More Discussion Topics from Sam Evan’s Piece on The Nantahala-Pisgah Plan Revision

Reflecting both on Sam Evan’s piece and the associated comments, I’d like to pull out some additional observations of his for further discussion. This is the first of two posts.

First, I’d like to point out that I’m interested in posting thoughts of anyone who experienced the 2012 Rule process, either as a stakeholder or as an employee (this perhaps would be difficult even with anonymity for current employees, so perhaps a recent retiree).  Sam was kind enough to offer this in response to a protracted campaign (years of harassment?) by me, but others are also welcome to submit.

Then, on to my thoughts.

TSW readers well know that I am not a fan of the abstraction “ecological integrity”.  Nor NRV, for that matter.  But how do people actually work through these abstract concepts in real (or at least planning) life?
So I was pleasantly surprised to find that Sam thinks (1)

First, and crucially, the Plan does provide detailed, well-supported desired conditions for each ecological community, or “ecozone.” Plan at 54–64. These reference conditions are grounded in the best available science and provide unifying direction for future management. Each set of “key ecosystem characteristics” describes characteristic species composition from the canopy to the forest floor, plus characteristic disturbance patterns and structure.

 
I would have been concerned about “how do we know what the landscape was like prior to the reduction in population/removal of Native Americans?” How can we possibly get Vegetation Desired Condition targets that are pre-Native American influence, or is our goal to emulate their activities? I also think about the American Chestnut, not coming back in the foreseeable future. Anyway, I was pleasantly surprised to see that they (the FS) apparently figured this out and the partner group agreed.

Sam also says “Still, much of the landscape is recovering well: pockets of old growth, disturbance-sensitive species, and backcountry areas large enough to allow for natural disturbance processes to resume.” That would be “natural disturbance processes subject to invasive diseases and insects, and climate change” so perhaps more clear would be “disturbance processes without local human intervention.”

(2) There is a tension between the existence of a “big blanket” suitable timber base, and the assumption that the forest will plan projects on all the acres in the suitable base. For example, Sam says “On average, therefore, 20% of harvests proposed under the new Plan are guaranteed to generate conflict” and what really happens on the landscape. Another example is “even-aged harvest is scheduled on a whopping 58% of the landscape.” See, I don’t interpret acres in the suitable timber base as being “scheduled”.. But that’s based on the model in my head of how this works (based on my own observations). To me, suitable acres are a big blanket. When FS folks decide where to put a sale, they use all kinds of different factors to decide where to put it… including where it will be less contentious. I don’t recall any forest (and for sure I don’t know them all) where everything in the suitable base was actually entered for timber management.

I don’t know what the suitable base was under the previous plan, but Sam says the forests were actually harvesting 750 acres per year. Now I don’t know if my numbers are right so please check but I added up the two forests’ acreages and got 1,044,000 million acres. At 750 acres per year, for a 30 year plan, 30 years or 22,500 acres and 2% of the Forests. At that rate, they would hit 2% rather than all 58% of the suitable.

(3) Which leads us to the issue of Post Plan Prioritization. Once you have the blanket (suitable base) where does the FS actually propose projects? It seems to me that Sam is arguing for more “Post Plan Project Prioritization” PPPP in the Plan itself. But there are other approaches that might work, like the less formalized “Zones of Agreement” approach that occur elsewhere. Actually, it sounds like it occurred here too, so the question is how formalized should it be? It seems like the other Zones of Agreement are more like a living process than a codified one. So this is a topic for discussion.. advantages and disadvantages or more or less codified PPPP?

(4) I also see both “Adaptive management “triggers” to gauge whether the Forests have the capacity to mitigate negative impacts before moving to stretch goals” and A “pacing” mechanism to ensure that high-consensus restoration occurs alongside scheduled harvest” as sub-plan level sideboards of a kind that are not exactly found in the 2012 Rule. The Rule says to monitor anyway, so why develop triggers in advance? Maybe those make more sense as an ongoing dialogue among partners and the Forest than a codification for likely to be thirty years?

