Planning

Humans sparked 84 percent of US wildfires, increased fire season over two decades

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How should we deal with the new math on forest fires?

If this article published in the February Proceedings of the National Academy of Sciences is not a fluke then it would seem to me that our expanding population dictates the need for more forest management not less. The less desireable alternative would be to severely restrict access to our federal forests. The main conclusion of the article is that humans sparked 84 percent of US wildfires and caused nearly half of the acreage lost to wildfire. This number excludes intentionally set controlled burns.

From the above, I would deduce that human initiated fires caused proportionally less acreage loss because they were closer to civilization and to forest access points and therefore closer to and more easily accessed by suppression resources. The fact that nearly half of the wildfire acres lost occur in these areas suggests that we would get more bang for our tax dollars if we increased and focused federal sustainable forest management around high traffic areas easily accessible to humans.

Knowing that humans who cause wildfires are, by definition, either careless or malicious, we might deduce that they are generally not inclined to put great effort into getting to their ignition set points. This would lead us to consider that human caused fires might prove to be in less difficult terrain areas with high human traffic. Fires like the Rim fire being the exception. That, if true, would suggest that forest management for risk reduction on these sites could be done at lower costs per acre than other less accessible forest acreage. Focusing forest management efforts on these high benefit to cost areas would have the biggest bang per tax dollar expended in order to lower the total cost of federal wildfire control. If my thinking is correct, this should play a large part in setting the priorities as to where we should: 1) apply controlled burns to reduce ground and other low fuels, 2) utilize commercial thinnings to reduce ladder and proximity fuels or 3) use commercial regeneration harvests to create greater variation in tree heights between stands in order to provide fire breaks for crown fires when appropriate for the site and species. The net effect would be positive for all species including endangered and threatened species. There would still be plenty of lightning caused wildfire, controlled burn hotspots/breakouts and a significantly reduced acreage of human caused fires to satisfy those who don’t mind national ashtrays. Reducing the number and size of human caused fires would also free resources to attack lightning fires earlier and harder when allowing the fire to burn was not an option.

Pertinent Quotes:

  1. “After analyzing two decades’ worth of U.S. government agency wildfire records spanning 1992-2012, the researchers found that human-ignited wildfires accounted for 84 percent of all wildfires, tripling the length of the average fire season and accounting for nearly half of the total acreage burned.” Italics added
  2. “”These findings do not discount the ongoing role of climate change, but instead suggest we should be most concerned about where it overlaps with human impact,” said Balch. “Climate change is making our fields, forests and grasslands drier and hotter for longer periods, creating a greater window of opportunity for human-related ignitions to start wildfires.”” Italics added
  3. “”Not all fire is bad, but humans are intentionally and unintentionally adding ignitions to the landscape in areas and seasons when natural ignitions are sparse,” … “We can’t easily control how dry fuels get, or lightning, but we do have some control over human started ignitions.””

Federal lands and transitional economies

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Headwaters Economics has released this update to a report discussed at length here last year:

 “Rural counties in the West with more federal lands performed better on average than their peers with less federal lands in four key economic measures.”

“This update of research from last year finds that from the early 1970s to the early 2010s, population, employment, and personal income on average all grew significantly faster—two times faster or more—in western rural counties with the highest share of federal lands compared to counties with the lowest share of federal lands. Per capita income growth was slightly higher in counties with more federal land.”

An article on “transitional communities” adds:

“Rural decline is a large and complex issue that appears to be accelerating. According to the Pew Charitable Trust, during the period between 1994–2010, 38.4 percent of U.S. rural counties lost population; since 2010, over two-thirds of rural counties lost population.  This level of decline has far-reaching national and international implications for food and energy production, tourism, and national culture and identity.”

Putting them together, it looks like public lands can be an important asset for minimizing or avoiding rural decline, if communities can get their act together to embrace this potential and plan for it.

“Particularly in declining communities where long-established residents remember the charm of life in simpler times, residents can have considerable resistance to change. This connection and preservation of the past, while a rural virtue, can impede its adaptation into the future. Resistance to any proposed solution that “hasn’t been done before” simply impedes innovation or positive transition.”

