| PORTLAND, Ore., July 24, 2024 — A Federal Advisory Committee has completed a comprehensive set of recommendations for amending the Northwest Forest Plan aimed at modernizing forest management practices across the Northwest Forest Plan area. After developing the recommendations over the last 10 months, the Committee voted unanimously to approve and advance the completed recommendations to the Secretary of Agriculture. The recommendations address critical issues such as ensuring tribes are included in land management planning and implementation, conserving mature and old growth forests and the species that rely on them, providing sustainable economic opportunities for rural communities, and supporting fire resiliency for forests and communities. The recommendations come as part of an effort to update the NWFP, originally implemented in 1994, to better align with current environmental, social, and economic challenges. “The recommendations from the Federal Advisory Committee represent a significant milestone in our efforts to update the Northwest Forest Plan,” said Jacque Buchanan, Regional Forester for the Pacific Northwest Region of the Forest Service. “These thoughtful proposals reflect a collaborative approach to addressing the complex challenges facing our forests today, including climate change, wildfire resilience, and the need for sustainable forest management. We are committed to carefully considering these recommendations as we move forward with the plan amendment process.” The committee developed 192 recommendations targeting key areas that update the current NWFP. These areas include Tribal Inclusion and Rights, Economic Opportunities, Fire Resilience, Climate and Ecosystem Integrity, Carbon Sequestration and Storage, Community Protection, and Adaptive Management. The FAC also made a host of recommendations for how to develop Forest Stewardship- across the diverse NWFP landscape. The FAC’s work provides a foundation for addressing these complex issues while honoring the plan’s original goals of ecosystem conservation, endangered species habitat protections, and sustainable timber production. “What the Committee accomplished is historic,” said Northwest Forest Plan Federal Advisory Committee co-chairs Susan Jane Brown and Travis Joseph in a joint statement. “By unanimously approving dozens of meaningful recommendations to modernize the Northwest Forest Plan, this group has demonstrated the power of collaboration, consensus, and working together for a common cause. We all share a deep love and commitment to our national forests and people and communities that steward them.” The 20-person committee is a diverse group from Tribes, local communities, environmental groups, industry, and academia across Northern California, Oregon and Washington. “We tackled some of the most challenging and contentious issues that ignited the Northwest Forest Wars,” Brown and Joseph wrote. “While we recognize our work does not address all the issues and injustices of the Northwest Forest Plan, the Committee’s consensus recommendations represent the most significant progress in the last 30 years to achieve our shared values for responsible forest stewardship on national forests in the Pacific Northwest.” The Forest Service will carefully review the FAC’s recommendations as the agency works toward amending the Northwest Forest Plan. Public engagement opportunities will be announced in the coming months as the plan amendment process moves forward. The Federal Advisory Committee’s recommendations can be viewed here: · NWFP FAC Recommendations direct link: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd1188978.pdf The Northwest Forest Plan is a comprehensive plan for administering parts of federally managed lands in Oregon, Washington and California. The plan was designed to protect old-growth forests and critical habitat for the northern spotted owl, while also providing for forest products, water quality, recreation and other uses. For more information visit: · Northwest Forest Plan Federal Advisory Committee: https://www.fs.usda.gov/goto/r6/nwfpfac · Northwest Forest Plan: https://www.fs.usda.gov/r6/reo/ · The Pacific Northwest Region: https://www.fs.usda.gov/r6 For more news & information about National Forests in the Pacific Northwest, visit our news page at https://www.fs.usda.gov/news/r6/news-events or our home page, at https://www.fs.usda.gov/r6. For more information about the USDA Forest Service visit https://www.fs.usda.gov. |
Going back to the Travis Joseph podcast Steve posted yesterday, I have some questions.
I thought Nick Smith did a great job interviewing Travis Joseph, one of the co-chairs of the FAC committee on amending the NWFP. Susan Jane Brown, a frequent commenter was the other co-chair. I’m hoping she will weigh in with her views, and especially if I got something wrong, or she sees it differently from Travis.