But those are enough discussion points for now… next post will be on Sam’s more general observations about the 2012 Rule.

24 thoughts on “More Discussion Topics from Sam Evan’s Piece on The Nantahala-Pisgah Plan Revision”

  1. > To me, suitable acres are a big blanket. When FS folks decide where to put a sale, they use all kinds of different factors to decide where to put it… including where it will be less contentious. I don’t recall any forest (and for sure I don’t know them all) where everything in the suitable base was actually entered for timber management.

    This take is not consistent with how timber planning works. Areas are assigned to “suitable” MAs if the Forests Service intends to regenerate them, whether that occurs in the current plan cycle or future plan cycles. Spectrum, like FORPLAN before it, schedules harvest over multiple planning cycles. Nobody is arguing that 58% of the forest will be harvested anytime soon, but timber resources require long-term management, which means that silvicultural investments have long-term consequences. Allocating an area to suitable management matters, and it should matter. You can’t move the suitable base around every 15 to 20 years any more than you can move the old growth network around every 15 to 20 years.

    Scheduling the suitable base for harvest means that the Forest Service is “counting” on those acres, now or in the future, to sustain a flow of wood products. Allocating acres to a suitable MA is a statement by the Forest Service that plan-level considerations (like a predictable flow of wood products and age class distribution) are going to predominate. Allocation to an unsuitable MA is a statement that local contexts are going to be as important (if not more).

    If the agency avoids high conflict areas now, it is either (a) deferring those conflicts to the future or (b) lying about how much timber flow it can sustain. If high-conflict areas won’t be regenerated and the suitable base includes lots of high-conflict areas, then the “real” suitable base is much smaller than they’re saying. So, if they’re producing timber consistent with a bigger suitable base now but avoiding conflict areas, then they’re going to be able to produce less timber in the future. (Boom, bust.)

    Further, I am glad that your experience suggests conflict avoidance, but shall I recite a litany of projects in which the Forest Service proposed to log old growth or rare habitats or build roads into unroaded areas? In some cases, they doubled down on those proposals over broad and vocal opposition. In many other cases, we persuaded them to drop stands by shaming them publicly. At the end, some areas of high conservation value were protected and some were not. But tremendous amounts of time and money were spent fighting over those outcomes. This is what I mean when I say that conflict is a sideboard to protect conservation values, but it’s not an efficient sideboard.

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    • §13 of NFMA prohibits “boom and bust” unless that has been disclosed to the public during the planning process as a “departure” from non-declining even flow of timber volume. (The Forest Service Handbook muddies this water by trying to redefine “departure” as something different from the traditional definition employed in NFMA.)

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  2. > there are other approaches that might work, like the less formalized “Zones of Agreement” approach that occur elsewhere. Actually, it sounds like it occurred here too, so the question is how formalized should it be? It seems like the other Zones of Agreement are more like a living process than a codified one. So this is a topic for discussion.. advantages and disadvantages or more or less codified PPPP?

    I hear your skepticism about ecological integrity and NRV. But theoretical uncertainty has to give way to concrete action, and I doubt you can show me a better reference condition to establish a direction for concrete action. Defining NRV, of course, is hard to do. It may be impossible to create a definition without ambiguity. Whether something counts as restoration is going to depend on lots of site-specific and landscape-scale contexts. So, I agree that “zones of agreement” are useful to flesh out what restoration is going to look like on a particular forest.

    That is precisely what happened here in the collaborative group. We defined a list of priority treatments that we believed responded to common conditions and would, at scale, restore structure, composition, and function. We’re not talking here about project prioritization. We’re talking about a definition of restoration without which there is no way to credibly say that we’re moving toward NRV. Those priority treatments are not included in the plan.

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  3. > The Rule says to monitor anyway, so why develop triggers in advance? Maybe those make more sense as an ongoing dialogue among partners and the Forest than a codification for likely to be thirty years?

