Sharon

A First Look at MOGgie ANPR. II. Let’s Ground Truth the New FS Climate Risk Viewer!

by

The Secretary’s Memo directs the Forest Service to spatially identify wildfire and climate change-driven threats and risks to key resources and values in the National Forest System, including water and watersheds, biodiversity and species at risk, forest carbon, and reforestation. Further, section 2 of E.O. 14072 specifically directs Federal agencies to identify mature and old forests on Forest Service and Bureau of Land Management (BLM) lands.

Through this ANPRM, USDA is sharing the beta version of a new Forest Service Climate Risk Viewer ( https://storymaps.arcgis.com/​collections/​87744e6b06c74e82916b9b11da218d28) for public feedback (see Section 1 below). This beta version was developed with 38 high-quality datasets and begins to illustrate the overlap of multiple resource values with climate exposure and vulnerability. The viewer also includes current management direction on National Forest System lands. The viewer allows for a place-based analysis of the need for climate adaptation to maintain, restore, and expand valued forest ecosystem and watershed characteristics. Additionally, the viewer supports identification of gaps between current management and potential conservation and adaptation practices. The beta version of the mature and old-growth (MOG) inventory that is being developed pursuant to E.O. 14072 and the RFI for MOG is also being released to help inform policy and decision-making on how best to conserve, foster, and expand the values of mature and old-growth forests on our Federal lands. Core information from the MOG inventory has been integrated into the viewer.

I took a brief look and it was very complex.  With a lot of RCP 8.5. So I will take some time and dig in for my own area, and hope others will do the same.

Synchronistically, Roger Pielke Jr. just posted a piece on his Substack this AM on another topic, but I think his thoughts are relevant to these maps.

Question 1: What scenarios are used to produce the estimates?

As frequent readers here will well know, the choice of scenario used in a climate projection can make the difference between an apocalyptic-looking future and one that appears much more manageable. You won’t be surprised to learn that many, if not most, studies that project future public health impacts of climate change rely on extreme, implausible or even impossible scenarios.

Question 2: How your analysis factor in adaptation?

One of the most incredible success stories of science, technology and policy over the past century has been the incredible progress around the world in improving adaptative capacity to weather and climate. This success story rarely gets reported on but that makes it no less real. There is of course more to do and continuing efforts are needed to maintain the progress made to date.

One dirty little secret in most studies of the future impacts of climate change (and not just on the effects of changes in extreme temperatures) in that future adaptation to climate variability and change is simply left out of projections. Assumptions are made that the climate will change, but people’s behavior will not. This is not how the real world works.

Adaptation- that’s the world of the natural resource professional.  Wildland fire technologies and people, and so on.  That’s us. We’re not included.

Note:  I am absolutely not criticizing the FS nor the USDA for doing it this way. They have to do what they are told, and use existing stuff. They have to go with the flow.

At the same time, in our quest to understand whether that information has any value, we need to take Roger’s points into consideration. And as I’ve said before, no one understands how populations of organisms will respond to any changes. So there’s that.

A First Look at the MOGgie ANPR – I. Up to Timber and Reforestation

by

Thanks to a TSW reader for this working link to the MOG ANPR!  Mature and Old Growth, Advanced Notice of Proposed Rulemaking, that is. It has the funniest and possibly least helpful title of any ANPR I’ve seen.. at least what the Federal Register has posted.

Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions

Ok, then.

Climate Resilience is a Thing Worthy of Note

My favorite part is

Uses the Planning Rule’s definitions of ecological integrity and social and economic sustainability to structure the concept of climate resilience. Climate resilience is essential for ecological integrity and social and economic sustainability.

Aside from the future Land Management Agency abstraction Smackdown with BLM on “intactness”, one wonders what it to use a “definition” to “structure” a “concept”.    As everyone knows, I have not been a fan of “ecological integrity” as a concept.  But I definitely like the idea of the essentialness (apparently not a word) of climate resilience.  Underlying these are ideas that “leaving alone is always best” (intactness) versus “to get things people, wildlife and fish like,  management can be necessary.”

Note that these ideas are not at their base scientific at all- they are philosophical differences.  And the importance of Native American tools and uses runs into philosophical problems with the Garden of Eden-y school of intactitude.

And so, what will be the role of HRV or NRV?  Will we be able to give the historic vegetation ecologists a well-deserved break (for whom, as I commented at the time, the 2001 and later rules were a full employment program) from their tedious (to me)  infighting about what used to be, the roles of Native Americans and so on.

I live in hope that the ideas of dynamic systems will root out the old forms of “return to equilibrium” “balance of nature” or a return to the past.. at least for the Forest Service. But maybe that’s too much to expect from this peculiarly named ANPR.

Timber Harvesting

“To put this evolution of National Forest System management into context, currently the Forest Service commercially harvests one tenth of one percent of acres within the National Forest System each year. Harvests designed to improve stand health and resilience by reducing forest density or removing trees damaged by insect or disease make up 86 percent of those acres. The remainder are final or regeneration harvests that are designed to be followed by reforestation.”

