21st Century Problems

Let’s Discuss: PERC’s “Next Era of Conservation”

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As the year draws to a close, let’s take our eyes from the day-to-day and look at the bigger picture.  Turns out that PERC has given us a template for that discussion.

 

Note: PERC had a good year in 2025. One of the ideas they championed . charging international visitors more for access to the National Parks with the funding going to the Park, has been adopted by the Feds and is beginning January 1.

Beginning Jan. 1, 2026, international visitors will pay a $100 surcharge at the 11 most visited national parks. PERC CEO Brian Yablonski shared this statement in response to the announcement from the Department of the Interior:

“This is a big win for everyone who loves America’s national parks. A $100 international visitor surcharge could generate $55 million annually at Yellowstone National Park alone, more than quadrupling that park’s revenue to address deteriorating trails, failing wastewater systems, and crumbling bridges.

PERC has long led an effort to adopt this smart pricing approach, already common abroad, as a way to steward America’s best idea. Thank you Secretary Burgum and the Department of the Interior for your leadership and working with us on this monumental investment in our parks.”

For a deeper dive, read PERC’s report exploring pricing options at Yellowstone, The Economics of Awe.

There was also a NY Times story on their virtual fencing efforts, and they added Robert Bonnie (in USDA political leadership from Obama to Biden) to their board.

PERC held a workshop at which they discussed “the Next Era of American Conservation.” The entire piece is linked here.. I thought it might be interesting for us to discuss some of their ideas.

Bryan Yablonski wrote down some of their ideas..in the piece, there are a few paragraphs on each one of these.

Private lands are the next frontier of conservation
Conservation must be bottom up, not top down
Speed up proactive conservation efforts, rather than slowing things down
Incentives and markets will need to play a more prominent role in the next era

Finally, a handful of other innovations—in technology, ambition, and philanthropy—will likely shape the next era of conservation.

Today, thanks to GPS tracking and remote sensing, we know that many species of wildlife migrate through corridors that transect a tapestry of public and private landownership boundaries.  A focus on conserving the fluidity and messiness of corridors, connectivity, and cross-boundary solutions will be just as relevant in our time as the creation of more geometric national parks and forests were in the time of T.R.

Moreover, setting big goals that can be achieved in an era’s-worth of time is a worthy priority. Where are the conservation moonshots? Why can’t we set a goal of recovering 10 percent of endangered wildlife rather than the dismal 3 percent of the last 50 years? Why can’t we “de-fence the West” of 625,000 miles of barbed wire in a way that makes better economic sense for ranchers through virtual fencing?

What are your ideas for conservation “moonshots”?

Similarly, private philanthropy is a marketplace that must become more entrepreneurial in backing new tools, experiments, and innovations. Conservation philanthropists tend to circle the wagons around the safe, older tools of the past or the politically popular issues of the day. But such safe thinking perpetuates the disconnect between challenges and solutions, rather than encouraging invention. With more tolerance for risk, the philanthropic community can act as a player in conservation markets to catalyze conservation innovation.

My own experience with philanthropies moving into the wildfire space, as they recently have, is that they seem to be more about strategizing, convening, collaborating and partnering and maybe funding some research (which often sounds duplicative with other research).  I don’t know if that’s from the lack of new ideas coming in from local folks, or from the difficulty of entering a new space and understanding what is truly helpful by the philanthropy staff.  Or maybe better linkages need to be made between people currently working in an area and philanthropic organizations. Or maybe they haven’t hired folks with market backgrounds or aren’t interested in market solutions?

Finally,

From Static to Dynamic

The story of conservation in this country has never been static, but it feels static at this moment. Perhaps our reliance on federal, top-down problem solving for more than a century has run its course. Perhaps our feet are stuck in the cement of the previous eras. That said, there are signs of vitality.

The window of what is socially and politically possible is shifting. As the wildfire crisis in our forests explodes, there is growing bipartisan support to accelerate mechanical thinning and prescribed burning by cutting red tape and limiting litigation. Some conservation organizations are beginning to soften hardline stances on endangered species policy, enabling quiet conversations about how to improve actual recovery rates. Likewise, wildlife migration policy became a priority for the first Trump administration, then bucked the trend by continuing to be championed by the Biden administration rather than being unwound as many other policies were.

