Sharon

Proposed CEQ NEPA Regs: Interpretation Help Requested

by

I could use some help.. I’m working on comments for the Proposed CEQ NEPA regulations. Here’s a link to the redline.

Here’s what the White House said about it:

CEQ’s Bipartisan Permitting Reform Implementation Rule would modernize and accelerate environmental reviews under the National Environmental Policy Act (NEPA), encourage early community engagement, accelerate America’s clean energy future, strengthen energy security, and advance environmental justice

Sure.. doing more analysis and “accelerating environmental reviews” are the same thing (reminds me of the 2012 Planning Rule claims). Because if agencies involve the public sooner and do more analysis..everyone will agree and there won’t be litigation. And if there is successful litigation, it’s proof that those agency NEPA practitioners are doing things wrong – again. Ah.. the Circle of NEPA Life!

Anyway, the legal minds out there could really help me out by helping me understand if I am missing something. The Proposed Reg uses the term “vulnerable communities” which it doesn’t define. It also talks about “communities with environmental justice concerns.” Now conceivably, any community could have “environmental justice concerns”.. so that’s confusing to me.

The Proposed Reg does define environmental justice..

“(§1508.1 k) Environmental justice means the just treatment and meaningful involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision making and other Federal activities that affect human health and the environment so that people: (1) Are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers; and (2) Have equitable access to a healthy, sustainable, and resilient environment in which to live, play, work, learn, grow, worship, and engage in cultural and subsistence practices.”

If I read this correctly, it means “all people” so that community members are “fully protected from disproportionate and adverse health and environmental effects.” So I thought about say, new transmission lines and wind facilities, even offshore wind. It seems to me that every new facility would have at least some (certainly) disproportionate and (litigatably) adverse health and environment impacts. I don’t quite understand being “fully protected from ..health and environmental effects.. including those related to the legacy of racism or other structural or systemic barriers.”

Now as far as I can tell, the regs don’t say that agencies can’t do disproportionate things, but must analyze them in § 1502.16.

The potential for disproportionate and adverse human health and environmental effects on communities with environmental justice concerns.

***********
Never fear, though, the Council may actually streamline some particular NEPA compliance:

§ 1506.12 Innovative approaches to NEPA reviews.

(a) The Council may authorize an innovative approach to NEPA compliance that allows an agency to comply with the Act following procedures modified from the requirements of the regulations in this subchapter, to facilitate sound and efficient environmental review for actions to address extreme environmental challenges consistent with section 101 of NEPA. Examples of extreme environmental challenges may relate to sea level rise, increased wildfire risk, or bolstering the resilience of infrastructure to increased disaster risk due to climate change; water scarcity; degraded water or air quality; disproportionate and adverse effects on communities with environmental justice concerns; imminent or reasonably foreseeable loss of historic, cultural, or Tribal resources; species loss; and impaired ecosystem health.

Note that “increased wildfire risk” is on the list.. as is the more generalized “impaired ecosystem health”. I could rationalize quite a few FS projects that way.. In fact, the FS has used existing CEQ emergency authorities on some projects.
And…”disproportionate and adverse effects on communities with environmental justice concerns” which, if I interpret correct, could be.. any community. It’s a pretty broad window. But if projects are to pass through it, they must go through two layers at least of environmental law folks, first to get the “innovative approach” and then through the courts if someone has the bucks to litigate. Also note that there is no public comment on the innovative approach, and only consultation with potential cooperating agencies.

***********
If these regs go through, I’m hoping the FS will use “wildfire risk” to justify perhaps a regional PODs network in each Region?

There are many interesting things about this proposed reg.. but my question is “do you read it the same way?”- that any disproportionate impact (project) could lead to any community having an “environmental justice concern?”.

Deeper Climate Change Discussions IV. Apocalypses and Trade-Offs

by

Thanks to everyone participating in our discussion on climate!.

Let me restate: we are leaving the “let’s not worry about it” folks by the side of the road for our discussion right now.  We heard you. We are not convinced and are unlikely to be. Speaking for myself, I don’t know for sure. But I also know that you don’t know for sure either. We can still act without knowing for sure.  Like wildfire mitigation efforts, we do them without knowing for sure a wildfire will hit our house while we live there. As Mike says, it’s about risks -and includes uncertainties and values.

Anyway, the last topic was exploring the differences between 4’s and 5’s in my original typology.. the difference was between “we need to focus on reducing GHGs” and “if we don’t stop fossil fuels apocalyptic things will happen.”

As it turns out, that was an oversimplification.  There are at least three different areas to explore 1) what needs to be done, 2) how quickly and 3) how apocalyptic future consequences might be.  Clearly all of these are related. If it was easy to fix, then decarbonization could happen rapidly and perhaps there would be no apocalyptic consequences.

One thing you may have noticed as you read the comments on the last piece is how few relate to atmospheric climate models, or physical science at all.

In fact, the discussion reminded me of the famous Thomas Sowell quote:

“Politics allows people to vote for the impossible, which may be one reason why politicians are often more popular than economists, who keep reminding people that there is no free lunch and that there are no ‘solutions’ but only trade-offs.”

