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21” dbh has been replaced by this guideline (“LOS” is late and old structure, and it refers to “multi-stratum with large trees” and “single-stratum with large trees”):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:
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.
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).