NWFP

If we can make it through the next month or so of “bad Forest Service and BLM” we can make it to “bad Trump,” and breath a sigh of relief. After all federal employees are wonderful, unless they do things (important people we don’t know) don’t like. I haven’t been following all the ins and outs of the NWFP amendment, but know readers are involved.

The U.S. Forest Service proposal, released Friday, would overhaul the Northwest Forest Plan that governs about 38,000 square miles (99,000 square kilometers) in Oregon, Washington and California.

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Much has changed in society and science since the Northwest Forest Plan was created,” Jacque Buchanan, regional forester for the Forest Service’s Pacific Northwest Region, said in a statement. He said the proposal would help the agency adapt to shifting conditions, as global warming increases the frequency of droughts and other extreme weather events.

FWIW, I think Jacque uses she/her pronouns. Oh well.

Cutting more trees would help reduce wildfire risk and make communities safer, the study concluded. That would be accomplished in part by allowing cuts in some areas with stands of trees up to 120 years old — up from the current age threshold of 80 years.

The change could help foster conditions conducive to growing larger, old growth trees that are more resistant to fire, by removing younger trees, officials said.

A separate pending proposal from President Joe Biden’s administration aims to increase protections nationwide for old growth trees, which play a significant role in storing climate change-inducing carbon dioxide.

“Much has changed in society and science since the Northwest Forest Plan was created,” Jacque Buchanan, regional forester for the Forest Service’s Pacific Northwest Region, said in a statement. He said the proposal would help the agency adapt to shifting conditions, as global warming increases the frequency of droughts and other extreme weather events.

The proposed plan also calls for closer cooperation between the Forest Service and Native American tribes to tap into tribal knowledge about forest management. Tribes were excluded when the 1994 plan was crafted.

Environmentalists greeted the proposal with skepticism. The group Oregon Wild said it was “deeply troubling” that the Forest Service would release the proposal just ahead of a change in presidential administrations.

“It appears that the Forest Service wants to abandon the fundamental purpose of the Northwest Forest Plan–protecting fish and wildlife and the mature and old-growth forests they need to survive,” John Persell, an attorney for the group, said in a statement.

It almost sounds like the FS is a separate entity.. the old “rogue agency” idea. Logically, there are a small number of possibilities.
1. The Biden Admin supports this decision.
2. The Biden Admin doesn’t care either way, everyone’s too busy looking for their next job.
3. Different entities in the Biden Admin disagree, but there is no conflict resolution system.
4. The Biden Admin doesn’t like the decision but is too disorganized to transmit that info to the FS.
5. The Biden Admin told the FS what to do, but the FS is blowing them off. (I consider this one least likely)

I disagree a bit with John P. (as quoted), I think it makes sense to cement in (insofar as possible) the work of the group they brought together (the FACA committee) before the next Admin kicks in.

The AP story does quote Travis Joseph of AFRC:

A timber industry representative who co-chaired an advisory committee on the Northwest Forest Plan said the proposed plan resulted from discussions involving committee members, the Forest Service and others.

“We want to see a modern approach to federal forest stewardship that protects us from catastrophic wildfires, reduces toxic smoke, meaningfully engages tribes, and delivers for our rural communities and workers,” said Travis Joseph, president of the American Forest Resource Council.

SJ and I were having a discussion which I will reproduce here, because it brings up questions beyond the NWFP.

First, I asked these questions.

I would still like to see an independent group examine how well it did on:
1. The social and economic aspects as per principle “ever forget the human and the economic dimensions of these problems,” we know that there were economists involved (with differing opinions) and I wonder how many social scientists were involved. As I recall, Bob Lee, a sociologist, was not a proponent of the approach and it led to a kerfuffle with Charlie Philpot, but I haven’t been able to find copies of the letter exchange, which I think would be useful to future historians.
2. How well did the “government working together” work? The REO.. was it another level of bureaucracy or did it provide value? Has it naturally died out? What happened?
3. Survey and manage pros, cons, was it a good investment, did it add value?
4. Adaptive management areas..the story I heard that was for litigators, cutting trees experimentally was not on the table either.. is that true? What happened that they didn’t apparently work as intended?
5. However many years later, thanks to the NWFP FAC, (even though there are few people from the NWFP terrain on the E side) it is officially recognized that dry forests are different and require different management, and yet many FS people were saying that at the time. Why did it take so long to figure this out? What about SW Oregon? Were regional differences and knowledge adequately considered? To what extent was “the science” Corvallis-centered and has this monopoly been adequately broken up?

