Restoration

Finding Agreement: Some California Environmental Groups’ Agreement on Forest Management

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Thanks to Susan Britting of Sierra Forest Legacy for sharing this Novermber 2020  Forest Management Statement signed by a broad coalition that included the following groups:

California Native Plant Society ▪ California Wilderness Coalition ▪ Central Sierra Environmental Resource Center ▪ Defenders of Wildlife ▪ The Fire Restoration Group ▪ The Nature Conservancy, CA Chapter ▪ Sierra Business ▪ Council Sierra Forest Legacy ▪ The Watershed Center

Statement on Forest Management
California forest conditions
• Well managed forests provide many critical benefits for nature and people including clean air, clean water, wildlife habitat, carbon storage, recreation and more.
• Current conditions in many fire-prone forests of the Sierra Nevada and elsewhere in California are degraded and not healthy due to past logging practices, fire suppression, drought, and climate change. From the perspective of forest health and resilience, there are too few large trees, too many small trees, and an excess of “surface and ladder fuels” that significantly increase the risk of high-severity wildfire.
• California is experiencing high-severity wildfire in larger landscapes and at larger scales than is desirable from an ecological perspective.
• Threats to forest communities from high-severity wildfire are increasing and need to be addressed.
• There is an urgent need to restore more natural forest structure and reintroduce beneficial fire so that forests continue to provide important ecosystem services and pose less of a threat to
life and property.

An integrated solution: communities and landscapes
• We support an integrated strategy to reduce the risk of high-severity wildfire near communities and across the forest landscape, including public and private lands.
• The strategy needs to utilize all tools in the toolbox: ecologically based forest thinning, prescribed fire, managed fire, cultural burning, working forest conservation easements, defensible space, home hardening, and emergency response.
• Different actions and priorities are appropriate across the landscape: 1) near communities, the primary goal should be protecting lives and property through steps like defensible space, structure hardening, emergency response, improved ingress/egress, and reducing unplanned human ignitions; 2) in the mixed forest landscape, we should work to increase forest resilience and mature forest structure using actions like ecological forest thinning and prescribed and managed fire while reducing unplanned human ignitions and hardening infrastructure; 3) in roadless and wilderness areas, the primary management tools should be cultural burning as well as prescribed and managed fire.
• There is a need for an all-lands approach, including public-private and tribal partnerships, to achieve these goals.
• We support the commercial use of woody material removed from forests (e.g., saw logs, mass timber manufacturing, woody biomass for heat and electrical generation, and added value wood products development) where the goal is increasing forest health and resilience and as long as species and ecosystems needs are met.

The letter even has a very nice glossary.

I find nothing to disagree with here (I could get picky about specific words but..).   I’ve found that for some E-NGOs, woody biomass is a non-starter (it seems to invoke Europe and southeastern US pellet exports), and and some seem to be against commercial use of woody material from National Forests. I think it’s important to note that these groups (who have to live with the “burn in piles or do something else” challenge staring them in the face) support useswith constraints (“when the goal is”.. and “as long as”). Certainly the devil is in the details, but some groups seem to assume that those details can’t be handled appropriately through existing mechanisms or those to be developed in the future.

Does anyone have a similar statement from groups in other western states?

Where should fire suppression be a “fact of life?”

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Sharon referred to “where fire suppression is a fact of life.”  I referred to the planning question of identifying where those areas are.  It seems to me that would be either where fires won’t ever occur (hard to imagine), or where they can’t be allowed to burn.  The reason in the latter case would depend on some kind of values at risk.  I continue to be amazed at how unwilling the Forest Service is to attack this problem from that direction – minimizing the values at risk in areas that are likely to burn.  In particular, their engagement (or lack thereof) with local community planning for developments and infrastructure.  And there are other reasons besides fire risk, in particular fragmentation of wildlife habitat that reduces connectivity.

Any way, here is an example from the Croatan National Forest.

