States, Feds, Community, Homeowner Responsibilities and Funding: Comparing Some Colorado and California Approaches

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A U.S. Forest Service staff member points to a patch of forest where the trees were removed to thin the amount of vegetation. The area in the background was clear-cut as a break to help slow fires. Kevin Moloney/Getty Images This photo is from the Cheng /Thompson piece mentioned at the end of this post. I wanted to highlight the clearcut photo given our ongoing discussions.

 

A few things came to mind when I saw this Colorado Public Radio story..

  1. What originally struck me was this statement :

Like many people working the issue in Colorado, McCombs and others praise their local federal partners. But if there’s another ask right now of Congress, it would be to ensure there is  adequate and qualified federal staff to help get their mitigation projects off the ground.

Pinnow, of the West Region Wildfire Council, said one project they’re working on that’s funded by the federal government requires an archaeological survey.

“Right now, the U.S. Forest Service in this area has no archeologist. And so those projects have been on the shelf and just waiting for more than nine months,” he said. “We borrowed a BLM archeologist to actually approve it on the federal level, but the U.S. Forest Service still has to sign off because that’s where the money came from. They don’t have anyone to even sign off.”

I understand the archeologist issue (if you listen to Chris French,  the point is to redirect positions to the field), but no one to sign off?  That sounds a little odd to me.  Seems like authorities could be delegated. even if there are some people missing. How long does it take to write a delegation of authority? There must be more to the story, so I have a call in to the RO.  I wonder why the reporter didn’t follow up on this.

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In addition, I found this interesting…

2. Given the return on investment, Tim Pinnow, CEO of the West Region Wildfire Council, whose mission is to build wildfire resilient communities in six Western Slope counties, would like to see more funding and focus on hardening homes.

“There’s almost no money anywhere for the home hardening piece, which is actually in terms of saving homes, the most important.”

Grant funding could be used for home hardening, fuel reduction programs — like removing beetle kill — and prescribed burns. Many groups and local governments have shovel-ready projects ready to go if and when funding comes through.

I always like to compare California and Colorado, as they are both D led states and so we can see the issues more clearly without the partisan blinkers.

In California, as I have pointed out, they have a loan program for home hardening and helping people find contractors.  They seem to see it as a state issue.  There are also some that resent their electric and insurance bills going up because “people choose to live in dangerous places.”

In July you might have seen this piece on insurance..

That’s still too much, according to Michael Wara, director of the climate and energy policy program at Stanford University, noting the cap is four times the median California home value.

Wara said one way to limit FAIR’s exposure risk is to exclude second homes from the plan and force those homeowners to seek coverage from lightly-regulated insurers in what is known as the “non-admitted” market, which has been expanding as climate change makes properties increasingly uninsurable.

“If you can afford to have a house in Tahoe, then you should not be reliant on what is essentially a subsidy from the rest of the state for your homeowner’s insurance,” he said.

I like the California home hardening and leveraged loan programs, imagined and supported by our friends at Megafire Action.

And if we follow Wara’s logic,  why should taxpayers pay for home hardening or local prescribed burning projects? Yes, the feds own land and have to pay for work on their land.   I just think it’s a broader question.. who pays for hurricane and earthquake improvements in homes?  Should the owner/insurance/county/state/fed split be the same for every kind of protection?

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The article indeed cites a report by Megafire Action but quotes folks that go directly to .. the feds.

A recent study found that for every dollar spent on removing fuels can save up to $7 on the suppression and recovery end. And every $1 invested by the government to harden homes can save $3 in recovery efforts.

Given the return on investment, Tim Pinnow, CEO of the West Region Wildfire Council, whose mission is to build wildfire resilient communities in six Western Slope counties, would like to see more funding and focus on hardening homes.

“There’s almost no money anywhere for the home hardening piece, which is actually in terms of saving homes, the most important.”

Grant funding could be used for home hardening, fuel reduction programs — like removing beetle kill — and prescribed burns. Many groups and local governments have shovel-ready projects ready to go if and when funding comes through.

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Two Rivers Executive Director Rizza agreed funding is key, but so is streamlining the process and providing consistency when it comes to grants and laws. “How the stuff is written, how it’s delivered, how it comes out of these programs. One year it says this, the next year it’s the complete opposite.”

Matt McCombs, Colorado’s state forester, pointed out there’s one funding program in particular he’d like to see renewed.

“Community Wildfire Defense Grant was a program that came out of the bipartisan infrastructure law,” he explained. “That has pumped $50 million into wildfire risk reduction and community resilience in the state of Colorado since its inception.”

He said that funding often goes to places that might not be able to afford to undertake mitigation work on their own. “That’s another great example of where those big federal investments, in leverage with state investments and community-based investments, start to get to the type and the quality and the intensity of the work that we know is necessary to try to respond to not what’s coming, but what’s here.”

He’d also like to see a program renewed and strengthened that allows state and local governments to continue to working with federal partners. It’s called the Good Neighbor Authority, and a number of lawmakers have agreed to introduce bills that do just that.

“The Good Neighbor Authority was invented in Colorado. We are hardwired for collaboration in a state. So let’s keep leaning into doing the most work in the highest risk places as fast as we can because of the speed and intensity of the problem that we’re facing,” he said.

I’ll also contact McCombs and find out his ideas for improving GNA.

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Finally, a few people have sent me this piece. I am a big fan of the folks at CFRI, but I don’t see the three distinct camps they see.. 1. Put ignitions out quickly, 2. manage vegetation through fuel reduction and prescribed fire, and 3.

