Cumulative Effects Analysis – A Guest Post by Courtney Schultz

Attached is a piece I wrote that came out of my dissertation research on how the Forest Service handles cumulative effects analysis, particularly when it involves resources that see effects over long temporal and broad geographic scales. This article came out in Bioscience this month and is a short piece that focuses especially on the limitations of how we do the analysis for wildlife species. My intention was to look at the requirement and at current practice and provide a critical assessment of where/how it falls short, where it works, and what are impediments to and opportunities for improvement. I’d be interested to hear what you all think. Having worked as a PMF (Presidential Management Fellow) for the last year, a question that looms large for me and that I would like to have addressed more is: What could practitioners (from district to regional offices) do to improve analysis with the resources available? I touch on this to some extent, but I’d like to keep exploring it. I look forward to hearing any of your thoughts and feedback.

Courtney Schultz is currently a Presidential Management Fellow with the U.S. Forest Service. She completed her Ph.D. at the University of Montana in the College of Forestry and Conservation and this fall will begin work as an assistant professor of forest and natural resource policy at Colorado State University.

7 thoughts on “Cumulative Effects Analysis – A Guest Post by Courtney Schultz”

  1. When I read Courtney’s paper, I sense a serious effort to find solutions to reduce litigation. However, It still stands that on forests that aren’t litigated, the need for analysis gets pretty small. I recently compared an Environmental Assesment (EA) for a timber sale in Montana (northern region) to one in Colorado. They were both MPB salvage timber sales. They both abutted roadless. Because of concerns about fire hazard,timber sale litigation in Colorado has stopped. It’s ironic that the Colorado counties effected are very pro-green. The EA in Montana treated 1300 acres and ran to 200 pages, the one in Colorado trated 4,000 acres and ran to 57 pages!

    Ecological analysis and science is fine, and I don’t want to downplay it, but ecology reminds me of molecular biology. The more we find answers the more we realize its complexity. Every answer only opens up a dozen more questions. It’s not engineering. There is no magic equation that will tell us how any one of dozens of sensitive species will react. We focus so much on the micro, we loose sight of the macro. More monitoring and more analysis only leads one to the impression that the USFS has become a jobs program for “ologists” to do pure research. The public still wants to see something accomplished “on the ground”.

    Now,how about the economic analysis of how much the “lawsuit proofing” of northern region timber sales adds to the cost to taxpayers to prepare timber sales. How much has the cost increased in 15 years (doubled)? Why does state of Montana timber sales make $2.00 in revenue for every $1.00 in costs(every state timber program makes a profit). I can’t believe the USFS can’t track costs related to timber sales. Oh I’m sure it’s complex, but so is building a $40,000,000 building and the contractor can still tell you exactly how much it costs to add twenty door knobs.

  2. CEA is a very important and complex issue for all Forest Service lands. As I have said before, we need to be analyzing and utilizing the “No Action Alternative” to spell out what is likely to happen if nothing is done, whether the project is litigated or the project area is “preserved”, as many litigants prefer. The impacts of “unstewardship” MUST be explored and paraded before the courts.

  3. Courtney-

    I wanted to give your paper the time it deserved so it took me a couple of days.
    With regard to Derek’s point above on the MPB sales.. generally Colorado doesn’t have an active timber industry. So people that don’t trust the FS not to cater to the timber industry at the expense of the environment can’t really find a foothold locally.

    It goes back to a point I’d like to explore more. Can FS activities really impact viability? It seems to be an assumption from the past, that perhaps, somehow through monitoring and analysis, we could disprove. But looking at an 80 acre WUI fuels treatment surrounded by thousands of acres of no activity whatsoever, it is hard for me to believe in the biology of a critter for which viability at that intensity of management is really an issue. Does someone have examples?

    I would be very interested in the results of an analysis that looked at acres per year treated compared to the total number of acres on various forests around the country.

    Is our current analysis a vestige of the old big timber days? Are we spending scarce funds (and the precious thinking of thoughtful academics) to do the analytical equivalent of running a tank over a fly?

    Here are a couple of other random thoughts:

    I am not a fan of the coarse filter approach as it seems based on the past (HRV). If we are really interested in species, let’s just admit it and see if conditions they like will continue through time. It is easier to talk about individual species and their needs than dynamics of vegetation through space and time, with the only possible target being the past. It seems like we have a simple choice- go to the past for what we want (impossible, ultimately, and especially with climate change) or just be upfront and admit we want to hang on to species as long as we can.

    One of the reasons cumulative effects analysis has been found wanting in forest plan EIS’s isn’t about the FS writing cumulative effects- it’s that to some extent our (and I mean humans’) understanding of complex systems and the future are both not good. The longer the future you try to predict, the less adequate your projections. If you’re talking about potential future effects of a variety of actions, when you don’t know if you’ll do them, where you’ll do them, or how you’ll do them, nor how other decisions will unfold, nor what climate change will do to the environment, it seems a bit of an exercise in random pontification. Any such exercise is of course, prone to legal criticism. Which may distract us from dealing with the reality of our not-knowing and having to decide, knowing we don’t, and won’t, know.

