What Should Plans Do?

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

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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.)

 

Nez Perce-Clearwater plan revision alternatives

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On a recent thread about getting land management decision “right,” I criticized an agency strategy of not identifying a preferred alternative in a draft EIS , using an example from BLM travel planning.  I said I was seeing more or this in land management planning, and here is an example from the Nez Perce-Clearwater forest plan revision.

A preferred alternative is not identified in the DEIS. Any individual component of any alternative analyzed in the DEIS may be combined into a preferred alternative. A preferred alternative will be identified with the release of the Final Environmental Impact Statement and Draft Record of Decision in 2021.

The link is to the DEIS Executive Summary, and here is their range of alternatives:

Four action alternatives were developed based on internal and external input, including collaboration on alternative development. All alternatives analyzed in the draft environmental impact statement met a minimum bar of being ecologically, socially, and economically sustainable per the 2012 planning rule. Furthermore, each alternative contributes to rural prosperity and other Department of Agriculture Strategic Goals. Alternative themes and the thought process behind their development are described below:

Alternative W

Resources and land allocation on the Nez Perce-Clearwater are not mutually exclusive. It may be possible to have high levels of timber harvest; sustain rural economies; recover fish and wildlife species listed within the Endangered Species Act; provide clean air and clean water; and provide habitat for viable populations of wildlife species all at the same time. For instance, areas evaluated for recommended wilderness are independent from most areas that provide for timber harvest due to the Idaho Roadless Rule. As such, it is possible to recommend all or nearly all Idaho Roadless Rule areas for recommended wilderness and have a very high level of timber outputs. Alternative W is a “have it most” alternative. The intent is to couple items that may otherwise be viewed as being mutually exclusive. This alternative has higher levels of recommended wilderness coupled with a higher timber output and a faster rate of movement towards forest vegetation desired conditions. Forest vegetation desired conditions would be minimally met within thirty years. Areas not selected as recommended wilderness allow for motorized use, including within Idaho Roadless Rule areas. Wild and Scenic Rivers found suitable stem from a collaborative approach that looks at rivers outside the wilderness.

Alternative X

Alternative X responds to a number of state and local plans, which call for few or no areas of recommended wilderness fewer or no suitable wild and scenic rivers and higher timber outputs. In this alternative zero areas are recommended as wilderness. The Comprehensive Water Plan is used as a surrogate to continue to protect key tributaries to the North and South Fork Clearwater Rivers while not pursuing Wild and Scenic River Suitable status on any river. Forest vegetation would be within the lower bound of the desired conditions within twenty years. Alternative X has the highest timber output, including a departure from the Sustained Yield Limit (SYL) for a period of two decades at 241-261 million board feet annually.

Alternative Y

Alternative Y provides for intermediate level of recommended wilderness and moves towards forest vegetative desired conditions in fifty years. Historic snowmobiling areas in the Great Burn are removed from consideration as recommended wilderness resulting in a boundary change, but within the areas moving forward as recommended wilderness we do not authorize any uses that may preclude designation as wilderness in the future. This alternative also looks at the major rivers not designated in the Wild and Scenic Rivers Act as suitable for inclusion in the Wild and Scenic River system. The major rivers not designated include the North Fork Clearwater and South Fork Clearwater.

Alternative Z

Alternative Z responds to requests to have an alternative in which natural processes dominate over anthropogenic influence. In this alternative a proposal for recommended wilderness that was brought forward by a group of national and state wilderness advocacy groups was mostly carried forward. Additionally, rivers were viewed as part of a larger system and major tributaries to the Nez PerceClearwater’s largest rivers will be analyzed as being suitable for inclusion in the wild and scenic rivers system. Areas in Idaho Roadless Rule Areas will not be opened up for additional motorized use and most current motorized use would not be impacted. Reliance on natural process would warrant a slower movement towards forest vegetation desired conditions within an anticipated one-hundred-years or longer. Timber outputs would also be lower and near a lower threshold needed to provide for economic sustainability and sustain rural economies. Additional plan components related to snag guidelines, live tree retention, fisher habitat, and elk security are included that limit uncertainty regarding how and where these features will be located on the landscape.

According to the forest supervisor in this article, “Emphasized in this planning process is the alternatives were put together as building blocks, Probert said, so pieces could potentially be mixed and matched to provide better combinations.”

