New Forest Service plan revision strategy – not doing it

Speaking of the Salmon-Challis and its forest supervisor, I was also reminded by this article of his novel approach to revising the Salmon and Challis national forest plans, which could mean not revising them.  Now it appears that the regional forester (Farnsworth) is actually considering that option.

Given the choice between full revision, amended revision or no revision of the two plans, commissioners Butts and Smith said full revision is the least desirable option.

 

Butts and Smith said they’re concerned a full revision won’t prioritize local stakeholders’ perspectives or address their specific needs. Fearing pressure from environmental groups who don’t live near the forest using lawsuits against the Forest Service to control what happens to it, the commissioners said they worry the most about losing multi-use land stewardship in the forest to wilderness and scenic river designations.

 

Reaffirming the revision process is about getting the national forest in line with current policies, not the Forest Service caving to legal pressures, Farnsworth told the commissioners she will look at the letters they have sent before rendering a decision. “I’ll make this call, one way or another, because we have to stop the bantering,” Farnsworth said.

My understanding is that the Forest Service is not given that choice, and there is only one call that can be made, and it is misleading the public to suggest otherwise.  NFMA requires that forest plans be revised at least every 15 years.  These forests should have revised their plans by 2002.  Congress has given the Forest Service extensions through appropriations riders as long as they are making reasonable progress.  There is no legal option of amending plans instead of revising them, or just keeping them in place forever.  Even further delay can’t be justified at this point, especially where these are the kinds of reasons.  While the requirement for plan revision doesn’t necessarily mean a plan has to be changed, it does require going through the revision process to readopt the existing plan, with full public involvement.  Maybe that’s what they have in mind …

52 thoughts on “New Forest Service plan revision strategy – not doing it”

  1. Finally a Forest Supervisor who gets it that forest plan revisions are really just venues for the big environmental groups to get more and more public lands locked up with new “recommended wilderness” and “wild and scenic river” designations. No matter how many wilderness areas there already are in an area, the wilderness groups always demand more, while every stream with more than a trickle of water in it has to be designated as “wild and scenic.” And if they don’t get their way, these groups have the resources to keep a new forest plan tied up in litigation for the entire life of the plan.

    Amazing to see a Forest Supervisor wise up to this and just refuse to play. There aren’t too many officials in the Forest Service that actually support multiple use anymore. Most have already surrendered to the idea that all federal lands must eventually be managed as Wilderness, and the only question is how to get there. Not that refusing to play will actually work in the long run since as Jon said, forest plan revisions are mandatory. But the longer she can delay the process the better. Endless delay is after all the environmentalists’ biggest tactic. Might as well use it against them.

    Of course an even better idea would be to start the Forest Plan revision process, and then do the unthinkable and *gasp* select the no action alternative. But that’s just crazy talk.

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      • Oops, my bad. I guess I should have read that a bit more carefully. I should have said it’s the commissioners who get it then. And the Regional Forester would do well to listen to them.

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  2. “Butts and Smith said they’re concerned a full revision won’t prioritize local stakeholders’ perspectives or address their specific needs. Fearing pressure from environmental groups who don’t live near the forest using lawsuits against the Forest Service to control what happens to it, the commissioners said they worry the most about losing multi-use land stewardship in the forest to wilderness and scenic river designations.”

    Their conviction are widely shared – not universally but pretty widely — in and beyond the Northern Rockies. It’s a pretty predictable response to revisions that would deal candidly with effects of reckoning with climate change

    Some of this is happening. For example, the Custer-Gallatin NF does report that : “Plan direction, which emphasizes ecological integrity and resilience, will be critical to minimizing the undesirable effects of these increasing and interacting stressors. Nevertheless, managers and the public should expect climate change to drive profound and often surprising changes on ecosystem structure, function, and composition in the coming decades.”

    I’d call that a critical insight, something all concerned should know. Alas, it’s buried 173 pages deep, in Volume 1, Final Environmental Impact Statement for the 2020 Land Management Plan Custer Gallatin National Forest
    https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd763586.pdf

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    • Yep, because closing public lands to all use except hiking is the only logical response to climate change….

      Convenient how every solution for climate change just happens to dovetail so perfectly with the longstanding agendas of all the wilderness groups from long before climate change was even widely known to be an issue.

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      • The quoted section of the CGNF’s EIS is in reference to insects & disease, drought, wildfire, and other stressors brought on or exacerbated by climate change. The statement has nothing to do with recreational use or recommended wilderness.

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        • I wasn’t talking about the quote from the EIS. The commissioners said they are worried about expanded wilderness and wild and scenic designations. In response to that, Lance called their worries “a pretty predictable response to revisions that would deal candidly with effects of reckoning with climate change,” thereby implying that more wilderness and wild and scenic designations are part of revisions necessary to candidly deal with climate change.

          That also coincides with the literature of numerous environmental groups pusing wilderness expansion as a response to climate change. See the arguments commonly made in favor of the CORE Act, the Colorado Wilderness Act, the Northern Rockies Ecosystem Protection Act, ARRWA, and the entire 30×30 campaign as an example. It’s an extremely common argument.

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          • I rarely know what you’re talking about. And, as you proved above, your reading comprehension is suspect. So, clarifications are warranted.

            The section of the EIS Lance cites does not say nor imply what you assert. It has no nexus whatsoever to expanding or recommending Wilderness designations.

            You repeatedly attribute the policy prerogatives of the most preservation-minded advocacy organizations to the Forest Service itself. It belies the superficiality of your understanding.

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            • I acknowledge I read that wrong, but I made it quite clear I was referring to Lance’s statement not that specific EIS.

              And there’s a reason I frequently conflate the Forest Service’s agenda with that of extremist environmental groups. At least in Colorado, the relationship between the Forest Service and local environmental groups is about as extreme a case of regulatory capture as you can get. I’ve seen the emails in FOIA requests. When these groups say jump, the district rangers and forest supervisors ask how high. They don’t give them everything they want of course, but they give them enough, particularly when it’s closing roads.

              I of course recognize that there is more to the issue than that, that Forest Service employees are individuals with their own agendas and concerns, all of that. But regulatory capture is real and cannot be denied in this case. The fact is that more often than not, the agendas of the most preservation-minded advocacy groups and decision makers in the Forest Service are aligned, particularly when it comes to screwing over the motorized community.

              The most fair-minded Forest Service employees know it too. That’s how we got this doozy of a quote from one Forest Service employee in an email objecting to the South Park District Ranger’s shenanigans trying to illegally decommission and obliterate one of the most valuable motorized routes in Colorado: “If our leadership wants to know why the motorized community does not want to cooperate with the forest service, this is a great example of why they don’t trust us. I don’t blame them for their outrage.”

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              • Howdy Patrick,

                Can you please tell us the names of some specific “extremist environmental groups?” Also, what in your mind makes them “extremist environmental groups?”

                Thanks in advance.

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                • I am mainly concerned with groups that promote a “re-wilding” agenda, taking public lands that are not wild and closing them to existing recreational uses that are incompatible with their idea of almost everything being Wilderness. Also any group that believes wildlife habitat is more important than human enjoyment of public lands. If the group has “wild” in their name, chances are I would consider them extremists.

                  I have no objection to preserving existing wild lands as Wilderness, Roadless, etc. But most of those lands are already designated as such. There is no room for further expanding these wildland designations without kicking out other users of public lands who have long enjoyed access to them.

                  When environmental groups don’t care about the right of the public to enjoy public lands in their traditional ways and value animals above people, that makes them extremists in my mind. Of course you would no doubt consider me an extremist simply for wanting to keep levels of public access to public lands the same as they are today. So I suspect we are both extremists in each other’s eyes.

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  3. Hellooooo,
    In my mind, a Forest Plan (LRMP) developed under NFMA is essentially a “business plan” for a NF. What are the priorities, which areas of the forest will produce which outputs, etc.
    Do you know of ANY SUCCESSFUL PRIVATE BUSINESSES that are operating under business plans that are as out of date as the NF Forest Plans? — If you do, please post a comment with the name of the company and which industry it’s in. Thanks.

