New Project to Watch: Iron Springs Vegetation Project

iron springs mpaInteresting how this project is characterized in Courthouse News here…I think the write of the article said “4890 acres of commercial logging.” But in the next paragraph quoting the plaintiffs it says that there are 381 acres of precommercial thinning. So I think you need to subtract that to get a total of commercial. But as we see below the commercial distinction is fairly fine.

SALT LAKE CITY (CN) – Uncle Sam refused to prepare an environmental impact statement before approving a 5,000-acre logging project in southern Utah that threatens rare and endangered species, including spotted and flammulated owls, goshawks, and three-toed woodpeckers, environmentalists claim in court.
The Alliance for the Wild Rockies and the Native Ecosystems Council sued the U.S. Forest Service and Dixie National Forest Supervisor Angelita Bulletts, in Federal Court.
The Forest Service in March approved the Iron Springs “vegetation improvement and salvage project,” authorizing 4,890 acres of commercial logging in Dixie National Forest.
“Among other things, the Forest Service’s decision notice authorizes 3,603 acres of spruce/fir commercial logging utilizing ground-based skidders, at least 1,927 acres of which will occur in old-growth stands, 366 acres of commercial sanitation and salvage logging, 381 acres of precommercial thinning, 152 acres of regeneration logging, and 388 acres of ‘aspen cleaning’ in aspen stands, for a total of 4,890 acres of logging,” the complaint states.
“The decision notice also authorizes road reconstruction and maintenance activities on 36.16 miles of existing roads and 9.61 miles of new, temporary road construction to facilitate logging activities.”
The plaintiffs claim the Forest Service approved the project without preparing an environmental impact statement, “instead finding that the authorized activities would not significantly affect the quality of the environment.”

Sensing that this will be an interesting project to consider (since we’ve never analyzed ones in Utah that I recall), I went to the project website here and found this explanation of why they were doing it.

Treatments within Engelmann spruce/subalpine fir stands Within the project area, there are 5,240 acres of Engelmann spruce/subalpine fir. Approximately 3,603 of these acres would be commercially thinned to reduce stand densities while maintaining a variety of tree sizes. Individual tree marking would designate trees that would be harvested. In addition to the commercial thin, there would be salvage and sanitation harvest of pockets of Engelmann spruce killed or infested with spruce beetle.
Approximately 381 acres of the 3,603 acres of treated spruce/fir stands would also be precommercially thinned to remove trees less than 5-inches diameter that exceed stand density objectives or species mix. Trees greater than 5-inches diameter would be removed commercially.

Trees between 5- and 7.9-inch diameter size class that cannot be sold commercially will be included in the pre-commercial treatment. Approximately 388 acres of scattered aspen clones
within spruce/fir stands would receive aspen cleaning through hand felling of conifer. Within aspen clones commercial-size conifer would be removed; non-commercial-size conifer and some
aspen would be cut and left on site to discourage browsing by larger ungulates, primarily deer, elk, and livestock.

Under the criteria in “Characteristics of Old-Growth Forests in the Intermountain Region” (Hamilton et al. 1993) and a 2007 Regional Office letter (USDA 2007) clarifying meaning and
intent in Hamilton et al. 1993, 2,058 acres of spruce/fir within the project area have old growth characteristics. This determination was made based on an evaluation of existing stand data and new data collected during field surveys. These data and findings are included in the project record. Thinning is needed in these stands to reduce the risk of timber loss due to beetle kill and to forestall the spread of beetle activity to additional trees. Thinning in these areas will be done from below, and will be restricted to trees between 5- and 18-inches diameter.
Of the 2,058 acres with old growth characteristics, 131 acres would not receive treatment. Of the 1,927 acres treated, approximately 1,541 acres would retain old growth status following treatment. Thus, of the 2,058 acres with old growth characteristic, approximately 1,672 acres would retain old growth characteristics. The Forest Plan requires that 7 percent to 10 percent of each drainage be managed as old growth. Retention of 1,672 acres as old growth exceeds the Forest Plan requirement in each drainage within the project area. Details are provided in the Forest Vegetation Report.