Finally, conservation groups once seen as regulatory and litigious adversaries of private landowners like ranchers and farmers are recognizing that development has become an even greater threat than extractive industries. Many of these groups have recalibrated and now seek to work with private landowners by harnessing incentives that enable these ranches and farms to operate in an economically viable way. Trust still needs to be built to bridge to more landowners, but many conservationists now see working lands as integral to their efforts.

These are all paradigm shifts that would make conservation more dynamic. For those of us who recently sat on the hallowed ground that is Mardy Murie’s front porch, the message could not have been clearer: We stand at a hinge point in America’s conservation story.

As inaugural participants in an ongoing dialogue about the next era of conservation, we may not have all the answers. But a good place to start would be an environmental reboot with several aims: 1) double down on private land stewardship with newer creative tools, 2) pivot from using evermore regulation to harnessing incentives, innovation, and markets that reward conservation, 3) lean into the local by bringing a bottom-up, rather than top-down, mentality to the challenges of today, and 4) recognize the need for reforms that deliver action and speed, especially when it comes to improving the management of our public lands and imperiled wildlife.

These approaches are not so much a departure from our heritage as they are a natural extension of it.

What do you all think?

The focus on private lands does remind me of the 2005 Forest Service report “Forests on the Edge“and previous FS efforts on forests and private lands.  It seems to me that the current connections of the Forest Service with its State Tribal and Private programs are key to keep.  Also the linkage to  USDA and its existing landowner grant programs and local offices will be key in maintaining and strengthening those linkages.  In fact, perhaps the BLM should move to USDA?

Could the federal government improve coordination and delivery of its  private conservation programs?

If all conservation is ultimately local, what is appropriate role of the federal government  (we already have LWCF and various other programs, but this question is more “what should it be?”). Block grants to states? What other kinds of help could the federal government give?

If you were a large foundation, what kinds of projects would you fund to further Bryan’s goals 1, 2 3 and 4? What are the gaps that you see that are filled neither by current philanthropy, NGOs, nor governments?

The Recoding America Fund

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I thought I’d start this conversation even though FS employees are not back to work yet.   I am a big fan of both improving government operations and departisanizing pretty much anything. So I was impressed by Jennifer Pahlka’s Substack post:

That’s why we’re launching the Recoding America Fund. It’s a pooled philanthropic effort that will raise and deploy at least $120 million over the course of the next six years. We’ll build off the work of so many over the past decades who’ve seen this problem from a variety of angles: the Congressional modernization field, good government groups, the civic tech community, think tanks who see the futility of their policy recommendations when they land in a system that can’t faithfully execute them, private sector leaders and contractors who have had to grapple with unnecessary government bloat, and others. But while this work will leverage the powerful insights so many have gained from grappling with a system in disrepair, it is also discontinuous with the past in three ways. First, the frame is no longer transparency or accountability or modernization, but rather state capacity – simply, the ability of our government to achieve its policy goals. Second, we seek to build a diverse but coherent field around that frame, one in which advocates can achieve more collectively than each could alone, while maintaining their own perspective and tending to their own politics. And lastly, we are collectively committed to leveraging this moment of disruption to achieve what’s needed for the future of our country, not what’s comfortable or convenient.

We have a view on how to do this. If you want a government that can achieve its policy goals, it must be capable of four key things:

  • It must be able to attract, select, develop, retain, and manage the right people, which means we need civil service systems at all levels fit for that purpose. Our civil service systems run the gamut from merely outdated to fundamentally unfit for this critical work.
  • It must ask those people to do the right work, which means reducing the procedural bloat that keeps most civil servants from focusing on the substantive outcomes the public needs and expects.
  • It must have purpose-fit systems, which means changing how we build and buy technology so it can adapt to changing needs and drive effective operations.
  • And it must employ test-and-learn frameworks, which means being able to act on what we learn as we pursue policy goals rather than stay locked into decades-long plans even as we can see they are not working. This also means constructing feedback loops between the makers of law and policy and those who implement them or experience their consequences, intended and unintended.

If the feedback loops sound a bit like adaptive management or continuous improvement, well, so be it.

Of course, when I think of “locked into decades-long plans even as we can see they are not working.” I see.. the entire NFMA planning process. But that’s just me. What I like about this effort is dreaming the dream of making things better even as downsizing and budget reductions are going on.

So I wonder what you would put on the table, either employees, retirees, or the general public.