    I have a pretty good sense of this because I worked on developing and implementing a couple of the old “Unit Plans” (precursors to Forest Plans) on the Gifford Pinchot NF in the 1970’s-mid ’80’s period.
    The Forest Plan for Mt Hood NF was adopted in 1990. My hunch is that most of the planning team members likely got their bachelor’s degrees before 1980; certainly any staff officer who was on the team got their degree well before that (just based on seniority & promotion timelines).
    The team wasn’t exactly up-to-date on forest ecosystem science, salmon habitat and other topics that were evolving quickly at that time. Climate change was probably not in their vocabulary or minds!
    That means the plans were probably being eclipsed by changes in forest ecosystem science before the ink was even dry on the paper. BTW – I still use a copy of the voluminous old MHNF Forest Plan.
    So here we are 31 years later managing a NF with the same old plan! Yes, I know there have been some tweaks, small revisions, etc. but come on folks; the Portland – Vancouver metro area is much larger and has different needs than it did in 1990. Climate change is real and fire seasons are now on steroids! NF land provides refugia for many listed and unlisted species. WOLVES have returned to MHNF and the adjacent lands managed by the Warm Springs Tribes.
    The world has CHANGED; ALOT – but the Regional Foresters think the OLD plans are good enough for managing large areas of public land in that changed world! Sorry, but that doesn’t pass the red face test!
    We’ve all seen & experienced the huge changes in the field of natural resources during the past 31 years and those of us who got our B.S. degrees in the early ’70’s have seen even more change.
    If the USFS wants to be taken seriously and regarded with respect then IMO they need to get serious about doing FULL revisions of the ANCIENT Forest Plans! (pun there; unfortunately, now there isn’t much actual “ancient” forest left to include in the plans)
    And yes, there may well be shifts in forest mgmt. priorities on some NF’s that affect some local communities. There are ways to work with those communities to help them with social and economic transitions and that should definitely be part of the process.
    In the early 1990’s I used to teach classes for seniors (like Elderhostel); one of my classes was on Ancient Forests of the PNW. Part of what I emphasized was how the scienfific understanding of those forests had changed dramatically since I got my degree in forest management. I remember a woman in one of my classes who told us about some of the changes she’d witnessed Her father was a blacksmith and had a thriving business in a city in Oregon; he was doing fine until Henry Ford came along with the Model T. She said her dad had to shift to other work; we can cushion the transitions for people now but let’s be honest, we can’t really slow the pace of change in our forests or our understanding of them.
    Bit long winded, sorry, but I think it’s important to consider context when we talk about the future of NF land.

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    • Guilty as charged. B.S. 1976, M.S. 1980, Mt. Hood planner 1984-88. Although climate change was mentioned in the Resources Planning Act of 1974 (which NFMA amended), it wasn’t in the 1979 or 1982 planning regulations. What was/is in NFMA was a requirement, in addition to the 15-year requirement, to revise the plan “when conditions in a unit have significantly changed.” I don’t think that provision has ever been successfully used against the Forest Service, but it helps with the arguments against further delay.

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      • No, not guilty Jon. You were doing work you were interested in doing and went to college when it fit your age.
        I got my B.S. in ’73 and graduated with a woman who was only the second female forester to graduate from the Univ. of Maine College of Forest Resources.
        I recall a professor telling us in an ecology course lecture that “old growth forests are biological deserts.” He was a wildlife biologist and I think he meant ‘we don’t see large ungulates in those stands.’ Good example of how the science has shifted.
        I knew Tom Hussey while he was at U. Maine; a year ahead of me. I hear he was a bit of a terror as a District Ranger on the Hood!
        Perhaps you know Dean Apostol? He’s a great person.
        BTW – I always appreciate what you post here to stimulate our thinking; Thanks!

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  4. A key part of forest plan revisions is defining the “need for change” – I don’t think that plan revision necessarily means start from scratch again (but I could be naive!). And the “no action” alternative in plan revision is to continue under the current forest plan – so theoretically it is possible to select the “no action” alternative or a “modified” no action alternative.

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    • Yeah but who are we kidding. No government agency ever selects the no action alternative in a NEPA proceeding. Those are pretty much a joke and are only included because they’re required by law. I haven’t even been doing this stuff that long and I already know that in any NEPA process, whatever the Forest Service designates as Alternative C is going to be the one that’s adopted. From the instant that is laid out, the decision is largely made, with only a few minor details to be worked out.

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    • Thank you for bringing up “need for change.” My observation of revisions under the 2012 Planning Rule is that they haven’t taken this seriously. The “needs” they identify are typically pretty vague, and then they tend to ignore them when they start writing the actual plan. Rarely do you see holdover language from a prior plan (typical exceptions being broader-scale conservation strategies shared with other units, like for Canada lynx). While this language was a key provision of the 2012 Rule that was expected to help reduce the scope and effort of plan revisions, it seems like most forests want to start over from scratch. That has a lot to do with how long these revisions are taking.

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      • Another reason is because forests have started treating ROS Spectrum planning as basically a pre-travel management travel planning process. It’s reasonable to say forest plans and travel plans are the two most controversial things the Forest Service does, with both taking many years and inevitably resulting in lengthy litigation after the fact.

        Even though the Forest Service claims that ROS planning is not travel management, in the plans I’ve seen lately in Colorado it basically is, since they are frequently taking areas full of existing designated roads and designating them with a non-motorized only ROS, thereby predetermining the closure of those motorized routes in the actual travel management process that follows. And in drafts I’ve seen of the GMUG NF’s forest plan, they are basically using winter ROS planning as a substitute for winter travel planning, drastically decreasing the areas open to snowmobiling before even beginning a formal winter travel planning process.

        I have heard that originally ROS was supposed to be descriptive of current conditions on the ground, but it seems lately it has become prescriptive and basically a way to predetermine the outcomes of travel management processes before they even begin.

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        • I didn’t get too involved in the recreation part of planning, but I think your last paragraph sounds right. It’s consistent with the language of the 2012 Planning Rule, §219.10:
          “(b) Requirements for plan components for a new plan or plan revision.
          (1) The plan must include plan components, including standards or guidelines, to provide for:
          (i) Sustainable recreation; including recreation settings, opportunities, and access; and scenic character. Recreation opportunities may include
          nonmotorized, motorized, developed, and dispersed recreation on land, water, and in the air.”

          I would say that ROS is now a desired condition, and yes it does commit the Forest to designating areas and routes for motorized uses during travel planning that are consistent with that desired condition. Any new closures would still require a separate decision. This all does make the plan-level decision important (and I think allocation of land to recreational use types is appropriate as part of the integrated forest-wide planning process).

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          • In that case though, it becomes a massive driver of complexity in the forest planning process, since the forest is then committing to examine basically every route on the forest the same way they do during travel management, only without the tools they would normally use in travel planning like travel analysis scores and individual route evaluation spreadsheets. I don’t know why forest planners would put themselves through that when they don’t have to, but it seems they are.

            I guess what I’m thinking is that forest planning would be a lot less of a herculean task if they actually left things like travel planning to their own dedicated NEPA processes instead of trying to lump everything into the forest plan.

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            • Patrick, you’ll be glad to know that many planners wanted to see if forest planning could be more of a “loose leaf notebook” of existing decisions including travel management and oil and gas leasing, species-specific amendments when new species attract attention, climate adaptation and mitigation strategies , fire management planning.

              There have been critics of the NFMA planning since the beginning. Especially since that was the era in which top down planning was the latest idea. There was also the idea you could do one big NEPA at the plan level and then not to do NEPA for each project..

              So you are not alone. I can share some of the literature if you are interested. It’s exhaustive and exhausting.

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          • We know forests that are in the process of finishing travel management plans and have not gone through litigation of them yet.. and the same forests are urged to start plan revisions. So the travel management/plan revision process seems to go on without end.. is this a good expenditure of tax $.. I am not so sure.

            And in the middle of this there are more recreationists due to Covid and generalized growth of recreation. Should we amend all the plans for changed recreation conditions … perhaps use the planning buck that could have been used for revisions? Or perhaps focus on managing recreation better where it’s currently occurring?

            So in this case “what does revision get us?” “ a chance to involve all the same folks and renegotiate what we just negotiated.”

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            • My thoughts exactly. The Forest Service spends a ridiculous amount of resources on bureaucratic processes endlessly planning route designations and then reevaluating and renegotiating route designations already made. As soon as one travel plan is finalized the next one effectively begins.

              Meanwhile most forests can only afford to employ a handful of rangers to patrol thousands of miles of roads and trails. So actual enforcement of the rules and designations created in travel planning is almost nil, and as a result those rules are frequently disregarded. It’s like expecting people not to speed when there are only two cops enforcing speed limits across an entire city. Not going to happen.

              If management in the field cannot happen, the only tool at the forest’s disposal is management on paper. Since paper management cannot address individual situations and only gives the forest a choice of whether a given route should be open or closed, the only way for them to deal with problems is by closing routes. Hence management by closure as the default.

              So yeah, in my view, the Forest Service is stuck in an endless cycle of planning that prevents them from actually doing much of anything on the ground. Less planning, more doing is what we need.

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              • So many things I could say to you Patrick but I’m going to limit it for now. My first summer season with USFS was 1973 as a driver of a fire engine on the Klamath NF.
                Tomorrow I’m meeting up with another volunteer to do a quick repair of a washed out road in Mt. Hood NF. We need access for passenger cars so we can get more volunteers in to a trailhead on Saturday for a trail maintenance project.
                The road leads to two small but popular NF campgrounds as well as some popular trailheads that many people like to access; primarily by passenger car.
                This road frequently washes out because MHNF has a huge road system and a teeny weenie budget for road maintenance. They can’t even keep the ditches and culverts clean so in this case the road becomes the ditch and all the soil washes out leaving ruts and oil pan eating rocks.
                They’re BROKE but keep trying to spread the limited money over a large road system. The result is poorly maintained roads at high risk of failure in large rain on snow flood events. At some point, storms are going to close roads and leave the agency with huge costs for reconstruction. I know one road in the Gifford Pinchot NF where a storm did that to a 20 foot diameter culvert; the pipe is still there but the entire road fill sluiced out into the downstream fish habitat. NO $$ for repairs so the FS put up a “Closed” sign. So much for proactive road management!
                The agency failed to take travel planning seriously, in MHNF, and decided to keep most of it’s road miles. So much for the direction to identify the “minimum road system!” Frankly, the process was a joke because the agency hates to give up roads; it’s like losing part of their fiefdom.
                If the agency would really take travel planning seriously they’d prioritize the roads that are needed for recreation access and other important needs. Then they could invest their maintenance money in the roads that matter to the public!