Spruce beetle-infested or killed trees throughout the project area would be removed using sanitation/salvage timber harvest and commercial removal. Some stands that contain infested or killed subalpine fir would also be commercially removed. Merchantable, dead standing, and down spruce and fir would be harvested.
Approximately 366 acres in the spruce/fir stands are currently at the desired density. These 366 acres would receive commercial sanitation/salvage treatment only.

Finally, approximately 154 acres would be planted with Engelmann spruce seedlings using hand tools or augers. These areas are conifer strips in the south half of the project area that were
clearcut in the 1960s and that do not contain the desired tree stocking.

I’m sure all the regular followers of this blog will spy a number of interesting things.

1) Is the 152 acres the same as the 154 that they are planting due to not enough stocking. If so, is planting trees the same thing as “commericial logging”.

2) Everyone loves aspen, but if you try to get more by cutting conifers, that’s bad. Or only if you sell them? What difference could it make? 388 acres of hand felling?

3) “Trees greater than 5-inches diameter would be removed commercially.” That’s a good market.

The “issue” with the plaintiffs is that “they should have done an EIS”. Somehow I don’t believe that is really their goal. Plaintiffs are being represented by the Northern Rockies Justice Center here. I think it’s interesting that their mission is in the NW, but they are doing work in southern Utah.

I wonder if a simple statute were passed that required cases (say, as a trial run, FS cases involving vegetation management) to go to mediation prior to litigation, and the mediation record was available to the judge when ruling, and the mediation documents were also publicly available. This could be tried as a pilot anyway.. perhaps starting with this case? Rider, anyone?

20 thoughts on “New Project to Watch: Iron Springs Vegetation Project”

  1. IMHO depends on how the Administration’s buds feel about it, but really I don’t see a rationale for why you would be against it.

    Interestingly, Utah requires mediation in divorce settlements for these reasons.
    Here’s the link.

    Why is mediation required?

    Mediation is appropriate in family related matters because it encourages collaborative problem solving by the parties. Mediation provides the greatest opportunity for direct communication and the sharing of information that can be critical to the successful resolution of disputes and when children are involved, the implementation of parenting agreements. Mediation offers an environment well-suited to identifying and addressing the strong emotional issues associated with divorce and parenting conflicts. Mediation is structured to focus parties on a common interest: the resolution of the disputed issues and when children are involved, the future of their children. The informality and flexibility of the mediation process allows issues to be discussed that might otherwise be raised in a more adversarial or narrowly-focused process.

    The benefits of mediation include:

    You directly participate in finding solutions to the issues in dispute;
    Mediation allows you to resolve your case more quickly;
    Mediation is less expensive;
    Mediation promotes relationships and you will end the process with a better relationship with your former spouse; and
    Mediation is less stressful than court.

    Strong emotional issues.. focus parties on a common interest… less expensive.. what’s not to like?

    The only addition I might add is that if it goes on to court after mediation, a public review of the plaintiff’s science claims and agency responses would be required also prior to court. Because at the end of the day, it’s really not about the science so the mediation would help with that, but the values implicit in the science would need to be picked out before it went to court.

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  2. “The only addition I might add is that if it goes on to court after mediation, a public review of the plaintiff’s science claims and agency responses would be required also prior to court.”

    Good idea, but unfortunately, as you also note, “at the end of the day, it’s really not about the science”. Two major factors making this so are 1) when judicial review is limited to the “administrative record” (i.e. plaintiff can’t bring in outside scientific evidence), and 2) so-called “deference to agency expertise”. Both of these factors, to the extent that federal judges adhere to them (and they often do), help to stack the deck against plaintiffs. The Forest Service often argues, in effect, that the relative merits of plaintiff’s and defendant’s science is immaterial, since if the agency can point to anything remotely resembling science in its decision-making process, then deference to the agency trumps any scientific arguments the plaintiff could make. Many folks complain about “procedural” litigation, but that’s in the nature of the NEPA beast, and if things ever evolve so that plaintiffs can truly bring substantive (including scientific) issues into NEPA litigation, then I expect that federal agencies will soon long for the good old days of procedural suits.