This is kind of a duh for most TSW readers.  So I can see the philosophical argument already. “Even though it’s only a little bit, it’s something we can control.” I’ve heard this argument about PM 2.5.. “we can’t control wildfires so we need to ratchet down fossil fuel use.” And of course, the idea that wildfires can’t be managed runs against folks’ lived experience, the Wildfire Commission, various Congressional large chunks of money, and so on.  It seems like no matter what the problem is .. diseases, wildfire, climate change.. the answer is always to reduce uses some key constituencies don’t prefer.

“At the same time, over the past 15 years data shows that disturbance driven primarily by wildfire and insect and disease has adversely impacted more than 25 percent of the 193 million acres across the National Forest System (see Figure 2). This rapidly changing environment is now the primary driver of forest loss and type conversion. Wildfire alone causes approximately 80 percent of reforestation needs on National Forest System lands, and we expect those needs to continue to grow: More than half of the 4 million acres of potential reforestation needs on National Forest System lands stems from wildfires in 2020 and 2021 (see Figure 3).

Interior, Agriculture Departments Host Summit to Develop Mental Health Resources for Wildland Fire Personnel

by

Lots of stuff rolling out this week..

Press release here.

BOISE, IDAHO—Last week, the Departments of the Interior and Agriculture hosted a three-day summit in Boise, Idaho, to spearhead the development of a joint wildland firefighter behavioral health program. Formally established by President Biden’s Bipartisan Infrastructure Law and announced in June 2022, and in alignment with ongoing efforts within both agencies, the program will address the unique experiences and mental health challenges of federal wildland firefighters. Through the Investing in America agenda, the Administration is committed to ensuring all permanent, temporary, seasonal and year-round wildland fire personnel have access to vital mental health services.

Secretary of the Interior Deb Haaland and Secretary of Agriculture Tom Vilsack provided opening remarks at the Summit emphasizing that both departments are prepared to meet the needs of firefighters and their families and are committed to work side by side to better support federal wildland firefighters to deliver more robust mental health services. Senior leaders from across both departments were there to listen and learn from wildland firefighters and mental health experts, as well as commit to create a comprehensive approach to support mental health needs of the wildland fire fighting community. The summit is a significant step forward in the implementation of the joint behavioral health program.

Throughout the event, participants examined what is already known about wildland firefighter mental health and the resources that are currently available to firefighters, including examining behavioral health programs successfully implemented by the City of San Diego Fire-Rescue Department, International Association of Fire Fighters, and the National Guard Bureau. Participants collectively defined a vision, framework and implementation plan for the program.

Wildland fire personnel are the backbone of the federal government’s ability to protect public and Tribal lands, vital infrastructure and communities from wildfires. They work in incredibly stressful environments that can have significant impacts on their health and wellbeing, including their mental health. This is exacerbated as climate change propels more extreme wildfires and longer periods of wildfire activity.

The goals of the new behavioral health program will be to establish year-round prevention and mental health training, provide post-traumatic stress care, enhance capacity for critical incident stress management, and create a new system of trauma support services with an emphasis on early intervention. By bridging existing mental health services and filling the gaps to address the full spectrum of wildland firefighter health and wellbeing needs, this program will increase access to services that build resiliency, improve mental preparedness, recognize the importance of self-care, and address the effects from cumulative stress.

President Biden is prioritizing mental health and has laid out a unity agenda, which includes a comprehensive national strategy to tackle the mental health crisis. Together with the other workforce reforms in progress across both departments, this effort will help meet the needs of employees, make the workforce sustainable into the future, and position the nation to address the growing climate crisis.

The Biden-Harris administration is also making historic improvements for the federal wildland firefighting workforce. More robust health and wellbeing support is being combined with proposals for a permanent pay increase for wildland firefighters, expanded hiring, and housing improvements that are included in the President’s Fiscal Year 2024 Budget request. These proposed investments are urgently needed, and they build on the temporary pay increase provided by the Bipartisan Infrastructure Law as well as efforts to develop a new occupational series to better define the unique duties and career progression of this occupation. Together, these initiatives will better position the federal government to recruit and retain wildland firefighters, meet the increasing challenges of more extreme wildfires, and provide much-needed stability, support, and improved career opportunities for the firefighting workforce.

In addition to these investments, both the Bipartisan Infrastructure Law and Inflation Reduction Act also provide historic funding for a suite of programs aimed at reducing wildfire risks, detecting wildfires, protecting communities and building more resilient infrastructure.

 

The Wildfire XPrize- Care of The Hotshot Wakeup

by

The Hotshot Wake up  does some good firsthand reporting and asks a key question about this..
Check it out here.

Welcome to the future… There are autonomous drone ships flying above our National Forests trying to detect wildfires. These unmanned craft are constantly overhead, scanning and communicating with an ever-growing number of wildfire satellites and self-integrating into public camera systems.

Once the fully autonomous AI systems detect a fire, they launch a drone helicopter which quickly joins the swarming symphony of non-human equipment. High-definition surveillance camera systems collect data and analyze weather and potential spread patterns of the new start as the drone helicopter makes its first drop.

