Does Anyone Read the Errata Sheets?

A 46-page 2nd “errata” sheet accompanies the Forest Service’s FY 2011 budget. All but one of the corrections are of no particular consequence.

The eye-popper is almost at the end (where else?). The Forest Service proposes to increase stewardship contracting targets by six to eight-fold compared to previous years. Timber volume from stewardship contracts will increase from 413 mmbf (2010 target) to 2 billion b.f. Biomass energy fuel will increase from 376,000 to 2.6 million tons. “Acres of wildlife habitat improved” (I’ve never understood what that means) go from 8,630 to 100,000 and noxious weed-treated acres (I’ve got a better handle on that notion) sky-rocket from 1,292 to 180,000.

Somehow these Herculean feats will be pulled off by reducing stewardship contracting spending from $6.5 to $6.0 million. And with zero employees, too (huh?).

So I thought, “Maybe the errata sheet itself is one big typo?” I called the Washington Office. The helpful lady said that these numbers reflect the Chief’s commitment to the stewardship contracting program. When I pressed her on how the FY 2011 numbers compared to previous years, she said “someone from upstairs will have to get back to you tomorrow.” No one did.

10 thoughts on “Does Anyone Read the Errata Sheets?”

  1. Let’s Face it: 15,000 readers of Biofuels Digest voted US Secretary of Agriculture Tom Vilsack numero uno of the “Top 100 People in Bioenergy”.

    There was probably an errata sheet posted after the Dec.7th surprise attack on Pearl Harbor too.

    Nobody had time to read it though.

  2. I have certainly never read them and I can’t tell you what any of the numbers mean, but I’m sure Kathleen Atkinson in the Washington Office can. (202-205-1088) You should give her a call.

    I can explain what “wildlife habitat improvement” means, though. In the Southern Region, anyway, wildlife habitat improvement through stewardship contracting has included overstory thinning of dense stands, removal of midstory vegetation, and prescribed burning, and other more specialized projects. All of this is aimed at restoring the ecological conditions needed by rare species such as the red-cockaded woodpecker, gopher tortoise, and indigo snake and many more common species such as wild turkey. These projects are developed collaboratively and have widespread support from environmental and sportsman’s groups and more recently, those in the timber industry who have figured out how to make a profit through activities that aren’t the traditional timber sales of the past.

    Rex Ennis, Stewardship Coordinator (573-325-4233 x102 )for the Southern and Eastern regions would be a good person for you to talk with if you want to know more about why stewardship contracting has great potential for leveraging dollars in the face of shrinking budgets and expanding ecosystem restoration on national forests. Dave Wilson, with the National Wild Turkey Federation (803 637-3106) can tell you why the Federation has been a big supporter of stewardship contracting. He’s also likely to tell you that he is disappointed with the Agency’s slow pace in making the use of stewardship tools more commonplace.

  3. If I might add to the Southern Region’s list of “wildlife habitat improvements” — the growing of thousands of acres of GMO corn and soybeans in riparian bottomlands in the nation’s largest National Recreation Area east of the Mississippi. Although there’s no apparent national/regional shortage of corn and soybean “habitat,” the Forest Service thinks it’s a nice idea to accelerate the growth of turkey and deer populations with chemically-intensive high energy foodstuffs. Turkeys aren’t rare; neither are deer. Corn isn’t native; nor are soybeans.

    To top it off, the Forest Service tried to outsource its administration of the farmers’ special-use permits to the National Wild Turkey Federation (turkeys guarding the hen house?). Only after a judge reminded the agency that the Organic Act charges the Forest Service with administration of the national forests (who knew?) did the FS back off (after appealing to the circuit court).

    Of relevance to this post, the Forest Service tried to use its stewardship contracting authority to do the outsourcing. According to the FS’s argument, the stewardship contracting law is so broad that its discretion overrides every other law on the books. Maybe that help explains the irrational errata.

    P.S. It would be nice if Ms. Atkinson would post the FS’s explanation on this blog (it is read by folks in the W.O.). That would eliminate the possibility that I might inadvertently misrepresent the agency’s response.

  4. Andy,

    The questions presented by such an expansion of stewardship contracting (with decreased appropriations) are worthy of extensive discussion.

    If you are interested, check out the relevant exchange between Chief Tidwell and Senator Murkowski regarding the expanded use of stewardship contracts. Hearing No. 111-391 is online at

    The exchange begins on p. 23.

    I’m a fan of stewardship contracting. But my take is that while it is an excellent tool, it was never designed for or envisioned as the primary way the agency would do business in the future.

  5. Martin, haven’t you also said that using stewardship contracting for a certain number of acres could provide the certainty that folks seek, but can’t really get, through place-based legislation?

    • Sharon,

      That’s right. But I also have a “Limitations of Stewardship Contracting” section in that report. Here is the link.

      Here are a few things I highlight in the Report that are of relevance to this discussion:

      “Possible changes such as these hold the potential of providing some additional certainty through an existing contract mechanism, without the need for a controversial legislated timber mandate. But stewardship contracting is no panacea. And place-based groups should recognize its limitations.

      First is to acknowledge its timber-oriented approach to restoration. Notwithstanding its other authorities, the goods-for-services provision is most often used, meaning that stewardship contracting is perceived and used mostly as a funding mechanism and vegetation management tool. Depending on the type of contract used, restoration is paid for by harvesting timber. Economically-valuable trees, in other words, need to be harvested in order to pay for associated restoration projects. If timber value is overestimated, or markets for small diameter timber do not materialize or cannot be sustained, restoration projects will not be financed. Unless, that is, they are supplemented with additional appropriated dollars.

