Forest Management

Stanislaus spotted owl plan amendment

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Photo of female and juvenile California spotted owl courtesy of University of California Cooperative Extension (http://ucanr.org/sites/spottedowl/).

We recently looked at the Biological Assessment of Northwest Forests, and the options for proceeding with revising forest plans currently governed by the Northwest Forest Plan. Some of those options involved amendments to existing plans prior to plan revision. I voiced support for amendments that would provide the ecological conditions needed for at-risk species. I thought this might be an example to look at for how that might go.

The Stanislaus National Forest is not in the area covered by this assessment. Its forest plan was originally completed in 1991, but it was amended by the Sierra Nevada Forest Plan Amendment (or Framework) in 2004, which is roughly analogous to the Northwest Forest Plan in that it had its origins in the work done to protect the California spotted owl (it has its own complicated political and legal history). Now the Stanislaus is proposing an amendment for a part of the Forest in conjunction with what it calls the Social and Ecological Resilience Across the Landscape (SERAL) project.

The Forest has identified a need to change the forest plan based on new information about the California spotted owl, as published in 2019 by the Forest Service in the “Conservation Strategy for the California Spotted Owl in the Sierra Nevada.”

In order to fully adopt and implement the management direction described in the Conservation Strategy and increase landscape resiliency as guided by NRV the Stanislaus National Forest’s forest LRMP must be amended. The proposed forest plan amendments would allow the SERAL project’s proposed landscape restoration treatments to best meet the purpose and need of the project and implement the guiding principles of the 2019 California Spotted Owl Conservation Strategy. The proposed amendments include standards and guidelines which will provide some immediate stability for individual owls while allowing forest management the ability to conduct treatments designed to help develop resilient habitat conditions that provide CSO conservation in the long term.

Unfortunately, the CSO Conservation Strategy was apparently written for a narrower purpose than its name implies:

The California spotted owl (Strix occidentalis occidentalis) Conservation Strategy is a strategic framework for active conservation of the California spotted owl on National Forest System lands in the Sierra Nevada.

It appears to be something less than a scientific strategy. By limiting the focus to “active conservation” it has failed to address the central debate about managing spotted owl habitat regarding when active management should even be used. Passive management is one obvious alternative to this amendment that the Forest is going to have to address in its amendment process. But I looked at some of the proposed changes in the forest plan.

The current plan designates spotted owl Protected Activity Centers (PACs) as management areas in the forest plan (which could be changed only by amending the forest plan). This proposed amendment would replace current management areas with guidelines to designate PACs later “in advance of any management activities that would reduce CSO nesting and roosting habitat quality.” The guidelines include criteria for delineating and changing PAC boundaries.

My opinion: This is not a coarse filter management strategy based on vegetation because it depends on actual owl presence based on surveys, or one might call it “condition-based.”  If owl presence is the kind of thing that changes frequently, this may be a reason to not designate permanent management areas at the plan level.  However, this creates the risk of cutting the public out of the part of the process that actually determines the locations for management.  The plan is no longer saying, “here is where we’ll manage for owls,” but instead, “we’ll manage for owls where we think we need to manage for owls, trust us.”  The criteria must be explicit and objective enough to fully evaluate at the plan level, and the decisions about whether and how to apply them at the project level must include the public. Given the importance that surveying would take on, there is no excuse for these being guidelines rather than standards. It seems to me that the certainty of owl protection, and therefore the viability of the species, is going to be reduced.

There are a lot of new plan components in the amendment, and the CSO Conservation Strategy is page-referenced for most of them. That’s how any conservation strategy should be used, so maybe this is a good example of that. Except that it strikes me that this “conservation strategy” may have actually been written as a “drop-in” amendment to be used this way (which makes that kind of cross-referencing a lot easier). This is similar to what would happen if plan amendments were developed that could be later “dropped in” to forest plan revisions. The problem is that if the “conservation strategy” is already a management-influenced document and not a science document, there would still need to be a reference to the actual scientific basis for these conservation recommendations that are being adopted.

