Still Against Commercial Logging After All These Years: Should the Sierra Club Update its ECL Policy?

I was curious about the claim that “forests can’t sell trees from areas that are not in the timber suitable acres in a forest plan”, as we discussed for this project here. Further exploration yielded the information that the Sierra Club is one of the plaintiffs in the current litigation. Which made me wonder whether they had ever changed their policy with regard to selling trees from National Forest. I looked on their website and it appears that they still have this 1996 policy.

The Sierra Club support[s] protecting all federal publicly owned lands in the United States and advocate[s] an end to all commercial logging on these lands.
Adopted in the Sierra Club Annual Election, April 20, 1996

Now 1996 was 24 years ago, and perhaps some things have changed since then. Especially in California, where the Sierra Club headquarters are located, many folks think that if wood from fuel treatment projects (or salvage) could be sold, it should be, and that would be better, say, for climate than burning it in piles.

I also found this clarification from 2012.

Commercial logging is the removal of trees from federal lands as commodities — whether for lumber (or other building materials), pulp/paper, energy, or other commodity production — regardless of the stated rationale for the logging project, or whether some term other than commercial logging is used to describe the project.

There has been a great deal of pushback in various op-eds that environmental groups’ efforts and lawsuits have nothing to do with ability to get fuel treatments (and prescribed burning, where pre-treatment is necessary) done on federal lands. (My view is that it’s one of many factors).

But in an effort to be logical, for that to be true then:

(1) The Sierra Club has been completely unsuccessful with this policy over 24 years, that is, it has no effect because no fuel treatments would potentially incorporate commercial logging (in this case, they might want to reconsider the policy), or

(2) Number of acres treated for fuels is invariant to whether trees are sold or not. (I think there are two piles of funding one for fuel treatment and one for timber, and if you can do both you can fund a project from either or both pots, but I’m sure it’s more complicated and would like to hear from some TWS experts on this.)

But with what we know today, the alternatives to selling trees from fuel treatments (because many trees can’t be sold, and the FS still does fuel treatment) is to pile and burn them, or chip and mulch or …

It’s an advantage of interest groups, unlike federal agencies, that they can say what shouldn’t be done, without being clear about what they think should be done instead. It’s a great position to be in, because you don’t have to consider how technically realistic the alternatives are, nor do you have to produce a document describing them, and the environmental pros and cons of each. Nor put those out for comment, or debate what the best available science says.

Perhaps it boils down to “you can’t trust those people to be honest about the reasons for cutting trees, and we’re going to assume that all tree cutting that might be sold is really for commercial timber production.” It seems to me, again,  that in 24 years, there might be other ways of dealing with these concerns.

When the FS was exploring getting wood certified by FSC, I heard that the FS couldn’t do it because the Sierra Club was against it. I was surprised that one organization could have enough clout to put an end to an idea. I’ve heard this several times, but did not sit in on the meetings myself, so can’t vouch for it. But that idea was for making the case that if people use wood, the NFs can produce it just as sustainably as anyone else. It makes perfect sense that to the Sierra Club  ECL means ECL no matter how gentle the practices used.

What I’m thinking about is an independent certification body that could say “we have looked at this and these folks are cutting trees for other reasons. The choices are leaving stacks and burning versus selling them and having people use them (substituting for Canadian imports or ??).” It seems to me a certification body would be cheaper, and better, and with my design incorporate public comment, so more transparent,  than going to court and having folks digging through federal employees’ emails for signs of hidden commercial intentions.  And at the end of the day the judge may well end up ruling on something completely different, leading to appeals and more court cases and so on.

I think that such a body might also help folks in the Sierra Club who might be puzzled by the complexities of the 2012 memo. If, when I worked for the FS, I had gotten a memo like that, I would have interpreted it “you are free to do what you think is right, unless someone more important than you finds out and disagrees, and then you will have to walk back agreements you made and possibly get in a lot of trouble.” Been there…

18 thoughts on “Still Against Commercial Logging After All These Years: Should the Sierra Club Update its ECL Policy?”

  1. “When the FS was exploring getting wood certified by FSC, I heard that the FS couldn’t do it because the Sierra Club was against it. I was surprised that one organization could have enough clout to put an end to an idea. I’ve heard this several times, but did not sit in on the meetings myself, so can’t vouch for it.”

    For whatever it’s worth, there were dozens and dozens of organizations – including the Sierra Club – that were opposed to FSC and/or SFI certification of U.S. Forest Service lands.

