It appears that we have some new subscribers and it has been awhile since we restated our norms and values. So Welcome!.. you’ll find we are a hospitable group.
The three doors of charitable speech. When commenting, please consider the three doors that charitable speech must pass through. It’s also in a widget in the right column of the website, in case you forget. “The gatekeeper at the door asks, “Is it true?” The second gatekeeper asks, “Is it helpful?” The third gatekeeper asks, “Is it kind?” (adapted from the writings of Krishnamurti by James Martin on p. 169 of his book “Between Heaven and Mirth.) “Many of us spend time on other social media such as Twitter, and TSW is intentionally a different space. We don’t always achieve that, we are human beings. Sometimes people just need to vent, and we are fairly tolerant of that. On the other hand, personal attacks are not OK. There are plenty of other internet spaces for that.
The rule of “some”. Again, TSW is about ideas and evidence, not tribalism. So if you make a comment about any group, you might be challenged. If you say “some” Republicans or “some” ENGO’s” it is both likely to be more true and less likely to be challenged. No one is perfect, and we are a forgiving lot, but like I said, you may be challenged.
Anonymity is OK, welcome, in fact. We have different Anonymous people on TSW who all have different perspectives and have different informational and philosophical gifts to share with us. From Hillel to the Hill. I’m retired now, and the drama that led to my retirement was partially from my involvement here, so I will always be sympathetic to any of the Anonymous among us.
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As environmental compensation for several solar farms, renewable energy developer Avantus retired grazing rights on 215,000 acres of federal land in California’s Kern County, including some with Joshua trees.(Avantus via LA Times)
Apologies to all who are not interested in the proposed BLM regulation. I haven’t seen anything much in the press on it so thought I would dive in. Plus we only have 15 more days, and it’s not an ANPR like the MOG for the Forest Service, meaning we all have another go at the MOG (when it is a proposed rule) but not this one.
Other than Sammy Roth at the LA Times, who has been covering the protection/renewable energy tension for some time, I haven’t seen much coverage of the details of the regulation other than a bit of “good people want it, bad people don’t”.
Back to the solar industry letter: they raised two points that are worth further examination.
Is it or Ain’t it… a Big Change, and if Not, Why Are We All Here?
Why No OIRA?
In addition to these potential unintended consequences, the Proposed Rule is a major agency action that would substantially alter the status quo of BLM’s management of federal lands and therefore should be scrutinized to examine its economic and environmental consequences. Among other things, the Proposed Rule:
• Requires OIRA Review. BLM’s effort to shield the Proposed Rule from OIRA review is inappropriate. At a minimum, it must be subjected to the detailed policy analyses required of “major rules” under the CRA, “significant regulatory actions” under Executive Order (EO) 12866, and “significant energy actions” under EO 13211.
Assuming that the solar folks did their homework (does anyone know where to look for this in the reg?), I guess that answers my question as to how the proposed regulation did not encounter some resistance from USDA about redefining “conservation” differently from long-standing and widely popular USDA programs. In addition, it seems highly likely that DOE would be equally concerned about taking land off the table for solar and wind. It seems to me that the Admin can’t argue that:
By putting conservation on an equal footing with other uses, the proposal would help guide responsible development while safeguarding important places for the millions of people who visit public lands every year to hike, hunt, camp, fish, and more.
It’s a big thing that needs to be done, but not big enough to require OIRA. As we used in say when working with Roadless, “they need to pick a lane.” Except that politically generated proposals don’t have to. Speaking with a forked tongue is an inherent tendency of all politicos, but I still think we need to point it out when it occurs.
A Categorical Exclusion?
Back to the solar folks.
• Requires Full NEPA Review. BLM proposes to comply with NEPA by applying a Departmental categorical exclusion (CX) typically used for “policies, directives, regulations, and guidelines that are of an administrative, financial, legal, technical, or procedural nature or whose environmental effects are too broad, speculative, or conjectural to lend themselves to meaningful analysis and will later be subject to the NEPA process, either collectively or case-by-case.” The Proposed Rule goes well beyond what is appropriate for consideration under a CX, and BLM should prepare an EIS analyzing the Rule’s environmental and economic impacts, including an evaluation of the potential negative consequences for renewable energy development on federally managed lands.
Some of us remember a NFMA Planning Rule that was required to have an EIS done when a CE was originally used. I spent a large number of hours discussing this with lawyers so am hoping that some of them can shed some light on why or why not this kind of “procedures and definitions” only kind of reg deserves (or doesn’t) an EIS.
