Sharon

OG:- White House Announcement; More NGO Comments and Some Concern About FS Bandwidth from AFRC

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Thanks to SJ for adding these ..  the White House Announcement is of particular interest. Here’s a copy of the letter to forests.  It reminds me a bit of the old “reviewing roadless projects in the WO” effort. As they say:

This letter only affects the process by which such activities are authorized. It does not alter or prescribe any substantive standards for the management of old growth forests

I always wondered about the legality of these kinds of   review processes, it seems they are designed to provide an outcome before there is a legal reason to do so.  Just saying it doesn’t prescribe anything different (perhaps on the advice of OGC?) has not, in the past, been accurate. Perhaps our legal TSW friends can clarify.

This workshop sounds interesting, and that it is joint by BLM and FS is good; after all, PJ is  the most abundant old-growth and traditionally disagreements have not been timber-war-ish.

Collaborative Efforts to Conserve Pinyon Juniper: Pinyon and juniper woodlands encompass tens of millions of acres of federal lands across the West, and have significant biodiversity, climate, and cultural values. Pinyon-juniper woodlands are the most abundant forest type in the federally managed inventory of mature and old-growth forests, and are the majority of mature and old-growth forests managed by the BLM. While much management focus has been rightly placed on pinyon-juniper encroachment onto sagebrush ecosystems, less attention has been paid to the importance of mature and old-growth pinyon-juniper ecosystems. The Forest Service and the BLM will co-host a public workshop focused on the conservation of these ecosystems in 2024. Through this effort, the Forest Service and the BLM will engage the public, Tribes, land managers, experts, and stakeholders in informed discussion around management issues, threats, trends, and opportunities for climate-smart management and conservation of mature and old-growth pinyon-juniper woodlands on federal lands.

Susan also linked to this group of ENGO’s quotes.

It seems like some of the quotes focused on  consistency across the country (Sam Evans) and a seat at the table for developing national policy (The Wilderness Society, Defenders of Wildlife), while EDF uses that other “f” word (flexibility) and notes the role of local folks:

The proposed forest plan amendment creates a rigorous, science-based process that will both protect old-growth forests and provide flexibility for managers, local communities, and tribal nations to recommend management actions to improve resilience to catastrophic wildfire and other climate change-induced threats.”

Meanwhile our friends at AFRC also have a press release. Perhaps oddly, so far they are the only ones who seem to be concerned about loading more paperworky processes on already-overburdened and difficult-to-hire federal employees. Excerpts:

 “The Forest Service’s data confirms logging poses a negligible threat to old growth forests, and existing federal environmental laws and forest plans provide direction on managing and protecting old growth. Yet the agency is now being directed to embark on a new, massive bureaucratic process – during a wildfire and forest health crisis – that will likely make forest management more complex, costly, and contentious.

 “Protecting old growth requires intentional, thoughtful action on the ground – not more paperwork.  It’s not clear how amending every single Forest Plan will help the Forest Service implement the Biden Administration’s own 10-year wildfire strategy that calls for a threefold increase in forest health treatments. Rather than giving our public lands managers the policy tools and support they need to sustain our forests and all the values they provide, this policy will force them to focus limited time and resources on more process and that will do nothing to address the real risks on the ground..

Some Groups Want the M Back in OG; WaPo Gets Five Smokeys for NOGPA Coverage

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Interesting stories about the National Old Growth Plan Amendment (NOGPA). Now at this point, I haven’t seen anything the FS has written about it, and The Smokey Wire was not granted an interview with the Secretary, but what can we pick up from these stories?

First a story from the Washington Post.

I give them 5 Smokeys (out of 5) for detailed description, not characterizing it as “timber vs. enviros” and pointing out the timing problem via Chris Wood, also what’s the immediate effect.  All the things I wanted to know without any extraneous editorializing.  If you agree, consider sending the reporter a nice note:

In a phone interview, Agriculture Secretary Tom Vilsack said the effort is the first time the U.S. Forest Service has proposed simultaneously revising all 128 of its forest plans, which dictate how all 193 million acres of forests and grasslands are managed. The plan would prohibit cutting down old-growth trees for economic reasons, preventing carbon-rich forests from being clearcut at a time when scientists say they are most needed. These trees, most of which are well over 100 years old, store vast amounts of carbon. They also provide an essential habitat for hundreds of species of wildlife and are more likely to survive wildfires.

Having examine the projects alluded to in the Carbon Forests initiative, I don’t think the FS was cutting down any old growth for economic reasons. Again, as I’ve asked many NGO’s, please send me a link to the project documents where this is occurring and we can have that discussion in detail.

But it leaves open the possibility of continued cutting under certain conditions. Forest Service Deputy Chief Chris French said forest treatments the agency uses to reduce wildfire risk, such as thinning understory trees, would still be allowed in old-growth stands to protect them from out-of-control fire. In the Southeast, where the Forest Service is trying to restore the longleaf pine forests that used to blanket coastal areas, the agency could still cut down large, old loblolly pines, the main tree grown for the timber industry.

Some environmental advocates also questioned whether the policy will last, as a future administration could easily undo it. The new language about protecting old growth also won’t be finalized until the agency has completed an environmental impact statement, which it expects to finish in early 2025. “I wish they’d initiated this earlier. I wish they were doing a rulemaking,” said Chris Wood, president of the conservation group Trout Unlimited. Still, he said: “This is a big deal. This is a different agency than it was 20 years ago. The Forest Service’s appetite for going in and liquidating old growth is pretty much retired.”

It’s unclear how the new proposal will affect the agency’s planned timber sales, some of which include forest lands dotted with mature and old-growth trees.
In a letter sent to forest managers Monday, French informed them of the agency’s plans and wrote that “effective immediately” any forest management activities planned for old-growth stands in national forests would need to be reviewed and approved.

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Here’s the AP story.

I give them two Smokeys.
Apparently they had an interview with the Secretary as well.

Agriculture Sec. Tom Vilsack said the agency was adopting an “ecologically-driven” approach to older forests — an arena where logging interests have historically predominated

Does anyone remember New Perspectives and Ecosystem Management?

Past protections for older trees have come indirectly, such as the 2001 “roadless rule” adopted under former President Bill Clinton in 2001 that blocked logging on about one quarter of all federal forests.

As we know, the roadless rule didn’t actually “block logging.”

Under former President Donald Trump, federal officials sought to open up millions of acres of West Coast forests to potential logging. Federal wildlife officials reversed the move in 2021 after determining political appointees under Trump relied on faulty science to justify drastically shrinking areas of forest that are considered crucial habitats for the imperiled northern spotted owl.

Trump.. really?
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Here’s a press release from various ENGO groups (thanks for sending!).

Short summary.. this is a good first step but they would prefer to include mature trees.  Or “put the M back in OG.”