    For those interested in exploring some of the reasons for opposition, I’d recommend this post from Andy Kerr: http://www.andykerr.net/kerr-public-lands-blog/2019/4/11/certified-wood-from-national-forests-no-make-that-hell-no

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    • Also, while the title of this post is “Still Against Commercial Logging After All These Years: Should the Sierra Club Update its ECL Policy?” and Sharon writes: “I looked on their website and it appears that they still have this 1996 policy.”

      As Sharon herself points out, the Sierra Club did, in fact, update their ECL policy in 2012. Here’s the same link to what Sharon posted above: https://www.sierraclub.org/sites/www.sierraclub.org/files/forest.pdf

      Below is what the document says. It appears to me that the Sierra Club would agree with Sharon that “1996 was 24 years ago, and perhaps some things have changed since then”….which is very likely why they updated and clarified their ECL policy in November 2012, which was a little more than 7 years ago.

      “While numerous written exchanges in 1995 and 1996 clarified the relationship of the ECL policy to Sierra Club activities, the passage of time and arrival of newer Club activists warrants a restatement of this relationship in order to provide guidance and consistency. These guidelines are divided into two parts: examples of things (a) that do not conflict with the ECL policy, and (b) that might conflict with the ECL policy.

      No Conflict with the ECL Policy

      The ECL policy does not preclude or prevent Club activists/entities from, for example:

      Negotiating with a federal land management agency to improve a site-specific forest management project, or land management plan, and reduce its potential environmental impacts, even where the ultimate negotiated result is a project/plan that involves some commercial logging. As the proponents of the ECL policy made clear in numerous Sierra Club election communications in 1995 and 1996, the policy does not “tie the hands” of Club activists, staff, or entities seeking to reduce adverse impacts of projects/plans. To avoid confusion, in such cases it may be advisable for the Club entity/activist to describe the Club’s position with regard to the commercial logging component of such a resulting project as one of non-opposition, rather than support (for example: “While we do not support the commercial logging components of this project [or plan], we feel that
      agency staff have negotiated in good faith, and have added numerous positive aspects [e.g., this might include things such as prescribed burning, logging road decommissioning, and/or snag creation for cavity-nesting wildlife, etc.] and have added significant mitigations to reduce adverse impacts. For these reasons, though we oppose the commercial logging components, we do not oppose [or we support] the overall project [or plan]”).

      Involvement in, or support of, personal use firewood permits for removal of small-diameter trees from federal lands for the permit holder’s use. Commercial logging is the removal of trees from federal lands as commodities — whether for lumber (or other building materials), pulp/paper, energy, or other commodity production — regardless of the stated rationale for the logging project, or whether some term other than commercial logging is used to describe the project. Removal of small quantities of wood material for personal use is not commercial logging. Similarly, an agency’s use of small trees cut on a national forest for infrastructure on that national forest (e.g., fencing along
      trails or interpretive centers) is not commercial logging.

      Supporting proposed federal legislation or regulations that increase protections for federal public lands, but do not specifically end all commercial logging on the public lands covered by the proposed legislation.

      Supporting proposed federal legislation or regulations that protect some federal lands but do not alter the multiple-use management outside of the protected areas. Legislation and regulatory proposals vary widely and, as always, such proposals would be evaluated on a case-by-case basis.

      Conflict or Potential Conflict with the ECL Policy

      Things with the potential to conflict with the ECL policy could include:
      Blocking, suppressing, or otherwise actively undermining the advocacy of an end to commercial logging on federal public lands by any Sierra Club volunteers, staff, or entities. In passing the ECL policy in 1996, the Sierra Club membership voted that the Sierra Club will “support protecting all federal publicly-owned lands in the United States by advocating an end to all commercial logging on these lands. As Sierra Club elections communications in 1995 and 1996 discussed in detail, the primary objective of the ECL ballot initiative was to allow Sierra Club activists, staff, and entities to
      advocate an end to commercial logging on our federal public lands. Whether in the context of comments on individual projects, forest plans, regulations, or proposed legislation, the passage of the ECL policy means that Sierra Club activists, staff, and entities may advocate for the ECL policy, and represents a commitment of the Sierra Club to advocacy of the ECL policy. Accordingly, reasonable accommodation of ECL advocacy must be made. At the same time, the Club should always strive to “speak with one voice.” ECL advocacy in particular contexts has the potential in some instances to lead to the Club taking inconsistent positions. By way of example, if a Club entity is successful in negotiating significant improvements to a site-specific project (or regional plan, etc) that reduce the adverse effects of logging and, in exchange for those improvements, agrees to drop its opposition, it would be inappropriate for another Club entity to continue to publicly
      oppose the project even if it still allows some commercial logging. Accordingly, in the course of such advocacy, reasonable notice and coordination among Sierra Club volunteers, staff and entities at different levels of the organization is expected. The ECL policy is a national Sierra Club policy, and chapters and other Club entities are not entitled to create alternate policies in favor of commercial logging on federal public lands.