The 2002 Croatan National Forest Land and Resource Management Plan stated that around 70 percent of the Croatan is home to short interval fire-adapted ecosystems—like pine trees and pocosins.

Low-intensity, prescribed fires allows nutrient cycling to occur. Without them, the entire structure and composition of species are subject to change.

“These are fire-maintained habitats, without prescribed burnings, it is like trying to save a salt marsh without the tide,” said Fussell.

Longleaf pine restoration is especially dependent on prescribed fires as the exposed soil helps the seeds to germinate and they control the population of competing pine variations.

Prescribed burning is harder to do the more fragmented an ecosystem is and the closer it gets to development. Because it is harder to burn in smaller areas, prescribed burnings have decreased in recent years, said Fussell.

The Forest Service has a legal imperative to NOT allow the structure and composition of species to change.  Where adjacent development has already occurred, fire suppression is probably going to be a “fact of life,” but that fact should be motivating the Forest Service to participate in local planning to encourage future development consistent with the fire regime on the adjacent national forest.  It’s difficult to understand why no one from the Forest Service was interviewed for this article, since they should be on the forefront of these kinds of discussions.  (They evidently did get involved in some highway planning in order to continue prescribed burning, which at least suggests they recognize the problem.)

This article cites some research that reiterates the findings of the Forest Service “Forest on the Edge” program (which I contributed to along the way).

By 2030, a study from 2009 by researchers at the University of Wisconsin and other industry professionals, projects that 16 million new housing units will be built around national forests across the United States. A projected 662,000 will be built in national forests.

“New houses will remove and fragment habitats, diminish water quality, foster the spread of invasive species and decrease biodiversity,” stated the study.

This is happening everywhere, and the Forest Service needs to be more assertive in trying to minimize the areas “where fire suppression is a fact of life.”

Science Friday: The Problem of Reference Conditions, and Alternative Management Approaches

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American Chestnut planting in Vermont

For many years, scientists and others have been talking about the problems of using HRV and reference conditions as management targets.  Jon and I have had many mind-numbing discussions about it (as placed in the 2012 Planning Rule)  on this very blog. So I thought on Science Friday, I’d start exploring the work of other scientists who have expressed concerns about this. Sadly for me the 2012 Rule is water under the bridge, but the Feinstein bill is not. Let’s see how that bill talks about using reference conditions in the large landscape projects:

“2) evaluates ecological integrity and reference conditions for the landscape;
3) identifies areas that have departed from reference conditions;
4) identifies criteria for determining appropriate restoration treatments;
5) are based on the best available scientific information, including, where applicable, high-resolution imagery and LiDAR; and
6) identifies priority restoration strategies.
o Restoration actions shall 1) emphasize the reintroduction of characteristic fire; 2) for any proposed mechanical treatments, seek to restore reference conditions and the establishment..

Now, you don’t need a Ph.D. in vegetation ecology (or plant evolution, or wildlife biology) to suggest that restoring (say, American Chestnut) may be difficult or impossible to achieve due to a) other changes that have happened since, like other species having taken over  b) climate change, c) invasive species, d) human population impacts (pollution, domestic animals and pets and so on)  e) lack of Native American practices and so on. So why does this idea have such a hold on the imagination? Why has it been argued that this is a more “scientific” approach, when many scientists disagree? And while we can discuss that reference conditions aren’t HRV, well, then aren’t they just conditions that some group finds desirable, and not any more “scientific” than any other conditions?

This article is by Dr. Connie Millar of the Pacific Southwest Research Station, and she uses her climate studies to come up with a different conclusion about what to do- not exactly what many mean by “restoration” but helping systems/organisms be resilient and adapt to future change. It seems like a very different, and possibly more realistic and less expensive, paradigm (to me). The paper also includes a history of the concept as used in forest management on page s30. Here are a few quotes:

From the standpoint of this review, I focus on an underlying assumption of stationarity that continues to emerge in the HRV literature even where discussions address historic variability. Further, two elements in the discussion of HRV remain unconfronted and problematic: First, what historic time period is most relevant to current and future conditions (and, in contrast, what periods are inappropriate); and second, whether “approximating historic conditions” of any historic time period is a wise approach to managing for functional ecosystems of the future

I agree that the latter deserves much more discussion. Especially since it could be argued that generalized “restoration to reference conditions” is a “nice to have” and strategic fuel treatments are a “need to have”; I’d put my tax dollars on the latter rather than the former.