A third camp says fire is coming regardless, and people have to live with it by accepting and promoting more fire, but allowing it to burn on our terms, when and where it’s safe. This is often called managed wildfire. It sometimes includes creating landscapes and communities that can survive and recover from fire.

I see “prefer prescribed to so-called managed wildfire to reduce fuels” “treat fuels using mechanical treatments” and “home and community hardening.”  I see the home hardening business as that of communities and homeowners, and fuel treatments and PF as a shared responsibility between communities and federal land neighbors, and the role of MF itself as the only issue that remains.   There are at least three camps in the MF world, 1. No never, 2. Build trust via pre decisional NEPA and public involvement as sidebars, then yes. 3. There’s no problem. Anyway, that’s the way I see it, and I think you can also see that from the CPR article, how communities and federal and state partners are working together on community protection, mechanical treatments, and prescribed fire.

Clearcutting, FACTS, and Many Thanks to Sean!

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(see text for definitions)

I’m reposting this today because I’m surprised no one weighed in.. and other posts were published so maybe everyone didn’t see it?

If we had cash or non-cash awards on The Smokey Wire (and maybe we should), Sean would definitely deserve one for taking the time to dive into the mysterious world of FACTS.  So a major thank-you to him!

From Sean:

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Here is a little workup of the FACTS data.

I downloaded the full FACTS dataset. Caveat – FACTS (like all huge, ongoing data projects…) is messy! I am working with it here pretending like it is perfect, but we all need to know that it is not and there are plenty of places with missing or incorrectly classified data.

I first filtered to remove anything earlier than 1905 (pre-FS – you may be surprised but some records go back to the mid-1800s, Forest Reserve days presumably) and later than 2026 (the future hasn’t happened yet as far as I’m aware). Then I filtered to include status “Accomplished” and “Completed”, but not status “Planned”.

I built this spreadsheet with the full list of Activity Names and my calls on whether they count as a clearcut. I did four versions: a strict interpretation and a liberal interpretation of what a clearcut is, one for all even-aged systems (including shelterwood and seed tree, for example), and one for all even-aged and two-aged systems (including what we would call variable retention harvest today, coded in FACTS as two-aged stand clearcut with reserves). You may disagree with my calls, in which case I invite you to propose something better.

Link to “is it a clearcut?” calls:
https://docs.google.com/spreadsheets/d/1nn6j8IbTO9g5EzrcQXA2Js04FfCGYUH7?rtpof=true&usp=drive_fs

Who knows exactly what queries were done to build the tables in the post, but what I get is pretty similar.

Clearcut (strict)
2023: 29,007 acres
2024: 24,283 acres
2025: 28,733 acres

The other three definitions are not as good of a match.

Clearcut (liberal)
2023: 34,635 acres
2024: 29,705 acres
2025: 32,917 acres

All even-aged
2023: 51,846 acres
2024: 44,898 acres
2025: 52,483 acres

All even-aged and two-aged
2023: 64,144 acres
2024: 55,520 acres
2025: 64,662 acres

Link to graph over time of National trend:
https://drive.google.com/open?id=1X3tDwWlbd_uKoQRdO5-iCRaTMMz1cjBk&usp=drive_fs

Link to acres of harvest per year by each of the four definitions by National Forest:
https://docs.google.com/spreadsheets/d/1GsaHjRcXsdzbQmFVDAMhR3ZParjVtDf-?rtpof=true&usp=drive_fs

Link to the full FACTS dataset as a table (340 MB file – no GIS required, you can open it in Excel):
https://docs.google.com/spreadsheets/d/17WiGYUn5cDWuQsvZ1mdFNYhxdkEKDfi1?rtpof=true&usp=drive_fs

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From Sharon:

I’m a bit stuck at the varieties of definitions and how they could add up to meaningful numbers of any kind.  At the 30K level, there is only even-aged and uneven-aged management (or is there?), maybe we should ask a current silviculture prof? Uneven-aged in many places won’t get back intolerant species, which we would need for diversity; and tolerants by themselves are not resilient to wildfires and tend to be host to a variety of diseases and insects. At the same time, they tend to be fairly good (along with LPP) at reproducing themselves, while the intolerant may need more assistance.

Would concerns about NRV and fuels lead us instead to a different taxonomy of treatments, perhaps based on density reduction and ladder fuels? Or are our current definitions not exactly fit for current purposes, but not worth changing? How do these numbers crosswalk with fuels acres accomplished, or do they?

Meanwhile, what do you all think of the exercise of asking the same “why do you clearcut, if you do?” of all forests and seeing what the national story looks like?

 

Why the Forest Service called in the Cows when the Gold Mountain Fire was Almost Contained: Dave Marston

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he Gold Mountain fire burns north of Ouray on Tuesday, June 30, 2026. (Photo courtesy of Grant Martin)

Yes, cows eat grass, otherwise known as fine fuels.  And we should thank Sean Brown, USFS range management and wildfire expert, for arguing for and succeeding in innovative practices!

From the Denver Post by Dave Marston
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When fire commanders try to figure out how to contain a major wildfire, the last thing you might expect them to deploy is a herd of beef cattle. But on the recent Gold Mountain Fire in western Colorado, cows are eating the “fine fuels” along a three-mile fire line on the Big Cimarron River.

Putting that idea into practice five years ago would have required miles of electric fencing and a range rider to gather strays. Now, new technology has changed the game for cattle grazing by putting electronic collars — all solar-powered — on cows and linking them by satellite.