If a) the Proposed Rule is finalized with a CE and 2) people with funding for attorneys don’t like the Rule, it seems probable that, like the Planning Rule, an EIS would ultimately be required.
There are many interesting (to me) things about the Proposed BLM Rule (Conservation and Landscape Health) and I’m glad they gave us more time to post on it.
Yesterday I empathized with the Biden Admin who want to please both their protectionist friends and their renewable energy development friends. And yesterday it was also announced that
Interior Department Proposes Rule to Bolster Solar and Wind Development on Public Lands, Continue Progress on Efficient and
Responsible Permitting
WASHINGTON — The Department of the Interior today announced a proposed update of its renewable energy regulations to promote the development of solar and wind energy on public lands. The Bureau of Land Management’s proposed Renewable Energy Rule would reduce fees for these projects by around 80%, facilitate development in priority areas by streamlining review of applications, and deliver greater certainty for the private sector.
“The Department of the Interior takes seriously our responsibility to manage the nation’s public lands responsibly and with an eye toward the increasing impacts of the climate crisis. The power and potential of the clean energy future is an undeniable and critical part of that work,” said Principal Deputy Assistant Secretary for Land and Minerals Management Laura Daniel-Davis. “Under President Biden and Secretary Haaland’s leadership, this Administration is taking an all-hands-on-deck approach toward ambitious clean energy goals that will support families, boost local economies, and help increase climate resilience in communities across the West.”
This sounds terrific, I mean why charge them at all?
The Bureau of Land Management (BLM) is proposing to amend its existing right-of-way (ROW) regulations, issued under authority of the Federal Land Policy and Management Act (FLPMA). The principal purpose of these amendments would be to facilitate responsible solar and wind energy development on public lands managed by the BLM. The rule would adjust acreage rents and capacity fees for solar and wind energy, provide the BLM with more flexibility in how it processes applications for solar and wind energy development inside designated leasing areas, and update agency criteria on prioritizing solar and wind applications. The rule would also make technical changes, corrections, and clarifications to the existing ROW regulations. This rule would implement the authority granted to the Secretary of the Interior (Secretary) in the Energy Act of 2020 to “reduce acreage rental rates and capacity fees” to “promote the greatest use of wind and solar energy resources” and achieve other enumerated policy goals.
In the description it says..
Through the rent and fee adjustments contemplated in this rule, the BLM also expects that lower acreage rental rates and capacity fees for solar and wind energy generating facilities would translate into lower costs for energy deployment, increasing renewable energy market penetration in domestic energy production. By reducing costs to producers, these reduced rates may also reduce electricity costs to rate payers.
Let’s see.. the Feds and States already provide subsidies to wind and solar, and BLM will reduce rates that they pay, but this “may” reduce electricity costs to rate payers. It would be nice if there were some guarantee that those savings (conceivably given up by taxpayers) would be passed on to ratepayers.
At some point, if protectionist groups are in disagreement with industrializing federal landscapes, we can expect to see media campaigns about “welfare turbines”, echoing previous concerns about “welfare ranchers”, royalties for oil and gas being too low, and all that. Not that I know what they should be other than fair market value, which is enormously difficult to figure out since private and public land are rarely in direct competition.
On the other hand, if I were in the renewable industry I would wonder how these two rules would interact. If the BLM were increasing the levers for protectionist control (the conservation rule, more intactness, more ACECs) at the same time, saying “if no one else (important to us) has a problem, we will streamline your permitting and charge you less.” Sure they would only pay 20% but first they need to lease a site. Investors don’t like uncertainties, and there’s nothing less certain than possible long-term litigation in the federal courts. While major ENGOs might not be on board to litigate these projects, our friends at other ENGO’s may take a different approach.
Here’s a link to the proposed regulation, called “Rights-of-Way, Leasing, and Operations for Renewable Energy.”
As usual, if anyone finds a good write-up on this, please link below.
Thanks to Rebecca Watson for clearing this up.. indeed the BLM has extended the time period for comments. There’s a great deal that can be said about this regulation, so I’m very glad they did this.
From E&E News..I’m sure there is partisan disagreement, but as I said in the previous post,the renewable energy industry also has concerns. And aren’t we all for “robust public involvement”?
At the end there’s a quote from Kathleen Sgamma saying it should’ve been an ANPR… Let’s see, what Department put out an ANPR AND extended their comment period for 30 days? I suppose they’ll also have a better array of public meetings when it comes time for the actual rulemaking. Way to go, USDA!!!