Custer-Gallatin wins salvage logging lawsuit

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On Feb. 6, Judge Molloy in the Montana District Court upheld the Custer National Forest’s  use of the categorical exclusion applicable to projects not exceeding 250 acres for the Whitetail Salvage Project.  In Native Ecosystems Council v. Weldon he found that even though it was the third project in the area affected by the 2012 Ash Creek Fire, the record showed that it was not reasonably foreseeable when the 2013 and 2015 projects were planned, and so the agency had not illegally “segmented” the projects to keep the acreages below the threshold for using the CE.

The court also found that effects on black-backed woodpeckers would be minimal because “the combined area of the Whitetail, Phoenix, and roadside hazard projects affect less than 2% of the highly suitable black-backed woodpecker habitat within the 90-kilometer cumulative effects area,” and “Abundant nesting and foraging habitat for black-backed woodpeckers will remain in the project area and cumulative effects area.”  This level of effects did not require an EA.  Plaintiffs had based much of their case on declarations they submitted by Chad Hanson.  However, the court refused to consider the declarations because documents that “challenge the underlying science and data used by the agency” can’t be submitted outside of the administrative record (meaning they should have been submitted to the agency prior to the project decision).  The judge found compliance with the 2012 Planning Rule requirement for using the best available scientific information for the woodpeckers (which is odd because the Planning Rule is not supposed to apply to projects).

The court also found that the project is consistent with the forest plan.  The project is in a wildlife management area, but the plan had selected mule deer for emphasis in this area, and it was proper under the forest plan for the Forest Service to balance the needs of black-backed woodpeckers and other species in determining to conduct the salvage harvest.

The beginning of state management of national forests

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A group of Western senators, including Sens. Jim Risch and Mike Crapo, both R-Idaho, have introduced a bill to allow states to implement their own conservation plans to protect sage grouse and their habitats, in lieu of federal management.

Congress would be allowing states to override the decisions by the Forest Service and BLM to amend their plans to protect sage grouse, which would amount to letting states take over planning for national forests to the extent that it can be tied to sage grouse in any way.

Resilient forests require change in “default” response to fire

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Here is the key conclusion in an article published by the Ecological Society of America (the article specifically addresses “dry forests”):

One of the most important and fundamental challenges to revising forest fire policy is the fact that agency organizations and decision making processes are not structured in ways to ensure that fire management is thoroughly considered in management decisions. There are insufficient bureaucratic or political incentives for agency leaders to manage for long-term forest resilience; thus, fire suppression continues to be the main management paradigm. Current resource-specific policies and procedures are so focused on individual concerns that they may be missing the fact that there are “endangered landscapes” that are threatened by changing climate and fire…. Without forest resilience, all other ecosystem components and values are not sustainable, at least over the long-term. It is therefore necessary to create incentives and agency structures that facilitate restoration of wildland fire and ecologically based fuel treatment to forest landscapes.

The authors have recognized the problem that fire planning is not well-integrated with planning for other resources on national forest lands.  A key recommendation is to, “Make forest resilience a stand-alone, top land management priority and connect it to managing long-term for endangered species.” It criticizes the continued emphasis on fire suppression, including the strategy of suppressing fires to protect at-risk species.   The article strangely omits any specific references to the 2012 Planning Rule’s ecological sustainability requirements, which I think has incorporated resilience, and its relationship to species diversity, as a policy about as well as we could expect. The question is what will forest plans actually do to avoid the alleged “tunnel vision.” The authors credit the southern Sierra revision forests as “pioneering some of these efforts.”

The authors do offer one recommendation that I think should receive more attention in the planning process: “analyze long-term impacts of continued suppression.” I would expand the recommendation to more clearly recognize that forest plans are the place where overall fire management strategies will be adopted, including identification of resources and areas deemed in need of protection from fire. Desired ecological conditions based in these needs must then be a consideration in fire management decisions, which must by law be consistent with the forest plan. Decisions in a forest plan about or affecting fire management, including those that promote fire suppression, will have effects on ecosystems that must be evaluated and disclosed during the planning process.

Court protects frog from Freemont-Winema National Forest grazing

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In a case with a long history, the Oregon district court enjoined grazing in a pasture on the Fremont-Winema National Forest to protect threatened Oregon spotted frogs and sensitive plant species. The frogs congregate in pools in late summer, and so do cattle.  The court found violations of both NFMA and ESA.

