Range of variation webinar (and more)

This is a topic that at least Sharon and I like to debate (though for some reason she didn’t weigh in here).  The Western Environmental Law Center is offering this hour and half webinar on July 17.  As far as I know, it’s open to the public.

PNW Forest Collaboratives Workshop Series Part 3: Historical Range of Variability (HRV): Uses and Various Approaches
 
Range of Variability (ROV) concepts – including Natural (NRV), Historic (HRV), Current (CRV), and Future (FRV) – are frequently used by the US Forest Service to help define land management goals. Nathan Poage, Forest Service Ecologist, joins us to provide an introduction to ROV terminology and examples of how the Malheur, Umatilla, and Wallowa-Whitman National Forests in the Blue Mountains have applied ROV concepts during project planning when addressing key requirements of the Eastside Screens. The discussion will include overviews of tools commonly used to conduct ROV analyses. Q&A will follow the presentation.
This webinar will be on Friday, July 17 from 10-11:30am Pacific Time.
Registration is required for this event. Register today by clicking this link.
Note that it also involves the Eastside Screens.  I don’t think I can make it, but I’d be interested in hearing about it.  I also wanted to point out that this is about how to apply these concepts to projects developed under antiquated forest plans that don’t include the concepts.  It was this kind of thinking that drove development of the requirement to do this instead as part of revising forest plans under the 2012 Planning Rule.  Natural Range of Variation (NRV) embraced by the Planning Rule is a required desired condition for ecosystems, which should not change over time, and therefore should not be redecided for each project.  I’d be interested in knowing how, once ROV is determined for a particular project here, it is then documented and used for future projects in the same ecosystem.
But maybe there would be more interest in this one:
PNW Forest Collaboratives Workshop Series Part 2: Collaborative Administrative and Judicial Review Opportunities
In this follow-up webinar to NEPA 101, WELC attorney Susan Jane Brown will give a presentation on and answer your questions about collaborative administrative and judicial review opportunities, and dig deeper into the administrative review process for the Forest Service, judicial review of agency decisions, and how collaborative groups can engage in these processes.
This webinar will be on Thursday, July 9 from 10-11:30am Pacific Time.
Registration is required for this event. Register today by clicking this link.

Virus driving forest fire policy

It looks like the pandemic is taking the Forest Service back to the old days of fire suppression, when the goal was to have them all out by 10:00 am.  It will be interesting to see (if it’s possible) what actual difference that makes in the coming fire season (which is predicted to generally be normal or slightly worse).  Of course changes in operations from social-distancing may also be a factor.  And this all has be squared with the Chief’s pronouncement (quoted there):  “Forest Service resources will be used “only when there is a reasonable expectation of success in protecting life and critical property and infrastructure.”

Prior to this year’s COVID-19 complications, the U.S. Forest Service and other agencies have increasingly looked to low-intensity, managed fires on wildlands to improve ecosystem health and reduce undergrowth that can lead to intense, out-of-control fires. This fire strategy has meant allowing unintentional fires and prescribed burns to reduce excessive undergrowth when conditions are favorable.

“We want to try to limit the amount of fire that is out on the landscape this year, which is in contrast to what we’ve been trying to do around here. We’ve been trying to get fire out on the landscape. But for obvious reasons, for the health of our  firefighters and the public in general, we need to limit those as best we can,” said James Pettit, fire staff officer for Coconino National Forest.

Another benefit of the quick suppres­sion strategy this year, according to Pettit and Russ Shumate, a district manager for the Arizona Department of Forestry and Fire Management, is reducing the need to bring large numbers of fire fighters and support staff together for long operations. Shumate noted that managing a large fire can involve fire camps with 500 people. Controlling spread in these conditions might be challenging.

Shumate said quick suppression will also allow the state fire agency to manage fires with fewer resources, something he is expecting this year.

“In the previous days of the Forest Service they had what they called a ‘10 o’clock rule’ — the goal was to suppress all fires before 10 o’clock the next morning. We’re not going to state it as that aggressive, but it’s a real similar strategy [this year]” Pettit said.

