A Trailblazing Plan to Fight California Wildfires: New Yorker Story

In pre-Colonial times, California’s forests burned regularly, thanks to lightning strikes and fires deliberately set by Native Americans.Photograph by Kevin Cooley for The New Yorker
Thanks to a Smokey Wire reader for this one!

The story is about Sagehen Creek Field Station run by UC. Well worth reading in its entirety. Lots of leadership, including by Scott Conway the silviculturist as well as I’m sure many others on the District, the Sagehen Creek folks, collaboration and patience. Sure, we all talk about the need for prescribed burning, but in this New Yorker story, the fact that it is University of California researchers saying it (and mechanical treatments prior) gives it extra cred in some communities.

As he led us through the trees, Brown pointed out that we were following an old railroad bed. Sagehen was clear-cut in the mid-nineteenth century to help build the railways and mines of the gold-rush era. (Sutter’s Mill, where the first gold was discovered, in 1848, is less than a hundred miles away.) After loggers felled the large trees, smaller ones became fuel for locomotives, and the eastern slopes of the Sierra are so dry that there are still stacks of cordwood left over from the eighteen-eighties. Nearby, Brown bopped up and down on pine needles that coated the ground. “See this?” he said. “These go down ten inches deep in places.”

In 2004, one of Brown’s colleagues at Berkeley, a fire scientist named Scott Stephens, came to Sagehen and took samples from the stumps of huge trees cut down during the gold-rush era. Examining tree rings and scorch marks, Stephens was able to construct a record of fires dating back to the sixteen-hundreds. His findings confirmed that, in pre-Colonial times, Sagehen burned regularly. Those fires sometimes occurred naturally, from lightning strikes, but they were also deliberately set by Native Americans. The consensus now is that the entire Sierra Nevada burned every five to thirty years.

So they tried to design some SPLATS (previously discussed here in an TSW interview with Dr. Mark Finney.

Brown and the rest of the Sagehen planning team decided to pursue a strategy that had recently been developed by a Forest Service scientist at its Rocky Mountain Research Station. Affectionately known as splat, for Strategically Placed Landscape Area Treatment, the technique involves clearing rectangular chunks of forest in a herringbone pattern.This compels any wildfire to follow a zigzag path in search of fuel, travelling against the wind at least half the time. The splats function as speed bumps, slowing the fire enough that it can be contained, while allowing the Forest Service to get away with treating only twenty to thirty per cent of any given landscape.

Adapting the splats to Sagehen’s terrain took four years. Then, just as the plan was being finalized, a paper was published documenting the unexpected decline of the American pine marten at Sagehen. The marten, a member of the weasel family, is not endangered, but its population levels are seen as a useful proxy for forest health. Soon, the Sagehen planning team heard from Craig Thomas, the director of the environmental group Sierra Forest Legacy, which has a long history of litigation against the Forest Service. Thomas asked them to redesign the project, with an eye to protecting marten habitat.

Thomas, a small-scale organic farmer in his seventies, told me that he was astonished when the Sagehen group, especially the Forest Service, seemed open to the idea. “Instead of getting their backs up, they jumped in with both feet,” he said. Conway recalled his own response a little differently. “I was, like, really?” he said. “It meant a bunch of complexity, and making this project, which was already really too long, much, much longer.” Still, as Thomas recalls, Conway “went away and read every marten ecology paper in existence by the time the next phone call happened. And I went, Ah, this is somebody I think I want to work with.”

So in 2010 the team, which had now been working together for six years, began planning all over again, this time with an even larger group of collaborators and a more expansive goal. “It started as science, but it became diplomacy,” Brown told me. “How could we get all these people—groups that didn’t trust each other, were actively suing each other—to a consensus on what was best for the forest?”

Brown secured grants, hired a professional facilitator, and brought together loggers, environmental nonprofits, watershed activists, outdoor-recreation outfits, lumber-mill owners. Sometimes there were upward of sixty people at meetings. Scientists from all over the region presented the latest findings on beaver ecology or the nesting behaviors of various bird species. To categorize Sagehen’s diverse terrains—drainage bottoms with meadows and those without, north- and south-facing slopes, aspen stands with conifer encroachment—working groups hiked almost every yard of the forest.