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                • You have an interesting perspective. You view the size of the road system as the problem, while I view the size the Forest Service’s budget (and what they are required to spend money on) as the problem. Perhaps if the Forest Service didn’t need to spend so much money on NEPA planning and fighting endless lawsuits from environmental groups demanding more road closures, they would have more funds for road maintenance.

                  We could also both probably agree that Congress has been neglecting the Forest Service for ages and not giving them the money the need maintain their infrastructure. I wish that would change, but I know at least in Colorado our congressional delegation is more interested in pushing massive Wilderness bills than funding maintenance of Forest Roads. Cory Gardner was the best senator we’ve had in a long time on public lands issues and actually pushed for more funding for land management agencies, but he’s gone now.

                  Your experience with travel management is also the exact opposite of mine. Maybe things are different in Oregon, but in Colorado the Forest Service is eager to give up roads, bending over backwards to cater to environmental groups in closing motorized routes. The most recent travel plan to be completed for the White River National Forest closed around 22% of motorized routes. It now has the least motorized access of any national forest in Colorado despite being the most heavily used, and it is now struggling with major overcrowding because there are nowhere near enough routes to handle the demand. And like clockwork, many of the areas with the most route closures are now proposed for Wilderness designation in the CORE Act being pushed by Senator Bennet.

                  The travel plan I have been most involved in, the Pike San Isabel NF, is nearing completion and proposes to close approximately 4% of existing roads. While that may not sound like much as a raw percentage, those closures are heavily concentrated in the most popular and heavily used areas, and target many of the post popular 4WD roads in Colorado, including numerous routes that have been featured in 4WD guidebooks for decades and have been actively maintained by 4×4 clubs at very little expense to the Forest Service. They are also closing the sole access route a major wilderness trailhead and several other roads to major recreation areas like popular fishing lakes, as well as several roads that serve as crucial connectors between two drainages close to an important gateway community over significant local opposition.

                  The vast majority of these closures are being done solely on the basis of hastily compiled travel analysis scores drafted by the ranger districts over 1 or 2 days with almost no public comment. Those were then run through an arbitrary scoring matrix to produce the “minimum road system”, which was basically set in stone before the formal travel management process even began. Then they refused to consider any public comments that challenged the accuracy of the travel analysis process scores or recommendations.

                  The result of that process was extremely uneven and depended largely on the personal views of individual district rangers. Rangers that supported motorized recreation kept most of their roads open by giving them high travel analysis scores for recreational value, while rangers that opposed motorized recreation rated everything low value causing many more roads in their districts to be closed.

                  So when you talk about prioritizing important roads needed for recreation access, it’s hard to take that seriously because that is solely dependent on what roads are important to whom and whether the Forest Service is willing to recognize their importance. In my experience, Forest Service personnelle are terrible at judging the actual value of roads in their districts, and they are completely unwilling to listen to the actual users of those roads in order to understand their true value.

                  The forest road system in Colorado is so heavily used there is virtually no such thing as an unimportant road. But there are roads that are unquestionably more important than others, yet in my experience, it is usually those very roads that are selected for closure while leaving many less important roads open.

                  That’s probably because the most popular roads also happen to be in highly scenic areas that also overlap with important wildlife habitat, or they are close to roadless areas which could be expanded and made better candidates for Wilderness designation if adjacent roads were closed. Those popular roads have an army of environmental groups lobbying for their closure on one side and a coalition of motorized groups lobbying to keep them open on the other side. The less important roads tend to be ignored by both sides and therefore kept open by default.

                  So I would actually agree with you that the idea of the “minimum road system” is a farce, but probably for the opposite reason.

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  5. So Jon, I see this as coevolution of the FS and its partners. We know two things 1. plans are required, 2. it is difficult and time-consuming to complete them. 3. They are often sources of future litigation. Why would any reasonable FS person want to do one?

    At the point when the regs were rewritten this time, Andy Stahl suggested a KISS rule that fit the needs of NFMA and was easy to accomplish. The FS chose to write one that is full of assessments, HRV, and bristling with currently unknown-how-they’ll-play-out legal hooks including “ecosystem integrity.”

    Despite the verbiage associated with the Rule of them being done more quickly (which was really hard to believe for those of us who read it, including internally) we have almost 10 years of history and we don’t see that happening.

    Many forests are doing just fine with their old plans and amendments. Some FS folks think that doing a plan revision is a time and funding sucking black hole of reopening a Pandora’s Box of disagreement. It might even seem like there are quid quo pros in collaborative forest planning where the quid (say RW) goes ahead and the pro quo (other projects) are litigated and ultimately put aside.

    That’s why I think someone (maybe an NGO with a committee representing different points of view to remove biases of various kinds) should do a study of what benefit has come from the current round of plans. Ask all the stakeholders and the FS employees involved. Open up the survey and findings for public discussion on the internet. As I said in 2000, that would be a good start.

    Otherwise the natural coevolution for a difficult (and untested in court) Rule is for units to observe and say, let’s try to get lower on the list. IMHO.

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    • Others jump right in, like the Wayne, which is working on revision #2. In 36 CFR §219.5, the Planning Rule says: “Biennial monitoring evaluation reports document whether a change to the plan or change to the monitoring program is warranted based on new information, whether a new assessment may be needed, or whether there is no need for change at that time.” §219.12(d) establishes the requirements for the biennial monitoring evaluation report: “(2) The monitoring evaluation report must indicate whether or not a change to the plan, management activities, or the monitoring program, or a new assessment, may be warranted based on the new information. The monitoring evaluation report must be used to inform adaptive management of the plan area.” The Forest Service should be using this information to prioritize revisions. (In hindsight, I would have had the monitoring evaluation report specifically address the question of whether conditions on the unit had significantly changed, which would automatically trigger revision – but I doubt the FS would have wanted to make that kind of admission/commitment.)

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  6. I’m sympathetic to those who think forest plan revisions aren’t worth the time or bother. As explained previously in the K.I.S.S. Rule discussion, NFMA focused on reining in logging levels. Logging levels that peaked in the 1980s at 12 billion board feet annually have bumped around at 2 to 3 bbf for the last 25 years.

    The law has achieved the purpose Hubert Humphrey envisioned: “The days have ended when the forest may be viewed only as trees and trees viewed only as timber. The soil and the water, the grasses and the shrubs, the fish and the wildlife, and the beauty of the forest must become integral parts of the resource manager’s thinking and actions.” NFMA’s heavy lifting has been done.

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    • Andy, your 2009 post is still my favorite on NFMA planning..
      “Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit. ”

      Which is a bit what Patrick thinks, and what I think. An unusual set of people in some agreement is worth noting, IMHO.

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      • Exactly. In addition to overlapping with other things like travel planning, why does absolutely everything need to be in the Forest Plan, down to the most minute details?

        For example, the pre-scoping draft GMUG Forest Plan released a couple years ago now (still awaiting the beginning of the official NEPA process) had rules prohibiting flying drones in recommended wilderness areas. This had the obvious issue I brought up in my comments that since recommended wilderness is solely a creature of obscure bureaucratic documents most people have no idea exist and it is not shown on any publicly available topo maps, how is anyone supposed to know the rule exists or whether they are in a recommended wilderness or not?

        But aside from that, is that really something that needs to be in the forest plan? Drone flying is an ephemeral phenomenon that doesn’t even affect the ground let alone create a permanent impairment of wilderness character. If drone flying is causing problems in a specific area, it would be far better to prohibit it in a specific location with a forest order rather than creating a blanket rule in the forest plan. Putting all kinds of super specific rules for particular activities in the forest plan strikes me as much the same as putting every mundane little law in the Constitution. Not only does it make it much harder to change things when needed, but it flat out doesn’t need to be there.

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  7. Patrick not every issue comes down to your hatred of “recommend wilderness”. Give it a rest for once.

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    • If the public comments Patrick submits to his local forest are as absolutist and hyperbolic as his comments here it’s no wonder why he feels ignored.

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      • Anonymous, it would interesting to have a rating system to compare “absolutist and hyperbolic” public comments. We could have other categories.. one I’d like to add would be “High Level of Domestic Imperialism”. I’m sure everyone could add categories..

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  8. I said ROS is appropriate at the scale of forest planning. Whether it is a good idea? I think everyone wrestles with the point Patrick is making about when the decision to close something is actually made and how much site-specific information do you need to make an ROS decision. I also agree with Andy that forest planning could have been limited to timber issues and how they are related to other resources, as well as plant and animal diversity. I have supported minimizing or eliminating issues and decisions from planning that are not related to these things, and if recreation could be considered largely unrelated, I would exclude that. Maybe it’s not true everywhere, but there are places where recreational use of roads has large implications for wildlife viability (e.g. grizzly bears).

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  9. To clarify my position on climate as a threat to forest persistence/resilience, I’ll post the objections I raised for the Custer-Gallatin and Helena-Lewis and Clark National Forests. Because they’re pretty detailed, I’ll just post my Custer-Gallatin objection and give all interested parties time for that one before posting the objection to the H-L and C.