The USFS instituted the “10 a.m. policy” in 1935. It was officially replaced in 1977 with a policy that expanded fire fighting strategies to include managed burns.

A similar message is coming from the Bitterroot National Forest (with more about “fewer resources” from the Job Corps):

Wilson said the objective will be to keep all fires on the national forest — including wilderness — small and limit the amount of smoke that’s produced.

 

Why Pinyons and Junipers Are Where They Are or Were Where They Were: Many Possibilities

This study says that PJ coming into sagebrush is not good for sage grouse. https://www.sciencedirect.com/science/article/pii/S1550742416300811

Last week I ran across two studies (a paper and a presentation) that both illustrate what I think it an important point. When we look at what happened in the past (usually from photos, or history books, or what’s there today) and see changes, we don’t know for sure if that is due to (1) previous people doing things (Natives and settlers), or (2) what happened when previous people stopped doing things, (3) vagaries of weather/climate or (4) other causes.

Last week I attended a Colorado State University featuring Dr. Marina Redmond, talking about pinyon-juniper woodlands and their expansion and contraction. The first point that she made is that there is an enormous range, and each situation/place is different. In some areas, PJ is expanding, and in other areas contracting, due to drought-induced mortality. According to this paper the mortality in pinyon is due to Ips species, and in juniper due to “plain old” drought stress.

If you just look at PJ expansion, you might think it’s due to fire suppression, which has changed over time. But it might also be caused by wetter conditions that were good for tree seedling establishment. Or it might even be that there was overgrazing in the past, which established conditions (little grass cover) in which PJs got a chance to take hold. It could even be a combination of several of these factors. Or in more generic terms, climate change (that is change mostly before what we call anthropogenic cc based on GHGS), post-disturbance recovery (I guess these would be “natural” disturbances, but perhaps these may not be obvious 100 years later), and changes due to human interventions (say, removing bison, adding cattle) and recovery from human interventions. Humans have a long history in the Southwest. Then, when you get into interactions among these, it seems like it would be hard to know for sure, and perhaps even harder to find (1) an ideal target NRV that people agree on (2) the FS can afford to intervene to produce and that (3) will be resilient to climate change.

It seems to me that keeping endangered species around (as in the study shown in the image above), producing useful things for wildlife and people (and cows) like forage and pinyon nuts, and at least thinking about resilience to climate change are challenging (and expensive) enough for land managers without introducing ideas like NRV or HRV. Perhaps the above observations in PJ are an example of what Millar and Woolfenden point out as “conceptual and practical” problems with ideas such as NRV.

While there are many important lessons to learn from the past, we believe that we cannot rely on past forest conditions to provide us with blueprints for current and future management (Millar et al 2007). In particular, the nature and scale of past variability in climate and forest conditions, coupled with our imprecise ability to fully reconstruct those conditions, introduce a number of conceptual and practical problems (Millar and Woolfenden 1999a). Detailed reconstructions of historical forest conditions, often dendroecologically based,
are very useful but represent a relatively narrow window of time and tend to coincide with tree recruitment in the generally cooler period referred to as the little ice age (figure 1). As such, manipulation of current forests to resemble past conditions may not produce the desired result when considering future climates.

This quote is from this paper by Stephens, Millar and Collins (2010). I’d only add to that list “the nature and scale of past variability in human actions and our imprecise ability to fully construct” them.

Mt. Hood (lack of) science loses in 9th Circuit

The way courts approach scientific controversy is a common thread on this blog.  We happen to have a perfect example from the Ninth Circuit Court of Appeals (link to the opinion included) last week.  And it happens to involve the science of “variable density thinning” to reduce wildfire threats, another popular topic here.

The Project is the Crystal Clear Restoration Project on the Mt.  Hood National Forest.  The stated primary purpose of the Project is to reduce the risk of wildfires and promote safe fire-suppression activities.  It would use “variable density thinning” to address wildfire concerns, where selected trees of all sizes would be removed.  According to the plaintiffs, it  would encompass nearly 12,000 acres and include almost 3000 acres of logging of mature and old-growth forests along with plans to build or re-open 36 miles of roads.  The court held that an EIS was required because of scientific controversy about the effects of variable density thinning on what plaintiffs characterized as “mature, moist forest.”  The court also found that the Forest failed to show that cumulative effects would not be significant.