This is literally right around the corner, and there is an $11M prize for those who can make it happen faster.

In the article, he talks about the different companies..

With the new wildfire competition launching today, I’m confident that many private military and California-based Tech companies will join in the competition to autonomously put out wildfires within 10 minutes… as stated by its founder.

Folks in the wildland firefighting world have worked hard to educate people on the need to NOT put out all fires immediately. This was the goal in early forest management and created overgrown and choked-out forests. Most recently, Rep. Tom McClintock of California pushed for a 24-hour rule on new starts and was met with a lot of backlash.

What are your thoughts on this competition and the systems being introduced?

I had two thoughts.. one is “when this works, how will that change the language of “increasing catastrophic climate-driven wildfire” with acreage estimates and so on.  Is there any feedback between modeling impacts and adaptation technologies?

But to his second question, I would think as the drone analyzed weather, etc. it could also call up WFU teams to engage.. or hold it until human beings “get there” and make decisions about engagement.  Lots of AI trust to be built there, but lots of WFU trust to be built anyway… might as well kill two birds with one drone.. 😉

E&E News Story on OG Forests and NASA

by

The Coconino National Forest in Arizona contains forests of pinyon pine and juniper. | Deborah Lee Soltesz/Coconino National Forest/Flickr
This one is now not paywalled.  I didn’t see the ANPR… can someone send a link?

“The Forest Service’s most recent science shows that fire, insects and other factors are leading to large-scale losses in mature forests, not timber harvest. Reforestation needs similarly are being driven by large fires,” said Bill Imbergamo, executive director of the Federal Forest Resource Coalition (FFRC), which represents companies that harvest timber on federal land.

In it advanced notice of proposed rulemaking and request for comment to be published in the Federal Register, the Forest Service said the changed environment from wildfire, disease and insect pests is the “primary driver” of forest loss in the past 15 years, with wildfire accounting for more than 80 percent of reforestation needs. Most timber harvesting in national forests, which has declined sharply over the years, isn’t designed for commercial purposes, the agency said.

“To put this evolution of National Forest System management into context, currently the Forest Service commercially harvests one tenth of one percent of acres within the National Forest System each year. Harvests designed to improve stand health and resilience by reducing forest density or removing trees damaged by insect or disease make up 86 percent of those acres. The remainder are final or regeneration harvests that are designed to be followed by reforestation,” the Forest Service said.

Also this from NASA:

The nation’s old-growth forests encompass different tree species in different regions, from towering redwoods and 5,000-year-old bristlecone pines to diminutive pinyon junipers whose age and grandeur are less immediately obvious. For decades the U.S. Forest Service has studied such trees in hundreds of thousands of plots across the country, but the agency has never issued a formal accounting until now. To identify and define such forests, the team analyzed decades of field-gathered data from a wide variety of forest types and ecological zones, while also collecting public input in the process.

 

America’s forests help absorb more than 10% of our annual greenhouse gas emissions. While younger vegetation accumulates carbon more rapidly, old-growth forests contain more biomass overall and store more carbon. Not only are these ecosystems essential to the country’s clean air and water, they hold special significance to Tribal Nations, they sustain local economies, and they conserve biodiversity.

 

Complementing the Forest Service’s boots-on-the-ground research, some NASA-funded scientists are using a space-based instrument called GEDI (Global Ecosystem Dynamics Investigation) to provide a detailed picture of these forests. From its perch on the International Space Station, GEDI’s laser imager (lidar) is able to peer through dense canopies to observe nearly all of Earth’s temperate and tropical forests. By recording the way the laser pulses are reflected by the ground and by plant material (stems, branches, and leaves) at different heights, GEDI makes detailed measurements of the three-dimensional structure of the planet’s forests and fields. It can even estimate the weight, height, and vertical structure of trees.

 

“The partnership with NASA will help us do analyses we have not been able to do in the past,” said Jamie Barbour, who leads the old-growth initiative for the U.S. Forest Service. “From space, we’ll be able to drill down and learn about so many more places.”

……….

GEDI collected four years of forest observations around the world, before recently entering hibernation on the International Space Station.  Extension of the GEDI mission is currently under discussion, and if the extension is approved, it is expected that monitoring of mature and old-growth forests will resume when it returns to service within two years.

This reminds me of the public forum I attended on MOG with the Forest Service, where many people wondered how useful an inventory is, and for what purposes, if not updated frequently.. like after wildfires take out old growth and mature trees.  But maybe the point is to do “monitoring” over longer periods of time, perhaps with scientific but not direct policy relevance to local/regional forest management? It does seem to be a feature of our age.. collecting info and using it are not necessarily connected.

 

Holland Lake: The Forest’s Side of the Story

by

Thanks to an alert TSW reader who forwarded this link to the Flathead Q&A’s about the Holland Lake Special Use Permit. The process is complicated enough, and specific enough to recreation special uses, that there are plentiful opportunities for misunderstandings.  For one thing, the application for a new permit with the new company is still under review and hasn’t been approved.

I think the FAQs clarify what Anonymous said here.

