Why 1%? EPA Blames Utah and Wyoming for Denver’s Ozone Pollution

Here’s a Colorado Sun story..

This is about non-wildfire air pollution (ozone), but to my mind doesn’t make a strong case for EPA regs making sense. And of course, EPA uses maps with un-groundtruthed wildfire risks directly from an outside group, so there’s that, and their lack of coordination with other federal agencies on wildfire smoke… I’m not picking on them as an agency, but like the FS and BLM I’m sure there are things they are doing well and others not so well.

The EPA’s justification for the new good neighbor rulings, published in the Federal Register, says the agency’s well-established monitoring methods show Utah contributing more than the 1% threshold of regulated substances to other states. “Its highest-level contribution is 1.29 parts per billion to Douglas County, Colorado,” the EPA said.

That number appears small, but the Colorado Air Quality Control Commission and the Regional Air Quality Council spend countless hours discussing strategies and policies to potentially shave a part or two per billion off summer ozone levels in the Front Range nonattainment area. Readings in recent summers have spiked above 80 ppb at some monitors.

At first, when I read this article, I was curious about the justification for 1%. It seems fairly, well, minimal.

Unfortunately, we don’t get to hear Utah’s side of the story because.. they are in litigation.
Colorado hasn’t joined in on the litigation despite pressure from environmental groups to support EPA (in blaming other states for our Colorado-generated problems?).

From a CPR story (that also talks about the relationship between ozone and wildfire smoke):

In 2014, Flocke and his NCAR colleague Gabriele Pfister conducted a state-commissioned aerial survey to track the ozone sources along the Front Range. The research found that the region has background ozone levels of about 40 to 50 parts per billion, which is short of the current federal health standard of 70 parts per billion.

Local emissions of air pollutants pushed air quality to unsafe levels. On days when ozone levels exceeded federal health standards, traffic and oil and gas combined are responsible for more than two-thirds of ozone production along the Front Range.

Colorado’s ozone landscape has likely changed in the seven years since the survey. Energy companies have installed more pipelines, cutting down on total emissions from oil and gas production. Over the same period, more people have arrived in Colorado and brought their cars with them. While the COVID-19 pandemic led to a reduction in Front Range traffic in the spring and summer of 2020, Pfister said state data show it has rebounded to record levels in Denver.

“There are basically just more cars on the road,” Pfister said.

When I first read the Colorado Sun story, I was puzzled by the mechanics of how pollution from Utah could fly over the western part of the state and lodge in Douglas County. A wise reporter friend suggested that perhaps Douglas County is in non-attainment, so the percentage is equally low in other counties, bu it doesn’t matter for them. This would make sense. I reached out to the reporter for the more information and name of his EPA contact but haven’t heard back.

Anyway, it seems like ozone is fundamentally an urban problem on the Front Range.. so why go after rural folks in Utah?

As it turns out, this came up last year in Wyoming, via the Cowboy State Daily.

The EPA, in an April 6 report, said Wyoming contributes up to 0.8 parts per billion to the Denver-Chatfield area “smog” — just more than 1%.

As a result, the agency wants to enact its “Good Neighbor” mandates that would allow it to place tougher greenhouse gas restrictions on Wyoming and several other states which contribute 1% or more to ozone pollution in “downwind” states.

The EPA early this month deemed the Denver-Chatfield area a “severe” violator of federal ozone, or smog, standards – a downgrade from its prior status of “serious” violation.

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Gov. Mark Gordon in a March statement called the “Good Neighbor” mandate an “attack on state-led approaches” moving “more authority away from the people to Washington, DC.”

Gordon also said the plan targets Wyoming and other Western energy-producing states, and seeks to penalize their energy industries.

“It will harm states like Wyoming who meet ozone standards and benefit more populous states that use our energy but do not meet their own standards,” Gordon continued. “EPA’s proposal does not ‘follow the science’ or the law and will unjustly discriminate against Wyoming industries.”

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The Cowboy Daily also raises the question about California..

In the same projection, California was expected nearly to double Wyoming’s chemical share of Colorado’s smog by contributing about 3 parts per billion to Colorado.

California also is expected to export about 40 times Wyoming’s ozone-chemical output nationwide, with 34 ppb total ozone-chemicals export.

And then there is this interesting critique of the EPA modeling from a Colorado engineer (yes, ozone is measured but of course, contributions are modelled), also from the Cowboy State Daily.

This is just one piece of the critique:

“EPA states that the average difference between the projected values and the actual values is 7.79 ppb (parts per billion of ozone-contributing chemicals),” reads Strobel’s letter to the governor.

Wyoming’s likely inclusion in the “Good Neighbor” restrictions is due to its projected 0.81 ppb contribution to Colorado’s total ground ozone, which is projected to be 71.7 ppb in 2023.
“If the model cannot project values with any more accuracy than 7.79 ppb for Chatfield,” wrote Strobel, “it is absurd for EPA to suggest that they can project that 0.81 ppb will come from Wyoming.”
If Wyoming’s projected contribution had been below 0.7 ppb, the state would not fall under the “Good Neighbor” restrictions.
“With such poor accuracy,” continued Strobel, “it is also absurd for EPA to claim that they can distinguish between 0.81 ppb and the 0.7 ppb threshold for requiring action.”