BLM offers extra comment time on public lands rule
E&E NEWS PM | The Bureau of Land Management has agreed to give the public until next month to weigh in on a hotly debated draft public lands rule that has sparked fierce partisan debate over the proposal’s emphasis on conservation in the face of increasing threats from climate warming.
BLM announced Thursday it is extending the 75-day public comment period, set to run through June 20, by 15 days, or until July 5.
The draft rule, which BLM unveiled in March, is designed to protect and restore rangelands so that they are able to be used in the future for multiple purposes in the face of a warming climate that has sparked drought conditions and extreme wildfires across the West.
But the proposed rule has stirred concern among various stakeholders, particularly congressional Republicans, who say it is a veiled attempt by the Biden administration to remove potentially millions of acres from public use in the name of conservation.
To date, more than 121,000 comments have been submitted to BLM, according to Regulations.gov.
“The proposed Public Lands Rule is essential to our work, to ensuring we can respond to changes on the landscape,” said BLM Director Tracy Stone-Manning.
“We appreciate the useful public input we’ve already received through five public meetings and the first 75 days of the comment period,” Stone-Manning added. “This extension will allow us to continue to work with the public to make sure that the final rule is durable and effective.”
Interested parties, including the ranching industry and congressional Republicans, pressed Interior Secretary Deb Haaland and BLM to extend the deadline, and to hold additional public hearings in more rural areas to allow more landowners to comment on the draft rule.
But some were disappointed Interior extended the comment period just 15 days.
The Public Lands Council, a ranching industry trade group, requested a much longer extension.
“While we appreciate the additional 15 days, it seems unlikely that two extra weeks over a holiday will give BLM time to facilitate the kind of dialogue needed to address the mountain of concerns that have already been expressed on the rule,” said Kaitlynn Glover, PLC’s executive director. “We are disappointed that BLM doesn’t appear to have taken our request for more meetings and a full 180 days to comment seriously, but we remain committed to leading the conversation to ensure this rule doesn’t destroy federal land management in the West.”
The announcement that BLM would extend the public comment deadline came just hours after a contentious, hourslong House Natural Resources Committee hearing during which Republicans sharply criticized the rule.
The legislative hearing Thursday featured only Utah Republican Rep. John Curtis’ H.R. 3397, which would require BLM to withdraw the rule and “not take any action to finalize, implement, or enforce the proposed rule.”
Congressional Republicans, who had previously asked Haaland for a 75-day public comment period extension, weren’t enthusiastic about the extension either.
“Given the level of resounding opposition we heard at our hearing today and for weeks prior, extending a comment period by only 15 days does not even begin to address our concerns,” according to a statement from Natural Resources Republicans.
Kathleen Sgamma, president of the Denver-based Western Energy Alliance, an oil and gas industry trade group, said the extension “is helpful for finishing up our comments, but this shouldn’t even have been a proposed rule at this time.”
Sgamma testified at Thursday’s Natural Resources legislative hearing against the proposal.
“As I said in my testimony, there are so many nebulous concepts and more questions than answers that this should have been an advanced notice of proposed rulemaking or request for information at this stage,” she said. “This rule is in no way going to be ready to be finalized as the next stage.”
As I mentioned before, the Biden Administration has a tough row to hoe keeping its protectionist friends and its development friends (solar, wind and transmission) happy on the same pieces of ground. It’s really hard to write regs that favor some development, but not other development without stating some logic say.. uranium mining is bad, solar arrays and wind turbines are good, if the stated goal is carbon-free energy. Interest groups don’t have to be rational, but it’s nice to at least try in a regulation. Hence some degree of regulatory fuzz. But the regulatory fuzz may make your friends mistrustful, especially when, as in this case, two sets of friends are not in alignment. And here we are with the solar industry groups’ letter, (thanks to Sammy Roth of the LA Times) which I think generally says “we don’t really trust you.” Pretty much like many current user groups. From the letter:
The Renewable Energy Industry’s principal concerns with the Proposed Rule are as follows:
• Establishes Duplicative Land Conservation Program and Lowers Bar for Establishing ACECs. BLM already has effective and well-understood tools to conserve public lands that authorize the BLM State Director to evaluate and designate ACECs for resources of regional significance. Those existing tools can be used to protect landscapes and ecosystem resiliency without adoption of the Proposed Rule. The Proposed Rule would allow local BLM Field Managers to establish ACECs to protect resources of local importance, likely eliminating potential renewable energy development on vast tracts of Federal Land, and to do so without publication for notice and comment in the Federal Register. These changes to current regulations should not be adopted.
My bold: is this true? I like giving field managers authority, but aren’t we for public processes (and dare I say, well-known ones like the RMP process)?