    Monitoring by itself does not tell you what is happening to a species. A species may go up or down based on factors unrelated to vegetation treatments (e.g, prairie dogs and plague). So monitoring may be necessary, but not sufficient to address the question of “do management practices have negative impacts on the survival of the species?”

    It seems odd to me that after all this time and all the research, we still don’t have “habitat models and empirically based wildlife habitat relationship models.” Maybe there should be a “Joint Fire Science Program-like” wildlife research program where information needs are prioritized by NEPA practitioners with an end toward analyzing cumulative effects.

    There is a tension, in my opinion, between the science that says “the climate will warm 3 degrees and massive unprecedented things will happen” and the science says that “we need to use past information to figure out how a species will do in the future.” It’s all science, but the different disciplines don’t necessarily lead us to the same place.

  4. Or, which is more likely, we may blunder into new vegetation landscapes in new areas, by not doing any significant and effective management. Does anyone REALLY think that thinning unmerchantable trees is going to have any impact on the unsettled AGW un-consensus?

    I think you planner types SHOULD be looking at how testimonies in Congress are siding with obvious junk science, for political purposes. Chad Hanson’s “Re-Mix” and “Donato’s Folly” were both recently cited by Jay Jensen as reasons not to treat 22 million acres of dead forests as an “emergency situation”.

    I’m not seeing any stability in that rudder, and the ship is still being buffeted by the squirreliest of winds. Some are paddling on one side of the ship while the other side is trying to put out the fires of the ongoing battle. The ship appears incapable of reaching port, anymore.

    The Obama Forest Service seems to want foresters to be quiet, obedient and patient while the adult scientists are discussing “important stuff”. Forestry is going the same way that Latin did. Few still study it. Few still practice it, and almost no young people are getting degrees in it. What’s next? Forestry book burnings?!?!

    Historians will look back on these times and consider our current forest policies to be barbaric and shortsighted.

  5. Sorry about my own confusion.

    I mixed up Jensen’s testimony on HR 5192 with that of the NRDC, which is worth reading, as well. Still, Jensen’s stubborness and the calls for “more study” reek of political inaction. If 22 million acres isn’t enough mortality to justify an “emergency”, then how much IS enough?!?! When will we reach that “mortality goal”? AND, there’s always the question of whether the preservationists will hold public safety hostage because they don’t like timber salvage. Yes, Chad Hanson sued and won against several roadside hazard tree projects because they were a part of a salvage sale. He also won the ability to make judgement about individual tree marking decisions on one of my own projects. Maybe Jensen is merely seeing what will be litigated and what will be allowed, letting radical preservationists dictate what happens in our forests.

  6. Thanks to those of you who took the time to read my piece and provide me with comments. A few thoughts….

    I don’t know if FS activities continue to pose threats to viability for species, but I think it’s a real possibility. In the Northern Region, we still see projects significantly larger than 100-acre WUI treatments, and we also have a number of species present that are in decline, listed, or are candidates for listing. I think there are real issues for fisheries and impacts from grazing and for species that depend on relatively isolated and undisturbed habitat. I posed some versions of Sharon’s questions to a number of biologists in Region 1 when I was doing my research. Are there really any potential threats from our projects? Is monitoring still important? The answer I got was always a very clear yes. We’ve made the mistake in the past, as have so many actors operating in areas of human or ecological health, of underestimating the impacts of our actions (and we’ve overestimated too). I think there is a clear case for increasing our strategies for monitoring to understand better what is occurring on the ground–what resources are present, what’s their status, and how they’re being affected.

    Indeed, understanding the effects of individual management actions is a huge challenge and in many cases would require an experimental framework that goes beyond the FS’s mandate and budget. Still, we can do better than we’ve done in the past and invest more strategically in monitoring and learning. In the case of wildlife, we can use detection data and couple that with spatial variables to continuously improve species habitat models that would allow us to model cumulative impacts both backwards and forwards in time. We could select species for monitoring, recognizing that we can’t monitor many of them, nor is any species really going to serve as a surrogate for others. Nonetheless we could select a few species for the best reasons we can come up with and concertedly put resources towards them. One scientist once suggested the notion of a roving team of experts that could work across agencies to select key species to target for different regions of the country. Resources and monitoring strategies could then be coordinated across agencies and with private parties to get better information. Why not? In many cases, neighboring forests have not chosen the same MIS, different agencies are monitoring different species, and local conservation groups in some cases are putting resources to yet other species. Sometimes there are good reasons for this, but I heard from many interviewees that often it’s just a waste of resources. We’d benefit from more coordination, and it would allow us to leverage more resources to get high quality information, even if that’s only for a limited number of resource indicators. So, even without adding additional resources, we could be doing a better job of coordinating the work that is already going on.

