Sharon

People Wary of Monumentizing: Dolores River Version

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A tree begins to bloom inside Dolores River Canyon, Apr. 23, 2023, near Bedrock. (Hugh Carey, The Colorado Sun)

Shout-out to Jason Blevins of the Colorado Sun for this story that shows the different local points of view around Monumentizing.

Pond, a former nuclear engineer who now runs an RV park in Naturita, quickly launched a petition at change.org saying the monument designation would cancel all mining in the uranium-rich area, end hunting and cattle grazing and curtail motorized travel.

“I think it absolutely, positively could be a threat,” Pond told The Colorado Sun. “If you look at the history of monument designations over time, more and more restrictions are put in place as more people start coming. We could start losing access. These are public lands me and my family and our neighbors have enjoyed for decades. A lot of local people have a lot of concerns.”

In the first 10 days more than 2,100 signed the online petition, many leaving comments blasting the plan.

Scott Braden, a Western Slope conservation advocate whose Colorado Wildlands Project is among the 13 conservation groups behind the monument proposal, said the petition “is making mischaracterizations about what a monument will or won’t be.”

“It will not end ranching. It will not close Jeep trails. It will not stop hunting. That is simply not what we are proposing,” said Braden, pointing to an online fact sheet he helped assemble to better inform residents about the plan.

This is the old “not in this decision” trick, as we have seen with the BLM Rock Springs draft RMP.. no, strictly speaking, this decision isn’t made in the designation but it narrows the activities allowed in future decisions.  And if the point is not to change activities to “protect” things.. ultimately.. why make BLM and FS folks go to the work of developing a new plan for the Monument.. unless the whole point is to attract more tourists.. and thereby not really “protect” it at all.  Puzzling.

And the ever-popular State of the Rockies poll, (generic and biased questions asked of people who aren’t familiar with the issue, IMHO).

Colorado College’s annual State of the Rockies poll this year asked 436 Colorado residents about protecting existing public lands surrounding 162 miles of the Dolores River to “conserve important wildlife habitat, and safeguard the area’s scenic beauty and support outdoor recreation.” The poll showed 92% of respondents support the protection plan and 6% oppose.

Advocates for the monument last year commissioned the nonprofit research group Conservation Science Partners to identify “biologically rich pockets of unprotected public lands” in Colorado. The group’s report showed the five-county region around the Dolores River as the largest and most biodiverse of the 71 areas identified, with high biodiversity values that support a variety of animals and plants.

Here we go.. unprotected from whom and what, exactly?

Natalie Binder, who has converted a 120-acre former mining camp above the San Miguel River in Naturita into a boutique retreat and artist compound, said even if a national monument increases visitation to the region, “it will not change the remoteness of these lands.”

“A monument is not the magic wand, nor does it come without some complexities,” she said. “However, we are rooted in supporting efforts that allow us to bring more people together, provide opportunities for more people and open our doors with kindness to all travelers who are passing through looking for something a little different.

It does sound a bit like.. more people are wanted, at least by some.

Pond said a shutdown on new mines would not work for the communities along the Uravan Mineral Belt, a 210-square-mile geological zone that has produced more yellowcake uranium and radium than any other region in the country. But there hasn’t been any hardrock mining in the 2,100-resident West End community for several decades and the coal-fired power plant in Nucla closed in 2020 and was demolished. There are hundreds of dormant mines in the area needing remediation.

But the price of uranium is up, over $100 a pound for the first time since 2007. There is a buzz in the West End communities of Bedrock, Naturita, Nucla and Paradox around a mining revival, Pond said.

What I think is missing from that part of this piece is:  there seems to be a nuclear energy renaissance going on around the world, including this COP28 statement:

At COP28, Countries Launch Declaration to Triple Nuclear Energy Capacity by 2050, Recognizing the Key Role of Nuclear Energy in Reaching Net Zero

Logically that would require more uranium mining.  And as we know, some Tribes don’t want it, so.. wouldn’t we want to think about that before Monumentizing? As to polls, here’s another one (granted it was Australia)

An exclusive Newspoll conducted for The Australian shows 55 per cent of all Australian voters supported the idea of small modular nuclear reactors as a replacement technology for coal-fired power.  But support was highest among 18 to 34-year-olds – the demographic most concerned about climate change – with 65 per cent saying they would approve of such a proposal.

If I were involved in that discussion, I’d ask the proponents exactly what they are looking to “protect” from.. industrial scale recreation? Moabization?  and then have the discussion move on from there. Because right now, it looks to me (to link to our previous discussion on targets) that certain groups, those with a heavy influence on certain politicals, have a “protection acres”… target.  And in pursuit of that target, perhaps they don’t actually care what “protection” means exactly.  And these local people in the article do care about the specifics.   So, given that.. what is the right process to involve local people in Monumentizing?