If you’re curious, you might wonder why Colorado isn’t a bad neighbor to Kansas.. it seems probably as there are no large urban areas in non-attainment.

It’s perfectly normal for federal agencies to find rationales to expand their power over states. But this one seems a little arbitrary and dare I say, capricious. A person could even wonder whether the political inclinations of the “bad neighbor” states have been somehow factored in..

Is Every Story Ultimately Political? Perhaps the WaPo Thinks So

Is everything political? It seems to be that politics is one filter to look at stories.  Climate is another filter.  A filter can help you see aspects of things.. on the other hand, it can filter out other aspects of things.  Kind of like the story of the blind people and the elephant.

As it turns out, the WaPo has hired political and climate reporters, so we can expect more of that. And we can expect the WaPo to encroach upon stories that would normally be “environmental disagreement” stories. In fact, they now have a newsletter called “your weekly non political political stories.”

If you’re new here: The Daily 202 generally focuses on national politics and foreign policy. But as passionate believers in local news, and in redefining “politics” as something that hits closer to home than Beltway “Senator X Hates Senator Y” stories, we try to bring you a weekly mix of pieces with significant local, national or international importance.

I always say we need to beware when organizations redefine commonly used English words. It’s hard to imagine any activity that might not have some kind of political or climate angle, but does the story benefit from that filter or obfuscate? That’s for us to examine and decide.

The story that intrigued me was the Maine Lobster vs. Monterey Bay Aquarium issue.

And the WaPo’s view of why this is a political story..

The politics: This has it all. A locally vital economic resource, interstate commerce, environmentalism. Trade-offs.

It’s fascinating. What might have been a business story, or an environmental story, is now a .. political story. No thanks, WaPo.

At the same time, I think we need to look at possible political angles for the behavior of.. well… politicians and agencies in the Executive Branch. We don’t know, or at least I don’t for sure, but I think they need to be considered. Especially when decisions don’t seem to make sense otherwise. Not that political decisions are bad, but understanding motives is probably good.

To Bolt or Not to Bolt? Federal proposals to ban climbing anchors sparks a wilderness climbing outcry.

 

Madaleine Sorkin, one of the world’s top big wall climbers, climbed the Hallucinogen Wall in the Black Canyon of the Gunnison in a single day in April 2022 after replacing old bolts on one of the nation’s most celebrated big wall routes. (Henna Taylor, Special to The Colorado Sun)

Another excellent Colorado Sun story by Jason Blevins.

And now climbers say the Forest Service and National Park Service are ready to propose a national prohibition on bolts and a review of all fixed anchors in the wilderness. The classification of bolts as permanent installations that are largely banned in the 1964 Wilderness Act, or require lengthy federal review, has galvanized the climbing community anew.

The Access Fund this month called the potential policy banning fixed anchors “a war on wilderness climbing.

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Climbers and their influential groups have supported major wilderness legislation in Colorado for decades. Longtime U.S. Rep. Diana DeGette has included language that specifically protects rock climbing and fixed anchors in her Colorado Wilderness Act, which she has proposed every year since 1999 to protect more than 700,000 acres as wilderness. The CORE Act also specifically mentions climbing.

“Imposing an unnecessary prohibition on climbing in the wilderness not only harms local economies and recreational experience and safety, it perhaps most importantly creates a serious obstacle to wilderness advocacy,” Murdock said. “A prohibition on fixed anchors in wilderness will make it very difficult for the climbing community to deliver full-throated support for wilderness initiatives. This is an existential question. A small minority of bureaucrats in D.C. are not understanding the far reaching implications and fast-acting repercussions of this type of policy.”

Colorado’s U.S. Rep. Joe Neguse, a Democrat, has joined Utah’s U.S. Rep. John Curtis, a Republican, with a bill that will fix the fixed-anchor debate. The lawmakers’ Protect America’s Rock Climbing Act, introduced in early March, directs the heads of the Forest Service and Interior Department to create a uniform policy and issue guidance for all of the country’s federal wilderness areas that allows “the placement, use and maintenance of fixed anchors” for climbing.

“By requiring additional agency guidance on climbing management, we are taking steps to protect our climbers and the spaces in which they recreate,” Neguse said in a statement.

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This is not the first time federal land managers have considered a nationwide ban of fixed anchors in wilderness. The Forest Service in the late 1990s decided to prohibit the use of new bolts in about 40 of its roughly 400 wilderness areas.

Climbers protested that decision too, alongside a wilderness group that argued all fixed anchors should be removed. In 1999, the Forest Service gathered the 23-member Fixed Anchors in Wilderness Negotiated Rulemaking Advisory Committee. The group met four times and agreed that climbs with lots of anchors did not belong in wilderness but climbing management plans can allow “a small number of bolts.”

But the committee was unable to, ahem, fix the fixed-anchor row. The result has been an array of management policies, with some public land managers prohibiting bolts and some allowing limited use, with many management plans concentrating anchors near roads and campgrounds.

 

Can Both Things be True? We Need to Protect Mesic Forests for Carbon and We Will Lose Them Due to Climate Change?

 

This is from a classic 1992 paper on genetics in reforestation under climate change. The Douglas fir near my house don’t appear to be suffering, 30-ish years later.