    Monitoring can provide useful information about whether there’s a need to change the plan during implementation. But triggers as discussed here are meeting different needs. And there are two kinds of triggers being mushed together here.

    First, “pacing”: As explained in the prior post, this is about making sure that “flexible” project development doesn’t result in doing the same easy, cookie-cutter things over and over again, moving away from NRV. Restoration inherently requires some attention to the proportions of different types of actions taken in different contexts, because local decisions have to contribute to landscape-scale outcomes. The alternative would be to “monitor” whether you’re making progress toward NRV and then amending the plan to modify your timber sale program if you’re not. That kind of nebulous monitoring task is impossible as a practical matter.

    Second, some triggers are needed to make the “tiered objectives” work. Forest plans must be integrated (i.e., making progress toward desired conditions for one resource cannot preclude making progress toward desired conditions for another resource). Forest plans must also be fiscally constrained. If you are going to adopt stretch goals that you know are beyond your current fiscal capacity and are in tension with other resource goals, then you must have a way to know when your capacity has increased enough to tackle your stretch goals without undermining other resource goals. If your alternative approach is “monitor and amend the plan,” then you shouldn’t have adopted stretch goals in the first place. You should have set fiscally constrained objectives. Then you can monitor and amend the plan to adopt higher objectives in the future if warranted.

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    • Sam, please tell me more about the concept of “stretch goals” and how it developed that it was integrated into the plan recommendations.
      Was it timber folks?
      Was it a trade-off agreement for other things?
      Was it the idea of the FS?

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      • Sharon, early “building blocks” for the plan anticipated lower outputs. The Forest Service built stretch goals (we called them tiered objectives) into the Draft plan in response to complaints from the stakeholders: (a) from the timber and game wildlife folks, that higher outputs were desirable, and (b) from the greenies, that the possibility of higher numbers was important to keep everyone working together.

        One of the collaborative insights was that higher levels of active management and more protected areas were compatible—ie, that we had been working very inefficiently on a suitable base that was too big (in that it included lots of high conflict areas). There was a narrative that “wilderness” was the reason we couldn’t have more harvest, even though we have very little wilderness. We knew we needed to prove we could grow harvest levels in order to earn political support for designations.

        So we wanted to build an incentive structure where we would work together to get more done in a more focused way (both geographically, with production on a smaller focus landscape, and prioritizing, with targeted restoration on a broader landscape). Part of that incentive structure was creating room to grow beyond historical levels of harvest.

        The Forest Service actually worked really hard to figure out how to include stretch goals in the draft. It was super innovative work, any it really made it possible for the collaborative group to stay together and reach agreement. The way I like to think about it: traditional planning is balanced when it disappoints everyone equally, but we wanted the Forest service to actually do more for everyone. We couldn’t have reached agreement on more protected areas without agreement for more harvest.

        This all sounds great, right? But there was a big shift from draft to final. At the draft stage, the consensus land allocations were still on the table. And we still believed the agency would see the value in our recommendations for “triggers.” We thought they would realize that with bigger numbers, they were building potential goal interference into the plan, and they would need thoughtful structures (like our collaborative recommendations) to prevent that from turning into conflict. Instead, at the final stage, they’ve given us a stage with the same old landmines as the old plan, and they’re going to be running around just as blindly, and trying to do it faster.

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        • This just goes to show that those three ‘C-Words’ should be completed in proper order. Collaboration always comes first. Consensus needs to happen before people can go on to Compromise. Most of us should have learned that, by now, but some of the authorities seek to impose Compromise before Consensus has been achieved.

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    • It’s not clear to me whether either of these is what I consider the traditional form of monitoring triggers. They would be written in the form of a standard, meaning that if X occurs (when it is not desired) or does not occur (when it is desired), then Y must not occur. (Since standards cannot compel something to occur.)

