously-logged forest to mature, removing vast amounts of atmospheric carbon and recovering their ecological and carbon storage potential.”          >>>Apparently, after 130 years of existence, the Sierra Club still doesn’t know much about plant physiology, the carbon cycle or the increased risk of calamitous wild fire spread caused by the close proximity of stems and competition driven mortality in unmanged stands (i.e. the science of plant physiology regarding competition, limited resources and fire spread physics). Nor have they thought out the real risk of permanent destruction of the desired ecosystems nor the resulting impact on climate change.<<<

Not only must we preserve untouched forests, proponents argue, but we must also walk away from previously-managed forests too. People should be entirely separate from forest ecology and succession. >>>More abject ignorance and arrogant woke policy based only on vacuous wishful thinking.<<<

Except humans have managed forests for millennia. In North America, Indigenous communities managed forests and sustained its resources for at least 8,000 years prior to European settlement. It is true people have not always managed forests sustainably. Forest practices of the late 19th century are a good example.                                                                                                                                                 >>>Yes, and the political solution pushed on us by the Sierra Club and other faux conservationists beginning with false assumptions about the Northern Spotted Owl was to throw out the continuously improving science (i.e. Continuous Process Improvement [CPI]).  The concept of using the science to create sustainable practices and laws that regulated the bad practices driven by greed and arrogance wasn’t even considered seriously.  As always, the politicians listened to the well heeled squeaky voters.  Now, their arrogant ignorance has given us National Ashtrays, destruction of soils, and an ever increasing probability that great acreages of forest ecosystems will be lost to the generations that follow who will also have to cope with the exacerbated climate change.  So here we are, in 30+/- years the Faux Conservationists have made things worse than the greedy timber barons ever could have.  And the willfully blind can’t seem to see what they have done. Talk about arrogance.<<<

Forest management provides tools to correct past mistakes and restore ecosystems. But Proforestation even seems to reject forest restoration that helps return a forest to a healthy state, including controlling invasive species, maintaining tree diversity, returning forest composition and structure to a more natural state.

Proforestation is not just a philosophical exercise. The goal is to ban active forest management on public lands. It has real policy implications for the future management (or non-management) of forests and how we deal with wildfires, climate change and other disturbances.

We’ve written before about how this concept applies to so-called “carbon reserves.” Now, powerful and well-funded anti-forestry groups are pressuring the Biden Administration to set-aside national forests and other federally-owned lands under the guise of “protecting mature and old-growth” trees.

In its recent white paper on Proforestation (read more here), the Society of American Foresters writes that “preservation can be appropriate for unique protected areas, but it has not been demonstrated as a solution for carbon storage or climate change across all forested landscapes.”

Proforestation doesn’t work when forests convert from carbon sinks into carbon sources. A United Nations report pointed out that at least 10 World Heritage sites – the places with the highest formal environmental protections on the planet – are net sources of carbon pollution. This includes the iconic Yosemite National Park.

The Intergovernmental Panel on Climate Change (IPCC) recognizes active forest management will yield the highest carbon benefits over the long term because of its ability to mitigate carbon emitting disturbance events and store carbon in harvested wood products. Beyond carbon, forest management ensures forests continue to provide assets like clean water, wildlife habitat, recreation, and economic activity.
>>>(i.e. TRUE SUSTAINABILITY)<<<

Forest management offers strategies to manage forests for carbon sequestration and long-term storage.Proforestation rejects active stewardship that can not only help cool the planet, but help meet the needs of people, wildlife and ecosystems. You can expect to see this debate intensify in 2023.

Sierra At Tahoe Ski Area Re-opens

by

After the Caldor Fire seriously impacted the ski area, Sierra At Tahoe is open again. As you can see, it was a high intensity portion of the fire, with the previous forest being highly flammable and loaded with decades of heavy dead fuels. After several droughts, the area did not have any salvage operations. The area is also known to have nesting pairs of goshawks around.

As you can see, snow sports people will be enjoying a new experience of skiing and boarding, without so many trees ‘hindering their personal snow freedoms’. *smirk*

New Steel et al. Paper: Mega-disturbances Cause Rapid Decline of Mature Conifer Forest Habitat in California

by
The Rim Fire in the Stanislaus National Forest U.S. Forest Service photo.