“The Halter Collar is similar to a dog collar, has a tone, vibrate and a shock,” explained Mike Higuera, agricultural manager of Western States Ranches, based in Eckert. An app on a smartphone allows range riders to draw electronic fences and track each cow by GPS.

“Gathering cattle in fall used to take four or more weeks and hundreds of person-hours, but now it’s a few days,” said Higuera.

The idea for using cows to help contain wildfire came from Sean Brown, a 23-year veteran of range management at the U.S. Forest Service, who pulls in overtime organizing logistics for major forest fires near his base in Montrose. He said he and the fire commanders realized that cattle would offer a safer way than setting a hazardous back burn to add to an “indirect” fire line, one away from direct flames.

Once Brown had permission from his bosses, he called Tyler Westhoff, Western States Ranches ranch manager. Westhoff quickly agreed to bring 350 radio-collared cows onto the fringes of the fire zone, which at that point, in mid-August, was 87% contained. Now in mid-September, the fire is 93% contained.

“Tyler flew into action,” Brown said. It turned out that Higuera and Westhoff were relieved to put cows onto their Big Cimarron federal grazing permit. “We’d been trucking water on another permit on the Uncompahgre Plateau, but this is better feed and good water,” said Higuera, who stressed that fire officials were ready to remove the cows if fire conditions turned ugly.

Brown said equipping the cows electronically gave him confidence that they could eat their way to an expanded fire line. This would reduce the burden on fire crews trying to keep the 39,000-acre fire contained until a season-ending event, typically rain or snow.

Westhoff loves what he calls the “Big Cim” grazing permit: “The top of it goes from 8,800 up to 12,000 feet. It’s northern San Juans and a prime grazing permit.” Best of all, he added, “There’s lots of grass.”

Brown took me on a Big Cim tour five days after the herd went to work. Standing in a field where tall grasses were now three inches tall, he explained that cattle are typically kept off burned permits for two years. Nature comes back, Brown said, but without constant herding, cattle can move into sensitive areas and exacerbate erosion.

“We’ll have this herd in the Cimarron Valley next year, and fire-affected areas will be excluded with a virtual fence.”

The wildfire work on the Big Cim is good news for Western States Ranches, which was having a dismal summer. The Gold Mountain Fire started near the tourist town of Ouray, quickly roared across the ranch’s Owl Creek permit outside Ridgway, and traveled 26 miles onto the ranch’s Big Cimarron permit.

“We felt like we had a target on our back,” Higuera said. “We were geared to release cattle above Ridgway, then four days later our evacuated cow camp was in flames.”

What does an electronic Halter Collar cost? The leased equipment costs $96 per cow per season. “But for sprawling operations, when you add up person-hours, diesel, and trucking water, a Halter pays for itself quickly,” Higuera said.

The collars have other uses besides wildfire work, especially for weed control. Often the first grasses to return after a burn are cheatgrass, which grows quickly in spring and then dries to become highly flammable. “But cows love it,” Westhoff said, “and on lower elevation permits, we’ve made it through a couple winters on cheatgrass.”

The ranchers said they were grateful to Brown and fire commanders for letting the cows perform. “Typically, there’s a risk aversion in the agency … but we showed we can be part of the solution,” Higuera said.

As for Brown, he said that sending in cows to expand a fire line was unique: “Never in my 23 years have I ever done something like this.”

PERC on the Roadless Rule

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The Property and Environment Research Center has a report worth a look: “The Roadless Rule and Wildfire Management:
More targeted policy could better balance costs and benefits across different landscapes.”

Highlights:

Road Access and Ignitions: Existing research on human and road access identifies competing effects. While limited access to roadless areas may make initial firefighting efforts more difficult, rescinding the Roadless Rule could lead to more ignitions. A Fire Ecology study by Aplet et al. earlier this year found that ignition density is roughly four times higher within 50 meters of roads than in inventoried roadless areas, particularly for human-caused fires.1

Community Risk: Inventoried roadless areas contain roughly 74,000 acres, or 2 percent of national forest acreage in direct-exposure zones—areas with buildings or populated land directly adjacent to flammable wildland vegetation—and 7.3 million acres, or 16 percent of acreage in broader wildfire-transmission zones, which include vegetated land within approximately 2.4 kilometers of clusters of buildings, where wildfire fuels may cause fires to spread into populated zones.

Emissions Risk: Fires igniting in roadless areas generate less fine inhalable particulate matter (PM₂.₅) in total than fires igniting in managed forests, although associated emissions per acre of roadless land are about one-third higher.

Suppression Costs and Damages: From 2010–2020, fires that ignited in inventoried roadless areas accounted for roughly 25 percent of reported suppression costs across Forest Service lands ($3.9 billion of a total of $15.6 billion). These fires were associated with approximately 1,700 reported lost properties, or about 11 percent of the nearly 16,000 total property losses reported. Suppression costs per acre of roadless land are higher than for managed forests but lower than for wilderness areas. These outcomes are assigned by ignition location, not by assessing all areas where fires eventually burned, suppression resources were used, or damages occurred

Reorganization FOIA II: FS Goals at Salt Lake City Meeting Address Concerns Expressed in 1993 National Performance Review

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Granted, not everyone is interested in blow-by-blow documentation of the reorg discussion. Still, I’m going to post pieces of this FOIA that I found interesting or informative.  I did my own redactions of folks’ names when I didn’t think they added anything.