If there are trade-offs, then indeed no particular discipline or expert, or even way of thinking, can claim to know the right answer.  Because someone calls themself a “climate expert” does not mean that they know any more about these trade-offs than anyone else.

First, about apocalypticism,

That was fairly vague, I grant you. Carl suggested:

a) “involving or causing sudden great damage or suffering” or more narrowly b) “involving a sudden and large-scale alteration in state.”

But if you believe that climate has been involved in wildfires, then a) has already happened.  We won’t know about b, probably until it’s too late.  So maybe that’s not a good word to use at all.

The next comment was he ever-helpful Anonymous leaving a link to a paper written by a philosophy professor and fortunately leaving a summary:

“All real-life decisions have the decision-maker face some kind of knowledge gap. Therefore, an idea of precautionary decision-making needs to be able to guide decision-makers with regard to:(1) if the knowledge gap faced is to be tolerated, and a decision made in spite of it, or(2) if the decision should be delayed while attempting to close or narrow the gap,(3) and, if so, how much time, effort and resources should be spent on that endeavor.”

Many of us may remember that there is in fact a social science field called “decision sciences” that has explored these kinds of questions in great depth (Al Lundgren cited an economics paper from 1921) .  In fact, my first memories of discussions of uncertainty  were Lundgren’s forest economics papers in the 1970’s- even one I recall on uncertainty in planning, though I can’t find it right now.

Jon then mentioned trade-offs as well:

 Where action is needed to mitigate climate change, it puts a premium on the tradeoff analysis, including on alternative locations that trade off some energy efficiency/cost for species protection.

And yet, trade-off analysis a project at a time doesn’t really work, so we’d need wider scale planning. Vladimir suggested that we need a plan, something like the Public Lands Commission in the 60’s. It’s conceivable that different alternatives could be looked at at either the national or state level and people familiar with the physical reality of building or changing, and the economic realities of who will pay and who will benefit, plus the availability of labor, capital and mineral and other resources.

Then there are values that haven’t yet been discussed in public fora… like how self-sufficient do we want to be as a country? Do we want to protect any domestic supply chains/jobs?

And Mike looked at it through the risk assessment lens..

Lastly, I try look at ACC through a risk analysis lens. What’s the worst that can happen if we continue down our current path of adding CO2 and other “greenhouse” gases (it’s not just about CO2) to the atmosphere vs what is the worst that can happen if we reduce those outputs and prepare for a warmer and, in some areas, drier future.

Who wins and who loses from any policy is ultimately in the realm of politics.  We folks who have spent time nestled in the depths of NEPA documents know that the best we can do is fairly describe the pros and cons and uncertainties insofar as they are known.  And present them to the public for feedback and additional info. I can see why maybe we don’t need to do that for national security policy, but decarbonization could be an opportunity to be as rational as we can be.. involving all the research disciplines, and people working on the ground.  No one discipline has the key to trade-offs, clearly if you are really an expert in industrial solar cells, then you aren’t an expert in hydro storage, electric cars, or carbon capture technologies. And to circle back, economists also have an important role to play in evaluating trade-offs.

Thanks again to everyone contributing to the discussion, and new people feel free to step in!

Friday News Roundup: Firing Ops, Agency Appears to Say “No” to Congress, Mining Reforms, Changing Wildlife Behavior

by

Please add your favorites from the week in the comments below.

Firing Operations During the 2012 Dixie Fire

Firing operations are one of the main tools firefighters have at their disposal to corral large fires once they have escaped initial attack, but putting fire on the ground at the peak of fire season, often during the extended periods of drought which bring us megafires, is rarely anybody’s first choice. Often these operations take place in a ‘we had to try something‘ context. We are reprinting this article now, as firing operations rarely get much attention in the press, and the mechanics behind how they are conducted is at the core of how large fires get fought.

************************************************

Yesterday’s “Analysis Paralysis”; Today’s “Permitting Reform”

Can Agency Heads Really Do That? And What is the Rest of the Story?

If you haven’t been following the proposed NEPA regs… thank whatever Deities you believe in. It appears to be another “we’ll require lots more stuff to do, but it will be faster and more efficient.. because.. we say so!” effort.

I realize 100% that the House Natural Resources Committee is not an unbiased group, but I didn’t know agencies could simply do this.

CEQ Chair Brenda Mallory was invited to testify but declined to appear or send a designee to testify on behalf of the agency. This is yet another moment in which Mallory, and CEQ as a whole, has ignored a co-equal branch of government.

60 Recommendations for Mining Law Reform

This is probably worth taking a closer look at. Maybe folks can put links to stories in the comments. I’ll probably have to read the report (shudder) for something else I’m working on.

“This report represents months of interagency policy work and over 50 meetings with industry, environmental groups, labor unions and tribes across the country, following the President’s Day One Executive Order on strengthening America’s Supply Chains,” said Deputy Assistant to the President and Deputy Director of the National Economic Council Joelle Gamble. “Securing a safe, sustainable supply of critical minerals will support a resilient manufacturing base for technologies at the heart of the President’s Investing in America agenda, including batteries, electric vehicles, wind turbines and solar panels.”

