Angora Restoration- Much Ado About Relatively Little

Watershed Tour of Angora Fire (photo by Steven McQuinn)

Today this story was in the AP “Burned forest value central to Tahoe logging fight.”

So far, I have seen it in a Bellingham Washington paper and the San Jose Mercury News. I wonder about the timing, as the lawsuit was filed in February (11th?) as per this press release.

As with all vegetation management lawsuits, I hunted around to get the acreage of the project. It was a bit hard to tell from the article since it seemed to be focused on “why fire is good” but not so much on “why whatever the project is proposing is bad.”

I found the EA and DN here, and the appeals here.
I decided to take a look at the John Muir Project appeal decision since those folks were interviewed in the AP story. Here is what that appeal decision says about the project (my apologies for the quality of Adobe to blog conversion):

Alternative 2 includes activities on approximately 1,416 acres of the approximately 2,700 acres on National Forest System lands. The modification included:

Hand thinning and piling/burning will be used instead of aerial logging approximately
447 acres where slopes are over 30%.

The prescription will change in Units 1, 3, 6, 8 and 11 to remove 16 inches and less live
trees and 20 inches and less dead standing and downed trees (See final EA Figure 2-2).
Piles would primarily include woody material 14 inches and less. The portion of tree
boles over 14 inches would be left on the ground.

Alternative 2, as modified, includes the following activities:
Fuel removal of standing dead and downed wood and thinning of live trees on
approximately 1,411 acres.
Within the 1,411 acres:
o 6 acres of conifer removal for aspen stand enhancement;
o approximately 77 acres of treatment proposed in wildlife snag zones (39 acres in
SEZ; 38 ac Subdivision);
o 13 acres of conifer removal for meadow restoration/aspen enhancement in the
Gardner Mountain meadow.

A ground-based logging system on up to 964 acres (including 13 acres of Cut-to-Length
mechanical thinning in Gardner Mountain Meadow) located in areas with slopes under
30%.
New construction of new roads (up to 7.7 miles) and landings to facilitate fuel removal.
Reconstruction or opening of existing roads, trails, and landings to facilitate fuel removal.
Decommissioning/restoring 1.9 miles of road and 16.7 miles of trail.
Existing and new landings and staging areas would be utilized to facilitate removal of
fuels for ground-based operations.
Reconstruction of 1,200 feet of Angora Creek.
Treatment of the following noxious weeds: bull thistle, field bindweed, St. John‘s wort,
tall whitetop, and oxeye daisy.

But here’s my favorite appeal point..(I couldn’t easily find the appeal itself, so I am assuming that the appeal point was accurately summarized; if anyone can point me to a copy of the appeal, I will post it here.)

Contention A: The CO2 emissions from the Angora project will have a significant impact on climate change. (Appeal #10-05-00-0102-A215, pp. 12-13)

I’m hoping that something got lost in translation between the appeal and the appeal decision.

15 thoughts on “Angora Restoration- Much Ado About Relatively Little”

  1. Chad Hanson and his eco-lawyer wife and back at it again! Yep, our forests should all be handcrafted especially for the black-backed woodpecker, a bird not on the ESA list. He knows that all fire salvage projects have contentions and that he can find both a sympathetic judge and a sympathetic press to push his extremist viewpoint. The article is full of holes, as well, including the assertion that Hanson is a researcher from UC California Davis. The university has consistently distanced themselves from him.

    Notice in the picture that the nasty whitethorn is already well on its way to blocking conifer growth. There is undoubtedly a whole lot of manzanita “stump-sprouting”, as well, seeking to dominate the burned landscape for decades, until the next lightning strike torches of the remaining fuels from fallen snags and thick brush. Re-burn is inevitable in the Sierra Nevada, whether it is ignited by humans or nature. We cannot sustain these massive piles of dead vegetation. The Angora Fire itself feasted on unsalvaged fuels from the massive bark beetle infestation of the 90’s. Sadly, it looks like we won’t learn from this wildfire that burned into the WUI and burned so many homes. You cannot blame residents for living in a housing subdivision but, too many preservationists resort to this unfortunate practice. Also sad is the inevitability that this tragedy will happen again and again, until we have legal reform for post-fire treatments, as well as real-world fuels reduction projects.