One thought I had is better integration of visitor info across federal lands.  This does not require moving the FS to Int, it just would help if some efforts were joint that clearly don’t need to be separate.  For example,  the NPS app worked well to show us a map of where we were, sites of interest around there, and descriptions (which got a bit didactic and climate-y, but that could be edited).  Also, the recorded sections didn’t work but the transcript did, but maybe that’s because of poor internet access (which is likely to be an issue in many places).  Maybe a “be sure to download before you go” would be helpful.

Ideas?

New to national forests – carbon sequestration

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The world’s largest carbon direct air capture facility has started construction in Iceland

From the news release:

The U.S. Department of Agriculture’s Forest Service today announced a Notice of Proposed Rulemaking (NPRM) that would allow the agency to consider proposals for potential carbon capture and sequestration projects on national forests and grasslands. This proposal would harmonize the framework between the federal government’s two largest land managers by aligning with regulatory structures already established for the U.S. Department of Interior’s Bureau of Land Management.

If this amendment is finalized, applications for carbon sequestration on national forests or grasslands would be considered for permanent use. The proposed regulation changes the initial screening criteria to allow the Forest Service to consider proposals for carbon capture and sequestration projects and does not allow for any other permanent uses on national forests and grasslands.

From the Federal Register:

The United States Department of Agriculture, Forest Service (Forest Service or Agency), is proposing to amend its special use regulations, which prohibit authorizing exclusive and perpetual use and occupancy of National Forest System lands, to provide an exemption for carbon capture and storage.

Carbon dioxide injected in pore spaces may remain for over 1,000 years after injection and would be tantamount to an exclusive and perpetual use and occupancy if authorized on NFS lands.

The proposed rule would not authorize carbon capture and storage on NFS lands. Rather, the proposed rule would exempt proposals for carbon capture and storage from the initial screening criterion prohibiting authorization of exclusive use and occupancy of NFS lands, thereby allowing the Forest Service to review proposals and applications for carbon capture and storage and to authorize proposed carbon capture and storage on NFS lands if, where, and as deemed appropriate by the Agency.

Proposals for underground storage of carbon dioxide would have to meet all other screening criteria, including but not limited to consistency with the applicable land management plan, potential risks to public health or safety, conflicts or interference with authorized uses of NFS lands or use of adjacent non-NFS lands.

Of course it would have to be consistent with forest plans, but would a forest plan that authorizes “exclusive and perpetual use and occupancy” of national forest lands be consistent with the Multiple-Use Sustained-Yield Act?  (Is the BLM different in this regard?)  I assume that’s why the existing special use regulations are written to prohibit permanent uses.  Maybe this should be viewed as a question of divesting ownership rather than a permitted special use.

 

And Then There Is This – Globally Wildfires Decreasing Since 2001

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Italics and bolding added by Gil

#1)  WSJ ByBjorn Lomborg,

Climate Change Hasn’t Set the World on Fire

a) It turns out the percentage of the globe that burns each year has been declining since 2001.

b) For more than two decades, satellites have recorded fires across the planet’s surface. The data are unequivocal: Since the early 2000s, when 3% of the world’s land caught fire, the area burned annually has trended downward.

c) In 2022, the last year for which there are complete data, the world hit a new record-low of 2.2% burned area. Yet you’ll struggle to find that reported anywhere.
d) Yet the latest report by the United Nations’ climate panel doesn’t attribute the area burned globally by wildfires to climate change. Instead, it vaguely suggests the weather conditions that promote wildfires are becoming more common in some places. Still, the report finds that the change in these weather conditions won’t be detectable above the natural noise even by the end of the century.
e)Take the Canadian wildfires this summer. While the complete data aren’t in for 2023, global tracking up to July 29 by the Global Wildfire Information System shows that more land has burned in the Americas than usual. But much of the rest of the world has seen lower burning—Africa and especially Europe. Globally, the GWIS shows that burned area is slightly below the average between 2012 and 2022, a period that already saw some of the lowest rates of burned area.
f) The thick smoke from the Canadian fires that blanketed New York City and elsewhere was serious but only part of the story. Across the world, fewer acres burning each year has led to overall lower levels of smoke, which today likely prevents almost 100,000 infant deaths annually, according to a recent study by researchers at Stanford and Stockholm University.
g)  Likewise, while Australia’s wildfires in 2019-20 earned media headlines such as “Apocalypse Now” and “Australia Burns,” the satellite data shows this was a selective narrative. The burning was extraordinary in two states but extraordinarily small in the rest of the country. Since the early 2000s, when 8% of Australia caught fire, the area of the country torched each year has declined. The 2019-20 fires scorched 4% of Australian land, and this year the burned area will likely be even less.
h) In the case of American fires, most of the problem is bad land management. A century of fire suppression has left more fuel for stronger fires. Even so, last year U.S. fires burned less than one-fifth of the average burn in the 1930s and likely only one-tenth of what caught fire in the early 20th century.