Arriving at a consensus took years of discussion, but, in the end, the strategy the team decided on turned out to mimic the way fire naturally spreads. For instance, fire burns intensely along ridges and more slowly on north-facing slopes. Martens, having adapted to these conditions, rely on the open crests to travel in search of food and mates, while building their dens in shadier, cooler thickets. Following the logic of fire would create the kind of landscape preferred by native species such as the California spotted owl or the Pacific fisher—a mosaic of dark, dense snags and sunlit clearings, of big stand-alone trees and open ridgelines connecting drainages. Conway then led an effort to formulate a detailed implementation plan whose treatments varied, acre by acre, according to the group’s predictions. Some areas were to be left as they were, some were to be hand-thinned with a focus on retaining rotting tree trunks, and some were to be aggressively masticated and then burned.

Typically, a Forest Service project takes two months to plan. Sagehen had been in the works for nearly a decade, but Brown eventually achieved the impossible: a plan that everyone—environmentalists, scientists, loggers, and the Forest Service—agreed on. Then, three days before the group was due to sign off on the plan, there was yet another hitch: in one of the units of Sagehen that were scheduled to be burned, a Forest Service employee discovered a nesting pair of goshawks—raptors that are federally protected as a sensitive, at-risk species.

This time, it was the conservationists who compromised. “I could have said, ‘O.K., this area is now off limits, and if you don’t believe me I’ll sue your ass,’ ” Craig Thomas recalled. But, after some discussion, he agreed to stick with the plan. He knew that burning might make the birds leave or fail to fledge young, but, he told me, “the collaboration effort and what we had accomplished together mattered more.”

But, despite the success of the project, enormous challenges remain. The Forest Service struggles to muster the resources and the staff necessary to burn safely. The California Air Resources Board restricts prescribed burns to days when pollution is at acceptable levels and the weather likely to disperse emissions from fire. In practice, this means that burning can occur only during a few weeks in the spring. In summer and autumn—the seasons when forests would burn naturally—the state’s air usually falls foul of the Clean Air Act. These are also the months that are most prone to uncontrollable wildfires, whose smoke is far more damaging to human health than that from prescribed fire. But, perversely, because wildfires are classified as natural catastrophes, their emissions are not counted against legal quotas.

Across the region, the Forest Service is devising projects to thin and burn on the Sagehen model. Meanwhile, Brown has helped launch the largest forest-restoration venture yet undertaken in California: the Tahoe-Central Sierra Initiative. It encompasses an enormous swath of forest that extends as far north as Poker Flat, level with Chico, and as far south as the American River, level with Sacramento. Brown’s goal is to return fire to three-quarters of a million acres in the next fifteen years.

This may sound like the same old..but again, why not export chips? I’d expect to see something more organized in California or with other states to develop markets for this material, e.g.chips to South Korea in Arizona, CLT mill in Washington, and so on. At least there would be folks at Cal working on this. When did using stuff become less-cool research? Back in the day. it would have been a good research consortium proposal with related education and extension to apply for NIFA grants. We have been talking about this for at least 20 years..

Brown has begun working with a group of researchers at U.C. Santa Cruz to imagine the outlines of a timber industry built around small trees, rather than the big trees that lumber companies love but the forest can’t spare. In Europe, small-diameter wood is commonly compressed into an engineered product called cross-laminated timber, which is strong enough to be used in multistory structures. Another option may be to burn the wood in a co-generation plant, which produces both electricity and biochar, a charcoal-like substance used to replenish soil. Brown has also been talking to a businessman who hopes to burn waste wood to heat an indoor greenhouse-aquaculture operation. His vision is to provide organic vegetables and shrimp to buffets in Las Vegas, and then to interest California’s cannabis farmers in using shellfish-dung-enriched biochar as fertilizer.

Here’s also a link to George Wuerther’s comments published elsewhere. https://www.counterpunch.org/2019/09/02/what-the-new-yorker-got-wrong-about-forests-and-wildfires/

There are sidebars that scientists working at Forest Service Research Stations or professors in forestry schools must observe if they want to keep their jobs and/or funding. These individuals do not fudge the data, but they start with specific questions and assumptions that beget certain conclusions.

Really? And others don’t frame questions that beget “certain conclusions”?

19 thoughts on “A Trailblazing Plan to Fight California Wildfires: New Yorker Story”

  1. “Brown has begun working with a group of researchers at U.C. Santa Cruz to imagine the outlines of a timber industry built around small trees, rather than the big trees that lumber companies love but the forest can’t spare.”

    The timber industry in the western US already is built around small trees. In Oregon, large logs are often less valuable than smaller logs (less than ~32 inches in diameter), because most mill aren’t set up for larger logs.