    Reply
  2. Earth Island Institute and Center for Biological Diversity Complaint, 02/11/2011.

    We can make our own judgements, then wait to see what the court decides. But we ought to do it with a bit more information than contained in Sharon’s post. A brief read of the complaint suggests to me that the lawsuit plays the carbon card in this way,

    47. In addition to disturbing the local forest ecosystem, the Angora project will also contribute substantial amounts of global-warming causing carbon into the atmosphere. The project will remove 1,398 acres of live, dead, and downed trees and other forest materials. EA at 1-14. Much of this forest material would be shipped to two biomass facilities located in Loyalton, California and Carson City, Nevada, where the material would be burned to generate biomass energy. Both biomass plants,located roughly 80 miles and 25 miles from the Angora project area respectively, were closed as of August 2010, and it remains unclear where and how far the biomass would now be sent.

    48. Logging, transporting, and burning trees and other forest biomass to generate energy emit substantial amounts of greenhouse gases. In fact, burning woody biomass for energy results in higher carbon emissions per unit of energy generated than burning fossil fuels, including coal, oil, or natural gas.

    49. As is required by NEPA, the Forest Service attempted to calculate the Project’s greenhouse gas emissions. The agency concluded that the Angora Project would release 59,272 metric tons (“mt”) of carbon dioxide equivalent (“CO2e”) by adding emissions from the decomposition of biomass in the Angora Project area and from the eventual burning of Project’s biomass at biomass energy facilities, when carbon stored in the forest materials is released.

    50. However, the agency failed to consider several substantial contributions to the Project’s total greenhouse gas emissions. Specifically, the agency failed to consider emissions from trucks and equipment used to log, construct roads, and chip biomass on-site. The agency failed to consider emissions from transporting the trees to the biomass facilities many miles from the project area. The agency failed to calculate the substantial amount of carbon released from soil respiration during logging and the forest’s reduced capacity for carbon sequestration after logging. Further, in calculating the total cubic feet of biomass that will be removed from the project area and burned at biomass facilities, the agency counted only the biomass (and thus eventual emissions) from the standing trees that remain, and excluded all downed wood in the project area, even though downed wood may be removed for energy generation.

    51. The agency also failed to adequately explain how it calculated emissions and makes several unsupported assumptions. For example, without explanation, the agency assumes the biomass energy produced from the Project would offset energy otherwise produced from fossil fuels, and thus unfairly offsets emissions estimates despite increasing energy demand.

    52. Both Plaintiffs timely appealed the Forest Service’s Angora Project decision, and on October 7, 2010, the Forest Service’s Appeal Reviewing denied the appeal.

    53. The Forest Service’s own science concludes that: a) there is not a present fire risk within the Angora fire area due to the recency of the Angora fire and the low fuel levels; b) there will not be any significant potential for fire within the Angora fire area for at least several years, even if no action is taken; c) the only woody material with any significant relevance to wildland fire behavior and intensity is small-diameter trees, logs, and branches less than about 10 inches in diameter; and d) the only effective way to protect homes from wildland fire is to reduce the ignitability of the home itself (a homeowner responsibility) and reduce brush and small-diameter fuels within at most 200 feet of individual homes and administrative structures. All or nearly all of the Project Area is beyond the 200-foot zone around homes, and the suitable black-backed woodpecker habitat at issue is not adjacent to homes within the 200-foot zone but, rather, is hundreds of yards, or more than a mile, away. …

    Case 2:11-at-00190 Document 1 Filed 02/11/11 Page 13-14 of 18

    BTW: The black-backed woodpecker card is played in the context of the Forest listing it as a “management indicator species” (MIS) and is played re: the 1982 “species viability requirements” of NFMA. I’ll not take time to embed quotes here/now.

    Reply
    • Let’s take these knowledge claims one at a time.

      47a.“The project will remove 1,398 acres of live, dead, and downed trees and other forest materials.” and cites the EA at page 1-14.

      Looking further in the EA we find “Fuel removal of standing dead and downed wood with thinning of live trees, based on desired residual basal area of 80 square feet per acre, to improve residual tree vigor.” Hmm. sounds like SOME trees will be removed from the 1398 acres..it’s not clear what percentage of the living and dead biomass it is.

