Planning

What Should a Forest Plan Do and Not Do?

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By Rex Norman, retired public affairs officer on the Lake Tahoe Basin Management Unit
Josh Milligan asks:

I’d be interested to hear thoughts on what specifically makes a good forest plan. It seems like they’re overly complicated and some of the direction is marginally relevant. Conversely, I’d be interested to hear what people think forest plans should avoid doing.

Any thoughts on whether there’s a mental filter to sift through the universe of topics a plan could address to those that are meaningful?

We used to have a great many discussions on planning back when we were bright-eyed and bushy-tailed. In fact, talking about our different views about forest planning was one of the reasons Martin Nie and I started this blog, almost 10 years ago. I’ll also admit I may be biased..I live near a forest that seems to be doing excellent and innovative work without having revised its 1984 plan.

Here’s what I said in 2011 in response to Dave Iverson’s piece on the three levels of planning..in which he quoted the Committee of Scientists on forest plans as a “loose-leaf notebook”:

At the risk of sounding like Andy (he of the KISS Rule, see tab above), those three levels are pretty much a myth. We can talk about oil and gas leasing decisions, which are neither plan nor project. Or travel management (not a “project” in the same way a fuels treatment project is). Not to speak of the comprehensive master development plans for ski areas (their desired conditions). There are forest-wide invasive species treatment decisions and fire use decisions. There are multi-forest “species” decisions like the grizzly bear and lynx. There are even projects that are multi-forest. like power line clearing. Or Idaho roadless, which was state-wide, even across FS regions.

I think the COS idea reflected reality; that there are overlapping layers of decisions that are constantly shifting – faster than NFMA 15 year plans can possible keep up with. The loose-leaf notebook is a great image. But the fundamental problem with their perceived NFMA tab in the looseleaf notebook:

“It can include regional guidance for conservation strategies relevant to the area; the strategic vision, policies, and multiple-use goals developed through large landscape planning, including the description of the desired future conditions ” are those darned DFCs. If they are too general (“happy healthy ecosystems”) no one knows what they mean; if they are too specific (30 percent ponderosa pine in the 20-40 year age class), in an age of climate, or other kinds of change (including insect outbreaks) they can easily become out of date before 15 years or 30 in the case of some forests..)

I often ask folks what bothers them about having an out-of-date forest plan; it is usually litigation because something in the plan has become difficult to achieve due to changing conditions.

As I’ve said before, if I had given the most recent COS group a charge, it would have been to figure out “What, if anything, is useful about NFMA planning? To whom is it useful? How could we continue doing the useful pieces, but more effectively and efficiently?

The most important things that I think plans do is “put lines on the ground” and decide what happens where in a way that travel management and oil and gas leasing decisions can follow. But lately it seems like folks do that through Wilderness or Roadless or Special Management Areas or Proposed Wilderness or … and not having a Plan Revision process is not a barrier to these. I do like the idea of “people sitting around talking and then monitoring results together” as described here in an effort to synthesize previous discussions.

And I agree with Dave Iverson here.
“You can only hope to accomplish anything when you are able to define the scope the problem (time, space, issues, etc.) into “decision containers” that people (stakeholders, administrators, etc) can get their minds around. It seems that traditional “forest plan” containers are hopelessly over-filled when land management zoning, land management goals and objectives, program goals and objectives, and related “standards and guidelines” are all in play — and “in play” in a spatial container that isn’t really relevant to many of the objectives at hand.”

So here we are eight years after these discussions with a new NFMA Rule and new plans.. what are people currently thinking in answer to Josh’s question? I’d particularly like to hear from commenters from outside the FS who have participated in plan revisions.

Why we need coordinated planning for habitat connectivity

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The Bridger-Teton National Forest amended its forest plan in 2008 to designate the portion of the “Path of the Pronghorn” migration corridor in Wyoming for special management to protect this historic 90-mile route with a northern terminus in Grand Teton National Park used for summer range.  It’s probably the most significant action taken by the Forest Service to plan for wildlife connectivity.