• Establishes Broadly Defined and Unworkable Land Management Standards. The Proposed Rule requires local BLM Field Managers to protect broadly defined “intact landscapes,” prioritize “ecosystem resiliency,” and apply “land health” standards designed for grazing land in all areas and decisions. Local staff would likely not process applications (by giving them “low priority” under the regulations) in areas that will potentially be preserved in Resource Plan Amendments as “intact landscapes.” In addition, because arid lands cannot by their nature meet ecosystem resiliency or grazing land health standards, projects would be denied even though those standards are by their nature inappropriate for application to desert areas. Ecosystem resiliency standards and grazing land health standards should not be applied to renewable energy projects in desert areas; current biological resource protection standards amply protect these lands. Similarly, protection of landscapes, where appropriate, should occur through State Director approval of ACECs, not a separate process.
What is broken about current protections for projects of all kinds? Why do more meaningless paperwork about what “land health” means?
• Creates Significant Litigation Risk. By establishing a programmatic mandate to require local officials to set aside intact landscapes and to apply inapposite ecosystem resiliency and grazing land health standards to solar applications on arid land, the Proposed Rule will expose BLM and developers to significant litigation risk from parties asserting that BLM failed to account properly for and consider these standards in the context of specific projects, or, more broadly, in the adoption of landscape level planning initiatives, such as the planned update to the Solar PEIS.
It appears that the solar industry’s Admin friends may have.. closer friends. Perhaps in large organizations with a contingent of environmental lawyers? Maybe a larger check needs to be written to the 24 campaign?
• Undermines the Administration’s Clean Energy Goals. Currently, BLM is considering approximately 220 applications for solar, wind, geothermal and transmission projects. Many BLM Field Offices are already understaffed, overworked, and unable to process renewable energy applications at the pace necessary to meet the Administration’s climate change goals on federally managed lands. Implementation of the Proposed Rule at the BLM Field Office level is likely to divert attention and already constrained resources from processing renewable energy permits. Furthermore, adoption of the Proposed Rule will likely result in conflicting standards and mandates at the BLM Field Office level without guidance as to how these conflicts should be resolved, resulting in ambiguity, uncertainty, increased risk and delay.
This was a concern of many of the people at our public meeting in Denver. So the BLM says it doesn’t have people to do the work it’s required to do by law, but needs to spend employees time on thinking and mapping intactness and defining land health. One person at our meeting wondered where the money was coming from for this, she was told that it was coming from the IRA. So climate bill money is used to make things more difficult for.. the renewable energy industry. OK, then.
The solar industry does like the conservation lease idea. At our Denver meeting, BLM folks said that conservation leases were an idea they undertook due to input from their “industry partners”. Why would you think federal land mitigation is better than private land mitigation, which the BLM already does? Perhaps to get more money for restoration? But when I asked in Denver, they said the funds from leases were going to the Treasury. So really, what they would do is enable BLM and industry to determine who else should be kicked off federal lands for an industry’s compensatory mitigation. To me, the idea of mitigation on private land makes more sense. That seems to give (certain) industries or NGO’s a leg up in determining what happens on federal land, beyond the permit boundary itself. What if Vail Resorts wants to kick some OHVers off someplace in Utah to mitigate its negative effects? It’s like dividing up the BLM between (certain) industries and certain non-users.. all in the name of the environment. Without actually making the case that the status quo with existing procedures is all that bad.
The comment period for what I call the Mature and Old Growth Advanced Notice of Proposed Rulemaking (the MOG ANPR) has been extended to July 20th. A nice gentleman at the Forest Service told me that it’s really called the ANPR on “climate-informed forestry” which would be different from the actual title at the Federal Register (Forest Service Functions). Anyway, it could be confusing if you just look at the main page which shows the old date and the number of days is wrong (see second screenshot above). This seems needlessly confusing IMHO.
If you’re interested in finding out about extensions, you can always subscribe for updates. Here’s where the the extension is posted.
As a non-paid person who often is asked to write or help with letters, I like to browse other people’s comments and see if they have interesting ideas. It would be handy if there were a search box that would not bring up form letters, or perhaps if you could set it to only include letters from organizations. Maybe more experienced people know if there’s a search possibility to do that?
Anyway, if you or your organization has submitted comments on either rule you would like to share, please link below.