 

#2)  The Canadian Take by LIFESITE News,Thu Aug 31, 2023

New research shows wildfires have decreased globally while media coverage has spiked 400%

Climate change in the courts – a win for Montana youth plaintiffs

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I mentioned this Montana lawsuit in an earlier litigation update since it was going to be the first case going to trial nationally involving youth plaintiffs demanding action on climate change in a state court.  Since then, we’ve been debating climate science a little here, so here’s an update.  The trial happened and the court ruled in favor of Plaintiffs on one claim (2023.08.14-Held-v.-Montana-victory-order):  a recent change in Montana’s environmental policy act (MEPA), which prohibited consideration of impacts on climate for proposed projects, “violates Plaintiffs’ right to a clean and healthful environment and is facially unconstitutional.”  The state also failed to show that “the MEPA limitation serves a compelling government interest.”

The Montana state constitution includes this specific right, so the applicability of this outcome elsewhere is uncertain, but Plaintiffs’ attorneys (who are representing youth plaintiffs in other climate cases) are optimistic that it may provide some momentum.

The Washington Post had an interesting take on factual questions related to climate change:

In a pivot from its expected defense disputing the climate science behind the plaintiffs’ case, the state focused instead on arguing that the legislature should weigh in on the contested law, not the judiciary.

Michael Gerrard, the founder of Columbia’s Sabin Center, said the change in strategy came as a surprise: “Everyone expected them to put on a more vigorous defense,” he said. “And they may have concluded that the underlying science of climate change was so strong that they didn’t want to contest it.”

The state’s defense was unsuccessful. Judge Kathy Seeley determined that the state’s emissions could be fairly traced to the legal provision blocking Montana from reviewing the climate impacts of energy projects. She further wrote that the state’s emissions and climate change have caused harm to the environment and the youth plaintiffs.

If the WaPo article isn’t viewable, here’s another with more background on the case.

(It was interesting when I looked for a meme to include with this post – they seem to be dominated by not-very-clever climate change denialism.)

Sierra At Tahoe Ski Area Re-opens

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After the Caldor Fire seriously impacted the ski area, Sierra At Tahoe is open again. As you can see, it was a high intensity portion of the fire, with the previous forest being highly flammable and loaded with decades of heavy dead fuels. After several droughts, the area did not have any salvage operations. The area is also known to have nesting pairs of goshawks around.

As you can see, snow sports people will be enjoying a new experience of skiing and boarding, without so many trees ‘hindering their personal snow freedoms’. *smirk*

Possible Salvage Strategy for Dixie and Caldor Fires

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Since a battle for salvage projects is brewing, I think the Forest Service and the timber industry should consider my idea to get the work done, as soon as possible, under the rules, laws and policies, currently in force. It would be a good thing to ‘preempt’ the expected litigation before it goes to Appeals Court.

 

The Forest Service should quickly get their plans together, making sure that the project will survive the lower court battles. It is likely that such plans that were upheld by lower courts, in the past, would survive the inevitable lower court battles. Once the lower court allows the project(s), the timber industry should get all the fallers they can find, and get every snag designated for harvest on the ground. Don’t worry too much about skidding until the felling gets done. That way, when the case is appealed, most of Chad Hanson’s issues would now be rendered ‘moot’. It sure seems like the Hanson folks’ entire case is dependent on having standing snags. If this idea is successful, I’m sure that Hanson will try to block the skidding and transport of logs to the mill. The Appeals Court would have to decide if skidding operations and log hauling are harmful to spotted owls and black-backed woodpeckers.

 

It seems worth a try, to thin out snags over HUGE areas, while minimizing the legal wranglings.

Are Drones Like E-Bikes? Or, is the Forest Level the Right Place to Decide, and Is There/Should There Be Some Form of National Direction?

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Drones.. are some uses OK and others not? Video of Sequoia NF https://www.youtube.com/watch?v=JAfr_J6Z2uQ
Video of Sequoia

I’ve been reviewing some of the posts since I was gone, and thought the topic of drone decisions as brought up by Patrick McKay with regard to the GMUG plan revision.