According to reports, the Biden administration will announce Tuesday a proposed nationwide forest plan amendment to advance protections for the last remaining old-growth trees in U.S. national forests. President Joe Biden has said these trees are critical components of the nation’s fight against the climate and extinction crises. The proposal, if adopted, would add new restrictions on logging and is a step toward fulfilling the promise of the president’s April 2022 Executive Order, which directs the Departments of Agriculture and the Interior to address threats to mature and old-growth forests on federal lands as a natural climate solution and develop policies to conserve them.

Members of the Climate Forests Campaign, a coalition of more than 120 organizations working to protect mature and old-growth trees and forests on federal land, welcomed the announcement as an important step forward while urging the Forest Service to pursue steps to protect mature trees. Both old-growth and mature forests are essential to removing climate-warming carbon pollution from the air and storing it, safeguarding wildlife, and providing clean drinking water for our communities.

The vast majority of old-growth forests have already been logged. Most that are left are largely on federally-managed public lands. As of November 2022, the Climate Forests Campaign had identified numerous timber sales targeting at least 370,000 acres of mature and old-growth forests for logging on federal land.

In addition to storing huge amounts of carbon and keeping it out of the atmosphere, mature and old-growth forests also provide essential wildlife habitats and are the most fire-resilient trees in the forest. As the world experiences record-shattering heat and widespread climate disasters, protecting these forests is critical to prevent the worst consequences of climate change.

The public will have an opportunity to weigh in on the proposal in a public comment period.

In response, environmental advocates issued the following statements:

“Protecting our old growth trees from logging is an important first step to ensure these giants continue to store vast amounts of carbon, but other older forests also need protection,” said Randi Spivak, public lands policy director with the Center for Biological Diversity. “To fulfill President Biden’s executive order and address the magnitude of the climate crisis, the Forest Service also needs to protect our mature forests, which if allowed to grow will become the old growth of tomorrow.”

“The Biden administration’s proposed plan to protect old-growth trees across the country is an important milestone for forest conservation and U.S. progress in addressing the climate crisis,” said Earthjustice senior legislative representative Blaine Miller-McFeeley. “Even as it works to complete this proposal, the Forest Service must take steps to fulfill President Biden’s executive order by also developing protections for mature trees, which are our future old-growth and exist in much greater numbers than old-growth, storing vast amounts of carbon. We look forward to working with the Forest Service to help it safeguard mature and old-growth forests. Conservation of these forests goes hand in hand with addressing the threat of wildfires as older and larger trees tend to be the most fire-resistant.”

“Americans love our forests. They’re natural playgrounds for people and wildlife alike. That’s why more than half a million people this summer asked the Forest Service to protect mature and old-growth trees and forests,” said Ellen Montgomery, Public Lands Campaign Director with Environment America. “Our mature and old-growth trees provide critical wildlife habitats, filter drinking water for communities and absorb and store tons of carbon. We’re really pleased that the Forest Service has taken this unprecedented step and we urge them to take actions to protect mature forests. To have a future where we have more old-growth, not less, it is critical to protect mature forests as well.”

“The Administration has rightly recognized that protecting America’s mature and old-growth trees and forests must be a core part of America’s conservation vision and playbook to combat the climate crisis,” said Garett Rose, senior attorney at NRDC. “This announcement is an important step toward meeting these goals. The Forest Service should move forward to develop the strongest possible safeguards for these forests.”

“Oregon Wild has been working to protect old-growth forests for 50 years. With today’s action, President Biden is taking a major step forward in protecting these national treasures,” said Lauren Anderson, Climate Forest Program Manager with Oregon Wild. “We look forward to working with his administration to implement this policy, and to ensure that mature and old-growth forests across the country are protected.”

“Our ancient forests are some of the most powerful resources we have for taking on the climate crisis and preserving ecosystems,” said Sierra Club Forests Campaign Manager Alex Craven. “We are pleased to see that the Biden administration continues to embrace forest conservation as the critical opportunity that it is. This amendment is a meaningful step towards averting climate catastrophe, safeguarding vulnerable ecosystems, and fulfilling President Biden’s commitment to preserve old-growth and mature trees across federal lands.”

“We applaud the Biden Administration for taking a significant step towards increasing protections for our nation’s endangered old-growth forests,” said Zack Porter, Executive Director of Standing Trees, an organization that works to protect and restore public lands in the six-state New England region. “But the reality is that more than 99.9% of old-growth forests in New England have already been cut down. For the climate and biodiversity, the Forest Service must put an end to destructive mature forest logging that prevents the recovery and expansion of old-growth forests across the US. We are buoyed by today’s announcement, and remain optimistic that the Forest Service will take further action to secure protections for America’s future old-growth forests.”

“Mature and old- growth forests are an essential component of a broader climate-crisis solution – but only if we protect them from logging,” said Adam Rissien, Rewilding Manager with WildEarth Guardians.  “Today’s announcement by the Forest Service establishes necessary and long-overdue protections for old growth forests, limiting when they can be cut and sold commercially. Taking the next step and developing a national rule covering both mature and old-growth would deliver on the Biden administration’s commitment to protect these trees once and for all.”

USFS Has a Sense of Humor About Cybertruck Video and MVUMs

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Clean Technica had an article about this. Apparently a Cybertruck got stuck and a video was making the rounds of a Ford truck pulling it out. Never folks to pass up an opportunity for public education, the Stanislaus NF weighed in.

Last week, a video of the stuck truck was making the rounds on social media. The vehicle was a little ways off the nearest forest road and appeared to be in use to pick up a Christmas tree. But, it didn’t have the right tires for conditions, and was good and stuck. But, even with better tires, there are doubts out there about whether the vehicle has a decent all-wheel-drive system or has some other problem that’s keeping it from being able to tackle off-road challenges.

At the other end of the tow cable is a Ford pickup. This led to Ford CEO Jim Farley making it clear that this was not a planned photo-op of any kind. A Ford truck’s owner really just happened to be there to help.

Here’s the video.

 But, instead of chewing Tesla out for having an employee go off established roads, managers took it for an educational opportunity. In a tongue-in-cheek manner, the agency asked Tesla to partner with the on educating the public about motor vehicle use maps (MVUMs), which specify where vehicles are allowed, as well as where vehicle-based “boondock” camping can be legally done.

“We are always thrilled when new opportunities to explore our public lands become available,” said Stanislaus National Forest Supervisor Jason Kuiken. “But feel there may be work to be done in educating users about our Motor Vehicle Use Maps (MVUM). We feel confident that had the driver of the Cybertruck had a better understanding of the topographical feature indicated on our maps, practiced Leave No Trace principles, and generally been more prepared, this whole incident could have been not only avoided, but also provided much-needed education to many new off-road users.”

The supervisor also poked fun at the problem of software updates.

“You never have to worry about a software update at an incredibly awkward moment with one of our MVUM maps,” Kuiken said. “We would invite executives of Tesla Motors to sit down at the table with us and develop an educational experience for new Cybertruck owners. We expect we could see this excited new user base joining our well-established OHV community and want to ensure we’ve done everything to create a positive user experience.”