More on Forest Service Accountability: Repost of 2022 Discussion and Does Anyone Have a Copy of the Mills Accountability Report?

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This is a re-ask from 2022. Accountability has come up in our recent discussion, and we have new TSW readers. I’m still looking for the Tom Mills Accountability Task Force report. Rich J has a number of interesting links in the comments.

The Smokey Wire Information Request- FS Accountability Study and a new “What Year Was This?” Quiz

Friday Fun: Chat with Google Gemini on The Smokey Wire and Related Topics

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I know that given what folks have heard about Google Gemini, you are curious about its take on The Smokey Wire. I posted it below. Of course, Google knows that I am me, so maybe it tailored its response to be nice.  Maybe others would like to try? Here’s a link.

Feel free to ask it questions on our kinds of topics and post in the comments. Here’s what it told me.

The Smokey Wire is a community-sourced online platform focused on news and views related to Forest Service and public lands policy in the United States [1].expand_more

Here are some key points about The Smokey Wire:

  • Mission: To facilitate open dialogue and information sharing among various stakeholders involved in public lands management, including practitioners, the public, and academic and scientific communities [3].
  • Content: The platform features articles, discussions, and resources on diverse topics related to wildfire management, forest health, wildlife conservation, and recreation on public lands [2, 4, 5].expand_more
  • Source of information: While not directly affiliated with the Forest Service, it serves as a platform for sharing perspectives and promoting collaboration on issues related to public lands management [3].expand_more

Overall, The Smokey Wire serves as a valuable resource for staying informed and engaged in discussions about the management and use of public lands in the United States.

I don’t know if people have read about Matt Taibbi’s experience with Gemini but I can only hope that The Smokey Wire stays under their “let’s make stuff up that’s negative” radar screen. Oops. I wonder if it’s absorbing this post into its maw of information?

Outcome-Based Performance Measures Report 2020

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A few weeks ago,  I heard Chief Moore say something like “the Forest Service is considering alternative measures for fuel reduction/wildfire resilience based on outcome not outputs.” This is somewhat related to our earlier discussion about timber targets.

I remembered that RVCC (Rural Voices for Conservation Coalition) had done some work on this, and the RVCC folks were kind enough to dig two reports up for me.  So it’s worth discussing and feel free to share any other reports or thoughts in the comments.   Discussions of performance measures do not normally get the blood flowing in many people I know.  Retirees may just roll their eyes and say “Thank Gaia I don’t have to think about this anymore or sit in meetings or read stuff about it…”  Nevertheless, here goes

It looks like there were two different thoughtful efforts.  One (2020) was called “Implementing Outcome-based Performance Measures Aligned with the  Forest Service’s Shared Stewardship Strategy.”

We’ll cover the other one (2022 with many of the same notable players) in the next post. This was a joint project of U of Oregon’s Ecosystem Workforce Program and RVCC with support from the Forest Service. The below is an excerpt of part of the paper.   The whole report is worth reading, and has many other points worthy of discussion.

5. Guiding principles and recommended next steps

In this section our goal is to provide guidance to the agency for moving forward with revising performance measurements in accordance with the Shared Stewardship Strategy. Our suggestions are derived from recommendations from the literature, stakeholder feedback, and our own experiences working with the agency

5.1 Internal agency considerations to prepare for performance measure redesign
The agency must define and communicate a clear purpose and audience for new performance measures prior to moving forward. We suggest that the agency consider the following questions and recommendations before requesting input from stakeholder partners.

It would be nice if all efforts required “communicating a clear purpose and audience prior to moving forward.”

Implementing Outcome-Based Performance Measures Aligned with the Forest Service’s Shared Stewardship Strategy 13
• What decisions and changes are new performance measures intended to inform? Whose behavior will change, and at what levels of the agency, as a result of the new performance measures? Be cautious of defining too many goals for performance measures. Composite priorities, such as those that are often referenced together in Shared Stewardship (e.g., cross-boundary, geographic prioritization, partnership), may require distinctly different performance measures.

• Will new performance measures replace or complement existing measures? New performance measures will not exist in a vacuum independent of existing measures, particularly timber volume and fuels reduction acre targets. As noted in the literature review, easily measured and defined goals and associated performance measures are likely to crowd out those with more complexity.  Furthermore, if new performance measures have no connection to budgets or staff performance reviews, they are unlikely to motivate or institutionalize new bureaucratic behavior. The distinction between performance measures should be clarified internally within the agency and externally for partners prior to moving forward.

• Who are the intended audiences (e.g., WO,Congress, OMB, states, community partners) and what would be meaningful to them? A single performance measure is unlikely to meet
the needs of all possible audiences. Counts of partnership agreements, for instance, may help signal progress to Congressional audiences, but are unlikely to be particularly meaningful to local stakeholders or state implementation partners. We encourage dialogue with intended audience(s) to ensure performance measures are meaningful to those parties.

