Do NFMA Timber Analysis Requirements and Terminology Get In the Way of Public Understanding and Support?

FS planning photo 1989.

Jon linked to this news article that mentioned the Commissioners’ letter about the GMUG plan revision.  As Andy Stahl has pointed out, NFMA was very timber focused (1976 is almost 50 years ago?) and to follow the law, perhaps the FS is stuck with out-of-date terms that are fairly arcane to most of us on a daily basis. But what if you’re a stakeholder who only interacts with these terms every thirty years during the NFMA planning cycle?  I wonder if there would be a way to simplify all this within the law.  Because if we are trying to change the pace and scale of restoration/fuel treatments and commercial harvest is nested within that,  the old ways and talk and the new ways may not fit -and indeed lead to more confusion and perhaps unnecessary bad feelings.

For example,  here’s what the Commissioners had to say about timber in the draft plan :

3. “A significant increase in suitable timber, which is a designation that interferes with consideration of responsible management of the forests that allow uses other than timber production” (my bold) .

I’m thinking here that the Commissioners simply don’t understand the suitable timber designation. Most of us can’t tell, when we’re recreating on the National Forests, or doing an APD, or applying for an easement, whether the map shows we’re in the suitable timber base or not.  It’s hard to imagine in practice how that could be.  In fact, we might be influenced in our uses by an actual timber sale (that is, staying out while equipment is working; looking out for log trucks on the road) but not by land being in a suitable timber base.

Conveniently, the GMUG clarified what the “timber-y” terms meant in this FAQ document .

Why does timber have a suitability decision?
No other resources seem to have this.
• The 2012 planning rule implements the National Forest Management Act and is used to write a forest plan. Both require the identification of lands suitable for timber production and the 2012
planning rule directs this process.
• Aside from coal suitability decisions required for forests with coal production, timber suitability is the only required suitability decision.
• Other resources are mapped and allocated, such as recreation and scenery, even though they are not specifically allocated as “suitable”.

Does the increase in lands suitable for timber production mean that other resources “lose” those corresponding acres?
• Lands suitable for timber production do not exclude other uses or resources. It does not mean that the area’s primary purpose is timber production. Production areas remain valuable wildlife habitat, popular recreation destinations, healthy watersheds and more.

Why do the acres of lands suitable for timber production increase between the former plan (1991) and the draft alternatives?
• The primary reason for the increase in acreage is the current policy does not require the exclusion of areas that may be uneconomical to harvest. (I asked the Forest and they said the new policy was the 2012 Planning Rule directives).
• Some of the area proposed as suitable for timber production likely will not be viable for commercial harvest, whether due to distance from existing roads, steep slopes, smaller diameter trees or dead stands. The economics and site particulars need to come together to make a viable and sustainable commercial timber sale. But we are unable to project where those will and won’t align, so the current approach is inclusive.
• Each future timber sale is analyzed in subsequent NEPA, and subject to public review.
• Commercial timber harvest is also allowed outside of lands suitable for timber production. Timber harvest in these cases may be for fuel reduction risk, wildlife habitat improvement, safety, salvage, disease or insect sanitation, or other reasons.


So what happens is:

(1) NFMA requires timber analysis perhaps currently of dubious value.

Forests do it.  Then they’re accused of focusing excessively on timber, despite all the other analysis that’s done.


(2) Forests will be asked to do more landscape scale restoration/fuel treatments.  But they don’t know how much of that will be commercial, either what we currently call commercial or what might be commercial in the future. I think the point of the analysis, and others more knowledgeable about the history can help me out, was to keep the forest from cutting too much .. so there were concepts like sustained yield and non-declining even flow and so on.  How relevant are these concepts and calculations today?

Since these future projects are wholly dependent on a) unknown future budgets and b) unknown economic factors, as well as c) unknown opportunities to/desire to salvage, what should a forest put under “timber volume” ? Here’s the GMUG explanation for the numbers in their plan.

Why does timber volume seem to be increasing in the draft forest plan?
• Current production is 60,000 CCF annually. The draft plan proposes as much as 55,000 CCF annually, so the plan would not increase production.
• Timber production on the GMUG has been higher the last few years, reaching over 90,000 CCF per year in 2018 and 2019. We’ve salvage-harvested more due to the spruce-beetle epidemic and lodgepole pine mortality. Timber production in 2020 was 75,000 CCF, and is anticipated to be 60,000 CCF in 2021.
• Harvest is expected to drop over time to approximately 30,000 CCF to 55,000 CCF due to the decline in salvage harvest.
• Because of the emphasis in alternatives B and C to do active vegetation management and more fuels reduction, those alternatives used the higher projection of 55,000 CCF. The other alternatives suggest approximately 30,000 CCF to showcase the lower end of the range in what we might produce.