The BLM chose to not play along at the southern end where major oil and gas fields are found in the species’ winter range, and the migration route lacks recognition, and protection, through BLM lands along its southern reaches.  Now they have issued an EIS for oil and gas development there.  Ideally, the EIS will disclose the effects on pronghorn migration and on the national park (using the best available science), which could include exterminating this migration and its pronghorn herd.  But I wanted to comment on the planning aspect of this problem.  BLM blames the State of Wyoming:

“It would help us out if the [Wyoming] Game and Fish were to formally designate something in there,” said Caleb Hiner, who manages the BLM’s Pinedale Field Office.

The Forest Service didn’t wait for state action to protect national forest lands.  As an environmental activist said, “The BLM has all the authority it needs to protect what it wants to protect in a site-specific document,… The BLM could decide tomorrow that it doesn’t want to lease or develop any of the NPL.”

The 220-square-mile project has major economic potential, and could generate 950 jobs and produce somewhere in the range of 3 trillion cubic feet to 5 trillion cubic feet of natural gas, Hiner said. It would add up to 350 wells to the landscape annually for the next 10 years, a level of development that equals the number of wells permitted for drilling in the BLM’s entire Pinedale Field Office during 2017.

The argument by the proponent seems to be that they can figure out mitigation well-by-well, but at that point there is little opportunity to develop an effective strategy for pronghorn to navigate the system of wells, especially with no plan-level requirement to do so.

It is important for federal land managers be leaders in coordinating connectivity conservation planning, if for no other reason that that may be what is necessary to provide for viable populations of migrating species to continue to use federal lands.  The absence of a plan based on an overarching strategy for the full extent of the herd’s range could now be fatal to a ecological phenomenon that has been occurring, in part on national forest lands, for thousands of years.

 

How the Forest Service manages fires – examples

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A couple of recent stories provide some information about how the Forest Service is “managing fire,” and might provide some insights into the opportunity for public involvement (or not).

The Lion Point Fire is burning on the Sierra National Forest in California. Here is an article that basically incorporates the language (which may be boilerplate) from the Forest Service on its Inciweb site. (As of today, it’s burned 9 acres.)

“This lightning caused fire started approximately two weeks ago. Forest managers are determining the feasibility to manage this fire for multiple resource and protection objectives.  Desirable fire effects that are consistent with the forest plan and beneficial outcomes to the resource values at risk will be the main objectives for this incident.”

If you were the Incident Commander, and looked at the forest plan to see what it says about the desired outcomes and values at risk, you would find this in the 2004 Sierra Framework amendment ROD:

“Lightning-caused fires may be used to reduce fuel loads or to provide other resource benefits, such as conserving populations of fire-dependent species. Before wildland fires can be used, national forest managers must prepare a fire management plan that describes how prescribed fires and naturally caused wildland fires will achieve resource management objectives.”

My search for “fire management plan” did not match any documents on the Sierra website. Does anyone know if such a document exists, or what the managers of the Lion Point Fire are using?

The Sierra forest plan is currently being revised, and the 2016 draft revised plan would create four “strategic fire management zones” with different desired conditions and guidelines. (“Fire management plans” are not mentioned.)

Meanwhile, the revised forest plan for the Coconino National Forest in Arizona has just been released; it emphasizes forest health and thinning initiatives to reduce the risk of catastrophic wildfire. The latest “update” says “the revised management plan provides greater flexibility on the management of wildland fires and seeks to return the forest to its nature-based fire dependent ecosystem.” The Forest Supervisor says the new plan includes updated guidance in managing naturally occurring wildfires to burn dry forest fuels.

I found this ecosystem desired condition and these guidelines in the “fire management” section:”

“FW-Fire-DC

2 Wildland fires burn within the historic fire regime of the vegetation communities affected. High-severity fires occur where this is part of the historical fire regime and do not burn at the landscape scale.