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    • Guy K.: I have mostly avoided politics during the past several decades, but couldn’t figure out how such bad scientific information was being interpreted by the courts. Your “deference to agency expertise” says it all. I had no idea that this perspective existed, but the fact that it does explains a lot. I’m not saying “agency science” is necessarily bad — but a lot of it really is, and all of it should be open to public and independent scientific review before it is ever integrated into law or policy well before hitting the courts. Thanks for the insight!

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    • I bristle at the idea that “Agency expertise” is, somehow, wrong, or “captured”, or slanted. Forest Service “Ologists” protect their “turf” very well, and any accusations MUST be backed up with evidence. Branding all these scientists in this way is exceedingly disrespectful. Just saying and assuming that the scientific deck is stacked, isn’t evidence. You need to prove that the site-specific science is wrong, and harmful. “Newer” science isn’t necessarily “better”. When the site-specific science is inconclusive, that is where the Agency’s deference comes in.

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      • Larry: First and foremost, I am in total agreement with your thoughts on “site-specific science.” It is definitely needed, rather than the homogenized stuff we’re currently dealing with. I’m not sure what accusations I’m making — other than “a lot” of agency science is bad — but I don’t see where I’ve branded “all” agency scientists with this statement in any way. I am pretty sure the Ologists that your are thinking of are different than the “agency scientists” I’m imagining. And you are right — I really have lost a lot of respect for “a lot” of the agency scientists I’ve worked with and read through the years. Others are brilliant and among the best forest scientists ever, in my opinion. And I have spent the better part of 30 years disproving many of the assumptions, statements, and “findings” with actual documentary evidence. I think you are probably aware of some of these efforts. Please note my next-to-last sentence. It is my opinion that much of the “science” being used by USFWS to affect public policies is bogus and should have been reviewed independently and publicly long before hitting a courtroom. We may be talking about different situations (court vs. field?), and you are far more familiar with those methods than I am. So far as “newest” science is concerned, please note that the legislation we are dealing with was written in the 1960s and 1970s and has not been significantly updated since then. (And by “bogus” I mean scientific information based on assumptions of little or no human presence in the environment prior to white occupation.)

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        • Of course, I was replying to Guy but, I was also talking about the Ranger District level “Ologists”. While I know a little about this and a little about that, these folks are the experts, applying the latest science, where it is applicable. Yes, they are apparently directed, at times, to justify a scientific point of view but, that seems to be attributed to which side is in power. An excellent “Ologist” will find ways to mitigate and protect areas of concern. It is their ability to reach a consensus to achieve the “greater good” that is needed in today’s Forest Service.

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  3. Here’s a great (IMO) law review on the subject of NEPA and scientific deference to the agency by the courts. http://www.vjel.org/journal/pdf/VJEL10087.pdf

    I think it’s worth a careful read, but a few excerpts illustrate why typically plaintiffs litigating against a FS decision don’t get a chance to have their scientific arguments heard, they instead have to show that the agency’s scientific evaluation was “arbitrary and capricious” (rather than merely weak or just plain wrong), which sets the bar very high indeed. From the Magee article: 9th Circuit said “questions involving ‘resolution of factual disputes between the [agency’s] scientific conclusions and those of [petitioner’s] experts…are subject to the arbitrary and capricious standard of review.” From another case: “it is not the role of courts to ‘second-guess the scientific judgments of the EPA’…and we give considerable latitude to the EPA in drawing conclusions from scientific and technological research, even where it is ‘imperfect’ or ‘preliminary.’” And from another ruling: “a federal court is not in the business of resolving scientific disagreements between plaintiffs’ experts and the [agency’s] experts.” And one more, from the U.S. Supreme Court: “when specialists express conflicting views, an agency must have discretion to rely on the reasonable opinions of its own qualified experts even if, as an original matter, a court might find contrary views more persuasive.”