Anyway, this project/amendment will be worth watching as it applies the 2012 Planning Rule diversity requirements to California spotted owls. And it may be setting some precedents for what could happen regarding how to plan for management of spotted owl habitat on other national forests.

Collaborating on national forest exploitation – an oxymoron?

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“Attendees engaged in fruitful conversations during the Green Mountain and Finger Lakes National Forests hosted Environmental Analysis and Decision Making collaboration summit. USDA Forest Service photo.”

“Before retiring, James Burchfield worked as a field forester for the Forest Service and served as dean of the W.A. Franke College of Forestry and Conservation at the University of Montana.”  Where our careers overlapped, he was known for his support of and expertise in collaboration in national forest management.  We have argued on this blog about the proper role of collaboration (it flared up again in the Rim Fire recent example), but in this Missoulian column he points out what I think most would agree is an improper role (on his way to making another point about adequately funding the Forest Service).

In 2002, former Chief Dale Bosworth, who now resides in Missoula, reminded the agency of the concept of stewardship, where the focus is not what we take from the land but what we leave on the land. I fear we may be forgetting these vital lessons.

The June 12 visit to Missoula by Agriculture Secretary Sonny Perdue to announce his Secretarial Memorandum on new agency priorities reminds us how easily we may be lured in the wrong direction. His mandate to “increase America’s energy dominance” and “reduce regulatory burdens” comes on the heels of a June 4 Presidential Executive Order that orders federal agencies to set aside environmental impact requirements because of the economic downturn caused by the COVID-19 pandemic. Certainly, the nation must take assertive measures to restore the economy, but a command to exploit complex ecological systems without appropriate environmental reviews, guaranteed by the National Environmental Policy Act (NEPA), abandons the sound principle of “look before you leap.” Further, forcing the Forest Service to meet production targets on a narrow range of resource benefits — those that can be commodified in the marketplace — discounts other critical resource values such as clean water, wildlife habitat and recreation opportunities that are well-recognized as central to Montana’s economic vitality.

Moreover, the Forest Service has learned its best outcomes emerge only after ongoing deliberations among partners and local residents to apply their nuanced knowledge and experience. This process actually happens in Montana via the decades of efforts by the 20-plus voluntary groups known as forest collaboratives that regularly engage with agency staff to improve project design, build understanding, and help get work done. These collaborative groups do not enter their deliberations with presupposed notions of resource exploitation. They want the best for the land.  

(My emphasis.)  I was always skeptical that including those with strictly monetary interests in collaborative efforts comported with this principle.  I assumed that there would have to be collaborative agreement with the desired outcome as step 1.  (This is also where forest plans should make an important contribution by defining the desired condition of the land.)  After Perdue’s announcement, it’s hard to see how any truly collaborative effort today could get past that step.

 

 

Black Hills Timber Growth and Yield Draft General Technical Report- Including Stakeholders/Tribes/Public in Peer Review

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Thanks to the Norbeck Society for posting a link to this recent draft report on the Black Hills as part of the comments on Steve’s post yesterday.

One of the interesting things about this paper is the peer review process- internal, external, and stakeholders and the public- the review period is from 3/15 to 4/15. I think it’s a great idea to have a variety of perspectives. Some of the most rigorous scientific reviews I’ve seen are when people with different opinions, interests, and experiences on the ground review a paper.

A key point from page 4.

These findings are dependent on estimates of standing live volume, tree growth rates, and especially mortality rates disclosed by Forest Inventory and Analysis (FIA) data. Future climate, weather, mountain pine beetle activity, and wildfire are unknown and potential forest dynamics and growth can only be inferred from past conditions.

These are almost the exact words I used in another thread- perhaps these scientists’ inclination is that the future may not be like the past, but it’s the best data we have. Perhaps that’s a disciplinary perspective, or the effect of watching trees grow and views about the future change over the latst 40 years or so. The reason I’m pointing this out is that scientists from different disciplines or inclination might have chosen to try to predict future impacts of insects, fire, climate and so on, and then claimed that those projections/guesses/assumptions were the “best science.” Since this is an important topic to a wide array of stakeholders, in my experience, concerns about the future might be better dealt with through some group scenario discussion/planning exercise.