For the many ecosystems not severely degraded, historically informed strategies focus on (a) removing barriers that impede inherent ecological capacities to respond to change, and (b) assisting species and communities to transform in ways most compatible with their inherent capacities and with social goals. In regard to the first, we learn from historic retrospect that the truly novel conditions at present and increasing in the future are not so much about the magnitude or even pace of climate change, rather the overwhelming transformation modern humans have imposed on Earth. The Anthropocene era (Ruddiman, 2003) is characterized by nonanalog conditions for species survival, and the accelerated pace of extinction shows that many species have not been able to use their inherent capacities to respond to change in the face of such barriers. Functional restoration thus can emphasize, to the extent possible, removal or mitigation of impacting barriers derived from land development; fragmentation; air, land, and water pollution and contamination—carbon dioxide being among the worst offenders; land-use changes, invasive species, and many others (Millar, Stephenson, & Stephens, 2007).

Assisting ecosystems to transform in ways most compatible with their inherent capacities involves exploiting species tendencies to move geographically and to adapt genetically in the face of change. In regard to the former, if barriers to dispersal cannot effectively be removed, assisted translocation, either of species beyond their current range limits or of genotypes beyond their current provenances, might be effective. Understanding changes that are already underway will enable restorationists to ease transitions to future states, often with less extreme variability or outcomes than socially tolerable. Assisting genetic adaptation can occur in many ways informed by natural selection—such as experimenting with seed diversity in restoration mixes, taking advantage of the significant opportunities that insect-mediated mortality events can have to ratchet population adaptedness forward, and setting goals at bioregional not local scales.

Goal Setting
While much can be learned from reconstructions of historic responses to climate change, and especially from historic periods similar to what might be expected in the future (e.g., the Medieval interval or the middle Holocene), historic conditions generally, and especially those from nonanalogous historic periods (such as the Little Ice Age) make inappropriate reference conditions for the future. In such a case, target and goal setting for functional restoration must pioneer additional approaches. The return to more utilitarian goals and targets recognizes both the reality of the Anthropocene and that resource-management has, in fact, always been a human-directed and conceived endeavor. Emphasis on ecosystem services—including essential utilitarian functions such as clean air and water, landscapes for recreation, production of fiber and meat, and sustenance of biodiversity desired by humans and provided by healthy ecosystems—will guide the next generation of management strategies. Achieving these goals will be greatly benefited by historically, as well as ecologically informed management.

Three Interesting Webinars! One Tomorrow

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Three interesting webinars:

Environmental and social values in restoration: beyond commercial logging

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Many conservation and environmental groups initially became involved in forest collaboratives because they saw an opportunity to advance ecological restoration (including wildlife habitat restoration and resilience) with tools like small-diameter thinning or Stewardship Contracting. As time has passed, some conservation and environmental groups are considering or have opted out of forest collaboratives because they feel projects have focused on “pace and scale” or economic gain above other restoration priorities.

How do we define success for conservation and measure it – beyond just acres treated for fuels and volume produced? How can these concerns from the conservation community be better addressed, both in the collaborative process and beyond?

Panelists:

Michael Krochta, Bark

Tiana Luke, Conservation Northwest

Laura Navarette, USFWS

Chandra LeGue, Oregon Wild

Lessons Learned: comparing survey results from 3 pilot restoration projects in Eastern Washington

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This session will share the lessons learned, challenges, barriers, and successes of 3 large-scale restoration pilot projects in E. Washington. The session will begin with a presentation of the results of a web survey including comparisons of tools, concepts, and processes utilized to achieve project goals of increased pace, scale, and efficiencies, and recommendations for improving successes on future restoration projects. After the presentation, there will be time for Q&A and larger group discussion.

