Pacific northwest collaboratives

This article is about the fact that the Malheur National Forest hasn’t had a lawsuit in 15 years.

Hannibal said “three to four times the amount of work” is getting done nowadays compared to 15 years ago. Timber sales data from the Malheur National Forest tell a similar story. From 2010 to 2016, the volume of timber cut from the forest more than doubled. The collaboration and a 10-year stewardship contract gets credit for saving the last sawmill in Grant County, Oregon, too.

It also links to the “Collaborative Directory” for the Pacific Northwest Region.

Every national forest in the Pacific Northwest has now aligned with at least one outside “collaborative,” as they are called. The idea is to build trust and get compromises done at the front end of proposed timber sales, thinnings or controlled burns. That way, the work doesn’t get bogged down in litigation or analysis paralysis later.

Forest Service directory lists 36 collaboratives associated with the 16 national forests in Oregon and Washington state. Some are more successful than others. Brown said the greater presence of endangered species west of the Cascades complicates the work of the groups active in wet-side forests.

It’s interesting to see how many groups are working where, but I just want to highlight that last point.  It suggests to me that addressing at-risk species is the key to successful projects, and that forest plans can and should provide the framework for doing so.  It would be nice to see revised forest plans treat this as an important issue and consider alternative approaches in that context.  On the other hand, there are no references to any forest plans or forest planning (as opposed to project plans and planning) in this document.  What am I missing?

65 thoughts on “Pacific northwest collaboratives”

  1. The Forest Plan revision for the Blue Mountains forests (Malheur, Wallowa-Whitman and Umatilla) just finished its objection period. The Colville NF revision is out for objections, and there have been no other forest plan revisions in R6 yet. Most of the west side of the region is under the Northwest Forest Plan, which was a region-wide strategy to deal with late-successional and old-forest dependent species. There is a region-wide network of reserves that does not easily lend itself to forest-by-forest revision.

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  2. apparently he, and all the “collaborators” measure “work” in volume of forest / landscape logged. Says an awful lot about the scientific, conservation and pubicl interest ethics and credentials of the collaborators!

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  3. I absolutely agree that forest plans should include specific, measurable, achievable, relevant, and time-bound plan components regarding management of listed species habitat and recovery of those species. Unfortunately, most of the plans I’ve reviewed lack such components. Although we don’t have many listed species in the Blues (most are fish), that’s no excuse for the lack of such components, even in plans – like the Blues – that are undergoing revision under the 1982 planning rule.

    Notably, the iron triangle forests in the Blues (Wallowa-Whitman, Umatilla, Malheur) have been undergoing revision since 2002, and the final plans – now in the objection resolution phase – are hot messes: not just regarding the few listed species we do have, but on wildlife issues more generally (in addition to other important issues). So, you’re not missing anything: we’ve just been forest planning for so long that forest plan revision is largely a distraction (although it shouldn’t be).

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    • Susan.. reasonable people can disagree about the utility of forest planning. Andy and I have argued in the past that it’s not all that useful. On the tabs at the top of this blog is the KISS planning rule proposal Andy suggested.

      The idea of plans sounds useful (in theory) but in 40 years of practice, it’s hard to argue for using the latest info in projects but using plan guidance that is only updated once every 20 years or so.

      Jon, actually the Malheur has been litigated in the last 15 years, just not about tree projects (as the article states more directly). About grazing projects. In fact this is from April of this year. https://www.opb.org/news/article/oregon-bull-trout-malheur-forest-lawsuit-dismissed/

      From an outsider’s perspective it looks like ESA makes it easier to litigate successfully when groups are against certain kinds of projects or activities. If there is a forest or region without many endangered species, then there tends to be less litigation (see also Black Hills).

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  4. I’m acquainted with a private company that produces a yearly volume that is essentially equivalent to the Siuslaw National Forest. However, the Siuslaw takes 7.7 times more staff to produce a thousand board feet! Stewardships, collaboratives, plans, revisions, appeals, lawsuits, etc. are expensive but I guess taxpayer-funded wages are plentiful and easy to get.

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    • Hello Dick,
      We’re talking about the management of PUBLIC land which means that the interested publics, whether they be international timber companies (such as Interfor here on MHNF), local companies such as SDS Lumber, recreation and conservation groups or local residents who have an interest in how their pubic land is managed.
      Yes, that takes more time but if done well it can result in decisions that will be more durable because they have the buy in of the stakeholders who participated in the decision.

      I’ve been engaged in NF management for 45 years and have always believed that involving the public is important both when I was wearing a green uniform and while working for three different non-profits on three different NF’s.

      The private company you cite answers to it’s owners or shareholders.

      The USFS is supposed to answer to the public including you and me even though you and I have different perspectives.
      I believe the current mission statement is: “Caring for the land and SERVING THE PEOPLE.”

      Working with the public and engaging them as partners should be a given on every NF in the nation.

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  5. Thanks Jon for another thoughtful post! I always appreciate what you share with us.

    Excellent point re: addressing T & E species in the forest plan revisions.

    Why no forest plan revisions on west side forests in Region 6?
    Because the region doesn’t know how it’s going to approach Clinton’s NW Forest Plan that provides range-wide direction for Northern spotted owl and related species. R6 just finished a review of the relevant science but I haven’t heard any updates re: the NW Forest Plan.
    Until they have a strategy for that all of the west side plans are hanging fire.