    To : Objection Reviewing Officer, Northern Region, 26 Fort Missoula Road, Missoula, MT 59804.

    Subject : Objection to Custer Gallatin Land Management Plan, Custer Gallatin National Forest, Mary Erickson, Forest Supervisor

    Objector’s name: Lance Olsen
    Address: 624 East Pine C3 Missoula MT 59802
    email: lancolsn@gmail.com
    Please specify whether this objection is to the Custer Gallatin Land Management Plan or the Regional Forester’s list of species of conservation concern (SCC) by checking the applicable box:
     X Land Management Plan

    Statement of issues and/or parts of the plan revision to which the objection applies:

    In its FEIS Vol 1, for example, the Forest refers to resilience 71 times, but only refers to regeneration failure 2 times. This is objectionable simply because the Forest has itself documented that resilience depends on regeneration, and has itself cited references to evidence that regeneration has been increasingly implausible across the western United States including in Montana (e.g., Stevens-Rumann 2018, Davis et al 2019).

    Concise statement explaining the objection and suggestion how the proposed plan should be improved:

    • The reasons for this objection are:
    Broadly put, the Forest is at risk of misrepresenting the viability of its intended management for resilience, ecological integrity, and desired future condition, all within a natural range of variation.

    Proposed Solution: There is no easy solution, largely because the future of forests is and will increasingly be determined by the future of the atmosphere, where elevated concentrations of greenhouse gas are already creating a climate-driven forest crisis expressing itself as, for example, seedling death in hot, dry conditions. That said, the Forest needs to more explicitly and more publicly align its management with the direction recommended by Coop et al (2020); “…management and conservation efforts should align with expectations of increasing forest vulnerability to conversion. In an era of change, the forest that was there before the fire may not return.” As the forest knows, there has already been an expanding area where forest has not returned. Indeed, the Forest could and should offer an increasingly realistic outlook as expressed by physicist and climate scientist Kate Marvel; “The world we one knew is never coming back”<>. As I will show herein, the Forest knows that this risk exists. It is a risk of such considerable material interest that the Forest is obliged to play a role in alerting the public to its existence. The Forest will, as a precondition to implementation of its Land Management Plan, have to work out for itself how it can best help convey this message to an unsuspecting public. The Forest may find that the most expedient way to help convey this message is to include it in the final Record of Decision.

    Statement demonstrating the link between objection and prior formal comments: As I previously noted during scoping, the Forest faces a dicey, risky situation, being forced into a reactive mode by consequences of a hotter and drier conditions that have been raising increasing evidence that forest is being converted to non forest in the western United States, a well-documented trend to which the Forest cannot be immune. This was the risky situation I stressed during scoping, and it’s that same risky situation now behind the Forest’s scramble to manage for desired future conditions of forest persistence via management for resilience and ecological integrity, and the Forest’s increasingly implausible assumption that there is still opportunity for forest management within a natural range of variation.

    Signature :_______________________________

    I can readily sympathize with the Forest’s attempt to manage for desired future conditions of forest persistence via management for resilience and ecological integrity, in a context that assumes there is still opportunity for forest management within the natural range of variation. That said, I will emphasize herein that the Forest faces a risky climate crisis which is on a path toward a forest crisis which is, in turn, becoming more risky, and that the Forest has reacted by putting on a brave face, mustering up a can-do facade, incessantly referring to this frequently repeated intent to manage for desired future condition, resilience, and ecological integrity, and all that within a natural range of variation.

    Good luck with that.

    It has been getting increasingly obvious that risks associated with climate change have forced the Forest and the Forest Service in general into an attempt to make the best of what can only be described as an increasing bad situation, namely an already documented trend of climate driven deforestation. Considering that evidence, I must object to the Forest’s insistence on repeating its key claims of managing for resilence et al, because the Forest knows full well that its attempt at achieving resilience, ecological integrity, and desired future is at some appreciable risk of failure and, accordingly, at risk of being a pretense.

    First, some background, specifically that the Forest knows that a National Forest Management Act requirement of sustained yield of timber has already been effectively mooted on the Ashland, where ~100,000 acres of ponderosa pine stands have already been converted to non-forest grass and shrub after successive fires. I think the Forest will concur that few if any stakeholders, members of the public, or policymakers had defined conversion of forest to non-forest grass and shrub as a desired future condition, or as evidence of resilience or sustained ecological integrity.

    And the Forest knows that most if not all stakeholders, members of the public, and and policy makers far prefer that it doesn’t happen again. Instead, and I expect the Forest to concur, most if not all stakeholders, members of the public, and and policy makers would define persistence of forest as the desired future condition and, furthermore, many if not all will specify persistence of commercially valuable tree species such as the Ponderosa pine and Douglas fir — or, more generally, the persistence of conifers — as the desired future condition and evidence of a persisting ecological integrity.

    All in all, they’d all likely like to see persistence of the familiar forest they see today. In other words, the status quo.

    And, indeed, the Forest plainly and frequently states that this is its intent to effect these desired status quo conditions, specifically via the Revised Plan’s repeated emphasis on a plan for resilience, ecological integrity, and desired future conditions, within NRV.

    The Forest would better serve the interest of present and future generations if it directly conveyed the same plain-language message that eminent climate scientist Michael Mann conveyed during an interview with the PBS News Hour in August, 2018, when he said that, if we keep burning fossil fuels, we will get “worse and worse” heat, drought, and fires <>.

    The Forest knows that it’s aim for a status quo forest via resilience is at risk of failure, and even at risk of being a pretense

    For example, on pp 170-171 FEIS Vol 1, the Forest advises stakeholders and other reviewers that, “While many effects of climate change are anticipated to be gradual, there is also the potential for interacting disturbances such as insects, drought and fire to drive systems towards sudden large-scale transformations (Millar and Stephenson 2015).”

    So the Forest knows not only that resilience is at risk, but also knows that “transformation” away from the desired status quo can be sudden, and large-scale.

    It is to the Forest’s credit that it does indeed make this point.

    Having established that much, the Forest immediately goes on to say, “For example, dry forests that already occur at the edge of their climatic tolerance are increasingly prone to conversion to non-forests after wildfires due to regeneration failure (Stevens-Rumann et al. 2018, Davis et al. 2019),” and adds that, “This trend is likely to continue in the future across all forest types as large wildfires remove local seed source and suitable climate space for tree regeneration becomes increasingly rare (Bell et al. 2014, Harvey et al. 2016b, Andrus et al. 2018).

    The key phrases above are “climatic tolerance” and “regeneration failure” and, as the Forest knows full well, regeneration failure after “large wildfires” is, in fact, a post-fire failure of the much-touted resilience. Thus, although never explicity stated in these terms, the Forest is recognizing risk of climate-driven forest crisis in the form of expanding areas deforestation.

    For example, the Forest knows that Stevens-Rumann et al (2018) explicitly define regeneration as key to resilience; “Forest resilience, or the capacity of a forest to return to a pre-disturbance state (Gunderson 2000), is strongly dependent on sufficient tree regeneration (Johnstone et al. 2016).”

    However, while the Forest has read Stevens-Rumann et al, it has somehow decided not to directly quote their finding that resiience depends on regeneration. This is unfortunate because many stakeholders, members of the public have not had the opportunity to read Stevens-Rumann et al, which means that the Forest knows what many stakeholders might not know.

    Namely, and in plain language, that hot dry conditions help set a forest up for fire, and that those same hot dry conditions kill seedlings after fire has come and gone. This is plain language accessible to many people, but it is plain language never set forth in either FEIS or the draft Rod where it is certainly needed.

    And so, while the Forest plausibly knows better than many in the public have yet had a chance to learn, the fate of seedlings sets the fate of a forest’s future. It is unfortunate that the Forest has not conveyed that basic message in those direct terms necessary to science communication. Instead, the Forest has biased its reporting toward those familiar with academic journals typically beyond the reach of the general public.

    Knowing what it knows about the critical importance of seedling death or survival, the Forest intends to monitor their status, and will monitor seedlings explicitly in order to know when and where it will need to change course via adaptive management; On pp 171-172 FEIS Vol 1, “Another key plan component that is critical in the context of future climate change is the establishment of a monitoring plan to inform an adaptive management approach. This enables the intentional use of monitoring to evaluate effectiveness of our plan direction and resulting management actions. For example, monitoring tree regeneration will provide critical information on possible climate change effects to this vulnerable life stage (Stevens-Rumann et al. 2018). “

    The monitoring of seedlings is so important that the Forest must make an effort to gather public support. Among other things, public support will be essential to monitoring seedlings of high economic value. However, the Forest cites Davis et al (2019), and knows but somehow has decided not to directly quote their finding that such thresholds have, already, been crossed for economically valuable ponderosa pine and Douglas fir. In this case, the Forest thus again knows more than it confides for the illumination of stakeholders, the larger public, and policymakers

    These matters are of such considerable material interest to present and future generations that they demand a full and coherent disclosure to stakeholders, the larger public, and policymakers. The Forest may claim that it’s done that, but, for example, the crucially import topic of regeneration gets only the most superficial and passing reference only on 2 pages of the draft Record of Decision, and neither of those 2 mentions includes risk of regeneration failure, a.k.a., failure of resilience.