Here’s an article in Mongabay, which attempts to explain this very complicated article in Nature.

  • Landscapes are showing signs of losing their ability to absorb the amount of carbon they once could, a new study revealed. That would pose serious obstacles to the fight against climate change.
  • The study reviewed the productivity of carbon storage of different ecosystems between 1981 and 2018, finding that many fluctuated greatly and were at risk of turning into permanent scrubland.
  • Researchers identified a concerning “spiraling” effect, in which landscapes absorb less carbon that in turn worsens climate change, which then destabilizes additional landscapes and puts them at higher risk of turning into scrubland.

One reason for this, the researchers said, is that landscapes have a “memory” of which years had high carbon storage and which were low. Low years are more likely to be followed by additional low years, meaning that as carbon storage potential diminishes, a landscape is more likely to permanently become scrubland.

The phenomenon can be thought of as a “spiraling” effect, researchers said, in which landscapes absorb less carbon that in turn worsens climate change, which then destabilizes additional landscapes and puts them at higher risk of turning into scrubland.

“If we destabilize the carbon net uptake, that will destabilize climate even more,” said lead author Marcos Fernández, researcher at the Center for Ecological Research and Forestry Applications (CREAF). “It’s like a positive feedback loop. As you destabilize the carbon balance, then the climate becomes more unstable, as well.”

The most-affected regions include the Mediterranean Basin, South and Central Asia, East Africa and the west coasts of North and Central America. More specifically, mapping suggests that Kenya, India, Pakistan, Russia, Kyrgyzstan and Iraq are losing their ability to store carbon while in the Americas, it’s the Northern Triangle, Mexico and the west coast of the United States that are the most affected.

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“For the first time, we’ve demonstrated that for certain regions of the world, the land might be reaching a tipping point in terms of its ability to host significantly forested land and absorb significant amounts of carbon,” said co-author Patrick McGuire, a staff meteorologist at the University of Reading and the National Centre for Atmospheric Science in the UK.

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“We need to take care of our land better and not let all the trees get cut down and converted to cropland,” McGuire said. “Trees can hold a lot more carbon than crops or grasslands.”

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The question is “how did the authors come to that conclusion?” The article was fortunately published with a sharing token from Mongabay, so perhaps you can access it.  Sadly I can’t copy the paragraphs that describe the authors’ thinking. but it’s something like if we measure variability in carbon uptake from year to year that might mean “ecosystems” are in trouble.  They talk about Net Biome Production or NBP.

We can access and copy the peer reviewers comments, though, and they explain perhaps better.. .

Fernandez-Martinez et al. take an interesting and novel approach by analysing changes in the interannual variability and autocorrelation of NBP to infer potential early warning signals for a “destabilization” of the terrestrial carbon sink.

Now it could be that internannual variation of NBP might be early warning signals for “destabilization” but first we’d have to define what destabilization means..  and some of us might want to see some evidence that points in that direction.  I don’t think there is any evidence of a link, just conjecture that there might be with calculations using data from Cams and Carboscope.

Anyway, it appears that CAMS and Carboscope are estimates of carbon in the atmosphere.  TRENDY appears to be a vegetation simulation.

My take: they  took two models at the global level for veg and atmospheric carbon. They used a term “destabilization” without making clear exactly what they meant.  And concluded that trees could die.

What is interesting about these kinds of papers is that they take datasets of unknown quality, define things without understanding or describing mechanisms, and then.. ask for monitoring to see if the results mean anything in the real world.

Last sentence of the paper..

Hence, regions showing increased variability and autocorrelations should be monitored in detail to properly understand the mechanisms and consequences behind these changes given that increasing variability and autocorrelation have been shown to act as early-warning signals preceding abrupt phase transitions in simulations of ecosystem functioning.

(so far observations in the “real world” have not entered in.

Here’s my fave:

Given the main role of climate change as a driver of these changes in their temporal behavior, mitigating climate change is needed to prevent further unforeseen changes in land C sinks.

I think you could probably say that without all this data. Here’s my take:

-Climate change affects trees (among other things)

-Trees sequester and store carbon

-With climate change, tree species may slow down growth or may be unable to live, and be replaced by shrubs or grass or desert.

-And we don’t know exactly what will happen one way or the other- nor can we really, because trees and forest ecosystems are so complex.

-Nevertheless, mitigating climate change is a good idea.

There.. was that so hard?

If we thought western mesic forests were in danger, perhaps we could look for signs that those trees were in serious trouble. What signs would those be?

Fire Retardant Legislation in Congress: Introduction of HR 1586 and Companion Bill in Senate

The San Bernardino National Forest team works on the Pilot Fire behind Ryan Nuckol’s home in Hesperia on August 9th, 2016. The pink fire retardant line is one of the reasons why fire crews were able to save the home from the fire. Don Tuffs for KPCC.

Speaking of the co-evolution of statutes and court cases, and the idea that talking to all kinds of people- practitioners, academics, stakeholders- involved and hashing things out in dialogue is a better way to develop policy than behind settlement doors..

it looks like Andy has been successful at creating a bipartisan effort to do just that with regard to fire retardant.. check out this piece from the Plumas News.

Citing the importance of using fire retardant as an important tool for the Forest Service in fighting wild land fires, Congress is taking action.