      Also, it appears that some snag areas will be left interspersed in each stand: Manage for 220 acres of wildlife snag zones spread across the
      tree cutting and thinning areas, a total of 12 zones within the 12
      project stands. There are 5 zones of “Leave” prescription (87 acres), 4 zones of
      “Leave/Plant” (56 acres), 1 zone of “Modify/SEZ” (39 acres), and 2 zones of
      “Modify/Subdivision” (38 acres). This totals 77 acres of modified treatment and 143
      acres of no tree cutting. (p 1-14)

      47b. If going to a biomass facility is bad, then not-going must be good. How can both things be bad? Unless they’re saying they need to redo the EA to reflect not-going. But why?

      48a.“Logging, transporting, and burning trees and other forest biomass to generate energy emit substantial amounts of greenhouse gases.”

      Burning forest biomass in and of itself (without the transportation element) is generally thought to release carbon that will be re-sequestered when vegetation grows back.

      But I think the key description is what else would happen if the biomass plants are closed. If you would pile and burn anyway, you would no doubt drive to the site and use chainsaws. So the added CO2 to get to a biomass plant would be to chip onsite and to fuel trucks to get to the plant. Those chippers and trucks could conceivably be powered by biofuel, but technologically we may not be there yet.

      Also I don’t know that those are “substantial amounts” of GHG’s. Don’t know how many trucks you need for the amount on those acres, but probably more trucks go weekly to service the Safeways in the Lake Tahoe Basin. Seems like “substantial” should be related to something. If it’s in relationship to 0, then anything is “substantial” (infinitely, to be precise).

      48b. “In fact, burning woody biomass for energy results in higher carbon emissions per unit of energy generated than burning fossil fuels, including coal, oil, or natural gas.”
      I don’t know about the total- haven’t checked. But this number doesn’t take into account the re-sequestering effect (BTW, I made up that term). If we didn’t remove the trees from the site, then new trees wouldn’t be able to take up CO2.

      49. “As is required by NEPA, the Forest Service attempted to calculate the Project’s greenhouse gas emissions.”
      I would argue that NEPA doesn’t require the FS to calculate greenhouse gases. Asserting it doesn’t make it so. If someone raises it as an issue in scoping or comments, then it should be addressed. Even if GHG’s are addressed in the document, there is no requirement that it be addressed quantitatively.

      50. a “The agency failed to calculate the substantial amount of carbon released from soil respiration during logging and the forest’s reduced capacity for carbon sequestration after logging.” I’m not sure about this.. in fact, I’m not even sure what “logging” is. I’m assuming that they mean dragging trees using equipment, and not thinning and hand piling. If I don’t know, how could a judge decide, let alone how substantial it is or isn’t?

      50b. “Further, in calculating the total cubic feet of biomass that will be removed from the project area and burned at biomass facilities, the agency counted only the biomass (and thus eventual emissions) from the standing trees that remain, and excluded all downed wood in the project area, even though downed wood may be removed for energy generation.” I am confused by the use of the terms “remain” and “removed”. If the trees remain, why would the agency count them as biomass that will be removed?

      51. “For example, without explanation, the agency assumes the biomass energy produced from the Project would offset energy otherwise produced from fossil fuels, and thus unfairly offsets emissions estimates despite increasing energy demand.”
      So, if we follow this argument, a) energy use is increasing so b) therefore you shouldn’t calculate biomass as replacing fossil fuels. If it is replacing fossil energy used in the next few years, then it doesn’t matter if total energy is “x” or “x+y”, z biomass energy still replaces z fossil energy. Their logic seems unclear.

      Reply
  3. There is no lack of snags in the Tahoe Basin, as well as in the Sierra Nevada. Today’s salvage projects leave significant portions of wildfires out of project boundaries, as well as designating wildlife snags or clumps within project units. My last salvage project only treated 55% of the wildfire, leaving it for snag-dependent critters. Hanson wants to end ALL harvesting on public lands, both Federal and State. He also doesn’t include comprehensive carbon studies of his own, ignoring the GHG releases of rotting wood and inevitable re-burns. Hanson continues to contest each and every salvage project and MIS analysis for the black-backed woodpecker. These birds migrate from wildfire to wildfire, as part of their natural life. Historically, fires didn’t burn as intense as they do today. The birds didn’t have as many snags to feast upon as they do today. Hanson’s goals for the black-backed woodpecker are ultimately unsustainable. He even feels that dead trees along roadsides are “critical habitat”, and has sued to preserve them.