    As the Forest knows well from actually having read Stevens-Rumann et al (2018), what might be most aptly described as climate-driven deforestation, thanks to failure of regeneration/resilience, has been a repeated trend, one documented across the western United States including in Montana. The certainty of this broad trend of climate-driven deforestation crisis has since been well-confirmed by Coop et al (2020), and in western Canada by Brecka et al (2020).

    In a system where researchers’ investigations will inevitably lead to lingering unresolved details, prompting them to bid for more research, it’s not as if we’re left clueless. The risk of post-fire resilience failures is well within the realm of certainty, and the fact that’s been happening is in the realm of high certainty. The big question is how many more resilience failures will occur, and when and where they will occur, in the Forest’s planning area, and, thus, how soon the Forest must adapt its current management plan to a new certainty, and get on with pursuing a necessary course away from the status quo forest familiar today.

    The Forest knows that it’s aim for a status quo forest via ecological integrity is at risk of failure, and even at risk of being a pretense

    For example, the Forest cites Halofsky et al (2018) as its main source, and cites their reporting how climate change translates to forest change ; “Increasing air temperature, through its influence on soil moisture, is expected to cause gradual changes in the abundance and distribution of tree, shrub, and grass species throughout the Northern Rockies, with drought tolerant species becoming more competitive.”

    This above direct quote from Halofsky et al is rich in meaning for any rigorous analysis of a sustained status quo of forest conditions implied by ecological integrity.

    First, their reference to increasing air temperature is a direct reference to climate change.

    Second, their reference to changes in “abundance” of species alone suggests a climate-forced departure from the status quo conditions implied by ecological integrity.

    Third, their reference to changes of “distribution” of species alone suggests a climate-forced departure from the status quo conditions implied by ecological integrity.

    Fourth, their reference to changing competitiveness of “drought tolerant” species suggests a further climate-forced departure from the status quo conditions implied by ecological integrity.

    Having actually read Halofsky et al, the Forest knows that these above findings do not bode well for the Forest’s plan to achieve or sustain the ecological integrity remaining within the planning area today.

    For another example of what the Forest knows; “Plan direction, which emphasizes ecological integrity and resilience, will be critical to minimizing the undesirable effects of these increasing and interacting stressors. Nevertheless, managers and the public should expect climate change to drive profound and often surprising changes on ecosystem structure, function, and composition in the coming decades.”

    The operative words here are “nevertheless,” “the public,” “should expect,” and “changes.” In that one sentence, the Forest does approach adequate disclosure of risk. That is to the Forest’s credit, but, again, this example of disclosure is obscured by the Forest’s persistent references to hope of resilience, ecological integrity, and achievement of desired future conditions.

    To its credit, the Forest says on that same page that, “Successful management of vegetation and ecosystems during this period of rapid environmental change will require ‘anticipatory’ planning and management.“

    Aye, there’s the rub. The most evident elaboration the Forest provides about this anticipatory approach is, ahem, a constant drumbeat of managing for resilience, ecological integrity, and desired future conditions — by remaining within a natural range of variation.

    As the Forest knows full well, Millar and Stephenson (2015) say that a serious threshold has been crossed when a forested area converts to an area without trees. As the Forest further knows, that “serious threshold” has already been crossed on ~100,000 acres of the Ashland, specifically with loss of the economically valuable ponderosa pine.

    Can the Forest legitimately leave an impression among stakeholders, the larger public, and policymakers that the Forest Plan’s direction, which emphasizes ecological integrity and resilience, therefore rules out the need to anticipate further, additional crossing of this serious threshold?

    The Forest knows that its attempt to deliver future desired conditions is at risk of failure, and even at risk of being a pretense

    While many — including conservationists — may continue to assume a permanence of forest cover, the Forest itself knows that post-fire heat and drought kill seedlings which are the foundation of a forest’s future. The Forest also knows that there will be fire, and that there will be drought.

    The Forest could, should, and plausibly does know that a remaining opportunity for forest management within a natural rate of variation is a lot cause, and, indeed, that continued insistence that it still has opportunity to manage forests within the natural range of variation is, now, already a pretense.

    NRV (natural range of variation) is specifically defined in the Forest Service planning rules:

    “NRV is the variation of ecological characteristics and processes over scales of time and space that are appropriate for a management application. The pre-European influenced reference period considered should be sufficiently long, often several centuries, to include the full range of variation produced by dominant natural disturbance regimes and should also include short-term variation and cycles in climate.”.

    While the Forest may or may not know it, the larger Forest Service parent agency is well aware that keeping within the natural range of variation indicated in the past several centuries will be, at a minimum, difficult.

    For instance, “Current projections indicate that a further 4° to 6°C global warming could be reached by as early as the end of this century (IPCC 2007), when global temperatures could exceed any reached in the last several million years.” Nathan L. Stephenson and Constance Millar. USDA Forest Service RMRS-P-71. 2014.

    Furthermore, “The climate change metric represents when the average annual temperature is projected to permanently depart from the prevailing climate of the past century under a ‘business as usual’ scenario.” (https://www.fs.fed.us/pnw/sciencef/scifi197.pdf)

    Even more Forest Service awareness is evident here; “… all global circulation models (GCMs) predict unprecedented increases in temperature for the western US …” (https://www.fs.fed.us/wwetac/brief/western-forests-and-climate-change.php)

    I think the Forest will concur that the third Forest Service analysis cited just above was describing a departure from a natural range of temperature variation when citing prediction of “unprecedented increases.”

    It is considerable interest, then, that the Forest can report, on p 165 of FEIS Vol 1, the Forest included this passage; “The natural range of variation has been criticized as less relevant in an age of climate change (Millar 2014). There is potential for ecological transformations to occur in temperate ecosystems, based on the potential for interrelated drivers such as chronic and acute drought, wildfire, and insect outbreaks to push ecosystems beyond their thresholds for resilience (Millar and Stephenson 2015, Golladay et al. 2016).”

    Now, having read both Millar and Stephenson (2015), and Golladay et al (2016), the Forest knows what these researchers actually said, which is something that many stakeholders, members of the larger public, and policymakers may not know.

    That includes their shared outlook that climate-driven change of forests weighed herein are “inevitable”.

    I expect the Forest to concur that risk of inevitable forest change does not leave the Forest immune. I further expect the forest to concur that its main source of information, Halofsky et al (2018) suggest at least some inevitability of climate-driven forest change when saying, in Chapter 5 by Keane et al, Effects of Climate Change on Forest Vegetation in the Northern Rockies, that, “Increasing air temperature, through its influence on soil moisture, is expected to cause gradual changes in the abundance and distribution of tree, shrub, and grass species throughout the Northern Rockies, with drought tolerant species becoming more competitive. The earliest changes will be at ecotones between life- forms (e.g., upper and lower treelines). Ecological disturbance, including wildfire and insect outbreaks, will be the primary facilitator of vegetation change, and future forest landscapes may be dominated by younger age classes and smaller trees. High-elevation forests will be especially vulnerable if disturbance frequency increases significantly. Increased abundance and distribution of non-native plant species, as well as the legacy of past land uses, create additional stress for regeneration of native forest species.”

    I further expect the Forest to concur that any degree of inevitability of a changing forest is a matter of material interest to many stakeholders, members of the larger public, and policymakers, who may have had opportunity to read — but need to know — important studies that the Forest has read.

    The question of inevitable change unavoidably includes risk of conversion from forest to non-forest, and the Forest knows that Millar and Stephenson refer directly to this possibility. Equal knowledge may not exist for every stakeholder, member of the public, or policymaker.

    Additionally, having read Millar and Stephenson, the Forest knows that they say, “Because the scope of the challenge is vast, triage exercises will almost certainly be necessary …”.

    Triage would of course be of special prominence as evidence of conversion from forest to non forest accumulates. But again, while the Forest is aware of a stated need for triage exercises, it is not likely that very many stakeholders, members of the larger public, or policymakers know what the Forest knows about inevitable change leading to need for triage in forest management.

    A big and lurking question is how many conversions like that on the Ashland will have to occur before the Forest issues full disclosure about this matter. In this, the Forest can and should give a hard look at the comment by Coop et al (2020) that, “ … the prospect of directional climate change beyond historical ranges of variability, and increased frequency and magnitude of extreme disturbance, compels us to consider the pos- sibility of profound and persistent ecological change across forested ecosystems. “

    Finally, this finding of relevance to the Forest’s claim to manage within natural range of variation; here, the atmosphere as a whole will, within the lifetime of the Forest’s revised plan, take a significant departure from the past several centuries of variation specified in the planning rules.

    Physorg. JULY 10, 2020
    By 2025, carbon dioxide levels in Earth’s atmosphere will be higher than at any time in the last 3.3 million years
    by University of Southampton
    <>

    By [ i.e., before ] 2025, atmospheric carbon dioxide (CO2) levels will very likely be higher than they were during the warmest period of the last 3.3 million years, according to new research by a team from the University of Southampton published today in Nature Scientific Reports [ OPEN ACCESS pdf]<>.
    Dr. Thomas Chalk, a co-author of the study, added: “Focussing on a past warm interval when the incoming insolation from the Sun was the same as today gives us a way to study how Earth responds to CO2 forcing. A striking result we’ve found is that the warmest part of the Pliocene had between 380 and 420 parts per million CO2 in the atmosphere. This is similar to today’s value of around 415 parts per million, showing that we are already at levels that in the past were associated with temperature and sea-level significantly higher than today. Currently, our CO2 levels are rising at about 2.5 ppm per year, meaning that by 2025 we will have exceeded anything seen in the last 3.3 million years.”

