Planning

Fracking on the Wayne protested

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This would be the first approval of fracking on this national forest, and it required a supplemental information review of the impacts of fracking, because that was not addressed in the 2006 forest plan.  I was curious about how the analysis would address the potential for earthquakes, based on what has been happening in Oklahoma.

The BLM’s analysis didn’t say much:  “Increased seismic activity has recently been a concern of the public following a number of low magnitude earthquakes centered on the Youngstown area. These earthquakes were within a mile of the Northstar 1 well, a Class II deep injection well…  In response to these seismic events and the possible linkage to the injection well the ODNR is pursuing reforms to the injection well program, including restrictions on injecting fluids in the Cambrian or Precambrian rock, requirements for testing and monitoring of pressures and injection rates and the installation of an automatic shutoff system, among other reforms (ODNR 2012).”

Talking about what the state might do is not exactly a disclosure of the environmental impacts.  The BLM concluded, “No additional analysis or protective measures are needed at the Forest Plan level, since the RFDS (Reasonably Foreseeable Development Scenario) discussed the common methods of waste disposal and this was used as the basis of the effects analysis conducted in the EIS.”

Some of the locals are not happy about the planned leases.

Do elk need trees? Maybe.

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This is an update to a September 12 post “Do elk need trees?”  The Forest punted the issue to its forest plan revision: http://helenair.com/news/natural-resources/forest-service-withdraws-controversial-big-game-standard/article_e5e22d8b-41f3-535f-94e6-58e098c86958.html

The first draft of the proposed Helena-Lewis and Clark revised forest plan punts elk security to project-level decision making. Here’s the draft guideline: “In order to influence elk distribution on NFS lands, management actions should not reduce the amount of elk security available during the archery and rifle hunting seasons over the long-term (generally ten or more years). Short-term reductions in elk security may occur when needed to achieve other resource management objectives. Elk security should be defined and applied at a scale that is informed by interagency recommendations if available, knowledge of the specific area, and the best available scientific information.”

The Forest Service is back to writing 1970s-era “plans” that left everything up to the local ranger. I foresee lots of litigation about the validity of these individual security interpretations on each project (instead of just determining if the project is consistent with the forest plan).

What’s Up with the Lack of a Link Between CO2 and Global Temperatures

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How does all of this affect current forest policy?

Here are two worthwhile reads regarding the role of forests in global warming / carbon sequestration. In addition, item “C)” raises and supports the question: ‘if there is no long term correlation between temperatures and CO2 then how can CO2 be the largest factor contributing to Global Warming?’. Everything we do is predicated on that one big “IF” yet, most refuse to acknowledge the lack of a direct correlation.

A) Pacific Northwest forests: Carbon sink or carbon source?

“Active forest management in dry forest ecosystems plays a critical role in reducing fuel loads, conserving functionality and biodiversity, and returning forests to a natural, resilient condition that is capable of responding to wildfire in a more socially desirable and ecologically beneficial way”

IMHO regardless of whatever role CO2 plays, healthy forests require, at a minimum, forest management as needed for the safety of society. The above quote simply illustrates that a “hands off” policy does not fit the needs of all forest ecosystems nor does it fit at all times within the need to maintain a specific forest ecosystem in order to support species dependent on the sustainability of a particular forest ecosystem niche. This in turn leads to the need for landscape level forest planning for all federal forest holdings.

B) Carbon storage in WA state forests is too small and too risky to play a serious role as a climate change mitigation tool

– 1) “the single biggest contributor to climate change is CO2 emissions from fossil fuel combustion. Indeed, global CO2 emissions from fossil fuel emissions in recent years have been roughly ten times higher than emissions from the next largest global source, land use change, including deforestation”
—> See “C” below about the “inconvenient truth” that there is no proven long term relationship between CO2 levels and global temperatures. This does not rule out the possibility that, as yet, undetermined interactions with other variables could have an impact on the role of CO2 in global warming.

– 2) “there are many excellent reasons to support planting trees in WA state … However, mitigating the threat of climate change is not among those reasons, based on the available science.”

– 3) “Thus, the management of forests to accumulate carbon must not delay or dilute the phasing-out fossil fuel use.”

—> agree – but not because of CO2 emissions:

—- a) Health – pollution dictates a reduction in the use of hydrocarbons and an increase in the use of alternative fuels to replace the extraction of below ground hydrocarbons and an increase in the use of sound, sustainable forest management to reduce the risk of Catastrophic fires.

—- b) Geologic ramifications of hydrocarbon extraction and hydraulic pumping include surface subsidence and earthquakes.

