First, I’d like to lay out a couple of organizational thoughts.. ones that haven’t changed over time. I would guess that these are things that FS leadership must be mulling over. Both things are true:
Decentralized decision making is a strength of the FS AND the public can get confused when neighboring forests and regions have different ways of interpreting regulations and practices.
The question is always, and has always been, “what should be standardized, and what left to local choices, and what criteria should we use to determine which is which?”
Somewhere, in some document or someone’s head, shouldn’t there be some thought given to this? With input from the public?
If we go a layer (or two) up from that, why shouldn’t the BLM and the FS try to harmonize their NEPA approaches, public outreach, and so on FOR THE GOOD OF THE PUBLIC AND THE TAXPAYER? I’m also thinking recreation maps. They don’t have to be combined into one department to do things the same way.. think NIFC. It just seems like effective public administration, and aren’t we all in favor of that?
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Anyway, here’s an illustration of diversity of approaches. Certainly few people would compare the PSICC and the Mendocino. Earlier this week, I posted about the Salida Ranger District and its scoping-like effort on the Bald Mountain project. It strikes me that, at least for vegetation projects, it’s fairly simple to have an outline of what is proposed, at some level of detail, and ask for comment. The rest is “how to”. The simplest is to scope and post info on the project website. Maybe even simpler to have a forest project dashboard with links to the project websites (SOPA like, but perhaps updated in real time). I just don’t think it’s good for the public, nor public trust, nor the agency itself to have apparently random approaches across districts and forests. For example, on the Mendocino, they had to involve the public affairs office to answer my questions- which would have been posted on the web in a scoping document! This is not a good use of the public affairs officer’s time, the project folks’ time, my time, or anyone else’s who wants to know about the project.
Here’s an example of the Parramore and Elder Creek Projects, which were brought to my attention by Denise Boggs. I wrote to the Forest and received a quick reply, so shout-out to them for that! My questions are in bold, and the answers in italics.
For the Parramore Project, a A USDA spokesperson said:
Where is it located? Can you provide a map?
The Parramore Project is located near the Penny Pines campground, about 10 miles north of Upper Lake in Lake County. The attached map shows the project broken out into North and South areas.
What treatments are proposed?
Targeted vegetation treatments- including thinning, prescribed fire, and removal of accumulated dead and down fuels. The intent of these treatments is to restore appropriate stand conditions, improve growing conditions, reduce fuel loads, improve habitat for biological diversity and foster a more resilient forest landscape.
How large is the analysis area?
The total project area is approximately 2155 acres.
Will scoping be conducted. if so, when do you estimate that will happen?
No, scoping will not be conducted. Under the updated 2025 regulatory framework (7 CFR 1b), this project is being developed under a Categorical Exclusion (CE) rather than an Environmental Assessment. Public scoping is optional for CE-level actions and was not selected for this project. We are engaging with Tribes, partners and FireScape Mendocino. If through the development of the project it is determined there is an extraordinary circumstance, then the project may be moved to an Environmental Assessment.
Project milestones with expected dates of completion are posted online on the Parramore project website. However these timelines are estimated and subject to change. Regarding the Parramore project, a decision is postponed and will not likely happen in February. We do not have an updated timeline yet, but as soon as we do, it will be reflected on the project website.
Did you send out an announcement about the project via the “sign up for proposed project updates” button on your project website?
No, the sign-up list is a new tool that we are planning to use to distribute quarterly updates.
We would welcome those who are interested in our projects to subscribe.
Will the decision document be posted on the website?
Yes, the NEPA finding will be posted on the project website when completed.
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For the Elder Creek Project:
Where is it located? Can you provide a map?
The Elder Creek project is located north of Whitlock Campground and approximately 12 miles northwest of Paskenta in Tehama County, California. A map is attached.
What treatments are proposed?
The project proposes a combination of fuels reduction, green tree thinning, and reforestation activities. The purpose of these activities would be to restore forest structure and function while reducing impacts and losses due to uncontrolled wildfire.
How large is the analysis area?
The total project area is approximately 1,192 acres. The fuels reduction and selective green-tree thinning would be carried out on approximately 935 acres. Reforestation activities would be implemented on about 257 acres. These activities would occur in high severity burn areas where natural seed banks are inadequate.
Will scoping be conducted. if so, when do you estimate that will happen?
No, scoping will not be conducted. Under the updated 2025 regulatory framework (7 CFR 1b), this project is being developed under a Categorical Exclusion (CE) rather than an Environmental Assessment. Public scoping is optional for CE-level actions and was not selected for this project. We are engaging with Tribes, partners and FireScape Mendocino. If through the development of the project it is determined there is an extraordinary circumstance, then the project may be moved to an Environmental Assessment.
Project milestones with expected dates of completion are posted online on the Elder Creek project website. However these timelines are estimated and subject to change. Regarding the Elder Creek project, a decision is postponed and will not likely happen in February. We do not have an updated timeline yet, but as soon as we do, it will be reflected on the project website.
Did you send out an announcement about the project via the “sign up for proposed project updates” button on your project website?
No, the sign-up list is a new tool that we are planning to use to distribute quarterly updates.
We would welcome those who are interested in our projects to subscribe.
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So the Mendocino approach seems to be like scoping notice with more work. Finding out about a project, in my view, should be standardized across Forests (and Regions). It shouldn’t be a game of “find the project.”
