Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington

One of the many things that went into the Trump dump the last couple of weeks was the amendment of the Forest Service Eastside Screens old growth protection standard:  “Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington.”    We discussed that at length here.  The Forest Service documentation for the amendment is here. The standard prohibiting harvest of trees >21” dbh has been replaced by this guideline (“LOS” is late and old structure, and it refers to “multi-stratum with large trees” and “single-stratum with large trees”):

Outside of LOS, many types of timber sale activities are allowed. The intent is still to maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible, by adhering to the following plan components: Managers should retain and generally emphasize recruitment of old trees and large trees, including clumps of old trees. Management activities should first prioritize old trees for retention and recruitment. If there are not enough old trees to develop LOS conditions, large trees should be retained, favoring fire tolerant species where appropriate. Old trees are defined as having external morphological characteristics that suggest an age ≥ 150 years. Large trees are defined as grand fir or white fir ≥ 30 inches dbh or trees of any other species ≥ 21 inches dbh. Old and large trees will be identified through best available science. Management activities should consider appropriate species composition for biophysical environment, topographical position, stand density, historical diameter distributions, and Adapting the Wildlife Standard of the Eastside Screens 5 spatial arrangements within stands and across the landscape in order to develop stands that are resistant and resilient to disturbance.

The proper way to read a guideline is that its purpose is a standard: “Managers must maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible.”  It’s not clear to me how you maintain LOS “outside of LOS,” so maybe only “enhance” is applicable, but even that term assumes what you are enhancing is already there to a degree.  This is also weakened by the qualifier “as much as possible.”  This could be interpreted to allow timber harvest even if enhancing LOS conditions is not possible.

The rest of the boldface language should be interpreted as actions that would always be allowed because they would always promote the LOS purpose.  This means that a decision to NOT retain all old and large trees could only be made if it is demonstrated that LOS is enhanced.  “Generally emphasize” allows probably unlimited discretion regarding recruitment.  A decision to NOT prioritize old trees (i.e. to log any old tree before logging large trees) could also only be made if it is demonstrated that LOS is enhanced.  This could be reasonably effective, but it puts a significant burden on project analysis and documentation to deviate from the terms of the guideline.  This is as it should be.  The last part of the guideline lists things that “should be considered,” which shouldn’t be given much weight.

There are also changes in standards and guidelines for snags, green tree replacement and down logs.

The last part of the “decision” is to adopt an “Adaptive Management Strategy.”  This strategy proposes monitoring and thresholds intended to trigger additional restrictions on large tree removal:

  1. If large trees are not increasing in number with appropriate composition, the Regional Forester will impose the Age Standard Alternative across the whole analysis area or by national forest or potential vegetation zone.

  2. If effectiveness monitoring does not occur, the Regional Forester will impose the Age Standard Alternative across all six national forests.

However, under the Planning Rule, these are not plan components and are not mandatory.  While there are “requirements” for regional forester review every five years, this is not a plan component either.  Since none of this “strategy” is enforceable it is of much less benefit than if it had been included as plan components like standards.

(For those interested in how the “natural range of variation” (NRV) is used in forest planning, there is a desired condition for the amounts of LOS in different habitat groups and it is based on NRV.  These new amendments leave in place the desired conditions for LOS previously determined in accordance with the original amendments in 1995.   An appendix in the decision notice includes a “Table 3” that is “only an example” of NRV because, “The number and kind of biophysical environments and the historic and current distribution of structural conditions vary by landscape.”  In order to fully understand the effects of this amendment on a particular landscape, we would need to see the definitions of LOS and actual desired conditions for LOS incorporated into a plan for that landscape.  I didn’t find them in or see them referred to in the amendment documentation, I suppose because they are not changing).


12 thoughts on “Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington”

  1. Those guidelines could qualify as “bafflegab”, at least to most people. — The danger is in the amount of discretion available to the silviculturist. We are considering developing and retaining trees that are 150+ years old. How many different silviculturists will the forest see in that time? And “discretion” only has to fail once along the way. And note, the regional forester will step in to impose a more rigorous standard only after some damage has occurred. There’s just a whole lot of room for this policy to fail at least once in 150 years. And then we start all over again. I suggest our Forests have more “control areas”, for all forest types, where we don’t busyfuss with the landscape.