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  4. Sharon – you wrote…

    I don’t know what the suitable base was under the previous plan, but Sam says the forests were actually harvesting 750 acres per year. Now I don’t know if my numbers are right so please check but I added up the two forests’ acreages and got 1,044,000 million acres. At 750 acres per year, for a 30 year plan, 30 years or 22,500 acres and 2% of the Forests. At that rate, they would hit 2% rather than all 58% of the suitable.

    The suitable base under the old plan was 429,732 acres, found in the FEIS Section 3.4.10 Timber Resources, page 3-542. It is 505,618 acres in the Plan.

    In a comment to Sam’s piece I pointed out that the numbers the USFS expresses and that you calculated are quite misleading. The suitable base is very strictly calculated based on rules in the Planning Act and Planning Directives.

    From page 3-538 of the FEIS
    Three definitions from Forest Service Handbook 1909.12 CH 60, which lays out the analysis process, are useful here:
    1. Suitability of lands: A determination made regarding the appropriateness of various lands within a plan area for various uses or activities based on the desired conditions applicable to those lands. The terms suitable and suited and not suitable and not suited can be considered the same (CH 60.5).
    2. 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 (CH 60.5)(36 CFR 219.19).
    3. Timber harvest: The removal of trees for wood fiber use and other multiple-use purposes (36 CFR 219.19).

    A key component of Suitable Base is the assigned Management Area. So the USFS has quite a lot of discretion regarding that factor – but they are constrained by various factors and conditions. See further the text on page 3-539 of the FEIS. Lands that are constrained by the factors and conditions are removed from the suitable base. I give the USFS credit for then calculating Operable Lands – which is a closely related to the suitable base and adds a few more conditions such as viability.

    Now here’s the rub in Pisgah and Nantahala – because many of those ‘other factors and conditions’ are not going to change the suitable and operable base isn’t going to change that much based on Management Area designations the USFS makes. And in fact, the Alternative E chosen by the USFS has THE MOST suitable and operable acres of any alternatives. Those other factors include MAs that USFS can’t change (Designated Wilderness) and conditions like steep slopes and riparian buffers which will never change because they are the landscape itself, and conditions like View Sheds and ROWs etc… which are never going to change because the Blue Ridge Parkway and Scenic Hwys like US276 and NC11 and powerlines etc… are permanent.

    So IMHO it’s not rational or logical to think about the % of timber harvest and operations on the WHOLE FOREST because the USFS is not ever going to manage timber harvests on the whole forest. The USFS has, whether anyone likes it or not, about 450,000 acres of land where it is possible to manage for timber production. And even that number is very misleading because the USFS says that only 233,000 acres of that is actually accessible given the current road network. That 233,000 acres isn’t in the FEIS anywhere, I got it by summing the acres in the Operable shapefile provided by USFS. Of those 233,000 acres only 107,000 is commercially viable in the plan life. There are 272,000 acres which are operable but not accessible given the current road network. So more than 1/2 the lands that can be managed for timber harvest will require new roads – and to Sam’s point about contention road building is always going to be contentious.

    So, let’s go back and look at the targets from the FEIS for Tier 1 and Tier 2. Tier 1 is 2,200 acres per year, 22,000 acres per decade, 44,000 acres over the life of the plan. That 44,000 acres represents 41% of the accessible and commercially viable land base. I would certainly expect the USFS to show me how that is sustainable, but there’s absolutely ZERO in the plan telling me that. The Tier 2 target is 2,500 acres per year, 25,000 acres per decade and 50,000 acres for the plan life out of a base of 133,000 acres operable+viable but not accessible. In total that 94,000 acres which would require a huge amount of road building (about 80 miles permanent and over a hundred miles temporary) and represents >38% of the total viable and operable base in the forest. Again, no mention of how sustainable that would be in the plan.

    These are the targets – and as soon as the USFS isn’t making targets there’s going to be a lot of pressure to make those targets….