The issue of fire to remove fuels, as in “prescribed fire,” on federal land by private contractor is more risk than reward. Private has unlimited tort liability and federal agencies, agents, have none. Federal Tort Claims Act only protects federal agents and agencies. Making the contractor a third party with no power over the decision to ignite or not? Bad deal. I don’t think, no matter what the record is, a private contractor should never in today’s litigious society of wildland fire, ignite any fire on federal land. If the fire escapes, the victims have to prove the contractor was negligent and them getting burned out. With the contractor NOT setting the fire, but managing it under federal aegis, what is the contractor guilty of? Doing what the federal government determined was permissible? Under their direction? I am fine with all the logging parts of fuel management until it comes to “inverse condemnation” CA statute language. No penalty for bad decisions in federal actions on their land, and also no penalty for federal fire trespass. If the contract holder does the ignition, the history in CA is USFS has no responsibility to victims of wildland fire from federal lands. Private actors and companies have unlimited liability. USFS just settled with PacificCorps for half a billion dollars for one fire. Victims accepted a settlement of less money because life if finite, and time flies when you have nothing but a verdict in appellate courts. PacificCorps just announced selling their Western Washington territory, infrastructure, customers for $1.3 Billion. Stockholders have less value and victims of non-economic damages, which are jealously of those who got paid for their losses at a generous price, for being impacted by smoke from the fire, and dealing with ash before the next rain washes it all away. Had to put an hour on the Hoover. Mental issues. Catching farts in a trout net. Stuff Premarin won’t treat. And if I am wrong, then why is total burning of one acre or 1 million acres of federal land not a more dire situation? Ho hum. What an opportunity!! A new forest will grow here for any who survive jihad against the infidels to appreciate when the Islamic faithful are all in Paradise. Which begs the question “Is there an old growth forest if none are left to identify it as an old growth forest untrammeled by the hand of man.”
I have problems today with the concept of any government owned forests as being the be all and end all for “good governance.” If random acts by humans over the last at least 18,000 years on this continent are the what is currently described as “natural” then what is any place on the planet without humans called? Un-Natural? Like the small pox virus, which exists supposedly in a frozen state in the CDC liquid nitrogen cold vaults so we have it to treat any future outbreak? What genius is behind that? We know how to use a harvested virus to make a vaccine. Or we can dredge up cow pox in some isolated agrarian area of eastern Europe. “Back to Basics.” Which ghouls are the keepers of the pox on mankind? Ours? or is it “Russia holds the virus in their Armageddon Vaults. We need our own.” The race to eternity hip hops along the moments we trek our trails to our own eternity. Maybe forests are best preserved by individual ownership by the world’s populace. I do mine my way and you do your’s your way. Viola’! Diversity. No “one size fits all.” Dolly Parton’s coat of many colors. The moths in Birmingham, England, which before coal and steam were white, and by the 1950s, they were all a mottled gray, with no white at all.
The threat to forests is not to their existence, but to where they will exist as this interglacial period matures to warmer, wetter, and in rain shadows, drier. They are species that move to the climate that best suits them, so upslope and northerly when the climate warms and down slope and south towards the equator when the Ice Age cooler periods return. Is “forest planning” an act of futility? A dead Clark’s Nutcracker results in its stash of food germinating into forest regeneration. A fire releases the seeds of knobcone pine in the Siskiyous and lodgepole across the cold elevations of the arid west and on our Pacific coastal strip from the littoral to inland a few hundred feet to a mile or two. The seashore is where it found security in this interglacial period as preserved pollen in the coastal soil profiles show it was the dominant conifer species when humans arrived via the Bering land bridge and island hopping along the West coast south to ?? Tierra del Fuego? The islands are now under 300 feet of melted glacier water. Which is why I ask if planning is a fool’s errand. Are federal lands as diverse as private lands in species distribution and numbers?
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Inconsistency among national forests was a big public gripe when the 2012 Planning Rule was developed, and it was a major topic of discussion in relation to whether the forest supervisor or regional forester would make the forest plan decision. The Forest Service admitted this in its response to comments, but basically did not provide a serious response (in going with the forest supervisor). Here was the question; the answer follows on p. 21191 of https://www.fs.usda.gov/sites/default/files/2012-planning-rule-stelprdb5362536.pdf
“Comment: Level of responsible official and consistency with regional or national programs. Some respondents felt the proposed change from regional forester to forest supervisor for the level of responsible official would make the plan more responsive to local situations. Others felt this change would result in inconsistencies across unit boundaries, limit collaborators, and reduce the accountability provided by a higher level responsible official. Several respondents felt the discretion given to local responsible officials in the proposed rule could lead to individual forest and grassland level plans that are inconsistent with neighboring unit plans and with regional or national programs.”
As for finding out that there is a project, maybe that’s a good job for AI? If the Forest Service puts it in any public internet location, there should be a standardizable way of finding it. A standardized way of storing and displaying it would be nicer, but maybe that could be done by the AI “viewer” now.
Achieving standardization and consistency could benefit both the Forest Service and the public. However, there are forces in play that will make standardization goals difficult to achieve. The agency has relied on a complex set of regulations and policies to compel consistency, but a January 2025 Executive Order established a “10-to-1” goal for deregulation, aiming to cut ten regulations for every new one introduced. Additionally, existing regulations are being revised to provide local decision makers greater discretion by reducing requirements. Some of these changes seem quite positive, but they don’t foster consistency.