Representatives Doug LaMalfa (R – CA) and Jimmy Panetta (D – CA) introduced the Forest Protection and Wildland Firefighter Safety Act of 2023 today, March 14. This bill creates a Clean Water Act exemption for federal, state, local, and tribal firefighting agencies to use fire retardant to fight wildfires. Fire retardant is an essential tool used to contain or slow the spread of wildfires. Currently the Forest Service and other agencies are operating under the assumption that a National Pollutant Discharge Elimination System (NPDES) permit is not required for the use of fire retardant because the regulations specifically state that fire control is a “non-point source silvicultural activity” and communications from EPA dating back to 1993 indicated a permit is not required.

This bill is being introduced because an environmental group is suing the Forest Service under the Clean Water Act to require a NPDES permit to use fire retardant, and they have requested an injunction on the use of fire retardant until the Forest Service receives this permit, which could take years. If the injunction is granted and fire retardant is not available for use in the 2023 fire year, firefighters and individuals living in forested areas would be in peril, millions of acres of forested land would be in danger, and billions of dollars of infrastructure would be at risk.

Congressmen LaMalfa and Panetta were joined by 22 Members of Congress: Reps. Dan Newhouse (R-WA), John Duarte (R-CA), Russ Fulcher (R-ID), Tom McClintock (R-CA), John Garamendi (D-CA), Austin Scott (R-GA), Amata Radewagen (R-AS), Troy Nehls (R-TX), Lauren Boebert (R-CO), Rick Crawford (R-AR), Young Kim (R-CA), Ryan Zinke (R-MT), Blake Moore (R-UT), Burgess Owens (R-UT), Mike Simpson (R-ID), Trent Kelly (R-MS), Ken Calvert (R-CA), Pete Stauber (R-MN), Darrell Issa (R-CA), Mary Miller (R-IL), Kevin Kiley (R-CA), and Matt Rosendale (R-MT).

Senator Cynthia Lummis (R – WY) introduced a companion bill in the Senate.

There’s a hearing on March 23, 2023 at 2 PM eastern which includes this bill, HR 1586. Here’s a link.

Giving EPA power over more aspects of a land management agency’s work could be a recipe for disaster, as per the GAO report we discussed last week.

Side note for those of you who know more about this.. if the drops in water are due to accidents or safety, how would getting a permit help with that? It seems to me that if there are things to be fixed, fixing should be approached directly, not through the EPA. But maybe the court case is just leverage for fixing.

Should ANILCA Access Provisions Apply Outside Alaska? New Case by Wilderness Workshop and Rocky Mountain Wild

The White River National Forest has approved year-round access and paving of Forest Service Road 780, a summer-only route above Edwards, to provide access to the proposed 19-home Berlaimont Estates project. (Jason Blevins, The Colorado Sun)
This is usually Jon territory, but since it’s in Colorado…
Interesting story by Jason Blevins at the Colorado Sun. Basically the plaintiffs are charging that ANILCA shouldn’t apply outside Alaska. Calling its use by Supervisor Fitzwilliams an “artful dodge” (plaintiffian hyperbole) is kind of silly in my view. TSW veterans of the great Village at Wolf Creek controversy (or as I called it “reasonable access for unreasonable people”) and other access issues across the country will know that Scott didn’t just dream it up.. after all, as the article says, the FS has been using the legal precedent since the 9th Circuit called it in 1981, and is certainly what FS folks are told by their lawyers.

has been deployed many times in the West and in Colorado to force the Forest Service to provide roads across public land to access islands of private property.

To me it says reasonable access and reasonable is in the eye of the beholder. Should this be changed to “not required to provide any kind of access?” Seems to me that that question should go back to Congress. Many of us could help with stories on the difficulties of interpreting “reasonable,” and ideas for useful clarifications. That’s one reason I prefer not to let courts handle these things..they can say what’s wrong, but can’t tell us what’s right, or what could work better.

Extra points to Jason for explaining this complex stuff accurately (or at least as far as I can tell) and attaching the complaint and a link to the precedent case Montana Wilderness Association v. US Forest Service. And Bob Zybach and others will appreciate that he spelled out how to pronounce FLPMA and ANILCA. If you appreciate his work, please consider sending him a note. Remember that old management idea “catch people doing something right”?

You don’t hear much about FLPMA and the Forest Service, since FLPMA is generally regarded as a BLM statute, based on the definition of public lands in it. See here.

This Complaint involves Forest Service decisions regarding National Forest System lands in Western Colorado. Defendants applied the mandatory access provisions of the Alaska National Interest Lands Conservation Act of 1980, 16 U.S.C. §§ 3101 et seq. (“ANILCA”) instead of the discretionary access provisions in the Federal Land and Policy Management Act of 1976 (“FLPMA”) that apply to federal public lands outside of Alaska, including National Forests. 43 U.S.C. § 1740 of 1976 (“Secretary of Agriculture, with respect to lands within the National Forest System, shall promulgate rules and regulations to carry out the purposes of [FLPMA]” when considering access requests.). The National Forest Management Act of 1976, 16 U.S.C. § 1600 et seq., (“NFMA”) also applies to the National Forests, but because access issues were inadvertently omitted from NFMA, the access provisions involving National Forests were included in FLPMA. Applying ANILCA’s Alaska-specific provisions to an access request
involving the National Forest in the Lower 48 States is contrary to the plain language of ANILCA and FLPMA.

