Judge Agrees With Forest Service On Thinning On North Kaibab

blackjack7

blackjack3

The above are photos of 1) what the stand is desired to look like, and 2) what stands look like when not enough 16 inchers have been removed. At least that is my interpretation of the photos in the EA here. If I misinterpreted, please feel free to point it out.

Here is the link and below is an excerpt:

The area in question is about 39 square miles located near Jacob Lake, or north of the 40,000 acres accidentally burned in 2006’s prescribed-burn-turned-wildfire on the North Kaibab Ranger District, called the Warm fire.

It’s a defeat for the Sierra Club and Center for Biological Diversity, which have raised objections over the age and size of trees to be thinned since 1998.

Those groups asserted that the scale of thinning the Forest Service had proposed on the Kaibab Plateau is not beneficial to the northern goshawk, a bird the forest service considers a “sensitive” species (not federally listed as threatened or endangered), and submitted data to support that view.

The Forest Service weighed that data, then set it aside in favor of what its own expert had said about how dense or sparse the forest could be in areas where the goshawk live.

The plans allow for logging of ponderosa pines 16 inches and larger in diameter (with no upper size limits), though the Forest Service says it will only account for fewer than 2 percent of the trees to be cut.

The matter is potentially significant because the conservation groups have raised objections to similar plans for a handful of other thinning projects on national forests elsewhere in northern Arizona, including closer to Flagstaff.

“It makes no sense for the Forest Service to continue to push to log these old growth and large trees, when we have so little remaining. This is not a restoration project. It is a squandering of these biologically significant large trees — critical and missing components in many of our forests,” stated Sandy Bahr, of the Sierra Club.

The district forester lauded the decision.

“Thanks to the hard work and perseverance of our employees, and support from our local communities, we can move forward to help protect the habitat and the forest from high intensity wildfire,” stated North Kaibab District Ranger Randall Walker.

Note from Sharon:
1) I am curious whether this is the same project as in this story here” Group Sues to Stop Thinning Project near the Grand Canyon.”

And only a small percentage of the forest’s old-growth trees will be removed, he added.
I anticipate that some critics of my decision may mischaracterize this project with claims that it will significantly reduce old growth habitat,” Short wrote in the assessment. “Alternative 1 would reduce old growth by up to 105 acres within the 26,916 acre Jacob-Ryan project area. This equates to approximately 0.4 percent change in old growth allocation.”

Loggers would cull old-growth trees only where it would be necessary to promote restoration goals, according to the agency.

However the same story also says…

Under the proposal, about 700 acres of mature and old-growth ponderosa pines would be harvested.

39 square miles? 700 acres? 105 acres? This seems very confusing.

I sure think it would be interesting if, for each project that goes to litigation, the unit would develop a standard video package that shows 1) what the area currently looks like, 2) explains why they are doing what they are doing, 3) show how they would do the marking, and then 4) show what nearby areas look like after that treatment. There was some of that done in this EA, but I think a video showing what trees would be removed and why would be clearer. It would be helpful for folks on this blog, and other members of the public and the media to understand and compare. It would also be interesting to know how much the FS, OGC and DOJ spent defending this one (39 square miles, or 150 or 700 acres, whatever..) compared to the 150 acre and 600 acre projects we’ve talked about on this blog before. We could even then generate a litigation cost per acre..

Here’s a letter to the editor by the ranger describing the project and the FS side..Good work by the FS, OGC and DOJ on the case, and the District for the EA and getting the word out.

Flexible NEPA in the Black Hills

Hand of Bobzien

Here’s a story from the Rapid City Journal on attempts (with CEQ) to design NEPA documents and decisions in a more flexible way.

Here’s an AP story as well, not so clear about the NEPA, more about the funding.

Black Hills National Forest officials will rely on streamlined regulations and extensive commercial tree thinning in a new attack plan against the mountain pine beetle aimed at protecting vulnerable areas before the bugs hit.

Forest Supervisor Craig Bobzien said Monday in releasing details of the Mountain Pine Beetle Response Project, which was developed over more than a year and included public comments and environmental review, that it would target 248,000 acres of highly vulnerable woodlands within the 1.2-million-acre forest for treatment in advance of beetle.

Commercial thinning would be used on almost half of those acres — 122,000 — over five to seven years to make them more resistant to the destructive bugs and less likely to erupt in wild fires, he said.

“It’s hard work and in many cases it’s expensive work,” Bobzien said. “But it’s worth the effort.”