I don’t think the findings of this paper will be surprising to many TSW readers. I usually try to excerpt from the discussion, but this paper also has a management implications section. The basic story is that ideas developed around mesic forests may not work in dry forests. “Protected” areas, including important endangered species habitat, may be lost to wildfire, beetles or drought, or any combination thereof, whether due to AGW, historic fire suppression, human ignitions or any combination of the above.. what is, is. Here’s a link in case it’s not posted on Treesearch yet.

***Note: some of what these authors claim is contrary to the “science-based” claims of many MOG advocates. It’s easy to say your claims are based on “science”; it’s a bit harder to dig into the existing scientific studies and what they show; especially if they disagree. The authors also question static conservation approaches (if this reminds you of Botkin’s 1992 book Discordant Harmonies, the idea has been around for a while), e.g, “Thus even today, in both law and in practice, the scientific conservation of endangered marine species continues to be based on the idea that nature undisturbed is constant and stable . . .” I wonder whether resistance to change from this static worldview is perhaps a form of scientific/philosophical comfort with the status quo or that the momentum of law and policy is just too strong for the few voices saying “maybe not.” Anyway, back to the paper.***

Such “static” conservation approaches are heavily embedded in existing wildlife and ecosystem conservation policy (Leopold et al. 2018), as well as land management plans (e.g.,USDA 2004) in North America. Yet recent disturbance patterns and their cumulative impacts have demonstrated that efforts to resist change are often falling short in dynamic ecosystems, such that achieving the specific conservation objectives and possibly the intent outlined in policy documents may no longer be feasible in disturbance prone areas (Davis et al. In Press). In fact, continued attempts to resist change may be counterproductive where a hands-off approach (but continued fire suppression) creates a higher likelihood of rapid, transformational, and undesirable changes in the form of large scale type conversion and habitat loss from disturbance (Rissman et al. 2018). In our study region spotted owl Protected Activity Centers are often managed using a static conservation approach but our analysis shows they have recently experienced more declines in canopy cover (49% relative to 2011) than outside of their borders (40%). This observation suggests that conservation of habitat for old-forest dependent species may require a more dynamic approach that increases resilience to disturbance while maintaining valuable habitat features such as large, tall trees.

This is from the last section of the Discussion.

Rapid loss in mature forest habitat in the southern Sierra Nevada and longer term trends in fire-related forest decline throughout California (Stevens et al. 2017, Steel et al. 2018) suggest that existing forest management paradigms may be inadequate for maintaining mature mixed-conifer forests under current and projected future disturbance dynamics (North et al. 2022). If these rates of decline continue, we are likely to see near total loss of southern Sierra Nevada mature conifer forests in the coming decades. This would be much more rapid than the time horizon of mature forest loss estimated by Stephens et al. (2016b) (by 2089, or ~75 years). However, Stephens et al. (2016b) did not consider drought-related mortality, and only analyzed fire activity up through 2014, which missed the record fire year of 2020 (Safford et al. 2022). It is worth noting that the extreme fire activity documented in California during 2020 was likely not a one-off anomaly; recent observations indicate similar, if not exacerbated fire activity in 2021 (Shive et al. 2021).

The region has also reentered extreme drought (Williams et al. 2022) with implications for both drought and beetle mortality and severe wildfire. More optimistically, total loss of mature forests in this region could be delayed until mid-century if we enter a period of cooler, wetter years, if surviving mature forests within these fire footprints have gained resilience to future disturbances, or if recruitment of mature hardwood species compensate for losses of large conifers. Hardwood species may become a greater component of the Sierra Nevada landscape as conifers decline (Restaino et al. 2019, Steel et al. 2021b). Oaks, especially California black oaks, are relatively resilient to both wildfire and drought, and are utilized by species such as the spotted owl and fisher (North et al. 2000, Aubry et al. 2013, Green et al. 2019). However, loss of mature forest habitat, on any likely timeline, is unsustainable given that the recruitment of conifer or hardwood mature forests takes many decades to centuries. Stephens et al. (2016a) emphasize that policies prioritizing forest resilience over other resource concerns may be needed to meaningfully address the current backlog in forest management and shift course from forest decline to sustainable disturbance dynamics. Indeed, our analysis showed that areas of higher canopy cover are more at risk of loss, and that large areas of relatively homogenous moderate and higher density forests, like PACs, are at risk of larger declines if resilience needs are not addressed. Recognizing the dynamic nature of habitat in these forests, and prioritizing the restoration of these dynamics over the attempted strict preservation of existing habitat, may help minimize the impacts of these changes and maintain habitat functionality in the long term (Fabritius et al. 2017, Stoetzel et al. 2020, Gaines et al. 2022).