It sounds like the FS was supposed to promulgate rules in NFMA.. did they? Lands people out there?

Check out the judges’ decision in that case, which goes back to mind-curdling details of the legislative history. And it returns to Colorado.

The appellees, however, have uncovered subsequent legislative history that, given the closeness of the issue, is decisive. Three weeks after Congress passed the Alaska Lands Act, a House-Senate Conference Committee considering the Colorado Wilderness Act interpreted § 1323 of the Alaska Lands Act as applying nation-wide:

Section 7 of the Senate amendment contains a provision pertaining to access to non-Federally owned lands within national forest wilderness areas in Colorado. The House bill has no such provision.
The conferees agreed to delete the section because similar language has already passed Congress in Section 1323 of the Alaska National Interest Lands Conservation Act.

Should be an interesting case..

The specific White River case seems to be about a summer only unpaved road being changed to an all-season paved road. We discussed it here, but it seemed like that story was used to take a swipe at Trump-era NEPA regs. And yet, here we still are…

Andrus Center “Re-Creating Public Land Recreation” Conference April 18- in Person and Virtual- TSW Reporting Opportunity

This sounds really interesting but I have a conflict. Please contact me if you would like to attend and report on it for TSW, TSW will pay registration. Even if you go in person :).
Here’s the link to register.

On Tuesday, April 18th, the Andrus Center will host an in person environmental conference focused on recreation and public lands with an eye towards resolving tensions and furthering best practices. Public lands act as anchoring institutions for surrounding communities. This conference, Re-creating Public Land Recreation, will celebrate the popularity of outdoor recreation on public lands and convene a dialogue over how to improve policies and funding, and collaborating across shared recreation spaces.

The conference is scheduled as a 7:30 am to 5 pm in person event and will be followed by a white paper. Due to the capacity of the venue, a virtual attendance option will be available.

Conference speakers will represent Federal and Tribal land managers, State and Local governments, and NGO and business leaders with expertise in recreation. Panel discussions will center on three themes:

Collaboration, especially working across jurisdictional proximities;
Funding, especially to overcome infrastructure and operational shortfalls;
Policy, especially shortfalls of current laws and policies.

Director of the Bureau of Land Management, Tracy-Stone Manning will deliver the lunch keynote address and will discuss ideas about what we can do together–with industry, partners, and land management agencies–to meet the challenges ahead. Former Montana Governor and Chair of the Foundation for America’s Public Lands (the charitable partner of the Bureau of Land Management, the new BLM foundation), Steve Bullock will address the emerging role of foundations and philanthropy to fill gaps and catalyze action. The remaining speaker lineup will be posted soon!

Registration for the full-day in person event is $85 and discounted student tickets are available thanks to the generosity of sponsors. There will also be registration for online viewing of the event for $20.

If you’re interested in representing us and reporting, please contact me.

DOE and BLM: Seemingly Contradictory Energy Strategy

Secretary Granholm at CeraWeek .Bloomberg photo.

Right hand-left hand. Interior vs. Energy.. with the White House as referee or ????

I’d like to start with Secretary Granholm’s statement at CERA week. From an article at E&E News..Energywire (open access).

The Biden administration’s seemingly contradictory energy and climate strategy was on full display here Wednesday: Try to pivot away from fossil fuels, but promote them for now.

Energy Secretary Jennifer Granholm faced that paradox as she addressed energy leaders and insiders gathered in a hotel ballroom, praising the uptick in U.S. oil and gas exports during Russia’s war in Ukraine while touting a clean energy shift.

“Europe is poised to reach the spring without major outages or shortages, and that’s thanks in no small part to many in this room, who have been producing and exporting and working with the U.S. and with allies,” Granholm said.

“Indeed, the U.S. has become in this year an indispensable energy partner to our allies and a global energy powerhouse,” she said to applause.

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Meanwhile, in another blow to the fossil fuel sector, the Biden administration said this week that a new five-year plan for offshore oil and gas drilling may be delayed until December (Greenwire, March 8).

To “complete all necessary analyses, approvals, and mandatory procedural steps, Interior requires until December 2023 to finish and approve the next Program,” said Walter Cruickshank, deputy director of the Bureau of Ocean Energy Management, in a legal filing.

That prompted a sharp rebuke from Sen. Joe Manchin (D-W.Va.), a key architect of the Inflation Reduction Act and a fossil fuel ally.

“The Department of the Interior made it painfully clear — again — that they are putting their radical climate agenda ahead of our nation’s energy security, and they are willing to go to great lengths to do it,” Manchin said in a statement Wednesday, saying the December deadline is “18 months late.”

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Despite Granholm’s comments commending the fossil fuel sector, she used much of her speech to champion a clean energy transition.

Granholm announced $6 billion in new grants for industrial decarbonization projects, which may involve carbon capture and hydrogen. And she urged the fossil fuel sector to help develop those and other technologies.

“The U.S. is the indispensable nation, and our companies are producing irresistible products. And this administration is all in on it,” Granholm said. “We need the energy sector stepping up and that certainly includes the oil and gas industry.”

“You have the skill sets and knowledge to build some of these critical technologies at scale,” she said.