FW-Fire-G

1 WUI areas should be a high priority for fuels reduction and maintenance to reduce the fire hazard.

2 Fire management activities should be designed to be consistent with maintaining or moving toward desired conditions for other resources.”

The Coconino forest plan describes the decision process for managing fires as follows:

“Site-specific analysis is conducted for prescribed fires and for any wildfire that extends beyond initial attack. For prescribed burns, the decision document is the signed National Environmental Policy Act (NEPA) decision. For wildfires, an analysis is performed using a tool like the Wildland Fire Decision Support System, and signed by the appropriate line officer.”

Which is not a “decision document” subject to NEPA.  And this language does not appear to address how to make a decision whether there would be an “initial attack” in the first place.

My take-away?  Forest plan desired conditions relevant to fires are even more important than for most projects if there is no later opportunity to influence a decision, so it is important for them to be specific and for them to vary in the forest plan based on the ecosystem and values at risk.  (While I didn’t look for them here, there should also be forest plan standards or guidelines applicable to suppression activities.)

Does a Fire-Ravaged Forest Need Human Help to Recover?

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That’s the title of this article.  It starts out with Chad Hanson walking the Rim Fire in California, so I thought there would be some interest here.  Like so many things, the answer I get from this is “it depends.”  It first depends on what the desired condition is.

Several months after the Rim Fire was extinguished, Eric Holst, a vice president of the Environmental Defense Fund, penned a blog stating that “letting nature heal itself” after a high-intensity fire is likely to result in a forest dominated by shrubs for many decades.”

As if that result is inherently wrong.  Whether that is a desired outcome or not is the kind of issue that should be addressed strategically through forest planning.  It may be fine from an ecological standpoint.  If the plan determines that speedier regeneration is needed for old growth species or economic reasons, that should be debated and decided at the plan level.

Then there is the science question of whether that would really be the outcome.  That depends on the nature of the site and the fire.  Regeneration problems seem to be the exception rather than the rule in the Bob Marshall Wilderness in Montana:

“The exception, he says, is in areas that have reburned in less than 20 years, too soon to allow for a seed crop to mature, especially on the west- and south-facing slopes that are hotter and drier.”

The key question to me then seems to be whether salvage logging in susceptible areas reduces the chance of reburns.  That is a determination that could be required at the project level by a forest plan standard (for those areas with a desired condition for rapid revegetation).

The site-specific effects of each salvage project would also need to be determined (and could provide reasons to not log despite the authority in the forest plan to do so), because …

“The scientific literature on post-salvage logging is contradictory. Some studies argue that the practice is beneficial because it churns up the ground, softening hard, water-repellant soils that sometimes form after an intense fire. Proponents also insist that the detritus left behind after logging inhibits erosion.  Critics such as Hanson say that the logging skidders decrease natural forest regeneration, kill seedlings, and compact the soil in a way that increases runoff and erosion, harming aquatic life in streams and rivers.”

Of course, maybe salvage logging is just as simple as how this reporter characterized the latest salvage efforts on the Lolo National Forest:

“The Lolo National Forest wants make the best of last year’s 160,000-acre Rice Ridge fire by logging some trees…  If they can get the chief of the Forest Service to grant an Emergency Situation Determination, the public will not be allowed to object to the project once Mayben makes her final decision.”

 

 

New lawsuit to protect red tree voles from logging project

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(Complete story here.)

Three environmental groups are suing the U.S. Forest Service to stop an 847-acre logging project on the Umpqua National Forest in southern Oregon, about 22 miles southeast of Cottage Grove.

Red tree vole surveys were also conducted during the fall of 2016. According to the lawsuit, the Northwest Ecosystem Survey Team found 75 vole nests in the forests slated for logging, but the Forest Service decided to proceed with the project.