Open Letter to Forest Service Leaders on Mature and Old Growth by Jim Furnish

by
Jim Furnish, right, a former deputy chief at the Forest Service, makes a point with Dave Mertz, a former natural resources officer with the agency, on a visit to the Black Hills National Forest. “The Forest Service managers are not keeping up with the real world,” Furnish said. Marc Heller/E&E News

Thanks to Jim Furnish for sending a copy of his letter for discussion.

I write as a loving critic to confront you about the future. Today, my 77th birthday, occasions much reflection after departing the agency over 20 years ago. My hope is that you share this letter broadly to stimulate conversation about agency action on the challenges ahead. I hope you embrace the same goal that inspired me in my career: a Forest Service that achieves greatness equal to that of the magnificent estate in its trust.

From the tempest that roiled the Forest Service in the 1990s emerged a policy and a plan – ecosystem management and the Northwest Forest Plan – that envisioned a very different future predicated on principles of ecological sustainability. The Roadless Area Conservation Rule followed shortly after; controversial within the agency, yes, but broadly appreciated elsewhere. The Roadless Rule withstood lengthy litigation challenges to finally become one of the boldest legacies in agency history. Promising winds of change blew strong toward a learning organization confronting a changing climate, lofty expectations, and fraught politics.

Climate science has advanced evidence of worsening pressures on forests, fire consequences among them, but also highlighting the valuable role forests play by sequestering and storing carbon. President Biden’s recent Executive Order 14072 mandates conservation of mature and old growth forests (MOG), specifically, as a mission priority and opportunity for the Forest Service to use public forest assets to mitigate climate effects. The agency’s response to date has been tepid at best, hardly an enthusiastic embrace of the spirit of the EO to fundamentally remake agency MOG policy in keeping with the promising vision of ecosystem management.

Forest fires provide a visceral drama that MOG forests lack, yet these forests do vastly greater work providing a broad array of ecosystem services that we desperately need, at no cost. I appreciate the challenges of improving agency performance on our fire dilemma, but you must also recognize the linkage between fire issues and MOG imperatives as you address both in synergistic fashion.

The current fire dilemma and MOG opportunity create an urgency to define a different, compelling future. I illustrate this pivot point by citing the owl crisis, when a federal judge determined that agency officials at the highest level had “willfully violated the law” in efforts to appease timber industry. This condemnation prompted Jack Ward Thomas, in one of his first acts as Chief, to demand that employees obey the law. How humiliating. Is it any wonder that forest managers were not in the “room where it happened” during development of the Northwest Forest Plan?

Organizations are birthed, grow and improve, then typically decline, necessitating reformation lest they die. The Forest Service has a storied history, but a clear eyed assessment of the agency today suggests it needs rebirth. I recognize that politics can muddle the waters, but your agency has the resources and obligation to define itself, something it has yet to do in the context of the post-owl ecosystem management era. Responding forcefully to EO 14072 could point the way to a new Forest Service model for effectively addressing forest carbon and fire – and the future.

To that point, I believe your forthcoming MOG policy is a legacy issue, a time of turning. But did you consider an interim prohibition on logging MOG timber, pending completion of measures to conserve MOG forests? Why not evaluate all pending timber sales for their impact on MOG forests? Why no public statements heralding this opportunity to buttress MOG protections? The Forest Service continues to log MOG forests, completely undermining the call to conserve them. Is this simply because EO 14072 does not explicitly prohibit it? In this I hear echoes of the agency’s response to the spotted owl issue. History did not look kindly on the Forest Service’s handling of the owl crisis when the agency failed to take appropriate actions, and history is watching again.

Our national forests and grasslands are increasingly important as climate issues worsen, beckoning you to the challenge of enhancing the role of MOG forests and their carbon attributes. This is not the time for procedural and process delays. Forest carbon possibly represents the most valuable national forest asset, but the Forest Service has not yet elevated consideration and management of forest carbon to the prominent place it deserves. The situation calls for decisive leadership action.