There’s also a story at Bloomberg that looks interesting but is paywalled:
Energy Secretary Granholm Changes the Tune on Big Oil
Just five months ago, President Biden was accusing the oil industry of profiteering. Yesterday, his energy secretary went to Houston to shower executives with praise.

You’d almost think there are three loci of control… the pragmatic DOE, the ideological DOI and the White House trying to placate key Demo interest groups without going to far into doing things that won’t look good for the 2024 election. The oil and gas industry.. demonized by some, and flagellated to produce more by others in the same Admin. If I were a political science professor, I would find this fascinating. What causes agency divergence? Career feds, or loyalties of politicals to the interest groups they came from? When are divergences tolerated, and when are they expunged?

GAO Report on EPA’s Coordination (or Not) with Other Federal Agencies on Wildfire Smoke

I’m one of many people who has had the opportunity to be in interagency conflict resolution meetings, in my case FS, ACE and EPA.  My own experience (based on a few incidents) is that some EPA employees have an attitude toward land management agencies that is not conducive to collaboration.  Their attitude seemed to be “we know more than you do”, which they didn’t, and “we are more righteous than you” which they weren’t.  At the same time, I have to say that one of the best people I’ve ever worked with was a political appointee at EPA (a lawyer and law professor) during the Clinton administration. So I’m not saying they’re all like that.. but I’ve run into a few.

The theme of the next few posts  is “right hand and left hand” or… are federal agencies aligned in the same direction? I think all of us agree that federal tax dollars should not be wasted or mismanaged by opposing government programs (if it can be avoided) and that for important topics like decarbonization or wildfires, agencies should be aligned.  It’s the administration’s job to make sure that happens and enforce it within the executive branch. We’ve discussed before this EPA PM 2.5 thing. Too bad the GAO didn’t explore how the proposed rule could have gotten all the way to OIRA before anyone noticed it was a problem. That could really shed some light on coordination processes and efficacy. Thanks to alert TSW readers for noticing this GAO report.

Here’s a link to the GAO Report, published on March 13, titled “Wildfire Smoke:Opportunities to Strengthen Federal Efforts to Manage Growing Risks.”

It could be that there are so many wildfire commissions and task forces nowadays that the idea of high-level officials actually engaging with each other and resolving disputes has fallen by the wayside. Which is of great concern. So while the EPA says they will respond to the need for “better coordination” with land management agencies, they haven’t actually pulled the plug on revising the 2.5 NAAQS. Maybe they have sent signals to high level folks at USDA and Interior, but it would be nice for us here in the cheap seats to also get the message.

Here is the National Association of Forest Service Retirees letter on the proposed rulemaking, which I also received last week. If they are standing down on this for prescribed fire, it would save work by many in our space. If they are not standing down- well actions speak louder than words about “coordinating.” Maybe the need is for less “coordination” and more “woodshed.”

 

I’m always a fan of coordinating research..does this seem like something the USG should institute as a matter of course for research topics?

Additionally, officials from the CDC said that creating a framework for coordinating research related to community preparedness for wildfire smoke could help federal agencies more intentionally plan such research and create a community of practice on the topic.

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Here’s the air curtain discussion…

Also, to remove barriers to certain wildfire risk mitigation strategies, EPA officials said that the agency could, for example, finalize its proposed rule related to permit requirements for air curtain incinerators. Air curtain incinerators are devices for burning debris collected through methods such as mechanical thinning.92 According to EPA officials, these devices offer an alternative to prescribed burns and have much fewer emissions than burning debris piles or prescribed burns

And ..According to Forest Service officials, the use of air curtain incinerators helps reduce woody fuel on a site but does not necessarily reduce the need for prescribed burns to reduce fine surface fuels.

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I thought it was interesting to compare the views of the FS and BLM (Interior), who conceivably have the same issues:

In its written comments, USDA stated that the role of the Forest Service in responding to wildfire smoke and protecting public health, as well as the importance of mitigation efforts to address smoke impacts associated with
the wildfire crisis, was captured well in our report, and that this role and mitigation are critical to long-term efforts for wildfire risk reduction. USDA also stated that, as the environmental impacts of catastrophic wildfire
extend far beyond air quality, effectively implementing our recommendations requires focused collaboration beyond smoke and its impacts to public health. USDA said that only focusing on the effect of wildfire smoke on public health minimizes the breadth of the current crisis impacting the natural and human environment and neutralizes the most effective mitigation tool that also mimics natural processes—prescribed fire, which, according to USDA, can be managed to minimize impacts on public health.

In addition, USDA said that, as air quality standards become more stringent, expanded interagency discussions are needed to ensure the increased use of prescribed burning as the primary mitigation to catastrophic wildfire. USDA said that bolstering current authorities and approaches mentioned in our draft report should balance impacts on firefighter and public safety, water quality, and protection of municipal water supplies, among other environmental effects. As discussed in our report, EPA has raised other concerns related to the increased use of prescribed burning. We believe USDA would have important opportunities to raise these and related issues as it works with EPA and Interior to
implement our recommendation to better align air quality and land management goals.

 

Here’s Interior, which seems like the answer is “we’ll hire more people.”