It’s complex, that’s what this paper says, talking about Western Canada https://iopscience.iop.org/article/10.1088/1748-9326/ac7345
It’s interesting to take one set of facts -there are wildfires in Canada, the smoke is going toward the East Coast, and people who aren’t used to wildfire smoke were breathing it-, and see how those facts can be framed differently. There are different fires in Canada, in extremely different parts of the country, that are being managed differently, from full suppression to big boxes or what we might call wildland fire use, ignited by different sources. This tends to get lost in some of the reporting.
(Some) Legacy Coastal Media and Some Politicians- Wildfire Smoke, the Scent of Apocalypse
If you read the NYTimes or the WaPo, it’s the harbinger of apocalyptic climate change. Perhaps because the WaPo hired a bunch of climate reporters, it’s not surprising that any story could be seen through the climate lens.
I’m not saying that climate and weather don’t affect wildfires. I’m just saying that it’s difficult to tease apart the contributions of various climate change elements (different greenhouse gases, land use changes) from natural variability and a host of other factors (ignitions, fire policy) and the history of vegetation that has developed through time. I’m OK with saying “it’s complex, and we don’t really know, but from what we know, the sum of human impacts on climate have affected the situation.” It’s complicated. But to some politicians, it’s simple- and the answer- to quit fossil fuels:
So that’s one framing.
The Hotshot Wakeup- It’s Complicated And You Need Suppression Folks- So Treat Them Decently and Support the Tim Hart Act
Let’s take a great the Hotshot Wakeup podcast from last week, titled “How Did the Canadian Wildfires Start? A Rational Response in a Sea of Conspiracy. What’s Really Happening?”
Tim does a terrific job of talking to people on the ground in Canada, and also trying to explain to people who aren’t familiar with the wildland fire world how things work. You can tell why he thinks the way he does because he gives his rationale. He also discusses some of the “out there” ideas that are floating around and, perhaps most importantly, doesn’t seem to have a specific axe to grind about causality (or would that be a pulaski?). He’s another one who looks at the situation and says “it’s complicated.”
He seems to come to the eminently practical suggestion that no matter what the different causes (ignitions, climate, past fire suppression), we are going to need wildland firefighters and they are not being paid or treated well and may walk off the job if Congress doesn’t get its act together. He suggests we all call our representatives and support the Tim Hart Act. NFFE has a link you can use to make it easy. I’d like to understand who is against it and why. Which goes back to the need for some Smokey Wire legislative contributors.
Anyway, I contacted my Congressperson’s office as a Smokey Wire reporter and asked whether they were supporting the Tim Hart Act, and if not, why not. They said their legislative team was reviewing it and did email me afterwards to say (sadly I’m not kidding) “I talked to our legislative team about the bill, and they said our office is not supportive as it’s a massive increase in expenditures for something that could be carried out at a state level.” I wrote back and said how can the state fund Federal firefighters?” and I haven’t heard back yet. I believe in fiscal responsibility, but the very same Congress just approved the IRA and BIL which the Admin seems to be sometimes using as a slush fund for their pet priorities (e.g., mapping intactness of BLM). After this depressing experience, I feel that filling out the NFFE form or calling would be helpful. It doesn’t matter is anthropogenic climate change is responsible for 5% or 40%, we need firefighters and they deserve to be treated decently.
Cliff Maas the Meteorologist- Smoke- Bad Luck Plus Some Climate Change? in the Wall Street Journal. I like how he mentions plants and seasonal drying. I don’t know how true this is of the areas involved.. would like to hear more local Canadian observations on the plants. The below is long, but in case you don’t get the Wall Street Journal..
The recent wildfires occurred in the boreal forests of northern Quebec. Fire isn’t rare in that region. The ecology of these forests relies on fire for the release of seeds and forest health. Many of the major boreal fires occur during a narrow temporal window from mid-April through early June, just after the winter snow has melted and before grasses and other small plants grow, reducing flammability. During this short window, the dead vegetation from the previous year can dry out sufficiently to burn if there is an ignition source such as lightning or errant human activity.
Many of the great Quebec fires have occurred during the spring, such as the May 2010 fire that spread massive amounts of smoke into New England and the May 1870 Saguenay fire, which spread smoke as far as the British Isles. Large boreal forest fires during the spring in Canada are neither unusual nor a sign of climate change.
The fires this month began on June 2, as hundreds of lightning strikes ignited vegetation dried by nearly a week of unusually warm weather. The weather prior to the warm spell wasn’t unusually dry, with the Canadian drought monitor showing normal moisture conditions and temperatures near or below normal.
Starting on May 27, an area of high pressure built over south-central Canada, warming and drying the area for several days into early June. With the light surface fuels, such as grasses ready to burn, all that was needed to start a fire was an ignition source, which occurred in early June with a lightning storm associated with low pressure.