• What investments will the agency be able to make in data collection and management? Utilizing existing data may be necessary and preferable in the short term; however, new performance measures will likely require some level of new data collection. We encourage the agency to recognize that updating existing databases and creating new fields, if not whole new data systems, is likely needed to meaningfully report on partnership outcomes.

• At what scale does the agency want to implement new performance measures? The recommendations and considerations offered below apply broadly across most or all scales, but
performance measure design and implementation will look different at varying scales. For instance, the principle of inclusivity may look different if a performance measure is intended to evaluate a District or District Ranger compared to a Region or Regional Forester.

We also recommend that the agency make revised performance measures one part of a broader strategy to ensure that incentives and policies within the agency align with the intent of the Shared Stewardship Strategy. In particular, we suggest the agency convene a series of workshops for academic partners and practitioners who specialize in United States public lands forest governance and policy to consider options for broader reform efforts within the agency (e.g., reforming the National Forest Management Act, incentive structures within the agency, long-term visioning). We further recommend that the agency convene a structured meeting of national partners to further develop recommendations for implementing revised performance measures.

I’d only add that partnership-ish measures at the landscape scale should perhaps be coordinated in such a way that landscapes with intermix of BLM and FS should consider collecting the same kind of information and consider developing similar performance measures in those areas, if performance measures occur at the landscape scale. I think partners, neighbors and taxpayers would thank you.

 

TSW Exclusive: A Tale of Two SERALs- Making Landscape Scale Resilience Happen With the Stanislaus Forest and YSS

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I am reposting this because I think it’s important and perhaps people missed it because Steve also posted yesterday. The question for readers who are currently working or involved in collaborative groups is “do you think some of these ideas are worth considering in your part of the country?”

 

There are many news stories about projects in litigation, or where there are controversies.   Forest Service folks may remember the management training of “catching people doing something right.”  The SERAL (Social and Ecological Resilience Across the Landscape) efforts are successful at getting large-landscape treatments done. Are there ways that other Forests and communities can learn from these efforts?

This story deserves much greater play in larger media IMHO. I’m thinking a NY Times, WaPo, or NPR-style set of emotion-inducing interviews, drone overflights, and all that.  I’ll be sending this to journalists with that wish.   It would also be an interesting case study for social scientists interested in trust building and collaboration.

From this January

“SONORA, Calif. (January 11, 2024) – In an incredible show of faith and recognition for work already accomplished, the Stanislaus National Forest recently received its annual budget for work on the Stanislaus Wildfire Crisis Strategy Landscape of $57.6 million.

“This funding level is a clear indicator that we are on the right path with our work and should continue at full speed,” said Stanislaus National Forest Supervisor, Jason Kuiken. “Not only is that apparent as people drive up Highway 108 and see with their own eyes the work, but it’s an acknowledgement all the way from Washington, D.C. that this work should continue.”

Part of the Forest Services’ Wildfire Crisis Strategy, the Stanislaus National Forest is currently into year three of a ten-year, 305,000 acres project to reduce fuel loads on the forest through a variety of methods to include mechanical thinning and the application of prescribed fire.”

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First of all, the Forest has an very helpful website on this project,  well worth checking out. It includes a story map that tells the story with photos and videos.

Background:  The first decision is Seral 1.0, which called for work on 55,000 acres; currently the Forest is taking public comment on Seral 2.0, which covers another 100,000 acres. The area is part of the one of the priority landscapes for the Wildfire Crisis Strategy (think $).  The priority landscape itself encompasses more than 300K acres and the non-SERAL parts include Wilderness and other decisions and collaboratives (see map above).

So let’s look at some of the ways that this success became possible.

1. Yosemite Stanislaus Solutions Collaborative Group

In an interview, the first thing that Supervisor Kuiken pointed to was the efforts of a collaborative group called Yosemite Stanislaus Solutions.  You can learn about them here on their website.  It includes everyone from Audubon and the Sierra Club (local chapters) to Sierra Pacific, Dirt Riders, Tribal folks and so on.  You can check the partners out here.

From the YSS webpage:

“After decades of adversarial “wrangling” over forest management policy, 25 local industry, environmental, and recreational groups decided it was time to focus on what we could agree on,” said Mike Albrecht, president, Associated California Loggers.

“When we sat down together, we found out we agreed on a lot, and so Yosemite Stanislaus Solutions (YSS) was born. YSS agreed to salvage logs the Rim Fire, get it reforested, develop a fuel break network to protect our local communities, and restore meadows, streams, and wetlands to better health,” Albrecht said. “This agreement has gotten us national attention and subsequent funding to undertake large “landscape level” forest management projects. This would not have been accomplished without the close 3-way partnership between Tuolumne County, YSS, and the U.S. Forest Service. Kudos to everyone that has worked so hard to make this happen!”

