PNW Forest Plan Revision Update and LSR Trends

The USFS press release today: “The initial comment period for the USDA Forest Service’s Northwest Forest Plan concluded Feb. 2. The Forest Service had been accepting comments on a Notice of Intent that the Agency will prepare an Environmental Impact Statement to evaluate the effects of proposed amendments to the Northwest Forest Plan.” Info here.

There’s an interesting Powerpoint presentation here, “Information Winter Webinar, January 2024.” Lots of stats and trends. This slide, for example, on LSR trends. Steady until recent wildfires.

This is compelling evidence that simply setting aside older forests with little or no active management is a losing proposition.


25 thoughts on “PNW Forest Plan Revision Update and LSR Trends”

  1. I remember being on a field trip on the Wenatchee about 20 years ago, and being in a stand where folks said “the big trees are going to burn up and that won’t be good for owl habitat.” Hopefully the new planning process will do better at incorporating the experience and knowledge of local folks throughout the widely differing places in the NWFP territory.

  2. By the way…. from the Society of American Foresters recently….

    SAF Addresses Mature and Old Growth Initiative in Recent Public Comment

    The Society of American Foresters recently commented on the USDA Forest Service’s notice of intent (NOI) addressing a proposed amendment to all land management plans for units of the National Forest System (NFS). This amendment aims to provide “consistent direction to conserve and steward existing and recruit future old-growth forest conditions and to monitor their condition across planning areas of the National Forest System.”

    SAF emphasized two critical points to the Forest Service: (1) science-based forest management is an essential tool for promoting the long-term conservation and sustainability of forested ecosystems, including old-growth forests; and (2) changes to NFS plans must be made through local processes and with input from local expertise to reflect the large variation in regional forest types, conditions, threats, and management needs.

    As the Agency’s initial threat analysis explains, “wildfire, exacerbated by climate change and fire exclusion, is the leading threat to mature and old-growth forests,

    followed by insects and disease.” It is critical that efforts to conserve mature and old-growth forests be compatible with the USDA Forest Service’s Wildfire Crisis Strategy. The recommendations produced by the Wildland Fire Mitigation and Management Commission offer a comprehensive, holistic guide to wildfire management that should be incorporated into future action. In order to address these threats while continuing to provide the historic suite of benefits provided by forests, we also need a stronger workforce to implement these strategies at scale.

    SAF will leverage this comment to share more broadly with policymakers and the public about the importance of forests, forest management, and forestry professionals in fostering the future health and sustainability of our nation. We encourage you to share the comment within your networks and use it in your own outreach efforts.  

  3. “… compelling evidence that simply setting aside older forests with little or no active management is a losing proposition”
    So, NSO habitat is down 6+% in 30 years. Works out to 0.2%/year. I can’t agree that this is “compelling evidence”, when the loss was unduly affected by one very bad year after 25 years of slow, steady improvement. Besides, the habitat is not lost but ALTERED, typical of the way landscapes change over time – diminished for NSO, but improved of numerous other OG associated wildlife. Further, I suspect that much of the NSO habitat is vacant due to their population losses (to barred owl, mainly), thus, even with losses the habitat still adequately supports existing NSOs.
    And what about Wilderness? Due to lack of management, I guess that whole enchilada is a “losing proposition”?

    • Jim, I’m not sure an area that’s burned over (depending on severity) would be “improved from numerous other OG associated wildlife.”

    • Not just one, but four bad wildfire years since 2017, and likely more to come. The trendline for LSRs is not promising.

      Some scientists promote establishing “Strategic Forest Reserves” to preserve older forests, for a variety of reasons, that are “given the same level of protection from logging, grazing and mining as designated wilderness areas receive.” I suggest that unmanaged stands are more likely to burn at high severity in future years than stands where careful active management is employed.

      Salem Statesman Journal: “All totaled, the fires burned 360,000 acres (over 560 square miles) of suitable nesting and roosting spotted owl habitat in Oregon. Of that, about 194,000 acres (over 300 square miles) are no longer considered viable for the birds, according to U.S. Forest Service data.”