    If the agency has been acting in good faith, and can demonstrate its use of high scientific standards (e.g., good experimental design, appropriate sampling, careful record-keeping, objectivity) and truly possesses a high level of expertise in the area in question (e.g., ecology, wildlife biology, soil science, whatever) then this policy has merit. But if the agency simply waves the agency deference flag as a legal defense, to avoid scientific scrutiny of its methods and analysis and conclusions, then that would be inappropriate. Thanks for reading, -gk

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  4. Interesting timber sale. Never paid much attention to Utah before. Now I can see why the AWR takes interest in this sale…it proposes to intervene to SAVE the old growth. A “commercial thin” is somewhat unusual for Spruce/fir…and it’s obvious regeneration is not the goal here. Lets see, the spruce beetle, which apparently isn’t as bad as in Colorado, is killing off the old growth spruce…and the USFS wants to thin out the smaller fir to save what’s left of the old growth. What a noble endeavor indeed. The beetle is bad enough that the old growth has been reduced by 50% (plus or minus). Give it five years when the rest of the old growth is dead…than do a salvage sale…which will have no opposition. It’s best to let the old growth die…and everyone will forget about the goshawk. Because enviro rule #1 is…if nature kills the goshawk…it never happened. The AWR is so lost in its paranoid deep ecology dogma that it feels these “do gooder” timber sales are just an excuse to cut big timber. That’s why the litigate all the WUI timber sales in Montana.

    This sale didn’t list volume harvested. The spruce/fir salvage sales in Colorado harvest 50-90 MMBF…a huge number. And it dawned on me the other day…that with all the stories about timber harvest in Colorado…we have not heard from one “radical” enviro opposing such salvage timber sales (except Bob Berwyn…who I respect). But the total absence of any such comments, in a state that has a huge population including a huge enviro population, is a bit befuddling. I’m guessing they’re so “shell shocked” by the various beetle epidemics. You see, they live amongst it. I’ve said it before, but it appears that increased “unlitigated” timber harvest can only occur where the majority consider themselves to be enviros.

    A short response to Guy. It seems to me it’s a gray area…that a judge mixes himself up in the science and expertise he is supposed to “defer to” when he is determining whether the agency action is “arbitrary and capricious.” I’d say that in many of Judge molloy’s rulings in Montana he is dissecting the science to determine the “arbitrary and capricious” findings. I can think of cases where he “second guessed the USFWS biological opinions.”

    I’m also going to throw in that the courts are a lousy place to manage for “species diversity or species viability,” in that the courts only focus on the species listed in the complaint…to the detriment of all other species. Real tunnel vision here. The end result is the “tyranny of the single species” that we see throughout the West. I don’t think the Goshawk was ever listed…as anything…but since efforts to even list it in the 90’s, and some 9th circus ruling to examine listing, it carries a lot of clout. I bring up this species because this whole timber sale revolves around two goshawk nests.

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  5. Guy: Thanks much for the insights. This explains a lot. I’m glad you decided to become a lawyer! When I rail against lawyers in this blog, I’m not talking about people like you — but I’ve probably been talking about some people that have been constrained by these types of rulings and didn’t have any other options.