    Professor Gavin Foster, who was also involved in the study, continued: “The reason we don’t see Pliocene-like temperatures and sea-levels yet today is because it takes a while for Earth’s climate to fully equilibrate (catch up) to higher CO2 levels and, because of human emissions, CO2 levels are still climbing. Our results give us an idea of what is likely in store once the system has reached equilibrium.”

    Concluded Dr. de la Vega, “Having surpassed Pliocene levels of CO2 by [ i.e., before ] 2025, future levels of CO2 are not likely to have been experienced on Earth at any time for the last 15 millions years, since the Middle Miocene Climatic Optimum, a time of even greater warmth than the Pliocene.”

    Elwyn de la Vega et al. Atmospheric CO2 during the Mid-Piacenzian Warm Period and the M2 glaciation, Scientific Reports (2020). <>.

    The Forest may well be presenting too optimistic a view of increasing water use efficiency in response to rising levels of atmospheric CO2.

    For example, on p 208 of the FEIS Vol 1, the Forest advises reviewers that “Elevated CO2 may counter the effects of higher temperatures and evaporative demand by improving water-use efficiency of plants (Morgan et al. 2011).” In this analysis, trees might have some chance of surviving the changes being driven by drought. The Forest asserts that possibility specifically for ponderosa pine. On p 197 of FEIS Vol 1, the Forest asserts that “Ponderosa pine dominance type provides important wildlife habitat, particularly as late- successional or old-growth forest on the warm dry potential vegetation type. It is a “drought avoider,” meaning it tolerates dry soil conditions by efficiently closing stomata to avoid water loss and xylem cavitation and stay alive during deep droughts.”

    However, two studies published in 2020 cite evidence that the understanding of water use efficiency circa 2011 no longer holds. Adams et al (2020) find “diminishing” CO2-driven gains in water-use efficiency because, instead of countering the effects of higher temperatures and evaporative demand, rising levels of CO2 are pushing trees to their “intrinsic physiological limits.” Brookshire et al (2020) find, more broadly, that increasing water use efficiency by plants is unsustainable.

    Forest permanence/persistence under drought thus appears less likely under drought than the Forest implies with its reference to what seemed true back in 2011.

    The Forest is at risk of misleading stakeholders, the public and policymakers about feasibility of maintaining old growth.
    For example, on p 260, the Forest claims that, “the trajectory of large tree size class and prevalence of large tree structure (discussed above) indicate that the amount of old growth should also be increasing forestwide under all alternatives.“

    However, McDowell and Allen (2015) find that, “… tall trees of old growth forests are at the greatest risk of loss” in a climate being forced into change. Similarly, Stoval et al (2019) find that, “Forest mortality is accelerating due to climate change and the largest trees may be at the greatest risk, threatening critical ecological, economic, and social benefits. “

    Also on p. 260, the Forest voices a belief that, “Succession will continue to be the primary means by which old growth forest is developed.” Well, succession of course depends on succession by younger trees, including whatver seedlings die in (expected) hot, dry conditions. So it is of material interest then that Xu et al find that trees are at risk of death at both ends of the age/size spectrum — a finding that cast doubt on any Forest claim of ability to retain ecological integrity.

    The Forest knows that alternatives to non-forest may exist when and where the Forest’s intended management fails in the face of an increasingly unfavorable climate.

    With drought a certainty, and fire another certainty, one such alternative to increasingly treeless conditions may be at hand via conifers with combined resistance to fire and tolerance of drought. Any such conifer might be resilient/resistant enough to persist and, therefore, offer an alternative to non forest.

    Any such conifer would thus be a high-value tree, worthy of special attention, but I found no such conifer identified in the Forest’s recent documents.

    This raises another question I couldn’t find answered in the Forest’s recent documents; if no such conifer happens to exist in the Forest’s planning area, might one or more such conifers exist elsewhere? If so, would the Forest then shift into adaptive management mode via assisted migration? And how many more conversions like the one on the Ashland need to happen before the Forest moves into that new mode of management?

    It is encouraging, then, that the Forest has said, on p 20 of Appendix F, Response to Comments, that , “The plan does not preclude the use of assisted migration,” and that “The Custer Gallatin may adopt a strategy of assisted migration if and when there is sufficient information to guide this activity.”

    Would some next conversion to non forest have to be as extensive as the ~100,000 acres on the Ashland before the Forest would adopt a strategy of assisted migration for conifers that are both fire-resistant and drought tolerant but are not now in the Forest’s planning area?

    These questions gain increased urgency when management within a natural range of variation is a lost cause, and when, at the same time, a general public desire for forest persistence is evident at many levels including scenics and wildlife.

    And it’s not as if assisted migration is a novel topic within USDA Forest Service. If not the Forest, the larger parent Forest Service has given assisted migration some serious attention. I’ll be uploading the pdf of each of the three examples of in-house, Forest Service studies discussed below.

    The Forest, stakeholders, the larger public, and policymakers at every level need to know what the Forest Service knows about assisted migration. At a minimum, all concerned need to know that assisted migration is not a novel topic, but instead has been a matter of serious consideration within the Forest Service.

    As a first example, consider Handler, S.; Pike, C.; St. Clair, B.; 2018. Assisted Migration. USDA Forest Service Climate Change Resource Center. These authors observe that, “A land manager may first need to make decisions about which species are appropriate to favor in a given area,” and immediately go on to say that, “In some cases, however, it is clear that climate change and other conservation challenges make the risk associated with doing nothing greater than the risk associated with intervening.”

    A second example is available via the USDS Forest Service Rocky Mountain Research Station’s website on Climate Change and Assisted Migration <>. This website allows Forest Service staff and others to “ … search more than 840 articles discussing assisted migration, climate change, and native plant transfer guidelines by author, title, subject, or keywords.” In providing this service, the website “… provides a central foundation for collaboration in generating research questions, conducting studies, transferring and acquiring data, expanding studies to key species and geographic regions, and guiding native plant transfer.”

    A third example is available as part of a broader conference sponsored in part by the Forest Service; i.e., Browning, J. Comp. Proceedings of the 60th Annual Western International Forest Disease Work Conference; 2012 October 8-12; Tahoe City, CA. 1 USDA Forest Service, Washington, DC. 2 Northern Institute of Applied Climate Science, USDA Forest Service, St. Paul, MN. 3 USDA Forest Service, Pacific Northwest Region, Pendleton, OR. 4 USDA Forest Service, Northern Research Station, Delaware, OH.

    One session of that conference was titled, “Policy and strategy considerations for assisted migration on USDA Forest Service lands,” and was co-authored by Forest Service personnel including Leslie A. Brandt, Douglas A. Boyce, and Louis R. Iverson. This Forest Service co-authored session on “Policy and strategy considerations for assisted migration on USDA Forest Service lands” reported that, “Assisted migration has been defined as the movement of species, populations, or genotypes to places outside the areas of their historical distributions to maintain biological diversity or ecosystem functioning with changing climate (Richardson et al. 2009; Schwartz et al. 2012).”

    The above authors point out that “Assisted migration changes the land management focus from past to future,” a value also stressed by Golladay et al (2016), where the value of considering today’s youth and future generations assumes its rightful importance in an age of mounting risk and worries.

    The above three examples of Forest Service attention to assisted migration demonstrate an awareness that requires dissemination beyond the agency, to stakeholders and the larger public, who may be unaware of serious consideration this topic has received even within the agency.

    The big “what if?” and a tree of last resort

    The big “what if?” question here is what if no conifer on the Forest or elsewhere is sufficiently fire resistant and, also, sufficiently drought tolerant to be resilient in the face of expected and plausibly inevitable increased frequency of fire and drought?

    A broadleaf tree might serve where the needleleaf conifers can’t. Because the broadleaf green ash does already exist within the Forest’s planning area, including the Ashland, might this tree offer an opportunity to avoid treeless conditions? It’s certainly fire-resilient, capable of resprouting back from roots where fire kills it aboveground. But alas, as the Forest points out on p 199, FEIS Vol 1, “Green ash is on the western and most arid margin of its range on the Ashland and Sioux Districts and is likely at the limit of its environmental tolerances. Because of this, extended periods of drought may have an adverse effect on regeneration and probably promote other problems.”

    The green ash is thus an unlikely candidate, one that is also at risk from the emerald ash borer.

    In that scenario, it is encouraging that the Forest can say, on p 104 Appendix F, Response to Comments, that “The Forest Service acknowledges the natural history traits of bur oak that would confer resilience to climate change. Currently, bur oak does not occur within the plan area.”

    The bur oak might be a tree of last resort, but its resilience does make it a high value tree that deserves broader attention. And its current absence within the boundaries of the plan area makes it another plausible candidate for assisted migration any time or place where a conversion to a treeless condition is not desirable or desired.