Why isn’t the FS or BLM or OSU figuring out how to do an independent review of the NWFP?
After all, one of Clinton’s principles was the government should work for us.. the same government that can do an after action review on a vehicle rollover, can’t initiate a review of a much more extensive and expensive process?
It doesn’t make sense, unless powerful entities don’t want to hear what might come up. But all the entities, OSU, FS BLM have a potential COI, so it would be interesting to design a truly independent review.

SJ added links to more information.

The monitoring reports (available here: https://www.fs.usda.gov/r6/reo/monitoring/) and the Science Synthesis (available here: https://www.fs.usda.gov/pnw/pubs/pnw_gtr966.pdf) answer many if not most of your questions.

Another source – perhaps the Cliff Notes version – is the law review article I wrote with Professor Mike Blumm (available here: https://lawcommons.lclark.edu/faculty_articles/146/).

A longer form source is The Making of the Northwest Forest Plan by Franklin, Johnson, and Reeves (available from booksellers).

After examining and reflecting,  I thought that perhaps we were talking past each other.  I was talking about “how well it worked and what was learned about how we could have done it better  (more efficiently, effectively and with fewer negative impacts.”  I was basically thinking from the management or public administration perspective.

So I looked up Program Evaluation and it turns out that GAO (the Government Accountability Office)  had this interesting report. Check out (3) continuous learning. But as I reviewed this, I thought the NWFP was not alone, there are probably many FS programs that have not had formal program evaluations. Suggestions?

So far it doesn’t appear that the NWFP has had a formal program evaluation, let alone independent external review. It would be a great deal of work but so was (is) the NWFP. Characteristics might include independence, transparency to the public, opportunities for listening to stakeholders. Yes, a program evaluation could become a bureaucratic morass if not carefully designed and implemented, but that could equally be true of the NWFP itself, and how would we know? Finally, I think it was interesting that Colorado and Idaho State Roadless Rules had a national FACA committee to ensure that the national perspective was taken into consideration, apparently this wasn’t thought necessary for NWFP, which covers three states.

Jim Petersen of Evergreen had an interesting post today.  I’d like to draw your attention to three things.

1. NWFP argument for an amendment rather than a revision.

     “Why is the Northwest Forest Plan being amended instead of revised?

And the answer to Question 3:

·     A plan amendment is required to add, modify, or remove plan components or to change how and where plan components apply to all or part of the plan area. A plan revision would create an entirely new plan.

·     The amendment approach allows us to keep what is working about the Plan and update those critical plan components most urgently needed to meet modern management challenges within the plan area.

While I think the NWFP FAC folks thought that a revision of the NWFP might be better, but the FS was told the Department preferred a more compact timeline (or so I’ve heard), I take the opposite view of the same FAQ.  The second bullet seems to me a perfect argument for why revisions should be exceptions, rather than a scheduled requirement.   I think you could make the same argument about almost any plan, including our local 1984 plan.

I’m a plan minimalist.  What is in the plan that keeps the FS from responding adequately to important challenges? In fact, that goes back to our ideas (in the 80’s) of a plan as a loose-leaf notebook, readily updated.  Opening up every decision or line of print in a 300 page document, for no compelling reason, leading to more litigation and stirring up bad feelings, and spending lots of money on analysis.. I’m not for it.

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2. Role of Experienced Forest Service People in Giving Advice, or Not

But why in heaven’s name was only one ex-Forest Service person named to the advisory committee and why were no agency retirees selected? Collectively, these men and women represent hundreds of years of first-hand, on-the-ground experience. They know what works and what doesn’t.

One retiree I know well said, “From a technical and managerial standpoint, this is a major failure. Execution is a critical part of reviewing a strategy or plan, and yet there was only one person on the advisory committee who had any experience at all to execute the 1990 plan which covered over three states, involving many field and management people from all the Forests over the past 30 years. This makes no sense at all.”

He’s correct. It doesn’t make any sense. It’s 1990 all over again – and it stinks.