“Those are the terms stated right on the face of the Holland Lake Lodge permit. The Forest Service ignored those terms and let the parties attempt to expand and upgrade by submitting an MDP and telling the public their preliminary decision would be to approve it as a categorical exclusion. The Forest Service accepted that MDP in April, 2022 but didn’t put it out for public comments until September, 2022, long after the permit had
been terminated. ”

It seems that there are three things that could easily be confused.

  1. The FS reviews a new permit (to a new party) for an existing site.
  2. The FS accepts an MDP.
  3. The FS makes a “NEPA decision” to allow a specific kind of expansion or change to the existing site.

So if we go back to Anonymous’s comment.

Those are the terms stated right on the face of the Holland Lake Lodge permit. The Forest Service ignored those terms and let the parties attempt to expand and upgrade by submitting an MDP and telling the public their preliminary decision would be to approve it as a categorical exclusion. The Forest Service accepted that MDP in April, 2022 but didn’t put it out for public comments until September, 2022, long after the permit had been terminated.

Here’s what the FAQ says about accepting an MDP:

A master development plan (MDP) is a conceptual guide encompassing the entire operation presently envisioned for potential long-term development in connection with use authorized by the permit. Upon acceptance by the authorized officer, the master development plan shall become a part of the permit. There is no public process for acceptance of the master development plan because this is a conceptual plan only and does not authorize any action. No proposal for changes to existing authorized use at the resort, including development or construction of improvements, will be authorized without the requisite environmental analysis and documentation needed to support that additional construction or development under the National Environmental Policy Act (NEPA).

Acceptance of the MDP does not constitute approval of its contents or provide any assurance that any item in the MDP will be authorized by the Forest Service or constructed by the holder. No rights or obligations of the holder or the Forest Service are determined by the authorized officer’s acceptance of the original or revised MDP, including the legal requirement to conduct environmental analysis under NEPA. Screening criteria are applied and if accepted as an application, subsequent NEPA analysis will occur when a proposal is brought forward for consideration.

(my bold).

It’s confusing because the “what is to be done” under the MDP may be similar, or identical, to a specific FS proposed action.  An MDP is a “might could” in the current regs between the FS and the permit holder.  The proposed action is a proposal for something to be done on the ground with environmental impacts, with all the public involvement and analysis requirements that need to be followed.

For those of us more used to the ski industry, an MDP is  a strategic document that outlines what might happen and what direction the Permittee wants to go.  Here’s an example of some coverage and here is a link to the Breckenridge 2022 MPD.

Here is a link to the Breckenridge 5-Chair Environmental Review, which  uses  similar language in terms of “it is anticipated but we are looking at scoping comments and further analysis.”  Shout out to Dillon Ranger District for their story map.

Categorical Exclusion

Based on resource information gathered to date, it is anticipated that the Proposed Action falls within a Forest Service category of actions under 36 Code of Federal Regulations (CFR) § 220.6 that may be excluded from documentation in either an environmental assessment or an environmental impact statement, and that no extraordinary circumstances exist that would preclude its use. Scoping comments along with a complete resource analysis will determine whether this project can be categorically excluded.

The proposed project is consistent with category 36 CFR § 220.6(e)(22): “Construction, reconstruction, decommissioning, or disposal of buildings, infrastructure, or improvements at an existing recreation site, including infrastructure or improvements that are adjacent or connected to an existing recreation site and provide access or utilities for that site.” Activities within this category include but are not limited to “Replacing a chair lift at a ski area.”

(my bold)

Anyway, back to the Flathead FAQ’s.

What is the process if a new expansion proposal is submitted?

The permit holder must submit a proposal from the accepted MDP. The proposal will be reviewed under the screening process criteria (Title 36, Code of Federal Regulations, section 251.54). If formally accepted, the proposal will be processed as an application and analyzed through the NEPA process as a proposed action. If rejected the proposal will be returned to the proponent.

OK, so what about the old permit and the new permit?

What is the Forest Service’s authority when a business changes control or ownership?

While the Forest Service does not regulate or otherwise control privately owned improvements, it authorizes and regulates use of National Forest System lands in accordance with applicable federal laws and regulations.

Any transfer of title to the improvements covered by a Special Use Permit or a change in controlling interest triggers termination of the permit. When private improvements change ownership or a change in the controlling business entity takes place, it is Forest Service policy to issue a new special use authorization to the new owner/controlling business entity. The acquiring party or entity must submit an application for a new permit.

Has the existing permit been terminated due to change in control?

The Forest Service was formally informed of the change of control and an application for a new permit was submitted. Acquisition of a controlling interest in Holland Lake Lodge, INC. triggered termination of the existing permit; however, termination is not effective until/unless a new permit is issued.

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

So there seems to be a question, brought up by the letter by Save Holland Lake, CBD and AWR  as to whether the FS should authorize a new permit.  But to me, the permit and specific construction in any proposal are separate.

In their letter, they say they  “demanded it comply with mandatory regulations when determining whether to issue Utah ski giant POWDR a new term special use permit to triple the size of the lodge on the pristine mountain lake.”  But a permit by itself wouldn’t authorize any of those actions without a further NEPA decision.  So I’m still confused about that.