My question is does it facilitate public comments, or more generally facilitate the process, to not identify a preferred alternative? This range of alternatives seems reasonable.  It is based primarily on varying how “designated areas” would be identified and recommended (wilderness and wild and scenic rivers) and managed (inventoried roadless areas, including addressing motorized and mechanized recreation), and how actively or passively the vegetation would be managed.  I’ve suggested something along these lines, and maybe if all the alternatives are truly reasonable and focused on the most relevant issues, it would be possible for an agency to not have a preferred alternative.   But is it a problem that the final preferred alternative doesn’t look much like any of the alternatives offered for public comments?  Still, I’m skeptical that the Nez Perce-Clearwater doesn’t care, and if they do, the law requires that they tell the public.

150,000 acre “project” on the Bitterroot

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Well, not exactly, maybe.  This could be a good example of how to get the public involved early enough in the process for timber harvest decisions that the locations have not been determined yet.  But consider that the decision-maker is the same one who applied “condition-based” NEPA analysis to the Prince of Wales area of the Tongass, which has ended up in court.

Bitterroot National Forest Supervisor Matt Anderson has added a new “pre-pre-scoping” stage to the process, not part of the traditional process in which a set of options is presented to the public for review and analysis.

The new approach is meant to get the public involved prior to coming up with any specific actions being planned for any specific location.

That much I like the sound of.

“There is confusion,” said Anderson. “It’s hard for the public to get involved. We are asking ‘What do you want to see? What’s your vision?’” He said the agency was “starting at the foundational level, not any particular location.” He said it was important to get to those particulars but the way there was to first describe the “desired future condition that we want and then look at the various ways we can achieve it.”

Asked about the fact that the current Forest Plan describes a desired future condition for the Bitterroot Front that involves returning it to primarily a Ponderosa pine habitat with little understory, Anderson said that is in the current plan, but that the plan is about 30 years old. He said a lot has changed in that time on the ground. There have been lots of fires and areas where no fires have occurred, and the fuel load has gotten extremely high. He said current conditions need to be assessed and they were currently compiling all the maps and other information they need to get an accurate picture of what is on the ground today in the project area.

This should raise a concern about how this process relates to forest planning, since forest plans are where decisions about desired conditions are made.  However, old forest plans typically didn’t provide desired conditions that are specific enough for projects, so that step has occurred at the project level.  Under the 2012 planning rule, specific desired conditions are a requirement for forest plans, but the Bitterroot National Forest is not yet revising its plan. Whatever desired conditions they come up with should be intended as part of the forest plan, and the public should be made aware of this.  If the new decision is not consistent with “Ponderosa pine habitat with little understory,” they’ll need an amendment to be consistent with the current plan.  (I’d add that changes in the on-the-ground conditions over the last 30 years shouldn’t necessarily influence the long-term desired condition.)

“The Tongass is so different than the Bitterroot,” said Anderson. “There is not much similarity. I’m not trying to replicate that process here. It was a conditioned-based process up there. It’s like comparing apples to oranges.” In reference to conditioned-based projects, he said, “One difference with this project is that some of that will be pre-decision and some of that will be in implementation. We are trying to shift some of the workload to the implementation stage.”

He said they have a slew of options, from traditional NEPA, to programmatic NEPA to condition-based NEPA “and we are trying to figure it out.”

He insists that the NEPA process will be followed with the same chance for public comment and involvement on every specific project that is proposed in the area.

There’s some ambiguous and possibly inconsistent statements there.  Condition-based NEPA seeks to avoid a NEPA process “on every specific project.”  I could also interpret shifting workload to “pre-decision” and  “the implementation stage” is a way to take things out of the NEPA realm.

And then there’s this:

In response to the notion that the huge project is being driven by timber targets and not health prescriptions, Anderson said that the Regional Office had set some timber targets for different areas of the region, but that those targets were not driving the analysis. “This project has nothing to do with meeting any target,” said Anderson.

This feels a little like “There was no quid pro quo.”  Would timber harvested from this project not count towards the targets?  (I’d like to see  targets for achieving desired conditions.) All in all this project would be worth keeping an eye on.

(By the way, here’s the latest on Prince of Wales.)