The report provides more than 60 recommendations to Congress and federal agencies, including for increasing public and Tribal engagement, making permitting processes more consistent and predictable for industry, and protecting impacted communities and workers, as well as the environmentally and culturally sensitive lands they cherish. The report also identifies reforms to revitalize federal support for research into advanced, lower-impact mining and exploration technologies and methods, workforce development, and the need for increased resources to address the legacy of abandoned and unreclaimed hardrock mining sites that continue to pollute land and water throughout the country.

And what agencies can do:

In the near-term, the IWG report makes dozens of recommendations for federal agencies that can be undertaken without Congress, including that federal permitting agencies adopt identified best practices for engagement, with early and extensive engagement with applicants, agency and intergovernmental partners, and impacted communities and Tribes prior to the start of the formal environmental review process.  This can help alleviate conflicts and speed permitting reviews, while improving outcomes for public health and the environment. The IWG report also encourages exploration and mining companies to adhere to established best practices, such as beginning community and Tribal engagement at the earliest possible stage, providing financial support to allow communities and Tribes to hire independent technical experts, developing community and Tribal benefit agreements, and considering independent and transparent reporting of air and water pollution monitoring data.

Wildlife Corner

 Lions and Wolves and Bears..

This New Scientist story is paywalled so I posted more than usual

In Yellowstone National Park in the western US, the habitat of cougars (Puma concolor) – also known as mountain lions – overlaps with that of grey wolves (Canis lupus), grizzly bears (Ursus arctos horribilis) and American black bears (Ursus americanus). Today, these top predators compete for similar food sources like deer and elk, and often steal fresh kills from each other – but it wasn’t this way a century ago.

In the 1920s, cougars and wolves were eradicated from the national park and bears were a rare sight. Cougars have slowly recolonised the area in the last few decades and initially had an abundance of elk to feast on. But grey wolves were reintroduced to the park in the 1990s, adding another elk predator and triggering a cascade of ecological changes.

The number of grizzly and black bears in the park has also jumped in recent decades, creating even more competition for elk and similar prey. To see how this was influencing cougars, Jack Rabe at the University of Minnesota and his colleagues tracked 13 cougars in the area using GPS collars. Their analysis, presented earlier this month at a meeting of the Ecological Society of America, included 381 kills by the cougars – primarily deer and elk – from 2016 to 2022.

They found signs that bears had visited around 30 per cent of the cougar kill sites, probably scaring the cats off their kill. Wolves visited cougar kill sites less often, around 8 per cent of the time. “Bears are definitely much more effective at finding cougar kills,” says Rabe, which might be because there are more bears than wolves in the area.

The researchers could also compare their data with similar tracking data recorded two decades earlier. This showed that cougars are now hunting a greater proportion of their prey on rough landscapes, including rocky slopes and forests. “Cougars are definitely better hunters where the ambush territory is better,” says Rabe. The cats may be returning to the hunting strategy they relied on before the loss of other predators left an abundance of elk and deer for them to pick off in more open areas.

And Coyotes and Bobcats

I can’t access the original article in Science. But this excerpt from New Scientist is interesting.

To investigate, Laura Prugh at the University of Washington in Seattle and her colleagues tracked the movements of 22 wolves (Canis lupus), 60 cougars (Puma concolor), 35 coyotes (Canis latrans) and 37 bobcats (Lynx rufus) using GPS collars between 2017 and 2022. They followed the animals across two forested regions of Washington state punctuated by roads, ranches, homes and small towns.

When wolves and cougars moved into an area, bobcats and coyotes appeared to avoid the larger predators. They spent more time near the developed and human-populated areas that wolves and cougars typically avoid. But this move often had fatal consequences: around half of the coyotes and most of the bobcats that died during the five-year study period were killed by people.

“A few coyotes and bobcats were shot while trying to raid chicken coops,” says Prugh, and others were shot on sight or snagged in traps. They found that humans killed between three and four times as many small carnivores as the apex predators did.

Prugh says that earlier studies on small carnivores suggested a strong fear of people, “so from that perspective, we were a little surprised that they shifted more towards humans in the presence of large carnivores”. The discovery that human-populated areas were more deadly to small carnivores suggests the phenomenon known as the “human shield effect”, in which some animals seek refuge near people, can be lethally self-defeating.

Coyotes, mountain lions, and bears seem to do pretty well in many forested rural and semi-rural communities, at least around here, although there are certainly conflicts.

Recreation Industry Worried About Future Lack of Recreationists Again

by
Skiers and snowboarders linger on the tundra below Peak 10 in the Tenmile Range, July 4, 2023, in Summit County. The Fourth of July Bowl tends to hold snow into the summer due to its aspect and elevation, which attracts the annual tradition to ski on July 4th. (Hugh Carey, The Colorado Sun)

 

Naturally, like probably all TSW readers, I am a big fan of, and participate in, recreation on National Forests.  It’s been interesting to observe the media concern loop on “outdoor recreation” over time.  First people weren’t getting outdoors enough (“nature deficit”); then people were getting outdoors so much that it created conflict and environmental damage; now the Outdoor Industry Association is worried again that there won’t be enough people recreating.  It’s always confusing because sometimes they count things like soccer balls as part of “outdoor recreation”; and of course RVs and boats and OHV’s and so on.  So sometimes it’s hard to tell what exactly what kind of outdoor recreation they are talking about, and how that relates specifically to FS and BLM lands.