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  6. Derek- just a comment, not in regards to this or any other specific timber sale, but regarding the “tyranny of the single species” and your points regarding northern goshawk (i.e., “I don’t think the Goshawk was ever listed…as anything…but since efforts to even list it in the 90′s, and some 9th circus ruling to examine listing, it carries a lot of clout.”) The real reason the northern goshawk (which you are correct is not ESA-listed) carries clout is because it is a MIS (management indicator species) for old-growth habitat in most (though not all) of the Northern Region National Forests. In the Forest Service’s own words: “Under the National Forest Management Act (NFMA), the Forest Service is directed to “provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives.” (P.L. 94-588, Sec 6 (g) (3) (B)). The 1982 regulations implementing NFMA require that “Fish and wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native vertebrate species in the planning area.” (36 CFR 219.19) Management Indicator Species (MIS) is a concept used by the agency to serve as a barometer for species viability at the Forest level.” In other words, a MIS serves as a “proxy” for a diversity of old-growth-forest animal species.The MIS species for each national forest are listed in the forest plan (you can look them up), along with the “maintain viable populations” language mandated by the NFMA. So, the requirements were imposed by Congress, and the MIS species were designated by the Forest Service. That’s the source of the “clout”, not environmental litigation. Best, -Guy

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  7. Thanks Guy for the history lesson on MIS…I never knew the source (NFMA), but nobody ever litigates for the MIS white tailed deer. And it doesn’t change the fact that whether it’s an ESA or MIS species, it is the species that is in front of the judge at the time that he rules on… to the exclusion of all other species. Is that not so? It’s myopic.

    Half the Kootenai National Forest is managed, or I should say forest management is excluded from, because of the grizzly bear…despite repeated efforts to do so… and repeated efforts my judge molloy to remand it back to the USFS. Now, when Molloy made his rulings based on the grizzly bear, did he also consider elk? Of course not. I’d call that a “single species tyranny.” I’ll stand by my statement that the courts are a lousy place to manage species for “viability or diversity.”

    NEPA, NFMA, and ESA litigation has become an industry in itself…one that produces nothing. But thanks for helping to clear up the intricacies and nuances of the litigation. I hope you continue to do so.

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  8. All MIS were selected ‘because their population changes are believed to indicate the effects of management activities.’ Beyond that, MIS could have been chosen for different reasons (‘where appropriate’). ‘Species commonly hunted, fished, or trapped’ was one reason, so whitetail deer and elk are often listed as MIS in land management plans. Other species were selected ‘because their population changes are believed to indicate the effects of management activities on other species of selected major biological communities or on water quality.’ Species on state and federal at-risk lists, and species with ‘specific habitat needs that may be influenced significantly by planned management programs’ could also be selected. However, risk to ‘viability’ was not a specific criterion for selection of MIS.

    That being said, most plans include MIS for which continued persistence in the plan area is a concern, often because it was also designated by the Forest Service as a sensitive species (species for which ‘viability’ IS a concern). Where viability is a concern, there are some legal requirements that the Forest Service must meet. (Whitetails don’t seem to have that problem most places.)

    So courts usually to have to look at how the Forest Service has considered individual species, but they rarely tell the agency how to manage them. Courts normally stop at telling an agency what it did wrong. They typically remand a decision to the agency to fix the problem. The agency is then responsible for meeting its obligations to look at the consequences (on other species for example) of the fixes they are considering.

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  9. thanks Jon, for your clarification, I can see that the language I cited could be misleading on the distinction between MIS and sensitive species. Northern goshawk, as far as I know is not a sensitive species in Region 1 (though it is in Region 2, where it also is a MIS in several Region 2 forests).

    The Nez Perce NF may be a good example, since even though goshawk isn’t a sensitive species, the NPNF Forest Plan requires the FS to “Monitor population levels of all Management Indicator Species on the Forest. These include bald eagle, grizzly bear, gray wolf, peregrine falcon, elk, moose, bighorn sheep, pileated woodpecker, goshawk, pine marten, fisher, westslope cutthroat trout, summer steelhead, and spring chinook. These species have been selected because (a) they are threatened and endangered; (b) they have special habitat needs that may be influenced significantly by planned management programs; (c) they are commonly hunted, fished, or trapped; (d) they are non-game species of special interest; or (e) their population changes are believed to indicate the effects of management activities on other species of selected major biological communities or on water quality.” -i.e., that’s where NFMA comes into play for goshawk on the NPNF: the need for FS to follow its own forest plan.