14 thoughts on “Do NFMA Timber Analysis Requirements and Terminology Get In the Way of Public Understanding and Support?”

  1. I believe that “timber suitabiliy” is a misnomer.

    As it is/was used 5 or more years ago, it really should be “forest suitability”.

    It is/was a FIA term that classified USFS lands by their ability to grow so many cubic feet (or whatever unit was used – i’ve forgotten) per acre per year. So prarie grasslands, rock outcrops and etc. were a zero. Some lands with a very low growth rate capacity for trees wern’t classified as forest lands in annual publications and eventually in the intermediate data base info which was eventually made available to the public via something called the internet.

    This info was extremly usefull to the private sector in sighting new or shutting down the infrastructure nessary to keep stand densities at reasonable levels and thereby provide the sustainability necessary to perpetuate our national forests. It was a symbiotic relationship.

    But that was all in the past. Emotions devoid of any understanding of sustaianable forest ecosystems kicked the professionals out in an attempt to save a doomed but cute little owl and allow a future head of the Sierra club and all his minions to be able to fly overhead without seeing any interruptions in their forest viewsheds. Silviculture was thrown out the window and replaced by ignorant, emotion based wishful thinking.

    Ooops, didn’t quite work out, did it? Now evolution is in final throws of eradicating that cute little owl. Now we have national forests with viewsheds mared with humongous ashtrays obliterating entire viewsheds. Now we’ve wiped out a city and come close to wiping out several more including one huge city. Now the smoke from these wildfires endanger lives for as many as a thousand miles downwind.

    Arrogance and ignorance combined with a desire to control policy or make a living off of lawsuits based on bad policy or heading up misguided conservation organzations or ??? sure has done wonders for saving endangered species and providing the sustainable forest ecosystems and edge effect that they need to survive. NOT!!!!!!

  2. I have never understood why the FS had to think up ccf. It is a unit of measurement used by nobody else. It is usually converted to mbf to be useful.

    • Ah, the good old “Cunit” which was 100 cubic feet which was ccf or Ccf. So the “C” was for one hundred and we just couldn’t get rid of Roman Numerals until the computer industry took off. I have no idea where their idea of using “K” instead of “M” for one thousand came from.

      In 1971 when i got into the business in the South, we were using Cunit for total tree volume because u can’t measure pulpwood (p/w) in board feet (bf) and cords for p/w made no sense ’cause u can’t make paper out of air or bark. So Cunits inside bark (i.b.) measured the total merchantable solid wood content in a tree. For small sawmills that stick scale, MBF still lives and, of course, lumber is still measured in nominal rough sawn (undressed) MBF rather than actual dressed (planed) MBF.

      I nearly retched when i first found out that the USFS was attributing bf to p/w which can not be sawn into lumber.

      • Before using MBF, commercial wood was routinely measured by the USFS as cordage. This has been defined as 128 cubic feet since the 1800s. So why did the USFS have to invent ccf for i.b. p/w instead of using widely-recognized cordage simply adjusted for air and bark? Also, worse in my book, why did they ever start inventing and enforcing acronyms and abominations as ccf, i.b., and p/w on the rest of us? This practice has been a major communications impediment between federal officials and their documents — including forest plans — and taxpayers for too many years, in my opinion. 100 cubic feet as a measure does make sense, though, and I’m just thankful that metrics (m. or cm. cubed) weren’t used.

        • Bob – it’s good to hear from you.

          One of the problems with cords is that different diameters have different ratios of bark and air. So a stacked cord has more bark but less air space if it is comprised of small diameters than a stack of large diameters. It’s just geometry. If you use 128 cf/cord, it is no more appropriate than reporting p/w as MBF.

          Customers within and without the USFS used to be satisfied with MBF & Cds. But, computers created the power to wring more info out the FIA. In-house and out-house users demand for access to the data blossomed. It became possible to take care of some research needs and a broader array of reporting requests. Corporations needed to be able to add up p/w, c-n-s and s/t (including veneer bolts) volumes in a single unit of measure to validate the total inventory volume reported which investors & auditors compared against prior yrs annual reports to get a rough feel for the sustainability of a business. The FIA inventory is designed to (and for other needs) help private corporations make siting and operational sustainability decisions.