Interesting story in the Colorado Sun.

A few years ago, the outdoor industry was struggling to get more people outside after several decades of participation studies showing nearly half of Americans did not go outdoors to have fun.

The pandemic changed that and the latest study by the Boulder-based Outdoor Industry Association shows a record 168.1 million Americans — 55% of the population ages 6 and up — went outside for recreation in 2022. That’s a 2.3% increase over the previous record in 2021. Since January 2020, 14.5 million more Americans went outdoors to run, hike, bike, camp and participate in all sorts of other activities.

And those newcomers are increasingly diverse. The participation rate for Hispanic people reached 56% in 2022, up from 34% in 2015. The rate of participation for Black people reached 40.7% in 2022, up 5 percentage points over 2021. Last year 61% of LGBTQ people recreated outside, with more than 18 million participants, up from 15.8 million in 2021. And more seniors (defined as 55 and older) than ever before went outside to play, with 35% joining the ranks of the outdoor recreators, up from 28% in 2018.

There’s a lot to cheer about in outdoor recreation right now, but “don’t think we are out here doing a victory lap,” said Kent Ebersole, executive director of the Outdoor Industry Association. “We’ve got a lot of work to do.”

The latest participation snapshot shows storms on the horizon. Younger Americans — ages 13 to 24 — are not getting outside. Outings for families with children are declining.

Thank you for recreating outdoors. Please come again. And again.

Americans logged 11.8 billion outdoor recreation outings in 2022 and while that number seems huge, it’s troubling. The frequency of those trips outdoors is declining. Ten years ago the average number of outdoor recreation outings was 84.6 per participant. Now it’s down to 71.8.

The decline in younger folks getting outdoors to play harkens to the industry’s struggles around 2008 when participation in all categories was flat or declining.

Hard work to reach new outdoor recreation players and more diverse groups has helped, but still the industry is struggling to reach younger generations.

“Fast forward eight years when today’s 18-year-olds are 25. Will there then be three generations with anemic participation and does that spell a future where we go back to 2008 and are flat for a decade or more?” Ebersole said. “If we let another generation go by and we don’t talk to them and we don’t reach them, we are going to be in a world of hurt.”

**********

Land managers are adjusting plans to accommodate the growth in recreation. The Bureau of Land Management hosted 81 million visitors on its 245 million acres in 2022, up 40% from 2012 with almost a third of that increase occurring since 2020. The Forest Service counted 168 million nationwide visits in 2020, up from 160 million in 2012.

Both agencies are launching community-focused strategies around recreation.

The BLM’s new Blueprint for 21st Century Outdoor Recreation started last month with major shifts in how the agency prioritizes recreation on its 245 million acres. The BLM’s budget for recreation in 2022 was $60.2 million, or about 74 cents per visit, compared with 84 cents per visit in 2012. The new strategy will enable local land managers to partner with a growing roster of groups lined up to help ease costs or even fund recreational amenities and events.

The Forest Service a year ago launched its five-year “Reimagine Recreation” plan with this note: “Our public lands can also be a source of healing, inspiration, and purpose to bridge some of the divides and challenges our country has faced over the past few years.”

The challenge is to convert that growing army of outdoor users into advocates who can sway public policy, said Tania Lown-Hecht with the Outdoor Alliance, a coalition of national recreation and conservation organizations that pushes for legislation to protect outdoor spaces.

One thing that always confuses me is that these groups say that they want more folks outside, so they will act to vote to “protect” the spaces.  But many of the places “protected”, say Wilderness areas, don’t allow certain kinds of very popular recreation.. in fact, as Patrick McKay has pointed out, new Monument plans also disfavor certain kinds of recreation. So it seems like the OIA works to reduce access, and is also worried that apparently the right kinds of people won’t be doing the right kind of recreation (possibly involving buying things from their associated companies?) sometime in the future. Would it be so bad if there were fewer people in the woods, grasslands, shrublands? Not so bad for other people recreating, it seems to me.  Not so bad for wildlife.  Not so bad for climate- for all the carbon people expend getting to recreation sites. Simple observation of interstates or other main routes to federal lands on Friday evenings suggest that recreation can have quite a carbon footprint.

Of course it might be considered bad to sell more recreation goods that would otherwise be bought… often made out of fossil fuels, transported from Asia and so on.  It’s interesting to me that environmental advocacy is often about pointing fingers at other industries and ignoring their own industry’s contribution to climate change or reducing biodiversity.  Of course, that’s human nature, but who knew that business institutions had those kind of human tendencies?  And media folks don’t seem to report on that much for whatever reason.

Anyway, I took a look at the OIA policy platform and they have some interesting trade-related policies …plus this

Require the United States Forest Service (USFS) to develop a 10-year outdoor recreation strategy for national forests under the forestry title.

I’ve seen many strategies come and go in my time, or don’t actually go, but sit around unread and unused. And as we have seen, both the BLM and the FS currently have new recreation strategies. Perhaps someone out there knows what the goal of this requirement would be?