  4. The original post says: “This is compelling evidence that simply setting aside older forests with little or no active management is a losing proposition.”

    Evidence that owl habitat may be declining due to wildfires is NOT evidence that owl habitat would be better off with more logging. Owl habitat is degraded by logging, no matter how well-intentioned it may be, and there is a low probability that fuel treatments will interact with wildfire, so most forests logged for fuel reduction will experience habitat declines without any offsetting benefits with respect to wildfire effects.

    Lehmkuhl et al. (2015) found –

    3. Tradeoffs between fire resistance and NSO habitat quality are real. Our results demonstrate that balancing the goals of increasing fire resilience while maintaining habitat function, especially nesting and roosting, for the NSO in the same individual stand is a difficult, if not an impossible, task. Even lighter thinning treatments typically reduce canopy cover below 40 percent. The reality is that nesting and roosting NSO habitat is by definition very susceptible to high-severity fire; owl habitat value and fire risk are in direct conflict on any given acre. …

    Lehmkuhl, John; Gaines, William; Peterson, Dave W.; Bailey, John; Youngblood, Andrew, tech. eds. 2015. Silviculture and monitoring guidelines for integrating restoration of dry mixed-conifer forest and spotted owl habitat management in the eastern Cascade Range. Gen. Tech. Rep. PNW-GTR-915. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 158 p.

    Odeio et al. (2014) found:

    Our calculations of thinning effects included rates of forest regrowth along with high-severity fire. The calculations illustrate how the requirement that the long-term benefits of thinning clearly outweigh adverse impacts (USFWS 2011) is not attainable as long as treatments have adverse impacts on spotted owl habitat. This is because the amount of dense, late-successional forest that might be prevented from burning severely would be a fraction of the area that would be thinned.

    This would not be a concern if thinning effects were neutral, but the commercial thinning prescriptions being implemented call for forests with basal area reduced by nearly half to 13.5-27.5 m2/ha, which is mostly well below the minimum level known to function as nesting and roosting habitat (ca. 23 m2/ha) (Buchanan et al. 1995, 1998). … Even an immediate doubling of fire rates due to climate change or other factors would result in far less habitat affected by high-severity fire than thinning. In addition, much of the high-severity fire might occur regardless of thinning, especially if the efficacy of thinning in reducing high-severity fire is reduced as fire becomes more controlled by climate and weather (Cruz and Alexander 2010). Clearly, the strategy of trying to maintain more dense, late-successional forest habitat by reducing fire does not work if the method for reducing fire adversely affects far more of this forest habitat than would high-severity fire, and the high-severity fire might occur anyway because it is largely controlled by climate and weather.

    Dennis C. Odion, Chad T. Hanson, Dominick. A. DellaSala, William L. Baker, and Monica L. Bond. 2014. Effects of Fire and Commercial Thinning on Future Habitat of the Northern Spotted Owl. The Open Ecology Journal, 2014, 7, 37-51 37.

    • This post cites a 2021 paper “Forest restoration limits megafires and supports species conservation under climate change,” Gavin M Jones et al., Frontiers in Ecology and Environment, December 2021.

      Study: Forest Restoration Can Benefit Spotted Owls

      “Forest restoration often involves some removal of live trees—mostly small and medium-sized trees in the forest understory that have grown in because of fire exclusion. These smaller trees increase fire risk to owl habitat, and removal of these smaller trees will protect the rare, larger trees that owls use for nesting,” lead author Gavin Jones, Ph.D., a research ecologist with the USDA Forest Service (USFS) Rocky Mountain Research Station, tells Treehugger.”

      “We found the direct, and potential negative effects of forest restoration to owl habitat (that is, removal of trees in owl habitat) were small relative to the positive effects that restoration had on reducing fire risk to owls,” Jones says. “So even though in some cases we found that restoration could have negative short-term impacts to owls, it reduced the long-term impacts of severe fire. These long-term benefits led to better outcomes for owls.”

