I know, I know. A person could get confused because “climate resilience” sounds like its about adaptation, and the MOG discussion seems to be mostly about carbon, or at least the arguments for not cutting trees.. which we have been listening to for 40 years or thereabouts.. are now centered about carbon. And of course, every little thing the FS does on the landscape needs to have some kind of climate considerations, and has for at least 15 years or so. So the ANPR seems to be asking for “suggestions about anything that the FS does.” I wonder how many other agencies have had a rule making that opens up “everything it does.”
In fact, the FS has what I consider to be an excellent document about climate adaptation. And many of the people on these calls talk about MOG. But I’ve been told by internal and external People Who Should Know that it’s really about resilience and not about MOG. Meanwhile ENGOs are working on a MOG policy solution with CEQ, the FS and others.
I’m a general fan of the FS, as you all know, but I would point out a couple of my concerns. They used an abstraction in the webinar- “active management” -regularly without defining it. Fire suppression is active management, prescribed fire, planting trees, timber harvest and so on are all active. Based on the views of the form letters I read in response to the ANPR and the views of people on our webinars, I’d say that most people with concerns did not want commercial timber harvest, although they said “logging”, which is not exactly well defined at the project level. Tree cutting, or tree cutting and removal using heavy equipment, or tree cutting and pile burning, or just commercial timber harvest but maybe not commercial firewood.. So that’s one thing.
My other quibble was with analyzing comments using AI (in this case, natural language processing). I recently had a bad experience with AI so perhaps am a bit grumpy about it. You’ll remember I FOIAd both CEQ and USDA for documents with “fire retardant” in them. USDA gave me the documents they had, as far as I know, including messages from key people at CEQ. CEQ did not give me those messages, but did give me a DOE annual report and a mass of unrelated material. Apparently, that was due to their AI, or perhaps someone did not type in exactly the right search term. It seems to me that using AI is not necessarily increasing transparency nor trust. I’d argue that to build citizen confidence, each AI application during a test period should have the standard human approach run concurrently and both sets of results published and open for comment (aka Lessons Learned). I have noticed that contractors and I didn’t always pick the same way of analyzing comments either, so perhaps there’s not one “human” way. But the results would then be compared in one document that the public could view. I would see this as needed only for rule making; in my experience, projects are not as complex for content analysis. Also the decision makers for projects and even plans tend to be close enough to the disagreements that they have a base understanding of them. I am not so sure that’s true of the politicals involved in rule-making.. if they only listen to their friends, then the public comment summaries are key element of their understanding of opposing views.
I’d bet that “double coverage” would be expected and required, say, in fire suppression applications. To increase trust, accountability is also important. AI, without careful management, could also be an escape valve for accountability, as in “Sorry, folks, the AI did it.” Similar to “it’s not our fault, it’s climate change.”
Anyway, here’s a link to the presentation. I’m curious what strikes you about it.
so is there a standard that measures fire Resilience in different veg types. There are some landscapes in mixed conifer types that have burned five or more times and are still considered a high hazard with tons of dead and down fuel and ten foot high brush types covering the landscape.
Well, “wildfire resilience” is an abstraction. So it depends on what exactly you want to be resilient (tree cover? foraging habitat for species x?) and at what scale and time period. I think it’s one of those words that’s used generically, but is hard (and contested) to measure.
We recently saw s prescribed burn that had stated objective of cleaning up the limbs and ground litter. A wind drove the burn out of Rx and it burned hot killing the overstory. Do agencies do a post burn report and report what will be done to remedy?
That’s a good question. I don’t know to what extent lessons learned for prescribed fire are formalized and where they might be posted. Nor if different agencies, cooperators do it differently.
Dead (and dying) forests do not make good “Connectivity Corridors”. Preserving such forests usually results in high-intensity wildfires. With so many humans running around, we can be assured of consistent ignitions, year in and year out, over the next 100 years.
If such areas are deemed to be truly all that important, the corridors should be managed to be resilient, instead of off limits. Of course, such management (including significant non-commercial work) never seems to get funded. Sometimes that kind of work is ‘bundled’ within timber sales, and paid for with logs.
Finally, the biggest dose of reality is that Congress cannot be depended on to do much of anything, these days. Republicans will label all of this as “woke”, while reminiscing about the good old days of logging big trees. Some Democrats would see it as “a giveaway to the timber industry”, if timber sales are incorporated into the plans.
The 5,000 pound gorilla in the room is the fact that with the current let burn/managed fire concepts and associated suppression tactics we keep making more of these dead tree landscapes and are doing nothing about the risk they create. They are dangerous for firefighters, rural communities, and adjacent green stands.
We are on the path of converting our forest to climax brush and hardwoods at an exponentially accelerated rate!