Smokey is Baaack! Channel the Smokey Within

by

Here at TSW, we’re all for that.. the you can’t get to the videos from the photos below.. but they are linked here.

The Ad Council, National Association of State Foresters and the USDA Forest Service are releasing new PSAs today as part of the iconic Smokey Bear Wildfire Prevention campaign. Inspiring the public to share in the same values of responsibility and empowerment as Smokey himself, the new campaign reminds audiences that when we practice fire safety, Smokey is within us all, encouraging individuals to learn more about how to help prevent wildfires at SmokeyBear.com.

Wildfire Prevention | Smokey is Within | Friends
Wildfire Prevention | Smokey is Within | Friends
Smokey is Within
Smokey is Within

Experience the full interactive Multichannel News Release here: https://www.multivu.com/players/English/9094556-new-smokey-bear-psa-channel-the-smokey-within-and-help-prevent-wildfires/

“Smokey has been a household name for the last four generations. His message has been heard and heeded by countless Americans who carry his iconic ‘Only you can prevent wildfires’ with them daily,” said USDA Forest Service National Wildfire Prevention and Community Mitigation Branch Chief Maureen Brooks. “What better way to continue his legacy and illustrate the power we all have in preventing wildfires than by showing the public how Smokey is within all of us.”

For nearly 80 years, Smokey has been the nation’s favorite bear educating the public on how to prevent human caused wildfires and his message is as important now as ever. Nine out of ten wildfires are human-caused and fully preventable. Recent data from FCB and AYTM Research shows that while 95% of Americans feel that they can make a difference in preventing fires, many don’t always know how.

WATCH THE NEW PSA, “FRIENDS,” HERE

Developed by FCB, the creative agency behind Smokey Bear since he was first introduced to the world in 1944, the new “Smokey is Within” campaign highlights everyday people who channel their inner Smokey Bear in moments of need. Whether on a camping trip, using the drown-stir-drown-feel method when putting out campfires or avoiding sparks by crossing tow chains or more, the new PSAs remind us that we all have Smokey’s wisdom within us and can always access his message and wildfire prevention tips at SmokeyBear.com.

Hotshot Wakeup Interview with Jason Forthofer of the US Forest Service Missoula Fire Laboratory

by
Jason Forthofer, mechanical engineer, stands in an area burned by the Carr Fire, one of the devastating California wildfires in 2018. (Photo provided by Bret Butler, U.S. Forest Service)

I thought this was a terrific podcast, an interview with Jason Forthofer at the Missoula Forest Sciences Lab by the Hotshot Wakeup on his Substack.  He has a gift for talking about fire models in a way that is easy to understand, at least for TSW-ites and our ilk.   And the range of tools he’s working on, and their practical applications, are fascinating. At least to me.

He talks about AI and machine learning .. I’ve always been interested in these new-fangled analysis contraptions, so asked Jason these questions.

When you say “AI” what do you mean exactly? Do you mean machine learning? I kind of thought that that was empirical also, based on loading data into it. But then you mentioned a combination of using your physical model with AI.  We have many older readers so if you could explain this a bit more (or anything else you wanted to say but did not get to, or links to key papers), that would be great!

Below are his answers.

Yes, when I was saying “AI” I was primarily talking about machine learning.  I often use these terms interchangeably, but I understand that there are some differences.  In the context of the spread model work we are doing with Google, we are using machine learning, and specifically a method called deep learning which uses the idea of neural network.

I would say that you are correct that AI and machine learning could be considered essentially empirical models.  And yes, often these models use learning data that comes from measurements of actual phenomena.  So in the case of fire spread for example, you could burn some fires in a laboratory and vary, say, the wind speed and measure the outcome (let’s say you measure the fire’s spread rate).  An empirical model would, in one way or another, correlate the input (wind speed) to the outcome (fire spread rate).  For simple cases like this you could do a curve fit to the data, just like you might learn in an elementary physics or math class (one common method is the “least squares” fit).  You could also use a more sophisticated and complex method like machine learning.  From my limited experience with machine learning, I would say that it really is like a kind of very sophisticated “curve fitting” method.  As the phenomena you are trying to model get more complex, for example many different inputs and outputs and also complex relations between the variables, more complex methods like machine learning may work better than the simpler methods.

But machine learning can also use data that is output from another model instead of actual measurements of the real phenomena, which is what we are doing in collaboration with Google.  Instead of the machine learning algorithm using lab or field measurements to learn from, we are feeding it input/output from our relatively slow running physically-based model of fire spread.  The whole purpose of doing this is to have a predictive model that is fast running.  To give you an idea of the speed up in the computation, some preliminary investigations we have done show that the machine learning model (that learns from our physically based model) can predict fire spread somewhere around 100,000 times faster than the original physically-based model.  The huge benefit of this is that it essentially allows us to use our machine learning model to predict fire spread over large landscapes (where tens of thousands or more of these small fire behavior calculations must be done).  It would not be feasible to do such a simulation using the original physically-based model.