In both cases, the court found that the Forest “did not engage” with the information provided by the plaintiffs after, “The plaintiffs, especially Bark, got people out into the landscape and spent thousands of hours collecting information about what was going on in the land and gave that information to the Forest Service,” said attorney Brenna Bell, who spent four years on the case.  Failing to engage is a common reason for the Forest Service failing to win in court, especially when under pressure to meet “timber volume targets imposed by President Donald Trump’s administration.”

The EA stated that the Project would assertedly make the treated areas “more resilient to perturbations such as . . . largescale high-intensity fire occurrence because of the reductions in total stand density.”  Plaintiffs had provided “substantial expert opinion” that disputed that outcome.  As plaintiffs point out in their victory notice, here is how the court viewed it:

“Oregon Wild pointed out in its EA comments that “[f]uel treatments have a modest effect on fire behavior, and could even make fire worse instead of better.” It averred that removing mature trees is especially likely to have a net negative effect on fire suppression. Importantly, the organization pointed to expert studies and research reviews that support this assertion

Oregon Wild also pointed out in its EA comments that fuel reduction does not necessarily suppress fire. Indeed, it asserted that “[s]ome fuel can actually help reduce fire, such as deciduous hardwoods that act as heat sinks (under some conditions), and dense canopy fuels that keep the forest cool and moist and help suppress the growth of surface and ladder fuels . . . .” Oregon Wild cited more than ten expert sources supporting this view.”

Even the fuels report by the Forest Service acknowledged the possibility of increased fire severity. The court held (emphasis added):

“In its responses to these comments and in its finding of no significant impact, the USFS reiterated its conclusions about vegetation management but did not engage with the substantial body of research cited by Appellants. Failing to meaningfully consider contrary sources in the EA weighs against a finding that the agency met NEPA’s “hard look” requirement as to the decision not to prepare an EIS. This dispute is of substantial consequence because variable density thinning is planned in the entire Project area, and fire management is a crucial issue that has wide-ranging ecological impacts and affects human life.”

The opinion is short and worth reading as a good example of how not to approach NEPA effects analysis (i.e. “let’s make this fit into an EA instead of an EIS”).  The court cited 9th Circuit precedent for this requirement: “To demonstrate a substantial dispute, appellants must show that “evidence from numerous experts” undermines the agency’s conclusions.” The court is not choosing the science; only faulting the Forest Service for ignoring conflicting views that it found rose to a level of scientific controversy.  Under NEPA, evidence of scientific controversy requires an EIS to fully explore how the use of that science may be important to determining environmental impacts.

The popularity of categorical exclusions

WildEarth Guardians noticed that the Forest Service is approving more and more vegetation management projects using categorical exclusions from NEPA procedures:  “a category of actions which do not individually or cumulatively have a significant effect on the human environment.”  They decided to do a little research, and found someone to report on it.

Rissien used Forest Service postings to tally all the logging and/or burning projects proposed for the past quarter – January through March – where forest managers had applied a “categorical exclusion” to avoid the public process normally required by law.

For just those three months, 58 national forests– that’s three-quarters of the forests in the West – proposed 175 projects that would affect around 4 million acres.

Rissien found, during the past quarter, USFS Region 4 – which covers southern Idaho, Nevada and Utah – proposed four projects that exceeded 100,000 acres each. One was 900,000 acres alone.

USFS Region 1, which includes Montana, northern Idaho and North Dakota, proposed 30 projects with CE’s last quarter, totaling more than 215,000 acres.

Logging projects intended to reduce insect or disease infestation or reduce hazardous fuels can be as large as 3,000 acres with some limitations. One CE created by the Forest Service for “timber stand and/or wildlife habitat improvement” has no acreage limit. Rissien found the Forest Service uses that for a majority of projects, and doesn’t even give a reason for others.

(There is also the “road maintenance” CE that has been the subject of litigation, including EPIC v. Carlson, here.)