Lotsa New Stuff from Admin: MOG Inventory, Reforestation, ANPR for Resilience, Climate Risk Viewer and Field Guidance

by

These are all of interest. Please take a look and let us know what you think! Here’s the press release. My first few thoughts are in italics.

“WASHINGTON, April 20, 2023 – Today, in anticipation of the upcoming Earth Day celebrations, the U.S. Department of Agriculture (USDA) and the Department of the Interior (DOI) announced actions to foster forest conservation, enhance forest resilience to climate change, and inform policymaking on ensuring healthy forests on federally managed lands administered by the USDA Forest Service and the Bureau of Land Management (BLM).

To support these actions, USDA and DOI worked together to develop several reports, as directed by President Biden’s Executive Order on Strengthening the Nation’s Forests, Communities, and Local Economies (E.O. 14072), which he signed on Earth Day 2022. The Executive Order calls for inventorying mature and old-growth forests, setting reforestation targets on federally managed lands, and analyzing reforestation opportunities on state, Tribal and private lands. In addition, the Forest Service is releasing a new tool that illustrates the risks and vulnerabilities of climate change across the landscape along with a call for public input on how national forests and grasslands should be managed for climate resilience.

These actions represent concrete progress on the goals and priorities outlined one year ago in President Biden’s Executive Order, Secretary Vilsack’s Memorandum on Climate Resilience and Carbon Stewardship, as well as in the USDA Forest Service’s Wildfire Crisis Strategy, Climate Adaptation Plan (PDF, 26.1 MB), and Reforestation Strategy (PDF, 7 MB).

“Our forest ecosystems and communities are struggling to keep up with the stresses of climate change, whether it’s fire, drought, or insect infestations, it is clear that we must adapt quickly,” said USDA Under Secretary for Natural Resources and the Environment Homer Wilkes. “The USDA and our federal, tribal, state, local and community partners are working together to meet these challenges, pooling knowledge, sharing resources and discovering new ways to conserve resources, protect communities and ensure future generations can enjoy the countless benefits our forests provide.”

“Healthy, resilient forests are critical to helping us respond to the climate impacts being felt by communities across the country, because they store carbon, provide clean air and water, and sustain biodiversity,” said BLM Director Tracy Stone-Manning. “The reports released today will help enhance our work to protect and grow forests by creating a scientific framework for further study and public engagement for effective forest management and protection.”

Newly Released Joint Reports on Forest Conservation

The Mature and Old-Growth Forest report defines what mature and old growth forests are, establishes the first-ever initial inventory of those forests, and shows their distribution across lands managed by the USDA Forest Service and the Department of the Interior’s Bureau of Land Management. The initial inventory identified more than 32 million acres of old-growth and around 80 million acres of mature forest across 200 types of forests. The initial inventory found that old-growth forest represents 18% and mature forest another 45% of all forested land managed by the two agencies. Recognizing the many values of mature and old-growth forests, both agencies conducted significant outreach to gather public input from communities, tribes, scientists, and agency professionals in the report’s development.

Like all the nation’s forests, mature and old-growth forests are threatened by climate change and associated stressors. The initial inventory and definitions for mature and old-growth forests are part of an overarching climate-informed strategy to help retain carbon, reduce wildfire risk, and address climate-related impacts, including increased insects and disease.

As directed in President Biden’s Executive Order and laid out in the report, the USDA Forest Service and the Interior Department’s Bureau of Land Management will use these definitions and initial inventory to continue to refine results, assess threats to old growth and mature forest stands, and conduct public engagement. In the near future, the USDA and BLM also plan to incorporate information gathered from the National Aeronautics and Space Administration’s (NASA) Global Ecosystem Dynamics Investigation mission, which will provide forest inventory and analysis plots using space-based laser measurements. These efforts will help the agencies meet the science-based approach required in the executive order as well as develop management policy and strategies to recruit, sustain, and restore mature and old-growth forests.

Pinyon and juniper woodlands are the most abundant forest type in the federally managed inventory of mature and old-growth forests, with nine million acres of old-growth pinyon-juniper across BLM and Forest Service lands and an additional 14 million acres of mature pinyon-juniper. This summer, the Forest Service and the BLM will be co-hosting public workshops focused on sustaining resilient pinyon-juniper ecosystems. The workshops are intended to ensure robust public engagement and scientific expertise and knowledge are underpinning the approaches taken to fulfill the Executive Order and other management strategies for ensuring healthy, resilient pinyon and juniper woodlands.

Interesting because as I’ve pointed out, previous forest policy issues and debates have always had a mesic/timber framing.  “Robust public engagement” might mean with those inhabiting those ecoystems- perhaps a different set of folks than the usual suspects.

USDA and DOI are also releasing a joint reforestation report (PDF, 471 KB) which includes reforestation targets, assessments and recommendations for increased capacity for seeds and nurseries.

In response to feedback from stakeholder engagement, the report offers recommendations to conduct seed and nursery operations, improve coordination with non-federal partners, leverage opportunities for innovation with the private sector, and build a reforestation workforce with partners like the Conservation Corps.

