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

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

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

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

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?

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

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?

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

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.)

The effects (NEPA) of bake-sale (timber-sale) funding of restoration

I  said here: “NEPA documents have started saying that cutting down trees is beneficial for the environment because it produces funding to replace culverts and the like. That may not be a defensible effects analysis.”

Sharon asked: “I don’t see why people need to say that at all in NEPA docs. Do you have examples?”

I do.  I’ll provide two here that I have encountered with forest plan revisions.

The Flathead revision FEIS provided very little useful information about aquatic effects, but it revealed this as part of their logic (p. 131, but their point seems to be that it doesn’t matter):

Although alternative D proposes more timber harvest and the potential to generate more Knutsen-Vandenberg revenue for restoration actions such as best management practices, road decommissioning, and culvert replacements that would benefit aquatics, it is anticipated that money would still be available from partnerships and appropriated watershed dollars to implement restoration projects regardless of how much money is generated from timber sales.

The Helena-Lewis and Clark was more to the point that it DOES matter in their revision DEIS (p. 71):

Alternative E would result in the highest volume of timber production and therefore have the potential to generate more money from timber receipts for restoration projects for watershed and fisheries. If more money is available from alternative E then there would be more short-term impacts from restoration projects but there would be more long-term gains

I think I have seen other better examples for projects that have stated that the proposed action is better for the environment than no action because the timber sale revenues will be used for restoration activities.  Maybe I’ll run across more examples, but I wanted to post this now so that others could contribute examples they are aware of.

So no, I don’t think they should include this in NEPA documents.  The problem is that effects disclosed in an EIS must be reasonably foreseeable.  If the funding process works in a way that makes money available but does not commit it to a specific use, then any effects are not reasonably foreseeable.  This is more obvious in the forest planning context because restoration is only a “potential” (to quote both examples above).  The result of including this kind of poorly substantiated assumption in an effects analysis is to distort the comparison of alternatives and to provide less meaningful information for the decision-maker and the public.  This tends to subvert the core purpose of NEPA.

Forest Management: “For a Warming World, A New Strategy for Protecting Watersheds”

This article was prepared by Yale Environment 360. Although its focus is primarily on protecting watersheds, most of the well validated scientific principles that Sound Forest Management is based on are clearly demonstrated in a way that easily shows the value of human intervention in our federal forests for other site/situational specific prescribed purposes as well. Here are some highlights which have been the subject of many previous posts on this site.

  1. water managers are learning that careful management and restoration of watershed ecosystems, including thinning trees and conducting prescribed burns, are important tools in coping with a hotter, drier climate.
  2. New Mexico’s forests … areas that supported 40 trees per acre in the pre-European era now were blanketed with up to a hundred times as many. This profusion of trees — as many as one per square yard — weakened all of them, and rendered them defenseless against megafires.
  3. the Las Conchas Fire … consumed nearly an acre of forest per second … and left behind nearly 100 square miles so severely burned that even seeds to regenerate the forest were destroyed …
    two months later, when a thunderstorm in the Jemez Mountains washed tons of ash and debris into the Rio Grande River, the water source for half of New Mexico’s population and for a major agricultural area. Only an inch of rain fell, but the debris flows the storm generated turned the river black and dumped ash, sediment, and tree and shrub remnants into a major reservoir⁠, requiring a costly cleanup … a heavy rainstorm two years later generated enough sediment to entirely plug the Rio Grande
  4. In the last two decades, megafires in similarly dry and overgrown watersheds have ended up contaminating downstream water supplies in numerous areas throughout the western United States, including Phoenix; Denver; Flagstaff, Arizona; and Fort Collins, Colorado. Downstream water managers serving millions of urban residents have learned that the security of their water supplies is tied to the health of upland watersheds that may be hundreds of miles away.
  5. In the Western U.S., watershed restoration chiefly consists of two steps: thinning of trees and shrubs, and prescribed burns. In the Eastern U.S., it involves a bigger set of tools, including planting native trees, reducing the area of impervious surfaces, and slowing the speed of stormwater so that more water percolates into soil and aquifers. All these measures are designed to improve water quality.
  6. numerous pilot projects have shown the efficacy of restoration, agencies rarely have enough money to treat entire watersheds
  7. after the Las Conchas fire, residents in the Rio Grande watershed … in 2014 they launched a public-private partnership, the Rio Grande Water Fund, whose 73 contributing members⁠ include government agencies at all levels, foundations and other NGOs, local water utilities, and local businesses and residents. Together they raised enough money for a 20-year program to restore 600,000 forest acres — enough to support the resilience of the entire central and northern New Mexico portion of the Rio Grande watershed. They have already restored 108,000 acres, and are racing to complete the job before another megafire occurs.
  8. The Rio Grande Water Fund’s public-private partnership model has become official federal policy. Last August, the U.S. Forest Service published a landmark report called “Toward Shared Stewardship Across Landscapes” that outlined the agency’s intention to convene watershed stakeholders of all kinds to plan and fund watershed restoration. “Because fire crosses back and forth across land ownership boundaries, the risk is shared,” the report said. “Accordingly, land managers cannot achieve the fire-related outcomes people want… without shared stewardship of the wildland fire environment.”
  • The benefits of watershed restoration extend far beyond water security. Most obviously, healthy forests deter megafires. Laura McCarthy, the Rio Grande Water Fund’s executive director, says that in three instances since restoration work began in New Mexico, wildfires that ran up against restored zones immediately died down. Healthy forests can tolerate low-intensity fires: they possess diverse understories of grasses, sedges, and forbs and rich, microbe-laden soil, all of which supports wildlife, from insects to mammals. Watershed restoration can double the amount of carbon stored in the soil, which means that it’s a vital tool in fighting climate change. And watershed restoration creates jobs: In the case of the Rio Grande Water Fund, many of those jobs go to youths in traditional Hispanic and Native American communities where unemployment rates are 30 percent or higher.
  • In some regions, forest restoration even increases water supplies. Roger Bales, a hydrologist at the University of California, Merced, has shown that because watershed restoration requires the removal of vast numbers of young trees, loss of water into the atmosphere through evapotranspiration in those trees is eliminated. The water instead flows downward, into the soil, often on its way to the watershed’s rivers and reservoirs. Bales’ experiments in California’s Sierra Nevada show that restoration can increase water supplies in downstream reservoirs by 9 to 16 percent. That makes restoration a more cost effective (and vastly less destructive) water supply method in California than building dams. Restoration is also cheaper than fighting the megafires that are otherwise inevitable in the overgrown forests: last year’s Camp Fire in northern California alone caused $11 billion to $13 billion in damage.
  • unless it is followed by prescribed burns, undesirable trees and shrubs grow back. In that case, said Don Falk, a leading fire researcher at the University of Arizona, “You’re either committed to a perpetual Sisyphean cycle of thinning” every 10 or 15 years “or you’ve got to let fire back into the system.” Fire is an integral part of the functioning of many ecosystems: Blazes of less-than-megafire scale germinate seeds, keep native species in balance while warding off invasive species, and stimulate microbial activity that produces soil nutrients.