2. The Rim Fire Galvanized the Community

The Rim Fire burned 402 square miles (260K-ish acres) with a “wide range of intensity and impacts.” These photos show that, at least in some areas, much restoration work for watershed, and to restore tree cover will be needed.  The experience of this fire showed the need for work at the landscape scale. It was the third largest wildfire in the State at the time.

“John Buckley, executive director of the Central Sierra Environmental Resource Center in Twain Harte, is also active with Yosemite Stanislaus Solutions. An immediate lesson learned was that doing scattered piecemeal fuel reduction projects, timber sales, mastication of brush, and isolated prescribed burns simply wasn’t going to be enough to prevent more Rim Fire type catastrophes. “That led the YSS forest stakeholder group to come together stronger than ever before to work to get tens of millions of dollars in grants to supplement the work that the Forest Service was already planning to accomplish,” Buckley said.”

3. At First Collaborators Worked Together on Reforestation

Perhaps getting to the “topics with more disagreement” was helped by relationships forged during the work on “topics with agreement.” Also, jointly doing work instead of just talking about how the FS should do it, perhaps caused a greater sympathy for difficulties and trust in Forest Service actions.

4. Getting Work Done Through Partners

Various master agreements, including with the County, enabled finances to be transferred and work to be done without federal hiring or FARs difficulties.  Counties and others can hire locally, so that issues like housing affordability may be less pressing.

5. Consistency of Forest Service Personnel and Alignment

Partners are always asking for this.  While personnel have indeed changed, the commitment to the process has not.  There have been three Forest Supervisors involved during and since the Rim Fire. How did the Forest Service pull this off? Personalities, policy or processes or all of the above?

6. They Were Able to Work Together on Traditionally Tougher Issues.

Example: fire salvage. As TSW readers know, salvage can be controversial, even in the Sierra Nevada.

“Because all the YSS stakeholder interests supported the compromise salvage logging plan, it managed to gain Forest Service approval and got implemented without any legal delays that would have meant a lot of the wood could have rotted,” Buckley said. “By working for consensus middle ground on the issue of salvage logging and then the following debate over how to do national forest reforestation, YSS set a national example — showing the benefits of diverse stakeholders working together in a spirit of compromise and cooperation.”

7. Role of Models and Scientists

Because this work was at the landscape scale, it required thinking beyond the stand level, including the development of PODs. This includes practitioner knowledge, and newer technologies (e.g., Lidar) and models were used; including workshops for the collaborative group with scientists.   Supervisor Kuiken would advise anyone “these new technologies and models can be very helpful and save a great deal of time.”

Probably a heavy direct involvement by scientists also helps collaborators learn together and operate from the same knowledge base.

8. NEPA Opportunities and Choices.

They did an EIS for Seral 1 and will do one for Seral 2. You can read the notice of intent on the Federal Register here.  I get the feeling that the way that the decisions are structured such that analyzed activities may occur over time with no new decisions required.  So big EIS, but considers many kinds of treatments over a large area over a long time period. For example, ongoing maintenance of fuelbreaks is included in the decision. If stands die due to bark beetle, that is also incorporated.

They are using some emergency authorities, specifically “only the proposed action and a no-action alternative” and “no pre-decisional administrative review process.” In the case of Seral 2.0, potentially more controversial decisions will be covered in separate RODs based off the EIS.

They have used new technologies, like Lidar, to help with the analysis.

Inquiring NEPA minds might want to know  “does this decision incorporate “condition-based management””?

Katie Wilkinson, the Forest Environmental Coordinator, addressed this in an email.

“The SERAL projects only have aspects of condition-based management – salvage, rapid response to newly discovered non-native weed infestations, hazard tree mitigation (only in SERAL 1.0).

The large majority of the SERAL projects proposed or authorized actions however, would not be considered condition-based management.  The SERAL decisions authorized site-specific vegetation management actions (other than those listed above) and the SERAL 2.0 decision will do the same. Modifications do occur from planned units to implementation units, regularly, based on a variety of factors or updated survey information considered and obtained internally.

None of the SERAL implementation will go through additional public review or comment periods.  The SERAL analysis document includes the site-specificity necessary to provide meaningful feedback and public comments and for the decision maker to make an informed decision.  That doesn’t diminish the amount of work left for the implementation team to complete after the decision and prior to implementation. “

9. Lack of Litigation. We’ve all seen collaborative groups work together well, with the decision then followed by litigation. This was not the case for Seral 1.0. We can’t FOIA internal documents of potential litigants to understand why they did not file.  Certainly litigation does occur with similar kinds of projects in the Sierra Nevada.   When asked why  Supervisor Kuiken replied in an email: collaboration on developing the proposed action (and associated response to the public concerns) and second that the IDT made a DEIS/FEIS that was both thorough and readable/understandable.