    The same NPNF plan elsewhere indicates obligations for sensitive species (not including goshawk): “Habitats will be maintained to provide for population viability of all sensitive species including the wolverine, big-eared bat, Harlequin duck, boreal owl, and common loon.” thanks, -Guy

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  10. Goshawk was recently removed from the R1 sensitive species list. At the time current plans were developed it was a sensitive species on some units. In any case, if a plan includes specific requirements for goshawk (for viability, monitoring or otherwise), as you say, the requirements in a plan must be followed.

    Thanks for the helpful overview of how science is addressed by the courts. Regarding some of the concerns expressed by others, I’m sure there are times that agency science is not the latest and greatest, if for no other reason than the agency doesn’t dedicate a lot of its staff time to reading research reports. But it is also true that any application of science is vetted through the public NEPA process where ‘better’ science or flaws in the application of science could be pointed out to the agency.

    Back to the process questions that Sharon was asking – mediation is most useful where the long-term relationship of the parties is really important (which is especially true when children are involved). I don’t think there are a lot of similarities in this regard between timber sales and divorce mediation.

    I guess I’m going to suggest that better collaboration could serve much the same purpose as mediation. How about starting to work with the public at step one instead of step four? I saw no indication in this record that the public was involved in the choice of the location of the project, the determination of the desired conditions or the purpose and need for the project. If the conversation starts with ‘what don’t you like about our proposal,’ the battle-lines are already drawn.

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    • Jon: I was also pleased with Guy’s description of how science is addressed by the courts in regard to ESA. It certainly broadened my understanding of the process and provided good insights as to where the problems are and how to best address them. I’ve been blaming lawyers for keeping newer and better understandings of the sciences involved in this process, when the actual problem seems to be the process itself. But why wasn’t this hurdle clearly identified and made public 20 years ago?

      I’m in total agreement with your suggestion that the public be allowed to participate in these processes from the very beginning as a project is first taking shape and identifying objectives. By the time the public is allowed to “comment” (or whatever term is used) under current practices, their perspective — as you point out — is adversarial. The government agencies have tended for a very long time to confuse “open discussion” with “public presentation.” The public is naturally offended by the “all-knowing” agency swooping down with 4 or 9 or whatever “alternatives,” after the boundaries and objectives have been set.

      Typically, the “do nothing” option has taken precedence on most federal lands the past 20 years, and the other options are basically a “variation on a theme,” and usually that theme is a distraction from the actual problems that need addressed in their design and in actual management options. Other possibilities are entirely ignored and it quickly becomes a political game of promoting your own personal “preferred alternative” from a plate of different cheeses — when you didn’t necessarily want cheese in the first place.

      I am not a lawyer and could well be misinterpreting the finer points of this discussion, but I very much appreciate your expertise and perspective being brought to the table. Please correct me where I’m wrong or have missed the point.

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    • Jon, really, you don’t think that long-term relationships among people who care deeply about the woods are important? That the land is our mutual trust (like children) and it and we both suffer from incessant squabbling- if only for the time and energy it takes away from land care? Each 100K currently spend on squabbling could be spent on the equivalent of basic care which we know needs to be done.. something simple like law enforcement for OHV’s, or tree planting, or fencing to keep cows from riparian, or buying parcels to create corridors or…

      Folks do seem to collaborate and still have lawsuits,,, e.g. the much discussed Colt Summit project. This would argue that it does not provide “much the same purpose.”

      For example, let’s use Colt Summit. A collaborative process was used. The project was clearly designed to take into account a variety of perspectives. Yet, it was still litigated and much more work and time needed to be done just for the purposes of litigation.

      So let’s imagine that formal mediation was required. Someone representing the plaintiffs would have to sit down with the FS (and collaborators) and talk about what design of the project they would be willing to accept.