C) The Question as to the pertinence of CO2 to Global Warming

We must consider the inconvenient truth that ice cores from Greenland and Vostok, Russia show that over the last ~ 100,000 years, temps have been significantly higher than today by more than 2 degrees centigrade when CO2 was 2/3rds of what it is now. So is CO2 really the cause of global warming?

Greenland Data – Mankind has lived in significantly warmer climates than current temps over the last 11,000 years with CO2 levels at 2/3rds of the present levels (current CO2 levels corroborates their extrapolation of CO2 levels to the present).

Global Mean Temperature Anomaly – 1880 – Present – Note 2000 – 2016 only shows a 0.3 degree centigrade increase versus the Greenland and Vostok Data and corroborates their extrapolations to 2000.

Vostok Data – Mankind has lived in significantly warmer climates than current temps over the last 140,000 years.

 

So the question is: how does all of this affect current forest policy?

County job description for biologist: “help us combat the radical environmental influence”

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This job interview of a former Forest Service employee by Tuolumne County Supervisors didn’t go well.

Supervisor Evan Royce noted he wanted to be explicit with Boroski, trying to make sure they are on the same page, by saying, “I think we have experienced a lot of extreme environmental influence on public lands policy and in Tuolumne County 78% of our county is publically owned and that has a huge effect on our communities, and we fight very hard on this board to try to protect our communities and represent them in a way that will preserve our quality of life and prosperity…looking into the future, as we are about to adopt a general plan and we’re dealing with new forest plans, it’s very critical to us that if we are going to do business with you that you represent us in that way and you help us combat the radical environmental influence that you see from groups like Center for Biological Diversity. That’s what we want.

A revealing look at their approach to forest plan collaboration.

Fixing Water By Fixing (Managing) Forests

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Preserving Drinking Water is just one of the many reasons that Landscape Level Sound Sustainable Forest Management Is Needed everywhere including our National Forests. This doesn’t preclude hands off management nor does it preclude tailored management to provide for the desires of society when it fits within acceptable parameters as dictated by:

  • The safety of society and the assets of the populace.
  • Landscape level long range planning providing for forest succession in order to insure sustainable habitat niches for the species of interest which depend on the availability of a continuum over time of forest types at all stages of type succession within the landscape.

The following are quotes from various synopses of related articles:

A) Fixing Water By Fixing Forests

  1. “Moreover, healthy forests reduce the amount of funds cities need to treat their water to ensure it’s safe to drink. According to the report, seven US cities saved between $725,000 and $300 million in annual water treatment through investments in nature.“
  2. “Denver’s program, which involves a partnership with the US Forest Service, has resulted in nearly 40,000 acres treated to reduce wildfire risk and restore burned acres in critical watersheds. And the programs that followed in other cities are modeled after Denver’s and involve the same network of practitioners.”
  3. “Plus, the private sector appears to be stepping up – albeit slowly. Ecosystem Marketplace’s report from 2014 on watershed investments found companies such as Coca Cola and SAB Miller going the extra mile to protect their water supply by engaging with other users in a watershed and using it sustainably.”

B) U.S. Cities Go to the Source to Protect Drinking Water

  1. “In 2002, a catastrophic wildfire that burned 138,000 acres of forest made Denver’s drinking water supply run black with ash and soil. Cleanup of infrastructure damage, debris and erosion cost more than $25 million, while the fire-ravaged landscape caused increased flooding that wreaked havoc on water infrastructure and roads for years.“
  2. “To lessen wildfire risks, Denver Water and the U.S. Forest Service (USFS) started a watershed investment program to improve management of source water forests, together dedicating a total of $32 million to forest restoration over five years. Starting in 2011, Denver Water has invested in forest restoration and improved forest management to reduce the risk of wildfires, and USFS shares costs and implements those restoration activities.”

C) Forest Trends: “State of Watershed Investment 2014”

  1. “Last year, governments and companies invested $12.3 billion (B) in initiatives implementing nature-based solutions to sustain the world’s clean water supplies. According to a new report from Forest Trends’ Ecosystem Marketplace, this funding – which supports healthy watersheds that naturally filter water, absorb storm surge, and perform other critical functions – flowed to more than seven million households and restored and protected a total of 365 million hectares (ha) of land, an area larger than India. Up from $8.2B in investment tracked in 2011,”

D) Report: Protecting Drinking Water At Its Source

  1. THE SOURCE DOCUMENT = 140 pages of maps, graphs and details

Do elk need trees?