You don’t need 3 G 5 G nor any other G for MVUMs either which can be a plus.

Here’s the Forest’s Facebook post in its entirety for those of you avoiding FB.

Stanislaus National Forest Looks to Partner with Tesla Motors
Release Date: Dec 14, 2023

SONORA, Calif. (December 14, 2023) – For car enthusiasts, the recent sightings of Tesla’s Cybertruck vehicle across National Forest Lands in California is exciting. However, with the increasing number of incidents involving the immediately recognizable vehicle, Forest Managers are eager for the opportunity to partner with Tesla Motor Corporation on an education campaign regarding off-road vehicle use on public lands.

“We are always thrilled when new opportunities to explore our public lands become available,” said Stanislaus National Forest Supervisor Jason Kuiken. “But feel there may be work to be done in educating users about our Motor Vehicle Use Maps (MVUM).”

Kuiken was responding to a recent incident on the Stanislaus National Forest involving a Tesla Cybertruck that apparently lost traction and slid down an embankment on a well-known Off-Highway Vehicle (OHV) area on the Forest’s Calaveras Ranger District while harvesting a Christmas tree in a moment that has since gone viral on social media.

“We feel confident that had the driver of the Cybertruck had a better understanding of the topographical feature indicated on our maps, practiced Leave No Trace principles, and generally been more prepared, this whole incident could have been not only avoided, but also provided much-needed education to many new off-road users.”

Across the U.S. Forest Service’s Region 5 (encompassing all of California, Hawaii, and other Pacific Island Partners) there are more than 15,867.8 miles of trails of which more than 5,000 are motorized.

“This number does not include our vast road system,” noted Christina Henderson, Region 5 Acting Public Services Director.

To that end, Kuiken is proposing a new, educational partnership between the Stanislaus National Forest and Tesla Motors.

“You never have to worry about a software update at an incredibly awkward moment with one of our MVUM maps,” Kuiken said. “We would invite executives of Tesla Motors to sit down at the table with us and develop an educational experience for new Cybertruck owners. We expect we could see this excited new user base joining our well-established OHV community and want to ensure we’ve done everything to create a positive user experience.”

#KnowBeforeYouGo #RecreateResponsibly #DiscoverTheForest California National Forests U.S. Forest Service

 

A Revisit with Chief Thomas on the Eve of a New Journey Down the Old-Growth Trail

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Jack Thomas in the Eagle Cap Wilderness, Oregon, August 1996.

 

Since this could be 2023’s Old Growth Week, based on a stakeholder update planned for tomorrow with news of some MOG policy, I thought it might be fun to go back in time to the 90’s, 92, to be exact, and see how far we’ve come on the Old Growth issue. We can revisit Chief Jack Ward Thomas’s 1992 Albright Lecture. It’s interesting to think about what has or has not changed, with the increased focus on climate change, carbon and wildfire- and what hasn’t, in the last thirty years.  And to think about where the issue will be in the next thirty years.  Will we still be fighting about it?  Will old growth be dead from climate change or burned up or …? Or will we have finally reached some kind of peace, in the direction that Chief Thomas describes.

It’s got a bit about planning and is worth rereading in its entirety, but I picked out a few excerpts below.

HA! Things Are Not What They Seem

Perhaps, further down line, it will be possible to discern exactly the attributes of owl habitat. If so, perhaps such habitat can be provided through innovative silviculture (Thomas et al. 1990).

Aha! So it is simply a question of habitat for spotted owls. If we can provide for owls with appropriate silviculture, there will be no need for reserving mature and old-growth forests. But, on the other hand, other species of plants and animals have evolved with or are disproportionately associated with old-growth. Some of these species will, almost certainly, end up in threatened status.

Aha! This is not only a question about owl habitat. It is, really, a question of old-growth management. But, the attributes of old-growth that provide the niches that support the animal species interact in mysterious ways to make up a forest ecosystem.

Aha! So, it is not really an old-growth question. It is an ecosystem question.

But, increasing knowledge indicates that the sizes, distribution, and connectivity between habitat patches are critical variables to consider in ensuring that the peculiar ecosystem retains the full inherent complement of species and ecological processes (Thomas 1979, Nass 1983, Harris 1984, and Probst and Crow 1991).

Aha! The issue is not just an ecosystem question. It is an ecosystem question and at landscape scale.

But, some people devoted to the preservation of old growth know or care little about the biological aspects of the issue. They simply see great beauty in the old-growth forests. Some perceive a spiritual value in the contact with and the existence of such forests.

Aha! So, it is not only a question of biological attributes but also of aesthetic and spiritual values.

But, if it is an ecosystem question that must be addressed at the landscape scale, what must this landscape accommodate? There are people in that landscape – part and parcel along with the plantations, the “ancient cathedral” forests, clearcuts, the elk and owls, and the streams and fish.

These people have desires, differing values, and untold aspirations that demand satisfaction. Each sees and wants different things from the landscape of which they too are part. And, they want their children and grandchildren to have these same things.

Aha! Then it really is an ecosystem sustainability question at a geographic scale where protection of nature, the production of goods and services for people, and the lifestyles of forest users must strike an enduring balance.

How do we do that?

And this..

Will the path we have been on for 50 years take us and our forests to a desired future state?

Consider the following. The first word in the pairs of words is where we have been and are. The second word is what we need to cultivate within ourselves to do a better collaborative job of stewardship. These word pairs are:

functional-interdisciplinary;
competitive-cooperative;
reductionist-holistic;
deterministic-stochastic;
use-value;
linear-interdependent;
rain in g-education;
simplify-diversify;
short term-long term;
site-landscape;
individuals-communities;
gladiator-diplomat;
rigid-flexible;
clever-wise; and
narrow-broad.
But, the fighting goes on and accelerates infrequency and intensity. The people, our sense of community, and the forest are bruised and battered in the process. The gladiators never tire of the fight – it is what they do. The fight itself provides their sustenance. I detect, however, that many concerned about forests we collectively own have long since approached exhaustion.

That may be good news, for with exhaustion, there may come a willingness to seek an answer to the statement made earlier, “There must be a better way.”

That better way can be built on new knowledge and past experiences and on changes in personal and societal concepts. And, that better way can be embraced because the old way has led us to a place where we cannot stand for long.

Shakespeare said (Julius Caesar, Act 1, Scene 2) “…the fault, dear Brutus, is not in our stars, but in ourselves…”

If the fault lies within us, the solution also resides in us as well.

Jack, .. we’re still on the path you laid out.. still looking for the diplomats. If you and your upstairs associates can help, we’d like to put in a request for more of these.

GAO Report on Agency Use of Artificial Intelligence-Forest Service Applications

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I was curious about what the FS is  doing so looked it up here on the USDA list.

Below are the FS entries.. my instinct would say that there are probably more, at least in R&D, that use machine learning.