    A white oak, the bur oak is not known to be affected by sudden oak death, which appears, at least so far, to be limited to the red oaks.

    It is also known for high value to wildlife, including a broad range of species including but not limited birds, squirrels, and bears. In fact, its value to birds, squirrels, and bears makes it an interesting and potentially valuable counterpart to whitebark pine — a troubled tree that my not be as resilient as the bur oak.

    To assist the Forest in making the bur oak’s attributes more available to stakeholders, the larger public, and policymakers, I’ll be uploading the USDA Plant Guide for this resilient tree.

    And, for the Forest’s sake as well as others, I’ll be uploading this peer-reviewed analysis in hope it will help all concerned prepare for project level decisions as future conversions to treeless conditions develop:

    SCANDINAVIAN JOURNAL OF FOREST RESEARCH, 2017 VOL. 32, NO. 6, 535–543 http://dx.doi.org/10.1080/02827581.2016.1249022
    Assisted tree migration in North America: policy legacies, enhanced forest policy integration and climate change adaptation
    Adam Wellstead and Michael Howlett
    ABSTRACT
    The weight of much expert forest management opinion is that issues such as climate change can be effectively addressed only if forest policy-making moves from a purely sectoral focus and undergoes a shift to a more integrated multi-issue, multi-sector policy-making process. This is because credible adaptation policies in the sector require greatly enhanced multi-sectoral policy integration if they are to succeed. But this requirement may be beyond the capacity of many countries to deliver. This article explores the integration challenges faced by forest policy-making in Canada and the United States and uses the case of assisted tree migration to probe the reasons for the failure of institutions in both countries to develop and manage better vertical and horizontal integration in a climate change-related forest policy area. The article emphasizes the importance of previous rounds of policy-making or “policy legacies”, which serve to constrain contemporary policy options. It argues that due to the presence of many such legacies, forest policy development will continue to feature incremental adjustments through policy layering and policy drift, processes which limit the prospects for greater integration and better climate change adaptation in this sector.

    The Forest’s plan to monitor post-fire status of seedlings deserves full and broad support across stakeholders, the public at large, and policymakers who want evidence brought to hand.

    The Forest and others do know that post-fire seedling mortality has been documented with increasingly hotter, drier conditions. And it is a certainty that success or failure of seedlings predicts the future of forested conditions, desired or otherwise. Therefore, monitoring of seedlings is of high material interest for present and future generations.

    However, and without any diminishment of the importance of post-fire monitoring, post-harvest or post-logging monitoring will be just as important. After all, seedlings will die in hot dry soils no matter whether those conditions follow fire or logging.

    Review

    The Forest faces an increasingly situation, and is gambling that it’s management strategies will get it through a western US forest crisis following on the heels of a global atmospheric crisis. The Forest needs to make extra effort to convey the risks it and the forests under its management face in a hotter, drier region that is on a course to get additionally hotter and drier as households and industries continue a dependency on energy derived from fossil fuels.

    Reply
    • Two comments on this. I don’t think your references to NRV reflect the way the Forest Service defines it. If NRV is not sustainable, it is an incorrect NRV (see the definition of “sustainability” in the Planning Rule, and its reference to ecological integrity, as well as 36 CFR§219.8(a)). Second, your arguments point towards the NFMA requirements for “timber production” only on lands that are “suitable” based largely on their ability to regenerate a forest. Maybe the revised plan has got that wrong for some areas.

      Reply
      • I’m not sure that we need to accept the (current) Forest Service definition of NRV. I think it utterly reasonable to assume that departure from NRV has effectively been documented . For example, “Current projections indicate that a further 4° to 6°C global warming could be reached by as early as the end of this century (IPCC 2007), when global temperatures could exceed any reached in the last several million years.” Nathan L. Stephenson and Constance Millar. USDA Forest Service RMRS-P-71. 2014.

        Even more Forest Service awareness is evident here; “… all global circulation models (GCMs) predict unprecedented increases in temperature for the western US …” (https://www.fs.fed.us/wwetac/brief/western-forests-and-climate-change.php)

        Reply
        • Departure from HRV (“historic”) has been well-documented. The Forest Service definition of NRV (“natural”) is forward-looking, so the term “departure” may not be appropriate, or if it is we won’t be able to identify it until future monitoring identifies it.

          Reply
  10. So many things I could say to you Patrick but I’m going to limit it for now. My first summer season with USFS was 1973 as a driver of a fire engine on the Klamath NF.
    Tomorrow I’m meeting up with another volunteer to do a quick repair of a washed out road in Mt. Hood NF. We need access for passenger cars so we can get more volunteers in to a trailhead on Saturday for a trail maintenance project.
    The road leads to two small but popular NF campgrounds as well as some popular trailheads that many people like to access; primarily by passenger car.
    This road frequently washes out because MHNF has a huge road system and a teeny weenie budget for road maintenance. They can’t even keep the ditches and culverts clean so in this case the road becomes the ditch and all the soil washes out leaving ruts and oil pan eating rocks.
    They’re BROKE but keep trying to spread the limited money over a large road system. The result is poorly maintained roads at high risk of failure in large rain on snow flood events. At some point, storms are going to close roads and leave the agency with huge costs for reconstruction. I know one road in the Gifford Pinchot NF where a storm did that to a 20 foot diameter culvert; the pipe is still there but the entire road fill sluiced out into the downstream fish habitat. NO $$ for repairs so the FS put up a “Closed” sign. So much for proactive road management!
    The agency failed to take travel planning seriously, in MHNF, and decided to keep most of it’s road miles. So much for the direction to identify the “minimum road system!” Frankly, the process was a joke because the agency hates to give up roads; it’s like losing part of their fiefdom.
    If the agency would really take travel planning seriously they’d prioritize the roads that are needed for recreation access and other important needs. Then they could invest their maintenance money in the roads that matter to the public!

    Reply
  11. There’s been some discussion of “need for change” as a justification for revising a Forest Plan.
    Others might agree that the sampling of 3 articles below belong in this discussion.

    ================================================
    “Our findings suggest a shift to novel fire–climate–vegetation relationships in Greater Yellowstone by midcentury because fire frequency and extent would be inconsistent with persistence of the current suite of conifer species. The predicted new fire regime would transform the flora, fauna, and ecosystem processes in this landscape”

    Continued warming could transform Greater Yellowstone fire regimes by mid-21st century

    Anthony L. Westerling, Monica G. Turner, Erica A. H. Smithwick, William H. Romme, and Michael G. Ryan

    PNAS August 9, 2011 108 (32) 13165-13170; first published July 25, 2011
    https://www.pnas.org/content/pnas/108/32/13165.full.pdf

    ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

    “We contend that traditional approaches to forest conservation and management will be inadequate … in the 21st century. New approaches … acknowledge that change is inevitable and sometimes irreversible, and that maintenance of ecosystem services depends in part on novel ecosystems, i.e., species combinations with no analog in the past.”

    Forest Ecology and Management Published – 15 Jan 2016
    Review and synthesis
    Achievable future conditions as a framework for guiding forest conservation and management
    S.W. Golladay a,, K.L. Martin b, J.M. Vose b, D.N. Wear b, A.P. Covich c, R.J. Hobbs d, K.D. Klepzig e, G.E. Likens f,g, R.J. Naiman h, A.W. Shearer I

    https://www.srs.fs.usda.gov/pubs/ja/2016/ja_2016_martin_001.pdf

    a J.W. Jones Ecological Research Center, 3988 Jones Center Dr, Newton, GA 39819, USA
    b USDA Forest Service, Center for Integrated Forest Science and Synthesis, Research Triangle Park, Campus Box 8008, North Carolina State University, Raleigh, NC 27695, USA
    c Odum School of Ecology, 140 E Green Str, University of Georgia, Athens, GA 30602, USA
    d School of Plant Biology, 35 Stirling Hwy, University of Western Australia (M090), Crawley, WA 6009, Australia
    e USDA Forest Service, Southern Research Station, 200 WT Weaver Blvd, Asheville, NC 28804, USA
    f Cary Institute of Ecosystem Sciences, 2801 Sharon Turnpike, PO Box AB, Millbrook, NY 12545, USA
    g Department of Ecology and Environmental Biology, University of Connecticut, Storrs, USA
    h School of Aquatic and Fishery Sciences, University of Washington and CENRM, University of Western Australia, 133 Wilson Lane, Friday Harbor, WA 98250, USA
    i School of Architecture – Center for Sustainable Development, The University of Texas at Austin, 310 Inner Campus Drive, B7500, Austin, TX 78712, USA

    =======================================

    “Our results indicate that terrestrial ecosystems are highly sensitive to temperature change and suggest that, without major reductions in greenhouse gas emissions to the atmosphere, terrestrial ecosystems worldwide are at risk of major transformation.”

    Nolan et al. Past and future global transformation of terrestrial ecosystems under climate change.
    Science 31 August 2018
    https://science.sciencemag.org/content/sci/361/6405/920.full.pdf

    Reply
    • Lance, I think there are two things going on here.
      A) 1. We don’t know exactly how “systems” are going to change. 2. So the best we can do is monitor and be alert.3. Exactly what to do is controversial, and not surprisingly lines up along the same old lines of “leave it alone” vs. “do something.”
      B) each forest was asked to do a “climate plan” of some kind back around the time I retired (2012). I was on the national climate team. So this isn’t something they haven’t thought about.
      So are you saying that you think that this should make each forest revise their plan ASAP? There isn’t money to do that. And honestly I don’t know what good it would do. If you would like to write a guest post on how you think forests should respond to an unknown future, please send me one and I will post it.