Recovery planning for the Gunnison sage-grouse

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The U. S. Fish and Wildlife Service has released a draft recovery plan for the Gunnison sage-grouse in Colorado and Utah.  The Center for Biodiversity doesn’t like it, but more to the point, they like less how the BLM is managing Gunnison sage-grouse.  More to the point because recovery plans are not mandatory, while federal land management plans can be – and plan components must be mandatory to be considered “regulatory” enough to carry much weight in ESA listing and delisting decisions.  As the FWS said, “Establishing durable regulatory mechanisms that are binding and enforceable, such as revised land use planning amendments, will be important for recovery.”

CBD:

The recovery plan comes on the heels of BLM decisions not to designate any Areas of Critical Environmental Concern for Gunnison sage-grouse in the Tres Rios and Uncompahgre Resource management plans, and to adopt inadequate safeguards for the birds’ habitat in recent land-use plans. For example, although the draft recovery plan calls on federal land-management agencies to improve their resource management plans and protect suitable habitat within four miles of breeding sites, the BLM’s August 2019 proposed resource plan for its Uncompahgre Field Office protects only habitats within 0.6 miles of breeding sites. The BLM admits this would “fall short of minimum protection standards to maintain sage-grouse viability.”

“Bringing the Gunnison sage-grouse back from the brink requires decisive and concerted action, but instead we have two federal agencies working against each other,” said Michael Saul, a senior attorney at the Center for Biological Diversity. “The Fish and Wildlife Service is urging federal land managers to improve protections for public-land habitat, but the BLM is moving in the opposite direction. This is a recipe for extinction for this beautiful bird. We’ll do everything possible to keep that from happening.”

The timing is also such that BLM plans were released prior to the draft recovery plan.  That means that the BLM should start taking another look at how their plans address this species and take into account the new information and recommended measures.  The same is true for the 10% of sage-grouse habitat that occurs on national forest lands. BLM is not subject to NFMA, so its obligation to maintain species viability to avoid listing under ESA is not as clear as for the Forest Service.  Forest Service plans must “contribute to recovery” of listed species, so failure to address elements of this recovery plan when it is final should raise serious questions.

In addition to specific conservation measures like the four-mile buffers for breeding leks, the draft recovery plan provides some specific desired conditions that could be included in land management plans:

2. Regulatory mechanisms or other conservation plans or programs, such as land-use management plans, reduce and ameliorate threats associated with habitat loss and degradation in all populations, such that:

A. Habitat in Dove Creek is improved and maintained at a quantity calculated to support a HMC of 30, although this criterion is not measured by achieving the target HMC.

B. Habitat in CSCSM is maintained at a quantity calculated to support a HMC of 7, although this criterion is not measured by achieving the target HMC.

C. Habitat is improved and maintained in Gunnison Basin, San Miguel, Piñon Mesa, Crawford, and Monticello at a quantity calculated to support the target HMCs as listed in Table 1.

At a minimum, the land management agencies will need to explain how these plans contribute to meeting their requirements under ESA to manage their programs to promote recovery of listed species, which should include how they are implementing the final recovery plan.

Forest planning for “sustainable” recreation

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A former Forest Service backcountry specialist talks about ecological integrity and increasing human recreation activities, and tries to answer the question of “what is sustainable recreation?”  The 2012 Planning Rule requires plan components “to provide for: (i) Sustainable recreation; including recreation settings, opportunities, and access; and scenic character.”

What is “Sustainable Recreation”? The Forest Service defines it as “the set of recreation settings and opportunities in the National Forest System that is ecologically, economically, and socially sustainable for present and future generations.”

Here’s how it’s done:

The Recreation Opportunity Spectrum can be used in forest planning to define a desired condition for management within each zone. Indicators and standards are meant to define the tipping point beyond which management action must be taken.
 If the standard for a backcountry area (called “semi-primitive non-motorized” in ROS jargon) is that no more than six other parties are encountered on a typical day, when the encounter rate exceeds that number some action is supposed to take place to return to the desired condition.
It’s a neat framework, but doesn’t always play out as intended on the ground. ROS doesn’t differentiate between a semi-primitive area in the back yard of a town like Jackson or Bozeman and one that’s two hours away.
That seems like a major shortcoming, especially if all areas with a SPNM designation must have the same desired level of semi-primitive non-motorized use.  However, the Planning Handbook encourages “new approaches,” including creating “desired recreation opportunity spectrum subclasses” §(23.23a).
The usual sequence of remedial actions begins with non-intrusive measures like visitor education. If the problem isn’t solved, additional actions are considered.
The Bridger-Teton forest plan is typical in its prescribed sequence of actions, this excerpt taken from its direction on wilderness. The following recreational strategies should be used, listed in descending order of preference:
First Action – Efforts are directed towards information and education programs and correction of visible resource damage.
Second Action – If the first action is unsuccessful, restrict activities by regulation (for example, set a minimum distance between a lakeshore and where people can camp).
Third Action – If the first and second actions fail, restrict numbers of visitors.
Fourth Action – If first, second, and third actions are not successful, a zone can be closed to all recreation use until the area is rehabilitated and restored to natural conditions.
In my experience, outside of designated wilderness and other special areas where specific laws apply, the Forest Service keeps circling around the first action, which isn’t a bad strategy given the continuing need for it in communities where resident turnover is high.  It’s an ongoing need regardless of the often unmet requirement to step up restrictions. But restrictions trigger blowback, as when the Shasta-Trinity National Forest tried to set encounter limits for the wilderness that includes Mt. Shasta.
People basically said they don’t care if it’s crowded—they just want to reach the summit, and a judge agreed with them. On the other hand, those who float the Selway River are happy to wait until they get a launch day shared by no one else. Since everyone is going the same direction at about the same speed, everyone can experience a bit of peace and quiet. So the application of sustainable recreation standards depends on who is using the forest and what they will accept.
And those are the questions that forest planning should be designed to answer.  (Note:  the Bridger-Teton plan has not been revised, so may not be the current state-of-the-art.  Also, I couldn’t find the court case referred to.)  And this must be done against the backdrop of a requirement for ecological integrity.
User-built trails and roads are often the opposite of sustainable. They develop incrementally and aren’t designed with soil type, grades and curve radii in mind, or the needs of resident wildlife. The trail system after adoption by the Forest Service usually gets reworked so it doesn’t turn into deep ruts or wash into the creek, but where is the analysis that determines that the trail location is right in the first place?  The trail itself becomes more sustainable, but where do the grouse and elk and owls go?
The adoption of forest plan of components for desired recreational use has effects that must be evaluated during the NEPA process, but rarely does the Forest Service devote much attention to this.
The author describes a common fallacious argument that the Forest Service likes to make about sustainability to avoid controversy:
While the planning rule makes clear that ecological integrity underlies compatible uses in a national forest, the ecological, economical, and social sustainability have since been referred to as a three-legged stool, with all three legs of equal importance.
But if you parse the actual language of the Planning Rule, it is apparent that the ecological leg needs to support more weight (driven by the substantive diversity requirement of NFMA) (my emphasis).
“Plans will guide management of NFS lands so that they ARE ecologically sustainable and CONTRIBUTE TO social and economic sustainability; CONSIST OF ecosystems and watersheds with ecological integrity and diverse plant and animal communities; and HAVE THE CAPACITY TO PROVIDE people and communities with ecosystem services and multiple uses that provide a range of social, economic, and ecological benefits for the present and into the future.

Forest planning for wildlife corridors

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The 2012 Planning Rule requires that forest plan revisions address wildlife habitat connectivity. In fact it is one of the “dominant ecological characteristics” that must occur with the “natural range of variation” in order to meet the substantive regulatory requirement for “ecological integrity” and the NFMA statutory requirement for “plant and animal diversity.” The Rio Grande National Forest doesn’t seem to want to take this seriously in its revised forest plan, as recounted here:

“At the federal level, New Mexico Sen. Tom Udall and others have proposed a Wildlife Corridors Conservation Act to create more tools for protecting migration routes. Our neighbors in New Mexico passed a state wildlife corridors act earlier this year. Colorado Parks and Wildlife has emphasized the need to ratchet up awareness and protection of corridors. And even former Interior Secretary Ryan Zinke issued an order to conserve big-game migration corridors and winter range.

“Hence, with all of this activity agitating for increased concern and elevated action to protect wildlife corridors, the new management plan just announced by the Rio Grande National Forest is astonishingly tone deaf. Our national forest neighbors to the east finalized their long-awaited 20-year vision and ignored widespread calls for action to elevate wildlife corridors.