The court held that annual operating plans for grazing were arbitrary and capricious because they were based on a viability analysis that assumed planned levels of grazing instead of the actual trespass and unauthorized use that was occurring and causing damage. Thus the Forest Service couldn’t show that the AOIs met the requirement in the plan to manage for viable populations of these species.

It also remanded the biological opinion that the Fish and Wildlife Service had prepared on the allotment for the newly listed frog. The court found the no-jeopardy conclusion was not supported by the record because there was no scientific basis for a 35% forage utilization rate protecting the frog, it did not provide a rationale for using studies from other areas, and did not explain why it failed to consider non-lethal incidental take in the final BiOp when it had done so in the draft. The magistrate judge suggested the latter was “a strategic application of a measurement convention that results in less apparent OSF loss…”

A NEPA claim was dismissed because Congress has overridden the usual NEPA timing requirements for grazing allotment planning.

Forest planning for federal land ownership

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The Superior National Forest has received a notice of intent to sue over a land exchange that would allow development of a mine on the former national forest lands. The notice involves federally listed wolves and lynx. My question was whether the exchange is consistent with the forest plan as required by NFMA.

The Superior National Forest Plan contains very useful direction for land exchanges. It includes priorities for acquiring land (one of which is “Land needed for habitat for federally listed endangered, threatened, proposed, or candidate species or for Regional Forester Sensitive Species,” but that was not invoked by the ROD for this exchange). The plan also includes criteria for conveying land out of federal ownership, and it determines whether lands in each forest plan management area are suitable for conveyance.

The Record of Decision for this exchange first finds that a mine in this location would be inconsistent with the forest plan direction for the area. It then addresses the criteria for acquisition and conveyance (which are guidelines in the forest plan) and finds that the exchange would be consistent with the forest plan. The lands in the federal parcel to be conveyed are in the “General Forest and General Forest-Longer Rotation Management Areas” where conveyance is allowed. They also contain a lake, and there is a forest plan guideline to retain ownership of lakes. However the guideline is defined to allow deviation as long as the purpose of the guideline is met, and the exchange would produce a net gain in national forest water frontage.  The ROD also considers the mining project and land exchange in relation to Forest Plan direction related to larger areas on the landscape, including lynx analysis units.  (The ROD mistakenly cites the 2012 Planning Rule consistency provisions, which do not apply to plans developed under prior planning regulations, but the result should be the same.)

The plan components in the Superior Plan seem to have provided for a relatively smooth project planning process. Other forest plans I’ve seen provide much less guidance for land adjustments. It is important for a forest plan to recognize areas that provide important values by including plan components to retain and acquire such areas (which may then be supported by more detailed land adjustment planning). This may be especially important in planning for wildlife habitat connectivity in mixed ownerships.

National forest plans aid in removing bat from ESA list

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The U. S. Fish and Wildlife Service is proposing to remove the federally “endangered” status from the lesser long-nosed bat found in Arizona, New Mexico and Mexico.  Public lands play an important role in providing habitat, and federal land managers were among the “conservation partners anticipating that their 30-year recovery efforts have paid off.”

In the United States, most lesser long-nosed bat roosts and forage areas are managed by federal agencies (U.S. Forest Service, Bureau of Land Management, National Park Service and the Army’s Fort Huachuca), which have integrated the management of lesser long-nosed bat forage plants – agaves, and saguaro and organ pipe cacti – into their land use and resource management plans.

The potential for this kind of success story is why the new requirement for forest plans to “contribute to the recovery” of listed species needs to be taken seriously by forest planners.

Lawsuit to stop federal highway on national forest lands

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The Sierra Club filed the lawsuit to stop construction of the U.S. 70 Havelock bypass in North Carolina.  According to their attorneys, “The important thing here is that this part of the forest is one of the prime examples still of what used to be a very common landscape in the coastal plain, which is the longleaf pine savannas, so there are parts of the forest that would be destroyed with the proposed bypass and that have intact, 100-year-old longleaf pine savannas that have good ground cover and are in good condition and that provide habitat for species like the red-cockaded woodpecker.”  They argue that there were feasible alternatives that weren’t considered.

The defendant is apparently the Federal Highway Administration, and the Forest Service isn’t mentioned at all.  There is a different set of laws governing federal highway projects, but they don’t exempt the FHA from NFMA’s requirement that “instruments for use and occupancy of National Forest System lands shall be consistent with the land management plans.”  The Croatan forest plan (2002) actually mentions this bypass proposal as an example of “requests for permits that serve a public benefit.”