Public land developers getting financial pushback

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An interesting observation from the Washington Post.  As investors become more enlightened about the financial risks caused by climate change they are starting to hold corporations accountable.  That includes their operations on public lands – and litigation is part of the risk.

A dozen-and-a-half senators wrote letters to 11 of the largest U.S. banks asking them to back down from financing any oil and gas activity in an unspoiled expanse of Arctic wilderness.

“The scale of your banks’ assets individually, let alone together, give you the ability to drive change in protecting the Arctic National Wildlife Refuge and in shifting towards a U.S. financial sector that effectively analyzes and plans for climate risks,” the group of a senators, led by Sen. Martin Heinrich (D-N.M.), told Wells Fargo, Bank of America, Citigroup, Morgan Stanley, JPMorgan Chase and six other banks in a letter sent last Thursday.

Democrats hope these banks follow the lead of one key peer: In December, Goldman Sachs said it is ruling out financing new drilling or oil exploration in the entire Arctic.

The world’s largest asset management firm, BlackRock, said last month it would divest from coal burned in power plants and make climate change a “defining factor” of its investing strategy.

And just last week, a group of investors representing nearly $113 billion in assets under management issued a similar letter to energy, mining and timber companies. Their warning: Don’t invest in certain federally controlled areas once protected but now open to development by the Trump administration.

These areas include not only the oil-rich Arctic refuge but also Alaska’s Tongass National Forest, the largest intact temperate rainforest where the U.S. Forest Service wants to allow new logging, (discussed here) and Minnesota’s Boundary Waters Canoe Area Wilderness (the Twin Metals mine litigation is discussed here), a popular lake-pocked forest near where the administration wants to allow a copper and nickel mining operation.

The institutional investors, which include several religious funds as well as a fund established by the late oil heir David Rockefeller, warned companies that many of the administration’s rollbacks of public land protections are legally precarious, and may be struck down by the courts or the next presidential administration. The letter went out to ExxonMobil, the timber company Weyerhaeuser and 56 other firms, according to Reuters.

“Many of these projects are mired in litigation,” the letter stated, “challenging the legality of any current or future industrial activity initiated in these regions and providing evidence of the risks associated with conducting commercial development on lands that the American public has deemed valuable for protection.”

The institutional investor letter also mentioned other areas, including protected sage grouse habitat (litigation discussed here) and the national monuments that have been reduced in size by the Trump Administration that are also under litigation (discussed here).  Here’s the latest on that.

150,000 acre “project” on the Bitterroot

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Well, not exactly, maybe.  This could be a good example of how to get the public involved early enough in the process for timber harvest decisions that the locations have not been determined yet.  But consider that the decision-maker is the same one who applied “condition-based” NEPA analysis to the Prince of Wales area of the Tongass, which has ended up in court.

Bitterroot National Forest Supervisor Matt Anderson has added a new “pre-pre-scoping” stage to the process, not part of the traditional process in which a set of options is presented to the public for review and analysis.

The new approach is meant to get the public involved prior to coming up with any specific actions being planned for any specific location.

That much I like the sound of.

“There is confusion,” said Anderson. “It’s hard for the public to get involved. We are asking ‘What do you want to see? What’s your vision?’” He said the agency was “starting at the foundational level, not any particular location.” He said it was important to get to those particulars but the way there was to first describe the “desired future condition that we want and then look at the various ways we can achieve it.”

Asked about the fact that the current Forest Plan describes a desired future condition for the Bitterroot Front that involves returning it to primarily a Ponderosa pine habitat with little understory, Anderson said that is in the current plan, but that the plan is about 30 years old. He said a lot has changed in that time on the ground. There have been lots of fires and areas where no fires have occurred, and the fuel load has gotten extremely high. He said current conditions need to be assessed and they were currently compiling all the maps and other information they need to get an accurate picture of what is on the ground today in the project area.