There apparently was some confusion about exactly what the FAC was supposed to do, but from the podcast, it was to provide the FS with ideas that could be used in developing alternatives. The idea apparently was that there would be an amendment and not a revision; and that some parts of the NWFP were off the table, like survey and manage. I get it, the NWFP is very important. But this has a whiff of “revisions for thee but not for me.” It also sounded as if the Admin or the FS was in a bit of a hurry to do this. Yes, I know, “a hurry” and “anything to do with the 2012 Rule” seem like something of an oxymoron.
I am the least political person imaginable, so it seems to me that A. if the Admin wants to be done by January, is there time to develop alternatives, have a 60 day comment period, and reflect the comments received?. B. If they win, they will have all the time in the world to do a bang-up revision job. So why choose this path? It may frustrate the members of the committee and no doubt FS folks as well. From what I heard, the FAC committee all worked very hard and put much of themselves into it. So kudos to them!
Travis talks about Indigenous Knowledge and involvement of Tribes. Seems like that could be more broadly applied than in just the NWFP and NOGA. Seems like it may just need a general FS policy statement of some kind? Which I think already exists. It would be great to understand the nuances of whether there are differences among NWFP, NOGA and FS policy in general on IK and Tribal relationships. Maybe someone can speak to that?
I have to say that with that, these approaches sound a bit like what Bob Zybach was telling us lo these many years ago. It sounds like the FAC committee did important work, and gives me hope that the next generation of PNW-ites is going forward with collaborative gusto and has learned from the past. Yay!
I see zero possibility a defensible revised amendment will be in place by January. I have been told that the USFS is going to attempt to get around the diversity requirements of the 2012 rule and are suggesting they do not really apply to what they are doing here and are not interested in developing species specific plan components. For those NFMA policy wonks out there, can you tell me how a “targeted,” “high level, and “narrow” amendment affects the diversity requirements in the 2012 rule? If a forest plan is amended in a manner that changes how a species is affected by previous plans or amendments (e.g., how NSO is managed in dry forest LSRs), does that trigger the need to ensure viability by providing the necessary ecological conditions? What if a listed species was not listed at the time of the original plan or past plan amendment (e.g., Canada lynx in the NWFP), how does that affect the scope of the diversity requirements? Do they still need to ensure the necessary conditions are provided, when prior planning efforts did not consider such things?
A. I think it would be quite interesting if challenging the amendment led to court review of the diversity requirements in the 2012 rule and how those relate to NFMA and its legislative history, or don’t. then the other question is “does an amendment for one thing have to address other things that have come up?”. Which would be of interest to me because I would like to see fire plan amendments without them taking on new species. My understanding (and this is Jon territory) is that listed species require their own plan amendments, like the Southern Rockies Lynx Amendment.
Perhaps someone else can explain how best to drill into NFMA plan stratigraphy.
It seems like a house of cards if an amendment can be used to change a forest plan in a manner that affects how a species is managed across a plan area, but the amendment doesn’t have to address the diversity requirements. If this is the case, an amendment can be used to get out of having to ensure viability or contribution to recovery. Sure, an amendment requires section 7 ESA consultation for listed species, but NFMA is stronger than the ESA when it comes to listed species because NFMA requires viability and contribution to recovery be provided at the plan level, the ESA does not.
This discussion touches on points I’ve been wondering about with regard to a NWFP amendment (which I have not looked at closely). A revision is required by NFMA whenever “conditions in a unit have significantly changed.” Is the Forest Service going to say this is not the case here?
Sharon: There is no requirement for species to have their own amendments. This has been done across species’ ranges for efficiency reasons, and it minimizes the risk of conflicting positions in different units.