The lightning ignited numerous fires and the low-pressure center’s circulation produced high winds that stoked the fires, resulting in rapid uncontrolled growth. Even worse, as the low center pushed south and intensified east of New York, it produced persistent strong winds from the northwest, moving the Quebec smoke into the New York metropolitan area.
It was the perfect storm for smoke in New York, with several independent elements occurring in exactly the right sequence. It’s difficult to find any plausible evidence for a significant climate-change connection to the recent New York smoke event. The preceding weather conditions over Quebec for the months prior to the wildfire event were near normal. There is no evidence that the strong high pressure over southern Canada that produced the warming was associated with climate change, as some media headlines claim. In fact, there is a deep literature in the peer-reviewed research that demonstrates no amplification of high- and low-pressure areas with a warming planet.
The long-term trend in Quebec has been for both precipitation and temperature to increase. Temperatures have warmed about 2 degrees Fahrenheit over the past half-century. Even assuming that this warming is entirely human-induced, it represents only a small proportion of the excessive heat during the event, in which Quebec temperatures climbed to 20 to 25 degrees above normal. The number of wildfires in Quebec is decreasing; there is no upward trend in area burned, which would be expected if global warming was dominant.
**********************
The Hotshot Wakeup also has a new post on arson in the Canada wildfires titled “Alberta Premier Says She’s Bringing in Arson Investigators From Outside the Province.-175 fires in Alberta still have unknown causes. Very Interesting Indeed.”
But if we read what Google searches come up with on the Alberta arson question (or at least mine does), we get interesting anti-arsonist-explanation sentiment..
“There’s a certain logic to trying to distract from the terror of wildfires and the changing climate that helps set the conditions for them. For many individuals, perhaps the truth is so unimaginable, unsettling and unavoidable, they refuse to accept the complex origins of the new reality. ”
And pretty much call the interest in arson “disinformation”.
The facts will come out as to how many, if any, were started by arson, so we’ll see. It’s interesting to note the fact to spin ratio… But why is it so hard for many to say “it’s complicated” instead of “it’s climate”? Is that in itself “disinformation”?
Legislation is extremely important to our mutual interests, and we need one or more volunteers to cover it.
Even if you just want to follow one topic, or one bill, that would be a tremendous help. You probably know if you’ve ever felt drawn to understanding the federal legislative branch.
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Please contact me if you’d like to chat about possibilities.
Side note: whatever your thoughts, please comment on the MOG ANPR here. That is Mature and Old Growth Advanced Notice of Proposed Rulemaking. Some people have had trouble finding the link, perhaps due to the bizarre title “Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions.” Comments are due June 20th. We appear to be in the middle of a major media campaign on the MOG, so this seems like a good time to discuss some concepts.
Norm Christenson and Jerry Franklin had a an op-ed in Politico yesterday. I’m a big Jerry Franklin fan, based on my personal interactions with him since the 80’s. I’ve told some of the stories before, so I won’t bore you with them again. Mostly our disagreements have been about west-side vs. east-side practices, ecology and experience.
I like how they tagged on the wildfires in Canada to “underscore the need to let our current mature forest grow old.” You could also argue that the wildfires in Canada underscore the fact that wildfires are a danger when trying to use forests to mitigate climate change. Because if you believe that climate change will cause forests not to grow back, you’ve just blown your last tree sequestration opportunity plus released much carbon (and PM2.5).
“It turns out the age and composition of forests makes a big difference in what role they play in preventing wildfires and storing carbon. Old growth forest is the best at both, but there is very little old growth left in either the western or eastern United States.”
I would argue that old growth forest in some species/places is not the best in “preventing” wildfires (what does “preventing” even mean in this context?). Take a mixed ponderosa/true fir understory stand with large old pp.. how exactly does that “prevent” wildfires? I won’t go into carbon because the sequestering/storage burning up all depends on assumptions which may differ.
As part of the MOG effort, the FS counted the BLM and FS Old Growth acres and you can see them in the above table. It looks like 33 mill acres or thereabouts, or about 18% of the total. Note that this is just FS and BLM, there is probably OG on other state and country and private lands as well. So.. are 33 ish mill acres plus other unknown acres “very little” or not? How would we know what the “right” amount is?
But a large amount of the forests on public lands is what foresters call “mature” forest, which is nearly as good as old growth and in fact is on the brink of becoming old growth. It is these older forests that will help us prevent future forest fires and will do the most to reduce climate change, and its these forests that we need to protect at all costs.