    • “Owl habitat is degraded by logging, no matter how well-intentioned it may be, and there is a low probability that fuel treatments will interact with wildfire, so most forests logged for fuel reduction will experience habitat declines without any offsetting benefits with respect to wildfire effects.”

      Saying it multiple times does not make it true, especially with large fires burning HUGE areas. I wonder what a statistician would do with the probabilities of a treated area burning before the treatment becomes a moot point. Personally, I think it is highly likely that a California fuels treatment will experience fire in the next 20 years.

      Remember, commercial thinning projects in the Sierra Nevada National Forests have MULTIPLE goals and benefits. Playing word games with “logging” and “habitat” does not help, especially in the courts. Pretending that “logging” in “habitat” involves taking all the big trees is really a flat-out lie, in every way possible. All projects will still follow the current diameter limits, while strictly protecting core nesting habitats. I really don’t put much stock in “roosting habitat”, as there are still ample snags throughout those National Forests. Currently, there are plenty of “foraging habitats”, which need few protections.

      Yes, ‘resilience’ is a desired thing, and we do not want to get there through preservationism (doing nothing).

  5. It is my understanding the LSR boundaries are not up for revision, but the standards and guidelines that apply to the LSRs are going to be revised.

  6. I have heard a lot of opposition to the reserve system, but I think there’s a lot of nuance to such a discussion that gets lost if we are limited to sound bites. Regardless, with the barred owl situation, NSO will require a “reserve-lite” system in order to focus barred owl management efforts. Such areas will also require routine active management to maintain reduced fire risk within the reservice-lite. Including treatment objectives for such a reserve system in the plan will be necessary to set expectations. The current plan clearly allows for treatments in LSRs to reduce fire risk, but the lack of much of a commercial harvest component and all the hurdles to plan such projects often results in the exemption not being used.

  7. What’s interesting to me about this discussion is that Oregon literature in general is different from California literature. Science is science, at least that’s what we are told, so what factors lend themselves to different answers about treatments?
    (1) California owl behaves differently/has different requirements than Oregon owl (which would raise the question of SW Or vs. western Or vs. Central Or and Wa..
    (2) Folks in Or and CA are proposing different kinds of treatments
    (3) Inclinations of scientists are different in Or and Wa.

    It might be an interesting Ph.d. dissertation.

    • Which is why no agreement is in sight when we talk about thinning vs spotted owls in the abstract.

      What kind of thinning in what kind of habitat, the status of the owls there, and how to factor in the probability of any benefits to owls since fire occurrence is not guaranteed within the life of the fuel treatment and the effectiveness depends on the conditions when a fire occurs.

      That is why thinning must be tightly regulated or excluded from areas where owl persistence is important. (A contrary decision would have to consider the effects of the worst-case combination of these uncertain factors.) Project-specific plan amendments could occur when the case can be made that it is important for a specific site. Not a Ph.d. dissertation but a project-level analysis.

        • Yes, there has been a lot of work completed in LSRs for risk reduction – sudden oak death, fuels/fire, etc. Whether that has been enough or in the right places deserves a look. The last sentence of the post seems to be premature and perhaps misinformed?: This is compelling evidence that simply setting aside older forests with little or no active management is a losing proposition.

          • ” The last sentence of the post seems to be premature and perhaps misinformed?: This is compelling evidence that simply setting aside older forests with little or no active management is a losing proposition.”

            I may be misinformed — it wouldn’t be the first time . But does anyone here on TSW see the decline in LSR acres since 2017 leveling off? Or are we likely to continue to lose LSR acres?

        • Adding on to this, the NWFP itself has an exemption for wildfire risk reduction in LSRs (C-13). To meet the exemption, it must be demonstrated that the risk reduction activity is necessary to reduce the risk, it will result in a greater assurance of maintaining habitat over the long-term, and it will not compromised the objective of the LSR. With this, I think strategic fuel treatments in any LSR, commensurate with the local fire regime and forest type, could be justified with this exemption.