      Right now that doesn’t happen until, and if, the FS loses or is pressured into settlement, with a small group of attorneys in the room. I have noticed that because attorneys are attorneys, the settlements may tend to be more paper-and-document based than changing- the- project based.

      Wouldn’t everyone learn a lot more if the plaintiffs were required to state what they wanted rather than have the conversation in the courtroom according to the time-honored mantra of “your NEPA sucks and you violated NFMA and ESA to boot.” That discussion never actually gets to the guts of the conflict that needs to be mediated.

      And it would be a more honest way to explore the disagreement. If it is a scientific argument, then the right people could be brought in to have a scientific discussion. Litigation is a adversarial process that tends to make adversaries of people who were close enough to get married; what more can it do to hurt a relationship that was never very good?.

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  11. The ‘children’ analogy is cute but not convincing. And relationships are among people (as you said) not positions – how often will Forest Service decision-makers stay in place long enough to get the payoff of building a relationship?

    I agree with the things that you said should be discussed in mediation, but I don’ think that mediation guarantees that you’ll necessarily find out ‘what they wanted., or if you do, it may be a lot harder to get there from this far down the road. I think that kind of discussion would be taken more seriously by prospective plaintiffs if it happened before there is even a ‘project design’ to talk about. I don’t know if the plaintiffs in Colt-Summit were asked at the beginning what they thought about the desired condition or if that particular location needed treatment, or whether somewhere else would be better. (I understand there might be times when opponents would say NOPE – not on planet earth – but then it at least becomes clear that you’re going to have to get the paperwork right.)

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  12. I’m all for “collaboration” and more local participation…but as far as a solution to the current impasse on the Northern Region…it’s based on the idea that the litigants “want to make a better project, when the fact is they don’t want any project at all.” You have to grasp that fact and get past the idea that collaboration is any solution at all. When all the politicians and “collaborators” finally grasp that fact, then a legislative solution will come forth. One with teeth in it.

    Meanwhile the “litigants” have been very successful at ending timber harvest on R1. It looks like they will have their most successful year ever. The 3rd quarter “cut and sold” results just came out (I need a life!).

    Let’s see, Montana sold a grand total of 51 MMBF…33% of that was personal use firewood, only 45% (a pathetic 23MMBF)of that was “sawtimber,” and 20% was “non-saw” garbage.

    Meanwhile, Colorado sold 65.5 MMBF (I lumped in the Wyoming portion of the Medicine Bow Rouet)…and 78% of THAT was “sawtimber”…or 51 MMBF. Twice as much as Montana. Only 12% was firewood and 6% non-saw. I’m gonna guess this is the first time in history that Colorado has sold more timber than Montana. And Colorado has what? Two significant sawmills when Montana has seven. It’s also worth pointing out that “somehow” Colorado cranks out way more sawtimber vs. Non-saw than Montana. I guess all the “roadside hazard trees” in Colorado are big and all the hazard trees in Montana are non-saw.

    And how bout that Arizona. THEY sold 54 MMBF, and 66% of that was “sawtimber” (36 MMBF), 20% was firewood, and only 11%, or 6 MMBF was “non-saw…or Pulpwood as they classify it. Arizona sold more sawtimber than Montana, and I wasn’t aware that Arizona even HAD a timber industry! Well, they do have a couple decent mills. Maybe they’re shipping sawlogs to Montana! I also find it interesting, that of all the talk of thinning “small diameter trees” in Arizona, that 6 times more harvest comes from “sawtimber” than pulp wood. Now I know they’re not cutting old growth any more, and I’m sure by far most of the sawtimber comes from 9-14″ DBH trees, but my point is…considering that that is the average diameter of harvested trees all over the west, especially in lodgepole country, why hasn’t there been a timber industry there all along? Maybe the CBD can tell us. I think you can explode the tiresome mantra that because of “100 years of fire suppresion, old growth logging, and cattle grazing,” that Arizona’s forests consist only of non-merchantable “small diameter dog hair.”

    No, collaborations are good…but it will be better when they fail.

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