      Proposed legislation or regulations that would effectively foreclose options for future protection by explicitly committing or ‘releasing ‘ certain federal lands to permanent or indefinite commercial logging. Proposed legislation and regulations vary widely and, as always, such proposals would be evaluated on a case-by-case basis.

      Supporting the construction/creation of a new mill/plant that would exclusively or primarily process trees removed from national forests as commodities. Such facilities are by nature indefinite in their duration and geographic scope. Supporting potentially permanent facilities designed to extract trees from national forests creates an inconsistency with the Club’s policy of advocating an end to commercial logging on federal public lands.

      Adopted by the Board of Directors, November 17, 2012

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    • Matthew, the story I heard was specifically the Sierra Club being in “the room where it happens” or in this case, didn’t happen. Now I for sure don’t know that to be true and have asked people who were at least next door to “the room where it happened.” I’ll see if I hear anything back from them.

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  2. I find it ‘interesting’ that for all of those 24 years, the Sierra Nevada National Forests (all of them) have been “commercially logging” and the Sierra Club hardly makes a peep about either the whole of the plan, or the individual green sale projects. Such “commercial” projects which sell green timber are rarely litigated (or ‘tree-sit’), in those Forests.

    Does the silence of the Sierra Club ‘say’ anything?

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    • Larry, I don’t know why folks in those kinds of organization go after some things and not other things, but I think it’s interesting to observe.

      In this case, the Cooper Creek Watershed Project, perhaps Georgia Forest Watch called them in.

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      • My guess is that they feel litigation will fail, as the Forest Service is jumping through all the hoops, in those Forests. Sure, they would like to return the diameter limits back to 20″ but, I think the SC knows that a collapse of USFS vegetation management would likely be catastrophic, in multiple ways.

        A moratorium on logging would result in a loss of important knowledge and experience. That has become scarce in the agency, anyway, with no plan to restock the logging knowledge base. It’s sad that timber temps have no career ladder.

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  3. “Commercial logging is the removal of trees from federal lands as commodities….”

    But they’d be OK with cutting trees and placing the logs in streams as salmon habitat? Or using them for erosion control? Guard rails on USFS campground roads? Bike barriers on wilderness trails? Firewood for seniors and needy folks?

    Reminds me of the removal of old-growth trees from one of the Bull Run Reservoirs — source of water for Portland, Oregon — maybe 25 years ago. The trees had washed into the reservoir and had to be hauled out before they damaged the dam. There’s a ban on commercial timber sales in the Bull Run watershed, so the beautiful, tight-grain logs were piled and burned.

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    • I have seen this happen many times. You might well be lighting your oil wells on fire and call it conservation.
      Those logs could of been preserved and use to create products of lasting beauty.

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  4. It bothers me that every tree cut but not used probably means (if demand doesn’t change) that another tree would have to be cut and sold somewhere else. Some of those somewhere elses would probably be other places where logging is not wanted.

    I still suspect that this has less to do with “commercialness,” and more to do with agency incentives to cut trees. If money from timber sales helps fund a district program, that’s an incentive. If they have to sell logs to get credit towards timber targets, that’s an incentive. Prohibiting sales would reduce this kind of incentives.

    But what if the incentives were structured around achieving scientifically sound sustainable ecological conditions (which is what forest plans should be providing), and whether logs were sold had no connection to the purpose of the project? I would be interested in seeing a statement of what kind of vegetation management the Sierra Club would support or not oppose (if any). They could then oppose projects that do not meet these criteria.

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    • Jon, I’m with you in that I think there would be some kind of mechanism/institution/way to build trust. Certification is one such way that builds trust around practices, due at least in part to the independence of the certifying body and auditors.

      I think it would be terrific if each organization would develop a list of “what is OK with us and what isn’t” in terms of vegetation management.

      Perhaps that would be easier for some organizations that don’t have local chapters because if you let the local chapters decide, there would be a major project to harmonize them, and if you didn’t, then local chapters wouldn’t get much latitude in deciding things, which would be discouraging to them.