One of the great things about elderly wisdom is the ability to detect long-term signals from short-term noise.  Many of us exposed to previous organizational improvement efforts will recognize concerns from the past in these reorganization documents.  Which is not to say that people didn’t address them then.  But organizations are like gardens, if you don’t cultivate them continuously, they will grown into a jungle of weeds.  Instead of continuous improvement, you might get continuous accretion of programs and rules, punctuated by intense focused efforts to streamline.  After all, in 1993, we remember various efforts at downsizing, streamlining, removing layers and all that:

The National Performance Review is about change–historic change–in the way the government works. The Clinton administration believes it is time for a new customer service contract with the American people, a new guarantee of effective, efficient, and responsive government. As our title makes clear, the National Performance Review is about moving from red tape to results to create a government that works better and costs less.

These are our twin missions: to make government work better and cost less. The President has already addressed the federal deficit with the largest deficit reduction package in history. The National Performance Review can reduce the deficit further, but it is not just about cutting spending. It is also about closing the trust deficit: proving to the American people that their tax dollars will be treated with respect for the hard work that earned them. We are taking action to put America’s house in order.

Note that trust, deficits, efficiency, costing less, and responsiveness were issues then…fortunately all those have been fixed (not)! Plus we have added concerns about transparency and accountability (related to trust).

Here’s the text of a letter email from Chris French to “All FS” called Thoughts and Updates.

Good morning,
I write to you this am from Salt Lake City where this week we had an agency leadership meeting at our SLC Geospatial Office. I want to take moment to thank all of the agency employees at our office for their hospitality and feedback as we descended on their workplace. It was good to see colleagues I haven’t seen in years and new folks that I met first time. I also saw first hand how our return to work has located folks together and what that means.

Our work session was focused on what we want our agency to BE as we work though our current staffing and future workforce. Chief Schultz asked us to create a shared vision for how we would become a more operationally focused agency – an agency that enables effective field work with decision making driven to lowest levels.

We met with agency leaders, forest supervisors, R&D representatives, and department leaders. We hosted open dialogues with District Rangers and agency Fire staff asking them – what needs to change and what is important to keep? In those calls we heard many operational issues including radio repeater failures, problems with our one device policy for fire fighters, and a wide set of issues from capacity and staffing losses, purchasing, or policies that just make work harder in the field. While we have taken immediate steps to address many of these concerns, the issues are wide and require us to rethink and change how we do business. This was the driver of our session and a foundation to the agency we will become.

Collectively we are committed to make your work easier to accomplish and that you have the tools, processes, and decisions to deliver our mission better than we do today. Frankly, so many of these issues, like the DR that has not been able to get a new printer for months, have been around for a long time and we have accepted that this is just the way the Forest Service works. We are committed to be a responsive agency leadership listening to you and our partners and making the changes that must be made. It will take time but we are committed.
Thank You – we so appreciate your dedication to our service –

Chris

As a long term FS veteran, the attention to a wide range of problems reminds me somewhat of Transformation, but also of the Pilots- where we worked on relatively small but annoying things, and had hope that we were able to make things better.. and did, at least in the Ochoco Pilot.  Thanks to the wonders of modern search engines, I found this classic “Transforming Organizational Structures’ from the Clinton Admin (1993)  which seemed relevant, I bolded a few.

Periodically, since the 1950’s, agencies have tried to reform their field structures. Some, such as the Social Security Administration, successfully transformed their field structures and trimmed staff while enhancing service. But most have not been as successful. For example, the Department of Veterans Affairs has tried and failed to close underused hospitals. Likewise, the Department of Agriculture has faced difficulties in closing offices where the administrative costs to run the office exceed the costs of the services delivered. In addition, the Department of Housing and Urban Development has been forced to maintain offices that it does not want. And the list goes on.

The predominant barriers to change include: congressional concerns about the adverse effects on local economies; agency concerns for maintaining services while trying to fulfill multiple missions; and the lack of a generally accepted process to identify offices for closure.

Fortunately, federal models exist where these barriers have been overcome. For example, the Department of Agriculture’s recently developed plan for closing selected field offices is well designed and participative and used objective measures as a basis for decisionmaking. The best federal models focus on both customer need and the mission of the agency, assess future needs in relation to existing structures, permit organizational boundaries within and between agencies to be crossed, and maintain service levels.

And the Forest Service is mentioned:

The three most commonly cited barriers to change are existing regulations, laws, and concern that “we haven’t done it that way before.”

First, federal entities often quote their own regulations as reasons not to try new ideas or “think outside the boxes.” Agencies often have discretion in how they implement laws, but are frequently restrictive in their interpretations. Regulations are then developed with an emphasis on reporting and policing, rather than accountability. The Forest Service, in a pilot project, found that 70 percent of its regulatory “barriers” were self-imposed, and not required by legislation. Other NPR reports (notably, Reinventing Human Resource Management; Mission-Driven, Results-Oriented Budgeting; and Reinventing Federal Procurement) have identified specific ways in which agencies have historically interpreted legislation in a more restrictive manner than necessary. As a result, new ideas and innovation are difficult to implement within this rigid framework and the regulations themselves become an excuse for abandoning more innovative management styles.

Second, legislation is cited by both employees and management as a justification for agencies not to cooperate across organizational lines. However, legislation usually does not prohibit but rather inhibits inter-organizational cooperation.

The third barrier, a fear of the unknown, is significant. But most of NPR’s recommendations are modeled after successful experiences that have occurred on a small scale in some agencies, or have been implemented in states, localities, the private sector, or other countries that have pursued culture changes analogous to those sought by NPR. The strategies highlighted in this report were chosen because they offer the most hope and best leverage for genuine change on a large scale.

