Landscape Scale

Roundup- Bonnie Op-ed on Roadless; Boren Move?; Wildfire Report Due Next Week and Longer-Term Timber Contracts

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I’ve been working on some climate stuff and will post that later (and also have some energy posts to catch up on), but while I was focused elsewhere several interesting pieces surfaced.

1.Roadless.  I’ve been keeping track of who is holding the “keep but tweak Roadless” position.   Robert Bonnie, whom you might remember as a member of the Biden and Obama Admins at USDA, wrote an op-ed in the New York Times.  Did that bring back the memories.. we had many discussions and differing maps about what was WUI.  Interesting, TWS had its own WUI maps, as I recall, as did other groups including the FS.  Then there’s the “how far, from what size of community, is WUI?” question.  But we didn’t include infrastructure nor watershed protection.

One way to allow forest thinning and prescribed burns to reduce the wildfire threat is to amend the roadless rule. Currently the rule allows new road construction only for forest management activities in cases of “an imminent threat of flood, fire or other catastrophic event that, without intervention, would cause the loss of life or property.” This standard is far too narrow and invites litigation over what qualifies as an imminent threat. The Forest Service is thus often reluctant to propose actions in roadless areas, given the high likelihood of delay and adverse court decisions that waste the agency’s time and resources.

But the Trump administration could update the rule to permit temporary roads in roadless areas that are near neighborhoods along the wildland-urban interface to allow for forest thinning or other ecological restoration.

Could such an exception be abused by timber industry allies in the administration? Not likely, since under current law, forest management projects are subject to public input and are required to be consistent with land management plans that use the best available science.

There’s also a legal precedent. After the rule was issued, governors from Idaho and Colorado initiated their own roadless rules for national forests in their states. Both rules supersede the 2001 rule and allow for limited forest management and road construction to address the threat of catastrophic wildfires in more populated areas while still protecting millions of acres for wildlife, water resources and recreation.

When I oversaw the Forest Service during the Obama administration, we defended the rule established under Jim Risch, Idaho’s Republican governor (and now senator), when it was challenged in court, and worked with John Hickenlooper, Colorado’s Democratic governor (and now senator), to design and defend his state’s rule. Bipartisanship and even consensus are possible on roadless policy.

The Trump administration isn’t much interested in either, but it has chosen to leave the Colorado and Idaho rules alone. Why not simply adopt the same approach in all states?

A bit of history that Robert left out is that the Colorado Rule originated as part of the State Petitions Rule, which was initiated by the Bush Administration.   And for Colorado, the process survived both R and D State and Federal Admins.  I agree that temp roads for WUI thinning is a good thing to work on, but there might also be specific instances of incidental difficulties (dam maintenance for those not in “imminent threat” of collapse; roads for power line maintenance; small boundary adjustments) that might be worth looking at.  Personally, I’d like to see more “adaptive management” occur in regulations and policies.

Note to current employees.  I haven’t mentioned this before, but many of the folks on the Planning Staff who worked on Colorado Roadless were not fans of the project.  In fact, among them it was known as CRAP- the Colorado Roadless Area Project.  I suppose they were not fans of the Bush Admin and didn’t want to engage, or  didn’t see it going anywhere.  So perhaps if you are working on something you consider dumb and pointless, it’s possible that some day in the future someone with D credentials will point to it and say “that was a good thing, we should do more of that.”  Who knows?

I, on the other hand, thought it was fun (I think “as much fun as a person can have legally at work”), especially working with the State, public meetings, advisory committee meetings and so on, regardless of what was ultimately going to happen.  Sometimes it’s hard to think about “it’s the journey, not the destination,” but when I look back it’s the journey I remember, and the destination will always be out of my and possibly your hands.  Whew! That was philosophical.

2. Trump Admin Gives up on Confirming Boren?

An alert TSW reader found this from Interior. It sounds like authority is being redelegated to some individuals.. Michael Boren is among them. A possible switch from Undersecretary at USDA-hood due to difficulties being confirmed? Or two different people with the same name? I’d try to confirm Schultz as Undersec and select a career Chief.. but I don’t know if Schultz would be confirmable either, depending on political topography and horse–trading potential.