Bobzien said the response project includes a variety of treatment options and costs about $70 million over the five to seven years. On an annual basis, that is slightly more than current forest management costs weighted heavily toward pine-beetle control work and fuels reduction to reduce the chances of wild fires.

Bobzien said the forest could put additional money to good use through the response project. But its effectiveness is about more than just money, he said.

“We’ll be able to respond much faster and adapt to what’s going on out there in nature. We’ll be able to move at a much-faster pace,” Bobzien said. “This allows us to be out in front of the beetle, which is where we’re most effective.”

The project was authorized by the Healthy Forests Restoration Act of 2003, aimed at a better response to the buildup of hazardous fuels in thick forests and including work against insects and disease. Additional pressure in recent years for streamlined regulations came from private citizens, state and local officials, and the timber industry, as well members of the state’s congressional delegation.

With support from the delegation, the Forest Service worked with the U.S. Environmental Protection Agency and the White House Council on Environmental Quality to find acceptable ways to streamline regulations, Bobzien said.

Rep. Kristi Noem and Sen. John Thune, both Republicans, celebrated Bobzien’s announcement Monday.

This is one of the current efforts at helping the Forest Service use NEPA in ways that facilitate dealing with 21st Century problems. 4FRI is another example, and there are others. Observers will note that the impetus to do this is still there, even though it’s not an R administration.

4FRI Update:Controversial Forest Restoration Contractor Draws Vote Of Support

Helicopter on Wallow Fire
Here’s an article in the Payson Roundup from Saturday. Below is an excerpt.

Gila County Supervisor Tommie Martin — one of the driving forces in the 4FRI movement — was among those openly questioning whether Pioneer had the financing or expertise to undertake the massive thinning project, which depend on the contractor building bio-fuel plants and mills that could turn a profit on millions of saplings and small trees.
#Locked in a campaign for re-election now, she says her doubts about Pioneer’s financing remain — but the effort now relies on Pioneer’s success. Martin has played a leadership role in the effort to convince the U.S. Forest Service to thin fire-prone thickets on the outskirts of Rim Country communities. She has also spearheaded the effort to post water-filled bladders strategically throughout the region to enable fire trucks and firefighting helicopters to quickly fill up storage tanks to contain brush fires.
#Meanwhile, other recent developments have advanced the effort to use a revitalized timber industry to thin millions of acres in Northern Arizona where a century of grazing and fire suppression have created an overgrown, tree-choked forest.
#Tree densities across most of the ponderosa pine forests of Northern Arizona have increased from perhaps 30 per acre to closer to 800 per acre in the past century, according to researchers from Northern Arizona University. A once-open, fire-adapted forest now generates an increasing number of massive crown fires, which threaten to incinerate forested communities.
#It costs up to $1,000 per acre to thin and burn off the slash piles, which means it would cost taxpayers about $6 billion annually to thin those forests by hand. The 4FRI approach would give private contractors a guaranteed 10- or 20-year supply of mostly small-diameter trees as an inducement to invest millions in building mills and power plants that could turn a profit on the vast oversupply of small trees.
#The 4FRI approach could get a boost in November if Flagstaff voters approve a $10 million bond issue to raise money to support forest-thinning projects in the Lake Mary watershed. Backers say that a crown fire that killed all the trees and scorched the soil would result in a dramatic increase in silt building up in Lake Mary, endangering Flagstaff’s already precarious water supply.
#The Schultz Fire two years ago demonstrated the risk to the city. The fire roared through an area that had been earmarked for a 4FRI project. The monsoon rains that followed caused mudslides that inflicted millions of dollars of additional damage on homes.