Actually I believe Jose Linares is retired, and did work for the Forest Service.  Here’s the nomination letter that NAFSR (retirees) wrote for him. At the same time, the “seat” he is filling is due to his membership in “underserved communities outreach organizations.” I doubt that the FS  meant NAFSR ;).

But Jim has a more general point. I recall when the “Committee of Scientists” (or as I called them “the Committee of Scientists Plus One Law Prof”)  discussed and made recommendations on planning.. no actual planners were involved on the panel, but they could “give input.”

To make something better, it seems to me that you need to understand the nuts and bolts of how it works.  Privileging outsiders’ views seems a bit disrespectful of  workers.   We wouldn’t enlist academics, for example, to do wildfire lessons learned.  At the same time, these are ultimately political decisions so you need people to support them that have political power of some kind.  I’d try two separate committees- one of employees, and one of outsiders, like houses of Congress only friendlier;  give the committees a chance to reconcile the versions and then, for the parts not agreed upon, the Department makes the call.  If they weren’t in a hurry they could still try this.  Or maybe just a list from the employees of  thteir druthers before the process is initiated and a review afterwards with employee comments. By the time it’s an EIS, the idea horses are too far out of the barn IMHO.

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3.   Spotted Own/NWFP History Story

I think we need to collect these stories before they are lost in case future historians are interested in the NWFP.  So if you have others..

Early in the owl war the long gone National Forest Products Association [NFPA] went looking for a statistician who could review the government’s owl data.

I know this because the late Con Schallau, a brilliant PhD forest economist and member of the Evergreen Board of Directors, called the late Ben Stout, with whom I was well acquainted, to ask who Ben might recommend for the job.

Stout earned forestry degrees from West Virginia, Harvard, and Rutgers Universities. He taught and held administrative positions at Harvard University, Rutgers and the University of Montana, where he was also forestry school dean until 1985.

He was then hired as National Program Manager, Air Quality and Forest Health by the science-heavy National Council of the Paper Industry for Air and Stream Improvement [NCASI] based in Corvallis, Oregon.

Suffice it to stay, Stout was well traveled and well respected in academic circles. Hence, the call from Con. Although Stout did not know him personally, he told Con that NFPA ought to consider Ed Green, a young statistician teaching at Rutgers.

Con hired Green to do the review because, among other things, he hadn’t heard much about the owl wars in the West. Thus, not much risk of bias.

The day before Green was scheduled to fly to Washington D.C. to present his findings at an NFPA press conference, he called Con to say he couldn’t go through with it.

When Con asked why, Green explained that Forest Service Chief, Jack Ward Thomas, had walked into his office unannounced the day before and threatened his untenured career if he released his findings in D.C.

“You’re in the big leagues now, boy,” Thomas had said. “Be careful.”How did Thomas know what Green was doing? It turned out that Green’s boss and Thomas were elk hunting buddies.

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About 20 years ago, I flew to Rutgers in Camden, New Jersey to interview Green.

I wanted to know if Thomas had threatened him. He had.

I left Green’s office that day with a copy of his statistical review. It blew the statistical validity of many owl plan assumptions to smithereens.

After Thomas quit the Forest Service, he taught graduate level wildlife biology classes at the University of Montana.

I was living in Bigfork, Montana at the time, so I drove to Missoula to interview him, not once but several times.

I confronted him with what Green had told me. At first Thomas denied it, but he ultimately grumbled that “something like that” had happened.Jack [we were now on a first-name basis] also admitted the daily working notes from the scientists who worked on the Spotted Owl Plan – had been shredded every night – then packed in large black plastic garbage bags and trucked to an incinerator at Boardman, Oregon.

“Why Jack,” I asked. “You were working behind locked doors with guards on the top floors of the 54-story US Bancorp Tower in Portland. Did you think burglars might steal the paperwork in the middle of the night?

“No, I was worried the press might go through the garbage bags on the first floor,” he explained. “Those were very tense times – with a lot at stake.”

Thanks to Steve Wilent for this one…

Maybe my math is off, but it sounds like 90 days after sometime in October will be close to Inauguration(Jan 20) so they are not in a hurry, because analysis of the comments will clearly take time. I think that’s a good thing for employees, the public, and good policy.