This should raise a concern about how this process relates to forest planning, since forest plans are where decisions about desired conditions are made.  However, old forest plans typically didn’t provide desired conditions that are specific enough for projects, so that step has occurred at the project level.  Under the 2012 planning rule, specific desired conditions are a requirement for forest plans, but the Bitterroot National Forest is not yet revising its plan. Whatever desired conditions they come up with should be intended as part of the forest plan, and the public should be made aware of this.  If the new decision is not consistent with “Ponderosa pine habitat with little understory,” they’ll need an amendment to be consistent with the current plan.  (I’d add that changes in the on-the-ground conditions over the last 30 years shouldn’t necessarily influence the long-term desired condition.)

“The Tongass is so different than the Bitterroot,” said Anderson. “There is not much similarity. I’m not trying to replicate that process here. It was a conditioned-based process up there. It’s like comparing apples to oranges.” In reference to conditioned-based projects, he said, “One difference with this project is that some of that will be pre-decision and some of that will be in implementation. We are trying to shift some of the workload to the implementation stage.”

He said they have a slew of options, from traditional NEPA, to programmatic NEPA to condition-based NEPA “and we are trying to figure it out.”

He insists that the NEPA process will be followed with the same chance for public comment and involvement on every specific project that is proposed in the area.

There’s some ambiguous and possibly inconsistent statements there.  Condition-based NEPA seeks to avoid a NEPA process “on every specific project.”  I could also interpret shifting workload to “pre-decision” and  “the implementation stage” is a way to take things out of the NEPA realm.

And then there’s this:

In response to the notion that the huge project is being driven by timber targets and not health prescriptions, Anderson said that the Regional Office had set some timber targets for different areas of the region, but that those targets were not driving the analysis. “This project has nothing to do with meeting any target,” said Anderson.

This feels a little like “There was no quid pro quo.”  Would timber harvested from this project not count towards the targets?  (I’d like to see  targets for achieving desired conditions.) All in all this project would be worth keeping an eye on.

(By the way, here’s the latest on Prince of Wales.)

Missoula Forest Collaboration Roundtable

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Montana Public Radio collected some interesting perspectives.

What collaboration looks like to what some would consider a “far-right politician:”

“We were thrilled to have the Rocky Mountain Elk Foundation with us today, that is exclusively focused on habitat restoration for elk and sportsmen. We want to continue to have all voices at the table,” Gianforte said…  I think all voices needed to be at the table in these collaboratives, but you have to participate in good faith,” he said. “There have been instances here in Montana where a collaborative worked literally for years to put a project together, and yet people who were at the table still sued. We have to prevent that sort of bad behavior.”

Is it “collaboration” when your participation means you can’t sue over the outcome?

What this idea of collaboration looks like to what some would consider an “extreme environmental group” (Alliance for the Wild Rockies):

“He wants to have all voices that agree with him at the table,” Michael Garrity says.  Garrity says he had no advance notice about Thursday’s roundtable. The Alliance is frequently at odds with — and in court fighting against — timber interests over forest policy.  Garrity said Friday that not only did he not receive an invitation, no one from what he called the environmental community got one either. And without that perspective, he says this week’s roundtable was simply an echo chamber. “It’s not going to be a good dialog unless they invite groups that oppose some logging by the Forest Service.”

My emphasis, especially on the “some,” not all logging.  (The Rocky Mountain Elk Foundation does not oppose logging, though some elk hunters and groups do.)

What collaboration and litigation look like to the Forest Service:

“Different people see it in different ways; including different courts,” (USDA Undersecretary) Hubbard said. “The idea is for us to come together and agree on what kind of treatments make some sense, what satisfies most of the interest out there in one way or another, and then be able to implement that and have the courts support that with some consistent rulings.”

(My emphasis.)  The implication is that courts are just another form of public opinion.  And that it’s ok to exclude some of the interest out there, like “groups that oppose some logging.”  (And my usual gripe – the scope of project collaboration should include not just the “kind of treatments,” but which areas should be treated.)

(And there’s some discussion of categorical exclusions and the Good Neighbor Authority, too.)

Stewardship contracts – a better tool for the job than a roadless rule?