Lessons learned have been identified through a web survey responded to by 65 key personnel and stakeholders engaged in at least one of the three pilot projects. Each project was represented by a different collaborative. The following projects and collaboratives were included in this effort:

  • Project 1: Mill Creek A to Z, Colville National Forest

  • Collaborative: Northeast Washington Forest Coalition

  • Project 2: Manastash-Taneum, Okanogan-Wenatchee NF (south end)

  • Collaborative: Tapash Sustainable Forest Collaborative

  • Project 3: Upper Wenatchee, Okanogan-Wenatchee NF (north end) Collaborative: North Central WA Forest Health Collaborative

 

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Summer is just beginning, but wildfires are already raging in the West. Large and destructive wildfires are becoming more common, with new records set almost every year. Although several factors contribute to this trend, a significant one is the declining health of our nation’s forests. The U.S. Forest Service, which manages 193 million acres of land, reports a backlog of 80 million acres in need of restoration and 63 million acres facing high or very high risk of uncharacteristic wildfire.

While improving forest health and mitigating wildfire risk will require long-term policy changes, forest restoration projects offer a way to address these issues in the short term. By promoting landscapes with healthy forests and diverse forest types, restoration projects can reduce the risk of megafires and provide other conservation benefits.

Join us as we explore how reducing regulatory barriers, encouraging private partnerships, and opening markets for wood products can help restore our nation’s forests.

The Fix America’s Forests panel discussion will be held virtually on Tuesday, June 22 at 10:00 am MST with experts from PERC, Pacific Legal Foundation, Blue Forest Conservation, and the U.S. Forest Service.

Register Here

I’m interested in this one because of Chris French and learning more about Forest Resilience Bonds.

 

“Coastalism” in Oregon and the 21-inch Rule

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Map of the study area and photograph of a representative mixed‐conifer forest within one of the stands where simulated thinning occurred (the Elk 16 planning area on the Malheur National Forest). Fig. 1 in Johnston, et al. 2021
I’m not a fan of abstractions in general, so I hesitate to introduce a new one into the lexicon. But if folks are going to use them, then I guess each person should be able to select and define our own. I will define “coastalism” as the tendency (conscious or unconscious) to see problems and solutions through the eye of a person living in a coastal environment. In the case of the US, that would be the East and West coasts. This is often coupled with a tendency to focus on scientific findings from coastal universities; policy recommendations of NGO’s with coastal boards and coastal headquarters, media from… coasts.. and so on. And often the people and organizations have not visited nor lived among non-Coastal peoples, except as tourists.

Coasts tend to have wetter forests and ideas like “leaving forests alone is the best thing for them” tend to have more of a grip there, because naturally (generally) they would just go on and on until some non-fire disturbance happens.

The history and funding of forest science has had a coastal bias in itself. For example, at Pringle Falls Experimental Forests in the early 80’s, we (the Area 4 Central Oregon silviculture folks) had a class taught by (terrific professors!) Bruce Larsen and Chad Oliver. We studied many models of species that were light limited; there were no models of trees that were water-limited. In our area, also, we hired a full-time reforestation specialist to experiment with planting, as the information we received from Doug-fir country didn’t work for drier areas.

It made some sense at the time to have that focus, as folks on the West side did more intensive management, and there was money related to that. However, we might ask if that coastalism still fits the needs of Oregon, given the overwhelming need to deal with fuels and living with fire in the fire-prone parts of Oregon. Which actually may compose more acres in the State.

Now, I don’t intend to give folks at OSU a hard time. My own Ph.D. professor, Tom Adams, was an OSU prof. They do terrific work. But it’s legitimate to wonder if OSU were located in Baker, or John Day, or even Bend, would the science produced be different? And of course, funding sources like NSF may also have a coastal bias. Since we don’t tend to look at things with that abstraction in mind, we might not observe it.