    On Mt. Hood the Forest Plan is ANCIENT !! Adopted in 1990 the planning team likely started drafting it in mid-80’s using science from early 80’s. Team members likely were in college in the 70’s.
    The science, local economy and other info in that forest plan is SO OUT OF DATE it’s laughable.

    Do you know any successful business that’s still solvent and operating using a 28 year old business plan? Probably not.
    But that’s what the FS is doing by continuing to operate under very old plans (OK they were revised a bit in ’94 with overlays from the NW Forest Plan).

    HIGH PLANNING COST IN REGION 6 is another issue – I was part of a meeting with then Regional Forester Jim Pena and all of his deputies and directors a few years ago. During part of the discussion re: plan revisions the woman who was director of planning for R6 said that her fellow planning directors, in other regions, were giving her a hard time because the planning costs in R6 were higher than other regions. They were NOT happy that R6 was sucking up too much planning money from the national budget.

    COLLABORATIVES – Yes, part of the idea is for stakeholders to work out issues in the collaborative group and help develop a project proposal that is more likely to be accepted by the various stakeholder groups. And thus, less likely to be appealed.

    I’ve commented previously about the very sad state of the three collaborative groups on MHNF; none of which is functional in terms of actually reaching the potential that collaborative discussions and problem solving offer.

    In one case the district ranger clearly doesn’t want to really work with the collaborative and ignores the input from the group. In another the ranger is willing but doesn’t provide the staff support for the group to be fully informed and successful. In all three cases the collaboratives are not truly representative of the public and community. They consist of people who can meet during the middle of the work day on a weekday. Those who can show up have a voice and those who can’t show up during the work day are out of luck.

    I’ve heard that things are going better on the south end of the Gifford Pinchot where the District Ranger seems to see the collaborative as a valuable partner.

    That to me is the key; does the ranger or forest sup see the public as partners in planning and land management or simply a check box in the process to crank out a volume target?

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    • I can confirm that the Mt. Hood planning team was working on its plan in the mid-80s (and one of its members graduated from college the year NFMA was passed).

      I can also confirm that there’s also nothing unusual about other regions complaining about too much money going to R6. I can also understand a strategy of putting off the most controversial (and therefore probably expensive) until last. I think there could be a big savings in R6 if they go back to the idea of setting minimum standards for compliance with NFMA diversity requirements at a regional level so that battle doesn’t have to be re-fought on every forest plan.

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    • OW.. the Committee of Scientists thought forest plans should be more like loose-leaf notebooks being regularly updated with new information. In R-2 we had very happy forests and public with old plans who seemed to use the “if it’s broke enough, do an amendment that fixes it” approach. Maybe that’s just a cultural difference- people in poorer regions tend to be used to doing more with less. There is also a budget game that involves taking planning dollars and dragging out planning.. with planning being naturally slow it would be hard to tell the difference.

      I never harassed Lisa about R-6 planning costs because I agreed with Chris Iverson, “if you don’t do very much you don’t need to plan very hard” and I assumed that R-6 was doing a lot, and was heavily watched and so on.

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      • To tie this back to your comment above, “do” really means things that have significant impacts, and yes ESA-listed species tend to be that way.

        Keeping forest plans current was a stated priority behind the 2012 Planning Rule, but it has never been a priority from a budget standpoint and the new Rule isn’t likely to change that. My impression is that some forests made it a priority, which allowed them to scrounge funds from multiple sources to get it done. I always thought it would be interesting to look at the variety of the extent and nature of amendments across the NFS, but I don’t know that anyone has done that.

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  6. It seems to me those that participate in collaboratives believe logging NFs is the end all. When they sit down at the table they are willing to help plan timber sales. They tend to be local people and often have family in the timber industry, or if in a “conservation” group, they take grant money from foundations whose giving comes from extractive uses. PEW Fdn. for example is Sun Oil. Some collaborators are actually paid to participate. NFs have been logged to death. Cutting on an 80-year rotation and clearcutting has not resulted in much native forest being left. Some forests have no old growth at all. A forest is a complex ecological system – it is not a tree farm. NFs are biologically bankrupt in many places due to unsustainable logging. They are also the last refuge for most wildlife in this country – wildlife suffering due to overlogging. If we want wildlife – and I do – then we must have places for them to live, reproduce, feed, etc. The FS no longer cares about wildlife. All they care about is logging to benefit private industry at taxpayer expense. And they use collaborators to accomplish their agenda. NFs belong to all Americans whether or not they live in the community of a certain forest. People who choose to live near a NF should have no more say than someone who lives thousands of miles away. That’s why they are “National” Forests and not “Local” Forests. Collaboratives should be banned. If these people want to participate they can under NEPA. Nothing is stopping them from sending in comments and expressing their views. But collaborators should not be allowed to aid and abet the timber sale program on NF lands, which is what they currently do. I view these people as an extension of the FS, and part of the problem. If all you care about is logging and saw mills then go to work for private timber industry and stay out of the NFs that are supposed to be multiple use – not timber use. Collaborators support logging and collaborations support logging. When was the last time you saw a collaboration that worked on a project with no logging component? I’m not aware of any. They are all about supporting the pro timber agenda and the FS uses them as a patsy towards that end.

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    • Was that 99 assumptions and opinions, or was it 100 assumptions and opinions, not supported by evidence? This long and agonizing paragraph of accusations and innuendo are just the kind of things that the USFS will explain away with a single sentence. Well done!!!