To develop targets for reforestation on public lands by 2030, USDA and DOI evaluated recent peer-reviewed assessments and datasets conducted on public lands and identified more than 2.3 million acres in need of reforestation. This report also includes an assessment of more than 70 million acres of possible reforestation opportunities with state, tribal and private landowners, providing valuable insight on how existing partnerships and programs could be focused where they are needed most.

Advanced Notice of Public Rulemaking to Build Climate Resilience

With climate change and related stressors causing rapid, variable change on national forests and grasslands, the Forest Service is asking for public input on how the agency should adapt current policies to protect, conserve, and manage national forests and grasslands for climate resilience. This Advanced Notice of Proposed Rulemaking for National Forest and Grassland Climate Resilience will be published in the Federal Register and publication will begin a 60-day public comment period. The Forest Service is also consulting with tribes and requesting feedback on current issues and considerations related to relying on the best available science including indigenous knowledge, as well as climate adaptation, mature and old-growth forests, and considerations for social and economic resilience.

I wonder why the BLM isn’t doing this also?  They don’t need a comment period, as they already know how to build climate resilience?  One could argue the FS also has a pretty good idea.  So, what is this really about?

Climate Risk Viewer

As part of today’s announcement, the USDA Forest Service is sharing the beta version of a new tool to assess climate risks and vulnerabilities called the Forest Service Climate Risk Viewer. Developed with 28 high-quality datasets, it shows how resources overlap with climate exposure and vulnerability. This allows for more localized analysis of how climate adaptation can maintain, restore and expand forest ecosystems and watersheds. The viewer includes the new mature and old-growth forest inventory data for the Forest Service as well as datasets to identify gaps between current management and potential conservation and adaptation practices.

Bipartisan Infrastructure Law Field Guidance

In keeping with the spirit of President Biden’s Executive Order, earlier this week Forest Service Deputy Chief Chris French sent a letter to Forest Service Regional Foresters outlining leadership direction related to implementation of section 40803(g) of the Bipartisan Infrastructure Law regarding, which requires the consideration of how to manage for among other things, large trees and old growth stands in forest health projects.”

I’m not sure how this last one might fit with legislative intent, but if it’s not, I’m sure that Congressional folks will point it out.

 

Bad Winter for Wildlife, Bison Genetic Purity and Early Dispersal of Domestic Horses

by

Antelope in southcentral Wyoming are dying in large groups from lack of food this winter. (Photo Courtesy Larry Hicks)

Bad Winter for Wildlife

This winter has been very hard on wildlife in Wyoming and Colorado.

The wildlife winter kill in southcentral Wyoming is the worst anybody there can remember, some locals are saying.

“It goes on for miles: dead animal after dead animal after dead animal,” state Sen. Larry Hicks, R-Baggs told Cowboy State Daily on Wednesday. “The antelope are dying by the thousands. Starvation is an ugly thing.”

Outfitter and pilot Bo Stacks said that at higher elevations, he’s seen even hardy bull elk struggling to survive.

“Usually the elk are pretty tough and don’t have much die-off,” he told Cowboy State Daily. “There’s still 4 feet of snow on the high ridges. When I fly over, they don’t even look up because they’re so weak. They don’t even do anything.”
 

In addition, near Pinedale a bacterium, Mycoplasma bovis, has killed more than 200 pronghorn.

The Question of Genetic Purity.. re Bison

From this Wall Street Journal essay..

Native American reservations across the Great Plains support a growing number of the animals that the Blackfeet call Iinnii, and today the total U.S. bison population is estimated at 500,000. It’s a huge conservation success, but it comes with a twist with far-reaching implications for species recovery: Genetically, these animals are different from their wild ancestors, with a measurable portion of their DNA coming from cows.

Hybrid species—and especially species hybridized to satisfy human needs—are valued less by conservationists than species with their original genetic legacy intact. To suggest that a hybrid bison riddled with cattle genes is the same animal that roamed the Plains in Paleolithic times would be, for many people, to commit wildlife heresy, like saying the difference between your neighbor’s kitty and a Himalayan snow leopard didn’t matter.

What struck me about this was the idea that non-human manipulated hybrid species would be of less value than those with the “original” intact. Especially since we are hybrids ourselves.. in the words of Wikipedia

Introgression of DNA from other lineages has enabled humanity “to migrate to, and succeed in, numerous new environments”. Therefore, a strong case can be made that hybridization was an essential driving force in the emergence of modern humans.

Evolution is a process and hybridization can help it along… “intactness” (or a specific genetic array) is a function of a particular time and place. And sometimes conservationists intentionally hybridize to generate more genetic diversity in small populations (e.g. the Florida Panther.


Horses in North America.

As it turns out there is debate as to whether wild horses count as native wildlife.

You may have read about this one. Here’s a link to the full text of the publication in Science. Basically, they think the reintroduction of horses came from the Spanish, and that Indigenous trade routes led to horses being throughout western North America by the time other English speaking settlers showed up.

It’s a little confusing, though, because there were headlines like “Native Americans corralled Spanish horses decades before Europeans arrived“. And of course, you would think, “aren’t the Spanish Europeans?” but what they mean is that horses were spread out around western North America before later European settlers showed up.