I wonder if the East Side 21-inch rule might never have been put in place were it not for West Side ideas about old growth colonizing (the idea, that is, not the old growth trees) the East Side? It took almost 30 years for folks on the East side to do their own research and find out…er… it doesn’t work? (We have applauded this co-designed and co-produced research on TSW before). I never thought of it as an antidote to Coastalism in science before.

Anyway, here is a news story (thank you NAFSR!) on the findings of the study.

“Historical conditions were much better suited for old growth trees,” said Johnston. “Since we began to suppress fires that maintained open stands of widely spaced old trees, competition from young trees, including fairly large fir that established in the absence of fire, is killing old growth trees faster than they can be replaced.”

Diameter limits were widely adopted by Forest Service managers throughout the 1990s, Johnston said, in the face of social and legal pressure to conserve old growth habitat. Eastern Oregon’s diameter rule was supposed to be temporary as the Forest Service put together a comprehensive ecosystem management plan, but that process stalled, meaning the 21-inch rule is now 25 years past its original sunset date.

“With the Forest Service’s 21-inch rule for eastern Oregon, even stands that could be restored to their historical basal areas still had a lot more shade-tolerant trees than they did historically,” Greenler said. “But allowing the larger shade-tolerant trees to be removed helps reduce competition around old growth trees and improves their chances in the face of future stress.”

Here’s a link to the Ecosphere paper which is open-source. Thank you, Johnston et al.! And all the partners!

How to get rid of non-native fish in wilderness

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Utah Division of Wildlife

Since we had such fun discussing use of chainsaws in wilderness and eliminating wolves from wilderness, here’s another example of challenges to managing under the Wilderness Act. The Lolo National Forest is seeking comments on the North Fork Blackfoot River Native Fish Restoration Project which is located in the Scapegoat Wilderness.  They have prepared an Environmental Assessment.

The project would authorize Montana Fish, Wildlife & Parks (FWP) to implement fish management and stocking actions within the wilderness that would establish a secure population of native trout, replacing an existing hybrid population.

To restore and secure this population, the project proposes the following actions; application of a piscicide, rotenone, to eradicate the non-native fish species; use of motorized equipment such as a boat motor, generator, and a helicopter to transport equipment, supplies, and fish for stocking; temporary development of structures or installations; and use of chemicals (pesticides or herbicides). Additionally, public access in the area would be closed for 7-10 days during the late summer of 2021 to reduce user conflicts with management actions.

The Forest Service has assessed the suitability of the proposed activities in the Scapegoat Wilderness through a process called a “minimum requirements analysis.” This is a process used to identify, analyze, and recommend management actions that are the minimum necessary for wilderness administration, as directed by the Wilderness Act of 1964.

From the linked article:

Opponents challenged the plan’s use of motorized equipment in a federal wilderness area where such machinery is typically prohibited, the idea of stocking otherwise fishless waters in wilderness, use of fish poison and the potential of harming non-target fish in the area.

There doesn’t seem to be much disagreement with the project purpose, but resistance to how they would do it.  The exception where “mechanical transport” and “structure or installation” would be allowed by the Wilderness Act is:  “except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act.”  It seems like their argument that they need motorized access is weak (see photo), but if chemicals are the only way to remove the non-native species, should they not do it?

Then there is the requirement to maintain viable populations of native species on national forests, which might for some species (maybe amphibians that evolved without fish predators) require them to do it.