    Having spent most of my time in Region 1 and more recently in Region 3, where we’re planning the largest restoration project the agency has even undertaken, I think there is still a strong case for developing key lists of resources we want to track and then using all the resources we can muster–new science, new partnerships–to understand the effects of our actions and continue to aim for the difficult target of high-quality adaptive management. This is the only way to deal with our own limited understanding of ecosystems and ongoing, unpredictable change in those ecosystems. Even if our own practices have improved drastically, the changes we expect to see from climate change should impel us to move in this direction.

    From a broader planning perspective, I have a number of outstanding questions. Don’t we spend too much time focusing on predictive planning, rather than on post-project monitoring, learning, and reassessment? Is there a way to fix this? If we made some institutional changes, would we see post-project assessment information feeding information into the next round of project and programmatic planning in a way that would make those processes more efficient? If monitoring is so critical to planning, should we have a small staff on each forest devoted to ongoing forest plan implementation monitoring? This staff would rely on project-level monitoring, forest-level monitoring, would feed information into project-planning, forest plan monitoring reports, and would be coordinated across districts and forests. Staffs on multiple forests would be tightly connected to coordination at the regional level. This is the direction it seems like the planning rule wants to go, but without institutional changes (staff organization, budgetary changes) it will be difficult for the FS to really move in new directions in how we do monitoring.

    In terms of forest planning, do we have any obligation to take a concerted look back at the impacts of forest plan implementation and carry those lessons forward? This seems to me to be a critical piece of the NFMA process: write a plan, monitor, revise the plan accordingly. But, the way forest planning and planning rule revision have played out, not to mention FS history over the last few decades, we aren’t looking at plan revisions as incremental revisions of the last plan. This is not a bad thing, but are we losing a step in there somewhere–a time for more programmatic learning and assessment? The idea in forest planning has always been to have periodic monitoring reports to accomplish just this. How will the new planning rule ensure that 1) monitoring happens and doesn’t fall through the cracks or produce reports filled with less-than-useful information and 2) monitoring reports integrate into ongoing project-level planning? I’m convinced that mandating quality monitoring is one of the biggest challenges in public lands planning.

    Finally, as for CEA and NEPA, I think as an agency we have an obligation to disclose past effects. I maintain that our approach of relying on current environmental baselines to capture cumulative effects misses the mark, especially if we are not comparing to any point in the past. Comparing to the past does not mean the past is what we’re aiming for; it’s just critical to have some reference point. Also, without any thresholds, assessing significance and practicing adaptive management are quite difficult. We run the risk of repeating a couple of major mistakes of the past–assuming that we know the effects of our planned actions, and losing perspective on actual effects and losses.

  7. I would like to respond to Courtney’s quote from above: “I don’t know if FS activities continue to pose threats to viability for species, but I think it’s a real possibility. In the Northern Region, we still see projects significantly larger than 100-acre WUI treatments, and we also have a number of species present that are in decline, listed, or are candidates for listing”.

    I put forth that we are so concerned with what occured in the past, that we are loosing sight of not doing enough now. Are we throwing the baby out with the bathwater? On the Northern Region, for the last five years the Gallatin forest harvested an average of 260 acres/year. The Beaverhead-Deerlodge only 500 ac/year. The Lolo harvested 2500 acre/yr. At that rate it’ll take the Lolo 50 years to harvest 7% of the “forested acres”. The Gallatin and BHDL will take 50 years to log 1%! I don’t know how that rate of logging can be considered a threat to viability. Frankly, at that rate of logging your National Forests are being managed more like National Parks.

    I believe Courtney has worked on the “Four Forests” initiative in Arizona. It proposes “restoration thinning treatment” on 30,000 acres/year. Off the top of my head I think the Lolo has 600,000 some acres in a “moderately warm dry” habitat that was also characterized by frequent low intensity fires”. Could it not also benefit from a greatly expanded “restoration” treatment? Do the people of Montana not deserve the same benefits the people of Arizona will derive from WUI treatments? To treat half those acres would take 120 years at the current rate. What are the effects of not doing enough?

    I’m with Fotoware, in that “Alternative A”, the no action alternative,is a rubber stamp. The consequences of doing nothing gets lip service. I think we’ve all seen post fire erosion that would have made the cover of TIME magazine if a logger had caused it. My point isn’t that fire is bad, it’s that it isn’t ecological news if it’s deemed “natural”.

    Would the perspective of monitoring be more effective when seen as a percentage of the whole? I’ve read lots of USFS annual monitoring reports. Big numbers by themselves mean nothing. Only percentages can lead us to perspective.

    Courtney, please don’t think me rude. My intent is not to indict what you say.I agree with 90% of it. I admire the thoughtfullness you have put into improving your profession.


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