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I wouldn’t have thought that one is a substitute for the other, and maybe this suggests that Utah defined its problem wrong initially.  But they’re happy enough with the way their Shared Stewardship agreement is working that they have put their roadless rule proposal on a back burner.  At least some greens seem happy, too, and least those concerned about roadless areas.  Priority-setting, within the framework of a forest plan, is one thing that I think lends itself to collaboration.

Amid debate about state-specific exemptions to the Roadless Rule, Congress created the capacity to negotiate “stewardship contracts” ranging up to 20 years with states in the 2018 Consolidated Appropriations Act.  It allows the Forest Service to rely on “state’s guidance for designing, implementing, and prioritizing projects geared toward reducing the risks of damaging wildfires and promoting forest health.”

 

Wilderness Society Senior Resource Analyst for National Forest Policy Mike Anderson said conservationists are encouraged by what Shared Stewardship agreements could foster in addressing critical needs.  “Working side-by-side to identify the major risks and implement projects that are actually going to make a difference on the land is something conservationists, I think, can generally can support,” he said. “We think it is good.”

 

(Utah Public Lands Policy Coordinating Office lead counsel) Garfield said under the agreement, projects “can happen, and are occurring, within and without the roadless area, when necessary.”    ‘The existing rule provides a lot of exceptions that the Forest Service can use for forest restoration,” he said. “The Forest Service wasn’t using those” exceptions in many cases.  Garfield said PLPCO will be watching closely over the next four years to see if the Shared Stewardship agreement works out before withdrawing its petition. “I won’t say everything we hoped to accomplish under a state-specific Roadless Rule will be achieved under the Shared Stewardship agreement,” he said, “but a lot of progress is being made.”

(One error in this article – the Idaho and Colorado state roadless rules have been approved.)

Recovery from 250,000 Acre Windstorm on the Chequamegon-Nicolet National Forest and Other Land Ownerships

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Trees sheared off at heights of 10 to 15 feet are a common sight in the Chequamegon-Nicolet National Forest following a severe windstorm July 19 and a smaller storm the next morning. (Photo: Larry Parnass / For the Journal Sentinel)

Larry Parnass wrote this story about a July windstorm in Wisconsin- worth reading in its entirety- also excellent photos. For westerners, it’s interesting that even though they have a healthy forest products industry, they too suffer from needing to remove the kind of woody material for which there is no market, or the prices are so low that removal can’t pay for itself. Too bad they can’t do chip and ship, as we previously discussed for Northern Arizona. Also the need to clear roads and keep people safe from falling trees seems like some of our insect-induced disturbances. We don’t hear much about the forests in the upper Midwest and I, for one, would like to hear more.

Their devastation remains topic No. 1 across Oconto and Langlade counties. As repairs and cleanups continue three months later, officials who manage federal, state and county forests still labor to grasp the extent of damage. The U.S. Forest Service estimates that at least 63,000 acres of the Chequamegon-Nicolet National Forest were affected — a land area larger than the city of Milwaukee.

That impact doesn’t include blowdowns in state and county forests in the area, all of which have sent timber and pulpwood prices tumbling due to oversupply, taxing the ability of forest managers to get salvage wood to market before it spoils.

In early August, the state Department of Natural Resources, using initial field and aerial surveys, pegged the damage at more than 250,000 acres — that’s 390 square miles — including 14,577 acres of state land and 53,647 acres of private land open for public recreation.

Barron and Polk counties in northwest Wisconsin were also badly hit, with spotty storm damage in Wood, Portage and Waupaca counties west of Green Bay.

Richard Lietz, Oconto Falls team leader for the state DNR’s Division of Forestry, has walked battered woodlands with private landowners, offering advice. “It’s a lot to take in. It comes as quite a shock,” he said. “There are hundreds and hundreds of people that are affected.”

John Lampereur, a U.S. Forest Service staff member in the Lakewood/Laona Ranger District, calls the storm a once-in-a-career event. After seeing tangled mounds of jack-strawed trees, some in piles 15-feet deep, Lampereur made a prediction.

“I told my wife. ‘This is going to change everything. We’re going to be working on this for 10 years,’” he said.

Lampereur, the Lakewood district’s expert on forest management, estimates that at least 10,000 acres of forest saw complete blowdown.

