One of the threads of this discussion went off on a topic of how much discretion loggers should have in deciding what trees to cut down. “Tricky Dick” offered that, “The USFS in its office attired lazyness doesn’t want to have to cruise the forest landscape piece by piece and thru honest Forestry discretion , uninhibited by profit motives, mark the bigger trees as ” leave or cut…” Larry replied with regard to marked trees, but what if they are not marked? I think there’s a name for that – “designation by prescription,” or DxP. Here is how the Colville National Forest explains it (2020):
The Colville National Forest in Washington began using Designation by Prescription (DxP) in 2009 in order to become more efficient in timber sale preparation. Marking individual trees with paint in a sale area can be a time-consuming and costly process. DxP saves time preparing a timber sale and money spent on paint by allowing the logger to select which trees to harvest based on a timber stand prescription, which defines the desired condition after harvest.
With DxP, the operator may need to know tree species, how to measure tree diameters, forest health indicators, or how to achieve desired stocking level. This has the potential to initially slow operations. However, the flexibility that DxP provides (the contractor needs only to meet the prescription and that outcome can be accomplished in different ways) can create efficiencies for both the USDA Forest Service and the contractor
Is Tricky right? But wouldn’t “allowing a logger to select which trees to harvest” allow them to do whatever they want within the broad confines of a “desired condition” in the “timber stand prescription?” I have lots of questions about this. How common is this? Is the “timber stand prescription” part of the NEPA disclosure process in a way that all possible effects of the loggers’ decisions are accounted for? If they only have to achieve the desired condition, could they do that in a way that is inconsistent with standards or guidelines in a forest plan? Those aren’t included in the Colville’s “need to know” list above.
Asking for a friend. Thanks.
Here in Pisgah/Nantahala National Forest the units are now clearly marked for boundary and leave trees. Road corridors are also marked with a different color – indicating the limit that can be cut to establish a road. Every unit, every time. There is some variability on the leave trees it seems to me, but overall with the markings you can at least call the sale administrator and have a discussion. They tend to leave skid-road placement up to the logger which is IMHO a much worse practice, and in some cases they even leave road placement up to the logger (usually when new road is built) – which is a horrible practice.
Here are the DxP instructions given to loggers by the BLM for a timber sale in Washington last year.
https://www.blm.gov/sites/default/files/docs/2022-05/orwa-racetrack-exhibit-e.pdf
The Colville’s comments are a general explanation, they are not prescription. DXP gives a specific prescription on which trees to cut, with specifics on species, size, density and other issues that might be important on a particular unit. There is a signed contract that specifies this information, and provides for appropriate penalties for not meeting the prescription or other aspects of the contract.
Of course Norm is spot on with his assessment and explanation of DxP. DxD and DxS are also utilities in the tool box for timber designations; unless you speak the speak, you can only guess at what these letters even mean in the woods.
With the amount of need across (mainly the West) Forests, the shear magnitude of work is overwhelming! Also, paint – make that tracerized marking paint, is expensive. The only issue I ever saw was the burden of selection and accountability to follow a prescription was shifted from pre-sale to the sale administrator; it doesn’t magically go away for the convenience of all these “massive profits” that only exist in never-never land, or the minds of the conspiracy theorists….
This is, in my experience, pretty much on target. A shift in administrative burden in part designed to cope with who can be hired and retained (TSA is a more complex, but also better compensated role than presale) and in part designed to use more digital tools than tracer paint. Could it be done poorly / inconsistently? (yeah, what couldn’t). But Rx’s and contracts should bring forest plan standards and guidelines along into that designation as well as general requirements of the contract (key – contracts are the bottom line with what sale admins work with). Desired condition alone is never the sole content of an Rx or a contract.
I think it is worth noting that a good District, and a good Sale Admin/Forester, can work well with the loggers out there who are intelligent and engaged, not knuckle dragging wrench monkeys driving cats around.
It takes an engaged Sale Admin/Forester to keep an eye on the loggers, and a good logger to do a good job, so they can continue getting jobs. Sadly, with a lot of institutional/local knowledge lost, I think Forests can get themselves into an issue with poor loggers getting in on work, and making messes.
That is all said, because DxP can work well where you can’t envision every single little situation on a landscape and how operations occur. There’s differences between the effort that goes into writing a prescription into a planing doc, marking a prescription on the ground, and then getting it done with logging equipment. Each takes a lot of effort and brains.
USFS timber contracts, including DxP, do have teeth. It is almost never just the logger selecting whatever trees they please to hit a density target.
When I worked for a logger on DxP sales in Northern AZ they hired me as a forester to guide their buncher operators in interpreting the Rx. They felt like they weren’t getting enough from USFS sale admin and it was a risk management thing for them. Aside from jeopardy under the contract, logging is a reputation-based industry. If you’re not making the client happy you’re going to have a harder and harder time getting work.
Other places I’ve seen the sale admin is really engaged and wants to make it work, and the logger gets all the guidance they need directly from the FS. It can definitely go sideways when sale admin is disinterested and the operator is too.
In N-AZ, DxP was better for a lot of reasons. Painted sales were usually marked by inexperienced contract crews or even youth corps. They had no concept of the mechanics of logging and would regularly paint us into a corner with an impossible mark. We’d have to be out with the sale admin nearly every day modifying the mark to make it operable.
Once we moved over to DxP, the sale admin was still there several times a week but instead of moving paint around we were discussing the progress and vision for the unit. I and the district silviculturist were both putting in plots to check our density and spatial pattern targets and really working together to get the right result. And the buncher operators picked it up quick, they were turning out quality work in every unit after 5-10 acres of dialing-it-in with the silv.
And yes, we did make more money on DxP. It wasn’t because we were grubbing for the biggest and best trees. It was because we could work within the unit in the way that was most efficient for our particular machines instead of being stuck with a crummy paint job.
This may all make sense from the standpoint of cost efficiency or the knowledge and competence of the players. What I am wondering about is the motivation of the contractor, and whether this leaves room for bias towards removing the most valuable trees, which are likely to be the largest trees, which are the issue in the Eastside Screens lawsuit.
Unless there is something in the contract (derived from the forest plan) that tells them they can’t. Whatever requirement might be in a forest plan, in Steve’s example, there is no mention of a land management plan or any way of telling if this prescription is consistent with the plan.
I also wonder about the effectiveness of compliance monitoring – is that easy to do after the trees have been cut, and how are the results actually used?
Again, there are specific contract specifications which dictate which trees can be cut, and specific actions if the contract is not followed. The cost of logging equipment is too high for a logger to deliberately cut the wrong trees as they would quickly be out of business. The federal agencies are not the primary source of work for loggers, it is private industry which can fire a logger very easily and word does get around. If you want specifics, you will need to look at actual contracts rather than second guessing what will happen. It is obvious that you do not trust people. If you want real dialog talk with your local forest office with your questions and get to know those people. It is very easy to throw stones from afar, much harder to do the work to understand the process.