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  7. I would add that virtually all of the timber sale projects I have reviewed that were developed by collaboratives violate the Forest Plan and/or federal environmental laws. They seem to think that if they all agree to a project it should happen regardless. Wrong. Projects need to comply with standards and guidelines, and all federal laws. If people agree to lawless projects they should not be surprised when the projects are litigated. And they should be ashamed for supporting them.

    Just today I read: “Hammer points to the fact that the proposal would require two Forest Plan amendments suspending lynx management standards as another indication this is not a true “restoration” project. “If the Forest Service and its collaborators think they need to suspend lynx habitat management standards in order to restore lynx habitat, maybe they should focus on proving the standards are wrong and changing them rather than simply sidestepping them,” Hammer said. “This is just one more example of collaborative groups working to help the Forest Service get around the law rather than comply with it.”

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    • Denise, I think if you could get down to the layer of specificity that we could understand, it would be helpful. What are they planning to do? What does the lynx management standard say? Are they doing a plan amendment (site-specific) as part of the project? It would be helpful to our understanding as most of us do not want to read the EIS. Thank you!

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  8. There is little mechanism for accountability to the public (owners of the national forests) pertaining to the U.S. Forest Service left anymore, and there is NO ACCOUNTABILITY MECHANISM to the public pertaining to collaborative partnerships. The collaborations are mainly to increase local, mostly extractive control over national forests. There are no principles, no scientific standards, just agreements to serve local interests. Collaboration puts forth the “pretty face” of the Sagebrush Rebellion and anyone who calls themselves a conservationist, scientist, or environmentalist should stay away and–just as important–call the collaborators on their phony “restoration” BS.

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    • Denise, I think if you could get down to the layer of specificity that we could understand, it would be helpful. What are they planning to do? What does the lynx management standard say? Are they doing a plan amendment (site-specific) as part of the project? It would be helpful to our understanding as most of us do not want to read the EIS. Thank you!

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    • Hmm. you don’t think local people should be listened to any more than someone who doesn’t live/work/recreate there.

      Yes, there are exactly the same accountability for collaboratively designed projects as there are for FS designed projects.. appeals and litigation. “No scientific standards”.. my experience reading the EAs and EIS’s are that the scientific input is identical (mostly because the same people actually write the EAs or EIS’s whether designed by the FS or the collaborative. Just my two cents.

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  9. Yes, national lands are “owned” by the public and, yes, the public rightfully has a say in how those lands are managed. A huge problem is that there are a whole lot of differing publics; some say cut every tree and, on the other extreme, don’t cut a tree.

    So, how do all these publics come together to determine how to manage their lands? To me, that should be the job of our elected officials; they are supposed to determine what the American citizen wants both for and from their lands and then set long-term management objectives. Unfortunately, our elected officials can think only until the next time they are up for re-election and they cater to or bend towards any “public” that helps get the re-elected! In other words, they seem incapable of thinking long-term; i.e., decades or even centuries.

    They seem incapable of determining long-term objectives and then turning those objectives over to the land managers; those are the people who have the training and are hired to manage the land. They seem incapable of letting the land managers do their jobs without micro-managing!

    For example: a long-term objective most people would likely agree to is that we want plentiful, clean, clear waters and to provide good fish habitat. With that as an objective, turn it over to the land manager accomplish that objective. However, the politician tends to set very prescriptive ways to accomplish that objective – most often with one-size-fits-all prescriptions that, while easy to enforce, often do not fit the land. They may prescribe that riparian areas MUST be a tree-length wide or, maybe, 200 feet wide. However, that is a one-size-fits-all prescription. It is highly probably an experienced, knowledgeable land manager could accomplish the desired objectives with varying riparian management area widths. On steep, unstable slopes, 200 feet (or more) might be necessary. But, on flatter, stable slopes, 30 feet (or less) might accomplish the desired objectives. If the land manager falls short of attaining the objective, then they should be held accountable.

    A big problem is that I do not believe our elected officials, the people who should be determining what the American citizen wants, have ever determined our public land’s long-term desired outcomes. I don’t think they are capable of thinking of a land that is decades or centuries distant. Until this is done, we are going to continue in the quagmire that we are currently in. We are going to continue to use stop-gap collaboratives, stewardships, lawsuits, etc. Congress is going to continue to pass bills that are likely short-term and will only last until the next pendulum swing.

    Further, and this is critically important, once these long-term objectives are set, we must let the land managers do their job and not change objectives with every political pendulum swing. Our desired outcomes MUST be thinking decades and centuries ahead. [Case in point — decades ago, Smokey Bear said every fire has to be out by 10 AM the next day. Was that thinking ahead decades or centuries? While that fit the thinking at the time, are the land managers allowed (think dollars and the public’s buy-in) to rectify the ill effects of that short-sighted policy?]

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  10. In regards to allowing land managers to do their job. In the old days there were some decent Forest Service personnel who I believe sincerely cared about the land. They listened to all concerned with differing opinions and tried to find a compromise. Those people have all retired or left the agency. In the late 90s and 2000’s the FS began hiring all kinds of people from the private sector that had little to no experience with the agency. Not only are these people bad fits but the long term FS employees resent them for walking into a District Ranger or Supervisor position when they were working their way up the ladder for that position. Many of these people are from industry: timber, oil, gas, coal, etc. There job was always to get the cut out (or oil, gas, coal) and that’s how they approach FS lands. they have no concept of multiple use. They don’t care about wildlife or water or fish. The upshot is I do not trust the current agency people to make good decisions and I base this on over 30 years experience reading FS documents. The FS is not the agency it once was – and the old timers from the FS would agree with me – at least the ones I know.