          I do think the NSO recovery plan is not as clear as it could be on thinning in NSO habitat for risk reduction. RA10 can be interpreted anyway one wants, which greatly reduces its usefulness. Hopefully, FWS can clarify how to interpret this aspect of the recovery plan as part of NWFP revision process.

        • “Endorsed” is a vast overstatement. The truth is much more nuanced. NSO populations are declining quickly and at an accelerating pace. To have a chance against the barred owl, NSO needs as much suitable habitat available immediately and in the near-term to avoid extinction. The species might not have 50+ years otherwise, which is when most purported “long-term benefits” of thinning in current habitat are meant to materialize.

          Direct quotes from the 2011 NSO Recovery Plan:

          “more research should be conducted on the relative compatibility or conflict between thinning a forest to reduce fire risk, its impact on long-term spotted owl habitat quality, and the action’s mitigation of climate change impacts.”

          “heavy commercial thinning operations have typically converted spotted owl habitat to non-habitat.”

          “Results from these studies suggest that active management projects should explicitly evaluate the short-term impacts to spotted owls and their prey while considering the long-term ecological benefits for such projects”

          “Restoration activities conducted near spotted owl sites should first focus on areas of younger forest less likely to be used by spotted owls and less likely to develop late-successional characteristics without vegetation management.”

          “Silvicultural treatments are generally not needed to maintain existing old-growth forests on moist sites . . . Potential management in older forests, either for climate-related management or spotted owl recovery, must explicitly weigh the pros and cons of such activities.”

          “there are younger or less diverse moist forest areas outside of old-growth stands where active management could promote ecological goals, including spotted owl recovery.”

          “There are areas in moist LSRs where stands average 50 years or older that are uniform and not likely to achieve desired complexity or resilience on their own, yet may develop structural complexity more quickly with treatment”

          “LSR thinning in plantations older than 80 years of age should occur in cases where long-term beneficial effects to spotted owls will be realized from enhancing within-stand structural diversity. The treatment should emphasize the retention of the oldest and largest trees in the stands . . . Cases where facilitating a thinning operation necessitates felling existing remnant trees over 120 years old should be rare.”

          “Emphasize vegetation management treatments outside of spotted owl core areas or high value habitat where consistent with overall landscape project goals.”

          “The Service recommends conserving occupied spotted owl sites throughout the range”

          “this Revised Recovery Plan recommends two basic strategies to
          address these threats: (1) conserve more occupied habitat and unoccupied
          high-value habitat; and (2) encourage and initiate active management actions
          that restore, enhance, and promote development of high value habitat,
          consistent with broader ecological restoration goals.”

          • I have to think that there could be some sort of ‘unhappy medium’ being possible. In forests which have value to the owls, the commercial part of “commercial thinning” should be a side-effect, rather than a goal. We should not be deciding whether a tree is 160 years old, or if it is merely 125 years old (and can be cut). Diameter limits, while flawed as a forest management tool, is the best way to thin in those owl zones (occupied or not). I could see where trees between 12.0 inches dbh and 15.9 inches dbh could represent the ‘commercial’ part of a thinning unit, where owls frequent.

      • The “life of the fuel treatment” is up for debate. If you are taking out merchantable trees, the effective fuels reduction is much longer lasting. It is not only about fire resilience. It is also about drought resilience and bark beetle resilience. It is also about silviculture and growing stands of healthy trees. Finally, it is more about multiple benefits of thinning, versus the viability of owls and their habitats.

        Finally, are people considering to set aside snag patches, solely for “roosting habitat”? That seems unnecessary, to me. Do birds REALLY need snags to roost in, or do green trees also serve that ‘function’? It seems more like ‘moving the goal posts’ again, to me.

        • The life of a fuel treatment is site-specific. Commercial can result in fuel treatments that are effective for a shorter period than non-commercial. If there is a shrub understory, opening the canopy too much can release the shrubs and the effectiveness may be very short-lived. All treatments require maintenance. I think one issue is the probability of maintenance is not part of the calculus when planning. Sure, immediately following treatment things might be better. However, I have seen plenty of fuel treatments that reduced canopy to 30% and then be left for 25 years to become 35% canopy with shrubs 15 feet tall. In such a case, maybe it would have been better to not have reduced canopy to that level as fire risk would have actually been lower at the present date.