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    • Nicholas.. Perhaps your numbers and mine are both correct? When I calculated, I was looking at the percentage of forest acres that would be impacted by timber sales (of course impacts would be different based on thinning vs. regen cutting but leaving that aside, we’ll just look at the acres the timber program touched. I’ll have to state my ignorance here, but from some of the articles it looked like more openings were needed for NRV or for wildlife or both. So there would be some overlap between “acres needed to restore” and “acres harvested.” So some of the acres touched would in fact be moving the Forest toward restoration goals.

      My point was that if we take your Tier 1 acres, you have 44K acres out of 1044 mill during the life of the plan, or 4% of the Forest impacted in 20 years. Now if we subtract the sales where restoration objectives are also being met, it doesn’t seem like a big “fingerprint on the landscape.” Say, take a flight over the Forest.. what would you see? That’s what I was calculating.

      What you were calculating seems to be “how much of what is practical/economic to log are they going to touch?” which is a much higher percentage, of course. But we won’t see on the landscape that when we fly over the Forest. We will see powerlines, Wilderness, towns and so on and ..some openings.

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      • I think it was this forest that was going to identify and manage permanent openings for wildlife. Those would not be suitable for timber production.

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        • Hi Jon: I have been arguing for restoring precontact prairies, meadows, and berry patches for decades. Not only do these historical landscapes create “permanent openings for wildlife” — songbirds, butterflies, wildflowers, deer and bear — they also make great firebreaks. That is exactly how they contribute to timber production — by protecting it from wildfires. Maybe especially when the policy is to not harvest snags from these events.

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      • Both our numbers are correct, but considering the % of land impacted by timber harvest and using the entire forest as the base is misleading. If you took a million acres of land and randomly scattered 2,200 or even 4,700 acres of timber harvest a year over that base then I agree that it might be hard, but certainly not impossible, to spot from the air. The reality, however, is what I highlight – the operable acres are not scattered randomly across the landscape. Operable and viable acres exist in a small 243,000 acre subset of the 1,000,000 acre forest. That’s roughly 24% of the landscape. About 500,000 acres of the forest will most likely NEVER BE OPERABLE for timber harvest. That operable subset is concentrated in areas where the slopes aren’t steep, there’s no wilderness or designated old growth, etc… it’s not just randomly scattered.

        Most people experience the forest from ground level and not 10,000+ ft up. Certainly the plan is at a landscape scale, but the implementation of the plan is on the ground. On the ground, fewer than 250,000 acres are available for timber harvest during the term of this plan.

        You do mention another important aspect – restoration objectives. But restoration today doesn’t equate to viable forest stands in 20 years, more like 60-80 years at least. The USFS doesn’t publish any forward looking stand-age and viability data for the next 20 years (after 2042). The timber harvest levels are required to be constrained by capacity for sustained yield in perpetuity. But the operable and viable lands have some huge gaps in the stand age classes. I’ve done the math and found there are < 10,000 acres in the 60,70,80 year age classes in the operable+viable lands. I argue that 44,000 acres over 20 years isn't sustainable at all.

        Operable + Viable Acres
        Accessible Inaccessible Age Class
        154 35 60
        1,289 1,000 70
        7,214 9,163 80
        25,486 32,312 90
        38,044 43,630 100
        21,603 30,954 110
        13,961 19,676 120
        107,751 136,770

        Appendix B of the FEIS table 209, page 3-540 shows ~700,000 acres that MAY be suitable for timber production. Per the 2012 planning rule that’s the number used to calculate the Sustained Yield Limit (SYL), as stated on page 3-535 of Appendix B.

        “The Sustained Yield Limit (SYL), as calculated during this forest plan revision analysis, would be 45.0 MMCF/year and does not change between the four action alternatives. This sustained yield limit was calculated from approximately 700,000 acres. ”

        Lands identified as accessible and viable in Tier 1 represent ~ 14.3% of 700,000. Lands identified as inaccessible and viable in Tier 2 represent ~ 19.6% of 700,000. Together, the operable and viable lands are ~ 33.9% of the total lands used to calculate SYL. Checking table 211 – Summary Harvest Information by Alternative and Tier shows 5.1 MMCF annual, or 11.3% of SYL under Tier 1 and 17.6 MMCF annual or 39.1% of SYL under Tier 2. The SYL isn’t meant to be a target it’s meant to be a cap. But the plan sets a TARGET of roughly the SYL on the lands they will operate on during the plan. To summarize that point – they target 11.3% of the SYL for the forests from 14.3% of the land and they target 39.1% of the SYL for the forests from 34.8% of the land. Is it wise to set a goal of harvesting at the absolute MAXIMUM SYL of the operable and viable base?