As Deputy Chief, I found myself in the forefront of efforts to resolve the decades-long roadless area controversy. Importantly, the Forest Service’s own logging and road construction activity posed the greatest threat to the integrity of roadless areas. Yet we changed; providing durable protection by developing a timely, forward thinking, effective solution via a federal regulation. You now find yourself in a similar situation as Forest Service enabled logging poses the greatest threat to MOG forests. President Biden’s EO 14072 provides the impetus and justification to advance the conservation legacy of the Forest Service on behalf of MOG forests. I urge you to seize this moment to craft a creative and robust response as you embrace the mandate to steward the public’s magnificent forest estate.

A Look at the Manchin-Barasso Promoting Effective Forest Management Act

by

Here’s a link to the announcement. Here’s the bill itself (only 21 pp).

Read a summary of the Promoting Effective Forest Management Act of 2022 here.

Read a section-by-section of the Promoting Effective Forest Management Act of 2022 here.

My comments are in italics.

**********

ITITLE I – ACCOMPLISHMENTS OVER RHETORIC
Section 101. Thinning Targets.
Section 101 directs the Forest Service and the Bureau of Land Management (BLM) to set annual acreage targets for mechanical thinning projects on National Forests and public lands. Under the
bill, agencies are to double their acreage targets by 2025 and quadruple them by 2027.

Just exhortation and funding won’t do it. Heck the Wildfire Commission couldn’t get going in the Congressionally prescribed timeframe with only picking people and having a meeting.  And there are the workforce problems we’ve discussed many times.  But perhaps timelines would be useful due to the next section.


Section 102. Annual Reports.
Section 102 directs the Forest Service and BLM to report certain acreage accomplishments,including whether the mechanical thinning targets in Section 101 have been met. If the targets
are not met, the agencies must report any limitations or challenges, including litigation or permitting delays that hindered their progress.

I think this one has value by making transparent what’s really holding up projects. We’ve discussed various sources of delays here, but with those reports everyone could get a better picture or what’s going on.


Section 103. Transparency in Fire Mitigation Reporting.
Section 103 increases transparency in fire mitigation reporting by directing the Forest Service and BLM to exclude acres that need to be treated more than once from output measures in
certain reports and budget request documents.

This sounds like cleaning up accounting, about time.

Section 104. Regional Forest Carbon Accounting.
Section 104 directs the Forest Service to, using data from the forest inventory and analysis program, determine whether National Forest System lands are carbon sources or carbon sinks,
and to publish that information online.

This sounds useful.


Section 105. Targets for Wildlife Habitat Improvement.
Section 105 directs the Forest Service and BLM to meet wildlife habitat improvement goals and targets relative to existing management plans.

There must be a backstory of how the FS is not meeting targets, the hook and bullet folks are on board with this bill so they must be concerned. There must be a write-up somewhere, has anyone seen it?


TITLE II – FOREST MANAGEMENT
Section 201. Land and Resource Management Plans.
Section 201 directs the Government Accountability Office (GAO) to report on whether shortening the length and development timelines of Forest Service land and resource management plans would help the agency address its backlog of out–of–date plans.

I think the FS should convene a Committee of Practitioners and Collaborators to review the successes and failures of the current planning process and recommend changes to NFMA. I don’t think the GAO has the folks to figure out how best to “shorten the length.”


Section 202. Management of Old Growth and Mature Forests.
Section 202 directs the Forest Service and BLM to adhere to the current definitions of “old growth forest,” and requires that any updates or revisions can only been made after a recommendation by a scientific committee, followed by a rulemaking process under the Administrative Procedure Act. Further, this section clarifies that “mature forests” are separate from old–growth forests, and that mature forests are to be managed according to current law.
This section also clarifies that executive branch actions shall not modify, amend, or otherwise change the duties of the Forest Service or BLM under current law.

This takes aim at the Moggie process which is I think a time-wasting (to the rest of us)  bone thrown to certain supporters of the current Admin. This bill seems like a step in the right direction, especially the part about mature forests.