************

When I think about different research that uses machine learning, I think it’s safe in the hands of folks like Jason who are experienced with the real-world processes he models.  If you are trying to relate machine learning to old processes that you understand, like, say linear regression, I thought that this Forbes article is helpful.  Let’s be careful out there!

Pattern verification is an especially powerful way of using machine learning models to both to confirm that they are picking up on theoretically suggested signals and, perhaps even more importantly, to understand the biases and nuances of the underlying data. Unrelated variables moving together can reveal a powerful and undiscovered new connection with strong predictive or explanatory power. On the other hand, they could just as easily represent spurious statistical noise or a previously undetected bias in the data.

Bias detection is all the more critical as we deploy machine learning systems in applications with real world impact using datasets we understand little about.

Perhaps the biggest issue with current machine learning trends, however, is our flawed tendency to interpret or describe the patterns captured in models as causative rather than correlations of unknown veracity, accuracy or impact.

One of the most basic tenants of statistics is that correlation does not imply causation. In turn, a signal’s predictive power does not necessarily imply in any way that that signal is actually related to or explains the phenomena being predicted.

 

Foot on the Gas. Log on the Brake and.. Arbitration?

by

A theme I’ve been thinking about..is in terms of infrastructure build-out our country has one foot (and lots of federal tax $) on the gas, and a log (and lots of federal tax $) on the brake. I’ve been working on comments to the proposed NEPA regs, and listening to speakers on their webinars. It’s kind of funny how agency NEPA people are responsible both for not using plain language, and not including enough detailed scientific perspectives- which might be hard to do at the same time. We can discuss the proposed reg here at TSW, if anyone wants. The Admin claims that it is streamlining while adding more analysis and legally disputable changes. Anyway, I’d appreciate draft copies of comments if you would like to share.

From last week, here are some foot and log stories..

From the LA Times:

Note what Dave Jones, director of UC Berkeley’s Climate Risk Initiative and the state’s former insurance commissioner says needs to be done to avoid an “uninsurable future” in California?

“I’m not suggesting that we’re there yet,” he noted, “but it definitely bears paying attention to, because that’s a potential path of transmission of this risk in ways that could have negative consequences for our financial system.”

So what else should the state and federal government be doing to avoid the “uninsurable future” Jones warns about? He shared a few ideas:

  • The Federal Reserve and other federal financial regulators need to get serious about assessing the risks climate change poses to the financial system. That’s something the Fed just recently started to do, though critics say their efforts are weak and well behind other countries’ efforts.

  • State and federal leaders should invest more in forest management, especially prescribed burns. Jones said officials finally recognized that “a century and a half of fire suppression has resulted in forests choked with fuel.” Prescribed burns are key to reducing the risks of fires growing to out-of-control infernos, and Jones would like to see insurers factor such risk reduction into their assessments.

  • Most significant, Jones said, is the need to dramatically and quickly cut the human-made emissions that affect our environment.

I’m kind of dubious when financial regulators, who seem to have challenges with regulating things currently and most notably in 2008 , may take their eye off the ball to worry about the climate future.  But then perhaps that’s a feature for them, not a bug.  I wonder what regulatory work they are now not doing and whom that not-regulating might benefit?  And could there be reasons for insurance companies to err on the side of overestimating future risk?

So we need to invest more in forest management?

And to the brake..

From the Flathead Beacon (op-ed by Jim Peterson):

How else to explain the Court’s rejection of two forest restoration projects on the Kootenai National Forest in only 41 days. Judge Donald Malloy shut down the Black Ram Project on August 17 and Judge Dana Christensen’s July 7 ruling upended the Ripley Project.

Lincoln County and the State of Montana have an agreement with the U.S Forest Service to restore – via thinning and prescribed burning – up to 10,000 acres of designated Wildland Urban Interface per year to protect homes and forests from catastrophic wildfire.

Again, like last week’s post, somehow I don’t think it’s true that if NEPA practitioners cleaned up their act, then these projects would move through smoothly.  The other interesting thing is that the Kootenai Tribe supports the project:

“The Tribe supports the Black Ram project, because it protects our Ktunaxa resources, furthers restoration of Ktunaxa Territory forests and was developed through our government-to-government relationship with the United States Forest Service,” said Gary Aitken, Jr., Vice-Chairman, Kootenai Tribe of Idaho.

So even their feet on the gas doesn’t seem to matter because at the end of the day a federal judge will decide.  I hope that any settlements will involve the Tribe.

Anyway, back to the op-ed – Jim suggests arbitration instead.. it’s been around awhile as an idea.. I think it might have been in some proposed legislation..at least as a pilot.  Does anyone remember what bill that was? He suggests:

Let’s nix litigation in favor of baseball-style arbitration. You bring your best ideas for protecting forests and we’ll bring ours and three qualified arbitration judges will decide which ideas best meet the goals and objectives of the Forest Service’s decadal forest planning documents. No more bad juju.

************

Which reminds me that I ran across this idea also from Wildlife for the 21st Century by the American Wildlife Conservation Partners.