3.  Wildfire Consolidation Plan Due Next Week. This is an interesting story from the Daily Montanan.. you don’t see too many stories about “things that haven’t happened yet.” But it’s a nice reminder that the due date is coming up..

The story talks about the group “Partners in Wildfire Prevention” which the story says is:

Partners in Wildfire Prevention, a coalition which includes clean energy interest groups, economic organizations, the Western Fire Chiefs Association and the Theodore Roosevelt Conservation Partnership, said there’s not enough attention on the issue of wildfires at the national level. They view the order as some acknowledgement of that and are hopeful it improves fire response.

I was curious about why clean energy groups specifically would be involved in wildfire, and also about the nature of “economic organizations.”
The coalition is much broader than usual, including traditional groups like RVCC, as well as newcomer Megafire Action, as well as many groups much less traditionally involved with wildfire (e.g. Caregiver Action Network). Here is the list, you need to scroll down. Perhaps we need to make a table of all the coalitions currently involved in wildfire and wildfire resilience so we can keep track.

4. Long-Term Contracts/Projects Update
From the AFRC newsletter.. it would be handy to understand how the contracts and the NEPA interact exactly. There are probably documents out there somewhere but maybe someone can answer these questions in a paragraph.
How do the forest plan, project NEPA and priority setting with FS and partners interact with each large landscape project? When the purchaser completes the NEPA process, who decides what kind of NEPA? EA, EIS for the planning areas with or without condition-based NEPA, CE’s?

The Colville National Forest is preparing its third A-to-Z style contract, which the purchaser completes the NEPA process and oversees implementation. The first two projects, Mill Creek and Chewelah, each treated more than 50,000 acres. The new Powers Lake Area project is expected to be of similar scale, continuing to bolster the Colville timber program, which now sells roughly 130 million board feet annually.
In Montana, the State and the Forest Service recently signed a Shared Stewardship Agreement to formalize a framework for addressing high-risk forests. The 200,000-acre landscape spans portions of the Flathead and Kootenai National Forests. Under this agreement, Montana DNRC will take on implementation of authorized restoration goals with a 20-year mutual commitment to planning and execution using the Good Neighbor Authority.
Meanwhile, the Bitterroot National Forest is pursuing a 10-year Integrated Resource Stewardship Contract for projects within the Bitterroot Front Landscape Planning Area and possibly other areas across the forest. Approximately 13,000 acres are planned for treatment over the next decade, with potential expansion to adjacent areas. Four project areas may be offered at contract award for immediate implementation, with additional areas to be added annually as funding allows. The effort includes at least 90,000 CCF, approximately 45 million board feet, of commercial timber.
On the Nez Perce-Clearwater National Forest, a Request for Information has been issued for the End of the World Planning Area, with objectives focused on reducing insect and disease risk, mitigating wildfire hazards, and improving vegetation and water quality. A long-term 10-year G-to-Z Integrated Resource Stewardship Contract is being considered, covering about 17,000 gross acres, with net treated acres expected to be lower following unit layout. Over the life of the contract, more than 50 million board feet of commercial timber could be offered. A public meeting to discuss the project is scheduled for September 10 in Grangeville, Idaho, followed by a site visit.

Overview of 4FRI Accomplishments

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I saw this earlier this year and hadn’t gotten around to posting, but recent discussions brought up the topic.

Description:
This document was developed by members of the 4FRI Stakeholder Group and provides a to-date overview of 4FRI’s accomplishments for interested parties. It summarizes information from 4FRI stakeholders and the Forest Service including implementation progress and investments. Specifically, treatment accomplishment data reflects total acres treated within 4FRI 2010-2024 and includes both mechanical thinning and beneficial fire acres, which may overlap geographically. Information about investments in 4FRI comes from partner leverage and match information 2022-2024 as contributed by stakeholders, industries, and the Forest Service. This document is not a Forest Service publication. For more information about 4FRI please see 4fri.org.

If you click on each of these, they will be larger.

TSW Exclusive: A Tale of Two SERALs- Making Landscape Scale Resilience Happen With the Stanislaus Forest and YSS

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I am reposting this because I think it’s important and perhaps people missed it because Steve also posted yesterday. The question for readers who are currently working or involved in collaborative groups is “do you think some of these ideas are worth considering in your part of the country?”