2
Section 203. Assessment of Processed–based Restoration Techniques.
Section 203 directs the Forest Service and the United States Geological Survey (USGS) to establish a pilot program to conduct research on and evaluate wetland and riparian restoration
techniques, including utilizing biologically–driven restoration.
Section 204. Intervenor Status.
Section 204 allows counties and local governments to intervene in lawsuits intended to stop wildfire prevention projects on nearby National Forests.

Help from legal folks here.. I didn’t know they couldn’t be intervenors..

Section 205. Utilizing Grazing for Wildfire Prevention.
Section 205 directs the Forest Service and BLM to develop a strategy to increase the use of grazing as a wildfire mitigation tool. This includes the use of targeted grazing, increasing
issuances of temporary grazing permits, and completing environmental reviews for vacant grazing allotments that could be used for grazing when drought and fires impact occupied
allotments.


TITLE III—WORKFORCE
Section 301. Logging workforce.
Section 301 directs the Forest Service to work with States to develop a universal, tiered program to train people to enter the logging workforce, and to examine ways to facilitate apprenticeship
training opportunities. This section also allows existing funding to be use for low–interest loans to modernize logging machinery.
Section 302. Break–in–service consideration for firefighter retirements.
Section 302 ensures that wildland firefighters can retain employment and retirement benefits for
breaks–in–service that are 9 months or less.
Section 303. Firefighter rental housing.
Section 303 places a cap on rent for wildland firefighters when they are forced to pay for agency–provided housing.

TITLE IV—CULTURAL CHANGE IN AGENCIES
Section 401. Mandatory use of existing authorities.
Section 401 requires each National Forest and BLM unit to use at least one existing streamlined authority for environmental review on a forest management project within the next three years.
Section 402. Curtailing employee relocations.
Section 402 directs the Forest Service to curtail employee relocations and to develop a program that provides incentives for employees to grow in place. Further, this section places a cap on
employee relocation expenses, and directs the Secretary to solicit employee applications in a manner that does not limit eligibility to current Forest Service employees.

I had to read the bill to see that the relocation is about line officers.  Since BLM and FS line officers are always switching back and forth, I don’t know about this one:

“Sec shall solicit applications for line officer positions in a manner that does not limit eligibility for the solicited position to only an applicant who is a current employee of the Forest Service.”


Section 403. Repeal of FLAME reports.
Section 403 repeals a report within the FLAME Act of 2009.

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

Please add your own thoughts and any analyses you run across,  and it would be great if someone would read the entire bill itself.

Mature and Old Growth (MOG), Moggies, and the Western Governors’ Letter

by

 

Moggies are cute and furry creatures. MOG is a political bone (:)) thrown to certain ENGOs, making unnecessary work for the rest of us. Hiss!

The Mature and Old Growth (MOG) comment period requested by USDA and BLM recently closed.  The Retiree Gossip Network says there is pressure from entities in the White House to USDA to hurry up with this effort, despite the need for consultation with Tribes and States, and public comment.  The Western Govs, though, don’t seem to be in the same place,  at least not in writing. It is not lost on them that more restrictions could easily be in conflict with other USG priorities like the Bipartisan Infrastructure Bill and the IRA.

Here’s what the Western Governors think..(my bold)

Western Governors are encouraged that the EO requires the Departments to consult with states as they work to establish a definition framework and use the framework to create an inventory of old-growth and mature forests. Early, meaningful, substantive and ongoing consultation is an integral component of any durable and effective land management strategy. This consultation will also facilitate the incorporation of state expertise, data and documentation into federal decision-making processes and land management activities.

WGA Policy Resolution 2021-03 articulates Governors’ support for increasing the pace and scale of restoration activities on western forests and rangelands, mitigating the potential effects of uncharacteristic wildfire, and supporting fire-adapted communities in the West. The resolution also highlights how a narrow focus on specific land management goals, such as carbon sequestration through old-growth forest conservation, can conflict with a more holistic management paradigm that seeks to satisfy a broader range of ecological and societal values. As the Departments implement Section 2 of the EO, Western Governors encourage you to comprehensively consider the various goals and values reflected in the Order.

Western Governors also engage on wildfire and land management policy through WGA Policy Resolution 2023-01, Working Lands, Working Communities. The resolution emphasizes Governors’ support for the integration of land management, fire management, and water protection functions within and between federal agencies, states and territories, and local communities. The resolution also underscores the need for sufficient infrastructure, access, and workforce necessary for communities to support forest and rangeland management activities.