    My Yosemite example is perfect for showing how much carbon and GHG’s go up in untreated fire areas. What used to be majestic 400 year old pine stands is now barren wasteland, where even brush is having a hard time regenerating. The giant old snags had fallen over and are now vaporized in only 20 years. Yep, 400 years worth of sequestered carbon went up in smoke.

    Does anyone really think that 200 feet is adequate for fire safety? No one is saying that we need quarter mile clearcut fuelbreaks but, how many firestroms have been stopped by 200 foot non-commercial thinng strips? I have seen where embers have went for over a mile, igniting new spot fires ahead of flame fronts. Fuel loadings in Tahoe are off the charts, due to overstocking, unnatural species composition and unsalvaged bug trees. “Pristine”, it is not!

    Reply
    • Does anyone really think that 200 feet is adequate for fire safety?

      Cohen, Jack D. 1999. Reducing the Wildland Fire Threat to Homes: Where and How Much? USDA Forest Service Gen. Tech. Rep. PSW-GTR-173. 1999 (pdf):

      Research Conclusions
      [Structure Ignition Assessment Model] modeling, crown fire experiments, and W-UI fire case studies show that effective fuel modification for reducing potential W-UI fire losses need only occur within a few tens of meters from a home, not hundreds of meters or more from a home. This research indicates that home losses can be effectively reduced by focusing mitigation efforts on the structure and its immediate surroundings. Those characteristics of a structure’s materials and design and the surrounding flammables that determine the potential for a home to ignite during wildland fires (or any fires outside the home) can be referred to as home ignitability.

      The evidence suggests that wildland fuel reduction for reducing home losses may be inefficient and ineffective: inefficient because wildland fuel reduction for several 100 meters or more around homes is greater than necessary for reducing ignitions from flames; ineffective because it does not sufficiently reduce firebrand ignitions. To be effective, given no modification of home ignition characteristics, wildland vegetation management would have to significantly reduce firebrand production and potentially extend for several kilometers away from homes.

      Reply
      • Yep, and the Japanese thought their reactors were safe from earthquakes and tsunamis.

        No worries about those worst-case scenarios, as dead forests don’t usually burn at higher intensities than highly flammable green trees. No worries about extreme fire behaviors (if you don’t live in the west). No worries about 22 million acres of dead trees (unless intense dry lightning or 20 Arab arsonists decide how much of it they could torch).

        Of course, you don’t have the same goals and use the same treatments and techniques outside WUI. Fire safety is an issue but, not the sole issue in projects more than 200 feet from homes. Preservationism strictly excludes beneficial mitigation and forest health projects.

        Hanson has a good gig, without that annoying integrity to get in the way. As another southern eco-lawyer was known to say, “Hey, it’s just business!”. Hanson also got the courts to decide that only roads maintained for passenger car use are worthy of hazard tree removal for public safety. It’s no wonder that even the Sierra Club disowned him. He’s a forest management “denier”. I’ll bet he would even sue if the Forest Service decided to close some of his loopholes. This is a perfect example of how the new Planning Rule will foster more loopholes in courts.

        Reply
  4. But Dave as I’ve said on this blog before.. this is a Science Policy Situation That Shouts Watch Out!
    Here’s a quote from that post. Also here’s a post with a link to the Warm Lake Fire Study-which arrived at different conclusions about the utility of fuel treatments. Note that Jack is a physical scientist and not an expert on fire suppression or firefighter safety. In my experience, when houses and wildfires mix, firefighters are there and their safety should be the critical issue.

    Of course, you and I had that discussion already in the comments to those posts. Having had a wildfire near my suburban (not rural) house two weekends ago and watching the firefighters stage themselves on our subdivision roads and preparing to light a backfire in back of a neighbors house (no trees around here).. I would say that 150 feet idea wouldn’t sell very well here. Firefighters need a place to work.