The North Oregon Coast population of voles is considered a candidate for listing under the Endangered Species Act by the U.S. Fish and Wildlife Service, from the Siuslaw River north to the Columbia River, due to habitat loss and fragmentation.

(A candidate species is warranted for listing, but precluded by higher priorities.)

But here’s the part I thought might be interesting:  “The Bureau of Land Management also lifted survey and management guidelines for the species in 2016.”  As things get worse off for a species everywhere else, the national forests will necessarily be under more pressure to provide regulatory mechanisms to protect the species, and conditions external to a national forest will make it harder and more important to provide conditions on the national forest that promote a viable population.  (Implications for revising the northwest forest plans?)

Idaho county votes down wilderness

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Follow-up:                                   

Voters rejected the proposal for the Scotchman Peaks Wilderness, 5,672 to 4,831.  As a result, Senator Risch will not reintroduce his legislation to designate the area, and wilderness legislation has no chance of passing without local Congressional support.  So to a limited degree we have local control of a national forest, but as the article points out, management under the forest plan, which recommends the area as wilderness, won’t change.  (The article suggests that Congress couldn’t change the forest plan; of course it could, but I don’t think there is a precedent for it.)

The unfortunate thing is that the voters seem to have been misinformed (which is something I would hope a congressman would take into account).

“The philosophy with wilderness areas is let it burn,” said Bonner County Commissioner Dan McDonald.

And, perhaps most importantly, (Forest Service spokesperson) Cooper said Forest Service personnel can and do manage forest fires in both recommended and designated wilderness areas. “We still do manage wildfire,” she said.  In 2017, the Forest Service sent smokejumpers into the Salmo-Priest Wilderness area to fight a forest fire.

My own interpretation is that suppression response depends on the values at risk, and wilderness area values, aren’t lost when they burn (in fact probably the opposite) – like other areas managed primarily for conservation or recreation, which is how this area is being managed now. 

The mysterious disappearance of sensitive species – Flathead plan revision example

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Harlequin duck (Histrionicus histrionicus)

The Forest Service created through its directives (FSM 2670) a program to manage sensitive species, which it defined as species “identified by a regional forester for which population viability is a concern.” Sensitive species “must receive special management emphasis to ensure their viability and to preclude trends toward endangerment that would result in the need for federal listing.” Up until now, forest plans had to include direction for sensitive species “to ensure viable populations throughout their geographic ranges.” In addition, all plans and projects required a biological evaluation (BE) for each sensitive species “to ensure that Forest Service actions do not contribute to loss of viability … or contribute to trends toward Federal listing.” The BE became an important tool for biologists to use at the project level.

The 2012 Planning Rule requires identification of Species of Conservation Concern (SCC). They are defined as those for which “the regional forester has determined that the best available scientific information indicates substantial concern about the species’ capability to persist over the long-term in the plan area.” The plan must maintain viable populations of these species, but there are no requirements for future projects to address them; compliance with forest plan requirements for SCCs is presumed to meet the needs of these species. This elevates the importance of plan components for these species.

The Forest Service issued an internal letter to regional foresters on June 6, 2016 explaining that it would phase out the sensitive species designation. It recognized that, “As noted in the preamble to the 2012 planning rule, “[Regional Forester Sensitive Species] are…similar to species of conservation concern.”   It also stated that, “Applying both systems on the same administrative unit would be redundant.” Consequently, “Once a revised plan is in effect, the Regional Forester’s Sensitive Species list no longer applies to that unit.” The letter acknowledges that a biological evaluation must still be prepared for a revised forest plan. (Interestingly, the letter had only a planning file code, so it did not necessarily go to biologists.)

The Forest Service is thus implementing a substantial change in wildlife policy, with no prior public involvement, through individual forest plan revisions. This should mean that the forest planning process would include a clear explanation for the public that some species are no longer sensitive, and that no species will be evaluated for future projects (outside of any effects analysis NEPA might require). In particular, there needs to be a reasoned explanation of what facts have changed for those species where viability was a concern, but isn’t any more. The forest plan EIS must also consider the effects on sensitive species of removing the existing requirements to evaluate and maintain their viability at the project level (in comparison to the no-action alternative).

