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 and to follow the law, perhaps the FS is stuck with out-of-date terms that are fairly arcane to most of us on a daily basis.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.