Let’s Talk About Specific CE’s in the Rissien Report: III. Pine Valley Wildlife Habitat Improvement Project

Front page of CE documentation.

This CE is particularly interesting because the scientific basis for treatment is right upfront.

The TNC analysis used a reference baseline concept referred to as Natural Range of Variability (NRV) to look at ecological departure for each ecological system on the district. The current condition of ecological systems was derived using the metric known as Unified Ecological Departure. This is a single measure that integrates concepts of: (1) ecological departure in the traditional sense, (2) high risk vegetation classes, and (3) acceptable amounts of certain unharmful or benign uncharacteristic vegetation classes. Twelve ecological systems on the
district were selected for simulations of likely future conditions under various regimes of active management.
Nine of these systems are brought forward in this analysis (Table 1 and Figure 1). A full breakdown of ecological departure by structural stage for each of the nine systems is available in Appendix 2.

How Many Acres?

320,000 acres are under review for treatments including the 250,000 acres in IRA outside of wilderness areas. Treatments would not occur in areas where vegetation is within a desired NRV or in areas where it is determined that restoration would not be successful.

Note: The TNC analysis maps show where treatments are outside NRV.

Purpose and Need

The purpose and need for the proposed project include:
 Improve and/or maintain wildlife habitat across the Pine Valley Ranger District including habitat for Threatened and Endangered species, Forest sensitive species and Forest focal species and species of concern (California condor, peregrine falcon, northern goshawk, Townsend big-eared bat, spotted bat, elk, mule deer, wild turkey, flicker, grey vireo, broad-tailed humming bird, Virginia’s warbler and brewer’s sparrow).
 Improve and/or maintain stand conditions in mature and old growth pinyon-juniper stands.
 Restore ecosystem composition and/or structure, to reduce the risks of uncharacteristic wildfire effects, and to conditions within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period (36 CFR 294.13 (b)(1)).

Note: the last bullet is language directly from the 2001 Roadless Rule.

Proposed Action

Based on findings from the Landscape Conservation Forecasting and project design features (Table 2) the Dixie NF proposes the following actions to improve wildlife habitat and select vegetation community conditions on the Pine Valley Ranger District:
1. Trend vegetation communities towards the Natural Range of Variability (NRV) as identified in the TNC Landscape Forecasting report (2014) using the most appropriate tool or suite of tools such as: mastication, harrow, seeding (rangeland drill and/or aerial), chipping, lop and scatter, cut/pile, and prescribed burning.

2. Modify existing conditions to improve wildlife habitat and reduce the threat of uncharacteristic wildfire across the landscape by manipulating vegetation age class and species diversity distribution across the project area.

There are 32 pages of detailed documentation, including design criteria. I didn’t see anything about later site-specific analysis on this one. Page numbers would have been helpful.

Again, here is the plain English of this category: 36 CFR 220.6(e)(6) “Timber stand and/or wildlife habitat improvement activities that do not include the use of herbicides or do not require more than 1 mile of low standard road construction”. This one seems to fit wildlife habitat improvement. Would you agree with the use of the category if they did the same activities in the same places, but had documentation and scoping separate for each site? Would you agree if they took some activities (say PB) and used a different category for PB? Based on this reading I don’t see any timber harvest (not pinyon or juniper).

Let’s go back to the way the news story was written: “Under this administration, there’s really only one goal and that’s measured in board-feet,” Rissien said. Uh..I wouldn’t go looking for board feet in PJ in Region 4, myself.

Here’s another quote: “Rissien and others question how the Forest Service can know that such large projects won’t have detrimental environmental effects. By using a CE, the Forest Service doesn’t have to conduct an environmental study, so the public has no information to know if the forest or wildlife is affected.” I’m just pointing out that the condensed info in these CE’s, that is the three we’ve looked at so far, is equivalent to that required in an EA. From CEQ’s guidance here:

While the regulations do not contain page limits for EA’s, the Council has generally advised agencies to keep the length of EAs to not more than approximately 10-15 pages. Some agencies expressly provide page guidelines (e.g., 10-15 pages in the case of the Army Corps). To avoid undue length, the EA may incorporate by reference background data to support its concise
discussion of the proposal and relevant issues.

9 thoughts on “Let’s Talk About Specific CE’s in the Rissien Report: III. Pine Valley Wildlife Habitat Improvement Project”

  1. Everyone knows the USFS and TNC HRV’s are fradulent. The rest follows..
    It is about logs to the mill, nothing more.

    • Paul, I’m curious as to why you would say that TNC’s analysis is “fraudulent”. Which aspects do you disagree with?

  2. Hi Sharon.
    This is question rather than comment. Actually planning to hike in Pine Valleys later in May so I am curious. The EA states “320,000 acres are under review for treatments including the 250,000 acres in IRA outside of wilderness areas. ” Sorry to be naive on planner-speak but what is an IRA? When is says outside wilderness does that infer 70,000 acres treated would be within wilderness? Does the CE show map of treatment area(s)? THANKS!