I’m thinking that it may also have something to do with the choices made by potential litigators, and the political horsepower behind the project.  Certainly a previous effort (salvage) was litigated, as we covered earlier on TSW.  I’ll try to find out more about this.

Summary

The SERAL efforts have been successful.Let’s look more deeply and share this information.

TSW readers: what aspects of this effort do you think are replicable where you work? Why or why not? Ideas for reporters to send this to.. either in comments or contact me directly.

Reporters: What might be interesting angles..

*What makes people who usually disagree come together? Interview various members of YSS.  Link to election year and reducing polarization? Something like this NY Times story about Blue Mountain Forest Partners.

*When Litigants Stay Home and Why: Interview folks who litigated on the Rim Fire and not on SERAL 1.0, and ask them about their rationale.

*Climate change and carbon:given the many op-eds that simply claim “leaving mature and old growth trees alone is best for carbon” how does the Forest and YSS think about carbon. Interview some scientists involved (and those who disagree).

*Old -growth.. how will old growth be delineated and protected in Seral 2.0?

*Digging into how they used new technologies in their work, and new ideas like PODs.

 

New Lawsuit on Timber Targets by SELC: Is More NEPA the Answer?

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In this post, I’ll focus on the lawsuit itself. In the next post, we can talk about the more generic question of “are timber targets of utility, should they be replaced, and if so, by what?” The press release by SELC raised many questions, and hopefully others will know the answers.

A new lawsuit alleges the U.S. Forest Service’s practice of setting ‘timber targets’ puts the climate at risk, undermines the Biden administration’s important climate goals, and violates federal law.

Back in 2018, we had a post on TSW about timber targets and how they’re set. Mac McConnell described the process in this comment. Maybe someone else could flesh Mac’s comment out more, or write a post on it?

The case centers around the Forest Service’s failure to properly study the massive environmental and climate impacts of its timber targets and the logging projects it designs to fulfill them. Each year, the Forest Service and Department of Agriculture set timber targets, which the Forest Service is required to meet through logging on public lands. In recent years, the national target has been set as high as 4 billion board feet – or enough lumber to circle the globe more than 30 times. The already high target is expected to increase in the coming years.

I’m not sure why that would be. Perhaps more fuel treatments projected due to the 10-year action plan? But those are not really “about” timber.

Forests on public lands provide a key climate solution by capturing and storing billions of tons of carbon. But rising timber targets push the agency to clearcut forests and log carbon-dense mature and old-growth forests. Logging these forests releases most of their carbon back to the atmosphere, worsening the climate crisis and undermining the Biden administration’s important efforts to protect old growth and fight climate change.

I’ve got two problems with this.. first, the targets don’t seem to be rising,  and second, the only clearcuts I’ve seen recently have been in MPB-susceptible old lodgepole.  And I guess the carbon question there is… the trees are gonna die, is it better to turn them into longer-lived wood products, or what.. burn them? Leave them to decay slowly until burned?  This is one of those cases in which specifics, and specific alternatives to the maligned practice, would be helpful. It’s almost as if these  MOG-ish carbon assumptions assume.. wildfire is not a thing.  At the same time, we are told that wildfires are getting worse due to climate change (Sierra Club- catastrophic), and our insurance premiums need to be adjusted to reflect that. Also the puzzling idea that carbon offsets are bad because trees will die; leaving them alone for carbon is good because… trees won’t die? To be fair, these are not SELC positions as far as I know.  At the same time, the idea that trees will not die or get burned up does seem to be part of this press release.

Internal Forest Service documents show that achieving timber targets is the agency’s “#1 priority.” According to agency staff, the need to meet timber targets impacts the Forest Service’s ability to provide “basic customer service for health and safety,” “keep trails opened and maintained,” and “respond to needs resulting from catastrophic events…in a timely manner.” In some instances, agency staff have used money meant for wildlife habitat improvement to fund projects designed to achieve timber targets, even if those projects had “no benefit to wildlife.”

“The requirement to meet timber targets results in adverse impacts on water quality, recreation, and imperiled wildlife, while distracting the Forest Service from more pressing tasks that don’t produce high timber volumes like preventing wildfires, saving trees from invasive pests, and controlling invasive plant species. If the agency is going to prioritize timber targets above the other benefits of National Forests, it needs to forthrightly disclose the consequences of that decision, particularly on our climate,” said Josh Kelly, Public Lands Biologist at MountainTrue.

Perhaps Sam Evans can help here, but when I signed on to the link, there were many files, so I couldn’t find the one that said that meeting timber targets was the agency’s #1 priority.  And I’m fairly dubious about that claim, since fire suppression and the 10-year wildfire action plan, and remember this about Fire consuming the FS budget..  Also, if we take Chief Moore’s word for it last year, he said:

The FY24 budget request focuses on three primary areas that impact the Forest Service: modernizing the wildland fire management system, combating climate change and confronting the wildfire crisis, and ensuring equitable access to the benefits of the National Forest System.