Senator Tester Spreads Misinformation About Forest Service Categorical Exclusions at Senate Hearing

by
“using a categorical exclusion that was meant for cutting trees not for recreational purposes” Sen. Tester

I was intrigued by the Senate hearing where Senator Tester of Montana grills Chief Randy Moore here. Yay! someone talking about FS categorical exclusions! On Youtube!.

We already have discussed the Holland Lake Project (which Senator Tester didn’t mention by name) here and here.

Senator Tester seemed to think that the fuels CE he had voted on had been used for recreation. Around 1 minute.

Hopefully his staff knew more but.. why would they allow him to say something that’s obviously out to lunch?

Tester states that a corporation will come in (to this recreation site) with “potentially devastating impacts”, and “no public input.”

As Randy answers, CEs in the FS don’t mean “no public input”- there is required scoping. Yay, Randy! Scoping is public input.

As to “no public comment” here’s the scoping letter:

The full public scoping package can be found on the Holland Lake Lodge Expansion project webpage at: https://www.fs.usda.gov/project/?project=61746.
The Flathead National Forest will be hosting a public meeting about the Holland Lake Lodge Facility Expansion Project on Thursday September 8th, 2022, from 5:00-7:00 pm MST on the Holland Lake Lodge grounds at 1947 Holland Lake Lodge Rd, Condon, MT 59826. The purpose for this public meeting is to engage in information sharing with the public on project activities and to answer questions.
Comments received in response to this solicitation, including names and addresses of those who comment, will be considered part of the public record and will be available for public review. Electronic comments must be submit- ted through the project webpage at https://www.fs.usda.gov/project/?project=61746. On the right side of the project webpage there is a box “Get Connected” click on the ‘Comment/Object on Project’ link to submit your comment. The sender should receive an automated electronic acknowledgment from the agency as confirmation of receipt. If the sender does not receive an automated acknowledgment for receipt of comments, it is the sender’s responsibility to ensure timely receipt by other means. Acceptable formats for electronic submission are text or
html email, Adobe portable document format (PDF), and formats viewable in Microsoft Office applications (e.g., Word). Please address your written comments to Project Leader Shelli Mavor, Swan Lake Ranger District, 200 Ranger Station Road, MT 59911. The office business hours for those submitting hand-delivered comments are 8:00 a.m. to 4:30 p.m., Monday through Friday, excluding holidays.

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

“The CE was meant for cutting trees, not for recreational purposes.” That’s not the CE that was used, so, well, that’s a false statement.

For the curious, it wasn’t a legislated CE. According to this article:

Recreation Site and Administrative Site CEs, 36 CFR §§ 220.6(e)(21) and (22)

These two new CEs allow for construction, reconstruction, decommissioning, relocation, or disposal of buildings, infrastructure, or other improvements at recreation or administrative sites. The Forest Service foresees using these CEs to help restore its aging infrastructure at various administrative and recreational facilities, as well as allowing it to establish agency procedures for facility master planning.

For me, as we’ve discussed before, if a category fits, use it unless there are extraordinary circumstances as defined in the regs. And Jon well represented another point of view.

Here is what the Flathead folks said in their scoping letter:

Based on a preliminary assessment, intentions are to categorically exclude the proposed project from documentation in an environmental impact statement or an environmental assessment under 36 CFR 220.6(e)(22): Construction, reconstruction, decommissioning, or disposal of buildings, infrastructure, or improvements at an existing recreation site, including infrastructure or improvements that are adjacent or connected to an existing recreation site and provide access or utilities for that site.

I’ll restate.. “based on a preliminary assessment, intentions are..”. In my experience in other Regions, this would have been met with “don’t use a CE” and “we think it’s overbuilding”,  not the level of outrage that this forest seems to have received.

Tester framed it as making corporations rich.. but on the other hand, no one is required to stay or eat there, so they must be providing a useful service to individuals and families. In fact, Tester started out in his statement with how important the recreation economy is to the State of Montana. Hopefully none of those folks are growing rich :).

The actions of the career feds.. er.. “Gives government a bad name,” according to Senator Tester. Actually, having watched some recent Congressional hearings, I would give Congress an 90/100 for “giving government a bad name”, and the Flathead a 0/100.
*********

Most irritating to me, Senator Tester even implied that the reason for the use of the CE was to sneak by and cut a deal with corporations.

It’s not really clear what kind of benefits would accrue to the employees of the Forest by “cutting a deal”. In my experience, when deals are cut, it’s at a much higher level than the Forest, even than the Chief.

I did get a laugh out of his next statement -“the government should never be cutting a deal”.

Indeed, folks in the Executive Branch cuts deals for corporations all the time- and indeed “make corporations rich off our public lands.” Here’s an example:

The Biden administration said on Wednesday it would cut in half the amount it charges companies to build wind and solar projects on federal lands, a move designed to encourage development of renewable energy.