    • Oh, and they seem to be using the CE in a programmatic way. I think this led to the high numbers of acres that Rissien found in his report. I think it’s a bit confusing as you can think the CE is appropriate for projects, but not agree that a programmatic is the way to go because the site-specific analysis/ comment may or may not be availabe to the public depending on the way they handle the site-specific documentation.

  3. Sorry, here’s the whole quote: “The Pine Valley Ranger District covers approximately 481,000 acres of which 250,000 acres are located within an Inventoried Roadless Area (IRA). An additional 55,000 acres are in designated wilderness. Approximately 320,000 acres are under review for treatments including the 250,000 acres in IRA outside of wilderness areas.”

    I would guess that the total acres on the District are 481K. Of that, a little more than half is in Inventoried Roadless Areas (250K acres). Additionally there are 70K acres of Wilderness in the District. So non-IRA non-W would be 481-250-70, or 161K non-IRA non-W. So their project would include reviewing 320K acres, some in IRA’s and some not, but none in W, for “departure from NRV” based on the analysis. Hope that’s clearer.. not sure…

  4. This sounds more defensible without logging Still the idea of a programmatic CE covering this large of an area just seems incongruous, and probably beyond the scope of the analysis they used to develop the CE. (Any CE with an acre limit has a limit an order of magnitude smaller than this.) For herbicide/pesticide use, forests have often used a forest-wide programmatic EIS. What makes this treatment different?

    They’ll have to demonstrate that the worst case scenario of all the possible implementation choices would not have a significant impact. Why not just do an EA (especially if they are essentially doing the same amount of analysis they would for an EA). (Maybe they have performance targets for CEs to match the national edict to maximize their use.)

    What I find a little troubling is that after looking through their document, I don’t really understand why the current condition is bad for wildlife and why removing mature pinyon pines and junipers would be good for wildlife (they admit wildlife needs cover). They allude to desired conditions in the forest plan (which are surely vague), but they don’t explain what the conditions are that they are aiming for on these sites, but it seems to amount to fewer trees. I don’t think trees are the cause for concern about fire either. They don’t mention livestock grazing as a purpose, but this is an area that is grazed and that is sometimes a motivation for getting rid of trees.

    • Some thoughts.
      1) I don’t understand why not having logging would make a CE more defensible. For me, logging or not logging (mastication, fire) could have equally significant effects.
      2) Herbicide/pesticide use has been identified as controversial, so those projects require more public involvement. I suppose if no one ever objects to grazing/mastication/fire then that would be the difference in level of analysis.
      3) I agree that with this amount of acreage, the level of analysis (BA, BE, specialist reports) to show no significant impact would basically make this an EA. But I don’t think they chose a CE because of CE targets, but that NEPA is so cumbersome. Even if they end up doing the same level of analysis, a CE will always be easier than an EA.
      4) They mention focal species. Different species use different habitats, including trees. So some wildlife need cover (forest and woodland species) and some wildlife shy away from areas where predators would have cover (grassland and shrubland species). So their management will be bad for some species but good for others. Assuming that the NRV analysis identified the “natural” way the landscape “should be”, than they will be benefiting native species that have lost out over time relative to other native or nonnative species.
      5) The number of acres and lack of specified time frame are the main concerns for me here. Hopefully they are doing adaptive management, tracking the results of management actions and adjusting accordingly.

    • Jon, I don’t think that this (wildlife and TSI) CE was developed using the current procedures for developing a category, so I don’t think there is a record supporting it. Maybe someone whose CE history goes back further than mine can shed light.

      It sounds like the current direction is “use CE’s where they fit” not a target based on CE numbers or acreage.

      It seems to me that they explained they used TNC’s NRV. The 2012 Rule, as we have discussed, is big on managing for NRV. So here folks are doing projects directed at getting closer to NRV, and it seems you are asking for a “utility for wildlife” analysis. Which is fine, but if they’re directly managing for specific wildlife species, maybe they could have skipped the NRV step and just rationalized projects on improving wildlife habitat and climate resilience?

      Anyway, if you look at other projects in the Utah Watershed Restoration Initiative https://wri.utah.gov/wri/project/search.html There seem to be a bunch about removing trees to promote brushy habitat for winter range and transition. I think we discussed this before, that without fire, trees moved in and use up water so plants that wildlife like to eat don’t grow (overly simplified).

      I guess you may think it’s really about cows and not wildlife, but at least we can agree it’s not about timber.

  5. I agree that if they are pursuing NRV that should be a good thing, but they didn’t explain why this (huge) area should have fewer trees (or what the actual desired NRV condition for trees is). I also focused on the wildlife habitat improvement CE, which should lead to a discussion of why this is good for wildlife, and should acknowledge that it would not be good for all wildlife. It does not feel like a full disclosure of what’s going on. Maybe because that would be “cumbersome.” Conor, could you elaborate on, “Even if they end up doing the same level of analysis, a CE will always be easier than an EA.”


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