“It’s a disappointing example of compartmentalization taken to the extreme. Immediately adjacent across the state line in New Mexico, the Carson National Forest unveiled its draft plan and highlighted extraordinary wildlife values there around San Antonio Mountain with a dedicated Wildlife Management Area.  But it’s as though an administrative wall exists at the state line.”

“Having the Interior Department and state wildlife agencies and elected officials and some national forests all calling for action to protect wildlife corridors isn’t enough if one critical player, like the Rio Grande National Forest, is missing in action.”

It only takes one bad actor to ruin a wildlife corridor. That is a reason why connectivity was given such a high profile in national forest planning for diversity (I was there). The Rio Grand is currently taking objections to its final revised plan, which will be reviewed by someone at the regional level to determine if the Forest is meeting its connectivity/diversity obligations.  However, this is a cross-regional problem (Region 2 and Region 3), which is why the national office of the Forest Service needs to look at why forests in two regions can’t get their acts together on what conditions are needed for connectivity.

Maybe they should also take a look at a recent example in Region 4. This is a case where a state-recognized wildlife corridor led to changes in a trail project on the Bridger-Teton National Forest.

“The now-scrapped trail could have interfered specifically with the Red Desert-to-Hoback mule deer migration corridor, which was the first route designated by the state of Wyoming. An estimated 4,000 to 5,000 deer pass through the narrow bottleneck at the Fremont Lake outflow, according to a 2016 assessment of the migration path.”

‘The “desired future conditions” — a U.S. Forest Service equivalent for zoning — for where the trail would have gone are “developed and administrative sites” and “special use/recreation.” Those classifications would have allowed for new trails, and the Bridger-Teton’s forest plan easily predates the discovery of the migration route, which wasn’t until 2013. Outside of those processes, the forest sought input before proceeding with the plans.”

It’s great that the project decision is considering this new information and the new state designation.  I hope the Forest also recognizes the implications for any future projects in this area where it looks like they have decided that the desired condition is now something else.  The discovery of the migration route should have led to another look at the forest plan desired condition, and a plan amendment if they are deciding that it is no longer appropriate based on this new information.

 

 

 

 

Forest Plan Participation 101

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Adam Romanowitz, Photographer

Some tips from a participant in the Manti-LaSal forest plan revision process, which includes developing a “conservation alternative” that “will emphasize the long term health of the forest.”

I’m afraid I’m pretty cynical about the payoff from this approach, but I’d be interested in stories from anyone who feels they had some success.  Part of the problem comes from the fact that the Forest Service creates its own structure for the alternatives it develops (such as the choice of management areas, what the different kinds of plan components should look like, how the plan document will be organized), and an outside alternative that doesn’t line up with this would be difficult for the planning team to document and evaluate.  Then of course there is the, “I am the professional” bias that resists outside ideas, the “don’t take away my power” bias that resists any actual obligations (standards) in the plan, and the “no-change” inertia bias that defines “reasonable alternatives” as those that aren’t much different from the current plan.  At best, it seems like there might be a few surprises that the Forest Service actually likes and tries to use.  Tell me I’m wrong.

It looks like Mary is already encountering some bias:

For instance, the Moab Sun News’ article on the public meeting reported that forest service grazing manager Tina Marian said people won’t see a lot of grazing changes in the new plan that aren’t already being implemented on the ground. She shouldn’t predetermine that outcome. The conservation alternative will recommend changes to how grazing is implemented in the forest (which is a part of Moab’s watershed), like reducing the rate of cattle grazing.

It’s not possible to tell where exactly the Manti-LaSal is in the revision process from their website, but there was a comment period on the “Draft Assessment Report” in June of 2017.  I think the best time to influence alternatives is probably when the Forest must “Review relevant information from the assessment and monitoring to identify a preliminary need to change the existing plan and to inform the development  of plan components and other plan content” (36 CFR §219.7(c)(2)(i)).  Any reasonable alternative would have to be traced back to that information, and if there are disagreements at that point it’s not likely that later suggestions would be well received.

In the example above, what did the assessment say about the effects of cattle grazing? The Forest seems to take the position that “historic” grazing was a problem, but “… (C)urrent grazing practices are not having as large an effect on stream stability, as evidenced by the many greenline transects rated as stable in 2016.”  But then there’s this proof of bias in the Assessment (I’m not familiar with these “directives,” and unfortunately, “Shamo” isn’t in the “Literature Cited”):

Livestock grazing has occurred on the Forest for over 150 years and will continue as part of the Forest’s directives to provide a sustained yield and support local communities (Shamo 2014, USFS 2014).