In its written comments, Interior stated that to achieve our recommendation to work with EPA and USDA to better align air quality and land management goals, it plans to increase staffing to plan for and manage smoke emissions at the departmental and bureau levels and to work across agencies at the national and regional levels, as well as with tribal, state, and local governments and other external partners. Interior also stated that its management of air quality and wildfire risk mitigation goals will include an increasingly wide array of communications, data management, planning, budget development, wildfire operations, environmental justice efforts, and fuels management implementation, which will be supported by its additional staffing. Interior said these efforts will be initiated this year and will enable coordination of its existing efforts with EPA and USDA and the joint development of further efforts. Interior stated that this will support efforts to increase the pace and scale of fuels management treatments and address the overall wildfire risk reduction objectives included in the  Infrastructure Investment and Jobs Act. The actions Interior described, if implemented effectively, would address our recommendation.

“Don’t Let the Loud Voices Shape the Narrative”: Usual and Unusual Claims About Wildfire Mitigation Projects- Jefferson County Colorado Version

Environmental activists Josh Schlossberg stands near recently cut trees in Elk Meadow Park in Jefferson County on Feb. 28, 2023. Schlossberg, other activists and some residents are concerned that the county’s fire mitigation strategy, which calls for thinning trees near populated areas, are harming the forest. (Photo by RJ Sangosti/The Denver Post)

 

For some reason, there is a tendency in some outlets to talk about the Jefferson County controversy about fuel treatment in some open spaces, and pivot from there to the national debate about federal lands. it’s interesting to  see how different reporters cover it.   Apologies for this being so long, but I got very interested in the different takes on the same subject,  as well as the omnipresence in these stories of a certain Californian.

Here’s the most recent by the Denver Post:

Tagline:

Logging opponent describes “complete shock and horror” at the sight of felled trees

Evergreen resident JoAnn Hackos, who also serves as a board member with the Evergreen Audubon chapter, said Jefferson County is targeting too many mature trees.

“I’ve seen truckloads of large, old-growth trees being driven away from our neighborhood parks,” Hackos said. “There is lots of money to be made in selling big trees, but it irreparably damages the forest.”

The county, she said, is using a technique called mastication, which essentially chops up treated areas into mulch. Hackos said the practice disrupts the soil and damages roots.

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Chad Hanson, forest and fire ecologist with the John Muir Project in Big Bear Lake, Calif., said Jefferson County “is doing everything wrong.”

“Removing mature trees increases wildfire spread and severity,” he said. “When they do these logging projects under the guise of thinning, that reduces the cooling shade of the canopy. Denser forests do not burn more intensely.”

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But Germaine said it’s a misnomer to call the ponderosas that are being cut old-growth trees, a term that evokes more of an emotional response.

“Ponderosa pine trees only begin to take on old-growth characteristics between 200 to 300 years of age, and they may live to 400 to 500 years,” he said. “Some of the trees we are cutting are large, and some are approaching 125 years in age, but none are old-growth.”

And the notion that the county is making a windfall from timber sales resulting from the felling is simply untrue, Germaine said.

“We hire local small business people to do most of our forest thinning. A lot of the material is ground up and spread around on-site because it has no market value,” he said. “We hold firewood sales to provide wood to local residents, and the county does not profit from any of this.”

Jefferson County pays contractors about $3,500 an acre for thinning, Germaine said.

Steve Germaine is the Natural Resources Supervisor for Jefferson County.

Here’s another  Denver Post article.

The government faces opposition from forest lovers and environmental advocates who contend logging contractors operating with minimal oversight often mow down trees — rather than thinning — converting forests to grasslands, which the opponents argue could actually accelerate wind-driven fire. They accuse federal authorities of short-circuiting legally required environmental impact reviews. They favor “fire-wise” home safety as a smarter way to shave wildfire risks.

The argument comes down to ecological nuance and costs, which range from $500 to $7,000 an acre. It can be more feasible for loggers to cut broadly across an acre or more, rather than thinning that sometimes requires hiking on steep and hard-to-reach terrain, lugging chainsaws to remove trees selectively and optimizing spacing and species diversity.

There are two claims we usually don’t see.. that contractors don’t follow requirements and that feds short-circuit environmental reviews. It would be handy to have a quote from a person here, who could later be asked about specifics.

Fury over forest cutting intensified this summer and a grassroots Eco-Integrity Alliance deployed a billboard in central Denver urging President Biden and Colorado’s senators to “stop wasting $3 billion” for logging national forests.

Here’s the link to Eco-Integrity Alliance.  It appears to be an alliance of groups including:

Eco Advocates NW

Friends of the Clearwater

Friends of the Wild Swan

John Muir Project

Protect Our Woods

Swan View Coalition

And I suppose a billboard costs some bucks, so there must be some funding associated with these groups.

What’s interesting about the Finley piece to me is he brought up Hanson as an advocate, not as the voice of science.

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Here’s a Westword article. Westword is one of those independent papers you usually see in newstands in coffee shops in cities.. lots of culture and marijuana ads.

First the article talks about how Jeffco Open Space decided to do the project, including the mapping by Colorado Forest Restoration Institute of CSU and a verbal description of the rationale.

As JCOS implements forest-thinning projects, it tries to cut younger trees out of areas that have more trees per acre than what it estimates would have been there without historic fire suppression.

Sound familiar.. a la East Side screens?