However, the Forest Service adopted many of the recommendations of the Stakeholder Group, but refused to commit to the preservation of most of the larger trees. Forest Service biologists reasoned that in some areas those larger trees exist in relatively dense clusters.
#That refusal to set a clear size limit on the trees caused concern among some members of the Stakeholder Group, including Martin — who found herself in the unusual position of agreeing with the Centers for Biological Diversity, which had spent years suing to block timber projects on the grounds they continued to target the big, fire-resistant trees.
#The selection of Pioneer after almost two years of study and delay initially posed a near-mutiny among the Stakeholder Group. Pioneer actually offered to pay the Forest Service millions less for the bid than did the contractor who had spent years working with the Stakeholder Group. Moreover, Pioneer omitted any money for monitoring whether the thinning projects had the desired impact on wildlife and watersheds.
#Martin also raised concerns about whether Pioneer had enough financing — and a business plan that would yield a profit on turning small trees into energy and into furniture.
#Forest Service officials in the Southwestern Regional Office in New Mexico made the selection, without direct input from the Stakeholder’s Group.
#Pioneer has said it remains on track to start work in the spring. Marlin Johnson said the company will start off with already-prepared timber sales and send the wood it harvests to existing mills, while the company continues to line up financing for its own mills.
#The company plans to build a 500-acre plant near Winslow, which will convert small trees into finger-jointed materials, like furniture and other wood products. The company also plans to build a bio-diesel fuel plant, which would turn brush and scraps into diesel.
#Johnson noted that Western Energy Solutions/Concord Blue USA will build and operate the bio-diesel plant.
#However, Pioneer has yet to announce any firm commitment for financing of the thinning projects or the Winslow plant.

I’ve heard many times that groups think “you should never take big trees,” e.g. diameter limits But if big trees are in a clump, and you are trying to thin trees, then to get fewer trees in the clump you would have to take out big trees. I’d be interested to have a discussion with someone with this point of view and see what their side of the story is.. that is.. the “no big trees” point of view.

Forest Guidelines For Goshawks May Not Help

TThanks to an eagle-eyed (or hawk-eyed?) member of our circle…

Here’s the link

And here’s an excerpt:

“Our forest plans require it,” he said. “But that would be a pain” if the existing guidelines don’t actually help the goshawks successfully rear more chicks. “We do have different prescriptions for the goshawk areas. In those breeding areas we know they typically have a higher (tree) density. So we have prescriptions for that. We’re trying to manage the future forest. One of the big concerns is whether we’re going to have adequate canopy cover — so we’re really managing groups of trees and also providing for those interspaces and managing for their prey.”

#But the NAU study raises questions about whether biologists yet know enough to micro-manage the forest for the benefit of any individual species.

#The goshawk and the Mexican Spotted Owl for years have fluttered about at the center of the legal and political fight about the future of the forest. The agile, crazy-orange-eyed goshawk is nearly as large as a red tailed hawk, but can maneuver deftly through the thick forest. In open areas, they tend to lose out to the red tails — which circle overhead looking for prey rather than perching on tree branches for a quick swoop to the ground.

#The now nearly defunct timber industry in Arizona made most of its money on cutting the big, old growth trees associated with those species and others like the Kaibab squirrel and the Allen’s lappet-browed bat. With most of those trees reduced to two-by-fours, the timber industry had a hard time making money on the smaller trees that remained in dangerous profusion.

#The Centers for Biological Diversity has repeatedly sued to prevent timber sales that included a large number of old growth pines greater than 16 inches in diameter at about chest height. For instance, earlier this year the Centers for Biological Diversity successfully blocked a timber sale on the North Rim of the Grand Canyon on the grounds that the 25,000-acre sale would include about 8,000 old-growth trees — even though such trees account for only about 3 percent of the trees.

#The NAU study demonstrated that biologists still don’t really understand what species like goshawks need.

#None of the sites studied very closely matched the guidelines, which call for clusters of giant, old-growth trees and nearby areas with underbrush likely to result in high populations of 14 different prey species.

#Although little true old-growth ponderosa pine forest remains in Arizona, the researchers expected to find that the more closely the conditions around the nest area resembled that prescription — the more chicks the goshawks would produce. In fact, the more closely the forest matched the prescription the fewer chicks the hawks reared.

#That doesn’t mean the goshawks don’t prefer nesting in big, old growth trees. But it does mean that they’re not as sensitive to the prey populations in the area or the nearby forest conditions as biologists had expected.

But my favorite quotes are:

The NAU research now throws into question many key assumptions built in ponderous legal strictures of existing forest plans.

#“The results raise questions about the decision to implement the goshawk guidelines on most Forest Service lands in Arizona and New Mexico,” the researchers concluded.

#However, the Forest Service remains legally bound to the detailed guidelines now cast in the legal concrete of adopted forest plans.

“Ponderous legal strictures” and “legal concrete of adopted forest plans”, indeed. The old conundrum – while some people look for certainty of protection in plans, others look for flexibility to respond to changing conditions. Can both sides ever be happy?

Wilkinson on 4FRI

I thought it was interesting that High Country News published this piece, by Charles Wilkinson, a law professor at University of Colorado. Here’s a link to his bio. Historical note: yes, the same person who was on the Committee of “Scientists” for the 2000 Planning Rule, so he’s been following these issues for some time.

