A test of the 2014 insect and disease categorical exclusion

The Center for Biological diversity is suing the Tahoe National Forest for its decision on the Sunny South timber sale. The sale is designed to “reduce the extent and risk of insect infestations, as well as to reduce the negative effects of those infestations on forest health and resilience.” Plaintiffs allege, “Six (California spotted) owl territories are slated to be logged …, all of which are important contributors to the overall owl population given the high degree of successful owl reproduction in these old forested areas.”

Section 603 of the amended Healthy Forests Restoration Act establishes a categorical exclusion for qualifying insect and disease projects in designated areas on National Forest System lands. An insect and disease project that may be categorically excluded under this authority is a project that is designed to reduce the risk or extent of, or increase the resilience to, insect or disease infestation in the areas.  The project must be located in an area designated pursuant to a Governor’s request for areas in their State that are experiencing, or at risk of, an insect or disease epidemic. The project must also meet other criteria, including these rather subjective ones:

  • The project was developed through a collaborative process that includes multiple interested persons representing diverse interests and is transparent and non-exclusive.
  • The best available scientific information must be considered to maintain or restore ecological integrity, including maintaining or restoring the structure, function, composition and connectivity.

We might find out a little more about what these things mean from this court.

There used to be a sort of rule of thumb that if a project looked controversial, the Forest Service wouldn’t pursue a categorical exclusion (in part because they may be difficult to defend in court). The new agency policy appears to be to thumb its nose.

 

Tales of two trees

Whitebark pine is a candidate for listing under the Endangered Species Act (meaning that listing is warranted).  The U. S. Fish and Wildlife (and tree) Service has recently downgraded its priority for listing from 2nd priority to 8th.

The primary threat to the species is from disease in the form of the nonnative white pine blister rust and its interaction with other threats…  However, the overall magnitude of threat to whitebark pine is somewhat diminished given the current absence of epidemic levels of mountain pine beetle, and because of this, individuals with genetic resistance to white pine blister rust likely have a higher probability of survival… Overall, the threats to the species are ongoing, and therefore imminent, and are now moderate in magnitude.

White ash is not a candidate for listing under the Endangered Species Act.  However, it is threatened with extinction as result of the introduced emerald ash borer.  The Forest Service is applying euthanasia treatments to the Allegheny National Forest.

The Emerald Ash Borer Remediation project would regenerate stands that have been or will be affected by non-native invasive insects. The purpose of this project is to manage the proposed treatment areas on the Bradford Ranger District to achieve a diversity of desired forest trees, a healthy and resilient ecosystem, and diminish the risks and consequences of forest health threats.

Desired tree seedling species do not develop in sufficient quantities on the Allegheny National Forest without intensive forest management. Interfering understory vegetation generally outcompetes tree seedlings. It is a result of decades of selective deer browsing (Horsley, Stout, deCalesta 2003). Unless management actions create suitable conditions for the establishment and development of desired tree seedlings, important ecological structure, function and processes will not be maintained in stands where white ash, American beech and Eastern hemlock individually or collectively make up the majority of the community.

Managing and regenerating declining stands now will promote natural regeneration of desired trees. It will sustain healthy, well-stocked forested stands over the long-term. This project is designed to address project area forest health concerns by regenerating stands before natural regeneration opportunities are lost.

Projected mortality is 99% of the affected trees without treatment (presumably it’s 100% with the treatment).  They don’t say what “desired trees” they are regenerating, and I can’t make much sense out of “natural regeneration” from the trees that would be “lost” (since they will be logged).  It looks to me like they are making sure there are no survivors, and if this is practiced across the range of the white ash, it would obviously become a candidate for listing.  Is there a better way?  Especially in the two old growth management areas where some of this project would occur, where making money off of timber harvest is not part of the purpose?  (Maybe killing deer would help – how about reintroducing wolves?)

Here’s the story that got my attention.  It mentions the need for a forest plan amendment, but the Forest Service documents do not mention this (and it would have to be part of the scoping package).

Massive Crater Lake Wilderness Area Fantasy

Oregon Wild has proposed a massive half million acre Wilderness Area, partly to “protect” Crater Lake. The Klamath County Commissioners are saying no, with fears that summer fires would affect public health, and that those unhealthy forests need active management.

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Here is a map of what Oregon Wild wants done.

The Rim Fire Salvage Seems Done

My last expedition included another trip to Yosemite, and the Rim Fire. I DO think that there are enough dead trees for the owls to “enjoy” in their respite from breeding. Then again, maybe this new “Circle of Life” will provide more food, in the form of baby owls, to larger predators?