      Arizona’s White Mountain Stewardship Contract is again demonstrative. For all of the certainty it has provided since its inception, the contract has had other consequences as well. The GAO reports that this very large stewardship project has incurred greater costs than expected and that such costs have “taken a substantial toll on the forest’s other programs,” including range, wildlife, hazardous fuels, and vegetation and watershed management. Furthermore, some other fuel reduction projects were not being completed because their funding sources were being “monopolized” by the White Mountain Stewardship Project. Other national forests in the region also paid a price to service the terms of this contract, and “[a]s the region has redirected funds toward the White Mountain project, these other forests have become resentful of the disproportionate amount of funding the project has received.”

      The White Mountain case is significant because it shows the promise and limitations of stewardship contracting. While it has provided industry more certainty, the contract is not self-financing, nor was it intended to be. (The average annual cost to the USFS for implementing the contract is $5.15 million). And the Apache-Sitgreaves National Forest considers the biggest challenge of the contract to be the funding of the related task orders each year, as it would be able to treat more acres with more funds.

      The type of landscape-scale restoration envisioned by the selected place-based initiatives will undoubtedly require additional Congressional appropriations. Without them, and with the agency contractually obligated, there is a risk that other national forests and programs will have to pay to service the terms of a long-term contract.”

      The Report then goes on to talk about stewardship contracting and its relationship to appeals and litigation.

      And some earlier writing of mine focused on place-based forest law reviews some recent case law regarding stewardship contracting and its relationship to NEPA and possible problematic incentives.

  6. Is stewardship contracting part of or come from the Healthy Forests Initiative? Am I wrong in my understanding that projects under the Healthy Forests Initiative can and do undermine the NEPA process because they are only required to look at two alternatives?

    I have seen (in my opinion) wildlife habitat improvement thinning projects for aspen stands in California.

  7. It’s a bit confusing. The web site explains it a lot better than I could. Some of the information may be out of date due to legal challenges.

    Sharon, can you clarify?

    Briefly, the HFI was a set of administrative actions, including pushing for and signing the Healthy Forest Restoration Act. Stewardship Contracting authority comes from a separate piece of legislation. I’m not sure if it was portrayed as being under the HFI banner.

    If projects are properly planned and conducted according to the provisions of the 2 acts, NEPA should be streamlined and enhanced rather than undermined, since both acts require that projects be developed collaboratively. By the time the projects get to the NEPA phase, a lot of up-front work should have been done to address concerns and examine different approaches. Are you aware of instances where the process is being abused?

  8. Stewardship contracting is indeed separate, but can be used for, HFRA projects. Here is what it says in the interim field guide under HFI about stewardship contracting:

    Stewardship Contracting
    Congress has enacted legislation expanding stewardship contracting authority with communities, the private sector, and others, allowing the USDA Forest Service and DOI BLM to enter into long-term contracts (up to 10 years) to meet land-management objectives (for example, to reduce wildland fire risk and improve forest and rangeland health). Stewardship contracts focus on producing desirable results on the ground that improve forest and rangeland health and provide benefits to communities. Among other things, the new stewardship contracting authority allows forest products to be exchanged for ecological restoration services, which may include thinning and removing brush


    here is the implementation guide for HFRA and a link to the piece that talks about NEPA . The field guide also has a good section on what is HFI and what is HFRA.

    With regard to Erin’s comment, she may be referring to the capacity to analyze the collaboratively developed proposal and the no-action alternative. I agree with Jim above that it is streamlining rather than undermining. Here’s a quote from the relevant section of the Interim Field Guide:

    Developing the Proposed Action and Alternatives
    Authorized hazardous-fuel-treatment projects under the HFRA cannot take place in any of the following:

    •Wilderness areas

    •Wilderness study areas

    •Areas where the removal of vegetation is prohibited by an act of Congress or Presidential proclamation (including prohibitions in the area’s implementation plan)
    All proposed HFRA actions must be consistent with the applicable resource management plans and they must be on lands managed by the USDA Forest Service or DOI BLM. This means that any proposed action that would not be consistent with a resource management plan must be: modified to make it consistent with the plan, or be covered by a plan amendment or project-specific amendment.

    For areas inside the wildland-urban interface and within 1 1/2 miles of the boundary of an at-risk community, the USDA Forest Service and DOI BLM are not required to analyze any alter­native to the proposed action, with one exception:

    If the at-risk community has adopted a Community Wildfire Protection Plan and the proposed action does not implement the recommendations in the plan regarding the general location and basic method of treatments, agencies are required to analyze the recommendations in the plan as an alternative to the proposed action (Sections 104(d)(2) and (3)).

    Agencies are not expected to develop a full no-action alter­native. However, they should evaluate the effects of failing to implement the project.This information will be useful if courts consider requests for an injunction and must balance the short-and long-term effects of taking or failing to take an action. See the Judicial Review section for more detailed guidance.

    For areas within the wildland-urban interface, but farther than 11/2 miles from the boundary of an at-risk community, the USDA Forest Service and DOI BLM are not required to analyze more than the proposed agency action and one additional action alternative (Section 104(d)(1)). Agencies are expected to analyze the effects of failing to take action.

    For authorized HFRA projects in all other areas, analyses must describe the proposed action, a no-action alternative, and an additional action alternative, if one is proposed during scoping or the collaborative process. If more than one additional alternative is proposed, the agency will select one and provide a written record describing the reasons for its selection (Section 104(c)).


Leave a Comment