    Situation 3. When Scientists Frame the Issue. This is a situation that occurs more frequently than desirable, and is actually the source of unnecessary tension between scientists and managers. Here is the way this dysfunctional cycle operates. First, there is a pot of money, to be distributed through a competitive process with a panel of other scientists. A scientist writes a proposal with a certain framing (e.g., fire protection of people and their communities is the same as protecting houses). Since none of the communities involved are at the table, and the framing sounds plausible to the other scientists, the proposal is funded. Then the scientist does the work. When they hear about the research results, managers then ignore the results, or only partially use them, because the results aren’t relevant to their framing of the issue. The last step of the cycle is that the managers are accused of “not using the best available science.” I have seen this cycle play out many times.

    The scientific evidence is clear that the only effective way to protect structures from fire is to reduce the ignitability of the structure itself (e.g., fireproof roofing, leaf gutter guards) and the immediate surroundings within about 100 feet from each home, e.g., through thinning of brush and small trees adjacent to the homes (www.firelab.org–see studies by U.S. Forest Service fire scientist Dr. Jack Cohen)

    In this case, the difference in framing is as simple as it’s not about the structures- it’s about the fact that people don’t want fire running through their communities. It is about all kinds of community infrastructure, stop signs and power poles, landscaping, fences, gardens, trees and benches in parks, people and pets and livestock having safe exits from encroaching fires. It is about firefighter safety and about conditions for different suppression tactics. That’s why fire breaks of some kinds around communities (not just structures) will always be popular in the real world. Of course, people don’t actually fireproof their homes either in the real world. “How can we best keep wildfires from damaging communities and endangering people” would be a more complex, but more real framing of the question. Note that one scientific discipline can’t provide the answer to this framing- there are elements of fire science, community design, fire suppression practice, sociology, political science and economics.

    Indeed, I would hope that fire suppression practitioners would be the key voice to be listened to in this case.

    Reply
  5. Note that Jack is a physical scientist and not an expert on fire suppression or firefighter safety.

    So what? I never implied that he was or needed to be.

    In this case, the difference in framing is as simple as it’s not about the structures- it’s about the fact that people don’t want fire running through their communities.

    Fine with me. Let them pay for it!.

    It is about firefighter safety and about conditions for different suppression tactics.

    Yes! And? Maybe we need thoughtful public deliberation as to when and where, and especially why wildland fires are fought.

    Of course, people don’t actually fireproof their homes either in the real world.

    Why not? Because they get subsidized and don’t get penalized by the rest of us for not doing so. Although this is changing due to emergent building codes thanks in part to researchers like Cohen.

    Reply
    • Yes! And? Maybe we need thoughtful public deliberation as to when and where, and especially why wildland fires are fought.

      Absolutely.. This is the sort of conversation that will need to occur to move fire policy from “appropriate management response” to “strategic management response” as I discussed in a past post. Upfront agreement on the role of fire in various ecosystems and places and strategies for protecting human communities, including the steps that those communities will need to take on their own.

      Reply
      • The first step would be bringing the fire folks and their programs under NEPA. If they cannot stand under the spotlight of required analysis and process, then they shouldn’t be public policy.

        Reply
        • If you are talking about wildland fire use, then forest plan amendments with accompanying NEPA are already required. If you are talking about decisions made regarding actions to suppress a wildfire, I am curious about what sort of NEPA you would like to see. Should it be at the national policy level? If so, would the new planning rule be an appropriate vehicle? What about other federal agencies?

          Reply
  6. Since it is clear that the Forest Service is planning for such Let-Burn fires, by the sheer existence of “Maximum Management Areas”. They need to do the official NEPA on that acreage, analyzing the effects, impacts and mitigations. These plans would never qualify for a CE, so why do they get a free pass when citizens and public lands are substantially affected by letting a wildfire burn. There are plenty of examples where the public was not consulted.

    Then, there is also the ESA issues within the MMA’s. How come the fire folks get a “free pass” to burn up habitat, while timber management has to do exhaustive NEPA and weather the gauntlet of litigation?? It seems silly that it is OK to burn up a MMA but, to salvage the same burn, it will require an EIS. I think it would be OK to set limits on how many acres can be allowed to burn under “firefighting tactics” but, they MUST use the closest logical fireline locations. We cannot afford to wait 6 weeks for a wildfire to burn 40,000 acres, especially in the middle of fire season. Suppression resources are even more scarce this year, and we cannot afford to tie them up for so long, in the middle of the summer.