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You might also notice the ongoing beetle kills, which will increase when spring and summer come into play. This next picture shows the little bit of harvesting that was done along Highway 120. You can see the drainage where the Highway sits, and you can also see how wide the hazard tree units are. The barren area in the foreground is/was chaparral.

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I am glad that the Forest Service “took my advice” about getting the work done before there was any chance to appeal to a more liberal….errr….. higher court. However, is THIS what we want our salvaged wildfires to look like? This area should be ready for re-burn in a few short years. Also, be reminded that two of the plantation salvage projects did not sell, despite the prompt action by the Forest Service. My guess is that SPI was low-balling the Forest Service to get those smaller trees at less than “base rates”. That means that the prices remain the same (rock bottom) but, some of the non-commercial treatments would be dropped. It appears that the Forest Service wasn’t willing to go as low as SPI wanted. So, those perfectly good salvage trees will be left, “for wildlife”, it appears.

California’s Forests: Where Have All the Big Trees Gone?

“The number of trees larger than two feet in diameter has declined by 50 percent on more than 46,000 square miles of California forests, the new study finds.”

“But in comparing a census of California forests done in the 1920s and 1930s with another survey between 2001 and 2010, McIntyre and his colleagues documented a widespread demise of big trees that was evident even in wildlands protected from logging or development.  The loss of big trees was greatest in areas where trees had suffered the greatest water deficit.”

If nothing else, this supports a policy of not killing the survivors.

More Rim Fire Pictures

All too often, once a firestorm goes cold, a fickle public thinks the disaster is over with, as the skies clear of smoke. In the situation of the Rim Fire, the public hasn’t had much chance to see the real damages within the fire’s perimeter. All back roads have been closed since the fire was ignited. Besides Highway 120, only Evergreen Road has been opened to the public, within the Stanislaus National Forest.

From my April trip to Yosemite, and Evergreen Road, this unthinned stand burned pretty hot. This would have been a good one where merchantable logs could be traded for small tree removal and biomass. Notice the lack of organic matter in the soil.

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Sometimes people say there is no proof that thinning mitigates fire behavior. It’s pretty clear to me that this stand was too dense and primed for a devastating crown fire. I’m guessing that its proximity to Yosemite National Park and Camp Mather, as well as the views from Evergreen Road have made this area into a “Park buffer”. Now, it becomes a “scenic burn zone”, for at least the next few decades.

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There is some private land along Evergreen Road, which seem to have done OK, at least in this view. Those mountains are within Yosemite National Park. Sadly, the media likes to talk about “reduced burn intensities, due to different management techniques”, within Yosemite National Park. Only a very tiny percentage of the National Park lands within the Rim Fire have had ANY kind of management. Much of the southeastern boundary of the fire butts up against the Big Meadow Fire, generally along the Tioga Pass Road (Highway 120). Additionally, much of the burned Yosemite lands are higher in elevation, as well as having larger trees with thicker bark. You can also see that there will be no lack of snags for the blackbacked woodpecker. Can anyone say, with scientific sincerity, that over-providing six years of BBW habitat will result in a significant bump in birds populations? The question is really a moot point, since the Yosemite acreage, alone, does just that.

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People have, and will continue to compare the Yosemite portion of the Rim Fire to the Stanislaus National Forest portion, pointing at management techniques and burn intensities. IMHO, very little of those comparisons are really valid. Apples versus oranges. Most of the Forest Service portion of the fire is re-burn, and there is no valid Yosemite comparison (other than the 2007 Big Meadow Fire). It has been a few months since I have been up there, and I expect that there are plenty of bark beetles flying, and the trees around here have no defense against them, with this persistent drought. Everything is in motion and “whatever happens” is happening.

Power Fire 2014

We’ve seen pictures of the Power Fire, on the Eldorado National Forest, before. I worked on salvage sales until Chad Hanson won in the Ninth Circuit Court, with issues about the black-backed woodpecker. The court decided that the issue needed more analysis, as well as deciding that the Forest Service’s brand new mortality guidelines were “confusing”. From these pictures, it is very clear to see that those mortality guidelines were way more conservative than they maybe should have been.

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As you can see, in this finished unit(s), there were ample snags available for birds to use, despite multiple cuttings, due to the increased bark beetle activity, during the logging. No one can say that they didn’t leave enough snags, (other than the Appeals Court). These pictures are very recent, shot last month.

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This picture amused me, as I put this sign up back in 2005. Plastic signs last much longer than the old cardboard ones.

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Here is another view of the area, chock full of snags, well beyond what the salvage plans asked for, to devote to woodpeckers and other organisms that use snags. People like Chad Hanson want more high-intensity wildfires, and more dead old growth. It is no wonder that the Sierra Club decided he was too radical, even for them.