You may remember when it came to e-bike policy, the Forest Service issued a generic policy and then suggested that each unit make site-specific decisions (as did BLM, see Steve’s post here).
Is this the current policy?

Questions:
1. is there a generic national drone policy to which the GMUG is responding?
2. Is a forest plan the right place to make the decision (and if so, does that mean no decisions until all revisions are complete (in 20-30 years))?
3. Should a generic policy be harmonized at least between the BLM and the FS due to interconnected lands/potential for confusion?
4. Since it seems that drones would be handy indeed for various forms of law enforcement that are otherwise difficult to afford in spread out spaces, e.g. this story from Hamilton, Ontario, would there be separate rules for law enforcement’s/ emergency rescue’s use of them? Researchers? Managers of wildlife/trees/recreation/fire?

This interesting article in Sierra Magazine (about drones in Parks) points out that 1. It’s hard to enforce. 2. Scientists use them all the time as well as search and rescue folks, and 3) they can also be used for management activities including PB.

The effort to keep parks drone-free is complicated by the fact that the machines have become indispensable to scientific research. “We have folks using them for various mapping purposes [and] surveys,” says Kristin Swoboda, a fixed-wing fleet and UAS specialist at the National Park Service. Her department receives weekly requests to record caves and archaeological sites, light prescribed burns, and monitor geologic events like landslides and glacial retreat.

Small aircraft are perfect for these tasks, especially fire management. “A helicopter is a whole lot more expensive and risky,” Buehler says. With prescribed burns, “you basically have someone leaning out the door trying to ignite fires with [something like] a paintball gun.” In the past five years, at least three people have died in helicopter crashes connected to prescribed burns in national forests. Drones can drop fire-starting agents remotely. “We by all means do not want to crash drones, but if we do, it’s not killing anybody.”

UAS are also increasingly considered essential to search-and-rescue operations. In 2017, Arizona’s Tonto Rim SAR team used drones to map safer rappels while recovering the body of a fall victim, and Colorado’s Douglas County SAR rescued two lost hikers in Pike National Forest after spotting them with a drone. “It’s really hard to find people, and drones are yet another tool,” says Morris Hansen, the lead drone pilot and vice president of Douglas County SAR. Some models carry enough weight that they can be used to drop supplies to victims or safely get a rope to them.

Other questions or thoughts?

Planning for protection from recreation

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This blog has discussed the effects of recreational activities on wildlife (here’s one), and whether federal land managers should be doing something different (than basically reacting to overuse).  It might be worth looking at how planning for use of newly acquired land is being done by local governments and land trusts that are interested in wildlife, and there happen to be a couple of current examples from Colorado.

Fishers Peak is a new state park near Trinidad, Colorado.  It was formerly a private ranch with very little recreational use and no trails or other developments.

“This is a property that has not been loved to death,” Dreiling says. “It’s been pretty well protected, and it’s important to us that we put recreation on this property in a wise way, in a thoughtful way. It’s an important ball that we’re not going to drop, that balance of conservation and recreation.”

In practice, that means a trail won’t be built just because it accesses the prettiest views; instead, the project partners are, for example, assessing where wildlife corridors are located and what sorts of impacts motorized vehicles could have so the public can enjoy the land inside Colorado’s second-largest state park without worrying too much about the environmental consequences. The park’s full playbook is still being drawn up, so not all of these questions have been answered, but efforts to bridge the sometimes conflicting ambitions of recreation and preservation could set a new standard for future projects—here and across the country.

Pitkin County has purchased land and granted a conservation easement to the Aspen Valley Land Trust to protect wildlife habitat.

The easement language includes a nod to a 2016 policy adopted by the Pitkin County Open Space and Trails Board, which states that the county shall “rely on the best available science for property-specific study of natural habitat conditions, including the role of the property in the context of larger habitat and wildlife patterns in the Roaring Fork watershed.” That policy also states that “human uses, if any, will be planned and managed to minimize intrusion into breeding/nesting areas and migration corridors … (and) minimize intrusion into the time periods and/or places of special habitat concern.”

Allowances for human use on the property are not guaranteed and would be made only after detailed studies are completed on site-specific conditions, identifying wildlife and habitat needs.