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    • Denise, I don’t know about where you live, but most of the folks I meet who did not come up in the FS came from other government agencies and some are from the military. As a coal and oil and gas producing region (which I don’t believe R-6 is) I don’t remember anyone coming from those industries to work for us.
      I do remember in various attempts to hire more diverse people, we did get some people with backgrounds from outside the FS. For seven years I participated in RO reviews of each DR, Supe and so on and never saw one from outside the FS for any of these .. in fact no one from outside the agency as I recall. It’s just not that easy to get hired from outside the government. I don’t know where you are getting your information.

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      • I was on a recent selection panel for a District Ranger position. Those are now classified in the “general management” series. There were 50+ applicants. Three had some natural resource-related experience. Most of the remainder were DOD employees. Some had incredible leadership skills honed in the military. I know of several situations where District Rangers were hired who had no natural resource experience – so it is not that hard any more for “new” folks to enter the FS at Line Officer levels.

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        • Anonymous.. I too have seen more people from DOD show up more recently.

          I was responding to Denise’s point about coming from the private sector, oil and gas and coal and timber. I too have seen people with exceptional leadership skills honed in the military, one a Presidential Management Fellow who is a Forest Supervisor somewhere.

          When I worked in R-5 in the throes of the Consent Decree, we had to come up with ideas. My idea was to hire experienced women in the administrative series for line, but give them a one month intensive course in Natural Resources (live-in summer camp-like). Bring in key wise old people and determine “the important things about natural resources a line officer needs to know” plus some agency history. Involve the universities (to the extent that they know useful stuff). IMHO, that in itself would be a fascinating convo to have between successful line officers and natural resource school leadership on what was really important for them to know.

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    • Wow, this is all over the place and could take a couple days to respond. In the old days and, for that matter, today as well there are lots of good Forest Service people committed to and care for the land. Some want to get the cut out and others are vehemently opposed to cutting a tree. I’d guess there are very few Forest Service people who came from the private world because, in the private world, they are accustomed to getting the job done and would find government service terribly frustrating. From my time in the military, I knew far too many government employees (both military and civilian) who’d just as soon skate along and do little to nothing. (I knew of a fellow who actually had NO job and did nothing!! There were others who simply occupied space.) From my experience of 46+ years in the private world, I resent the intimation that we’d have no concept of multiple use or that our job is just to get the cut out. The tree farms I worked on had plenty of wildlife, produced good water, wrote thousands of hunting or other recreation permits every year, had diverse forests, hosted dozens of tours every year, and so forth – and, by the way, we also sustainably produced enough logs that we kept, either directly or indirectly, at least 150 people working!

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  11. I’m getting my experience from being out there working with FS people. Are you still with the FS? Back in the early 2000s a District Ranger on the Manti La Sal in UT came from the oil industry – and pissed off every one he worked with. I managed to get the RO involved and he was reprimanded. Several supervisors in the southwest did not come from within the agency. Senior level admin in N CA came from outside the agency. I don’t think these are anomalies. I’m guessing it is widespread based on my national contacts.

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    • Denise wishes to use one anecdote from nearly 20 years ago in southern Utah and make sweeping generalizations about the entire FS.
      Denise, you are wrong – it is very rare for folks from “industry” to end up in FS management positions. (I actually can’t think of one.)
      Contrary to your allegations, most FS employees care deeply for the land they have been trusted to manage. NFS lands are managed under multiple use principles and yes, on some Forests, that includes timber. And, believe it or not, timber management can be compatible with clean water and good wildlife habitat. (Take a look at some of the research on these topics.)
      Your reflections on collaborative groups likewise do not appear to be based on any real world experience with these groups, how they operate and who participates.
      Maybe drop into your local FS office and try to learn what is really happening on NFS lands.

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      • I have experienced some situations where forests want very little in their Forest Plan revisions because they want to collaborate on everything – so I have seen some of what Denise is referring to. Upper leadership decided that that approach (no standards and guidelines – let us collaborate on everything) was not going to occur. Some of the “collaborate on everything” comes from an agency feeling that as long as they don’t get litigated, they can do whatever they want as long as they collaborate (including doing things that violate law/policy). And some of it comes from line officers determining the “risks” that they want to take, including taking a risk on complying with the law. Jack Ward Thomas said it best (at least to me) in his 3 things when he was Chief – Obey the Law, Tell the Truth (and I can never remember the 3rd one!). There is no “evil” intent here – just people trying to get work done, but perhaps cutting a few corners that they shouldn’t cut. So this is where the “local” forest or “national” forest comes into play. Do you let local collaborators determine what is best for that forest or do you reflect the need for some broader thoughts about what that forest needs in the form of a Forest Plan with Plan Components?

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        • Anonymous.. I think JWT also realized that it’s not so easy to obey the law when they conflict. This Lewiston Tribune article is interesting in the face of current debates and discussions, plus ca change and all that… (1996) https://lmtribune.com/nation/world/forest-service-chief-is-backed-into-the-ropes-jack-ward/article_46dcfd74-967e-5635-8252-2a2574a822f8.html
          My italics…

          “As for the administration, Lyons and White House officials make no bones about their resistance to Thomas’ broad policy proposals that are opposed by environmental groups.