        So maybe from an airplane you don’t notice how much, but IMHO the plants, waters, wildlife, and people will certainly notice that on the ground.

        I'd really like to see the plan include forecasts for acres by age-class at the end of the 20 years under Tier 1 and Tier 2. I'm skeptical about the plan because they didn't provide them. In the 40 and 50 year age classes there are about 50,000 operable acres. While that's more than the 44,000 acre harvest goal of Tier 2 those 50,000 acres will only be 60-70 years old in 20 years. So they aren’t replacing the trees they are harvesting.

        In closing I'll reiterate my point – using 1,000,000 acres to analyze the timber harvest goals isn't being honest, transparent, or realistic. The USFS has, at most, about 500,000 acres that can be managed for timber (by law and regulation and site condition). Of that, during this plan, only 243,000 viable acres can be managed for timber harvest … So when we talk about timber management for timber production let's be honest and talk about the acres that can actually be managed for timber production and not all the acres in the forest. Then, to be really honest, let's talk about managing those other acres for the uses and purposes and conditions that it's possible to manage them for.

        IMHO we have two forests in Nantahala and Pisgah – one forest can only be managed for multiple uses OTHER THAN timber production. The other forest can be managed for multiple uses which includes timber harvest.

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        • I’m all for these ‘reality checks’ and full transparency. There needs to be a realistic estimate of ‘economic acres’ (where profit can be made on cutting the excess amount of timber in those acres, using current rules, laws and policies). Then you can decide what amount of acres can be sustainably harvested.

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        • Nicholas- I think I’m actually asking a spatial question. As in, are the acres designated for potential future timber harvests in a clump..? How are they aggregated across the landscape. I think you mentioned some GIS work you had done in an earlier comment, so it would be helpful for us to see that. Thanks!

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        • The “sustained yield limit” is not a limit at all because (by the incorrect Forest Service Planning Handbook definition) it does not take into account the restrictions on timber harvest imposed by each alternative. It is an unachievable maximum. This is even worse than ASQ as a target, because ASQ did attempt to factor in the restrictions in alternatives (and each alternative had a different ASQ). The FS could not achieve ASQ most of the time on most forests, so I did not think the it would be foolish enough to use SYL as an even more impossible target.

          Interesting that the effect of costs on the likelihood of timber harvest is an issue. Under the 1982 planning regulations, lands were not suitable for timber production if it cost too much to do so, and ASQ also took that into account. So is this the case now – there is a much larger suitable timber base, leading to higher targets, but much of which can’t be logged because of conflicting management goals or because it is too expensive, so when the economical and non-controversial lands have been logged, timber yield will drop off a cliff?

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          • You said it better than I did…. SYL is calculated from 700,000 acres. The operable, accessible, and viable lands total 107,000 acres. The operable, inaccessible (need roads to harvest), viable lands total 137, 000 acres. Tier 1 goal is 44,000 acres from the 107,000 accessible base and Tier 2 goal is 50,000 acres from the 137,000 inaccessible base. From 700,000 acres they got 45 MMCF annual SYL. Tier 1 goal is 5.1 MMCF/year. From the 244,000 acres the combined goal is 17.6 MMCF. That is essentially logging those acres at the SYL on a per acre basis.

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            • NFMA §6(e)(2) requires that harvesting levels consider the limitations imposed by the plan, and §13(a) requires that they explain to the public how it is “consistent with the multiple-use management objectives of the land management plan” to have (severely) declining timber volume in future years.

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