    A National NEPA process for MMA’s could lay out the groundwork but, I think each MMA must be evaluated for a myraid of issues and impacts. Up to 100,000 acres of fire should merit formal required studies. Sure, it isn’t going to be easy but, science and law MUST be followed, instead of our fire folks just “winging it”. How come foresters are held to a higher standard than the fire folks? My choice would be that Let-Burn fires can only be allowed on treated acreages. As more treatments are accomplished, more acres will be ready for “natural fire”. (Sounds “strategic” to me!)

    Reply
    • Since it is clear that the Forest Service is planning for such Let-Burn fires, by the sheer existence of “Maximum Management Areas”. They need to do the official NEPA on that acreage, analyzing the effects, impacts and mitigations.

      I’m confused. MMAs apply to wildland fire use. Wildland fire use requires NEPA and ESA consultation. The NEPA I have seen has been in the form of EAs not CEs. Are there forests that are employing fire use without having amended the forest plan (with appropriate NEPA)?

      Reply
      • While the fire folks use NEPA-like concepts and ideas, they don’t follow proper, legal process. I can’t imagine that a 100,000 acre MMA doesn’t have any ESA issues. Simply saying that a Let-Burn fire has no significant effects carries no weight without the site-specific studies that the ESA and NEPA requires. Where are the air quality studies? Where are the water quality studies?

        This problem will come up again and again and again. These Let-Burn fires simply do not adequately address the issues, and go directly against the Clean Water, Clean Air and Endangered Species Acts. The Rogue River-Siskiyou National Forest has tried twice to ramrod their Let-Burn program through formal NEPA, running into opposition they could not satisfy. Mike D. knows those issues better than I do.

        Reply
  7. Wildland Fire Use are not the only fires which are allowed to burn in my experience. The Forest where I’m at in Idaho, they have often in the past allow fires to burn and just do structure protection. I believe they still classify them as suppression fires and put a team on them, but only seem to protection. In 2006 they had several fires that were called suppression but were basically allowed to burn. That fire season wasn’t very severe, and most of the fires burnt under inversion conditions, and tended to smolder around and not stand replace or make large runs. These fires were basically in back country roadless areas. The backcountry village of Yellow Pine was smoked in most of the summer, and had to cancel their annual Harmonica Festival which brought a lot of business to the local store, café, and taverns.

    I was on the BAER team, and it looked like the fires did much more good than bad. Then comes 2007, a much drier year. The District FMO was interviewed for an article that spring and was quoted as saying something to the effect “that if they wanted somebody who would wait till September to turn a fire loose then they hired the wrong guy” They had a lightning start in early July which the Forest chose to put in monitor status and provide structural protection. It was situated between two of the smaller 2006 fires. The fire didn’t do much for a week or so, but then all hell broke loose. Warm dry temperatures backed by winds. In the end the fire joined with others and formed a complex of over 700,000 acres and was on 3 National Forests. The burnt area was about 100 miles long by ten miles wide, much of which was stand replacing. The fires never went out till late September

    Big columns of smoke rose ever afternoon with white thunder heads rising above the smoke. Yellow Pine had to cancel the Harmonica Festival for the second year in a row, and lost the powerline to town. Idaho Power had to bring in a portable generator, until the power could be restored that fall. BAER spent millions after the fire, repairing roads, seeding, mulching, upsizing culverts, bale bombing. Much of the burn was stand replacing. The next summer the area had considerable damages from flash floods coming off the burn area. The South Fork Salmon River ( home to 3 listed fish species) still runs black in the spring. Recently Western Pine Beetles have taken their toll on large Ponderosa Pine which underburned in 2006.

    Then in 2008 I was out past Yellow Pine and saw a fire smoldering in spruce, lodgepole, subalpine fir in an unburnt island in the 2007 burn. I asked the fire guys what the deal was. They said it wasn’t going anywhere and was going to burn sooner or later. That may be true but, I kind of think it would be nice to hold on to some older stands in that type since so much of it had al ready burned. I guess since this was mostly roadless, nature and the fire guys know best.

    Please note this is my take on it and others probably see it different. And the 2007 fires were extreme, but I did not see any NEPA.

    Reply

Leave a Reply to Dave Iverson Cancel reply