          Lyons sat on Thomas’ proposal to streamline forest planning, saying it would dilute the same wildlife “viability” rule that led to the shutdown of federal logging in the Northwest. The rule calls for ensuring that all native vertebrate species remain viable throughout their range. Thomas claims that the rule is impractical and favors using indicator species and their habitat.

          Lyons also watered down Thomas’ 1994 Forest Health Initiative, which included more salvage logging than environmental groups wanted. And the undersecretary stymied Thomas’ bid to fold several laws on environmental compliance into one coherent statute, eliminating overlapping and sometimes contradictory language.

          Katie McGinty, Clinton’s top environmental adviser, said Thomas is correct to suggest that “it is time to start looking at” a revised and streamlined environmental compliance statute.

          But she doesn’t want this Congress to do it.

          “It would be a dangerous prospect at the very least to unleash many of these members on environmental laws,” she said in an interview. “They’re not going to improve the laws, but to repeal them.””

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  12. It doesn’t really matter how many, NEPA documents we have, red tree vole surveys, endangered species plans, environmental lawsuits, land use plans, or collaborative meeting, if the FS doesn’t stop burning up our forests.
    I had the pleasure of another trip up the Chetco river in Southwestern Oregon. Last summer the FS let a 1/2 acre lighting fire turn into a 180,000 acre catastrophe.
    I was overwhelmed again after driving mile after mile by trees, 250 years and older, that are now dead. This is right along the main stem of the Chetco, right down to the river itself. The mortality rate must be in the upper 90%. And this is just a small fraction of what burned.
    Is this how we take care of our “ancient” forests? Kill them?
    (And they turned around and did the same thing this summer with the Klondike fire).
    Smokey has it right, stop the fires.

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    • For whatever it’s worth…

      According to an October 14, 2018 piece in the Medford Mail Tribune by Annette McGee Rasch:

      Only 2 percent of the land affected by the 211,801-acre Klondike and Taylor Creek fires on the Wild Rivers and Gold Beach Ranger Districts burned at high severity; an additional 75 percent burned at “low” or “very low” severities — or remained “unburned,” according to a recent U.S. Forest Service assessment. About 20 percent burned at medium severity.

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      • One of the big problems with the Klondike fire is that a lot of it is reburn. This kills what has grown back, and often the trees that survived the original fire. The result is no future seed source. This changes the landscape from forest to fast growing shrubs that sprout after a fire.

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        • Bob, it might be handy if you know someone who could do a drone flight with a camera so we could all get a sense for what you are experiencing. I think “fire severity” as measured may not be relevant to “less desirable things people see on the landscape.” and a video would help make the translation.

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  13. This massive project says it will require suspension of two major lynx management standards.

    “The Flathead Forest developed the proposal with the ‘The Southwest Crown Collaborative’, an independent volunteer-based project that works with the Lolo, Flathead and Helena-Lewis and Clark Forests on restoration projects.
    Keith Hammer says the Swan View Coalition has participated in several collaboratives and always walked away disappointed.

    “Every single one of them has helped the Forest Service to get around its own laws and guidelines and its own forest plan. And that’s why we don’t go full-term with these collaboratives. We reach a point where they want to break the law and we say ‘no, we’re not going to help the agency break the law.'”

    http://www.mtpr.org/post/flathead-forest-proposes-70000-acre-restoration-resilience-project

    Flathead Forest Proposes 70,000-Acre Restoration, Resilience Project

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    • Denise, FYI, deviating from a Forest Plan standard is not “breaking the law.” There is a process set up to allow for site-specific deviations from a standard. If the project follows the appropriate process, the FS is not breaking the law – despite what Mr. Hammer may say.

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      • Thank you, Bob. My understanding is that when these get litigated, the judge looks at the rationale for deviating from the standard and makes a judgment about that. These were/are called “site-specific plan amendments”.. are they allowed in the 2012 Rule?

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  14. Dick said: “If the land manager falls short of attaining the objective, then they should be held accountable.” (“Objective” here means the agreed upon desired outcome for a project area, including environmental effects.) I’m not familiar with an agency process designed to insure this personal accountability. (Is project monitoring of relevant outcomes certain to occur, and will the results be reflected in someone’s personnel file regardless of how long after their decision the monitoring results are obtained?) Lack of such accountability contributes to the “trust” issue that Denise mentions, and is one reason that binding forest plan requirements are necessary.

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    • This sounds plausible but many land management improvements occur over time. Just take a simple objective like “5 year reforestation success”. What does it mean to be accountable? Do you take into consideration that the nursery had a bad year one year, that a freeze occurred at an unusual time the next year, or maybe there was drought that you could blame on climate change. Are the same people even working there in five years?

      What I think might work is a limited number of measurable important objectives agreed to with the public (through some mechanism). A joint review of those objectives each year with a field trip. Representatives of the boss (say a deputy RF if the boss is the forest supe) attend the review and write it up and submit it to the boss (RF) who takes it into consideration for their performance review.

      I think the Medbow-Routt used to do something like this as part of their annual monitoring report, without of course, the performance related part.