Development and AcquisitionIn-house
Ecosystem Management Decision Support System (EMDS)USDAForest ServiceEMDS is a spatial decision support system for landscape analysis and planning that runs as a component of ArcGIS and QGIS. Users develop applications for their specific problem that may use any combination of four AI engines for 1) logic processing, 2) multi-criteria decision analysis, 3) Bayesian networks, and Prolog-based decision trees.Operation and ManagementContracted
Wildland Urban Interface – Mapping Wildfire LossUSDAForest ServiceThis is a proof-of-concept study to investigate the use of machine learning (deep learning / convolutional neural networks) and object-based image classification techniques to identify buildings, building loss, and defensible space around buildings before and after a wildfire event in wildland-urban interface settings.Development and AcquisitionIn-house
CLT Knowledge DatabaseUSDAForest ServiceThe CLT knowledge database catalogs cross-laminated timber information in an interface that helps users find relevant information. The information system uses data aggregator bots that search the internet for relevant information. These bots search for hundreds of keywords and use machine learning to determine if what is found is relevant. The search engine uses intelligent software to locate and update pertinent CLT references, as well as categorize information with respect to common application and interest areas. As of 2/24/2022, the CLT knowledge database has cataloged >3,600 publications on various aspects of CLT. This system fosters growth of mass timber markets by disseminating knowledge and facilitating collaboration among stakeholders, and by reducing the risk of duplication of efforts. Manufacturers, researchers, design professionals, code officials, government agencies, and other stakeholders directly benefit from the tool, thereby supporting the increasing use of mass timber, which benefits forest health by increasing the economic value of forests.Operation and ManagementContracted
RMRS Raster UtilityUSDAForest ServiceRMRS Raster Utility is a .NET object oriented library that simplifies data acquisition, raster sampling, and statistical and spatial modeling while reducing the processing time and storage space associated with raster analysis. It includes machine learning techniques.Operation and ManagementIn-house
TreeMap 2016USDAForest ServiceTreeMap 2016 provides a tree-level model of the forests of the conterminous United States. It matches forest plot data from Forest Inventory and Analysis (FIA) to a 30×30 meter (m) grid. TreeMap 2016 is being used in both the private and public sectors for projects including fuel treatment planning, snag hazard mapping, and estimation of terrestrial carbon resources. A random forests machine-learning algorithm was used to impute the forest plot data to a set of target rasters provided by Landscape Fire and Resource Management Planning Tools (LANDFIRE: https://landfire.gov). Predictor variables consisted of percent forest cover, height, and vegetation type, as well as topography (slope, elevation, and aspect), location (latitude and longitude), biophysical variables (photosynthetically active radiation, precipitation, maximum temperature, minimum temperature, relative humidity, and vapour pressure deficit), and disturbance history (time since disturbance and disturbance type) for the landscape circa 2016.Operation and ManagementIn-house
Landscape Change Monitoring System (LCMS)USDAForest ServiceThe Landscape Change Monitoring System (LCMS) is a National landsat/sentinal remote sensing-based data produced by the USDA Forest Service for mapping and monitoring changes related to vegetation canopy cover, as well as land cover and land use. The process utilizes temporal change classifications together with training data in a supervised classification process for vegetation gain, and loss as well as land cover and use.Development and AcquisitionIn-house
Geospatial and Remote Sensing Training CoursesUSDAForest ServiceSeveral courses are offered which teach the use of software and scripting which allow for machine learning.  The courses change, but current topics include Intro and Advanced Change Detection, eCognition (software package), Geospatial Scripting for Google Earth Engine.  Some of the courses show how to use Collect Earth Online.Operation and ManagementIn-house
Forest Health Detection MonitoringUSDAForest ServiceMachine learning models are used to (1) upscale training data, using Sentinel-2, Landsat,  MODIS, and lidar imagery, that was collected from both the field and high-resolution imagery to map and monitor stages of forest mortality and defoliation across the United States, and (2) to post-process raster outputs to vector polygons.

Here’s a link to the GAO report. I have some concerns about AI use, as it is another layer between the real world and decisions by humans.  If trust is about transparency and accountability, we’d want to make sure that the uses and what’s under the hood would be publicly reviewed..regularly.  “Whoops, the AI told us to!” might become an off-ramp for accountability for, say, fire errors and make “lessons learned” the domain of the app and not  firefighters. What could go wrong? I imagine many things. Seems like there might need to be a discussion around “social license” with this technology.

There’s actually an AI Accountability Framework:This is pretty common-sensical, but it seems like we have more government employees, contractors and partners, in general describing what other people should do rather than actually doing anything, making sure that contractors are doing things, or checking on their work. And it does mention “engaging stakeholders.”

As AI technologies continue to advance at an incredible speed, federal oversight needs to evolve alongside them. GAO’s AI accountability framework can help federal agencies and others use AI responsibly.

This framework is organized around four complementary principles:

  • Governance—promote accountability by establishing processes to manage, operate, and oversee implementation
  • Data—ensure quality, reliability, and representativeness of data sources and processing
  • Performance—produce results that are consistent with program objectives
  • Monitoring—ensure reliability and relevance over time

AI Accountability Framework

AI Accountability Framework

I thought that this was interesting from the new report:

“Commerce reported the use of AI for satellite-based fire detection and intensity products combined with fuel, elevation, and weather data to determine the probability of rapid intensification and spread of wildfires.”

Commerce? Was that an error?  Maybe Congress could ask GAO (or an AI app for GAO) to identify how many agencies are funding what appear to be identical scientific projects?Anyway, here are some background info I selected from the GAO report.I particularly liked NISTs “that can.. generate outputs such as predictions, recommendations or decisions influencing real or virtual environments. AI systems are designed to operate with varying levels of autonomy.” Here are the FS entries.. my instinct would say that there are probably more, at least in R&D, that use machine learning.

COP Nuclear Pledge and Federal Land Choices

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For those of you not following the COP, the US signed a Declaration to Triple Nuclear Energy. The Department of Energy posted it here.

Commit to supporting the development and construction of nuclear reactors, such as small modular and other advanced reactors for power generation as well as wider industrial applications for decarbonization, such as for hydrogen or synthetic fuels production;

Recognize the importance of promoting resilient supply chains, including of fuel, for safe and secure technologies used by nuclear power plants over their full life cycles;

When it comes to federal lands and various energy forms, I’m not surprised that some folks who are physically close to the new infrastructure, be they mines, solar arrays, turbine fields or geothermal do not want them (this differs by area and kind of infrastructure), and many times folks like our friends at CBD are against them for biodiversity reasons.  It’s problematic and a ripe field for litigation.

These different energy forms also differ by the need for new power lines. Power lines being both sources of wildfire and wildfires causing danger to them.  Meanwhile our current power line infrastructure is in bad shape, and power companies can go bankrupt for damages from inadequately managing the power lines.  As far as I can tell, the cost of constructing and maintaining these new power lines is not taken into account when accounting is done for new energy sources. And permitting issues will slow down any build-out of new transmission lines.