“You answer those questions first and then say what niches are left where you can integrate humans,” Will said in an interview. That could take the form of enacting seasonal closures or making specific areas of the property off-limits year-round. The management plan could take years to come together.

Of course federal lands are already developed to facilitate recreation.  This doesn’t mean they couldn’t be redeveloped (or undeveloped) where effects on wildlife have been identified.

Woodman spare that forest (the climate needs it)

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Source: Biodiversity Sri Lanka

I’ve been wondering if there is a straightforward answer to the question of how to best manage forest lands to sequester carbon for the foreseeable future to reduce potential climate change impacts.  We’ve beaten around that bush a few times, such as here.

I thought such an answer might be found in the kind of forest management activities carbon offset programs are willing to pay for.  I recently ran across this example, which describes two new programs for small forest landowners.

“Forest carbon projects have historically faced skepticism around their additionality and potential for leakage — that is, the shifting of tree removals to nearby acreage. The concern is that despite paying a landowner to keep trees on one parcel, the same number will simply be removed elsewhere, resulting in a null offset with no net change in carbon storage. Yet SilviaTerra believes this problem can be addressed by creating a market in which all landowners are eligible to receive carbon payments as an alternative to timber revenues…  Payments are scaled to target the timeframe when forests have matured to a point of likely timber harvest… SilviaTerra believes that timber harvest deferrals hold the potential for removing over a billion tons of atmospheric carbon within the United States in the coming decade, or 4.3 billion tons globally.”

SilviaTerra is paying landowners to not harvest mature trees now, and presumably they would continue to do that indefinitely for a parcel because, (according to this article on the carbon value of old forests), “We now know that the concept of overmature forest stands, used by the timber industry in reference to forest products, does not apply to carbon.”   The Family Forest Carbon Program pays for “improved forest management practices,” “such as removal of invasive species or limiting thinning.”  Both seem to treat the answer to my question as obvious – the best management for carbon is “don’t cut down trees.”

Here is what the Forest Service has had to say about the best available science.  This 2017 General Technical Report covers a lot of the pros and cons and questions and considerations and reservations that we have previously discussed, such as wood products, wood energy and fire risk, but if the goal is to “maintain and increase carbon stocks,” the best answer appears to be “decrease carbon loss:”

“Decreasing the intensity of forest harvest is one way to decrease carbon losses to the atmosphere (McKinley et al. 2011, Ryan et al. 2010). Across diverse forest systems, the “no harvest” option commonly produces the highest forest carbon stocks (Creutzburg et al. 2015, Nunery and Keeton 2010, Perez-Garcia et al. 2007).”

The Report was written for a broad audience of landowners and managers, so it also discusses options for managed stands:

“Managed stands typically have lower levels of forest biomass than unmanaged stands, even though the annual rate of sequestration may be higher in a younger forest. In managed forests, reducing harvest intensity, lengthening harvest rotations, and increasing stocking or retention levels will generally increase the amount of carbon stored within forest ecosystem carbon pools in the absence of severe disturbance (D’Amato et al. 2011, Harmon 2001, Harmon and Marks 2002, McKinley et al. 2011, Taylor et al. 2008b).”

However, they also provide caveats and qualifiers associated with obtaining overall carbon benefits from any strategy that removes trees, which make it clear this would likely be a second-best strategy for carbon sequestration.

With regard to national forests, the Report recognizes the role of NFMA and forest plan revisions:

“Assuming carbon is one of these key ecosystem services, the plan should describe the desired conditions for carbon in the plan area that may vary by management or geographic area. In developing plan objectives, the interdisciplinary team should consider the linkage between carbon and how plan objectives would contribute to carbon storage or sequestration. Standards and guidelines may also be needed to achieve desired outcomes for carbon.”

We shouldn’t have to just assume the importance of carbon sequestration, since that is a decision a forest plan could make.  With an incoming administration that has said it would integrate climate change into everything it does, a good question to ask them would be why should the Forest Service not establish in its forest plans the desired outcome to “maintain and increase carbon stocks.”  This should create a presumption or default that trees should not be removed unless the Forest Service can demonstrate scientifically that it would improve carbon sequestration (apparently difficult to do), or if it would meet some other goal that the planning process has determined is a higher priority than climate change (such as public safety).  Climate change mitigation has typically been diverted to a side-channel during forest planning, but there doesn’t seem to be any excuse now for why at least managing for carbon sequestration isn’t mainstream.