They’ve got some other interesting issues on the Manti-LaSal:

The alternative will ensure that pinyon and juniper communities are not removed on thousands of acres for the purposes of growing grass for cattle and artificial populations of elk.

It will require the forest to remove the non-native mountain goats that are tearing up the rare alpine area above 11,000 feet in the Manti-La Sal Mountains. It will not allow honeybee apiaries, which would devastate native bees.

And that’s where part of the Bears Ears National Monument is/was.  There was a lawsuit on the goats, and there are several on Bears Ears. 

 

 

BLM land management plans maybe prevent species listing

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At least that is what I think happened, but because of the government shutdown, I can’t confirm the details.

The Trump Administration has declined to extend federal protections for two plants native to the Mountain West.

Julie Reeves, plant and wildlife biologist with the service, said the plants didn’t make the cut because another federal agency, the Bureau of Land Management, prohibits energy development and other potentially damaging activities near their habitats.

“Those (threats) are not going to rise to the level of high magnitude that could affect the species because of protections put in place by the BLM,” she said.

A good idea for Forest Service plans regardless.

Pacific northwest collaboratives

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This article is about the fact that the Malheur National Forest hasn’t had a lawsuit in 15 years.

Hannibal said “three to four times the amount of work” is getting done nowadays compared to 15 years ago. Timber sales data from the Malheur National Forest tell a similar story. From 2010 to 2016, the volume of timber cut from the forest more than doubled. The collaboration and a 10-year stewardship contract gets credit for saving the last sawmill in Grant County, Oregon, too.

It also links to the “Collaborative Directory” for the Pacific Northwest Region.

Every national forest in the Pacific Northwest has now aligned with at least one outside “collaborative,” as they are called. The idea is to build trust and get compromises done at the front end of proposed timber sales, thinnings or controlled burns. That way, the work doesn’t get bogged down in litigation or analysis paralysis later.

A Forest Service directory lists 36 collaboratives associated with the 16 national forests in Oregon and Washington state. Some are more successful than others. Brown said the greater presence of endangered species west of the Cascades complicates the work of the groups active in wet-side forests.

It’s interesting to see how many groups are working where, but I just want to highlight that last point.  It suggests to me that addressing at-risk species is the key to successful projects, and that forest plans can and should provide the framework for doing so.  It would be nice to see revised forest plans treat this as an important issue and consider alternative approaches in that context.  On the other hand, there are no references to any forest plans or forest planning (as opposed to project plans and planning) in this document.  What am I missing?

Forest Service promotes wildlife overpass

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Despite a national effort (see pp. 29-30) to encourage it, and requirements in the 2012 Planning Rule to provide wildlife habitat connectivity, the Forest Service doesn’t seem to like to assert itself much in cross-boundary planning for such connectivity.  Here is a big exception, which should be an example of what can be done – and what should be done where the Forest Service is responsible for improving conditions for at-risk species.

By revamping the highway with wildlife’s needs in mind, officials were able to broker an easement with the U.S. Forest Service to add the additional lanes.

“It’s a win-win. We could improve transportation. We did lose some national forest,” said Garvey-Darda referring to construction of additional highway lanes. “But we can connect the North Cascades and the South Cascades.”

More importantly, I was told that the forest plan provided the basis for the Forest Service position in the negotiations that the North Cascades and South Cascades should be connected.  I can’t find language in the current plan that would clearly address this, but I know the plan revision process was moving towards useful language for connectivity.  Other revised plans are including language that at least provides some intent to participate in highway planning.  This is from the recently revised Kootenai National Forest Plan:

FW-DC-WL-17. Forest management contributes to wildlife movement within and between national
forest parcels. Movement between those parcels separated by other ownerships is facilitated by
management of the NFS portions of linkage areas identified through interagency coordination.
Federal ownership is consolidated at these approach areas to highway and road crossings to facilitate wildlife movement.

This would at least tell a Forest it needs to be a player and give them some leverage.  However, for at-risk species its role is to be a leader, and with nothing more than a desired condition and without identifying any linkage areas in the plan this would not meet any substantive requirements of ESA or NFMA (recovery or viability).  (Similar language in the uniform plan amendment for lynx does apply to mapped linkage areas.)