Enter C2N . The Breakthrough Institute wrote a piece on a strategy for coal to nuclear (C2N).

The Breakthrough Institute proposes a U.S. Department of Energy (DOE)-led program aimed at alleviating regulatory uncertainty. This program would assess retiring CPP sites nationwide, categorizing and prioritizing them based on local need for power, remediation, viability of existing infrastructure, and demand for workforce transition. Under the Energy Policy Act of 2005, the DOE can apply for an ESP to conduct site-specific evaluations of a location with potential for a nuclear power plant before the actual construction and operation of the facility begin. This process allows the DOE to assess the suitability of the site and address any potential safety and environmental concerns in advance. The proposed program targets eligible sites with transferable workforces and essential infrastructure, helping to facilitate a seamless transition for C2N projects. In the proposed program, the DOE’s role will be to mass-acquire ESPs for multiple eligible C2N sites and subsequently to transfer those permits to utility companies and developers to recover the costs.

You could add environmental justice concerns of various kinds and community support to the list of criteria.  It might be a better “workforce transition” than many; involving high-skilled union jobs. Best of all, from the federal lands perspective, and the cost perspective,  the transmission structure already exists.

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The other story is called History of U.S. Uranium Industry: Decoupling Past Practices from Future Endeavors

Side story: I did my Ph.D. dissertation so long ago that the Forest Service had only the Data General and PCs were not around.  Because the Forest Service determined that I had done my graduate work without their funding, I was not allowed to use the FS computer for my dissertation.   I worked at the Supervisor’s Office in Lakeview, Oregon.  So I found a woman in town that could type it for me.  She worked at the Lakeview Lumber mill, so my little Mazda hatchback would wait in line with the log trucks so I could get to the window and hand her my drafts.  Now I wish someone had taken a photo of my tiny car amid the trucks, but.. cameras on cell phone were a long way away.  Some of you might wonder “what on earth does that story have to do with uranium”? But former and current Lakeview folks know that Lakeview Lumber was/ is? located on the former uranium processing site. The Fremont had two uranium mines, the White King and the Lucky Lass, which apparently went into the nuclear weapons program.

Anyway, back to the Breakthrough story..

Past uranium mining practices loom over the future of U.S. prospects. Beyond question, the uranium mining industry of the late 1940s through the early 1980s has inflicted significant harm upon workers and local communities, particularly Navajo and Hopi people who continue to face environmental and health risks from un-remediated uranium mines that still lie abandoned across their ancestral homelands. The American people and the U.S. federal government must take responsibility by compensating citizens exposed to pollution and redoubling public funding and agency efforts to clean up abandoned mine sites.

Weaponizing mining misrepresents nuclear power efforts. At the same time, rhetorical efforts to frame Cold War-era tragedies as the unforgiving, original sin of the domestic uranium mining industry and by extension the civil power sector are undeniably misrepresenting history and do little to contextualize the past, present, and future of uranium mining for nuclear fuel production. Addressing unquestioned perceptions is vital for the advancement of low-carbon nuclear power during the industry’s decades-long period of inactivity.

The analysis presented herein investigates the timeline of the U.S. uranium industry during the Cold War era to delineate causes of the historical malpractices, emphasizing the following major points:

  • Environmental impacts from uranium mining arose from the absence of environmental laws and regulations from the late 1940s to the early 1980s, an issue common to the overall U.S. mining sector with uranium mines constituting only a fraction of abandoned mine lands. The vast majority of historic domestic uranium production occurred during this period of accelerated nuclear weapons and defense-related production, before the federal government enacted even the most basic safeguards in place today;

  • Federal agencies undeniably could have been more proactive in mitigating impacts of radiological health hazards to laborers. Instead, they engaged in willful complacency, presumably influenced by the need to maintain uranium supply chains for national defense purposes and weapons programs. To a lesser degree, state agencies and mine operators were in similar positions motivated by their own respective interests;

  • Despite low rates of production, the domestic uranium mining industry has operated responsibly since the end of the Cold War with the establishment of environmental and health standards as part of regulatory reform efforts targeting the overall mining sector;

  • The majority of growth in uranium demand for U.S. civilian nuclear fuel supplies for energy production occurred following these key reforms, suggesting that arguments framing the expansion of the U.S. civil nuclear sector as irrevocably synonymous with legacy uranium mining impacts are selectively misstating the historical record.

Nevertheless, the future of uranium mining is not impervious to the potential occurrence of new injustices. In the broken checkerboard of Navajo Nation lands near the site of the 1979 Church Rock uranium tailings dam failure and other uranium industry superfund sites (EPA Church Rock; EPA Homestake; EPA Jackpile), Canadian firm Laramide Resources’ recent quiet commencement of uranium exploration activities (NMPR, 2023) highlights the risk that the mining sector could continue to aggravate tensions with local communities by failing to engage deeply and demonstrate a strong commitment to sharing benefits and reducing risks. While on paper, Laramide may be proceeding in line with regulations, this illustrates a case where Laramide’s social license to operate depends critically upon its willingness to undertake outreach efforts and make community guarantees well above and beyond the requirements of written law.

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When President Biden was working on the new Grand Canyon National Monument, E&E had this story.

Most monument proclamations since 1996 have barred new mineral leases, mining claims, prospecting or exploration activities, while carving out protections for valid, existing rights, according to a recent report from the Congressional Research Service.

Legal experts say it could also throw existing claims into question unless companies can show they can mine the claim at a profit.

“It’s frankly very unlikely that any existing claims would be valid,” said John Leshy, who served as Interior’s solicitor during the Clinton administration and is now an emeritus professor at the University of California College of the Law in San Francisco. “But that’s a fact question, and you’d have to go claim by claim.”

Companies eager to mine in the area have argued they have valid and existing rights. What’s more, mining advocates say a national monument designation would throw Biden’s own climate and national security strategy into question.

They’re quick to note that the U.S. currently relies on Russia for a share of its low-enriched uranium. And with the war in Ukraine pushing up prices, they argue the need for advancing extraction and rebooting idled mines has only grown in importance.

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I don’t know how all this will turn out.. it seems like one way would be to estimate how much and what kind of uranium the US would need to live up to its COP commitment, considering recycling and whatever today’s current technologies are. Then assume we can still import from Canada and the Aussies. Then figure out how much we need, and do a programmatic EIS comparing different strategies/places the uranium could be mined and processed.

Yes, whose ox gets gored will always be a political decision. But at least the public would know the pros and cons of the choices.  Which might increase public trust.

MOG Proposal-Soon To Come Out as Plan Amendments Not Regulation

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Despite MOG not being on the regulatory agenda as I posted yesterday, within minutes I heard that it is coming out soon. Because it won’t be a regulation but rather a bunch of plan amendments, so that explains it, I guess.  I was hoping, based on climate and wildfire emergencies  for each forest to do a fire plan amendment focusing on delineating and maintaining PODs and fuelbreaks, plus fire use, so maybe there is some of that in there.