      Reply
      • The short answer to “what to do” is that national forests must establish a desired condition based on an NRV that they determine (based on the best available science). How different the current condition is from that desired condition would determine whether they should “do” something. I do think that the term “desired condition” becomes a bit of a misnomer when it really means “what we’re going to have to live with due to circumstances beyond our control” and so it may have little to do with what we do or don’t do.

        Since you mentioned Yellowstone, I thought it might be worth a quick look at what the Custer-Gallatin revision did with climate information. They obviously gave it some serious thought: https://www.fs.usda.gov/detail/custergallatin/landmanagement/planning/?cid=fseprd587995
        Interestingly the Hansen presentation explores the option of forests converting to grasslands. However the revised plan says, “potential vegetation types generally remain constant” and I don’t see any recognition of reduced overall forest cover. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd762990.pdf

        As for whether this kind of information should trigger immediate revision of other forest plans, that would depend on whether the information represents a significant change in conditions for a particular unit (per NFMA) since the current plan was adopted. My guess is that current plans are not likely to keep the forests from “doing” things that would make much difference, so fixing this problem isn’t urgent. (Some wildlife protections may make a difference at the margins, but measures deemed important to sustaining wildlife are not going to be easy to change.)

        Reply
  12. Lance, I think there are two things going on here.
    A) 1. We don’t know exactly how “systems” are going to change.

    But we have known that they’ll change, and we know now of documentation that change is already occuring.

    2. So the best we can do is monitor and be alert.
    I stressed the importance of monitoring for both Forests where I filed objections

    3. Exactly what to do is controversial, and not surprisingly lines up along the same old lines of “leave it alone” vs. “do something.”

    Except in the likes of designated wilderness, leave it alone is obviously a non-starter.
    Yes, controversy comes center stage about what, exactly, to do. In my objection to the Custer-Gallatin Plan Revision, I focused on the material interest of climate-forced forest system change, and stressed that the Forest needs to disclose that this change is a threat to the Forest’s claim that it can “manage for desired future conditions of forest persistence via management for resilience and ecological integrity, in a context that assumes there is still opportunity for forest management within the natural range of variation.”

    Now, it has to be said, and it’s to the Forest’s credit that it said so, it does say, “Plan direction, which emphasizes ecological integrity and resilience, will be critical to minimizing the undesirable effects of these increasing and interacting stressors. Nevertheless, managers and the public should expect climate change to drive profound and often surprising changes on ecosystem structure, function, and composition in the coming decades.”

    Trouble is, this bit o needed realism is buried about 170 pages deep in the DEIS, so that stakeholders and interested parties may never get to know what the Forest itself knows

    B) each forest was asked to do a “climate plan” of some kind back around the time I retired (2012). I was on the national climate team. So this isn’t something they haven’t thought about.

    Yes, and there’s been even more thinking since then, with Forest Service researchers joining other in taking the lead. For example,It is considerable interest, then, that the Forest can report, on p 165 of FEIS Vol 1, the Forest included this passage; “The natural range of variation has been criticized as less relevant in an age of climate change (Millar 2014). There is potential for ecological transformations to occur in temperate ecosystems, based on the potential for interrelated drivers such as chronic and acute drought, wildfire, and insect outbreaks to push ecosystems beyond their thresholds for resilience (Millar and Stephenson 2015, Golladay et al. 2016).”

    Now, having read both Millar and Stephenson (2015), and Golladay et al (2016), the Forest knows what these researchers actually said, which is something that many stakeholders, members of the larger public, and policymakers may not know.

    That includes their shared outlook that climate-driven change of forests weighed herein are “inevitable”.

    I expect the Forest to concur that risk of inevitable forest change does not leave the Forest immune. I further expect the forest to concur that its main source of information, Halofsky et al (2018) suggest at least some inevitability of climate-driven forest change when saying, in Chapter 5 by Keane et al, Effects of Climate Change on Forest Vegetation in the Northern Rockies, that, “Increasing air temperature, through its influence on soil moisture, is expected to cause gradual changes in the abundance and distribution of tree, shrub, and grass species throughout the Northern Rockies, with drought tolerant species becoming more competitive. The earliest changes will be at ecotones between life- forms (e.g., upper and lower treelines). Ecological disturbance, including wildfire and insect outbreaks, will be the primary facilitator of vegetation change, and future forest landscapes may be dominated by younger age classes and smaller trees. High-elevation forests will be especially vulnerable if disturbance frequency increases significantly. Increased abundance and distribution of non-native plant species, as well as the legacy of past land uses, create additional stress for regeneration of native forest species.”

    I further expect the Forest to concur that any degree of inevitability of a changing forest is a matter of material interest to many stakeholders, members of the larger public, and policymakers, who may have had opportunity to read — but need to know — important studies that the Forest has read.

    So are you saying that you think that this should make each forest revise their plan ASAP?

    No. I’m only saying that the few Forests now doing revisions have to get it right.

    isn’t money to do that. And honestly I don’t know what good it would do.

    Full, accessible disclosure of forest exposure to climate risk is a public good

    Reply
  13. A worthy assessment of forest exposure to climate risk
    Lance

    National Wildlife Federation

    TOWARD A SHARED UNDERSTANDING OF CLIMATE-SMART RESTORATION ON AMERICA’S NATIONAL FORESTS A Science Review and Synthesis

    Suggested citation: Glick, P., B.A. Stein, and K.R. Hall. 2021. Toward a Shared Understanding of Climate-Smart Restoration on America’s National Forests: A Science Review and Synthesis. Washington, DC: National Wildlife Federation

    https://www.nwf.org/-/media/Documents/PDFs/NWF-Reports/2021/2021-Toward-a-Shared-Understanding

    Excerpt

    5. MANAGING NATIONAL FORESTS FOR ADAPTATION AND RESILIENCE

    5.2.2.1. Challenges and Opportunities in Managing for Transformation in Practice

    To some forest managers, the idea of accepting or managing toward ecological transformations that differ from historical conditions may run counter to what are considered best practices for forest restoration— primary among them the focus on use of locally adapted native species (e.g., Murcia et al. 2014, Backstrom et al. 2018, Breed et al. 2018). Given the pervasive ecological and economic impacts of nonnative, invasive plant species in national forests across the country, for instance, invasive species control has understandably and importantly been a high priority for the Forest Service (D’Amato et al. 2017, Poland et al. 2021). Similarly, forest restoration has traditionally adhered to the mantra of “local is best” when considering sources for seeds or seedlings, based on the assumption that local populations are likely to be better adapted to local conditions (Prober et al. 2015, Aitken and Bemmels 2016).

    Certainly, many conventional forest restoration and management strategies will continue to be relevant and useful in an era of climate change. As some scientists suggest, it is important that we not “throw the baby out with the bathwater” (Prober and Dunlop 2011) or abandon fundamental principles of ecological restoration, such as focusing on ecosystem processes and functions (Hanberry et al. 2015).

    Yet, there is growing recognition that, in some areas, the rate and degree of climatic changes are going beyond the adaptive capacity of species and ecosystems to cope or adjust, which may necessitate more rigorous interventions to forestall change, or, alternatively, decisions to either accept or actively manage for change (Millar and Stephenson 2015; Dey et al. 2019; Kemp et al. 2019; North et al. 2019; Parks et al. 2019a, 2019b; Prober et al. 2019; Stevens-Rumann and Morgan 2019). The consideration of ecological transformations as an outcome of restoration may be particularly appropriate in instances where landscapes are so altered that a return to a previously desirable set of conditions, such as those represented by HRV/NRV, is deemed unlikely or infeasible, with or without management intervention (Miller and Bestelmeyer 2016).

    For instance, low-elevation ponderosa pine and Douglas-fir forests in parts of the West may already have passed a threshold where regeneration is unlikely due to the combined effects of climate change and high-severity fire (Davis et al. 2019). Proponents of transformational adaptation argue that, given the pace of climate change combined with a host of additional, often synergistic stressors, novel conditions are likely to occur in many forest ecosystems, even within a single tree generation (Stanturf et al. 2018). Golladay et al. (2016) note that, in light of inevitable and possibly irreversible change, the ability of forest systems to provide valued ecosystem services will depend, in part, on the development of novel ecosystems.

    https://www.nwf.org/-/media/Documents/PDFs/NWF-Reports/2021/2021-Toward-a-Shared-Understanding

    Reply
  14. The Custer-Gallatin NF expresses important candor about prospect that its Forest Plan is at some risk of failure:

    “Plan direction, which emphasizes ecological integrity and resilience, will be critical to minimizing the undesirable effects of these increasing and interacting stressors. Nevertheless, managers and the public should expect climate change to drive profound and often surprising changes on ecosystem structure, function, and composition in the coming decades.”

    Buried 173 pages deep, in Volume 1, Final Environmental Impact Statement for the 2020 Land Management Plan Custer Gallatin National Forest

    https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd763586.pdf

    Reply

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