Not all forests fit that mold, though, including those populated by ponderosa pines, points out Chad Hanson, practicing ecologist and director of the John Muir Project, which works to improve ecological management of public forests.

“The science strongly contradicts that narrative,” he says. “This is true for forests all across the West. This is true in the Colorado Front Range. … Everywhere scientists have looked at this, we’ve found the same thing: that historical forests were much denser overall than the U.S. Forest Service, or some state agencies that are involved in logging, have told the public they were.”

An expert person on the ground says “our forests are like this’ to Chad saying “the science says that many are not”. I think the question is simply “is this true of the forest we are working int?”

Schlossberg’s (he of the Steering Committee of the Eco-Integrity Alliance- sf) concerns come not only from the lack of scientific considerations in the forest-thinning plan, but also from the age of some of the downed trees. According to Germaine, the department doesn’t remove trees that are technically considered “old growth.” Those trees provide habitat for small mammals and birds and, if they are over 150 years old, were likely around before European intervention in American forests. It’s important to eliminate younger trees to keep the forest healthy, he contends.

“We don’t get a lot of water here on the east side of the Rocky Mountains, so when those trees are too crowded, they’re competing,” Germaine says.

According to Brett Wolk, assistant director of CSU’s Colorado Forest Restoration Institute, ponderosa pine tree systems take centuries to develop, and the trees can live for 500 years.

Schlossberg still takes issue with the idea that cutting down trees that have lived for a century is the answer, especially when it comes to the ponderosa pine.

“Why is it that ponderosa pine can grow that old?” he asks. “The answer is because they’re fire-resistant trees.”

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“The notion that removing trees from the forest will curb fire has been soundly discredited,” Hanson says. “Wildfires are driven mostly by weather and climate, and therefore also by climate change. In drought years, you get the ignition, and you get hot, dry, windy conditions. Those are conditions for fires. It’s not mainly about forest density.”

In forest fires, trees like the ponderosa pine are rarely consumed; removing them doesn’t change fire intensity because they don’t contribute combustible materials. A study of California forest fires showed that even large wildfires consumed only about 2 percent of tree biomass.

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Hanson warned of emerging “sterilized landscapes” where forests once stood around cities.

The cited paper is by Harmon, Hanson and DellaSala (he who reviewed the Proforestation paper we discussed).  It’s perfectly OK to be against commercial logging.  It’s when you claim that “the science” says something and it turns out that we can find plenty of scientists who don’t agree.  To reporters: anytime someone says “the science says this,  ask them “are there any scientists who disagree with you?” and interview them.

They cannot go toe-to-toe with us on the scientific evidence,” he says. “Every time they try, they lose, so now, in desperation, they’re hitting below the belt, and they’re going personal and engaging in character assassination.”

Hanson believes that the logging industry relies on people buying into a positive narrative around cutting down trees, so it lobbies Congress to support forest-thinning management to keep that narrative alive. That lobbying trickles down to local forest management, he adds.

Or maybe other scientists  can go toe-to-toe, and have in the 10 Common Questions paper.  This is where some skepticism by the reporter might have paid off.

Here’s a link to a Colorado Sun story from last September. The Colorado Sun is a journalist-owned independent news outlet.

Again, Schlossberg

“What’s happening is we’re using the public lands as the sacrifice zones. We don’t think any of this tree cutting should be happening on public lands,” Schlossberg said. “It’s not justified scientifically or ecologically.”

A quote from Denver Mountain Parks.

The portions of Flying J that have raised the most public ire are actually controlled by Denver’s mountain park system, which cooperates with Jeffco when they have adjacent land.

“We got the short end of the stick at Flying J,” said Andy Perri, a Denver Mountain Parks program manager for forestry and natural resources. “We were dealt a very unhealthy forest on our two sections.”

Thick lodgepole stands on Denver’s portion of the property were plagued by beetles and dwarf mistletoe, which grows in the canopy and effectively places a tinderbox high in the forest. So Denver simply had to remove more, creating the shorn-land look that riled many visitors.

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“We try our best to contact neighbors, but it’s just me and two others in our program,” Perri said. Reaction ranges from extremely upset to extremely grateful, he added. “I try my best to explain the science — and we’re not here to sell timber, our wood is basically worth nothing.”

If a loud voice falls in the forest, does anyone hear? 

Hannah Brenkert-Smith watched some of the same thinning vs. perception dynamic play out during a 2,460-acre cutting program on Arapaho-Roosevelt National Forest lands around Nederland. The plan included a public conflict-resolution process, which Brenkert-Smith later studied from her position in the Environment & Society Program at the University of Colorado’s Institute of Behavioral Science.

“What we found is that the people who are in opposition were actually in the minority,” Brenkert-Smith said. “They’re just really vocal and well organized, and they get a lot of attention.”

Forest managers the researchers worked with were often braced for much more overwhelming opposition that never really materialized, Brenkert-Smith said.

“So one of the things that I think is really important is not to assume what the public is going to think. And also not to let loud voices shape the narrative,” she said. “You actually have to go out and find out what people think, and not just the people who have the time and the motivation to show up at everything, and to write all the letters and to harness their social capital, but the silent majority who tends to be supportive.”

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This story gets points for including local scientists, and a social scientist.