 

Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington

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One of the many things that went into the Trump dump the last couple of weeks was the amendment of the Forest Service Eastside Screens old growth protection standard:  “Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington.”    We discussed that at length here.  The Forest Service documentation for the amendment is here. The standard prohibiting harvest of trees >21” dbh has been replaced by this guideline (“LOS” is late and old structure, and it refers to “multi-stratum with large trees” and “single-stratum with large trees”):

Outside of LOS, many types of timber sale activities are allowed. The intent is still to maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible, by adhering to the following plan components: Managers should retain and generally emphasize recruitment of old trees and large trees, including clumps of old trees. Management activities should first prioritize old trees for retention and recruitment. If there are not enough old trees to develop LOS conditions, large trees should be retained, favoring fire tolerant species where appropriate. Old trees are defined as having external morphological characteristics that suggest an age ≥ 150 years. Large trees are defined as grand fir or white fir ≥ 30 inches dbh or trees of any other species ≥ 21 inches dbh. Old and large trees will be identified through best available science. Management activities should consider appropriate species composition for biophysical environment, topographical position, stand density, historical diameter distributions, and Adapting the Wildlife Standard of the Eastside Screens 5 spatial arrangements within stands and across the landscape in order to develop stands that are resistant and resilient to disturbance.

The proper way to read a guideline is that its purpose is a standard: “Managers must maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible.”  It’s not clear to me how you maintain LOS “outside of LOS,” so maybe only “enhance” is applicable, but even that term assumes what you are enhancing is already there to a degree.  This is also weakened by the qualifier “as much as possible.”  This could be interpreted to allow timber harvest even if enhancing LOS conditions is not possible.

The rest of the boldface language should be interpreted as actions that would always be allowed because they would always promote the LOS purpose.  This means that a decision to NOT retain all old and large trees could only be made if it is demonstrated that LOS is enhanced.  “Generally emphasize” allows probably unlimited discretion regarding recruitment.  A decision to NOT prioritize old trees (i.e. to log any old tree before logging large trees) could also only be made if it is demonstrated that LOS is enhanced.  This could be reasonably effective, but it puts a significant burden on project analysis and documentation to deviate from the terms of the guideline.  This is as it should be.  The last part of the guideline lists things that “should be considered,” which shouldn’t be given much weight.

There are also changes in standards and guidelines for snags, green tree replacement and down logs.

The last part of the “decision” is to adopt an “Adaptive Management Strategy.”  This strategy proposes monitoring and thresholds intended to trigger additional restrictions on large tree removal:

  1. If large trees are not increasing in number with appropriate composition, the Regional Forester will impose the Age Standard Alternative across the whole analysis area or by national forest or potential vegetation zone.

  2. If effectiveness monitoring does not occur, the Regional Forester will impose the Age Standard Alternative across all six national forests.

However, under the Planning Rule, these are not plan components and are not mandatory.  While there are “requirements” for regional forester review every five years, this is not a plan component either.  Since none of this “strategy” is enforceable it is of much less benefit than if it had been included as plan components like standards.

(For those interested in how the “natural range of variation” (NRV) is used in forest planning, there is a desired condition for the amounts of LOS in different habitat groups and it is based on NRV.  These new amendments leave in place the desired conditions for LOS previously determined in accordance with the original amendments in 1995.   An appendix in the decision notice includes a “Table 3” that is “only an example” of NRV because, “The number and kind of biophysical environments and the historic and current distribution of structural conditions vary by landscape.”  In order to fully understand the effects of this amendment on a particular landscape, we would need to see the definitions of LOS and actual desired conditions for LOS incorporated into a plan for that landscape.  I didn’t find them in or see them referred to in the amendment documentation, I suppose because they are not changing).

 

Hundreds of Giant Sequoias Considered Dead From Wildfires

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It appears that rumors of ‘natural and beneficial’ wildfires in the southern Sierra Nevada have been ‘greatly exaggerated’. Even the Alder Creek grove, which was recently bought by Save the Redwoods, was decimated. Of course, this eventuality has been long-predicted.

https://www.latimes.com/environment/story/2020-11-16/sierra-nevada-giant-sequoias-killed-castle-fire

Good news for wildlife on two national forests

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Here are two different kinds of success stories about restoring wildlife species that have been missing from national forests.

