I said here: “NEPA documents have started saying that cutting down trees is beneficial for the environment because it produces funding to replace culverts and the like. That may not be a defensible effects analysis.”
Sharon asked: “I don’t see why people need to say that at all in NEPA docs. Do you have examples?”
I do. I’ll provide two here that I have encountered with forest plan revisions.
The Flathead revision FEIS provided very little useful information about aquatic effects, but it revealed this as part of their logic (p. 131, but their point seems to be that it doesn’t matter):
Although alternative D proposes more timber harvest and the potential to generate more Knutsen-Vandenberg revenue for restoration actions such as best management practices, road decommissioning, and culvert replacements that would benefit aquatics, it is anticipated that money would still be available from partnerships and appropriated watershed dollars to implement restoration projects regardless of how much money is generated from timber sales.
The Helena-Lewis and Clark was more to the point that it DOES matter in their revision DEIS (p. 71):
Alternative E would result in the highest volume of timber production and therefore have the potential to generate more money from timber receipts for restoration projects for watershed and fisheries. If more money is available from alternative E then there would be more short-term impacts from restoration projects but there would be more long-term gains
I think I have seen other better examples for projects that have stated that the proposed action is better for the environment than no action because the timber sale revenues will be used for restoration activities. Maybe I’ll run across more examples, but I wanted to post this now so that others could contribute examples they are aware of.
So no, I don’t think they should include this in NEPA documents. The problem is that effects disclosed in an EIS must be reasonably foreseeable. If the funding process works in a way that makes money available but does not commit it to a specific use, then any effects are not reasonably foreseeable. This is more obvious in the forest planning context because restoration is only a “potential” (to quote both examples above). The result of including this kind of poorly substantiated assumption in an effects analysis is to distort the comparison of alternatives and to provide less meaningful information for the decision-maker and the public. This tends to subvert the core purpose of NEPA.
7 thoughts on “The effects (NEPA) of bake-sale (timber-sale) funding of restoration”
Here’s one for you.
In one of my current post-fire salvage cases, the Forest Service has argued that it needs to salvage log in an inventoried roadless area, botanical area, essential wildlife connectivity area, Late-Successional Reserve, spotted owl critical habitat, and Riparian Reserve (all adjacent to the Pacific Crest Trail) so that it can generate revenue to create fuel breaks so that we don’t have another Paradise Fire. Which may seem laudable (to some) until you realize that there is exactly zero economic data in the entire administrative record to support this claim.
At what point does the agency cross the line from exhibiting “scientific expertise” to simply making stuff up?
Susan- can you show me where it says that? I am trying to get context here… is it a stewardship project or a regular timber sale? thanks!
Wildfires kill trees by the billions of all age groups. Wildfires often promote the growth of invasive species and brush making it difficult for future forests to reestablish itself. Wildfires cause extensive shade loss and erosion in our watersheds. Wildfires pollute our valleys with smoke, endangering our health and keeps us from enjoying outdoor activities and our forests in the summertime. Wildfires are using up most of the FS budget and cost billions of control.
Wildfires cause irrepressible damage to forests. Wildfires destroy our future timber resources and impoverish our rural communities. Wildfires destroy property. Wildfires do not promote forest health, make future fires .more controllable, or cost less. After over 25 years of the FS promoting fires we have more larger, dangerous and expensive fires than ever.
Wildfires make the world a hotter and drier place.
Put the fires out when they are small. Play with fire in the spring or fall.
Thanks for your comment Bob…I fixed it!
The timber industry kill trees by the billions of all age groups. Logging often promote the growth of invasive species and brush making it difficult for future forests to reestablish itself. Logging causes extensive shade loss and erosion in our watersheds. Cutting down the most fire-resistant trees has polluted our valleys with smoke, endangering our health and keeps us from enjoying outdoor activities and our forests in the summertime. Logging has used up most of the FS budget and cost billions.
Logging causes irrepressible damage to forests. Unsustainable logging has destroyed our future timber resources and impoverished our rural communities. Logging destroys property values. Logging does not promote forest health, make future fires more controllable, or cost less. After over 100 years of the FS promoting logging we have more larger, dangerous and expensive fires than ever.
Logging make the world a hotter and drier place.
Let assume Matthew you are correct and maybe I am too. Do you think it is a good trade off?
This looks like another forest plan example from the Sierra/Sequoia revision. This is being attributed to a Forest Service “report” that was the reason for the issuing a revised draft plan/EIS:
“For its part, the Forest Service admits that it does not have enough money to complete the forest restoration, and needs to rely on certain logging operations within the park in order to underwrite other rehabilitation efforts. Without the logging, those efforts would be hampered, the agency wrote in its report.”
If they carried this information into the NEPA process, they would again appear to be assuming beneficial effects would occur from projects based on speculative funding sources (and suggesting that the purpose of projects is to make money, which might conflict with NFMA).
This Might be another example From the Nez Perce-Clearwater NF:
Page i of the DSEIS for the “Clear Creek Integrated Restoration Project” September 2018:
Purpose and Need for Action
As stated in the 2015 FEIS, the purpose of the Clear Creek Integrated Restoration Project (Project) is to manage forest vegetation to restore natural disturbance patterns; improve long-term resistance and resilience at the landscape level; reduce fuels; improve watershed conditions; improve elk habitat effectiveness; improve habitat for early seral species; and maintain habitat structure, function, and diversity. Timber outputs from the proposed action would be used to offset treatment costs, support the economic structure of local communities, and provide for regional and national needs.