 

There are many news stories about projects in litigation, or where there are controversies.   Forest Service folks may remember the management training of “catching people doing something right.”  The SERAL (Social and Ecological Resilience Across the Landscape) efforts are successful at getting large-landscape treatments done. Are there ways that other Forests and communities can learn from these efforts?

This story deserves much greater play in larger media IMHO. I’m thinking a NY Times, WaPo, or NPR-style set of emotion-inducing interviews, drone overflights, and all that.  I’ll be sending this to journalists with that wish.   It would also be an interesting case study for social scientists interested in trust building and collaboration.

From this January

“SONORA, Calif. (January 11, 2024) – In an incredible show of faith and recognition for work already accomplished, the Stanislaus National Forest recently received its annual budget for work on the Stanislaus Wildfire Crisis Strategy Landscape of $57.6 million.

“This funding level is a clear indicator that we are on the right path with our work and should continue at full speed,” said Stanislaus National Forest Supervisor, Jason Kuiken. “Not only is that apparent as people drive up Highway 108 and see with their own eyes the work, but it’s an acknowledgement all the way from Washington, D.C. that this work should continue.”

Part of the Forest Services’ Wildfire Crisis Strategy, the Stanislaus National Forest is currently into year three of a ten-year, 305,000 acres project to reduce fuel loads on the forest through a variety of methods to include mechanical thinning and the application of prescribed fire.”

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First of all, the Forest has an very helpful website on this project,  well worth checking out. It includes a story map that tells the story with photos and videos.

Background:  The first decision is Seral 1.0, which called for work on 55,000 acres; currently the Forest is taking public comment on Seral 2.0, which covers another 100,000 acres. The area is part of the one of the priority landscapes for the Wildfire Crisis Strategy (think $).  The priority landscape itself encompasses more than 300K acres and the non-SERAL parts include Wilderness and other decisions and collaboratives (see map above).

So let’s look at some of the ways that this success became possible.

1. Yosemite Stanislaus Solutions Collaborative Group

In an interview, the first thing that Supervisor Kuiken pointed to was the efforts of a collaborative group called Yosemite Stanislaus Solutions.  You can learn about them here on their website.  It includes everyone from Audubon and the Sierra Club (local chapters) to Sierra Pacific, Dirt Riders, Tribal folks and so on.  You can check the partners out here.

From the YSS webpage:

“After decades of adversarial “wrangling” over forest management policy, 25 local industry, environmental, and recreational groups decided it was time to focus on what we could agree on,” said Mike Albrecht, president, Associated California Loggers.

“When we sat down together, we found out we agreed on a lot, and so Yosemite Stanislaus Solutions (YSS) was born. YSS agreed to salvage logs the Rim Fire, get it reforested, develop a fuel break network to protect our local communities, and restore meadows, streams, and wetlands to better health,” Albrecht said. “This agreement has gotten us national attention and subsequent funding to undertake large “landscape level” forest management projects. This would not have been accomplished without the close 3-way partnership between Tuolumne County, YSS, and the U.S. Forest Service. Kudos to everyone that has worked so hard to make this happen!”

2. The Rim Fire Galvanized the Community

The Rim Fire burned 402 square miles (260K-ish acres) with a “wide range of intensity and impacts.” These photos show that, at least in some areas, much restoration work for watershed, and to restore tree cover will be needed.  The experience of this fire showed the need for work at the landscape scale. It was the third largest wildfire in the State at the time.

“John Buckley, executive director of the Central Sierra Environmental Resource Center in Twain Harte, is also active with Yosemite Stanislaus Solutions. An immediate lesson learned was that doing scattered piecemeal fuel reduction projects, timber sales, mastication of brush, and isolated prescribed burns simply wasn’t going to be enough to prevent more Rim Fire type catastrophes. “That led the YSS forest stakeholder group to come together stronger than ever before to work to get tens of millions of dollars in grants to supplement the work that the Forest Service was already planning to accomplish,” Buckley said.”

3. At First Collaborators Worked Together on Reforestation

Perhaps getting to the “topics with more disagreement” was helped by relationships forged during the work on “topics with agreement.” Also, jointly doing work instead of just talking about how the FS should do it, perhaps caused a greater sympathy for difficulties and trust in Forest Service actions.