There are some things to question in the article, but the slant of the article is not so much that what the Forest Service is doing is illegal, but that it is being done without much public information or awareness.  The article also points out that the Forest Service just seems to be following its marching orders from the president.  Tracking through the links gets you to this letter from the acting deputy chief, which says:

Consistent with this direction, Regional Foresters are to ensure that the Agency meet minimum statutory timeframes for completion of National Environmental Policy Act documentation and consultation with regulatory agencies. Categorical exclusions to complete this work should be the first choice and used whenever possible. I encourage you to explore creative methods and set clear expectations to realize this priority effort.

There’s a few points to make here.  I’m not aware of any “minimum statutory timeframes” for NEPA or consultation (the consulting agencies do have a deadline for providing a biological opinion).  I would translate “explore creative methods” into “take legal risks.”  Artificial deadlines aren’t creative, but they also result in legal risks.  Last is the implication that the use of categorical exclusions somehow avoids the need for an administrative record that shows that the use of the categorical exclusion isn’t arbitrary – that it fits the requirements of the category and does not have any extraordinary circumstances that could result in significant effects.  The lack of public review or an administrative objection process may save time, and it forces an opponent to sue, but it increases the risk of losing the case on an issue that could have been resolved before the decision.  (But if it gets points on the board during the game, does it matter what happens after?)  WEG said, “But we have to take their word for it since there is no supporting analysis we can review.”  If that’s what is really happening, it would eventually be a problem for the Forest Service in court.

Helena project clears the 9th Circuit, except for some “WUI”

Fine specimen of a real antique Morse code telegraph machine.Copyright: Photowitch | Dreamstime.com

The Ninth Circuit Court of Appeals has upheld the Telegraph Vegetation Project on the Helena-Lewis and Clark National Forest, except for one question about the location of the Wildland Urban Interface (WUI).  The case was previously described on this blog here.  That description included this allegation by plaintiffs:

Agency used non-federal definition of the Wildland Urban Interface 


“While the lynx amendment allows logging in the Wildland Urban Interface, it also defines the Wildlife Urban Interface to be within one mile of communities,” Garrity explained. “But the Forest Service used a new definition provided by local counties and then remapped the Wildland Urban Interface to include areas over five miles away from communities.”

The court remanded the decision for 50 acres of the 5000-acre plus area to be treated, and left the record of decision in place while the Forest Service completes its reevaluation:

“The Forest Service has acknowledged that it erred in calculating the wildland-urban interface for the project area. The Forest Service estimates that, once it has corrected its error, 50 acres of forest that it had planned to treat may no longer be eligible for treatment. If that estimate proves correct, the Forest Service represents that it will not treat those 50 acres. We grant the government’s request for a voluntary remand to allow the Forest Service to undertake the necessary reevaluation.”

I have been interested in how WUI is identified, by whom, and using what process under what authority – especially the role of non-federal parties.  WUI is generally  identified based on the Healthy Forest Restoration Act of 2003 (HFRA).  Areas identified using that process qualify for streamlined projects in accordance with HFRA, and may be eligible for particular funding.  However (in accordance with HFRA), WUI projects are still subject to requirements of the governing forest plan.  Management direction for lynx is part of the forest plan, and this article (like plaintiffs) suggests it imposes greater restrictions on part of this project:

“In the second portion of the court’s order, the Forest Service proposed logging and thinning in areas defined as the “wildland-urban interface,” which is where houses or cabins meet the forest. Regulations related to lynx allow the removal of some trees and vegetation in lynx habitat if it falls within the wildland-urban interface and if the agency shows it is part of a wildfire mitigation project. The alliance inspected the area and reported only a handful of houses. The Forest Service conceded in court documents that it erred in calculating the size of the wild-land urban interface based on discrepancies between what qualifies.”