      I don’t think “binding forest plan requirements” help with any of this.. except possibly to get forests to do monitoring.

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      • I see this went on for awhile after I took a fun-break. My point about standards is that there can be much greater accountability for compliance with standards on a project-by-project basis than the kind of long-term landscape-scale accountability associated with objectives you discuss above. (Some possibility for confusion here because Dick used the term “objectives” in a project accountability context, which is not how this term is used in forest planning.)

        To put a finer point on your question about “deviating” from standards, here is a more technical answer. A project can’t deviate from a STANDARD (under either the old or new planning rules). A site-specific amendment could change the forest plan for a particular project, and the project would therefore be consistent with the modified plan. Under the 2012 Rule, projects may deviate from GUIDELINES as long as they are “designed in a way that is as effective in achieving the purpose of the applicable guidelines.”

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  15. Thank you, Bob. My understanding is that when these get litigated, the judge looks at the rationale for deviating from the standard and makes a judgment about that. These were/are called “site-specific plan amendments”.. are they allowed in the 2012 Rule?

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    • In response to Sharon’s question about site-specific forest plan amendments: the answer is yes, the 2012 rule – as amended in 2016 to provide additional specificity regarding amendments – permits site-specific forest plan amendments. The 2016 amendment (81 Fed. Reg. 90723) to the 2012 rule make it clear that the amendment process cannot (should not, anyway) be used to escape compliance with forest plan components. The Fourth Circuit Court of Appeals just struck down forest plan amendments for the Mountain Valley Pipeline that did exactly what the 2016 amendment says NOT to do. Sierra Club, Inc. v. United States Forest Serv., 2018 WL 3595760 (4th Cir. 2018).

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      • Susan, thanks for this link. I tried to read through this and figure out what it says not to do, but was unsuccessful. Does anyone have a plain English version of these requirements?

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        • Regarding Sharon’s question about how the 2012/2016 rule apply to amendments, I’d encourage interested folks to read the preamble of the 2016 amendments, which explain how the process should work. From the preamble:

          “This amendment to the 2012 rule clarifies that the responsible official is not
          required to apply every requirement of every substantive section (§§ 219.8 through
          219.11) to every amendment. However, the responsible official is required to apply those
          substantive requirements that are directly related to the plan direction being added,
          modified, or removed by the amendment. The responsible official must determine which
          substantive requirements are directly related to the changes being proposed based on the
          purpose and effects of the amendment, using the best available scientific information,
          scoping, effects analysis, monitoring data, and other rationale to inform the
          determination. The responsible official must provide early notice to the public of which
          substantive requirements are likely to be directly related to the amendment, and must
          clearly document the rationale for the determination of which substantive requirements
          apply and how they were applied as part of the decision document.”

          The preamble also includes some helpful examples of how this process should work:

          “For example, the 2012 planning rule requires that the plan must include plan
          components to provide for scenic character, which is a term of art associated with the
          scenic management system that was developed in the mid-1990s. If the scope of an
          amendment to a 1982 plan includes changes to plan direction for the purpose of, or that
          would have an effect on, scenery management, then the responsible official must apply
          the 2012 rule requirement about scenic character to the changes being proposed.
          However, a responsible official is not otherwise required to review and modify a 1982
          rule plan to meet the 2012 rule’s requirement to provide for scenic character. This is true
          even if there is also a separate, additional need to change the plan to protect scenery. The
          responsible official would have to address the scenic character requirement throughout
          the plan area in a plan revision, but in an amendment, the responsible official has the
          discretion to more narrowly focus on a specific need for change.”

          Note that the “biggest” concern about plan amendments is how to amend a 1982-era plan (or plan developed under a different rule other than the 2012 rule) using the requirements of the 2012 rule. This is generally because as I see it, the 2012 rule is a Ferrari whereas the 1982 rule is a VW bug: the new rule is very powerful, complex, and detailed, whereas prior rules just were not.

          I had hoped that the Planning Rule FACA Committee would have been allowed to develop a handbook explaining how the 2016 amendment on amendments was supposed to work in practice, but alas: our charter wasn’t renewed by the Trump Administration – #RIPpublicparticipation 🙁

          If anyone is interested in a more step-by-step discussion of amendments under the 2012 rule, I’m happy to discuss further offline.

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  16. Sharon said “I don’t think binding forest plan requirements” help with any of this…….” You aren’t alone in this thinking – the Forest Service does not believe in their forest plans even though they wrote them years ago. There is no accountability in this agency. Only excuses for why they should not have to enforce their own rules, much less federal environmental laws. This isn’t rocket science. I have the benefit of age and the fact I have spent decades outdoors. The FS lies about logging being the cure all for every issue on the forest and the results can be seen on the land. Don’t take my word for it – go hiking. The FS has destroyed most NFs and turned them into sterile tree farms. Many are lacking native vegetation, old growth, and wildlife. Most are lacking native fish species and clean water. I work on four NFs. Every salmonid is endangered; every river has been on the TMDL list under the EPA for decades; very little wildlife exist; hundreds of miles of roads; logging everywhere. It is a disgrace. This agency can’t be fixed. I don’t want public lands given to the states because in most cases it would result in even worse management. But the FS is irrevocably broken and should be eliminated. Put the NFs under Interior and managed under NPS. It would be a good start. The FS gets litigated for a reason and it is shame only 2% of projects are litigated. There should be far more.