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For many years, it has been pretty much common knowledge, supported by science, that as the amount of hunting season open roads increases, there is more need for cover for elk to hide.  The Helena National forest plan (and others) have incorporated this relationship into standards for elk security.  (Full disclosure – I had something to do with this on the Helena 30 years ago.)   When the Helena National Forest developed its Divide travel plan, it found that it couldn’t meet its requirements for elk habitat because there were too many roads and not enough trees to provide security (trees in the area have been killed in large numbers by mountain pine beetles in recent years).  So it amended its forest plan elk standard to eliminate the role of tree cover in determining elk security (distance from roads replaces road density as a factor).

The rationale provided in the Record of Decision emphasizes the fact that elk have been doing well despite the fact that the existing forest plan standards have not been met in many places.

I have taken into account the fact that Montana Fish,Wildlife and Parks data indicate that elk populations in the Divide landscape are either at or near population objectives of the 2005 Montana Elk Plan and that elk management challenges are only partially related to access management according to that Plan. I have also taken into account the fact that, despite several miles of road closures, only one herd unit comes into compliance with standard 4a in the Travel Plan Decision. Given this, I have concluded that the existing standard 4a is not an accurate indicator of elk security and is insensitive to changing road densities. The methodology utilized for the new standard (based on the percentage of an elk herd unit occupied by elk security areas and/or intermittent refuge areas) indicates that overall elk security in the Divide landscape is adequate. This measure of security is sensitive to changes in open road configuration and will provide a way to determine where proposed management actions are effective or where management needs to improve to ensure adequate big game security. I believe the new standard will provide a more realistic means of guiding travel management and other future management activities in the Divide Travel Planning Area.

In essence, the Forest is using anecdotal evidence in place of long-established science (which the Forest now asserts is not relevant to this kind of forest).  Has the science just not caught up with reality, or is it possible that the high elk numbers are a result of unknown factors that, when they change, will render excessive road densities fatal to meeting elk harvest goals?  When the plan is revised under the 2012 planning rule (revision is ongoing), it will have to meet the requirement for using best available scientific information for its elk habitat management decisions.  (The amendment is using the 1982 planning process, but scientific integrity is still required.)

A court has been asked to weigh in on the amendment.

Interestingly, the lawsuit is by participants in a collaborative process.

Natural Range of Variation in the southern Sierra national forests

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So what did the Sierra, Sequoia and Inyo do to apply this planning rule requirement to terrestrial ecosystems?  I’ve just reviewed the draft plan and DEIS, and I don’t think I’ve got a good answer.  They don’t directly say what NRV is or how they determined it (at least in the places I’ve looked).

The Bio-Regional Assessment says this (p. 39):  “NRV only was not used because at this time conditions are far removed from them in terms of fire regime, and even a modest shift toward that level of resiliency would benefit ecological integrity and is more feasible in a short period of time. The planning rule specifically provides for using ecological integrity based on measures other than NRV where this is the case.”

This view is supported by the Planning Handbook (1909.12 FSH 12.14b) (but again, the Handbook does not appear to be supported by the Planning Rule): “In some situations, there is not enough information to understand the natural range of variation under past disturbance regimes for selected key ecosystem characteristics or the system is no longer capable of sustaining key ecosystem characteristics identified as common in the past based upon likely future environmental conditions. In these cases, the Interdisciplinary Team should establish an alternative ecological reference model for context for assessing for integrity by identifying the conditions that would sustain these key ecosystem characteristics.”  However no “alternative ecological reference model” was documented.

For terrestrial vegetation the Bio-Regional Assessment then apparently ignores itself (p. 98):  “Under the 2012 Planning Rule, “natural range of variability” is a key means for gauging ecological integrity. Ecosystem sustainability is more likely if ecosystems are within the bounds of natural variation, rather than targeting fixed conditions from some point in the past (Wiens et al. 2012, Safford et al. 2012). Safford et al. (2013a) compiled comprehensive, scientific literature reviews on natural range of variability, and these are the primary basis for the summary below.”  The summaries conclude whether ecosystems are within or outside of NRV, but they don’t say what NRV is.

The Sierra Assessment says this (p. 17):  “Comprehensive, scientific literature reviews on natural range of variability were compiled. The following is an overview. Consistent with trends across the entire assessment area, terrestrial ecosystems in the Sierra NF are predominantly outside the natural range of variability (NRV) for key indicators of ecological function, structure, and composition. First, nearly half (44 percent) of the area of the Sierra NF dominated by woody vegetation (or 76 percent of montane coniferous forests) is in a highly departed condition with respect to the historic fire return interval, burning at frequencies that are significantly longer than pre-settlement fire regimes (Safford and van de Water 2013). The Sierra NF has missed an average of three to four fire return intervals across all vegetation types dominated by trees or shrubs (Safford and van de Water 2013). Subalpine forests are the exception, burning at intervals that within one or two fire return intervals.”