However, this actually indicates that the problem was in the definition of “community” (based the on number of houses), rather than the distance from one.  In fact, the Northern Rockies Lynx Management Direction refers to WUI “as defined by HFRA.”  Those definitions and criteria for “WUI” and “at risk community” are summarized by the Forest Service here.  Although which communities are to be included (they can self-identify) are mostly listed in the Federal Register, that doesn’t address their boundaries.  The district court opinion upheld the Forest Service WUI designation, stating that, “The Powell County Plan does not begin with the HFRA definition; it creates its own, “and “the Court is not persuaded by Council’s attempt to discredit the map provided by the Forest Service in the Telegraph Project EIS” based on that county plan. Yet it sounds like the map may have been wrong in this case.  This all reminds me of my take-home from my Forest Service days that “WUIs are fuzzy.”

Here’s why this might be important to planning.  I agree with the idea that forest plans (like the lynx direction) should identify areas with differences in long-term management that result from a wildland-urban influence.  However, if the WUI definition refers to another source (HFRA and a local plan), instead of being specifically defined in the plan itself through criteria and/or a map, there may be confusion about where and how the plan applies (as seems to be the case here).  (Yes I’m criticizing the lynx strategy for doing that; they didn’t take my advice.)  In addition, if external decisions about WUI locations change, the Forest Service may have to publicly consider whether to adopt that change in its forest plan (that situation wasn’t addressed in this case).  I’m also contrasting “decisions” with new “information” that affects how an existing decision applies (e.g. someone building a new house), which must be considered in a planning context but doesn’t necessarily trigger a plan amendment.  (A court has held that even changes in something like criteria for maps of lynx habitat must be considered in a public planning process when forest plan direction is tied to it.)

(The other issue addressed by the 9th Circuit in its short opinion was the ESA consultation process for grizzly bears.  The court approved a consultation process that tiered to forest plan decisions and consultation, which lead to streamlined project consultation.  The value of forest plan consultation has been questioned, but that value is evident here.)

 

Stewardship contracts – a better tool for the job than a roadless rule?

I wouldn’t have thought that one is a substitute for the other, and maybe this suggests that Utah defined its problem wrong initially.  But they’re happy enough with the way their Shared Stewardship agreement is working that they have put their roadless rule proposal on a back burner.  At least some greens seem happy, too, and least those concerned about roadless areas.  Priority-setting, within the framework of a forest plan, is one thing that I think lends itself to collaboration.

Amid debate about state-specific exemptions to the Roadless Rule, Congress created the capacity to negotiate “stewardship contracts” ranging up to 20 years with states in the 2018 Consolidated Appropriations Act.  It allows the Forest Service to rely on “state’s guidance for designing, implementing, and prioritizing projects geared toward reducing the risks of damaging wildfires and promoting forest health.”

 

Wilderness Society Senior Resource Analyst for National Forest Policy Mike Anderson said conservationists are encouraged by what Shared Stewardship agreements could foster in addressing critical needs.  “Working side-by-side to identify the major risks and implement projects that are actually going to make a difference on the land is something conservationists, I think, can generally can support,” he said. “We think it is good.”

 

(Utah Public Lands Policy Coordinating Office lead counsel) Garfield said under the agreement, projects “can happen, and are occurring, within and without the roadless area, when necessary.”    ‘The existing rule provides a lot of exceptions that the Forest Service can use for forest restoration,” he said. “The Forest Service wasn’t using those” exceptions in many cases.  Garfield said PLPCO will be watching closely over the next four years to see if the Shared Stewardship agreement works out before withdrawing its petition. “I won’t say everything we hoped to accomplish under a state-specific Roadless Rule will be achieved under the Shared Stewardship agreement,” he said, “but a lot of progress is being made.”

(One error in this article – the Idaho and Colorado state roadless rules have been approved.)

Environmental investors fund fuel reduction projects

Here’s how it works: Investors buy into the bond, and the money is drawn as needed for forest restoration work. This includes thinning, strategic backfires and other rehabilitation. In this first case, it was a $4 million bond with money from CSAA Insurance, Maryland-based investment firm Calvert Impact Capital, The Rockefeller Foundation, and the Gordon and Betty Moore Foundation.

The investors are paid back over five years, with 4% interest, by those who benefit from the work and have contracted with Blue Forest, like the U.S. Forest Service and state agencies. In this case, payments will come from the Yuba Water Agency, whose reservoirs receive water from the forest and the California Department of Forestry and Fire Protection.