Instead, the Flathead has mostly hidden any information about sensitive species. Most existing sensitive species (17 animal species) are not designated as SCC (3 animal species), but there is no list of sensitive species in any of the Forest documents (though they can be identified from a list of all species included in an EIS appendix). There is no biological evaluation as required by the Forest Service Manual and the 2016 letter. There is a summary of “biological determinations” for sensitive species, but it is not listed among the planning documents on the website. It cites the forest plan EIS as the basis for its one- or two-sentence summaries. The EIS does not mention sensitive species at all, but it includes effects analysis for species that are/were sensitive.

While it is therefore possible to find some information on sensitive species, the Forest does not explain the significant implications of that information. It does not disclose the changes in scientific information that provide the rationale for declassifying them as at-risk species, and it does not explain how the sensitive species policy changes will affect future management of this Forest. These seem like fatal (arbitrary) omissions.

Voting for/against Wilderness

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Seriously.  Bonner County, Idaho is holding an advisory vote on whether its residents want the Scotchman Peaks area to be designated as Wilderness.  Sen. Jim Risch, R-Idaho, has indicated he will follow the advisory vote result.

One one hand, this is a good way to get information about policy preferences that opinion polls and candidate elections may not.  But really, how much weight should one county’s vote carry in making decisions about national forests?

Here’s a detailed fact-check developed to help voters.  Importantly, this area has been recommended for Wilderness in the Idaho Panhandle and Kootenai revised forest plans.  Watch for the results of the referendum on the May 15 primary ballot.

Oregon to look again at western forest habitat conservation plan

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The Oregon Department of Fish and Wildlife and the Oregon Department of Forestry have received a $750,000 federal grant to explore the possibility of a habitat conservation plan for state-owned forests west of the Cascades.  HCPs are authorized by §10 of ESA, and they allow the state to obtain an incidental take permit to kill or injure listed species if that happens in accordance with the plan.   The plan would consider species including the spotted owl and marbled murrelet and set guidelines for timber harvesting and recreational use.  A previous attempt to create a plan ended in 2008 without new guidelines being adopted. Without the HCP and permit, harming listed species is illegal for anyone.  “Harm” is defined to include significant habitat modification or degradation which “actually kills or injures fish or wildlife by significantly impairing essential behavioral patterns, including, breeding, spawning, rearing, migrating, feeding or sheltering” (50 C.F.R. § 222.102).

 

 

Making decisions to not mine national forests

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Here’s a role reversal for the Forest Service, who has recently been in the news more for making it easier to extract things from federal public lands.

New oil, gas and mineral exploration and development will be barred in the San Gabriel Mountains National Monument under a long-awaited management plan, released Thursday, governing the largest wilderness in Los Angeles County.

Of course the forest supervisor hinted that the main reason might be “there just aren’t any significant oil, gas, mineral or timber aspects to this monument.”

The U.S. Forest Service wants to ban new mining claims on about 30,000 acres of public land in the mountains north of Yellowstone National Park for 20 years, a move they say will hamper mine development and protect the environment.

Forest officials released a draft environmental assessment of the proposed withdrawal Thursday that considered potential environmental and economic impacts from future mine development. A 20-year ban wouldn’t affect existing mining claims but would likely limit future mining development.

The Forest Service’s environmental assessment will now be reviewed by the Department of the Interior, and Interior Secretary Ryan Zinke has the final say on whether the ban will be extended and for how long.

Zinke, who has opposed mining near the Paradise Valley, said in an emailed statement that he looks forward to “hearing from the community and seeing how we can work together to protect this area.”

Zinke has been accused of treating his native Montana different from other parts of the country.