There was no reference to this project on the Croatan website, but the FHA ROD discusses six issues raised by plaintiffs regarding consistency with the forest plan, finding them all to be without merit.  It talks about Forest Service participation in the project planning process and off-site mitigation elements, neither of which directly address the question of what the forest plan requirements for this area are.  It did mention that “some portions of the easement that would be transferred to NCDOT for the bypass are designated black bear sanctuary.”  How would a four-lane expressway be consistent with that?  There is something wrong with this process if it does not require the Forest Service to directly address the NFMA consistency requirement for highway permits.

IN SEARCH OF COMMON GROUND

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It seems like an exercise in futility for the “New Century of Forest Planning” group to be discussing and cussing forest planning &/ policy when we haven’t even agreed to the scientific fundamentals that serve as the cornerstone and foundation for any such discussions.

Below, I have developed a tentative outline of the high level fundamentals which any Forest Plan or Policy must incorporate in order to have a reasonable chance of meeting the desired goals. Until we can come up with a version of these “Forestry Fundamentals” that we generally agree to, we are pushing on a rope and wasting each other’s time unless our objective here is simply to snap our suspenders and vent on each other.

In your comments, please note the outline Item that you are responding to. Maybe we can revise my initial effort and come to some common ground. In doing so we would perform a service and make a step forward that would be useful outside of this circle instead of just chasing our tails. Coming to such an agreement would be a step towards developing a priority hierarchy and eliminating the internal conflicts which make current federal forest policy and law ambiguous and self-contradictory. Until we reach common ground, the current obviously unworkable policies will continue to doom our forests to poor health and consequentially increase the risk of catastrophic loss of those forests and the species that depend on them for survival.

– FORESTRY FUNDAMENTALS – 1st Draft 12/15/16

ESTABLISHED SCIENCE WHICH MUST BE INCORPORATED IN PLANNING FOR

THE SUSTAINABILITY OF FOREST DEPENDENT SPECIES

I) The Fundamental Laws of Forest Science which have been repeatedly validated over time, location, and species. They include:
— A) plant physiology dictating the impact of competition on plant health,
— B) fire science dictating the physics of ignition and spread of fire and
— C) insects and pathogens and their propensity to target based on proximity and their probability of success being inversely proportional to the health of the target.

— D) Species suitability for a specific site is based on the interaction between the following items, those listed above and others not mentioned:

— — 1) hydrology, the underlying geology and availability of nutrients in the soil.

— — 2) latitude, longitude, elevation, aspect and adjacent geography.

— — 3) weather including local &/ global pattern changes.

 

II) The Fundamental Laws controlling the success of endangered, threatened and other species dependent on niche forest types (ecosystems):

— A) Nesting habitat availability.

— B) Foraging habitat availability.

— C) Competition management.

— D) Sustainability depends on maintaining a fairly uniform continuum of the necessary niches which, in turn, requires a balanced mix of age classes within each forest type to avoid species extinguishing gaps.

— E) Risk of catastrophic loss must be reduced where possible in order to minimize the chance of creating species extinguishing gaps in the stages of succession.

 

III) The role of Economics:

— A) Growing existing markets and developing new markets in order to provide revenue to more efficiently maintain healthy forests and thence their dependent species.

— B) Wise investment in the resources necessary to accomplish the goals.

— C) Efficient allocation of existing resources.

 

IV) The role of Forest Management:

— A) Convert the desires/goals of the controlling parties into objectives and thence into the actionable plans necessary to achieve the desired objectives.

— B) Properly execute the plans in accordance with the intent of: governing laws/regulations and best management practices considering any economies.

— C) Acquire independent third party audits and make adjustments in management practices where dictated in order to provide continuous improvement in the means used to achieve goals.

— D) Adjust plans as required by changes: in the goals, as required by the forces of nature and as indicated by on the ground results.

— E) Use GIS software to maintain the spatial and associated temporal data necessary for Scheduling software to find and project feasible alternatives and recommend the “best” alternative to meet the goals set by the controlling parties.

What did I miss, what is wrong, what is right, what would improve this list of Forest Fundamentals?