I guess we can add another barrier, negative attitude toward Administration that proposes changes.  And changes are being litigated, by some of the same groups which supported the same kinds of ideas in 1993.  Hard not to see the fickle finger of partisanship.  So maybe instead of reducing barriers, we are accumulating them.

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Silviculture, Ecology, Means and Ends, and Terminological Confusion

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Jon questioned whether the goals of the Round Star project were “ecological” or “silvicultural” and T responded (this is part of the response) that

All silviculture is applied ecology.
While the FHF’s public affairs shop didn’t clearly draw the line to their Forest Plan, that is definitely in the minds of their Silviculturists. Many of the considerations mentioned above (eg root disease, fire resilience, beetle resistance) are very likely laid out in the FHF’s Forest Plan.

On the other hand, I work under a forest plan that is 40 years old, and very divorced from ecology. The goals it lays out are largely driven by timber production, and the ecological considerations I include in management decisions are not laid out in the Plan at all.

This discussion reminds me of  when I worked in R&D (I know that some of you may find this scary, but for some time I was both the Silviculture and Genetics Program Manager, because we couldn’t get a “real” silviculture researcher to move to DC).  Anyway, part of that was helping organize the National Silviculture Workshop.  A local group handled all the arrangements and field trips, and it was a terrific experience to be there and learn from the researchers, the working silviculturists, and their interactions.  At the time I had two ideas, which turned out to be universally unpopular..

  1. The first was to change our name from silviculturist to “applied ecologist”.  I thought “hey, if ecologists are cool, and we are ecologists, why not ride in the slipstream of this popular trend?”

How does Wikipedia define ecology?

Ecology is the scientific study of how living organisms interact with each other and with their physical environment

Not to get all super-picky about language, but what biological science doesn’t involve “interacting with their environment” to some degree? Even cells on a petri dish do it.   So what we used to call forest biologists are all ecologists in that sense.  Wildlife biologists can be renamed wildlife ecologists and no one will really know the difference.  We even had a class in “genecology” in my master’s program, so conceptually I might have been a genecologist. Whatever.

Here’s Google AI’s take on the Dictionary of Forestry definition..

In The Dictionary of Forestry edited by John A. Helms (published by the Society of American Foresters), silviculture is defined as: [1]
“The art and science of controlling the establishment, growth, composition, health, and quality of forests and woodlands to meet the diverse needs and values of landowners and society on a sustainable basis.” [1, 2]

Key Elements of This Definition
  • Art and Science: It blends biological and ecological sciences with practical, hands-on management skills. [1]
  • Control of Attributes: It gives managers the tools to actively shape five critical forest elements: how a forest starts (establishment), how it develops (growth), what species live there (composition), how it resists diseases (health), and its overall economic or ecological worth (quality). [1, 2]
  • Diverse Needs and Values: It acknowledges that modern forestry is not just about logging for timber. It also prioritizes wildlife habitats, carbon storage, clean water, and recreation. [1, 2]
  • Sustainability: It requires managing resources responsibly so that the forest continues to thrive for future generations. [1, 2]

Thanks to the wonders of Google AI, I found this handy set of definitions compiled by Dr. Kristen Waring at NAU.

As Jerry Franklin once said of FS geneticists (at a biodiversity workshop?), (he was defending us against other FS employees who associated us with commercial timber production), we don’t set the goals, the landowner does.  We could be “conservation” geneticists or “exploitation” geneticists (as I was once called by an FS researcher)- the tools are the same, but the goals different.

2.  My other highly unpopular idea was to take our silvicultural definitions, with their hints of a timber-y past, and  develop a new set of definitions that could be more easily explained to the public- just for federal forests.   Then there is how things are reported in FACTS (and elsewhere?), which may have different definitions than the Harvest Report we discussed last week (or not?).

Remember Anonymous found out about those definitions:

There is a technical breakdown of the classification of activities on the last page of the report.

“Removal cut” is the final stage of seed tree or shelterwood harvest.

“Improvement Cut” is an intermediate treatment made in a stand, pole-sized or larger, primarily to improve composition and quality by removing less desirable trees of any species.

“Special cut” is harvest without restocking. Like a power line right-of-way.

Let’s go back to a discussion between Anonymous and T last week. Anonymous said:

Curious how a shelterwood with residuals is categorized on the Colville? Normally, a shelterwood harvest is considered even-aged management, but the Colville never does the second entry; therefore, the shelterwood is never removed. NTM, eastside screens includes a 21-inch dbh limit, so that also affects the result of a shelterwood. Given these caveats, is that really an even-aged harvest and how does the forest track this harvest method in FACTS? Seems more like a thinning from below, given the overstory retention and canopy cover target, and the result is a two-aged stand.

T replied:

I think that’s a good point. My understanding is there’s a specific FACTS Activity Code for Two-Aged Shelterwood With Reserves, where it is acknowledged that the shelter trees are to be retained with no intention of removal. Because the primary intent of the treatment is to regenerate the stand and establish a new cohort, it is a regeneration harvest not an intermediate treatment (ie thinning). Even if there are a lot of residual trees, it all comes down to whether the intent is to establish a new cohort or manage the existing cohort.

The Forest Service lumps single-age and two-age treatments into “even-age” systems, and anything with three or more age classes as “uneven-age” systems. This has implications for 40-acre openings: a two-age regeneration harvest over 40 acres requires public notice and approval, but an uneven-age regen harvest over 40 does not.