I’m still interested in the mechanism of older forests helping us “prevent” fires. I have to admit, the old forests in my neck of the wood seem to be slacking off on this.
Then there’s the “p” word.. protect- the question is “protect from what?” This op-ed seems to mean “protect from removing any trees”.. but you can in the chart below (in the ANPR) see the timber harvest acres (including ecological restoration and fire risk reduction) are relatively tiny compared to fire and bugs and diseases. I guess I can see the argument “we can’t affect wildfire, and insects and diseases, so let’s focus on timber”; except that we can affect acres impacted by wildfire by thinning. Unless you believe that fuel treatments, PODs, etc. don’t help protect mature and older forests. Which isn’t the view of the fire science community nor practitioners. In fact, that isn’t addressed in this op-ed.
Within a few years, tree seedlings grow quickly, and their canopies expand to form a continuous green “solar panel.” The time it takes for this growth depends on the site’s fertility and the number of pioneer trees in the environment. The result is an immature forest composed of trees of small stature and similar age. These immature forests pose a high risk of wildfire due to the abundance of fine fuel, small branches and leaves, near the ground.
This reminds me of our 1980’s Central Oregon silviculture workshop with Bruce Larsen and Chad Oliver- when trees compete for water, they don’t grow the same way as the standard models and thinking based on competition for light. The old mesic forest bias. And when water is limiting, then thinning can increase vigor of trees and reduce beetle outbreaks in some cases. This isn’t scientifically controversial. There’s probably a literature review out there; here’s one example from the Northern Rockies
Our results show treatments designed to increase resistance to high-severity fire in ponderosa pine-dominated forests in the Northern Rockies can also increase resistance to MPB, even during an outbreak.
So “protecting” increases risks from pine beetles and wildfire, which doesn’t actually sound, in those cases, very protective.
As to the green “solar panel” well..that kind of implies an even-aged stand, which many stands that I observer are not. And then there are forests that never form continuous crowns due to competition for water.
I can understand if some don’t want to count pinyon-juniper as forests, but then maybe each kind of forest should be considered separately, including mesic and dry forests.
Here are some interesting and relevant Q&As from the ANPR.
Q. What restoration options are available to restore old-growth forest structure in frequent fire forests?
Mechanical thinning and prescribed fire represent the primary approaches to active restoration of frequent-fire mature and old-growth forest areas to reduce their vulnerability to wildfire. Reduction in tree density often increases resilience to the climate-driven impacts of droughts, insects and wildfire.
Restoration prescriptions generally aim to increase the diversity of trees – age, size, and species – and retain the largest trees of the most fire-resistant species in the area. Diverse forests are more resilient because threats are less likely to impact trees species, ages and sizes at once.
Q. Are old-growth forests climate resilient?
Many old-growth forests have resilient characteristics like thick bark, high canopies, and deep roots. Some, like coastal redwoods, require moderate year-round temperatures and abundant moisture to thrive. As such, they are highly vulnerable to shifting conditions. As climate continues to deviate from historical
norms, even otherwise resilient forests are expected to be at increasing risk from acute and chronic disturbances such as drought, wildfires, disease, and insect outbreaks. These threats heighten the vulnerability of mature and old-growth forests resulting in higher chance of forest loss.
On one hand, it seems like the Boulder County folks, with help, did an excellent job investigating the Marshall Fire, and changing their practices based on that knowledge. Along with the concept of “lessons learned”. All that information is posted on their website. including an After Action Report and a Facilitated Learning Analysis.
On the other hand, we’ve had a global pandemic. Two federal agencies (DOE and FBI) think it might have been due to a lab leak. Other federal agencies were funding the research that might have led to the lab leak, and don’t think it was.. which seems like an obvious conflict of interest.. and they are continuing to fund similar work. You don’t need to have WHO numbers at hand to know that the Covid pandemic had substantially worse impacts than the Marshall Fire. Through the work of independent investigators, we have found many unsavory things about how gain of function research was managed, and how the discussion was handled in the press and on social media. Scientists are asking “is this research a good use of federal funds? Are the risks too great? Was gain of function research actually helpful in this pandemic, as promoted in the proposals? If it’s essential should it be done in more isolated places..say like Plum Island is for foreign animal diseases. Would it make more sense to have a commission of independent folks look at all this holistically -whether this research is needed and how it’s managed- rather than a variety of intelligence, law enforcement and other agencies coming to different conclusions on the more narrow question of a specific lab leak? Or should the usual “management of research” questions be considered (from London Times story):
It could have been the end of the Wuhan-North Carolina collaboration, but a loophole allowed gain-of-function work to proceed if deemed urgent and safe. Baric made the argument to the NIH, which gave approval.