          So FIA provides the inventory in units of measure (Cunits for all products & culls/mortality as well as reporting s/t in both Cunits & MBF). All of this is computationally easier for both the FIA and customer.

          Since i last used the FIA data base, i’m sure a lot has changed so the above is my take on a 38 yr window begining in 1971.

          • Hi Gil:

            Good to be back in touch with you, too!

            Why couldn’t the USFS use a “commercial (or other modifying adjective) cord” as a measure of a 100 cubic-feet of potentially-merchantable timber? And then use actual English words to describe the process and provide a range of values (whether the bolts are from 3″ or 48″ in diameter) as to the MBF that might be included in this measure? Plain English, some basic arithmetic and reasonable conversions for those using other measures would greatly improve trust and communication, in my opinion. Your thoughts?

            • #1) It is all tied to what the market (paying customer) wants.

              #2) In addition, the lingo of specialists is always difficult for outsiders to understand. You wouldn’t think that the language of statisticians has change significantly since the 1960’s, but it has. In this case that we are discussing, the tech lingo of mathematicians, statisticians, inventory & computer people kind of sticks until someone wants to pay for simplification. I attribute some of this to a well documented fact that specialists have been known to deliberately/subconsciously create their own jargon to keep down the competition.

              But, no matter what, #’s 1 and 2 interact and, just like the English language has, you evolve to a point that makes some old timers cringe. I wasn’t particularly great at grammar but I do know that reading a newspaper today and hearing the way some people talk has made me cringe and has made some of my former English teacher’s roll over in their graves many a time. Try reading Beowulf from somewhere around the year 1000, then read the King James Bible (KJV) of 1611 and you’ll see how much our language has changed in 600 years. If you are a real glutton for punishment compare the KJV to the New American Standard Bible (NASB) or the New International Version (NIV) and you’ll get a feel for the rate of drift over the last 400 years. The rate of drift seems to have slowed down but, still, it is difficult for most people today to read the KJV.

              • Gil: I completely agree with your statement: “I attribute some of this to a well documented fact that specialists have been known to deliberately/subconsciously create their own jargon to keep down the competition.” I attribute almost all of this obfuscation to that fact.

                Government-induced acronyms are not a “change in the English language,” though, they are purposeful obfuscation — apparently used in many cases to hide the inability and lack of actual experience of the inventors and users. Pig-latin for bureaucrats to justify unnecessary meetings, defray public questioning, and requiring additional “work from home” funding. In my opinion.

  3. The FS has simplified things. Many timber sales are now sold by the ton. The mills and loggers are able to figure out the basic value of the offered timber and bid accordingly. It also makes It much easier to buy and sell the timber. The rules the FS has for a scaled sales are very difficult for the buyer and often makes it more difficult to sell FS logs.
    One comment on ccf vs metric system of Cubic meters is that at least with cubic meters we would be using the same system as most of the rest of the world.

    • 1) “The FS has simplified things. Many timber sales are now sold by the ton.”
      > I guess that I’m not surprised. Depending on the company and it’s size, we (the South) often used weight combined with number of stems to get a proxy for size at the scales because the cost of stick scaling was too expensive for a big mill and it held up trucks getting in and out.

      The problem with “weight only” is that in the winter when the sap is down, wood weighs less per Cunit than in the summer when the sap is up. All that you can do is hope it will average out over the year or at least over a couple of years depending on changes in the growing season.

      And of course, all of that is confounded by changes in stand size and age and whether it was genetically improved stock and or fertilized for fast growth and whether it was local stock or naturally regenerated and whether it was wide spacing or dense spacing which all impact specific gravity and therefore weight/cf which has a very big impact on on pulp yield. Oh yeah, I almost forgot unthinned or thinned also confounds things as does the number of thinnings and ages at which thinned,

      All of this makes anyone have a better appreciation for the KISS principle (Keep It Simple Stupid) and helps us to understand why people have gone to weight.

      2) “at least with cubic meters we would be using the same system as most of the rest of the world”
      > That isn’t a big problem since the conversion between volume measured in Cunits and cubic meters is a constant.