Below is an excerpt of the piece. You can also find it at here at the Summit Daily News (thanks, Bob Berwyn) and other papers where Writers on the Range is syndicated. Because HCN and the syndication reach many readers who are not following this issue, I think it’s important to take a look at what Wilkinson says- what most people (outside the area) will read about what’s going on. The stakes are high for a landscape scale collaboration, so it is interesting to follow this, even for those of us far removed. What is interesting to me is the continuing story/question that the FS is screwing up with its choice of contractor, or about to screw up (before the EIS is released..??). Do people really think that the FS would go back on the general agreements that they worked so hard, for so many years, to get?? Or is this about something else entirely?

This blog is one of the few places that we could actually have this discussion with the details and knowledgeable people involved, so I am hoping when the EIS comes out we can track it here. Also, I think it’s the proposed action we’re interested in and not the EIS, but I guess I’m being pedantic again. I like to keep those separate in my head because I think it helps clarity.

We have discussed the 4FRI selection of contractor before here on this blog. including here, here and here.

The first link discusses the FS reasons for selecting the contractor. Like I said in that post, there is plenty of wood around the SW and Interior West, if folks have a good business plan maybe they could take it and develop 4FRI II elsewhere?

But a red flag has gone up: On May 18, the Forest Service announced its choice of contractor for the 4FRI process — Pioneer Associates, whose representative for the project just recently worked for the Forest Service. This was the largest stewardship contract awarded in the agency’s history, and yet the agency bypassed the contractor most deeply involved in 4FRI, the one whose business plan was closely tied to the project’s unique provisions.

Several 4FRI organizations have strongly criticized the choice of Pioneer Associates, citing the inadequacy of its business plan. The Eastern Arizona Counties Organization, for example, detailed “glaring deficiencies” in Pioneer’s bid and concluded that the award was “not based on either economic or ecological merit.” What’s troubling to many observers is that the choice of contractor may indicate that traditional attitudes are tearing away at the agency’s support of 4FRI.

The Forest Service, with its long and rich history, has run into trouble with the public and Congress in modern times over two main issues: Its timber harvests for far too long were set way too high, and far too often the agency insisted on doing things its own way. This approach — “we are the experts” — persisted in spite of contrary public opinion.

Both problems have been alleviated over the past decade or so. The timber cut is way down. The Forest Service now touts its commitment to collaboration with citizen groups, an approach that is widely agreed to be preferable to litigation and top-down, federal decision-making.

Doubters in Arizona, however, see the recent selection of Pioneer Associates as a bad sign. Tommie Cline Martin, a Gila County supervisor, predicts that, given the chosen contractor, the Forest Service will follow the same path as in the past, and that means “cutting big trees before getting to the small stuff, which is the threat to our remaining sickly forests.”

In the next few months, the Forest Service will face a major test on 4FRI, perhaps the agency’s most ambitious and carefully prepared collaboration effort. The regional office in Albuquerque will release — probably in July or August — the draft environmental impact statement for the collaborative effort. Does the choice of contractor suggest a lesser Forest Service commitment to 4FRI? Will the draft EIS weaken 4FRI’s environmental safeguards?

An immediate sign of trouble ahead is the news that Pioneer failed to include in its bid any funding for the regular monitoring of restoration efforts, an essential activity for good public land management. Will the draft EIS insist upon monitoring that will meet the standard set by the collaborative effort? Another hallmark of 4FRI’s approach is its commitment to thinning small-diameter trees because they, and not the large-growth trees, constitute the fire hazard. Will the draft EIS continue that emphasis?

Time for litigating forest restoration projects has ended : Editorial from Az Daily Sun

Here’s a link. Below is an excerpt.

The Forest Service helped its cause by finally releasing its rationale for picking the Montana company for the initial 300,000-acre contract.

— Pioneer would hire about 500 people,

— It could get started just seven to eight months after contracts were signed

— It would make a variety of products (furniture parts, molding, flooring mimicking hardwoods) that would be diversified enough to sell consistently during recessions.

— It would have the advantage of stable fuel costs in turning branches and fine matter into biofuel as proposed.

That didn’t convince Pascal Berlioux of AZFRP, who sent out a three-page single-spaced email on the day that administrative appeals were due listing the reasons he thought his company would be a better choice. Whether it was price, risk, technical expertise or marketability, Berlioux insisted his was the better proposal. Personally, he noted, he had put six years of his life into the project, and some of his fellow board members had put up their life savings.