    Reply
    • Indeed! Some mills will not pay as much for “Oversized Logs” at their small log mills. Even SPI only has ‘regional’ big log mills, where the few large logs from USFS projects go to. Transportation costs are higher but, since SPI has a virtual monopoly on Federal timber, they have a lot of control on how milling is done in California.

      Hey, I’ve even seen tiny logs piled high on log trucks, with a 7″ dbh and 8.5 feet long being a minimum piece. I once counted 212 logs on one load.

      Reply
  2. See: What the New Yorker Got Wrong About Forests and Wildfires
    by GEORGE WUERTHNER

    https://www.counterpunch.org/2019/09/02/what-the-new-yorker-got-wrong-about-forests-and-wildfires/

    The New Yorker recently published an article titled Trailblazing plan to fight California Wildfires that contains misinformation. I’ve had many people ask me what I thought of the piece. Given the influential nature of the New Yorker, I decided to respond here.

    The writing is good. There is much that is accurate about wildfire in the article, such as the problems with the Clean Act and how it limits prescribed burning. But in many ways, the piece serves as propaganda for the Forest Service and its logging agenda.

    The main problem is that the author relied upon a limited number of sources for her article, and all the sources are pro logging/thinning the forests. The on-going propaganda promoted by the Forest Service is that large fires are “catastrophic” and such blazes are demonized to justify a pro-logging agenda. One would not know that many of the statements in her article are either vigorously debated in fire ecology circles with no clear consensus.

    For example, she boldly states that frequent low-intensity blazes can preclude large fires. But there are counter-arguments and research that challenges such assertions which were never mentioned. While prescribed burning and thinning may “appear” to reduce fire spread under low to moderate fire weather conditions, there is a wealth of evidence that these management prescriptions usually fail in the face of fires burning under extreme fire weather conditions.

    More than 200 preeminent scientists signed a letter to Congress finding that proposed solutions to wildfire like thinning forests are ineffective and short-lived.

    To quote from the scientists’ letter:

    “Thinning is most often proposed to reduce fire risk and lower fire intensity…However, as the climate changes, most of our fires will occur during extreme fire-weather (high winds and temperatures, low humidity, low vegetation moisture). These fires, like the ones burning in the West this summer, will affect large landscapes, regardless of thinning, and, in some cases, burn hundreds or thousands of acres in just a few days.”

    The letter goes on to say:

    “Thinning large trees, including overstory trees in a stand, can increase the rate of fire spread by opening up the forest to increased wind velocity, damage soils, introduce invasive species that increase flammable understory vegetation, and impact wildlife habitat.”

    There are sidebars that scientists working at Forest Service Research Stations or professors in forestry schools must observe if they want to keep their jobs and/or funding. These individuals do not fudge the data, but they start with specific questions and assumptions that beget certain conclusions.

    For example, in a paper published in the Proceedings of the National Academy of Science “Adapt to more wildfire in western North American forests as climate changes” the authors concluded: “the effectiveness of this approach (logging and burning) at broad scales is limited. Mechanical fuels treatments on US federal lands over the last 15 y (2001–2015) totaled almost 7 million ha (Forests and Rangelands), but the annual area burned has continued to set records. Regionally, the area treated has little relationship to trends in the area burned, which is influenced primarily by patterns of drought and warming.”

    The author of the New Yorker piece apparently is unaware of these nuances, nor did she consult with any of the many scientists who come to differing conclusions about the effectiveness of prescribed burning and thinning.

    All of the people she interviewed are part of the “school” that attributes large fires to past “fire suppression” which they assert has led to “fuel build-ups”.

    In her opening few paragraphs, the author describes a prescribed burn where people purposefully light fires under conditions where the fires are likely to remain small and “controlled”.

    The author suggests that if we had more use of prescribed burns, large so-called “mega fires” would be snuffed out by a lack of fuel. Problem solved.

    She then goes on to describe “mega fires” as “uncontrollable”. And she notes that the resulting “the cinder-strewn moonscape that mega fires leave behind is unlikely to grow back as forest.” She says the forest is “incinerated.”

    So the first problem with the article occurs in the first few paragraphs where death and doom are used to describe what are large blazes. The term “mega fire” is itself pejorative suggesting that large blazes are somehow out of the ordinary or unusual and destructive. By contrast logging the forest is called “restoration.”

    Never mind that high severity and the snag forests that result from them have some of the highest biodiversity in the West. They are hardly “moonscapes”.