4. Getting Work Done Through Partners

Various master agreements, including with the County, enabled finances to be transferred and work to be done without federal hiring or FARs difficulties.  Counties and others can hire locally, so that issues like housing affordability may be less pressing.

5. Consistency of Forest Service Personnel and Alignment

Partners are always asking for this.  While personnel have indeed changed, the commitment to the process has not.  There have been three Forest Supervisors involved during and since the Rim Fire. How did the Forest Service pull this off? Personalities, policy or processes or all of the above?

6. They Were Able to Work Together on Traditionally Tougher Issues.

Example: fire salvage. As TSW readers know, salvage can be controversial, even in the Sierra Nevada.

“Because all the YSS stakeholder interests supported the compromise salvage logging plan, it managed to gain Forest Service approval and got implemented without any legal delays that would have meant a lot of the wood could have rotted,” Buckley said. “By working for consensus middle ground on the issue of salvage logging and then the following debate over how to do national forest reforestation, YSS set a national example — showing the benefits of diverse stakeholders working together in a spirit of compromise and cooperation.”

7. Role of Models and Scientists

Because this work was at the landscape scale, it required thinking beyond the stand level, including the development of PODs. This includes practitioner knowledge, and newer technologies (e.g., Lidar) and models were used; including workshops for the collaborative group with scientists.   Supervisor Kuiken would advise anyone “these new technologies and models can be very helpful and save a great deal of time.”

Probably a heavy direct involvement by scientists also helps collaborators learn together and operate from the same knowledge base.

8. NEPA Opportunities and Choices.

They did an EIS for Seral 1 and will do one for Seral 2. You can read the notice of intent on the Federal Register here.  I get the feeling that the way that the decisions are structured such that analyzed activities may occur over time with no new decisions required.  So big EIS, but considers many kinds of treatments over a large area over a long time period. For example, ongoing maintenance of fuelbreaks is included in the decision. If stands die due to bark beetle, that is also incorporated.

They are using some emergency authorities, specifically “only the proposed action and a no-action alternative” and “no pre-decisional administrative review process.” In the case of Seral 2.0, potentially more controversial decisions will be covered in separate RODs based off the EIS.

They have used new technologies, like Lidar, to help with the analysis.

Inquiring NEPA minds might want to know  “does this decision incorporate “condition-based management””?

Katie Wilkinson, the Forest Environmental Coordinator, addressed this in an email.

“The SERAL projects only have aspects of condition-based management – salvage, rapid response to newly discovered non-native weed infestations, hazard tree mitigation (only in SERAL 1.0).

The large majority of the SERAL projects proposed or authorized actions however, would not be considered condition-based management.  The SERAL decisions authorized site-specific vegetation management actions (other than those listed above) and the SERAL 2.0 decision will do the same. Modifications do occur from planned units to implementation units, regularly, based on a variety of factors or updated survey information considered and obtained internally.

None of the SERAL implementation will go through additional public review or comment periods.  The SERAL analysis document includes the site-specificity necessary to provide meaningful feedback and public comments and for the decision maker to make an informed decision.  That doesn’t diminish the amount of work left for the implementation team to complete after the decision and prior to implementation. “

9. Lack of Litigation. We’ve all seen collaborative groups work together well, with the decision then followed by litigation. This was not the case for Seral 1.0. We can’t FOIA internal documents of potential litigants to understand why they did not file.  Certainly litigation does occur with similar kinds of projects in the Sierra Nevada.   When asked why  Supervisor Kuiken replied in an email: collaboration on developing the proposed action (and associated response to the public concerns) and second that the IDT made a DEIS/FEIS that was both thorough and readable/understandable.

I’m thinking that it may also have something to do with the choices made by potential litigators, and the political horsepower behind the project.  Certainly a previous effort (salvage) was litigated, as we covered earlier on TSW.  I’ll try to find out more about this.

Summary

The SERAL efforts have been successful.Let’s look more deeply and share this information.

TSW readers: what aspects of this effort do you think are replicable where you work? Why or why not? Ideas for reporters to send this to.. either in comments or contact me directly.

Reporters: What might be interesting angles..

*What makes people who usually disagree come together? Interview various members of YSS.  Link to election year and reducing polarization? Something like this NY Times story about Blue Mountain Forest Partners.