……..
This triggered alarm bells for the US government because it would have involved the type of gain-of-function experiments that were still barred. According to documents obtained by freedom of information campaigners, Daszak argued the Mers experiment was not gain of function because it was unlikely to make the virus more pathogenic. A compromise was reached whereby the scientists would stop work and report to US officials if they created a new mutant virus that grew ten times faster than the natural virus it was created from.
…….
And the old and familiar, one agency found out something but it didn’t make an impression on another agency.
The US embassy found out about the experiments in Wuhan and sent diplomats with scientific expertise to inspect the institute in January 2018, according to diplomatic cables leaked to The Washington Post. They observed “a serious shortage of appropriately trained technicians and investigators needed to safely operate this high-containment laboratory”.
In the case of the New Mexico fires last year, the Forest Service had a 90 day stand-down, and involved the public in figuring out how to improve, and changed practices based on those findings. There’s a public report.
Then there’s the Durham Report. I recommend that if you’re interested, you read it yourself, not believe what others say about it. I think anyone working in a frequently FOIAed/litigated bureaucracy may enjoy it from a “glad that wasn’t me” perspective. There’s some humor in there as well. From page 258:
Within a day of receiving the Alfa Bank materials, Cyber Agent- I and Cyber Agent2 drafted a report of their analysis. he report’s summary stated that they had “assess[ ed) there is no CyD [Cyber Division] equity in this report and that the research conducted in the report reveals some questionable investigative steps taken and conclusions drawn.” The report acknowledged that there was no allegation of hacking and so there was no reason for the Cyber Division to investigate further. The report also said that
it appears abnormal that a presidential candidate, who wanted to conduct secret correspondence with the Russian government ( or a Russian bank), would (1) name his secret server ‘mail I.trump-email.com’, (2) use a domain (trump~ernail.com) registered to his own organization, and then (3) communicate directly to the Russian bank’s IP address (as opposed to using TOR or proxy servers).
Cyber Agent- I testified that both he and Cyber Agent-2 did not agree with the conclusion in the white paper and assessed that (i) the authors of the white paper ‘jumped to some conclusions that were not supported by the technical data,” (ii) the methodology was questionable, and (iii) the conclusions drawn did not “ring true at all.”
Now, I don’t expect the FBI to stand down for 90 days and look at how they went off the rails and how they might fix it. But why not have a report of what they found they had done wrong and how they plan to fix it in the future? After all, I’ve heard another election is coming up…
Here are my hypotheses:
-Fire culture has a history of lessons learned, others don’t.
-Important people don’t really want to know or improve; it’s OK for fire folks to undergo review, but not really important people.
– Partisans will try to get partisanship to creep in certain reviews and not others, and once partisan demons have entered the discussion, any review and improvement is DOA (dead on arrival). It has already reared its head with Covid in ways that I find, as a non-partisan, unfathomable. I understand how it happened with the Durham report, which was after all, about the FBI putting its thumb on the political scales before an election to the benefit of one party. Notice the Politico headline “Republicans dive into politically fraught push for Covid’s origin.”
But despite a growing chorus of bipartisan calls for such a probe, it’s unclear whether Democrats are actually willing to launch a wide-ranging review. The House’s select panel on Covid-19 has not committed to exploring how the deadly outbreak started, with its chair, Majority Whip Jim Clyburn (D-S.C.), recently suggesting he’d rather look forward than backward.
What is missing from this take on Clyburn’s take on (some) reviews is the idea that information helps agencies improve What if Chief Moore had said “I’d rather look forward than backward” after the New Mexico fires last year, or NASA had said that after the Challenger disaster?
Some (I would argue many or all) things are more important than partisan sparring. Like improving the way our agencies operate, especially those tasked with public health and law enforcement. Especially if you are in a party, I think, which holds the position that the government should be doing more things, an important piece of gaining trust would be being transparent about failures and fixing them… all across the interlocking mass of federal agencies. Among us the knowledge hasn’t been lost on how to do bipartisan commissions and reviews, all that’s lacking is political courage and a certain amount of bipartisan trust.
But even without the Congress setting up a bipartisan review, or the President setting one up.. perhaps they are all too embroiled in power-seeking to hear the call to good governance, there is nothing to keep NIH and CDC, and the FBI, from getting some fire folks in to help them develop the skills to have a more open, lessons-learned kind of culture. Who could be against better governance and developing trust?