          • I agree about “site-specific”. In some areas, there are few shrubs and almost all grass (grazed or not); in other areas if the stand is not thinned it may become susceptible to bark beetles and then large dead trees are not good fuels. Then in different areas, thinning does or doesn’t help with bark beetles. I’d think if shrubs would come in and be a future fire hazard, you’d either thin more lightly, like you said, or be sure to prioritize that stand for prescribed fire.

  8. Thank you to one of the anonymi for pointing out this current requirement of the NWFP for the drier “provinces”:

    “While risk-reduction efforts should generally be focused on young stands, activities in older stands may be appropriate if: (1) the proposed management activities will clearly result in greater assurance of long-term maintenance of habitat, (2) the activities are clearly needed to reduce risks, and (3) the activities will not prevent the Late-Successional Reserves from playing an effective role in the objectives for which they were established. Such activities in older stands may also be undertaken in Late-Successional Reserves in other provinces if levels of fire risk are particularly high.”

    This is all that I was looking for, and when they examine the “need for change” before amending the NWFP this should NOT be. It properly puts the burden on the agencies (including the FWS) to “clearly” scientifically demonstrate the need and benefit to the species of thinning in specific circumstances. It also appropriately establishes older stands as a lower priority than young stands.

    I also agree with the comment about the ambiguity of the spotted owl recovery plan. If the FWS has something in mind different than what the NWFP already says, I think that would be big news. I don’t see them being able to shift more of the risk to the species.

    (There is some ambiguity in the last sentence of this NWFP language that could be clarified to make it clear that such activities in the “other provinces” would have to meet the same requirements, which I assume was the intent.)

  9. FYI, the new Northwest Forest Plan Amendment Newsletter.

    “The inaugural Northwest Forest Plan Amendment Newsletter is here! It provides current information on the amendment process and how you can get involved. Highlights in this issue include the upcoming Federal Advisory Committee meeting, Tribal input in the amendment efforts, and ways Endangered Species Act (ESA) consultation plays a significant role in the process. We welcome your participation and input.”

  10. I am a little surprised that there were no comments on the content of the table that Steve shared above (Long Term Trends in LSRs). It seems to me from a quick look to be incomplete or misleading, perhaps to support the current NWFP revision or “modification” process. By my estimates from the “NWFP Wildfires” bars, since 2017 there has been cumulatively about 6.5 million acres of wildfire, of course some portion may be overlapping but I think not much during that time period. (Is this correct? Seems high – in 2020 alone about 2.7 million acres burned according to the table bar chart?). Additionally, as pointed out, some portion of this “wildfire” area may still be providing suitable NSO habitat depending on the fire severity.

    This 6.5 million acres of wildfire appears to have occurred across the entire 24.4 million acres covered under the NWFP, not just in LSRs – the table appears to be mixing LSR “NSO forest” with overall “NWFP Wildfire” acreage. The table shows about 3.5 million acres of “NSO forest” in LSRs, diminished rather minimally by these fires (another graphic shows 9 million acres of “NSO forest” within NWFP). The misleading part, I think, is that they do not show the percentage of NWFP wildfire that occurred in other NWFP allocations for context. LSRs are available for active management, primarily thinning from below in younger stands, and that may be where much if not most of the forest management occurs on some forests. This is partly because there are 7.4 million acres of LSR compared to about 4.0 million acres of matrix where timber management and production is the emphasis. This was a NWFP recognition that there are plenty of old FS clearcuts/plantations that are located in LSR that could benefit from some judicious thinning to increase growth to late-successional conditions more quickly (of course still over many many decades) and to add some spatial and species heterogeneity in these youngish plantations.

    Anyway, I would have liked to see a graph that showed wildfire acreage in other allocations for context. If the 6.5 million acres is correct, my guess that perhaps a higher percentage may have occurred in other forest in non-LSR allocations outside “NSO forest”.


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