*When Litigants Stay Home and Why: Interview folks who litigated on the Rim Fire and not on SERAL 1.0, and ask them about their rationale.

*Climate change and carbon:given the many op-eds that simply claim “leaving mature and old growth trees alone is best for carbon” how does the Forest and YSS think about carbon. Interview some scientists involved (and those who disagree).

*Old -growth.. how will old growth be delineated and protected in Seral 2.0?

*Digging into how they used new technologies in their work, and new ideas like PODs.

 

Forest Service staffing now a bottleneck for forest thinning: Report from 4FRI Country

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Logging small trees is just one part of forest restoration.
File photo by Peter Aleshire

Thanks to Jon for finding this story from the Payson Roundup by Peter Aleshire about difficulties in Forest Service hiring.  It’s also interesting to compare with the BLM as they state they are 40% down in some places.  The BLM and FS have different hiring centers.. it would be interesting to compare how they are doing and whether they suffer from the same roadblocks and problems. Anyway, here’s the story.

No one to mark the trees.

Fill out the paperwork.

Or count the owls.

So it’s going to be tough to stay on schedule when it comes to thinning the forest – and protecting communities like Payson, Show Low and Pinetop from the next megafire.

The Forest Service briefed the Natural Resources Working Group April 18 on the complicated effort to revive the timber industry in Northern Arizona for the critical task of thinning overgrown forests.

It wasn’t pretty.

But it’s still progress.

Turns out, the Apache Sitgreaves Forest has only about a third of its authorized staff – which means it’s scrambling to prepare timber sales.

Partly because a national labor shortage has made it hard to find people to do the job – especially in remote, forested areas.

But also because it takes the federal human resources department 12 to 18 months to actually approve a request to hire someone.

That has delayed preparation of timber sales across northern Arizona, although study after study has concluded that forested communities in places like Gila, Apache and Navajo counties remain among the most fire-threatened in the country.

It also explains why places like the Payson Ranger District headquarters are essentially closed to the public.

“We have a total of 183 non-fire positions. We’re missing 66 as of today,” said Acting Apache-Sitgreaves Forest Supervisor Rob Lever. “Times are tough, but I actually think we’re being a little bit more innovative. I feel like the clarity of what we’re supposed to be doing allows us to be a little more creative.”

The 4-Forests Restoration Project has been designated one of the top priorities for logging and forest restoration in the country. The assorted infrastructure bills and an overhaul of the Forest Service budgeting system for restoration has provided a lot of new money.

But the staffing shortage has made it all but impossible to quickly complete required environmental assessments and prepare the timber sales. The bottleneck may limit how much thinning gets done.

“So you’re running with 36% of your staff being essentially out?” asked Pasal Berlioux, executive director of the Eastern Arizona Counties Organization. The group hosts monthly meetings for representatives of the logging industry, the Forest Service and local officials to try to keep the forest restoration efforts on track.

“You said 12 to 18 months? So if I apply – you don’t see my application for that long?”

“We prioritize which positions they deal with for us,” said Lever. “We can submit five positions at once. I think we need more candidates. And we need to make our operation more efficient – maybe we don’t need some of those positions.”

New CEQ Guidance on Habitat Connectivity

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Cascade Forest Conservancy

On March 21, the Council on Environmental Quality provided “Guidance for Federal Departments and Agencies on Ecological Connectivity and Wildlife Corridors” to federal agencies.  The Forest Service was a member of the working group that developed this guidance.

“Connectivity is the degree to which landscapes, waterscapes, and seascapes allow species to move freely and ecological processes to function unimpeded. Corridors are distinct components of a landscape, waterscape, or seascape that provide connectivity. Corridors have policy relevance because they facilitate movement of species between blocks of intact habitat, notably during seasonal migrations or in response to changing conditions… Increasing connectivity is one of the most frequently recommended climate adaptation strategies for biodiversity management.”

“To the maximum extent practicable, Federal agencies are expected to advance the objectives of this guidance by developing policies, through regulations, guidance, or other means, to consider how to conserve, enhance, protect, and restore corridors and connectivity during planning and decision-making, and to encourage collaborative processes across management and ownership boundaries. Any existing corridor and connectivity policies or related policies should be updated as needed to align with the objectives in this guidance. Federal agencies should have new or updated policies ready to implement by the first quarter of 2024 and make their policies publicly available. Federal agencies should also actively identify and prioritize actions that advance the objectives set forth in this guidance.”