    • While I am a fan of increased science-based discretion, I also see a need to be very specific in new allowances on the east side. For an example of a potential guideline, I think it would be a good idea to cut larger pines that have a Hawkworth Mistletoe Rating of 4 or higher. I think it would be best show the eco-community that accountable standards are resistant to corruption. Otherwise, in essence, USFS leadership is saying, “C’mon! Trust us!”

      Most Silviculturalists are sharp enough to be able to ‘spin’ their analysis, if they wanted to. However, the best ones are out in the field, looking at actual conditions, and deciding what is the right thing to do. Most of the ones I’ve been around are absolutely sincere and objective.

      • Not my intention to question anyone’s qualifications or sincerity. But, note, you referred to “most” siviculturists. My point was it only took one not so sincere, or broad-minded during 150-200 or more years, or one 4-year period of really bad politics and direction and demands from the top, to undo all that has gone before.

        • James, do you believe that one Administration did “undo all that has gone before”? My point has been that if something the Trump Admin did that is Really That Bad, it will be reversed either due to litigation or the works of the new Admin.

          What examples do you have where “all the that has gone before” has been undone?

          • My view of “all that has gone before” was not in reference to policies or laws of state or federal governments being “unchangeable”. What I was referring to was on-the-ground effects of policies to preserve and reestablish old, large trees. This can take 100 – 200 or more years. Trees can be spared for 100 years on their way to becoming “old growth”, and be cut down when only half way there. That was my original point: in, say, 150 years – how many changes in local foresters, in regional foresters, in federal administrations will occur? and it only takes one to undo all the progress toward old trees that has gone before? And this scenario is enhanced by having only broad directions, allowing lots of local discretion, in forest management. — Your experience with “most silviculturists” has not been the same as my more limited experience. Once, with a student field trip to a ranger district in Idaho, the district ranger claimed they were harvesting on a sustained-yield basis. I asked what was the sustainable harvest for the district. His response: “We don’t know. We don’t have the inventory.”

            • I see. It sounds like the problem is if you say “don’t cut any old trees” then people can’t thin a stand of old trees even to promote old growth characteristics of the old growth.

              This seems like another case where generalized mistrust could be helped by some kind of third-party certification. And perhaps video tours with the trees already marked so we can make our own judgments?

              • I see your point. Early settlers found “old growth” that developed during centuries with no saws in the woods, so people find it easy to trust leaving nature take its course once again. I agree that we can accelerate the development of large trees by controlling stand densities. That will be “artificial” selection, rather than natural selection. But large trees are not the only characteristic of natural old growth. Natural selection may favor disease-resistance, insect-resistance, may result in a different array of patch sizes, for example. I fall back on my first recommendation: We should fall back on having more “control” areas that we leave alone. If we had wilderness areas that were not selected largely as the less tree-productive areas, they would do much better that the current reality. I’m not opposed to production forestry, that emphasizes trees. But not everywhere.

                • When I last marked timber, on the Eldorado, we did have up to 2 acre patches within the cutting unit where we didn’t take any trees. Additionally, we made some openings a little bigger. It was usually up to me to find the preserved patches, as I was better at looking ahead, while marking timber. That was part of the “clumps and gaps” strategy, detailed in a referenced study (GTR-220, I think).

            • The concept of “Natural Succession” often seems inapplicable, these days. Even without human impact/intervention, nature doesn’t always follow “Natural Succession” on its own. For example, after a wildfire, without a good cone crop in the pines, other trees are more likely to seed in. I’ve seen pure natural stands of young true fir dominate a burned landscape, bypassing the brush and pines.

              • I don’t see anything “unnatural” about your example. I admit that with today’s human density, it is easy to find some amount of human impact on just about every process. But I question whether we are smart enough to accurately mimic the “naturalness” that is left. And even when we do know much about how the system works, applying that knowledge is extremely difficult in today’s political world. I still suggest more respect to leaving some areas alone, as stated earlier.

                • My point is that it goes against this cherished concept of “Natural Succession”, either skipping several steps at once, or going on a much different route than some people insist SHOULD happen. Usually, the result of having a true fir thicket, where pines should be growing, is water stress, bark beetles and stand-replacing wildfires. No hint of an old growth seral stage. Sure it is ‘natural’ but, it goes against the textbook example of “Natural Succession”.

                  So, why do some people insist that “Natural Succession” is the most-desired forest condition? I, for one, like the idea of growing an old growth-like forest, quicker than “letting nature take its course”.


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