Excellent article about Cottonwood by Joshua Murdock of the Missoulian. with a flowchart! Very comprehensive.
Planning
Court vacates Colville NF project and parts of its revised forest plan
This was going to be a “featured” case in a litigation summary post, but it turned out to be long enough for its own post. Besides, forest plan litigation is rare, especially Forest Service losses, and this case covers a number of NFMA and NEPA issues that are frequent topics on this blog. (And, full disclosure, I had something to do with it.)
- Court decision in Kettle Range Conservation Group v. U. S. Forest Service (E.D. Wash): Sanpoil clean
On the first day of summer, the district court vacated the decision for the Sanpoil Project on the Colville National Forest, and also vacated the relevant portions of the 2019 revised forest plan. The portions of the revised plan at issue replaced the Eastside Screens 21-inch diameter limit with a guideline to protect large trees, but included many exceptions. It also did not designate a minimum amount of old growth habitat to retain.
The court held that, “the agency failed to explain how the 2019 Forest Plan maintains the viability of old-growth-dependent species.” More specifically, “the agency erred by failing to demonstrate that its data and methodology reliably and accurately supported its conclusions about the viability of old-growth dependent species under each planning alternative, and depicted the amount and quality of habitat.” (Note that the Colville plan was revised under the 1982 planning regulations, which had somewhat different language describing wildlife viability. However, this court did not rule on substantive compliance with the NFMA requirement, but rather found a failure to demonstrate compliance due to an inadequate administrative record based on the APA.)
The Forest stated that the selected alternative, Alternative P, provided a “high” viability outcome for these species and that the no-action alternative would not improve viability outcomes. However, in the EIS, the data showed that “the No Action alternative provides more habitat than the selected alternative for three of the surrogate species,” and “creates the most late structure of any alternative.” The Forest relied instead on an appendix in an associated Wildlife Report that employed a Bayesian belief model to assign letter grades to viability, which supported the rationale for selecting Alternative P. The court explained:
Neither the EIS nor the Wildlife Report describe how the agency came to these scores for each species and action alternative. The agency did not define its methodology for assessing the letter grades, such as what factors it considered and the weight they were given. The grades assigned to each planning alternative lack explanation… the agency acted arbitrarily and capriciously when it offered explanations that ran counter to the evidence before the agency and failed to satisfy the requirements of the NFMA.
The court also found that the Forest failed to discuss the amount and quality of habitat and population trends (a requirement of the 1982 regulations).
The court also held that the forest plan EIS violated NEPA by failing to meaningfully address the original Eastside Screens Report. The Forest simply argued that it needed more flexibility to achieve the desired conditions, including avoiding numerous site-specific amendments to deviate from the diameter limit in the Eastside Screens. The Forest failed to include the original Eastside Screens Report in its administrative record, and did not adequately respond to public comments about the Eastside Screens. The court stated:
Its absence demonstrates that the agency failed consider the scientific rationale for adopting the 21-inch rule before deciding to discard it. The agency did not respond to viewpoints that directly challenged the scientific basis upon which the final EIS rests… In doing so, the agency violated the NEPA. The absence of the Eastside Screens Report also demonstrates that the agency did not consider an important aspect of the issue, as required by the APA.
… the agency did not consider negative impacts, if any, from (1) elimination of the 21-inch rule or (2) retention of the exceptions in the new guideline. The NEPA requires the agency to discuss and not improperly minimize negative effects of a proposed action… In this case, the EIS did not assess how often the new guideline’s exceptions will be invoked and how the exceptions may impact the agency’s conclusions about the environmental effects and species viability.”
The Sanpoil Project also violated NEPA. The EA simply assumed that the new forest plan guideline would protect old-growth trees. The court held:
This conclusion was contrary to the evidence. The Sanpoil Project EA did not specify the frequency of which the new guideline’s exceptions would be invoked, despite the 2019 Forest Plan’s stated objective of preserving old-growth trees. The agency is not required to catalogue specific trees that will be removed, but in this case, the agency was required to provide site-specific details at the project planning stage to provide a sufficient picture of the Sanpoil Project’s cumulative effects… Without sufficiently specific information about site impacts, the Sanpoil Project’s impact to old-growth trees and their dependent species is speculative.”