Here’s a story from E&E News.

The Biden administration is closing in on a proposal to protect old-growth forests on federal land while allowing some tree thinning and timber harvesting, groups familiar with the basic outlines of the plan said.

While the fine details of the proposal, to be published in the Federal Register within days, are closely guarded, policy groups said they expect the Forest Service to pursue forest plan amendments across the 193 million-acre national forest system that would limit — but not necessarily eliminate — logging in remaining old-growth stands.

The Forest Service referred questions to the Department of Agriculture, which didn’t immediately return a request for comment. The actions stem from an April 2022 executive order from President Joe Biden directing an inventory of mature and old-growth forest on federal land and measures to protect those areas for carbon sequestration and other purposes.
By amending forest plans — which are the guiding documents for managing each forest — the USDA would avoid the more lengthy route of proposing a formal rulemaking that would go past the current Biden administration. Still, forest plan amendments are subject to public comment periods that would stretch a few months, and there’s no guarantee that they’ll
proceed free of legal challenges that could delay or derail the process.
The environmental impact statement associated with a forest plan amendment would also take considerable staff time for an agency that’s already acknowledged being stretched.
Groups in contact with the Forest Service said they don’t expect the administration to address “mature” forests — or those that haven’t quite reached old-growth status — at length in this proposal, which would be a disappointment to environmental organizations that say those forests, too, deserve greater protections.
The administration’s actions could bring more consistency to managing old growth around the country, said Sam Evans, senior attorney with the Southern Environmental Law Center in Asheville, N.C.
“Protecting and restoring older forests is mission critical for the Forest Service. Across the board, it’s the single best way to protect rare species, store carbon, provide clean water and increase resilience to wildfire,” said Evans, who leads the organization’s national forests and parks program. Evans said forest plans are “wildly inconsistent” in how they treat areas of old growth, which can be areas that were never logged or have over time taken on similar characteristics.
The plan for the Nantahala and Pisgah national forests in North Carolina allows for logging old growth to encourage the creation of younger forest, for instance, while the Custer Gallatin National Forest in Montana requires projects to “retain old growth characteristics” while allowing projects in old-growth areas as part of meeting that objective, he said.
“There’s really no excuse for the lack of consistency. Cutting old growth in some places while protecting it in others will never make any real progress toward restoring our forests,” Evans said.
Seeking a consistent approach from one end of the country to the other presents its own challenges, advocates of a more intensive management approach say, because protecting an old-growth forest in fire- and drought-prone California, for instance, may require different approaches from protecting old growth in the rainforests of Alaska or the hardwood forests of the eastern U.S. And while some environmental groups say logging is the greatest threat to old-growth forests, the Forest Service is casting threats such as climate change and associated drought, wildfire, disease and pests as the main dangers — which can be addressed through a more intensive approach to managing forests.

In some places, the Forest Service continues to pursue timber sales in old-growth stands even though Biden pledged through an executive order to protect old-growth forests as a pillar of his climate policy.

I keep hearing this on various webinars and have asked the individuals for names of projects.  With regard to ones I’ve looked at, thinning in old forests, it’s intended to protect old trees in old-growth forests.

A lobbyist who works with the wood products industry said revising forest plans to reduce management — which can include thinning to reduce the spread of wildfire as well as larger-scale logging — misses an industry point: that healthy forests and such projects go hand in hand. “Millions of acres of forests of all ages are vulnerable to fires, insects and disease — which the Forest Service says are the leading causes of forest loss across the National Forest System,” said the lobbyist, who was granted anonymity to protect relationships with the administration. “Yet the administration is forcing the Forest Service to revise over 120 forest plans to impose further restrictions on management. This is an intentional distraction from the mission Congress has assigned to the Forest Service, which is reducing hazardous fuels and protecting communities from wildfires.”

There are lots of us out here that, again, don’t have a timber industry, but still want fuel reduction projects to go ahead.  Maybe we need to start an interest group (Wildfire Resilience Forever?) so we’ll get interviewed?

Forest plans have already become a battleground on the mature and old-growth issue, as critics of large-scale logging say the Forest Service is taking an overly permissive approach that collides with Biden’s executive order, which promised to “institutionalize climate-smart management and conservation strategies that address threats to mature and old-growth forests on Federal lands,” and will be the basis for how the Forest Service determines how and where trees can still be cut to meet the goal.

In October, for instance, the Center for Biological Diversity filed an objection to the new forest plan for the Grand Mesa, Uncompahgre and Gunnison national forests in Colorado. Among other complaints, the CBD said the forest plan — which was being developed at the time Biden issued the executive order — doesn’t do much to protect old-growth areas, although it does discuss retaining areas for wildlife habitat and says older trees store the most carbon.

On the other hand, the CBD said, the forest plan doesn’t include an accounting of how much old growth is present on the forests, and it specifically calls for removal of larger trees that the agency said may be most susceptible to beetle infestation. The Forest Service said in the forest plan, “This will temporarily reduce the live tree carbon pool but may increase the rate of carbon uptake and resilience to future disturbance.”

The idea that the GMUG didn’t count the old-growth seems unlikely to me but I will check.

However the administration proceeds, Congress will be tracking the issue as it crafts a new five-year farm bill in 2024, delayed from this year. That legislation’s forestry provisions will protect broad uses of national forests, including for timber production, House Agriculture Chair Glenn “G.T.” Thompson (R-Pa.) told E&E News on Tuesday.
“We want healthy forests, and that means regular harvesting and replanting,” Thompson said. “We’ll see what they say, and then we’ll tell them what they need to do with the farm bill.”

Can’t wait to see what they came up with!

Nez Perce Clearwater Forest Shrinks Great Burn (Recommended) Wilderness

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The details of this plan are outside my range of knowledge, but I thought this story was interesting.  First of all the headline, “shrinks Great Burn Wilderness”. Of course, forest plans can’t actually do that, so I looked further and the plan reduces the Recommended Wilderness.  Which of course is not the same thing. Headlines.. sigh.

The Nez Perce-Clearwater National Forest supervisor trumpeted her new forest plan as the best compromise for all, but when it comes to proposed wilderness, both advocates and opponents disagree.I’m not a fan of using the word “trumpeted”.   It seems like there’s been “emotional wording” inflation since folks discovered that emotions drive engagement which drives bucks in internet world.

The story has many quotes from Probert, the Forest Supe,  the Great Burn Conservation Alliance executive director Hayley Newman,  and other ENGO folks.

“The Forest Service has sat back while illegal motorized use has encroached on the Great Burn for years, and now it’s decided to reward illegal use by rewriting the forest plan to make it okay,” said Maddy Munson, Wild Montana Public Lands director.