Increase Collaboration, Reduce Litigation
* Authorize collaboration in federal land decisions and protect collaboratively based decisions from litigation. Congress;Agriculture/FS; Interior/F WS, BLM; Defense/COE
* Authorize alternative remedies to litigation, including arbitration, and limit fee reimbursement to cases of direct and personal interest as defined in the Equal Access to Justice Act. Congress; Agriculture/FWS, BLM; Defense/COE; DOJ Collaboration is the voluntary work of citizens with each other and federal agencies to develop plans and projects.
These locally driven solutions achieve buy-in from diverse stakeholders. New policy must place collaborative agreements on par with lawsuits in determining the direction of federal land conservation. Arbitration between litigants and collaborative groups can avoid costly and disruptive litigation on projects where stakeholders have already agreed upon the best approach.

Of course, the forest kinds of collaborative efforts might work for forest resilience projects, probably not so much for transmission lines, solar and wind installations, carbon capture, mines and other kinds of facilities. Still, it may be worth it for vegetation projects.

Deeper Climate Change Discussions III. Does Apocalypticism Affect Our Path Forward and If So, How?

by

So let’s go back to our discussion. Again, the point is not to change minds but to understand each other better. It turns out that many of us are in camps 4 and 5.

4. Humans are influencing the climate and we need to focus on reducing greenhouse gases, notably carbon and methane.
5. Humans are influencing the climate and if we don’t stop fossil fuels apocalyptic things will happen.

It is true that some folks here are not in 4 and 5. For the time, though, let’s leave that discussion. We don’t need to convince them, nor they us. As the English cleric and writer Charles Caleb Colton wrote: “The greatest friend of truth is Time, her greatest enemy is Prejudice, and her constant companion is Humility.” So we can leave them to their beliefs.. they may be correct but time will tell. It’s also possible that the way we propose to deal with decarbonization will have other advantages such that those folks may ultimately agree. For example, the way the authors of he 2009 Hartwell Paper framed the issue:

Therefore, in our view, the organising principle of our effort should be the raising up of human dignity and in that pursuit, our re-framed primary goals should be three:
1) to ensure that the basic needs, especially the energy demands, of the world’s growing population are adequately met. ‘Adequacy’ means energy that is simultaneously accessible, secure and low-cost.
2) to ensure that we develop in a manner that does not undermine the essential functioning of the Earth system, in recent years most commonly reflected in concerns about accumulating carbon dioxide (CO2) in the atmosphere, but certainly not limited to that factor alone;
3) to ensure that our societies are adequately equipped to withstand the risks and dangers that come from all the vagaries of climate, whatever may be their cause.

So stand by, 1s,2s, and 3s, we may pick you back up somewhere along the way.

For now, I’d like to go back to 4s and 5s and look more deeply into where our different views could lead us in terms of efforts to decarbonize.

If I think about the differences between 4’s and 5’s, we all agree that decarbonizing is something that needs to be addressed. What we differ on (perhaps?) is urgency, what environmental, social justice, economic, national security trade-offs should be made, and what will work in physical reality. Then there’s scale, country or international. Should the US export more LNG to help other countries burn less coal? Should we tell Africa not to develop its resources? And there are so many values and scientific disciplines and practitioners involved in all the possibilities and trade-offs. This is a tough problem, because right now our world runs on fossil fuels- electricity, transport, chemicals and so on. We also know it’s difficult because states like California, and countries like Germany, have tried a bunch of things- some have worked better than others- and we have watched them struggle. If you follow Sammy Roth at the LA Times you can follow some of California’s twists and turns.

At the same time that states and countries are making efforts to decarbonize, the natural world (e.g., many aspects of wildfires); the human world (e.g., the War in the Ukraine); and interactions of both (e.g., the Covid pandemic) can change expectations and possibilities of any steps forward at any time. As does technological innovation for both mitigation (carbon capture, geothermal, small modular reactors, and so on) and for adaptation (wildfire suppression technology, CRISPR for plant breeding and so on).

So decarbonizing will be difficult in terms of new energy sources and building and buying new energy sources and physical infrastructure, it can’t physically happen as quickly as some might want, and care will have to be taken such that the transition doesn’t impose undue burdens on the non-wealthy/environmental justice/marginalized communities; AND we will have to be flexible as new information and natural, human and the interactions of those change through time. It seems like we should ask everyone to help row the boat. and we need to build a coalition that can maintain itself and be flexible through time and all kinds of internal and external trials. Including groups that want to hijack the issue to their own known or unknown ends. So what is the path to that coalition.. via old-fangled traits such as honesty, transparency, intentionally developing trust, and perhaps a healthy dose of humility?

So my question to 4s and 5s, do you see the situation the same way? If not, why not? And specifically for 5’s, do you think your view on the possibly apocalyptic nature of climate change affects your views on the above?

Thanks to all for your continued participation in this discussion.

Alaska Oil and Gas Leases Cancelled Due to …Poor NEPA?

by

Now, I’m not a lawyer,  but I have sat in many meetings with OGC folks about cancelling existing oil and gas leases.  So I was surprised by this :

Here’s  the NPR story.

“They just yanked those leases,” Sullivan said. “But now we’re going to get ready for the next lease sale. Give me a break. Who the hell in their right mind would invest money in a lease sale when they just watched the first lease sale get yanked?”