  4. I don’t know why the GMUG didn’t just include the legal definition of “timber production” (as in “lands not suited for for timber production,” the phrase used in NFMA): “Timber production. The purposeful growing, tending, harvesting, and regeneration of regulated crops of trees to be cut into logs, bolts, or other round sections for industrial or consumer use.” And a regulated crop of trees is one that is managed to produce a sustained yield of timber. A sustained yield of timber is only a requirement for land that is suitable for timber production, so timber volume from suitable and unsuitable lands must be tracked separately.

    While projected yields from suitable lands can be reduced from what is optimal for timber volume, it is more likely that logging will occur on suitable lands, and that should be an important consideration to the public in the forest planning process. Why it is more likely is related to the Forest Service’s secretive program/budget/target process that I would be happy to have someone explain to me, but I think the Commissioners’ conclusion that timber production “interferes” with other uses is valid.

    The Forest Service seems to want to obscure this distinction. Even worse, they want to avoid the requirement related to the distinction. In the Planning Handbook they have stopped basing sustained yield on what their selected alternative is likely to be able to produce from suitable lands, which I believe is a violation of NFMA. Maybe this is all because they see an opportunity for more flexibility for how to meet their timber targets.

    NFMA requires that lands suitable for timber production should be based on “physical, economic, and other pertinent factors to the extent feasible …” Failure to account for lands where timber production is economically infeasible would result in an overestimate of sustained yield and may lead to a declining harvest flow.

    It’s dangerous to throw the term “commercial” into this discussion because timber sales may occur on lands that are not suitable for timber production.

    I disagree with the GMUG statement that timber is the only required suitability determination. NFMA requires “the identification of the suitability of lands for resource management,” and forest plans usually contain a table showing this identification.

    • Jon

      I’m not sure that there is any orchestrated effort to cover up.

      I think that the problem arises from the fact that the USFS organization has to deal with the complexity of the science, variety of conditions and ambiguity of “product”, coordination between the different arms of the large heterogeneous organization, policies and priorities imposed by outside sources with little or no understanding of how one part affects the other as well as ambiguity around interpretation and compliance.

      And, then, all of that is subject to constant emergencies on a catastrophic scale equaling that of floods, hurricanes, volcanic eruptions, and earthquakes constantly requiring excruciating and rapid priority changes. Then there is the constant legal nitpicking from those outside with little or no understanding of the many pertinent and interrelated sciences while demanding one size fits all solutions. These last two alone are enough to continually defeat management efforts to provide sustainable forestry for the good of the worldwide environment and it’s denizens.

      It’s Just Too Complex And Everything Is Interdependent. It’s not like a corporation or any closed loop system in which you can compartmentalize horizontally and operate vertically with a demand < supply hierarchy within and between compartments to produce well defined products that can be boxed up with a ribbon around it and then shipped. It is a Terrorized Management Monster Nightmare. Who has time to check against 3 million different places that define this as that and to separate it all out when they contradict and sometimes even self contradict?The USFS is part of the federal government which constantly writes laws that contradict the constitution and it's sub parts without going through the constitutional amendment process. How could anyone but self serving: double talking politicians, lawyers, accountants and their obedient pencil pushers survive and thrive in such an environment? Think about it: How Would Anyone Successfully Manage An Organization Like The USFS when their supervisors can’t even manage much other than pork barrel projects, parties, concealing bribes, photo ops and political fighting with lies to make sure that they get rehired by fooling their constituents? Oh, I forgot their supervisors don’t even do most of that. They leave all that to their aids who they are training to take their place.

      This sounds Jaded N. Cynical but I do try to Love All as is required by the Lord God Almighty and I try to Rejoice Always for I know that He is in charge and is simply allowing the chaff to be sifted out while the rest persist while waiting for the transition out of this burden filled life to an eternal life of joy.

  5. I’m glad my comment was so inspirational, Gil, and I don’t disagree with some of your points about the agency mission and workload (been there). But the USFS doesn’t write laws, and I’m not familiar with any hot Constitutional questions about the public land laws they follow or the regulations implementing them.

  6. Of course, the USFS doesn’t write the laws but their supervisors (i.e. congress) do and there seem to be plenty of conflicting dictates.

    Those same law makers are the ones creating laws of all sorts contradicting the constitution.

    My comment alluded to the failure of congress to follow the law (costitution) yet, expecting their employees to do so.

    Apparently my efforts to avoid a long drawn out response was too subtle.


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