There is the treatment, there is what is left (some of us remember the old Ecosystem Management mantra, “more concerned with what we leave than what we take”), what the long-term intention is (reduce fuels, protect trees from …, increase species diversity). Site-specific attributes also enter the picture .. depending on the soil and wind patterns, will residuals blow down?

So folks can propose different treatments toward the same long-term goals, or the same treatment with different long-term goals. But you can’t tell the goals by driving by. You have to read the EA or talk to a silviculturist. Who knows much more about the site and what works towards the stated goals, and incorporates information from other experts (wildlife, soils, fuels etc.).  So a federal silviculturist is both an expert and a convenor of other local experts, plus does projects that move toward the DCs in the forest plan (if it is a recent one) or does things that otherwise make sense (if not).

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Reflecting back, I think the “why” is very important and doesn’t show up except in EAs or if we ask the silviculturist involved.  It’s hard to argue with increasing species diversity..when it’s in the forest plan.. or is it (hard to argue with)?

My FS Reorganization FOIA Story: I. My Request – and FOIA vs. Litigation “Deliberative Process Privilege”

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I filed a FOIA on the documents that came out of the Salt Lake City meeting, prompted by The Hotshot Wakeup’s interview with Chris French. Here’s what I asked for:
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I heard about this meeting from Chris French’s interview with Tim of the Hotshot Wakeup from the transcript: https://thehotshotwakeup.substack.com/p/forest-service-announces-reorganization?utm_source=publication-search

starting at 15:49

“whether it’s their inability to effectively get a contract in place, hire people, or the decision-making where our local managers or district rangers and others feel like they can’t make decisions. We took all that and we convened a whole bunch of people in Salt Lake City mid-summer of last year. People represented from across the agency. For supervisors,

district rangers, people from research, people from our business operations, people from our regional offices. And we basically asked them the question, hey, what needs to change in this agency? And what do we need to make sure that we emphasize and maintain? What’s good and what are the things that we need to change?

We had 15 teams come out of that that provided us a set of recommendations of the type of shifts that we needed to make in this agency. We then convened another group of folks in the fall, again, representing the agency that took all those recommendations,

and they worked with a smaller team of folks made up of four supervisors and other representatives around the agency to present the chief and I a set of options to meet the secretary’s direction that she had given us to reorganize the agency. We took those options last fall, made some decisions.

They were approved by a broad set of folks that were on a representative recommending board, again, representing the agency. And we took those to the secretary. And so this has been over a year and a half of work. The things you see being proposed here are coming through us, from us, addressing the things we know about us.”

I would like to see the set of recommendations from the 15 teams.

I would like to see the set of options presented to the Chief.

If those sets of recommendations include not reorganizing, that’s fine, I just want to see them all.

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That’s what I asked for. Last week I got my first bunch of documents. There were many, many redactions. I asked the helpful FOIA person why. Here’s his answer.

“As described in the interim response letter, the majority of the information that has been withheld falls under FOIA Exemption Five (5 U.S.C. § 552(b)(5)), Deliberative Process Privilege, which protects from disclosure those “inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency.” One of the frequently invoked FOIA Exemption 5 privileges is the deliberative process privilege. To fall within FOIA’s deliberative process privilege, the records must be both pre-decisional and deliberative; the records must precede the adoption of an agency policy and include the opinions, recommendations, or deliberations on a legal or policy matter.

In this instance, the OIA withheld, under the deliberative process privilege, pre-decisional, intra-agency proposals and recommendations regarding the reorganization of the FS, as well as analysis regarding potential facility actions and/or considerations. This information is pre-decisional in that it is antecedent to any final decision. It is also deliberative in that it reflects the evolving back-and-forth process between agency employees that is so integral to the Executive Branch decision-making process; more specifically, the development of potential recommendations made by agency advisors for use in making determinations and policy decisions.

If this pre-decisional, deliberative information were released to the public, USDA and other Executive Branch employees would be much more cautious in their discussions with each other, and in candidly discussing and providing all pertinent information and viewpoints in a timely manner to agency decision-makers. This lack of candor would also seriously impair the Department’s ability to engage in forthright, internal discussions necessary for efficient and proper agency decision-making.

This makes some sense (except perhaps it is too widely applied?) but one of the many tasks of a Planning Director is to agree with OGC about what should be withheld in litigation. Much of that information was pre-decisional, or maybe I don’t understand what pre-decisional means in legal terms.

Personally, I was pretty deferential to OGC, and their view was that we should hardly withhold anything. So it appears to me that people with lawyers get all kinds of info that Jane Q. Public cannot access about how their government works. This doesn’t necessarily seem like justice to me. But maybe I’m wrong and one of our TSW legal folks can explain how this really works or is supposed to work?

If I wanted to get these parts unredacted, I guess there are appeals, and then possibly lawsuits?  As you will see, the redacted parts seem fairly uninteresting except to those of us who are interested in organizational stuff (not as potential partisan fodder), which might be the few, and those without the financial means for lawsuits.

Why Do Folks Clearcut on the Flathead National Forest? For the Silviculturally Curious

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The Flathead National Forest’s Round Star Project includes many silvicultural prescriptions, including regeneration harvest which reset forest stands to trend the conditions to a more fire and disease-resistant species dominance. This photo illustrates two different regeneration prescriptions: on the left, clearcut with reserves leaves varying density of 5-10 trees per acre, depending on natural variability, to maintain a reserve of existing desirable species, and on the right, shelterwood harvest leaves varying density of 15-25 trees per acre and maintains existing trees that provide shading and microsite protection for the next generation of trees. (Note: you can click on this photo and make it larger).