Edit: Here is the link to a previous posting from almost 2 years ago, with pictures. https://forestpolicypub.com/2012/05/28/the-power-fire-six-years-later/

Aerial view of the 1987 Complex Fire Salvage

I took this shot while flying with a Forest Service buddy in 1989.

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I am pretty sure that this is Forest Service land, near the Groveland Ranger District office. When I worked there in 1990, the Timber Management Officer was still angry at the less-than-aggressive post-fire salvage efforts that allowed so many “brain dead” trees to die and add to the fuel loading. I’m sure that all those dead trees had some green needles on them as salvage logging was proceeding. As you can clearly see in the photo, there are PLENTY of snags left in this HUGE wildfire zone. This isn’t even where the fire burned hot. The subsequent bark beetle bloom spread northward, chewing up forests more than 100 miles away. On the Eldorado, our Ranger District harvested 300 million board feet, between 1989 and 1992, of dead and dying timber from the severe bark beetle infestation. We were lucky, able to slide our EIS into place before the litigators could gather their case together. The Tahoe National Forest was too slow, and lost 2 years worth of salvage logging opportunities, turning merchantable dead trees into future wildfire fuels.

The Lake Tahoe Basin Management Unit was also hard hit, and slow to react. Here is a 1990 view of the north end of the Lake Tahoe Basin. My first two summers in the Forest Service were spent at the top of that mountain as the Martis Peak fire lookout. Of course, there are a LOT more dying trees up there than just the brown trees. So many of those trees became unmerchantable before they could be salvaged, as the public and eco-groups hoped that “nature” would take care of the problem. Since fire suppression in the Tahoe Basin is ensured, most of those dead trees are now horizontal, and perfectly preserved as fuels for the next big, destructive, erosion-causing, lake-polluting disaster.

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Democrats Comment Against Forest Thinning

Here is an early July LA Times article that, apparently, says that only Republicans are seeking to thin our forests, as we watch our forests burn. Clearly, this is a tactic to rile up their mostly Democratic readers.

http://www.latimes.com/news/nation/nationnow/la-na-nn-gop-fire-hearings-20130703,0,2185679.story

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Yes, it did rile them up, as evidenced by the wild comments. Here are a few examples:

As a logger in Susanville, California said at a Forest Service public comment session (1997), “But Trees are Dying in the Fiorest”!!!! (and therefore NOT making a profit for him).

My response, People are dying in the streets, so what is YOUR point.

The aLand Raping Logger coundn’t answer, because the only thing he cared about was turning a PUBLIC RESOURCE into his own private profit.

Dead trees in a dorest serve as nesting sites for birds and other animals and eventually fall to rot, providing food foe grub eating bears, light spaces for juvenile trees to start and replenishing the forest soil, for the next generation of trees.

When a person dies, what good do they do the Planet?

This commenter doesn’t realize that clearcuts have been banned in the Sierra Nevada for over 20 years.

The logging companies will only clear cut…not select cut, making for the ugliest scars and worse…ecological destruction of forest habitats.  This is not a good idea.  The problem is not the density of trees…it’s the residential areas built near thick forests.  Bad planning is a result of homes destroyed in forest fires.

Ummm, I think it is the wildfires that are causing “deforestation”, bud!

Is that what the GOP is calling deforestation for profit these days, as they bend over for their lumbering lobbyists?

Was this supposed excessive harvesting done in THIS millennium??!?

They have a point, but the GOP has a history of letting “thinning” evolve into excessive “harvesting” by lumber companies.

This person is in denial about current forest management practices that have eliminated high-grading AND clearcutting, while reducing fuels in the form of trees in the 10″-18″ dbh size class. The last 20 years of active management has not resulted in adverse effects. On the other hand, wildfires lead to MORE insects, as they kill the fire-adapted pines, through a combination of cambium kill and bark beetle blooms.

Much of the GOP have forest management/preservation for the past 40 years. While some may see forests as natural resources to be preserved and cherished, others see them as purely economic resources to be exploited. Timber interests in California have utilized the same pretext to no avail. Note that thinning the forests would have little effect in preventing or curtailing wild fires. Let nature take its course becasue fires are a natural occurance; and are necessary for killing insects, spreading new seeds and burning away dead wood.

Really, though, THIS is a big part of what we are up against. Loud-mouthed partisan politics, not based in fact, is harming our ability to do what is right for the “greatest good”. Shouldn’t we be “thinking globally and acting locally”, regarding forests? Is this mindset fitting into “If you are not part of the solution, then you are a part of the problem”?? It looks like commenters will say ANYTHING to bash the GOP, even if it is hyperbole and rhetoric. Sadly, this ignorance of forest facts continues to have a harmful and hazardous effect on our forests.