I remember a quote along the lines of  “to find the real policy, don’t listen to what they say, look at the budget.” Maybe someone remembers the real quote on that, and who said it originally? But back to SELC:

The Forest Service’s refusal to take a hard look at the direct, indirect, and cumulative effects of its timber target decisions is a violation of the National Environmental Policy Act, our nation’s bedrock environmental law.

It almost sounds to me like a request for a national programmatic on the timber program as a whole.  Which is interesting, but could be asked of any program (recreation impacts on climate from people driving to national forests?); or how about a national programmatic on fire suppression or prescribed fire?  Then we could have litigation on (1) the programmatic, (2) the forest plan and (3) any timber project – all at the same time. I’m not sure who this benefits. I don’t think it’s taxpayers.

Also, I’m not sure that courts are the right places to have these discussions.  For example, we could FOIA discussions of the timber program at the Forest Service or USDA, but not settlement agreements, nor the discussions that arrived at them. I’m interested in transparency and accountability; and the need to build trust in our government institutions.  As a result, I consider  non-transparency to the public as suboptimal.  Also, I would say to SELC, we could ask questions of them equivalent to their points about the Forest Service “have you considered that lawsuits like this and the 15-acre one might equally distract your organization from more pressing tasks and environmental concerns, especially with regard to climate?

The Next Big Grift?: Doomberg on NACs

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I asked the folks on Doomberg to take a look at NACs from a financial perspective. As a non-financial person, I’ve written about them here, here, and here.

Doomberg’s piece on Substack is called “Measurement Army: Natural Asset Companies (NACs): the next big grift?

We begin with some important definitions culled from a 56-page exhibit filed with the SEC as part of the petitioning process, and from the United Nations System of Environmental Accounting (SEEA):

A “Natural Asset” is “[a] statistical representation of ecosystems for accounting purposes that defines them as productive units of ecosystem services” that can be “monetized directly or indirectly.”

“Ecosystem Services” refer to the benefits that people obtain from ecosystems and are categorized broadly into provisioning, regulating, cultural, and supporting services.

“Ecological Performance Rights” are “[t]he rights to the value of natural assets and the production of ecosystem services in a designated area, including the authority to manage the area. These rights are granted to a NAC, from a natural asset owner, as provided through a license or other legal instrument.”

Finally, an “Ecological Performance Report” is “[a] report with statistical information on the ecological performance of a NAC, including sections with data on (i) Natural Production, (ii) Natural Assets, and (iii) Underlying Asset Condition. This Report is unique to NACs and will be provided in addition to traditional financial statements.”

Let’s see if we get this right: NACs hold claim to the Ecological Performance Rights over the Ecosystem Services delivered by the NAC’s licensed Natural Assets. Think of all the measuring needed to make that construct work.

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I guess this could be more abstract, but it’s already beyond my imagination.   A thing is not a thing, but a “statistical representation” of a thing.  I didn’t even know that there was a United Nations System of Environmental Accounting.

The authors of the SEC filing go on to claim an astonishing measurement of their own: natural assets are valued at approximately $5 quadrillion. Listing NACs on public stock exchanges “can convert the long-understood – but to-date unpriced – value of nature into equity capital which can generate the financial capital needed to manage, protect, and restore healthy ecosystems over the long term.”

Doomberg, like me, takes a dim view of the many potential transactional hogs at the trough..

Imagine the wealth creation opportunities for the cadre of sponsors, advisors, brokers, and attorneys when passive fund managers are mandated to allocate to NACs, options markets are developed for them, and retail traders give them the Nvidia treatment.

I don’t know what the Nvidia treatment is..

And then there are the measurers! All players involved in the new world of NACs – including governments, banks, law firms, and the NACs themselves – will need an army of them. Given the bulging numbers of the administrative class, this is one modern army sure to exceed its recruitment needs.

If you’re not familiar with ideas about the administrative class, you might take a look at this piece by N.S. Lyons, in which he describes what N.S. describes as the “managerial ideology.”

7. Abstraction and Dematerialization: The belief, or more often the instinct, that abstract and virtual things are better than physical things, because the less tied to the messy physical world humans and their activities are, the more liberated and capable of pure intellectual rationality and uninhibited morality they will become. Practically, dematerialization, such as through digitalization or financialization, is a potent solvent that can help burn away the repressive barriers created by attachments to the particularities of place and people, replacing them with the fluidity and universality of the cosmopolitan. Dematerialization makes property more easily tradable, and can more effectively produce homogenization and fulfill desires at scale. Indeed in theory dematerialization could allow almost everything to take on and be managed at vastly greater, even infinite, mass and scale, holding out the hope of total efficiency: a state of pure frictionlessness, in which change (progress) will be effortless and limitless. Finally, dematerialization also most broadly represents an ideological belief that it is the world that should conform to abstract theory, not theory that must conform to the world.