    This is due in part to the fact that most fires burn in are a mosaic of fire severity. You tend to have a quilt like patches of burned to lightly burned areas mixed with more severity burned areas. As a result, there is usually plenty plant regeneration after a blaze though it may be flowers, grasses and shrubs or different species like aspen or oaks that are favored by the opening of the forest canopy. No matter what grows back, it is not a “moonscape” for long.

    Secondly, even in high severity fires, most of the tree boles remain after the blaze. They are hardly “incinerated.” Several studies suggest only around 3% of mature trees are consumed in a blaze, which is why we have snags remaining.

    Furthermore, though fuels due to fire suppression might be an issue in a few specific forest types—predominately ponderosa pine forests—most of the vegetation in California as well as the rest of the West is not ponderosa pine and is characterized by long fire rotations.

    For example, much of California is covered with chaparral. Chaparral tends to have long fire rotations up to a hundred years or more. And when this plant type burns, it does so naturally at high severity. Fire suppression does not influence wildfires in chaparral. Indeed, most of the larger recent fires that have burned in California are largely in chaparral ecosystems including the Thomas Fire by Santa Barbara, the Tubbs Fire by Santa Rosa, and so on.

    Most of the large fires we are witnessing today are a consequence of climate change and natural climate variation, not a “disastrous buildup of forest density” as the author and her sources suggest.

    First, the idea that areas with a lot of fuels are more prone to high severity fires can be challenged both scientifically and logically. The highest biomass on the West Coast is in the coastal forests of Oregon and Washington. Despite the abundance of fuels, these forests seldom burn. If fuels were the most important reason for large fires, we would expect these areas to be the center of so-called “mega fires.”

    In addition, any number of studies have shown that areas that are “actively managed” (meaning logged) whether it is private timberlands or public forest tend to burn at higher severity than protected landscape where presumably the fuels are greatest.

    One study that reviewed 1500 blazes around the West found the highest severity fires were in managed logged landscapes while parks and wilderness areas where there is no “active” management tended have lower severity blazes.

    If you have drought, low humidity, high temperatures and most importantly, you have large fires. Since the canopy of dense forests provides shading and thus cooling of the forest floor, and also slows down wind penetration, wildfires are often slowed when they enter an old growth forest stand. By contrast, thinning the forest opens the stand to greater solar penetration (drying) and greater wind penetration, which can “fan” flames.

    Keep in mind the 1910 Big Burn that raced across some 3-3.5 million acres of Idaho and western Montana occurred long before there was a “fire suppression” to create “excessive fuel.”

    The author repeats the often-heard phrase that “a century’s worth of fire suppression” has created large fuel build-ups. This assertion fails to acknowledge that much of the last century between the late 1930s through the early 1980s was cool and moist due to natural climate variation. Indeed, in the 1970s there were fears that a new Ice Age might be upon us.

    What happens when the climate is cool and moist? First, you get few ignitions. Second, the burns that do start, do not spread rapidly. Third, you have favorable conditions for tree germination and establishment which in turn leads to “denser” forests.

    Furthermore, back in the early 1900s, all fire suppression was done by guys riding mules through what is largely wilderness. To suggest that this was an effective fire fighting force beggars the imagination. It was only after the advent of helicopters, smoke jumpers, and modern fire fighting equipment that one might be able to suggest fire suppression had a potential role in slowing fires.

    But even this is hard to believe. Was there that much less fuel in 1987 in Yellowstone National Park than in 1988 when more than 1.2 million acres burned in the ecosystem? And why could firefighters control fires prior to 1988, but suddenly the same equipment, including at one point more than 10,000 firefighters failed to contain the blazes? Why did the fires suddenly stop on September 11th when it snowed?

    All this is ignored by the advocates of the “century of fire suppression” proponents.

    The idea that Indians burned most of the California landscape and thus precluded large blazes is another mythology she incorporated in her essay. For one thing, some research has found that Indian burning, to the degree, that it did occur, did not add significantly to the total acreage that burns naturally. Yes, in the immediate area around villages, and other high use areas, Indian burning likely exceeded the natural background fire.

    Then as now, the majority of all acreage burns only when climate/weather conditions are favorable for fire spread. For instance, some 95-99% of all fires seldom burn more than 1-5 acres before they self-extinguish. In other words, whether a fire is started by lightning or humans, most fires do not spread very far.

    If, however, the right conditions exist for fire spread, particularly if the wind is blowing hard, you will get a large blaze. That is why most of all acreage burned annually in the West is due to a very small number of blazes that occur during “extreme fire weather” conditions. If you don’t have these conditions, you don’t get a large blaze.