Newman said one forest – the Nez Perce-Clearwater – shouldn’t be allowed to diminish a wilderness that’s partially managed, and managed differently, by another forest: the Lolo. For example, the Lolo Forest recently designated the mountain goat as a species of concern while the Nez Perce-Clearwater has not. Plus, one forest plan might sway another, said Katie Bilodeau, Friends of the Clearwater staff attorney.

Yes, plans done on a forest by forest basis may not harmonize across boundaries. The idea of “swaying” is interesting. Conceivably earlier plans may make it easier for the next plan to make the same kinds of choices.  I don’t see that that is good or bad necessarily unless you don’t like ideas in the earlier ones.. but that could work both ways “hey that forest gave us an extra 100K of RW, so you should too!”

I thought that this was interesting.

In her decision rationale, Forest Supervisor Cheryl Probert said the question of what to recommend as wilderness garnered the most public interest of all aspects of the draft forest plan released in December 2019, accounting for 18% of almost 20,000 comments.

Different forests have people interested in different things during planning and apparently wilderness is big there.

Probert said she’d heard about the need to protect wolverine and mountain goats but also heard complaints from snowmobile users who said that “there are no replacements for the opportunities provided here.” She asked opposing groups to come up with a compromise, but none came. So she carved the area up to create one.

I don’t know if it’s just the way it’s reported, but it sounds like she herself did it. I’m thinking it’s likely that her staff and she had many discussions and they probably didn’t all agree.  It sounds kind of dismissive “she carved up” versus, say, “after a series or far-ranging discussions with members of the public, interest groups,  elected officials, she and her staff came up with this proposal as a possible solution.”

In fact, wilderness groups want the Forest Service to enlarge the Great Burn Wilderness to encompass adjacent roadless areas to the west, an addition of 40,000 acres. But, Probert bypassed three plan alternatives with more recommended wilderness – between 309,000 and 857,000 acres – preferring an alternative with just 197,700 acres of proposed wilderness.

However Probert did propose one new wilderness, Meadow Creek, with almost 73,000 acres adjacent to the Selway-Bitterroot Wilderness south of the Selway River.

Hopefully some TSW readers, including motorized folks (apparently not interviewed for this article) will weigh in and add their perspective.  Just a thought.. there seem to be forest vegetation collaborative groups where people who disagree reach compromises.. this doesn’t seem common in recreation disputes (or is it?).  Maybe our social science friends have studied why that might or might not be the case.

Finally, did opening up the decision about Recommended Wilderness via plan revision lead to a better on-the-ground outcome in some way?  Did it encourage groups to work together, or just open a new arena for the same old battles?

 

PERC’s Payments for Elk Presence on Private Land

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‘Since I mentioned this in yesterday’s post, I thought I would post here. Here’s a direct way to pay people for ecosystem services.. which seems efficient. Plus there’s AI.. and local firms and people.

Paradise Valley, MT — The Property and Environment Research Center (PERC) today announced an innovative payment-for-presence program to compensate a rancher for providing elk habitat in Montana’s Paradise Valley.

Using advanced camera traps powered by artificial intelligence (AI) together with landowners’ innate knowledge of the land, this innovative program is the first of its kind in the region. Rather than paying ranchers for predator losses as traditional livestock compensation programs do, PERC’s payments are based on the presence of elk to specifically mitigate elk-livestock conflict.

Paradise Valley serves as an important wintering ground for the Greater Yellowstone Ecosystem’s migrating elk herds. As rapid development threatens wildlife habitat in the valley, ranchers and their large, open land holdings play a valuable role in maintaining ecosystem connectivity. Providing habitat, however, comes at a cost.

As the national leader in market solutions for conservation, Montana-based PERC works to develop incentive-based solutions that conserve wildlife habitat by helping mitigate those costs to landowners.

“Elk are often viewed as uninvited guests on a rancher’s property,” says PERC CEO Brian Yablonski. “Ranchers are essentially feeding the elk at great personal expense. Ultimately, we need these private open lands to remain intact if we want to conserve this unique migratory ecosystem, and paying ranchers ‘elk rent’  for providing this public good is a critical step toward accomplishing that.”

A minimum of 20 elk captured on camera across the ranch in a single day constitutes an “elk day” and triggers a financial payout to the rancher. A bonus payment is offered when 200 or more elk are captured in a single day, with a $12,000 cap on total annual payments.

Druska Kinkie, who along with her husband and son run Emigrant Peak Ranch, regularly sees 400-500 elk on her property during peak migration season. The heavy wildlife presence imposes costs through lost forage, fence damage, and the threat of disease transfer, namely brucellosis, a reproductive disease that is spread from elk and bison to cattle.

“This program has offered us a ray of hope,” said Druska Kinkie of Emigrant Peak Ranch. “We want to do right by the elk, but not at the expense of our livelihoods. Compensating their presence offsets the costs they impose, making the elk less of a liability for us.”

Jeff Reed of Grizzly Systems (left), Druska Kinikie of Emigrant Peak Ranch (center), and PERC’s Brian Yablonski (right)
Harnessing smart cameras to calculate elk rent

The new program brings together Emigrant Peak Ranch and Grizzly Systems, a local technology firm that uses advanced AI camera traps with an integrated software platform. The advanced technology helps differentiate between random movement such as grass blowing in the wind and actual wildlife detection.

Harnessing smart cameras to calculate elk rent

The new program brings together Emigrant Peak Ranch and Grizzly Systems, a local technology firm that uses advanced AI camera traps with an integrated software platform. The advanced technology helps differentiate between random movement such as grass blowing in the wind and actual wildlife detection.

To try capturing the number of elk on the ranch at any given time, the program relies on game cameras installed in key locations throughout the property. Over time, the AI technology will learn how to better identify elk, reducing the amount of data to analyze. The rancher can also take photos with her smartphone to augment the game cameras.

The pilot program is designed to test the payment-for-presence system as well as the efficiency of artificial intelligence game cameras with continuous refinement.

“We’re excited to test the potential of our technology in such an important region for wildlife,” said Jeff Reed of Grizzly Systems. “We appreciate PERC’s spirit of creativity and flexibility to explore what makes the most sense for ranchers and wildlife. As our technology evolves, so too can the model of this program, delivering more tailored results.”

PERC’s Paradise Valley payment-for-presence program is the fourth project out of PERC’s Conservation Innovation Lab, including Montana’s first elk occupancy agreement, the Paradise Valley brucellosis compensation fund, and the grizzly grazing conflict reduction project in the Gravelly Range. When conservationists help ranchers offset the costs wildlife impose, they’re ultimately helping sustain the wildlife themselves.

Learn more about this project.

The Need for NACs (or Not)

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There is a great story in E&E News about NACs or “natural asset companies.”