“Federal agencies should not limit engagement in restoration activities only to circumstances when restoration serves as a mitigation strategy to compensate for adverse impacts from projects or actions. Instead, Federal agencies should consider where there are opportunities in their programs and policies to carry out restoration with the objective of promoting greater connectivity.”

One of the specific “focal areas” listed in the memo is “forest and rangeland planning and management.”  “Connectivity and corridors should factor into high-level planning and decision-making at Federal agencies as well as into individual decisions that lead to well-sited and planned projects.”  “In carrying out large-scale planning required by statutory mandates (citing NFMA and FLPMA) Federal agencies should consider updating inventories of Federal resources under their associated management plans to assess connectivity and corridors.”

The Forest Service 2012 Planning Rule already includes language requiring that forest plans address connectivity as part of its wildlife viability considerations.  I had something to do with that, but I was regularly disappointed in the agency’s unwillingness to “think outside the green lines” about how species occurring on a national forest depend on connectivity across other land ownerships, so I’m always happy to see someone try to make them do that:

“Ecological processes and wildlife movement are not limited by jurisdictional boundaries. Therefore, Federal agencies should seek active collaboration and coordination with other Federal agencies, Tribes, States, territorial, and local governments, as well as stakeholders to facilitate landscape, waterscape, and seascape-scale connectivity planning and management, and consider appropriate collaboration with other nations. Prioritization and strategic alignment of connectivity efforts across partners improves the effectiveness of each entity’s activities and enables larger-scale conservation, enhancement, protection, or restoration to occur.”

“Federal agencies with investments on Federal lands or in Federal waters adjacent to designated areas that may have conservation outcomes (e.g., National Park System units, national monuments, national forests and grasslands, national marine sanctuaries, national estuarine research reserves, wilderness areas, national wildlife refuges, etc.) should explore collaborative opportunities to enhance connectivity across jurisdictional boundaries.”

These kinds of initiatives seem to come and go, but we should at least expect to see the land management agencies tell us what they think under this administration by next year.  If anyone happens to notice, let us know!

Double Landscape Trouble : Injunction of Two Landscape Level Projects on the Nez-Perce/Clearwater

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While Jon is our litigation expert, a TSW reader submitted the below litigation post. This case reminds me of the old strategizing we did about packaging decisions in a Queen Mary of analysis versus a flotilla of small decisional boats. If we accept that there are people who don’t want projects and use litigation to stop them,  the Queen Marys will become larger targets, whereas some in the flotilla of small boats might successfully evade fire.

In this case, two landscape level projects were enjoined at the same time. Another point of interest is that the Court held the Forest to using definitions in the Forest Plan rather than perhaps more current definitions.  Which suggests perhaps that the old growth EO new definitions might take a national amendment of all forest plans?

Still, this was useful in the sense that if the Forest fixes these things as the judge requires, then they both should be good to go.  Or the additional work will open up more opportunities for litigation. Or using the latest science, or not, if it conflicts with the Forest Plan. And so it goes.

Other thoughts? Here’s the post.

..the court decided to remand (send back) both projects to the Forest and enjoined until their identified errors are fixed……………………..the court decided that EOTW needs to be an EIS rather than an EA to address old growth.

The 3 identified issues:

  • NIOG (Green et al. definitions) cannot be counted towards Old Growth to meet Nez Perce Forest Plan Appendix N. They must use the Appendix N definition.
  • MA20 needs to be verified as to which stands are Forest Plan Old Growth and which meet Replacement. We can’t assume all MA20 is Forest Plan OG
  • Cumulative effects of old growth between the EOTW and Hungry Ridge projects were not discussed.

Here are the main points….