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    • Denise.. the National Forests run from Florida to Vermont to Alaska to California with widely varying degrees of timber management or not. Oh and El Yunque in Puerto Rico. And I do go hiking. The National Forests are managed under laws related to them and even if Interior wanted to take that on, it would more likely end up in the BLM. Federal lands are managed according to the laws (otherwise there wouldn’t be lawsuits!) and inclinations of the executives in the executive branch, ultimately not the druthers of the personnel involved.

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    • Every single National Forest in the Sierra Nevada range has followed the law and accomplished beneficial commercial thinning, with absolutely minimal environmental effects and impacts. No clearcuts or old growth harvesting for the last 25 years, on 8 entire National Forests. The truth is, they need to triple the amount of thinning they currently do, to have any impact on the many, many decades of mismanagement and fire suppression, as well as fighting against kneejerk reactions of misinformed people against all forms of ‘logging’.

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  17. I’ll give Dense credit … she doesn’t even acknowledge some of the comments that question her generalities and outright falsehoods …. she plows ahead and doubles down on her rhetoric.
    This one might be my fav “The FS has destroyed most NFs and turned them into sterile tree farms.” Really, Denise, what metric are you basing this on? I took your advice and went hiking on my local NF and I found you to be wrong on every account.
    Thankfully your extremist opinions are in the minority. Try moderating your stance a little – you might be supposed by the results.

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  18. Sharon, with all due respect that’s a cop out. Policy is set in DC but FS staff have a lot of latitude in what they do and how they do it. They bring this up themselves in court claiming they should be given deference and their opinions are based on “professional judgment.” The type of logging conducted is far more destructive than it has to be. Saying you are only following orders is taking no responsibility for your decisions.

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    • ‘Whatever Happens’ is a very poor management policy, especially with millions of humans, a warming atmosphere, severely overcrowded forests and bark beetles running rampant. Your solution seems to be ‘do nothing’. Show me any example where an overstocked and unhealthy forest has been ‘fixed’, by doing nothing.

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  19. Show me a forest that is overstocked and unhealthy that has NOT been logged. The FS created this situation and doing more of the same isn’t going to fix it.

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  20. There are plenty of photographs of beautiful forests prior to the FS logging program. We could do many comparisons. Those forests looked like real forests – because they were. They were not all filled with beetles, disease, and burning – although those are all endemic to native forests. You can try to justify logging NFs in ways currently being done but common sense and observance don’t support it.

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    • Humans managed California forests since the last glaciers receded, and before the Europeans came. You offer no site-specific treatments or solutions, while advocating ‘doing nothing’, while forests are incinerated. Te blame sits in the past but, the solutions are trapped by people like you, who block meaningful actions. Your stance is noted, and rejected by the people who really matter. Go right ahead and file all the meaningless petitions and “official comments” that do absolutely nothing to restore these forests you deem to be “destroyed”.

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  21. The Trinity Collaborative is an odd duck here in the Shasta-Trinity NF. The local environmentalists have teamed up with the local timber industry to push roadside shaded fuelbreaks throughout the County. The environmentalists feel some vindication, after watching our forests degrade, in allowing green tree removal, including some over-mature old-growth while the industry is glad to get whatever it can. We’re talking millions of board feet. The problem I’ve had with this program is the intentional lack of concern for communities at risk. The Mad River Ranger District of the Six Rivers NF has totally bought into this in that they can produce timber outputs while not getting litigated.
    This roadside shaded fuelbreak subcommittee was formed without it being on the agenda and the members were pre-determined. I am a member of my local community’s fire-safe council and was told I couldn’t be included even after I raised the issue of inclusiveness being a cornerstone of any collaborative effort.
    Anyway, I have nothing against roadside shaded fuelbreaks, per say, I feel, and I think the science backs me up, that this prescription should be used as a part of a strategic, comprehensive plan. This view is ignored.
    My point is, just because environmentalists and the timber industry (both have some skin in why our forests are in the shape they’re in) can come to an agreement, doesn’t mean that it’s the right thing to do. 150′ buffer on either side of the road that creates a linear, temporary reduction in fuel throughout our forests does very little in addressing the needs of our forests and communities.
    My view is being pushed under the rug in our Collaborative. The environmentalists have lawyers, as does the industry. I’ve been wondering lately if I need a lawyer to push for more consideration of science and prioritizing wildfire risk reduction projects around communities.
    Anyway, here’s some spin coming out of the Six Rivers on a plan just passed by our Collaborative. It wasn’t unanimous as stated, as I objected to it. One local environmentalist actually apologized to the Mad River District Ranger for having brought this plan to him and now he has to put up with “this crazy shit”, which was me pressing the Ranger on what kind of local community input went into the development of this plan (there wasn’t any) and also asking about landscape scale projects (he just said if he tried doing something like that he would be litigated).
    This project is being slated as “strategic” when the only strategy is to provide talking points for the environmentalists to say they’ve approved x amount of acres to have green tree removal for fuel reduction projects while not caring where the project will be implemented. All roads that the public has access to is hardly a strategic, fire resiliency plan, imo.
    https://www.fs.usda.gov/detail/srnf/news-events/?cid=FSEPRD601096

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    • Larry, sounds like shaded breaks were the “low hanging fruit” for enviros and industry to agree.
      In our part of the country, there’s a pretty strong relationship between communities wanting fuel reduction projects and pressure to get them done that comes to the FS from the County Commissioners, mayors and so on. Of course, in many cases we don’t have timber industry as a (helper? distraction?).