Dead Trees Sequester No Carbon: What We Learned About Offsets Should Apply to National Forests (or Not?) And A Request for More Voices

by

 

A ponderosa pine seedling peeks out of the Hayman-Fire scarred landscape near Cheesman Reservoir. After the fire, Denver Water spent more than 10 years working with volunteers and Colorado State Forest Service crews to plant about 25,000 trees per year on the 7,500 acres of Denver Water property destroyed by Hayman.

There’s a recent story in E&E news about MOG (Mature and Old Growth), that was framed as being about timber interests versus environmentalists (no one here will be surprised by the mention of Dominick Della Salla and the John Muir Project.. on the other side, we have…”timber interests”, as in Bill Imbergamo with the Federal Forest Resource Coalition.  I’d argue that the timber wars are actually over, and the question today has a variety of voices that need to be heard.  For example, people concerned about old growth and mature forests burning up; dying due to bark beetles and other insects, proponents of Native American burning practices, fire suppression folks who appreciate operating zones, and so on.  I’d like to develop a list of potential sources, possibly including state foresters, entomologists and pathologists, prescribed fire and fire suppression practitioners and academics, Forest Service and BLM partners for restoration and fuels projects, and others.

If you have suggestions for contacts and you feel comfortable, please put them in the comments. If you don’t feel comfortable you can email them to me.  The idea would be to have a list that reporters could select from that would give a more comprehensive framing than “loggers versus Hanson et al.”, which I could ship off to any reporters interested in the issue.

Thank you!  Now on to the story…

Let’s talk about carbon..the erstwhile reason (this time) to go after the same old-same old (no logging on federal lands) with the same groups.

On the other side are advocates for less logging, or no logging, on federal lands, who say more protections will help sequester carbon and fight climate change.

People keep saying this, but without intervention in some cases (fuel treatments, beetle sanitation), trees will die. And Dead Trees Sequester No Carbon. So yes, there are places accumulating much carbon that are unlikely to burn up, but this effort is targeted to the entire US.  So it’s not really about that, is it?

It seems logical to me that if keeping out of forests really helped with carbon sequestration, then… people would be all for carbon offsets in western forests! From this NY Times story

Carbon-offset programs, which are designed to fight climate change, typically pay landowners to manage their land in ways that store carbon. Usually, that means paying landowners to not chop down trees.

Wildfires, however, don’t respect those agreements.

An estimated 153,000 acres of forests that are part of California’s carbon-offset project have burned so far this summer, according to CarbonPlan, a nonprofit climate-research organization. Three projects have been affected. In Oregon, a quarter of the Klamath East project, or close to 100,000 acres, has burned in the Bootleg Fire since early July.

(my bold in both spots).

While the rest of the NGOs are working, as the FS asked us, on the definition framework… this group went ahead, made up his own definitions and mapped them.

The use of the NASA information is “an amazing accomplishment,” given its level of detail, said DellaSala, who offered to share the data with the Forest Service.

“It’s not rocket science. It should not take a year,” said DellaSala, who added that 80 years of age is a benchmark for mature trees.

I don’t know how they can tell how the age of trees from NASA information, I have trouble telling how old they are (without knowing the area) without an increment borer.

OTOH

Commenters told the Forest Service on an agency webinar several weeks ago that “mature” defies a simple definition, considering trees that live hundreds of years might not be considered “mature” at 80 years old.

I think what the commenter said was something like “if aspen lives to x years and bristlecones live to y years, you can’t use the same age for each species.”

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

The John Muir Project called for a partial moratorium on logging while the Forest Service inventory is underway and until protections are in place, and asked supporters to submit letters to the agency in support of the idea. The Forest Service, though, has said the executive order doesn’t call for any changes in projects underway or planned.

“For the purpose of this immediate moratorium, individual trees and stands of trees, whether burned in a fire (dead or alive) or unburned, that are 50 years old or older, should be excluded from cutting and removal in any areas where logging operations are allowed, and should be prohibited from being cut and removed in any area where logging operations have already been approved,” a sample letter says.

Note the current rationale is for carbon storage and sequestration, the the moratorium includes dead trees.  It’s the same old stuff with different packaging- or dare I say veneer?

Clearly we need more voices for reporters to call on… please append or send.  Thanks again for suggestions.