Investors could soon buy into companies trading on the New York Stock Exchange with a unique dual purpose: protect nature — including on public lands — and make money.
The Securities and Exchange Commission is currently weighing whether to clear the way for the NYSE to offer a new kind of investment known as “natural asset companies,” or NACs.
The idea proposed by the NYSE is to list companies with missions to improve ecosystems through management, maintenance, or restoration of public or privately-owned lands — and then put a dollar figure on the resulting benefits, like clean air or wildlife habitat.
The proposal so far hasn’t gotten much attention, but caught the notice of conservative lawmakers and property rights advocates. They’ve warned the companies could open a backdoor into strict management restrictions for public lands and waters — as well as foreign investment on federal lands — while raising questions about whether the investments are even viable.

But the financial services firm Intrinsic Exchange Group, which launched the idea two years ago and has drawn support from the NYSE and groups like the Rockefeller Foundation, says it would give investors interested in preserving nature a place to put their money.
“We were looking for a private-sector approach that wasn’t dependent on policy, it wasn’t dependent on traditional taxes, regulation or philanthropy to price in these assets and give investors the opportunity to invest directly in nature, whether that’s for climate or biodiversity,” said IEG Chair Douglas Eger.

I’m neither conservative nor a lawmaker, but I’m skeptical, at least based on this story.

Now I am way above my pay grade with talks of the SEC, but as I said with cap’n’trade, the financial sector does so well policing itself (think 2008, mortgage crisis) we should definitely reward them by handing over … the environment(!)… not.

I think there is a private sector approach to preserving nature.. it’s called “buying land.” Conceivably, people could get together, form a company to “buy land”, and take advantage of all the USDA and private programs (such as PERC talks about) to pay owners for preservation. Seemingly if you were a supporter of this idea, like say, the Rockefeller Foundation (with assets of $7,117,904,789,  you could actually buy quite a chunk!).

On the other hand, I looked at the company proposing this and their supporters

And many of them are in other countries. So maybe those countries have rules about foreigners buying land?

It seems to me that there are three different things that are not clearly delineated:
1. What they want to do in other countries
2. Willing buyer and seller of whatever (I don’t have a problem with that).
3. Selling contracts for certain kinds of management on public lands.

Eger compared their approach to improvements on public lands to a mining claim or a timber lease, or utilizing air rights on private lands.

Eek !Let’s not go back to 1872.. and public (federal) lands don’t actually have “timber leases.” When I think of these, mining claims tend to be limited in time and space; mine themselves are subject to NEPA and public comment (and, dare I say, litigation). Timber sales (and stewardship contracts) are made to carry out decisions agencies made with public involvement.

Instead of a lease to extract ore

There are actually two bills in Congress about redoing the 1872 Mining Act right now..claims are not “leases.”

or cut down trees,

Again, timber sales on federal land are not “leases” they are for specific actions for a specific period of time.

however, NACs would ink agreements granting them “ecological performance rights.” Where a successful mining claim is intended to result in the collection of ore, the value of the ecological rights would be judged on a series of factors, ranging from data on carbon storage and sequestration to more ephemeral qualities like the “sensory benefits” of a nice view.

Critics have targeted the concept as creating companies that would attempt to make money off monetizing aspects of nature that belong to everyone.
“This is creating this whole new category and monetizing things that nobody has a right to own,” said Margaret Byfield, the executive director of the American Stewards of Liberty, a property-rights-focused organization.

This is confusing, because if you were with a “property rights focused” organization, you’d be all for #2 but maybe not for #3.

In order to qualify as a natural asset company, a corporation would need to document how it is improving the lands included in its portfolio.
In broad strokes, a NAC is responsible for the “conservation, restoration, or sustainable management” of those lands, which commit to various goals, such as improving wildlife habitat or ensuring clean air.

But if you include “sustainable management,” what makes them different from BLM or the FS?

Based on these quotes, NYSE and IEG may not be on the same page.. NYSE is a #2 and IEG mentions #3.

“NACs — which have not yet been approved for listing — are a voluntary, free-market decision by a landowner to monetize their assets,” said NYSE spokesperson Lauren Sullivan.
In a document detailing the companies’ structure, IEG notes that lands “can be areas that are publicly owned, such as a national park, or tracts of privately owned property held by individuals or corporations.”

What do elected officials in states with large amounts of public land think about this?

“This rule has wide-ranging implications for the citizens of our states, specifically in our natural resources and agricultural industries,” Govs. Joe Lombardo of Nevada, Greg Gianforte of Montana, Mark Gordon of Wyoming and Brad Little of Idaho wrote in an October letter to the SEC.

The governors also questioned whether the Interior or Agricultural departments had been involved with the proposal. An Interior spokesperson declined to comment, and the USDA did not respond to a request for comment.

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Harris said another complication is the environmental statements and audits these companies would be required to produce — a potentially significant expense.
“The innovation here is that these companies are being given a mechanism by which they can credibly show that they’re doing what they say they’re doing,” Harris said. “And to give investors some confidence that they’re not rapaciously destroying the planet or the environment.”
Eger pushed back against that analysis, arguing that NACs will create a return on investment because individuals choose to value the environment, along with sustainable production of timber or agriculture.

I thought folks like SFC and SFI had already figured out what was sustainable; so conceivably companies that are certified are doing that, and people could invest in them directly.

“There’s no reason that we can’t set a price to ecosystem service,” Eger said. “Between a willing buyer and seller, the underlying becomes true. If they think that value is there, then it is there,” he said, comparing the idea to “the price of paintings or gold.”
He added that while some of the lands have an existing “production value,” whether because of agricultural or other uses, investors into NACs are supporting an “existence or appreciation value” of the benefits of those lands, like support for biodiversity or natural beauty.

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So some people would have the duty of checking on landowners to make sure that they were doing the things they were supposed to be doing, that they wouldn’t otherwise do without the payments.  But there are already a variety of agreements for paying people to do what they otherwise wouldn’t want to do. Folks like PERC have examples like paying for elk presence.

Here’s a link to a WSJ op-ed by the treasurer of Utah.

Why would anyone invest in a company that can’t make money? Initial buyers would likely be “impact investors,” committed to sacrificing returns to advance the climate agenda. But it seems clear the goal is to sell NACs to endowments, sovereign wealth funds, pension funds and other investors demanding greater direct and immediate ESG presence in their portfolio. Demand from “values-driven investing” alone could drive up NAC share prices even as the value of the assets they purchase decrease by virtue of the NAC’s ownership of them. More disturbing, reducing U.S. mineral extraction could be intriguing to Chinese, Russian or Saudi sovereign wealth funds.

Environmental offsets in the form of carbon credits or government transfers for “conservation uses” could also generate ostensible revenues.

I’m a bit leery of companies buying these things and then pressuring the government for more subsidies. Right now the subsidies go directly to landowner. Getting more financial and auditing middle-people requiring salaries may not be a terribly efficient way of meeting environmental goals. And how are we doing with carbon credits? It seems like where there is big money, there is also a tendency for questionable auditing.. check out this CAP article on carbon offsets.

Also, TNC already has an investment program which sounds a bit like the same thing, without the trading part. Maybe some of our financially-inclined readers can explain the difference?