    We have evolutionary evidence for this situation. For example, take sagebrush ecosystems. Most sage species must regenerate from seeds. The latest science suggests sagebrush burns anywhere from 50-400 fire rotations. If Indians were burning sagebrush ecosystems every few years as some suggest, there would be no sagebrush landscapes. And there would be no sagebrush obligate species like sage grouse, pygmy rabbits, sage sparrows and the like.

    At the other end of the spectrum, higher elevation forests of spruce, fir, and mountain hemlock also burn infrequently, often hundreds of years between significant blazes, but when they do, they often burn at high severity as well.

    She finishes up her piece by describing how allowing fires to burn, and/or thinning can result in higher water flows from the Sierra Nevada. A review of the assumptions by Chris Frissell and John Rhodes The High Costs and Low Benefits of Attempting to Increase Water Yield by Forest Removal in the Sierra Nevada found that while there might be modestly higher flows in high snow years, in drought years, there was little extra water. In other words, at the time when you might want more water flows, you are unlikely to see it. Regrowth of vegetation promoted by forest removal will suck up much of the expected additional flows and countering this effect would require clearing at least 25% of a watershed every ten years—an expensive and generally impossible task.

    What is obvious to anyone familiar with the scientific literature on wildfire is that while the author dutifully and accurately reported on the opinions and work of her sources, she did not realize that much of what she reported is contested or countered by other scientists and sources.

    While permitting more wildfires to burn in remote areas is a positive outcome of our understanding of the important role of wildfire in forest ecology, the idea that massive thinning and burning can preclude large fires is delusional. In the end, the focus should be on reducing the vulnerability of homes and cities to fires–and this starts at the home and works outward–and preventing the construction of homes in the “fire plain”. Unfortunately, the article gives the impression that all that is needed is more management of our forests.

    Reply
    • Matthew : Wuerther says the scientists that are cited are wrong and scientists that agree with him are right. He pretty much implies that they are from “forestry schools” and biased. Of course, scientists who agree with him frame things completely objectively and aren’t biased. As if.. there was a correct framing. That’s why STS experts suggest framing and designing research collaboratively.
      But, that’s pretty much the same old stuff. What Wuerther seems to skip is the motivation of the environmental groups who are also convinced that this is the best thing to do. What possible motivations could they have for collaborating on this if they really think it won’t work? Have they been brainwashed by the FS or by biased scientists?
      And why would we think that a Montanan would know more about what Californians should be doing and their forests than people who have been working together for 10 years on a particular area of land with a particular history, environment, fire history and so on?

      Reply
      • Fantastically said Sharon. I normally ignore and overlook the (mostly) nonsense Koehler writes on here. Even when it is a valid point, he seems to have missed that the world changed and it is no longer 1993. Or that the ‘evil’ timber companies and others are now the ones who speak with reason and civility (right or wrong, agenda driven or not), and his style simply makes him and his ilk look…bad.

        As to attacking scientist, he has made it clear he is bitter about the treatment of certain intellectuals such as Chad Hanson, Derek Lee, etc. In fact, the other day he had a comment where he lumped Don Donato in with these people; I think Dr. Donato would be rather appalled to be lumped in with them, while ‘scientists’ such as Hanson and Lee have been repeatedly, with a plethora of evidence, proven to be agenda driven and dishonest.

        More to the point, this post was a fantastic example of MOVING THE BALL FORWARD in a world that needs more of it. But clearly, some people would rather it be 1993, or we simply construct infrastructure from concrete and metal, materials that are oh so renewable.

        Reply
        • Takes a real special person to anonymously attack someone, eh?

          For the record, my supposed “lumping” of Dr. Donato “in with these people” was simply pointing out this fact:

          “Anyone is welcome to go through the history of this blog and see the countless times that people like Dr. William Baker, Dr. Beverly Law, Dr. Chad Hanson, Mike Garrity, Dr. John Talberth, Dr. Daniel Donato and host of other scientists, researchers and forest protection activists have been dragged through the mud.”

          You’ll note that I never mentioned Dr. Lee…and also for whatever it’s worth, Dr. Law was Donato’s former advisor at OSU.

          Reply
          • You have had no problem attacking anyone and anything. So yes, I prefer to stay anonymous. You get what you get. As in another post where a commenter pointed out who unprofessional your posts are, and how they don’t really get you anywhere here, or any traction.
            Dr. Lee is lumped in by association and authorship. Or you can play word games.
            Advisors? Ok. Let’s discuss the relationship Dr Hanson has with his former advisor… would you say it is good and professional? That his former collogues have never brought up serious issues with his past work?