Burn Boss Arrest: Editorial Board of Eastern Oregon News Outlets Steps Up to Reduce the Heat

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Right after I posted Steve’s op-ed, I was sent a piece by the editorial board of the East Oregonian media group along the same lines.  That’s what peacekeeping leadership looks like.  Local journalism is more than just coverage of local issues; it’s the people involved.   They can be voices in the community who are interested in its well-being, not stoking resentments, or finding the shortest distance between the facts and a narrative such as “incipient Bundys.” People in communities need to get along over time; people in our country do, too, but, sadly, some national media seems to see their role as furthering divisions and encouraging outrage.  It’s not their fault in a way, it’s a business model that works, but we can support local journalism and journalists to the best of our ability.  Here’s a link.

 

There comes a time during a controversial situation where public officials need to step back, take a deep breath and start acting like adults.

A good case in point is the current hullabaloo around the U.S. Forest Service and Grant County regarding a 2022 prescribed fire that spread beyond its start on the Malheur National Forest onto private land owned by the Holliday family.

On Oct. 19, 2022, Grant County Sheriff Todd McKinley arrested Rick Snodgrass, a Forest Service employee, while the prescribed fire that Snodgrass was in charge of was still burning south of John Day.

On Feb. 2, 2024, a grand jury indicted Snodgrass on one count of reckless burning, a Class A misdemeanor.

The entire case should leave most readers with a slight distaste on the palate.

On the big picture level, the case is in some ways a classic local versus federal dispute, but why this incident has been drawn out for this long is a mystery.

Snodgrass was doing his job, a job delegated to him by his superiors. The arrest is believed to be the first case of a Forest Service firefighter being arrested in the course of his normal duties.

Anti-government sentiment is nothing new to Eastern Oregon. As a culture, we tend to be suspicious of the federal government and hold dear the concepts of personal land ownership and dislike interference from federal and state governments. Those sentiments are ingrained into our culture as Americans.

Yet this case in Grant County remains baffling on many levels. Local and federal officials are at loggerheads while an individual who was following orders and adhering to established protocols for prescribed fires is left holding the bag.

This incident should have been handled in a totally different way and through appropriate channels.

The prosecution of this case only serves to exacerbate already existing tensions about federal land management in Grant County and Eastern Oregon. Feeding and stoking anti-government feelings may be convenient for some but hardly qualifies as problem-solving.

Instead it looks absurd. Worse, the prosecution could impede efforts to find common ground and solutions to the growing danger that wildfire poses.

Prescribed fire is a vital tool, but not always a perfectly precise one.

Legitimate concerns or disagreements regarding prescribed burns or other land-use issues should be addressed through proper legal channels and in a manner that is in line with our system of laws.

The fire ignited by Snodgrass and his crew torched some trees during the afternoon, when the wind picked up, and embers spread onto land owned by the Hollidays.

The ember started a fire that burned an estimated 20 to 40 acres of the Hollidays’ land.

If the Hollidays can show that the fire damaged their property, or reduced its value, then they have legitimate grounds for a civil suit against the federal government.

That, rather than a criminal case, is the appropriate legal venue for trying to punish the Forest Service.

What this matter needs is some adult leadership to bring everyone to the table to find a viable solution. Indicting people isn’t the answer. Compromise is.

Steve Ellis Op-ed on “Arresting Burn Boss” Episode

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I’ve been noticing a tendency for federal agencies to become more vague and abstract about what exactly they’re doing, with many agencies seemingly having identical programs, or overlap (or run against each other). At the other end of the spectrum, we need to ask “what is the work that needs to be done that doesn’t have anyone stepping up to do it?”  When I read Steve Ellis’s  op-ed about the Arrested Burn Boss case, I wonder how many Forest Service folks are assigned the role of peacemakers.  And if the Forest Service doesn’t have that role because they are involved in a dispute, what is the role of local institutions in peacemaking? I’m thinking here of Steve’s previous piece in which members of a religious group did the work of protecting a community from flooding.  I would bet that many folks in religious institutions have excellent dispute resolution skills, and are acknowledged community leaders, but there are plenty of others who are community leaders of various kinds.  Perhaps this is an opportunity for them to exercise their skills for the well-being of all.

Here’s Steve’s op-ed. It ran in newspapers in Pendleton, Baker City and LaGrande this AM:

 

Destructive wildfires have resulted in the devastating loss of communities, loss of life, impacts on human health, untold damage to our watersheds, and the pumping of massive amounts of climate-changing carbon dioxide into our atmosphere. Conditions are such that large fires are becoming difficult, if not impossible to suppress.