“While the Forest Service may have developed regional definitions of old growth depending upon forest type, the Forest Plan cannot reasonably be read to include NIOG as meeting the criteria for an old growth stand. The purpose of the Forest Plan was to establish a floor of old growth forest wide, and in each OGAA. Logging predominantly favored large sized trees such as Douglas and Grand Fir. When these factors are considered together, the Court finds the Forest Service’s interpretation that NIOG meets the criteria used to identify old growth in Appendix N is clearly erroneous.” Pg. 18

“Here, while the Forest Service’s NEPA documents indicate it used aerial photos, stand exam information, previous land uses, and personal knowledge to verify stand conditions in MA20, the Court cannot find any evidence in the record demonstrating that it did so other than its bare assurances. The Forest Service did not direct the Court to any documentation in the record of its activities verifying the makeup of MA20 stands. Further, Appendix N requires actual verification of individual stand conditions by specific methods – aerial photos and field reconnaissance. This was apparently done prior to adoption of the Forest Plan to verify the amount of sawtimber throughout the forest. Utilization of “previous land uses and personal knowledge” do not appear on the list of approved verification methods. “ “The Court therefore finds the Forest Service acted arbitrarily and capriciously when it took liberties outside of a reasonable interpretation of the Forest Plan to meet the minimum old growth requirements, and it failed to accurately identify the composition of areas of MA20. ” Pg. 20, 21

“But the Court was unable to locate any discussion or analyses of the cumulative and synergistic impact of the two projects on old growth. This is problematic because the Forest Plan requires the Forest Service to maintain a minimum of 10% of the total forested acres as old growth. It is difficult to reconcile the Forest Service’s justification that old growth need only be looked at in the context of each project’s boundaries when the Forest Plan requires the Forest Service to view the forest as a whole. In this respect, the Court finds the Forest Service’s analyses of cumulative effects to old growth failed to consider an important aspect of the problem, and is therefore arbitrary and capricious.” Pg. 53

The resulting order….

5) The Decision Notice and Finding of No Significant Impact for End of the World are hereby reversed and remanded to the United States Forest Service for preparation of an environmental impact statement under NEPA consistent with this decision.

6) The Record of Decision and the Final Environmental Impact Statement for Hungry Ridge are hereby remanded to the United States Forest Service for further evaluation under the NFMA and NEPA consistent with this decision.

7) The End of the World Project and the Hungry Ridge Project are hereby enjoined.

Here is the text of the decision.

4FRI By The Numbers- January 2022 Accomplishment Report

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Why it 4FRI important?  At our Region 2 Wildfire Strategy Roundtable, I heard “entrepreneurs need some guarantees for supply.” Which makes sense. But as we have seen, that and “having NEPA done” hasn’t necessarily worked out as well as expected for a variety of reasons that are important to understand.  Since they are the main pioneers in the efforts to do fuel treatments at scale in places without existing infrastructure sufficient to process the material (a common problem across the west), I think it’s worth understanding their context to help understand how replicable it is in other places.

Here’s a handy chart of what they accomplished by year.

 

Here’s the January accomplishment report. It includes a list of NEPA projects and NEPA status.

Large landscape connectivity – could the Forest Service be a leader?

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I watched a webinar provided by the Center for Large Landscape Conservation titled “Legal Protections for Large Landscape Conservation,” part of which focused on “Habitat Connectivity and the U. S. Forest Service.”  That segment can be seen here from 4:15 to 19:05.  The presentation goes over the elements of Forest Service planning that could be useful for habitat connectivity.  It includes a couple of examples of “innovations” from the Flathead and Carson/Santa Fe forest plan revisions, but concludes that few plan components that address connectivity are likely to be very effective.  It cites a familiar refrain that the agency is “unwilling to commit to specific direction,” and “lack of commitment and interest from line officers.”  However, the presenter observed that the movement of the Forest Service toward more centralized planning organizations might provide an opportunity to look at connectivity as a broader regional issue, and to develop regionally consistent approaches to planning for connectivity.

What if the Forest Service was actually interested in conserving the species that use its lands but require connectivity across other jurisdictions and ownerships (as it is required to do, “in the context of the broader landscape,” a phrase used seven times in the 2012 Planning Rule ), and what if the Forest Service played a leadership role in facilitating such cross-boundary connectivity by promoting large-landscape conservation strategies?

Maybe it would look something like what the Yellowstone to Yukon Initiative has accomplished since it began promoting large-scale landscape conservation in 1993.  As Rob Chaney reports in the Missoulian, they have recently evaluated the effectiveness of their program in “Can a large-landscape conservation vision contribute to achieving biodiversity targets?”  They found that in the Y2Y region where landscape connectivity was actively promoted, more public lands were dedicated to protection, more private lands were protected, wildlife highway crossing structures proliferated, and occupied grizzly bear habitat (as a proxy for actual benefits to wildlife) expanded.

