Initiation of “Moving Toward Resiliency Within the Mokelumne to Kings Landscape” (MOTOR M2K) Project

Thanks to Sue Britting for bringing this to our attention. Below are links to the information presented at the public meeting with regard to the large landscape NEPA project currently being initiated on the Stanislaus and Sierra National Forests.

Their argument seems to be that they want to work towards NRV, and based on historic conditions and acres burned, that will take doing more than they currently are doing. They have this interesting table in their briefing paper (attached below). Note that the total acreage of both forests is approximately 2,200,000 acres (not sure that is exactly the right denominator to use) so treating 20K acres per year, as they are currently doing, would be about 1 percent. Please feel free to check my math. Based on this table, their desire is to treat 10% of the Yellow Pine Mixed Conifer, but that 100K per year would be about 5%/year  of the acres on the two forests. I agree with others the this is perhaps overly ambitious personnel and funding-wise, but I also don’t see that it hurts to be ready NEPA-wise for some unknown increased level of activities and to be able to take advantage of opportunities as they occur.

Please check out all the NRV documentation, maps and photos in the Powerpoint 2019-0711_MOTOR_M2K_JUL 11 Presentation_V5revised. The 2019-0702_MOTORwithinM2K_Project_Brief describes the idea and the process. The BP also has links to other landscape-scale NEPA projects.

One suggestion for discussing this.. doing things differently is not necessarily a highly valued trait in Forest Service culture. I can’t remember who said something like “organizational antibodies to change attack new ideas, and suck the life out of them until they are dried up husks and blow away”. In my own experience, it can be hard on employees to be asked to devote their attention to something new, that isn’t “the way we’ve always done it”, and might not work out. So let’s try to assume the best about their intentions, and not give these human beings any unnecessary grief.

17 thoughts on “Initiation of “Moving Toward Resiliency Within the Mokelumne to Kings Landscape” (MOTOR M2K) Project”

  1. Both the Stanislaus and Sierra National Forests have vast acreages that are not able to be ‘managed’ through efficient and affordable ‘logging’, especially at this particular point in time. It would be nice if they actually studied the implementation of such projects, before they do much else.

    Sure, it gives them maximum flexibility to adjust to changing conditions but, I think those Forests have nothing but trouble ahead of them. It’s too late to really effectively respond to the drought, the bark beetles and the worthless sea of dead old growth. Those Forests have been rudderless ships, tossed about on the winds and currents of forces they cannot control, or barely direct. I think there isn’t much we can really do, other than watch it burn.

  2. “Treatments could potentially include mechanical treatments, prescribed fire and managed wildfire fire.”

    It is highly unlikely that good things will come from wildfires burning in such impacted (dead) stands. I don’t want to see them using “Wildfire Acres Burned” as an accomplishment, especially on those particular Forests.

  3. “managed wildfire fire”

    I wonder if a new terminology could be created here, since over 90% of so-called wildfires are in reality human caused. Wildfire gives the idea of something of a wild origin which many clearly are not. How about labelling them “Manfires” (include – Arson, inept utility line maintenance, general carelessness on private property, prescribed & control burns would also fall under this umbrella, etc) which would allow authorities to focusss on limiting and deal with human stupidity and/or criminal intent, greed and apathy.

      • Do you know what one of the most common stupid reasons for a fire starting in rural areas (often classified as wildlands) ? People in rural areas with these small 2 & a half or 5 acre Ranchettes will have animals (Horses, cows etc) and will pile up manure at one far end corner of the property. Countless spontaneous combustion fires happen all the time this way. I stopped at many a property looking for the owner because white smoke was smoldering from the piles, some with tiny flames just a few inches high. Other examples are idiots welding on equipment next to dry weeds. There is no end to the ignorance or sloppiness from your average person. Fortunately most of these are put out in time, but never end up on the official reports.

  4. They determine the management emphasis for areas and provide criteria for future actions in those areas. These are the kinds of programmatic decisions required by NFMA in forest plans, so I hope they include it their revisions (or they may have to amend their plans). Of course the site-specific effects can’t be determined in accordance with NEPA until they have an actual proposed action for a project.

    I guess I’m getting to be old and in the way, but the NFMA and NEPA requirements have not changed. The main logic flaw seems to be that they want to be able to consider new information and changed conditions (condition-based) for planning the project, but they do not want to determine and disclose to the public how the environmental impacts change as a result of that new information or changes in the project. That’s what NEPA requires.

    They suggest a desire to be able to move faster to take advantage of “opportunities,” but most of that could be accomplished by getting prepared with a landscape analysis – without a landscape decision. This is the NFMA(analysis)/NEPA(decision) triangle that the FS taught for years, and I thought it worked pretty well. I don’t see “more fires” as a justification for skirting the process the law requires.

    • I think people have different opinions about the details of what the law requires. I could be wrong, but I think I remember CEQ encouraging this approach on the Black Hills which I believe has been successful.

      • Anonymous = Jon Haber (I skipped a step). Maybe I need to study “this approach” a little more (did you intend to only post one page of the briefing paper?).

        • Oh darn, sorry! I had to extract one page to pluck out the figure from the pdf. Then I got the two files mixed up. Will attach correct one. IMHO they did a super job on explaining their rationale in the BP. As everyone knows, I am not necessarily a fan of NRV as a goal, but if Forests need to get there (because of the 2012 Planning Rule.. to me an odd place to set management direction) then Forests will have to do projects in that direction. At least to my simple way of thinking.