The administration is required to hold at least one more lease sale in ANWR. Senior administration officials said they “intend to comply with the law” in regards to that mandate which requires another lease sale by December 2024.

The original sale, held during the last weeks of the Trump Administration, drew unexpectedly little industry interest. Major oil companies did not participate, and the state of Alaska was the largest bidder.

Sen. Lisa Murkowski told reporters on the Hill she wants to put pressure on Biden to reverse his decision but cautioned that it’s “incredible to think that people are going to trust this administration on anything related to oil in Alaska.”

Haaland said the environmental reviews done under the Trump administration to allow the lease sales were “fundamentally flawed and based on a number of fundamental legal deficiencies.”

According to a Biden White House release, this includes failure to adequately analyze a reasonable range of alternatives and properly quantify downstream greenhouse gas emissions, as well as failure to properly interpret the 2017 tax law.

The administration said Wednesday’s announcement “does not impact valid existing rights” from developing leases.

****************

So it sounds like, based on this, Admin’s can simply state that the previous analysis was wrong and revoke decisions? Folks can always find flaws in any analysis.. one would think that since our usual suspect ENGOs did not litigate this project that they didn’t see those fundamental flaws quite so.. clearly.  And yet, we can suspect they didn’t want these leases, because at least some are supporting this decision.

I don’t particularly like the idea of possibly endlessly recursive NEPA.. suppose the Admin were to find “fundamental flaws” in the last ten years of Forest Plan EIS’s.

It will also be interesting to see how this is portrayed politically; looks like at least one Alaskan D is not on board.

“I am deeply frustrated by the reversal of these leases in ANWR,” said Democratic Alaska Rep. Mary Peltola. “I will continue to advocate for them and for Alaska’s ability to explore and develop our natural resources, from the critical minerals we need for our clean energy transition to the domestic oil and gas we need to get us there.”

According to AIDEA, the non-wilderness section of the ANWR where its leases are located contains approximately 7.6 billion barrels of recoverable oil and 7 trillion cubic feet of natural gas. The agency said a large share of economic development and jobs supported across Alaska’s indigenous and rural North Slope communities are related to oil and gas development.

Deb Haaland claims that this commitment recognizes Indigenous Knowledge, but doesn’t acknowledge that different Indigenous groups disagree about the project.  I guess that some Indigenous folks’ views count more than others.

“With climate change warming the Arctic more than twice as fast as the rest of the planet, we must do everything within our control to meet the highest standards of care to protect this fragile ecosystem,” Haaland said in a statement. “President Biden is delivering on the most ambitious climate and conservation agenda in history.”

“The steps we are taking today further that commitment, based on the best available science and in recognition of the Indigenous Knowledge of the original stewards of this area, to safeguard our public lands for future generations,” she continued.

************

Coincidentally, journalist Matty Iglesias on his Substack this morning made the claim that:

The current Biden policy is to support domestic oil production for economic and geopolitical reasons, even while investing in long-term decarbonization via technological progress. The old Schumer policy was to try to take advantage of the pandemic to crush the domestic oil and gas industry.

I think we can safely say we are entering pre-election silly season.

 

Two New Recreation Strategies: BLM and the Forest Service

by

Thanks to all who are contributing to our ongoing climate discussion! I think already we’ve seen that our thoughts are complex and not easily categorized and we’ll be looking at other ways to break free of categories. But there are probably many TSW-ites interested in more newsy things, so here are some posts along those lines.

BLM Seeks Public Input on a New Plan for Recreation Management

WASHINGTON – The Bureau of Land Management is welcoming public input on a plan to inform recreation management on America’s public lands. The new Blueprint for 21st Century Outdoor Recreation will guide Bureau decisions to proactively meet modern demands for exceptional and unique outdoor experiences, complementing the significant public land investments in President Biden’s Investing in America agenda.

“BLM hosted more than 81 million visitors on our public lands last fiscal year – a 40 percent increase since 2012. We are thrilled at this trend, but also recognize that more guests means a need for varied and diverse response strategies,” said BLM Director Tracy Stone-Manning. “The Blueprint aims to help BLM meet the growing demand for exceptional recreation experiences on our public lands.”

Managing for recreational opportunities is a core tenet of BLM’s multiple use mandate and aligns with BLM’s mission to sustain the health, diversity and productivity of public lands for the use and enjoyment of present and future generations. The increasing demand for recreational activities on public lands has provided a critical window of opportunity to advance a transformational shift in recreation management. This Blueprint will help BLM prioritize recreation investment and staffing appropriate for current and future needs.

BLM is seeking input from partners and the public, including in-person and virtual recreation Blueprint roundtables hosted by the Foundation for America’s Public Lands. Together, BLM and its partners will implement a strategy to guide the agency in providing the resources and experiences that visitors to public lands expect in the 21st century.

Forest Service Reimagine Recreation

The FS is also working on a recreation strategy that they call Reimagine Recreation.  They had a workshop in July and I will post the summary when I receive it from them.  Here are the Recreation Workshop – Case Studies and Successes Links .

*****************

At that point maybe someone will volunteer to review both strategies and talk about similarities and differences?