The Bio-Regional Assessment describes fire history on p. 33, and the Sierra Assessment appears to use historic fire intervals as a reference, but what are the vegetation conditions that would produce the desired fire intervals (which would be the NRV for vegetation)?  I didn’t find a document that says what what vegetation NRV is or how it was determined, or even what the “key indicators” are.  The draft plan does have desired conditions for vegetation, and the DEIS says those are or are based on NRV.  The quickest way to get a feel for these DC=NRV is Tables 1-7 in the draft revised forest plan.

What is NRV for vegetation characteristics?  Are they based on the best available science? Did they properly use historic reference conditions?  What was the reference period? Did they consider climate change?  Are these sustainable desired conditions?  Do they comply with the requirement for ecological integrity?   Do they provide conditions needed for at-risk species? You’d think the answers to these important questions would be easier to find, but I’m out of time.  Maybe someone else can find some answers on the revision website somewhere.

Science consistency review on the southern Sierra national forests

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The draft revised Sierra, Sequoia and Inyo national forest plans include aggressive restoration programs across the forest, including logging areas of existing old forest structure to protect old forests and associated wildlife species.  The Forest Service has asked (unidentified) reviewers to look at the draft forest plans and draft EIS and address these questions in the first science consistency review conducted under the 2012 planning rule (it is an optional process under associated agency policy):

1. Has applicable and available scientific information been considered?

2. Is the scientific information interpreted reasonably and accurately?

3. Are the uncertainties associated with the scientific information acknowledged and documented?

4. Have the relevant management consequences, including risks and uncertainties, been identified and documented?

Here are some of the topics being addressed:

• Vegetation: Forest Resilience, Seral stage distribution, Effects of post-disturbance harvest, and Impacts on native vegetation.

• Fire and Fuels: Fuels management and community protection, Current fuel loading, Current and future wildfire trends, Effectiveness of treatments for fuel reduction.

• Wildlife and Habitat: Impacts to wildlife and their habitats, terrestrial and aquatic, Protection of old forest and associated species, Threatened and endangered species habitat requirements and availability, Species of Conservation Concern habitat requirements and availability.

• Climate Change: Current and projected trends, Effects on wildlife habitats and populations, Effects on carbon sequestration and carrying capacity

Given the debate on this blog surrounding these issues, the results should be interesting.  However there is no commitment here to any public release or discussion of the results.  The comment period on the draft EIS closes August 25th.  The results of this review were scheduled to be available in August.  “The technical experts (on the planning team) will review the report, consult and address any concerns from the review team, and incorporate any recommendations that would benefit the final EIS.” 

Given the debate on this blog surrounding these issues, the results should be interesting.  However there is no commitment here to any public release or discussion of the results.  The comment period on the draft EIS closes August 25th.  The results of this review where scheduled to be done in August.  “The technical experts (on the planning team) will review the report, consult and address any concerns from the review team, and incorporate any recommendations that would benefit the final EIS.”

Here is the revision website.

Timber numbers in revised forest plans

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If there is one thing the Forest Service should have learned from the last round of forest planning, it is that they should put realistic projections of timber volume in their forest plans.  These numbers are going to create expectations for the timber industry and Congress that will translate into pressure to produce that amount.  It’s when they try to plan timber programs and sales that are more intensive than are appropriate for other resources (i.e. wildlife) that they often end up in litigation.

Unfortunately, what I’ve seen in the few revised plans that have gotten this far looks like a continuing tendency to declare as many acres as possible to be suitable for timber management (defined as growing a regulated crop of trees), and to be evasive about how much future volumes would be reduced because of the presence of at-risk wildlife species (and the standards and guidelines required to provide their habitat).

In addition, there is a greater emphasis on the role of agency in budgets in determining the amount of timber that will be produced, to the point that forest plan alternatives may differ as much in their assumed budgets as they do in actual management direction.  This is despite the fact that forest plans do not make budget decisions.

I get the feeling that there is a lack of transparency developing about the real tradeoffs involved in national forest management so that the Forest Service can once again promise everything for everyone, and then give itself the most flexibility to find timber sales on the largest possible suitable land base.

Here is an article on how the Flathead National Forest is addressing these questions in its plan revision.