      Also, I can certainly understand the reluctance to analyze landscape- scale projects. If you work in an area with active litigants, it just provides a larger target that goes can take years to accomplish and may never get done. But some folks have been successful e.g. https://forestpolicypub.com/2018/04/23/landscape-scale-success-stories-i-upper-monument-creek/
      I asked for more examples of successful landscape scale projects and didn’t hear from anyone.

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      • Seems like the Willamette and Umpqua National. forest have been successful with thinning sales on landscape size projects. The Rouge Siskiyou also, that is if their project area didn’t just her burned up.

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      • The Weaverville Community Forest is one that seems to continue successfully. The Western Klamath Restoration Partnership with it’s recent Somes Bar Integrated Fire Management project as well as the Ashland Forest Resiliency Project are a few that I’m aware of.

        The problem I have with the low hanging fruit concept is that it focuses SOLELY on what can be done vs. what needs to be done. That’s fine to start out with but we need to move beyond that. It reminds me of the UN Security Council where one vote can nix any proposal. In this case, the environmentalists have veto power over what CAN BE discussed just by threatening litigation so we can’t even discuss what needs to be done. Very frustrating in these times of degrading forests.

        Here’s the thing. Communities were to be protected from boom and bust economics through the Sustained Yield law and policies. That didn’t work out. Who spoke up for communities? The timber industry? Not much of a proponent when I’ve seen multiple communities wither on the limb due to timber industry competitiveness. Communities at risk are to be prioritized when developing fuels reduction projects according to the Healthy Forests Restoration Act as well as more recent farm bills. So who is supposed to advocate for these communities if the industry and environmental factions don’t? When they feel that protecting communities goes against their preferred idea of what “can be done”?

        Our collaborative has the 3 legged stool concept where our projects are supposed to have economic, ecological and social aspects. When the social aspect is defined to irrelevance in the design of projects, it doesn’t bode well for the future of our forests and communities.

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        • Larry, you’ve raised some great questions and I wish I had some answers. Here are a few thoughts:
          Probably other readers who didn’t work for the FS would know more.

          1) Gather like-minded people and meet with the District Ranger. What could we do to help you prioritize WUI fuel treatments because they are important to us? Is it $, the color of $, views of certain groups who litigate counting more, or ??? I don’t think this would come out directly but might require some “reading between the lines.”

          2) Contact local political representatives and have them ask the FS these questions. Advocating for communities should be in their job description. Not saying that FS/local elected official relationships are always rainbows and unicorns, but who could be against fuel treatments around their communities?

          Another HFRA idea was the CWPP(community wildfire prevention program). In Colorado those were developed with the idea of prioritizing across fed/state/private ownerships. https://csfs.colostate.edu/wildfire-mitigation/community-wildfire-protection-plans/

          Not sure that CWPPS are still used that way but joint prioritization does seem to be the way to go. Does CalFire have something similar?

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          • What if each national forest had a “board of directors” composed of a diverse group of folks who represent the community? This board would work like the collaborative groups that focus on specific projects, but who provide forest-wide direction, and any decision or recommendation would carry a great deal of weight, including in litigation, though ultimately the forests would make final decisions.

          • That’s kind of what the Black Hills has with its FACA committee. It seems to work for them. I don’t understand why they haven’t become more popular other than the time-consuming paperwork associated with keeping them going.

  22. Funny how my comments are just “opinions” but yours and others are “facts.” All you advocate is more logging; doing the same thing that got us in the situation we are now in. Beetles? Log. Wildfire? Log. Disease? Log. Doesn’t matter that all forests evolved with these things and survived for MILLINEA without human interference. I have never said all logging is bad – but I am saying the way the FS logs is wrong-headed and not based on the best available science. Your stance is also noted – and it is close-minded and biased. And you have no idea what I do to help restore forests so don’t pretend like you do.

    Reply
    • Logging does not cause bark beetles. That’s a ludicrous claim.

      My recipe for restoration, in the dry west National Forests

      1) Match stocking levels to annual precipitation levels
      2) Adjust species compositions to be more resilient to drought, bark beetles and wildfires
      3) Change forest structures to be more all-aged (including snags), instead of even-aged management

      I would bet that I have seen much more forest types and sheer acreage than you. You lump everyone together as evil loggers bent on forest destruction. Your narrow point of view is currently being left behind.

      My “stance” is site-specific, unlike yours.

      Reply
    • Wildfire suppression for 100+ years has lead to an increase of the densities of dry forest types across the west. Logging reduced those densities. I think there is a valid discussion to be had of “why here” and “why now” but I think way too often groups come forward under the mask of collaboration when their sole intention is to stop all management for any reason. I believe there is sufficient scientific support in regards to environmental, economic, and public safety justifications for accelerated logging on national forests. Beyond that we need to manage the National Forests because they are not National Parks. They do not have the congressional designated protections that National Parks have. If we cannot generate value from those lands via logging and grazing we need to either move to protect them with congressional designations as parks or be willing to loose them eventually to a higher valued use (e.g. mineral extraction, housing development, etc.).

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  23. I was wondering if Denise had ever been in the forest, Well I guess she has, but I am not sure I would like to go hiking with her. I can usually see the amazing beauty of our forests.

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