 

 

Grizzly bears – Lolo National Forest.

Current efforts on the Lolo National Forest demonstrate one way that forest plans can improve conditions for at-risk species; in this case the plan is contributing to conservation of the federally threatened grizzly bear. Grizzly bears have been sighted in recent years in this part of the Forest, but none are females or considered to be residents.

In 2011, the forest plan was amended to include what is commonly referred to as the Access Amendment (similar amendments also applied to the Kootenai and Idaho Panhandle national forests, prior to the revision of their forest plans).  The amendment established “standards” for motorized road and trail density in grizzly bear management units (BMUs, there is one on the Lolo).  In many cases, the current conditions did not meet these standards, so in the terminology of the 2012 Planning Rule, these would be desired conditions or objectives to be achieved.  In addition, their achievement was assumed in the biological opinion on the effects of the forest plan on grizzly bears prepared by the Fish and Wildlife Service, and failure to achieve them would likely trigger the need to reinitiate consultation on the forest plan (which had happened on the Flathead National Forest).  So there is a little added incentive, but here is what they are doing now.

The Forest has completed the “BMU 22 Compliance Environmental Assessment.”  In it they have proposed to formally close some roads that are effectively closed already and 21 trail miles currently open to motorized use.  In response to public comments, they are also considering an alternative that would close fewer trails, and instead close some roads currently open to motorized use.  In addition to other closures included with some prior vegetation management projects both alternatives “would bring the Forest into compliance with the Forest Plan motorized access management standards for the Cabinet-Yaak grizzly bear recovery zone.”

Brown-headed nuthatch – Mark Twain National Forest

The nuthatch is not at-risk range-wide, but they have not been found in Missouri for at least a century.  The species requires shortleaf pine and oak woodland forests, which have been greatly reduced from historic levels.  The loss of these forests has prompted an ecosystem restoration effort across Missouri, Arkansas and Oklahoma (notably using the Collaborative Forest Landscape Restoration Program).  Restoration of such forests is a desired outcome of the Mark Twain forest plan.  Curiously, there is no mention of the brown-headed nuthatch in the 2005 forest plan, although it does address other species using the same habitat:

Objective 1.4a Improve open woodland conditions on at least 10,500 acres to provide habitat for summer tanager, northern bobwhite, Bachman’s sparrow, and eastern red bat.

The EIS states that the nuthatch is a Management Indicator Species for forest plan monitoring, but that doesn’t seem to be in the plan itself.  Of course, a species that is absent from a national forest would not make a good MIS.  In any case, it looks like there was no interest by the Mark Twain in reestablishing a species that was not present on the forest under that rules applicable to forest planning in 2005.

However, Forest Service, state and university researchers came to the rescue of the species, determining that sufficient woodlands now exist in Missouri to support a population of Brown-headed Nuthatches, that populations in Arkansas were robust enough to supply birds to Missouri, but that nuthatches are not likely to make the return on their own because of the distance and habitat fragmentation.  The Mark Twain National Forest site was chosen for the release of 100 birds because it is the largest area of open pine woodlands in the state.

Under the 2012 Planning Rule, the Forest Service would probably argue that this species is not “known to occur” in the plan area, so the requirement to provide ecological conditions for it (as a species of conservation concern) would not apply.  However, the separate requirement for ecological integrity requires “species composition and diversity” to occur within the natural range of variation.  That should make the Forest Service more proactive in reestablishing species that historically occurred there.  (The forest plan also omits the listed red-cockaded woodpecker, which also uses these habitats, is also absent, but must be conserved and recovered.)

(For a look at how the natural range of variation might work under the 2012 Planning Rule see Table A-2, “Desired conditions for natural community types.”)

Stanislaus spotted owl plan amendment

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Photo of female and juvenile California spotted owl courtesy of University of California Cooperative Extension (http://ucanr.org/sites/spottedowl/).