But in the end, Berlioux did not appeal, saying the Forest Service had made a nebulous “best value” judgment that it was unlikely to overturn. For the forest’s sake and the health of its host communities, Berlioux did the right thing by not appealing, and we in northern Arizona owe him a big thanks.

That still doesn’t rule out possible legal appeals by the Center for Biological Diversity, Grand Canyon Trust and others with objections to the contract. Their main concerns appeared to be a fear that Pioneer would not be as collaborative a partner as AZFRP (it didn’t offer to pay for monitoring) and that it lacked relevant local experience. Also, its plan to convert biomass into cellulostic biodiesel fuel was untested, they said.

Those objections, however, amount to speculation. The reality is that both companies would have been good choices, but only one could win — there isn’t enough wood to support two wood processing mills over the next 20 to 30 years.

Each year of delay is another year that catastrophic crown fires could wipe out much of the forest resource and devastate local ecosystems. As it is, the Pioneer mill won’t be up and running for at least a year or more. There are no more legitimate excuses for delay, and we urge conservation groups to stay in the 4FRI process and see it through to a successful conclusion.

Note from Sharon: So what interested me was this statement: “The reality is that both companies would have been good choices, but only one could win — there isn’t enough wood to support two wood processing mills over the next 20 to 30 years.” Maybe not around Flag, but lots of other places there is. This seems to be one of the few places where there is more capacity than material.

Too Little of A Good Thing? Early Seral in the Pacific Northwest

Sitkum Valley, on the East Fork Coquille River; Bob Zybach took about this photo around this time in 2011

Bob Zybach is bringing this draft review article to our attention.

The article is by Mark Swanson, a professor at Washington State University.
Here is the abstract

Abstract
Early seral forest is attracting increasing attention from scientists and managers. This literature review, produced under contract to the United States Forest Service, addresses basic questions about this important seral stage in the forests of the Pacific Northwest (west and east of the Cascades Range). Generative processes, historic landscape abundance, ecological value, associated species (and their ecological adaptations and conservation status), landscape-scale considerations (including patch size), and issues relatied to forest management are central topics. In general, naturally structured early seral forest in the Pacific Northwest is important for many ecosystem services and species (including obligates and near-obligates), but has declined from historic landscape proportions.

And the Conclusions:

Conclusions
While the public is not necessarily predisposed against early seral forest (and in some cases may favor certain types), there is still greater public concern over late-successional types (Enck and Odato 2008), likely due to widespread policy and media emphasis on old-growth forests and their relationship to management. However, specific values associated with early seral habitats, from big game production to huckleberry harvesting, are attracting increasing attention from the public. Managers concerned about maintaining rare species are increasingly acknowledging the value of early seral habitats for a substantial portion of the biodiversity of the Pacific Northwest. Potential management responses may include:
 Deferring salvage and dense replanting across all or parts of major disturbed areas (Lindenmayer and Noss 2006, Lindemayer et al. 2008))
 When salvaging, practice variable retention to retain significant structural elements such as large-diameter live trees, snags, and down woody debris (Franklin et al. 1997, Eklund et al. 2009).
 Avoiding reseeding with exotic plant species such as perennial ryegrass (Lolium perenne) following fire or volcanic eruption (see Dale et al. 2005b).
 Attempt to incorporate elements of natural disturbance regimes into landcape-scale management (Lindenmayer and Franklin 2002)
 Deliberate creation of large, early seral areas via silviculture (Swanson 2010).
Researchers have an important role to play in facilitating changing attitudes. Much of the excellent research done on seral dynamics in Northwestern forests (e.g., Ruggiero et al. 1991) was focused on biota associated with young, dense forests, mature forests, and late-seral forests. The pre-canopy closure stage component of succession was either not measured (as in Ruggiero et al.), or clumped together with stem exclusion (sensu Oliver and Larson) stands in analysis. While there is an increasing amount of research on true early seral forest, and management responses to these advances (King et al. 2011), much remains to be done in most temperate forest regions both in terms of research and management (Swanson et al. 2011b). It is hoped that the diversity and value of early seral conditions, from clearcuts to structurally and compositionally complex early seral habitat, will come to be recognized and widely incorporated into contemporary land management.

Arizona forest deal winner now taking heat: Arizona Sun

I got this from the Forest Business Network here.

