A First Look at the MOGgie ANPR – I. Up to Timber and Reforestation

Thanks to a TSW reader for this working link to the MOG ANPR!  Mature and Old Growth, Advanced Notice of Proposed Rulemaking, that is. It has the funniest and possibly least helpful title of any ANPR I’ve seen.. at least what the Federal Register has posted.

Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions

Ok, then.

Climate Resilience is a Thing Worthy of Note

My favorite part is

Uses the Planning Rule’s definitions of ecological integrity and social and economic sustainability to structure the concept of climate resilience. Climate resilience is essential for ecological integrity and social and economic sustainability.

Aside from the future Land Management Agency abstraction Smackdown with BLM on “intactness”, one wonders what it to use a “definition” to “structure” a “concept”.    As everyone knows, I have not been a fan of “ecological integrity” as a concept.  But I definitely like the idea of the essentialness (apparently not a word) of climate resilience.  Underlying these are ideas that “leaving alone is always best” (intactness) versus “to get things people, wildlife and fish like,  management can be necessary.”

Note that these ideas are not at their base scientific at all- they are philosophical differences.  And the importance of Native American tools and uses runs into philosophical problems with the Garden of Eden-y school of intactitude.

And so, what will be the role of HRV or NRV?  Will we be able to give the historic vegetation ecologists a well-deserved break (for whom, as I commented at the time, the 2001 and later rules were a full employment program) from their tedious (to me)  infighting about what used to be, the roles of Native Americans and so on.

I live in hope that the ideas of dynamic systems will root out the old forms of “return to equilibrium” “balance of nature” or a return to the past.. at least for the Forest Service. But maybe that’s too much to expect from this peculiarly named ANPR.

Timber Harvesting

“To put this evolution of National Forest System management into context, currently the Forest Service commercially harvests one tenth of one percent of acres within the National Forest System each year. Harvests designed to improve stand health and resilience by reducing forest density or removing trees damaged by insect or disease make up 86 percent of those acres. The remainder are final or regeneration harvests that are designed to be followed by reforestation.”

This is kind of a duh for most TSW readers.  So I can see the philosophical argument already. “Even though it’s only a little bit, it’s something we can control.” I’ve heard this argument about PM 2.5.. “we can’t control wildfires so we need to ratchet down fossil fuel use.” And of course, the idea that wildfires can’t be managed runs against folks’ lived experience, the Wildfire Commission, various Congressional large chunks of money, and so on.  It seems like no matter what the problem is .. diseases, wildfire, climate change.. the answer is always to reduce uses some key constituencies don’t prefer.

“At the same time, over the past 15 years data shows that disturbance driven primarily by wildfire and insect and disease has adversely impacted more than 25 percent of the 193 million acres across the National Forest System (see Figure 2). This rapidly changing environment is now the primary driver of forest loss and type conversion. Wildfire alone causes approximately 80 percent of reforestation needs on National Forest System lands, and we expect those needs to continue to grow: More than half of the 4 million acres of potential reforestation needs on National Forest System lands stems from wildfires in 2020 and 2021 (see Figure 3).

7 thoughts on “A First Look at the MOGgie ANPR – I. Up to Timber and Reforestation”

  1. Checkerboard RRR/W ownership pattern by land grants was Congressional intent to have private land and state governments and owners construct access by federal permit across the odd numbered sections. Clever Congress avoiding road building costs.
    Twenty and thirty years ago I was marginally involved in a private land owner’s attempt to trade his inholdings for USFS sections. 3 were in Wilderness. Essentially was three miles (2 his and 1 USFS) blocking a trail from a National Park to an interstate hiway crossing. USFS would not trade unless private guy allowed USFS to construct a trail with a right of way across his land outside Wilderness and at lower elevation than the Wilderness sections. Guides with pack strings paying permit fees to USFS having free rein to cross his land in hunting season. As you would guess, that went nowhere. He died in later years, and Ranch was sold. Likely the amenity buyer was romanced by NGOs and Federal tax forgiveness by all the sleight of hand rich urban TNC, RMEF, usual suspects of agreed to “conservation easements” and private land devaluation to gain 50% or more taxpayer financed amenity ranch buying assistance. Wolves and opening parts of the private land to cow elk hunting salves the conscious and gives safe harbor to political figures. Whoopee.

  2. I’d like to see how “overstocked” and “reforestation need” are defined. Both arguably should be based on the natural range of variation. Proper stocking should be defined in a forest plan for management areas and vegetation types. Does “reforestation need” count all areas disturbed for any reason or just those areas that would not regenerate naturally to the proper stocking level? The former is pretty meaningless, and shouldn’t the latter be zero (what regenerates naturally is what would regenerate based NRV, keeping mind that “natural” is not necessarily “historic”).

    • OK, this is a very specific thing- let’s take reforestation need.. how is NRV related, and how would you measure it? How would you determine a “proper” stocking level based on NRV, given that “natural is not necessarily historic”?

      • I wouldn’t. That’s what specialists are for. The foresters/ecologists would use expected climate/weather conditions (obtained from other specialists). They would generally follow the guidance in the Planning Handbook( §23):

        “e. Natural range of variation(NRV). The natural range of variation (NRV) defined in
        FSH 1909.12, Zero Code, Section 05 describes the variation in physical and
        biological conditions exhibited by ecosystems as a consequence of climatic
        fluctuations and disturbance regimes. NRV is a useful tool for understanding past
        ecological processes and the resulting biological diversity that persisted under those

        NRV can also be a fundamental tool in strategic thinking and planning, even if
        restoration to historical conditions is not the management goal or possible. NRV
        evaluation provides the ecological understanding of temporal dynamics of systems
        and its consequences for management understanding of the specific geographic
        location under consideration, its existing ecological conditions, and projections of
        various climate regimes that might characterize the area in the future.”

        • I understand that it says that.. I’d just like to work through that specific example. Since I was once a reforestation person, it’s particularly of interest to me. I’ll start a separate post on that- I think it’s a great topic.


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