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Last week I asked the question “what are the reasons for choosing clearcutting as a prescription” and got a quick and well-written answer from the Flathead, so shout-out to their silviculture and communications folks!

The Flathead National Forest spokesperson answered the questions as follows:

What are the forestry reasons for clearcutting?

We have a diversity of tree species on the Flathead National Forest. Some are fire and disease-resistant while others are susceptible to root rot, bark beetles, and some are less adapted to survive wildfire. Active forest management on the Flathead targets areas with high densities of species that are less resistant to both diseases and fire, like lodgepole, grand fir, and subalpine fir), and resets the forest stand by harvesting those trees and replacing them with tree species (western larch, ponderosa pine, Douglas-fir) that are more likely to stay healthy through disturbance events like fire and disease.

 

Why does the Forest Service plant trees following a harvest?

When the forest managers reset a stand of grand fir and subalpine fir – shade tolerant species – with shade intolerant species like western larch, there are no naturally occurring seed sources so we plant seedlings of the species of tree that best aligns with the future desired condition of the forest. In other cases, we plant western white pine seedlings that have genetics for resistance to known diseases like blister rust.

 

Where does lodgepole pine fit into the picture? 

Lodgepole pine is a fast growing, naturally regenerating tree species and does well after a disturbance event. However, these trees have a tendency to get bark beetle outbreaks once they achieve a certain age.  Forest managers will identify areas with high levels of insect infestation and designate them for clearing to limit the infestation spread. Depending on the site conditions, some of the healthier lodgepole are left, but often times, in certain soils with certain wind patterns, lodgepole blow down after a treatment. Forest managers will plant western larch, ponderosa pine, western white pine, and Douglas-fir to add species diversity to the area.

 

How does the forest combat root disease with regeneration harvests?

Forest managers use “regeneration” harvest in areas with a high occurrence of root disease and plant tree species that are less susceptible to that disease. Sometimes, a previous treatment that released the midstory needs to be retreated with a regeneration due to the amount of disease that developed in that stand.

In other instances, forest managers use a “clearcut with reserves” that leaves individual trees or clumps of trees of western larch and doug fir scattered through the treatment area to meet objectives for both the future desired condition of the forest and for wildlife species that benefit from forest openings. These treatments usually leave 5-10 trees per acre.

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I will only add, as a person involved with the western white pine resistance program in the earlier days, that restoring WWP seems like a good idea, for ecological value, for Native Americans, for wildlife, because it is fire-adapted, and for biodiversity.

 

 

“The Dog in the Manger” School of Government Improvement and the Need For Bipartisan Work and Structures

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This story (thanks to Nick Smith) on USDA reorganization plans being litigated, plus looking into the Clinton-era Reinventing Government efforts which identified many of the same issues and concerns and acted upon them, without apparent litigation, makes me think that the current partisanization of everything has led to a “Dog in the Manger” approach to government improvement. “We don’t want to fix these things, but we don’t want you to either, and we will bark at you if you try.”

Friedman’s Law: No Public Policy, or Government Program is Improved or Clarified By Becoming a Partisan Issue. As I used to say about a project on the Rio Grande “reasonable access for unreasonable people,” reason tends to go out the window once tribal loyalties enter the picture.

I’ve told this story before, but there are new people here, so..  As a training assignment, I worked on Representative Carrie Meek’s staff  (D-17th District Florida, first African American  elected to Congress in Florida since Reconstruction) in the House. Being a small staff, I did science, women’s issues, the biological side of medicine, and the environment.   As the rep to the Democratic Environmental Caucus, I suggested that we work with the R’s on improvements to ESA. The head staff person on the Caucus told me “we don’t want to do that because it’s more important to attack R’s that want to change it.” OK, then.

Isn’t it reasonable that organizations would  figure out key measures, monitor those, and try to improve. Wildfire folks tend to be more structured and upfront about all this.  Like I often say, we get more lessons-learned from the Fire people on an ATV rollover than we got for Covid response, or closer to home, the NWFP or the 2012 Planning Rule.  Perhaps it’s because some can argue that there is nothing wrong, so why improve? But we know that some people think that there is something wrong, so why ignore them (or not even have a process to listen to them?)

Let’s use Forest Service policies as an example.  Some people have seen problems with the mapping of 2001 Roadless, with forest planning implementation, with travel management mapping and implementation, or a $740 million deficit?

Here’s how it seems to go:

1. Everything is fine.

2. Some people think things are not fine, but we can ignore them, or don’t have processes in place to listen to them.

3. The people who think things are not fine have spoken with politicians who agree with them.

4. The politicians are doing something or are asking the organization to change.

5.a. They are the wrong politicians (from the other party) so we can focus on how bad they are and they want to destroy everything. And/or

b. Ok, so there might be a problem, but they are going about fixing it the wrong way, because their intention is really bad and they have bad ideas to boot.

And never have a discussion directly addressing the concerns and potential alternative approaches.

6. When we get back in charge, we continue to ignore the problems.  Hurray!

This can work with 1-6 being worked by either party for different issues, but right now it seems to D’s and their allies focused on not changing organizational structures.

It seem to me that the fact is that folks will always disagree, about what should be decided, what scale it should be decided at, and what the decisions should be. In Spencer Cox’s book, he says that he thinks the best way to get good, long-lasting decisions is through the legislative process, because people with different views have to interact directly with each other.  Of course in a lopsided legislature, they don’t have to. And they might be more interested in performative displays that look good on social media, decrying the badness of the other party, or working on their elections rather than sitting down to work things out.