Viability must be addressed under the Planning Rule if it is “directly related to the plan direction being added, modified, or removed by the amendment.” Is the Forest Service going to say this is not the case? They are going to have to identify and address species of conservation concern “if the proposed amendment would substantially lessen protection for a specific species.” I would like to think that wanting to avoid this effectively sets a floor on the kinds of changes that will be made so that existing protections are not substantially lessened.
All listed species will require ESA consultation on an amendment. The Forest Service is reluctant to admit that it must also meet viability requirements for listed species, which a court told them they had to do under the old planning regulations. I don’t think they can count on the new regulatory language that limits viability to SCC changing a court’s NFMA diversity holding.
A lot of this is pretty uncharted territory and testing it in a hurry is risky.
Amendments to forest plans under the 2012 rule (as amended in 2016 to address amendments specifically) still must provide for the diversity of plant and animal communities. The issue is whether all of the plan components – including those not affected by the amendment plus the new plan components – are sufficient to provide for that diversity (coarse filter) or whether species-specific plan components (fine filter) are necessary.
While the FAC’s recommendations do allow for more proactive stewardship in some places, it also conserves mature and old growth forest that is currently subject to timber harvest.
Thus, the question is whether species-specific fine filter components are still necessary to provide for diversity of non-ESA listed species given the coarse filter approach. The FAC didn’t address this issue (outside our wheelhouse), but the Forest Service will need to address it in the amendment.
Given that more older forest would be conserved, and existing plan components related to snags and down wood would not change, the question really is, what’s missing (fine filters) and for whom (which species)?
NSO are supported by well known and clearly defined concentrations of dense forest habitat at the home range and territory scales, even in dry forest system. These are the necessary conditions on which the species depends for survival, reproduction, and occupancy. My read of the FAC recommendations allows for dense old forest habitat that supports NSO to be converted to open old forest that do not support NSO across entire frequent fire landscapes and there are no recommended plan components to ensure habitat is provided in a spatial configuration that would support any NSO in frequent fire landscapes. Open forests with downed wood and snags are not what NSOs requires. Frequent fire landscapes include large proportions of entire forests in the plan area, all of which must have populations for recovery.
The FAC recommendations utterly fail to provide for the well known necessary conditions on which the species depends in dry forests. LSRs were established to support metapopulations of NSO. Were necessary conditions on which NSO depend or the foundational purpose of the LSRs ever discussed in the FAC?
Yes, managing for NSO in dry forests is really hard, especially with climate change, but that does not mean a plan for how to do it is not required. None of the threats to NSO can be dealt with independently. There must be an integrated strategy to address climate, fire, forest health, and barred owls.
The FAC’s recommendations for dry forests are consistent with FWS’s 2011 recovery plan for northern spotted owls in those forest types, which specifically encourages proactive restoration in dry forests with owls.
I could not disagree more. The recovery plan recommends proactive restoration, while also maintaining appropriate amounts of appropriately configured habitat. It is concerning this essential and overarching piece of Recovery Action 10 was not raised as part of the development of plan components.
You’ve entered the amendment/revision house of mystery. I agree that the diversity requirement of NFMA (and viability requirement of the Planning Rule) applies to the “plan as amended.” It is a substantive bar that must be cleared at the level of the entire plan.
However, the regulatory requirement for a fine filter for SCC applies to an amendment based on the degree of change from the existing plan. So there may be a need to identify SCC based on the changes in the plan, but to evaluate the effects on SCC based on the plan as amended.
But what are the effects to be considered via the NEPA process? Those should be the effects of the changes in the plan (the action), not of the plan as amended. That is the difference between amendments and revisions (where the entire plan is viewed as being restarted). However, neither the Forest Service nor the courts seem to be consistent (or even want to talk about it).
And of course effects to be considered under ESA would be similar to NFMA diversity – the effects of the plan as amended on the jeopardy/critical habitat standards. If a change in the plan is enough to trigger the requirement to reinitiate consultation, that consultation would be on the effects of the entire plan.