This reminds me of when we were working on Colorado Roadless right before an election; Mark Rey (the Undersec at the time) told us something like “a good process will hold up across Admins, so just take your time.” The end result decision in our case was ultimately signed by Hickenlooper and Obama.. and still litigated for a substantial period of time by the usual suspects. And so it goes…

Update on the Release of the Draft Environmental Impact Statement for the Amendment to the Northwest Forest Plan

Portland, Ore. (August 27, 2024) – The USDA Forest Service is informing partners, collaborators, and the public that the release of the draft Environmental Impact Statement for the amendment to the Northwest Forest Plan, initially anticipated at the end of August, is now expected in October.

When released, the draft EIS will be published in the Federal Register which will start a 90-day public comment period allowing all interested parties to provide input on the proposed amendment.

The USDA Forest Service is amending the Northwest Forest Plan to address changed conditions with a focus on five key areas: wildfire resilience, climate change adaptation, tribal inclusion, sustainable communities, and conservation of old growth ecosystems and related biodiversity. The Forest Service is committed to preserving the elements of the plan that are working well while incorporating the latest science to help forests adapt to social, economic, cultural, and ecological changes.

The Northwest Forest Plan covers 24.5 million acres of federally managed lands in California, Oregon, and Washington. It was established in 1994 to address threats to threatened and endangered species while also contributing to social and economic sustainability in the region. After nearly 30 years, the Northwest Forest Plan needs to be updated to accommodate changed ecological and social conditions.  

For more information visit the Northwest Forest Plan webpage at: www.fs.usda.gov/goto/r6/nwfp

Speaking of the Timber Wars, I received this in the mail from Andy Kerr this morning.

It’s part 2 of what he thinks needs to be changed in the NWFP.  Kerr talks about his views and looks at the recommendations of The Making of a Northwest Forest Plan and The World’s Largest Ecosystem Management Plan: The Northwest Forest Plan After a Quarter-Century.  I’m sure you NW-ers will find something to discuss.

1.  I was kind of surprised that Westsiders felt like they knew what was best for dry forests.  I’m not sure about this..

It’s still stand-density reduction, whether the trees being removed are dead or alive. As Jerry and Norm have told me many times, if a dry-forest stand burns before it is treated (thinned), the best course is to leave the larger trees that would have been left and take the smaller trees that would have been removed in a restoration treatment had the stand not burned.

2. The NWFP was just the beginning, folks want the same thing on private lands (now why wouldn’t people invest in private timberlands?)

The NWFP should call for terrestrial habitat restoration on nonfederal lands as well—better yet,  to reconvert private timberlands to public forestlands.

3. At least the recommendations cited here, seem related to past views of ecological stability vs. dynamism, and only incorporate climate change in ways that support what they thought 30 years ago.

(NJG) UTILIZE TREATMENTS, INCLUDING THINNING AND BURNING, TO RESTORE OLD DRY FORESTS TO APPROXIMATIONS OF THEIR HISTORICAL STATES

(AK) Amen, with a however. Burning must always occur, either as the only treatment or the follow-up treatment after scientifically sound thinning.

Some folks here are concerned that burning can be more dangerous due to climate change-induced factors of heat and drought. Others model and say the trees are all going to die in the next 50 years.  When and how do we consider climate change impacts?

4. If AGW is real then lots of species will move around and may be more successful than the natives.  If that happens should we/can we afford to kill them all off? Is the NSO in some kind of sacred category or how many species will we do this for?

CONSERVING THE NORTHERN SPOTTED OWL

(NJG) • KILL BARRED OWLS TO PROTECT NORTHERN SPOTTED OWLS ON AT LEAST A PORTION OF THE SPOTTED OWL’S RANGE.

(AK) Amen and hallelujah. See my Public Lands Blog post entitled “B. Owl v. N. S. Owl.” ”[A]t least a portion should, praise be, “all” of the spotted owl’s range.

5. And always, wolves are moving back so…end livestock grazing and reduce road densities. And yet somehow their ranges are expanding without ending livestock grazing, or timber harvesting, or  reducing road densities.

 Gray wolves are returning to the NWFP area and need to be made more welcome. Wolf-friendly measures include equitably ending livestock grazing and reducing road densities.

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With the FACA committee, I suppose that this is only the beginning of these discussions.