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      • Here in California, the Sierra Nevada thinning projects also take out crowded trees in the 20-29.9 size class, making projects quite economical. Sadly, SPI has a large monopoly, except in the southern Sierra. They are notorious ‘low-ballers’, often pushing the Forest Service to further lower the “base rates”.

        I was always fully behind the style of thinning we were doing, sculpting the forest into a healthier, more vigorous and aesthetically-pleasing forest. Economics never affected my marking style, under the guidelines and prescriptions. My ability to see and imagine in 3D allowed me to add art to the job of creating a new future forest.

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      • Here’s what FSC says:

        Supplementary Requirements for US Forest Service Lands

        The FSC US Forest Management Standard now includes supplementary requirements for National Forests.

        https://us.fsc.org/en-us/certification/forest-management-certification/federal-lands-certification

        Historically, FSC certification of US Forest Service lands (i.e., National Forests) was not possible due to an agreement amongst stakeholders that additional FSC forest management requirements were needed to capture the unique conditions associated with National Forests, including ownership, history, mandate and resource management objectives.

        In January 2015, the FSC US Board of Directors initiated a process to develop both the necessary supplementary certification requirements for the FSC Forest Stewardship Standard, and the Certification Body Auditing Procedures.

        The process to develop these requirements followed FSC procedures for developing or revising normative documents, including technical input and oversight from a chamber-balanced and consensus-based working group and technical experts. It also included opportunities for broad stakeholder engagement. The supplementary requirements and associated Certification Body Auditing Procedures were taken through three rounds of public consultation. The supplementary requirements for national forests were approved by FSC in March 2019. You can download these documents below.

        This inclusion of supplementary requirements for USFS lands comes at a time when we are actively working on a full revision of the FSC US Forest Management Standard, to bring it into alignment with newer FSC Principles and Criteria (Version 5). As part of this revision process, the supplementary requirements will need to be reviewed to ensure that they also remain aligned with the indicators in the revised standard. You can read more about the standard revision process on the FSC US website.

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        • Thanks for this information Steve, especially this:

          “Historically, FSC certification of US Forest Service lands (i.e., National Forests) was not possible due to an agreement amongst stakeholders that additional FSC forest management requirements were needed to capture the unique conditions associated with National Forests, including ownership, history, mandate and resource management objectives.”

          That account directly from FSC stands in stark contrast to the rumor that Sharon shared above, which she admitted she “can’t vouch for.”

          “When the FS was exploring getting wood certified by FSC, I heard that the FS couldn’t do it because the Sierra Club was against it. I was surprised that one organization could have enough clout to put an end to an idea. I’ve heard this several times, but did not sit in on the meetings myself, so can’t vouch for it.”

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          • Some of you may recall the 20013 National Forest System (NFS) Certification Study: An Evaluation of the Application of Forest Stewardship Council (FSC) and Sustainable Forestry Initiative (SFI) Standards on Five National Forest System Management Units.

            “The report, produced by the Pinchot Institute for Conservation (PIC), documents the study in which third-party auditors evaluated current forest management practices on five national forest units using the existing certification standards of two certification programs, Sustainable Forestry Initiative (SFI) and Forest Stewardship Council (FSC).”

            This study was essential a “what if” audit of 5 National Forests, including the Mt. Hood. I attended one meeting between the auditors and MHNF staff.

            The upshot was that, “Much of what the audit teams observed was considered exemplary, and provided evidence of good overall conformance with most of the FSC and SFI standards currently being applied to private and state-owned and DOD-DOE lands in the U.S.”

            The report document are here:

            https://www.fs.fed.us/projects/forestcertification/

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  5. Reading the article, “The Fires Next Time” in the November 2020 issue of Wired Magazine it seems after the devastating Creek Fire in the southern Sierra Nevada that the US Forrestry would consider allowing A logging company to remove the 150 million dead trees from the western Sierra Nevada, not for profit but for a price (in order to pay the loggers) and use the lumber to improve our lives in some ways suggested by comments above. It seems to me we could be preventing another catastrophic fire. Wisdom ought to prevail rather than stubbornness.

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    • Most of those dead trees have no commercial value. Probably half of them have become unstable, after being dead for over 5 years, making them hazardous to cut. There really isn’t any options left, other than waiting until it burns. Replanting right now, in un-burned snag patches, is useless. Personally, I think the Sierra Nevada, south of Yosemite, is going through major changes in forest types. Us humans are helping this process along, too. It’s reality, and I think people need to start seeing it. I also think the best way to deal with it is to set it on fire during the right conditions, without the liability issues, ‘for the greater good’. That would probably be the only way for it to burn, at lower intensities.

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