“The scale of it is so big that you feel powerless to effect what you consider meaningful change,” he said. “We’re going to do our best. To say that we are going to clean up 50,000 acres, it’s not happening.”

Simply put, there is too much wood for the region’s forest-products industry to handle, even in a state that ranks in the top 10 in this sector.

“We’re only going to be able to absorb so much,” Lampereur said of forest products going onto the market as a result of the storm. “We’re kind of a can-do bunch. It’s hard to swallow your pride and say we’re not going to be able to do it all.”

Tongass transition to young-growth – are we there yet?

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The Tongass National Forest is being managed under a 2016 amendment to its 2008 forest plan that addresses the Forest’s transition away from old-growth timber harvesting.  The amendment accelerated the transition in the plan from 32 years to 16 years, but there has been continuing controversy over how long that process should take.   Here’s the latest in an extended article from E&E News:

A new complication in the debate over the young-growth transition comes from Catherine Mater, a forest products engineer from Oregon who recently completed an inventory of 43 areas within the Tongass under a contract with the Forest Service’s Pacific Northwest Research Station. There’s enough young growth coming online to provide around 55 million board feet of timber annually for decades, she said, or more than double the total timber volume the service reported cut there in fiscal 2018. Mater found 138,760 acres of young growth — between 55 and 80 years old — suitable for harvest. All of it was within 800 feet of Forest Service roads and away from steep slopes and other environmentally sensitive areas.

Of course there’s still pushback from the “timber companies and industry-friendly politicians, who want more thinning and bigger clear cuts.”

What caught my attention though was these comments from the Tongass spokeswoman:

Forest Service managers stand by their estimates that the young-growth transition won’t be complete before 2033, Fenster said. “If, once the analysis is complete, it shows the projections in the forest plan were not valid, then the Forest Service would have to consider alternatives to incorporating new information into the forest plan estimates,” Fenster said.

The projected volume of young growth was a fundamental assumption in the 2016 amendment, so I don’t think the Forest has the option of ignoring how it could affect the decisions it made in the forest plan.

Midwest timber wars revisited

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For the first time in nearly three decades, the Shawnee National Forest in Illinois has proposed a commercial timber harvest of mostly native oaks and hickories. And environmental activists whose high-profile fight against logging in the 1990s led to a 17-year moratorium are once again raising alarms.

Lisa Helmig, acting forest supervisor with the Shawnee National Forest, said the plan is rooted in the best available science about how to maintain the keystone oak ecosystem that is native to the Shawnee foothills.  “The oak ecosystem has been in place here in the central hardwood region for 5,000 years,” she said. But Helmig said the ecosystem is at risk due to a lack of natural or man-made disturbances, such as fire, storms and, yes, even logging. Without these disturbances, non-native, shade-tolerant sugar maple and beech trees sprout up and fill in the forest’s midstory, she said.

The activists have filed an objection, based largely on their past experience with timber harvest on the Forest.

The trees that have grown up to replace the harvested oaks and hickories are mostly 28-year-old stands of “undesirable” beeches and maples.  “When you think about how many oaks were here, it’s heart-wrenching,” Wallace said “Had they not cut the oaks, we’d have oaks here,” Stearns added. In addition to the Farview site, in their letter they write that we also returned to the North End Ecological Restoration project logged in Pope County in the late 1990s. “Little to no oak and hickory have been visibly restored.” They cited other examples, as well.

This is the root of their concern: What the Shawnee National Forest’s leadership claims is happening isn’t.

Asked about their concerns, Helmig said that her “gut reaction” is that the Forest Service likely didn’t follow through with what should be a multiphase treatment. Helmig said she’s confident that the Forest Service is committed to seeing (this) project through… “We have a wonderful silviculturist on staff now,” Helmig said. “He’s been here five years and is absolutely fantastic.”

Hopefully we can assume that there has been a science-based determination that ecological integrity requires regenerating some young oaks and hickories.  But implementation unfortunately still boils down to “trust us,” and “we’re different now.”   (But then the Forest evicted the media from the objection meeting, wrongly according to the Washington Office.)