And the bond couldn’t come at a better time in the investor community, as an increasingly popular trend of socially conscious investing is taking off. It’s called ESG, which stands for environmental, social and corporate governance. It focuses on investing for the greater good; in this case, buying into the health of the forest but still making money.

It is exactly the kind of investment Jennifer Pryce, CEO of Calvert Impact Capital, says her clients want.

“Our investors are looking for an impact and a financial return, and this is off the charts when you look at what it’s giving back,” said Pryce, who polls investors each year to see how they want to align their capital with their values. “Fighting climate change is No. 1.”

She admits this one was a difficult sell because it is designed to prevent fires, rather than fight them. Still, once the possibilities and savings were made clear, the investors were in.

It’s not exactly “fighting climate change” either.  I wonder what else might get lost in translation, and would the “environmental” investors necessarily like the “other rehabilitation” that the Forest Service decides to fund with their money, and whether there are any restrictions on what an agency could use the funds for.  An interesting concept though …

Rocky Mountain Restoration Initiative- Focused Landscape Restoration

In La Plata County, about 53,800 people, or 96.9% of the total population, live in the wildland-urban interface where residents are at-risk of wildfire. A pilot project aims to build a better buffer around these homes.
Durango Herald file
I hadn’t heard about this effort until the the Durango Herald story here. The article has great photos, also it was interesting that 96.9% of folks in La Plata County live in the WUI. The National Wild Turkey Federation is coming out with more info later this week, so stay tuned.

Southwest Colorado could be the focal point of a pilot project that seeks to make strides in improving forest health in the face of increasing dangers from wildfire, disease and beetle kill.

Earlier this year, the National Wild Turkey Federation approached the U.S. Forest Service to talk about the challenges in forest management that impede fast-paced and large-scale landscape restoration.

In the past, the Forest Service has tried to spread its budget for forest health projects evenly across a landscape, said Kara Chadwick, supervisor for the San Juan National Forest.

“We’ve been struggling with this as an agency for a while,” Chadwick said. “We get a little bit done everywhere.”

But forest officials started to wonder: What if you directed all your resources, in terms of time and money, to one or two places to accomplish critical improvements, rather than make slow progress in multiple places.

“The idea is to focus in one place, and once you’ve achieved that change on the landscape, move to another,” Chadwick said.

The project is called the Rocky Mountain Restoration Initiative, or RMRI.

Colorado was chosen as the state to pilot the project for several reasons: It’s home to the headwaters of four major river systems; nearly 3 million people live in the wildland-urban interface; and outdoor recreation is a big part of the state’s economy, to name a few.

Within the state, three regions are being considered to test the project: the central Front Range, the Interstate 70 corridor and Southwest Colorado.

The idea, Chadwick said, is to work across all boundaries – federal, state and private lands – to make “transformative change” on the landscape through projects like forest thinning, prescribed burns and boosting logging operations.

Chadwick said areas around Durango, west along the U.S. Highway 160 corridor and up to Dolores could be areas of particular focus.

In La Plata County, for instance, about 53,800 people, or 96.9% of the total population, live in the wildland-urban interface.

Another major part of the program is to improve and protect watersheds. Mike Preston with the Dolores Water Conservancy District said the pilot project could also be used to thin badly overgrown ponderosa forests in the Dolores River watershed.

Past forest management practices have created too-dense tree stands, which can exacerbate issues with wildfire and beetle spread, as well as suck up an inordinate amount of water, Preston said. Encouraging prescribed burns and forest thinning through harvest sales could help with all these issues, he said.

“The problem is, with limited resources available to advance forest health, the pattern has been to spread resources across the entire forest,” he said. “With this project, we’re attempting to concentrate on one or two projects and see what can be accomplished moving more aggressively and timely.”

Chadwick said the hope is to have a final decision on the pilot project by this December. Any work on the landscape would have to go through the National Environmental Policy Act, which requires a study on the environmental impacts of a particular project.

“I think we can get a lot of really good work done, and in the process, build better relationships across the landscape,” she said.

Midwest timber wars revisited

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

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

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

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

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

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

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