  5. So, let’s look at these numbers a little more closely. Currently, the total yearly acreage is about 20,000. They aim to push that all-inclusive number to 100,000 per year. Let’s look at how we might have to get there.

    Timber harvesting for both forests, (which is solely thinning, roadside hazard tree and salvage logging- no clearcuts or old growth harvesting), is about 2800 acres. Given the lack of USFS expertise and a reduced amount of acres that need thinning, I don’t see much of an increase in green timber sales acreage. Even if we were to double that amount of logging, it is still just a drop in the bucket towards that 100,000+ acres goal.

    With pre-commercial thinning at 2500 acres per year, an increase would be quite modest, since the Forests stopped clearcutting in 1992. I would expect that number of acres to somewhat decrease over the next 15 years.

    Fuels treatments, which are probably non-commercial service contracts, would probably increase but, such acreage would not be significant, due to the high costs of preparing projects, as well as paying contractors for the work. There is also a decided lack of contract inspector types, with the proper training.

    Then, we have prescribed fires, at about 4800 acres per year. First of all, some of those acres are counted twice, using a formula to turn pile burning into acres. Any increase in prescribed burning would be tied to how many acres have been prepared to burn. There is absolutely no way that those Forests will actually light prescribed burns without some sort of fuels work done first.

    Finally, it appears that those Forests intend to meet their goals with “managed wildfire fire” acres. THAT is the only category that can be significantly increased without limitations, to reach that 100,000+ acres.

  6. After reading the whole briefing paper, I’ll elaborate on my anonymous comment above …

    There are two potential problems with this approach. One is the lack of site-specific data to determine the effects of the project (“will be specific enough to satisfy the requirements of NEPA” but there is a “lack of initial site-specific data” is the conundrum). As the briefing paper defines condition-based NEPA: “if we find condition X on the landscape we apply treatment Y.” They have to be able to also say the effects on Z are Q. I’ll allow that if they can think of every possible future combination of X and Y that is relevant to every Z that could occur over the life of the project, so they have included and evaluated the worst case Q, this could work. This seems like a big bet on a mediocre hand, but the additional NEPA they would have to do for implementation of specific actions may not be much (especially if they have a categorical exclusion that fits this situation).

    And the results of the “project” may be used in forest planning, which is the other question I’ve had. I was relieved to see that they say they would amend their forest plans where necessary, because it would clearly be necessary:

    • They are writing specific desired conditions: “The challenge before us is to define a condition for the landscape…” This is a forest plan component.
    • They are adding objectives: “desire to treat ~10% of the Yellow Pine/Mixed Conifer vegetation type plus an additional ~9,000 acres of other vegetation types annually across the planning area.” This is a forest plan component.
    • They are adding “management requirements.” These could only be standards and guidelines – forest plan components.

    The only way to do adopt these forest plan components so that they apply programmatically to future actions is through the process prescribed by the 2012 Planning Rule. One of the steps they will have to take early in the process is to identify the amendments they are going to propose so that they can be included in scoping. (For the Sierra, they are going to have to figure out how to integrate this with their ongoing forest plan revision process.)

    So these are probably resolvable problems, and if the forests can properly prepare their forest plans to make fire work for them that would be a good outcome. But I’m not confident the agency will do these things. It feels more like another attempt to deflect blame from managers who haven’t been able to get the job done “in the traditional fashion,” and instead of asking for the budget and staff necessary, they want to change the rules.

    • Really, I don’t think the old process has been the problem. The thinning under CASPO and SNF rules hasn’t drawn much litigation. Yes, there are reasons why those Forests don’t produce much results, as compared to other Sierra Nevada Forests. The previous differences have become amplified, due to the drought and bark beetle problems. Those Forests are becoming more and more fragmented, due to multiple impacts, including overstocking and a change in species compositions.

      Yes, I think we should look at the bigger picture, here, because something isn’t adding up. I think it might be Congressional influence, myself.

    • Jon and Larry, like I said, I worked on “big NEPA” projects before and the motivation was nothing more than “hey, this works sometimes, in some places, and CEQ tells us (or at least told us that 10 or so years ago) it’s a good way to proceed, let’s try it!” Again, as I remember, CEQ encouraged this approach. Old fuddy duddies like me thought “this just makes a bigger target for litigation, lots of little decisions mean that at least some with go forward..”.

      Like I said before, exploring new ways of doing business and learning is sometimes a thankless task and I hope we don’t assume the worst about their intentions.

  7. I think we need to be careful about equating “big NEPA” the last time around with “landscape-scale NEPA” now. I understood the former to be about making lots of decisions for the same area at the same time, which allowed evaluation of site-specific impacts of various activities together. That makes more NEPA-sense than what appears to be the current strategy of making the areas (and duration) so large and vague that the site-specific effects can’t be determined. And yes, that strategy seems more likely to fail bigly because any flaw would affect everything.

    • That’s a really good point. Maybe we should call them LSSWSS and LSSNSS. Just to be clear, the project I remember discussing with CEQ was LSSNSS. Big NEPA arguments work for each, though, in my view.
      Say you have site specific analysis and the trees die (changed conditions) on a bunch of sites. So you need to do those analyses over as opposed to just moving the site from “site with live trees we know the characteristics of and have a plan for” to “site with dead trees we know the characteristics of and have a plan for”. Or it’s too late for the sites we planned but other sites are now experiencing those conditions.

      • Maybe, if those other sites are identical with respect to forest plan management area and every at-risk species, as well as soil, water, recreation, adjoining landowner’s back yard, etc. Or if the sites are different, that the other possible situations have been evaluated in the effects analysis (to cover the worst case) and discussed with the public.


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