We recently looked at the Biological Assessment of Northwest Forests, and the options for proceeding with revising forest plans currently governed by the Northwest Forest Plan. Some of those options involved amendments to existing plans prior to plan revision. I voiced support for amendments that would provide the ecological conditions needed for at-risk species. I thought this might be an example to look at for how that might go.

The Stanislaus National Forest is not in the area covered by this assessment. Its forest plan was originally completed in 1991, but it was amended by the Sierra Nevada Forest Plan Amendment (or Framework) in 2004, which is roughly analogous to the Northwest Forest Plan in that it had its origins in the work done to protect the California spotted owl (it has its own complicated political and legal history). Now the Stanislaus is proposing an amendment for a part of the Forest in conjunction with what it calls the Social and Ecological Resilience Across the Landscape (SERAL) project.

The Forest has identified a need to change the forest plan based on new information about the California spotted owl, as published in 2019 by the Forest Service in the “Conservation Strategy for the California Spotted Owl in the Sierra Nevada.”

In order to fully adopt and implement the management direction described in the Conservation Strategy and increase landscape resiliency as guided by NRV the Stanislaus National Forest’s forest LRMP must be amended. The proposed forest plan amendments would allow the SERAL project’s proposed landscape restoration treatments to best meet the purpose and need of the project and implement the guiding principles of the 2019 California Spotted Owl Conservation Strategy. The proposed amendments include standards and guidelines which will provide some immediate stability for individual owls while allowing forest management the ability to conduct treatments designed to help develop resilient habitat conditions that provide CSO conservation in the long term.

Unfortunately, the CSO Conservation Strategy was apparently written for a narrower purpose than its name implies:

The California spotted owl (Strix occidentalis occidentalis) Conservation Strategy is a strategic framework for active conservation of the California spotted owl on National Forest System lands in the Sierra Nevada.

It appears to be something less than a scientific strategy. By limiting the focus to “active conservation” it has failed to address the central debate about managing spotted owl habitat regarding when active management should even be used. Passive management is one obvious alternative to this amendment that the Forest is going to have to address in its amendment process. But I looked at some of the proposed changes in the forest plan.

The current plan designates spotted owl Protected Activity Centers (PACs) as management areas in the forest plan (which could be changed only by amending the forest plan). This proposed amendment would replace current management areas with guidelines to designate PACs later “in advance of any management activities that would reduce CSO nesting and roosting habitat quality.” The guidelines include criteria for delineating and changing PAC boundaries.

My opinion: This is not a coarse filter management strategy based on vegetation because it depends on actual owl presence based on surveys, or one might call it “condition-based.”  If owl presence is the kind of thing that changes frequently, this may be a reason to not designate permanent management areas at the plan level.  However, this creates the risk of cutting the public out of the part of the process that actually determines the locations for management.  The plan is no longer saying, “here is where we’ll manage for owls,” but instead, “we’ll manage for owls where we think we need to manage for owls, trust us.”  The criteria must be explicit and objective enough to fully evaluate at the plan level, and the decisions about whether and how to apply them at the project level must include the public. Given the importance that surveying would take on, there is no excuse for these being guidelines rather than standards. It seems to me that the certainty of owl protection, and therefore the viability of the species, is going to be reduced.

There are a lot of new plan components in the amendment, and the CSO Conservation Strategy is page-referenced for most of them. That’s how any conservation strategy should be used, so maybe this is a good example of that. Except that it strikes me that this “conservation strategy” may have actually been written as a “drop-in” amendment to be used this way (which makes that kind of cross-referencing a lot easier). This is similar to what would happen if plan amendments were developed that could be later “dropped in” to forest plan revisions. The problem is that if the “conservation strategy” is already a management-influenced document and not a science document, there would still need to be a reference to the actual scientific basis for these conservation recommendations that are being adopted.

Anyway, this project/amendment will be worth watching as it applies the 2012 Planning Rule diversity requirements to California spotted owls. And it may be setting some precedents for what could happen regarding how to plan for management of spotted owl habitat on other national forests.