In my experience, what might  be helpful is to have standing groups with representatives of various interests to review, at regular intervals,  implementation of regulations or processes.  I would say FACA committees, but these tend to be overly regulated and hard to keep going due to all the paperwork.  Plus the current Admin often wants to put its thumb on the scale (or more than a thumb, in some cases).  Most of the groups that get started to work on something are disbanded by the time the flaws start showing, and the agency might not have the energy or political oomph to argue for fixing the problems (and factions within the agencies might not agree on what the problems are).   On the other hand, to be within an organization and know that something isn’t working often runs into what some partners call “antibodies to change.”

I would propose that in the same way that the Colorado legislature selected interests for the State Roadless Taskforce, that the federal legislature could select interests and require an agency to set up a review taskforce to examine implementation at 10 year intervals.  It would include open public listening sessions and documentation, and identify needs for change, both for agencies, partners and Congress. Because courts work off statutes and sometimes case law can develop over time that is not great for anyone.

For those who are interested in improving government implementation..check out Recoding America by Jennifer Pahlka, this is a Google AI summary..

  • Policy vs. Implementation: The book argues that government fails when lawmakers separate high-level policy from the messy details of how it is actually carried out. [1, 2]
  • Industrial-Era Culture: Government relies on rigid, outdated systems from the industrial age that make public services slow and cumbersome. [1, 2]
  • Focus on Outcomes: Instead of just buying new technology or adding more money, the government needs to change its operational culture to focus on real human outcomes. [1]
  • Test and Learn: Agencies should use flexible feedback loops and test-and-learn approaches rather than sticking to decades-long, top-down plans that fail in practice. [1]

Pahlka and Greenway at The Niskanen Center developed this thought paper for those who are interested in the broader topic of improving state capacity.

Rebuilding our state capacity — the how of our government — is an arduous task that requires a stomach for learning and fixing the rules and culture of the bureaucracy. But make no mistake: whether or not we do it is not a technocratic choice. It’s a political choice — a leadership choice. Previous administrations may not have actively set out to make dealing with public services a burden, or to cripple our nation’s military readiness with policy clutter amounting to hundreds of copies of War and Peace, or create a veto-cracy that limits our ability to build infrastructure. But neither have they made fixing it a priority. This one can, and should.

Our two parties (and even the factions within them) often speak about state capacity in very different languages and have differing priorities for where that muscle should be deployed. But the vast majority of elected leaders on both sides of the aisle would like the bureaucracy to be capable of achieving the missions it is assigned

 

Where is the Forest Service Clearcutting Today and Why?

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We’re going to dive down to the “why,” at least on one forest, to satisfy the silviculturally curious, but this handy table shows us where clearcutting is happening in terms of Region. I’d like to step back a minute and say that my perspective depends on my observations at a specific spatial and temporal scale, and also how I perceive them, for example driving through California post-wildfire is different from info derived from satellite photos.  Point being, everyone, including researchers, can be “right” in their own observations, but not give a complete story.  It’s only in engagement with each other, and with various kinds of data, that we can get closer to an overall picture of how things are and why people think as they do.

 

Anyway, the tables go back to 1984.

I asked Google AI to plot clearcut acres for me from 1984 to 2025.  Google AI even made up a narrative to go with it! I don’t know how true the narrative is. Or really even the plotting, but..

So it looks like if you were in R-3 or 6, you would think “there is no clearcutting” but if you were in Rs 1,2 and 9, you might think differently. Or if your career began in the 1970’s or 80’s, it might seem like there is little to no clearcutting comparatively.

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To get to Forest, I think I would have to dive into FACTS, which would be a handy thing to be able to do (and might be handy to compare fuel treatment acres over time), but here is what Google  AI said I would need to do. Maybe there’s still time to consider a Peoples’ Non-GIS Database for info people have proven to be interested in?

No, the publicly available summaries from the annual reports do not break down these totals by individual National Forest.
The standard published source for this data—Table 20 of the Annual Reforestation and Timber Stand Improvement Report—aggregates clearcutting acreage strictly at the Regional level. [1]
To obtain the 2024 clearcutting totals for individual forests within Region 1 (such as the Flathead, Bitterroot, or Kootenai National Forests), you must access the raw FACTS database layers directly using one of the following approaches:
    • Download the Geospatial Data: You can download the raw shapefiles from the USDA Forest Service Enterprise Data Portal. By uploading the Activity_TimberHarvest layer into GIS software (like QGIS or ArcGIS), you can filter the data by Fiscal Year (2024), Region (01), and FACTS Activity Codes (4110 through 4119)—which explicitly denote clearcutting—and group the results by the NATIONAL_FOREST_NAME attribute field. [1, 2]
    • Use the ArcGIS Online Portal: You can use the interactive ArcGIS FACTS Harvest and Silviculture Portal to visually filter for Region 1 projects, click on specific management boundaries, and view the attribute tables containing the exact acreage for that specific forest unit.

    • Submit a FOIA or Info Request: If you do not have GIS software, you can contact the Region 1 Regional Office in Missoula, Montana, or the specific forest’s silviculturist to request a copy of their localized FACTS tracking spreadsheet for FY 2024.

Would you like the exact list of FACTS activity codes used for clearcutting to help you filter the GIS database, or are you looking for details on a specific logging project in Region 1?

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