People who live in rural parts of Oregon are especially aware of this and the pressing need for effective landscape fuel treatments that include thinning, fuels reduction and prescribed fire. Practitioners, the research community, and most members of Congress have recognized the need for management activities.

We are the National Association of Forest Service Retirees, and our experience has been that this is best achieved by the agency, communities, landowners, Tribes, state forestry organizations, and various partners working cooperatively together. The good news is trust has been on the upswing and more of these partnerships are having success around the country.

Building the trust that enables prescribed and managed fire where there is not already a strong foundation of trust will be a challenge for the U.S. Forest Service. However, even with the best intentions, damage may sometimes occur to neighboring properties that was clearly not part of the plan.

Using fire to help forests become healthier and more resilient is a delicate balancing act. The intent is to work collaboratively in increasing “good” or beneficial fire and decreasing “bad” fire. Prescribed burning on National Forest System lands is designed to also protect neighbors’ homes, property and livestock from intense and destructive wildfires.

Regrettably, putting fire on the landscape, no matter how well meaning, does have its risks. Several of us had experiences during our careers where a well-intended prescribed fire went beyond the planned burn area.

I recall one instance in Idaho where the fire progressed onto some private land and burned approximately 10 acres of a rural mix of forest and rangeland property. We worked with the landowner, paid for replacing the fence and some other costs, and ended up with a very good working partnership. The landowner did not call the sheriff and ask that federal fire personnel be arrested.

Beneficial fire has been missing from many western landscapes for decades with profound impacts on forest health and resilience. Restoring fire’s role in the forest is critical. We all jointly need to properly use fire on the landscape. Along the way, unplanned events will no doubt occur, even with the best of plans and safety measures in place.

When accidents do happen, impacted landowners should be appropriately compensated. At the end of the day, if ultimately fire is to be managed well, cooler heads must prevail. Arresting an agency employee while he is performing his duties for the agency is not a productive path to building partnerships, and only exacerbates bad feelings and mistrust.

We look forward to Grant County and the Forest Service working to build cooperative relationships and stakeholder success to proactively manage forests and rangeland landscapes at risk of large destructive wildfires, regardless of ownership. Success makes for better media headlines.

Steve Ellis, former supervisor of the Wallowa-Whitman National Forest, is chairman of the National Association of Forest Service Retirees.

Update, A Few TSW Notes, A PSA and a Volunteer Opportunity

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FS Program Community Navigators- More Info Coming

One of our Anonymous folks asked about a program called “Community Navigators” that showed up on the FS LinkedIn site. I asked the WO Media Office and they said the announcement is coming out soon with more information. Hopefully someone will let me know and I can post about it, as I don’t read the FS LinkedIn feed.

Management Note:  What I think are AI Comments Thwarted; if They’re Yours, Let Me Know

We have had some comments from various entities which strike me as possible AI comments, to what end I have no idea.  They seem impersonal,  add no particular value and have an air of knowing about things that are, in reality, contested.   So,  I make a judgment call and delete them.  If I am mistaken about your comment, please contact me directly via email (see donate widget).  Then I will use Real Human Intelligence to change my personal algorithm.

TSW (at least this contributor) Has Lost Access to E&E News for Now

Sadly, we’ve had a breakdown on E&E News, my favorite outlet.  The generous ENGO who was forwarding stuff had their subscription raised to $1700 a year, which they can’t afford.  I am exploring alternative means of access (volunteering with the FS or other entities who have subscriptions?).  Meanwhile if you do get it and see something  interesting, please forward the link, so at least we know that there is an interesting story out there even if we can’t access it.

Public Service Announcement on Accessing Paywalled News

Since that happened, I’ve learned some things about accessing paywalled news that you might find helpful

    1. Local libraries often have digital access to newspapers.  Some including the NY Times.  Worth a check if you run into a paywall.  I now have cards at three county library systems, all of which have different ways of accessing different news outlets digitally.  And the most recent was just by walking in to a library (in a county I don’t live) and asking for a card.
    2. You can use archive.is where many news stories that are paywalled are saved.

Volunteer Wanted to Dig Into Project on Chequamegon-Nicolet

I received an email (as a media person) from the Environmental Law and Policy Center about violations of the timber sale contract on the Sunfish Timber Sale in the Fourmile Project Area on the Chequamegon-Nicolet National Forest in Wisconsin. It’s a Good Neighbor Authority (misspelled God Neighbor Sales  in the powerpoint) sale and it looks like thinning from the powerpoint. They are concerned about contractors working over-snow as in the contract, and claim that some cut trees violate the “proposed” old growth definition by diameter, and maybe the intent of the MOG executive order?

Here’s a link to the powerpoint. Anyone who lives in the area and wants to investigate further, please let me know.