            I also notice you never bother to directly address issues that someone legitimately brings up showing the flawed or agenda driven approach the people you are citing use. And do not point fingers at others on here. They’re just names on a board, and not actually making real decisions or science. But you clearly have every intention of stopping anything you don’t agree with.

          • RE: “But you clearly have every intention of stopping anything you don’t agree with.”

            You realize I’m one of the moderators of this blog? And during the course of the past 10 years or so have approved hundreds of comments on this blog that I disagree with? Including approving comments on this blog from anonymous people who go after me?

            For the record, in this thread I simply shared a commentary by George Wuerthner, which is directly related to the New Yorker piece. Yet I get anonymous attacked for that? Whatever dude. Here’s a prediction: You will anonymously come and you will anonymously go, but I will remain posting and engaging here.

            P.S. Here’s a history of all the posts I’ve made to this blog, which have contributed to the content and issues discussed here: https://forestpolicypub.com/author/cleangreensustainable/

  3. I’m happy to hear that “splats” are being properly viewed as something that does not contribute to ecological integrity (where they are a landscape pattern not seen in nature).

    Reply
        • I’m not sure I get Sharon’s argument, but I think it’s made of straw. The requirement that national forests provide ecological integrity applies to “ecological characteristics.” It does not apply to man-made things so they don’t have to be eliminated to have integrity. Whereas “ecological conditions” is defined to include human developments. That’s a fuzzy, but important distinction. Forest plans must provide both ecological integrity/NRV for ecological characteristics (219.9(a)) and ecological conditions necessary for at-risk species (which may include things like security from human activities) (219.9(b)).

          Reply
          • Jon, that is incredibly confusing to me, who survived involvement with the two previous planning rules. I don’t know what others may make of it. Could you take a real life example, as a post here, say a specific ecological characteristic and talk about how integrity or NRV applies? Also a specific ecological condition. Maybe from the Flathead? I think that would be illuminating to many of us.

        • I realize that … and so the black footed ferret driven to almost extinction has been bred by humans since to maximize diversity, is now the species unnatural? Does the act of direct human intervention cause something to be unnatural (say rust resistant sugar pine) or can indirect actions that affect selection in the wild (say presence of hunters) also be unnatural? And if climate change is affecting selection pressure through changes in the environment is nothing “natural” anymore.?

          Reply
          • That’s undue focus on the term “natural,” which as I’ve explained elsewhere is not the actual requirement (and I’ve agreed it’s an unfortunate word choice). The Planning Rule specifically includes “species composition and diversity” as ecological characteristics subject to the NRV requirement, but not genetic diversity. I would say that there is some level of both ferrets and rust necessary to meet this requirement. If ecologically sound levels of game species can be maintained artificially, that’s probably fine (though ecological integrity would require the full complement of predators).

            Note that all of this is qualified in §23.11a of the Planning Handbook, which lists a number of exceptions and concludes:
            “If past conditions relative to the natural range of variation are not appropriate, practical, possible, or desirable approaches:
            a. The Interdisciplinary Team should design plan components based on a general scientific and ecological understanding of the conditions that would sustain key ecosystem characteristics and sustain at-risk species using factors such as: representativeness, redundancy, habitat associations of particular species, disturbance dynamics, or observed conditions in reference areas.”

            The bottom line for diversity is “would sustain key ecosystem characteristics and sustain at-risk species.” The Rule favors NRV, but recognizes the limitations. I realize an example of how this actually works would be helpful. It’s just a bigger project than I’ve been able to get to.

        • Sharon: – “Mountain bikes and ski lifts are not found in “nature” but cows are…”

          Mystery Poster: – “New world bovine species evolved from their now-extinct auroch ancestors via artificial selection (i.e., domestication and selective breeding by humans).”
          ===

          So ?

          Mystery Poster: – “Cows as we know them are just as man-made as ski lifts and mountain bikes.”
          ===

          But unlike ski lifts and mountain bikes, cattle can be used to biomimic what wild animals use to do in servicing ecosystems out in nature when the larger wild animals were in greater abundance. But of course this takes regular hands on management and moving them continually.

          Reply
          • Kevin — Public lands grazing would (arguably) mimic natural processes if apex predators were also also allowed to proliferate and depradate those animals as a substitute food source for native ungulates.

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