Come to think of it, wouldn’t that be a great assignment for the Biden Administration to give the Forest Service (both the National Forest System and State and Private Forestry divisions) to promote its 30 X 30 conservation agenda?

 

 

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.

Chief Moore Announces New Funding and 4FRI Strategy

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Here’s a link to the press release:

USDA Forest Service Chief Randy Moore today announced new funding and a redesigned strategy for the Four Forest Restoration Initiative (4FRI) during a visit with elected officials in Arizona.

The agency will be committing $54 million dollars in fiscal year 2022 to accelerate the needs for implementing high-priority projects on 135,000 acres over the next 10 years. The funding will also address annual road and bridge maintenance.

“The Forest Service is increasing the scale of our investments into the 4FRI project, and we’re getting started sooner than previously planned,” said Chief Moore. “This strategy will focus our forest maintenance work to reduce wildfire danger in the 4FRI project area where wildfire is most likely to place homes, communities and infrastructure at risk. By placing our treatments in the right places and at the right scale, we will reduce wildfire risk, protect communities, and restore forests.”

The announcement today represents an important step toward the agency’s broader, national strategy to treat landscapes, protect communities and watersheds, and create fire resilient forests at the scale needed to address the nation’s growing wildfire crisis.

“We are committed to reducing the risk of destructive wildfire and protecting communities, and recognize the scale of the need for restoration,” added Chief Moore.  “Industry is vital to our success in this commitment, and we are fully committed to working with partners to achieve our restoration needs at scale.”

 

The key decisions from the 4FRI Restoration Strategy are:

  • Immediately prioritize and expand the highest-priority, partnership projects to significantly reduce the risk of catastrophic wildfire to communities on approximately 135,000 acres (i.e. Bill Williams Mountain, Flagstaff Watershed Protection Project, CC Cragin, Sierra/Anchas).

  • Immediately implement current plans which provide approximately 300,000 acres over 20 years to maintain existing industry.

  • Treat 86,000 acres using prescribed fire and non-commercial thinning (over 20 years) on the Tonto and Kaibab National Forests.

  • Conduct a rapid assessment and optimization effort using the best available science to assess approximately 300,000-350,000 acres (over 20 years) on the Coconino and Kaibab National Forests, with treatments assessed to prioritize which acres to treat to reduce the risk of wildfire the quickest beginning in FY2023.

  • Focus on resolving and improving conditions for industry success by addressing factors like cost and risk reduction, incentives, market conditions, availability of raw material, transportation plans, and fire liability risks.

There is also a paper that has more detail.

Accomplishments and Expected Outcomes
The restoration strategy is quicker and more diverse with opportunities for existing and new industry. It uses a variety of scales, different contracts and agreements, over multiple time frames (5,10, 20 years) to expand industry and jobs (1,400 jobs and $56.6M income in FY2021).
Based on pending and completed National Environmental Policy Act (NEPA), there is a need to treat approximately 700,000 to 880,000 acres over the next 20 years to meet desired conditions and reduce wildfire risk using a variety to approaches include mechanical thinning and prescribed burning. These acres include the high priority partner projects, providing acres to maintain existing industry and both product and non-product removal areas with implementation tools to be determined. This is in addition to 258,000 acres already completed under 4FRI over the past 10 years.
Considering the total acres treated and planned under this strategy (up to 1.2 million acres) across the 2.4 million acres landscape, the outcome is approximately treating 47% of the 2.4 million acres.
Based on new information for restoring fire-adapted ecosystems in 4FRI for fire resiliency (RMRS GTR 424), blending financial and resiliency objectives are critical to defining the overall outcomes for success. On average only 40% to 50% of a planning area’s acres need to be strategically treated to reduce 80% of the exposure from wildfire. This collaborative effort will help to further understand and define tradeoffs between financial and fire resiliency objectives, while we continue to implement this 4FRI Restoration Strategy

It sounds as if they are breaking the work down into smaller contracts to give opportunities to a variety of industry, and focusing on prioritizing reducing wildfire exposure to communities of all the possible acres that could be treated. The latter seems like a general movement within the FS and part of the national 10 year plan.