The new policy comes after years of lobbying from clean power developers who argued that lease rates and fees for facilities on federal lands were too high to draw investment

It’s not clear from the newspaper articles if there was public comment on this change.
**********************

Anyway, I can hear it now, why pick on this guy? They all bloviate- it’s in the job description. Yes, I agree, but I’d like them all to be less casual with facts. And not punch down. Yes, it’s too much to ask, but I can still ask. Accountability- not just for agencies anymore.

Director Martha Williams’ Science Degree Kerfuffle at USFWS- A Legal, Political or “Scientific Integrity” Issue?

by

Not only is this story interesting, but how it’s been covered is also interesting. Apparently, the Director of FWS is required to have scientific credentials. But scientists are saying that appointing a lawyer instead is..illegal. and one wonders “why now”?

According to this AP/ABC News story..

Federal law says only someone with “scientific education and experience” can be appointed director of the service.

Attorneys for the Biden administration said in court filings that the law requires Williams’ education to be considered “cumulatively” with her experience.

“She clearly has the requisite background,” they wrote.

Here’s what E&E news says about “education and experience”:

Justice Department attorneys rejected Aland’s arguments, starting with his claim of being harmed, which they noted was framed around the idea that somebody could seek to overturn a decision by Williams because of her qualifications. The attorneys dismissed that argument as “speculative at best.” The Justice Department added that “Williams’ extensive career as a professionally trained public servant in the field of fisheries and wildlife management is sufficient to satisfy the requirements” of the law. “The statute provides that both education and experience should be considered when confirming that a nominee has adequate knowledge of the principles of fisheries and wildlife management, but there is no independent requirement that she attain any specific education,” the attorneys wrote.

They claim Williams is serving in contradiction to the administration’s own policies and ethics rules. They pointed to an assessment done by Biden’s Scientific Integrity Task Force that suggests executive branch positions should be filled by candidates with appropriate credentials and that violations of scientific integrity policies should be taken as seriously as violations of ethics rules.

So there are two separate concerns here.. one is the unique requirements for FWS Director.. and the other is more of a global “need for a science background” concern- which could be applied to natural resource agencies, or DOE or…

With the exception of Williams, every director since the agency was overhauled in the 1970s had a scientific education, according to Public Employees for Environmental Responsibility.

“I see this appointment as a tipping point, where politics will forever override statutory credentials,” said Parsons, who authored the letter.

In the lawsuit challenging her confirmation, Illinois lawyer Robert Aland claimed decisions made by Williams would be “contaminated” since she was appointed illegally. Wildlife “could suffer the most serious adverse consequences” as a result, he said.

Could wildlife suffer direct consequences from the illegality? I think not. So the assumption is that perhaps regulatory decisions will go wrong if political appointees don’t have a science background? Or is it all agencies that work with the environment? But at the Cabinet level, they tend to be politicians, who tend not to have science backgrounds- and then there is direction from anonymous White House officials that can overrule Cabinet Secretaries.. so I think the “technical background” argument is pretty well lost.

 The preceding FWS director, Ashe, had a background in marine affairs and wetlands and had also served as chief of the service’s National Wildlife Refuge System and as the science adviser to the director.
Ashe was preceded as director by a decades-long FWS career employee. The four directors before that had earned a master’s in fisheries science, a doctorate science, a doctorate in forest resources, a master’s in wildlife ecology and a master’s in forestry, respectively. All had field experience.

Note the mention of “field experience” in the E&E news article. I think it’s a good thing to have, but many appointees and career folks come without it.

“Many familiar names, and a few close associates and friends, are among the signatories to this letter. I would ask each of them to reflect on the words of Voltaire — To hold a pen is to be at war,” former FWS Director Dan Ashe said in an email. “Any individual’s qualification to serve as U.S. Fish and Wildlife Service Director is a matter between the President and the U.S. Senate, and Martha Williams is the confirmed Director. Her job is formidable and she deserves our confidence and support. She has mine.”

Now I don’t know Dan Ashe, but the warfare thing seems a bit  over the top (although I have to admire using Voltaire in snippets for media quotes) and mildly threatening.

I thought it was interesting where CBD is on this (from the ABC news story)..since their main work seems to be suing FWS..

Center for Biological Diversity government affairs director Brett Hartl said the group knew about Williams’ lack of a degree, but decided nevertheless to support her.

He said his group believed having “an outside person” serve as director would offer a better opportunity to solve deep cultural issues that have plagued the agency over the years. Hartl agreed that the law requires a science degree but said the Senate has the ultimate authority to decide who’s qualified.

Does anyone know what the “deep cultural issues” might be?

Here’s the scientists’ letter.

And finally this paragraph from the letter:

A 2022 survey of Service personnel conducted by the Union of Concerned Scientists revealed the persistence of significant barriers to science-based decisions within the Service: 43% agreed that the “consideration of political interests” hinders the ability of the agency to make science-based decisions; and 19% agree that the “absence of leadership with scientific experience” also hinders science-based decision-making. See raw survey tabular results here.

Unfortunately for me, the links in the letter (bolded above) were not live. I found this on the UCS website  but it wasn’t helpful.. so if anyone has the links from the scientists’ letter, please put them in the comments.