Here’s the link to the story in the Arizona Sun.

Below is an excerpt:

COVINGTON LIKES CHOICE

The only real question is who should do it.

Wally Covington, head of the Ecological Restoration Institute at Northern Arizona University, said he likes the choice and that it’s time to get to work.

“I think we’ve got it together pretty darned well here,” he said. “… We’ve got to get the excess trees off the landscape before the outcomes that are worse than the very worst clear-cut can propagate across the landscape.”

So does Paul Summerfelt, a longtime city of Flagstaff firefighter and president of the Greater Flagstaff Forest Partnership, which has successfully pressed for less dense and healthier forests around Flagstaff.

“It’s a win in that we finally have a contract, which has been a long time coming. It promises to bring a lot of wood-related jobs into northern Arizona irrespective of who the contract winner was, and it restores the forest,” he said.

And so does Steve Gatewood, who has worked elbow by elbow with Summerfelt for years to try to thin forests here.

Environmental groups do have a case history to stand on when thinking the agency won’t do the minimum it promises, he said.

But this is a big departure from past thinking for the Forest Service, in his view.

“They’re actually talking about interspaces and openings and savannas and that kind of stuff,” Gatewood said.

SOUR GRAPES

Opponents are guilty of sour grapes, says the main person planning the Four Forests Restoration Initiative, as this big thinning idea is called.

“Obviously, several folks aren’t happy with the selection. And to be honest, there’s a lot of misinformation being spread by those folks,” said Henry Provencio, head of the implementing the project for the Forest Service.

The Center for Biological Diversity was first in denouncing the decision earlier this month, saying the U.S. Forest Service went with the bidder offering to send a lesser amount of money to the U.S. Forest Service for reasons that aren’t clear.

“On the one hand, they’re saying they can’t afford to monitor endangered species, such as the spotted owl … and on the other hand, they’re saying they’re going to reject $5 million for monitoring. It makes no sense,” said the Center’s Taylor McKinnon.

The Forest Service hasn’t released any of the bids to the public, but it has released its criteria for winning.

A business’ willingness to remove limbs and fine matter, its past performance, references from others, its business plan, its impact on local communities and the amount of money per acre it offered to the Forest Service were all considerations, according to documents sent to bidders.

EXTRA SCRUTINY

Among Pioneer’s partners is Marlin Johnson, a former administrator in the U.S. Forest Service who retired from that agency a little more than four years ago, Johnson said.

That was before bids for this project were submitted.

The Center for Biological Diversity faced him in court sometimes, and it asserts that he intends to log big trees from other areas and use them to feed a big mill.

Johnson says otherwise: His mill won’t be able to accept trees bigger than 16 inches in diameter, he said.

He or any other winning business would have to cut whatever trees the Forest Service wants removed, he said, and sell the bigger ones to other businesses.

“We won’t legally be able to tell the Forest Service: ‘Oops, you want that 20-inch tree cut? We won’t do it,'” Johnson said.

The project triggered extra scrutiny within the Forest Service.

“As soon as we knew that Marlin was a participant, I asked for a review by our ethics branch …” and then also one in Washington. “I knew that would come up,” said Corbin Newman, regional forester for all national forests in the Southwest.

BIGGER PICTURE

He says the debate over who got the contract is obscuring the bigger picture.

“I want folks to realize: Let’s have a little concern about who got it and who didn’t, but let’s also have a little concern about restoring Arizona’s forests,” Newman said.

The other three bidders have until the end of Friday to appeal the bid decision.

Arizona Forest Restoration Products did not respond to phone calls on Tuesday or Wednesday.

Biscuit “Scenic” Pictures

This is an example of a “protected” nesting site for a northern spotted owl. It was never logged and will not be habitat for many decades, especially if a reburn occurs. It sure doesn’t look “natural and beneficial”, to me, OR the owls and goshawks.

Here are the kind of snags (the large orange-marked one) that were selected to be “saved”, within Biscuit cutting units. Of course, only 4% of the 500,000 acres of the Biscuit were salvaged, so there certainly is no lack of snags in the huge burn.

Here is a cutting unit where mortality was close to 100%, in unlogged old growth. Instead of thinning a green stand, we ended up “thinning” snags.

Here is some erosion, in a small gully. I wonder what the “cumulative impacts” of hundreds of similar gullies have upon salmon populations, and other aquatic organisms. Surely, some of these gullies experienced accelerated erosion in the 5+ years since I took this picture.

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