(This overlaps to some degree the issues surrounding “condition-based NEPA.” The court even cites the Forest Service Handbook: “If the Agency does not know where or when an activity will occur or if it will occur at all[,] then the effects of that action cannot be meaningfully evaluated.” It also is difficult to demonstrate consistency with the forest plan if the project documentation does not provide information about how a project is meeting forest plan requirements.)
The project also violated NEPA and NFMA by conducting “cursory analysis” of the effects of the project on gray wolves, wolverine, sensitive bat species, northern goshawk, and the western bumblebee. Finally, the court found that NEPA requires an EIS for the Sanpoil Project because it “creates uncertain risks to old-growth forests and the wildlife dependent on them, and “sets a precedent for future actions that utilize the new old-growth guideline, each of which may be individually insignificant, but create a cumulatively significant impact when applying the new guideline.” Moreover, the lack of quantified or detailed information about the Sanpoil Project’s impacts in this respect “is also highly controversial due to the same questions about its size and nature and effect of the action on old-growth dependent species.”
The court found that this “case” was ripe for judicial review “when the agency issued RODs for both agency actions” “because the Sanpoil Project is a site-specific action governed by the 2019 Forest Plan.” The plaintiff had argued that forest plan decision challenge was ripe because it dealt with a forest-wide viability requirement rather than timber sale requirements found not ripe by the Supreme Court in its Ohio Forestry decision. However, the plaintiff also argued that ripeness of forest plan issues could be based on this project decision implementing the plan. It is not completely clear which rationale the court is employing. The court also found that the plaintiff had exhausted administrative remedies by identifying large, old trees, wildlife viability and the Eastside Screens “thoroughly and consistently during the public comment process.”
Friday the 9th on the Flathead
On June 9th, the 9th Circuit Court of Appeals dismissed an appeal in a lawsuit against its revised forest plan. The appeal involved questions about ESA consultation on the plan’s effects on grizzly bears, and the proper environmental baseline for the amount of roads used in the consultation process. After the district court opinion found flaws in the analysis conducted for consultation, the Forest reinitiated consultation with the Fish and Wildlife Service, which has now been completed. The 9th Circuit held that the new biological opinion made that issue moot. (A new lawsuit was filed against the new biological opinion, discussed here.)
However, Kurt Steele won’t be overseeing the Flathead Forest Management Plan. As of Friday, USFS Region 1 press officer Dan Hottle said Steele “was offered and accepted” a new post as deputy director at the regional office that involves “environmental planning,” according to the Flathead Beacon. It is unknown who will be Steele’s replacement.
This was also announced on June 9th, but I assume there is no connection between the Flathead Forest Plan and Steele’s move to the regional office forest planning staff (he wasn’t hired by the Flathead until after the plan was done). However, there may be a connection to his work on Holland Lake (discussed most recently here), since it’s hard to imagine that a forest supervisor would consider a deputy position on a regional office planning staff to be a great career move. That connection is denied by the Forest Service.
“There’s no correlation with this (personnel change) and Holland Lake,” Hottle said. However, he said he did not know whether Steele had initiated applying for the position or if the Forest Service offered it to him first. Hottle characterized the change in position as a “lateral move” with a salary that should stay the same.
This is interesting to me because the regional planning staff didn’t have a deputy director position when I left, and the current agency directory does not show that there is such a position to apply for. It’s not unheard of for the agency to create a position to place someone where they will be out of the way, and I’ve observed that planning staffs tend to be seen as places to put people who need putting (and of course, anyone can be a planner). Or maybe there is some kind of vindication going on because he will nominally be overseeing the revision of the Lolo National Forest Plan, and the Lolo is where a lot of the same people who oppose the Holland Lake development like to hang out.
The Forest Service role in fire adapting communities
It’s rare when I run across reporting about the Forest Service taking an official position on development of private land. Yet the importance of doing so is increasing in a world where more frequent and dangerous wildfires on national forests are affecting human developments. Here is one of those rare examples.
Grand Targhee Resort in Idaho has proposed adding cabins to its base area of private land, 120 acres surrounded by the Caribou-Targhee National Forest. This has been controversial, in particular because of concerns about limited access and how the Resort would plan for and respond to wildfire. The Forest Service has expressed concerns to the county commissioners about the ability to fight wildfires there.
Asked where Targhee fell in his list of wildfire priorities, Jay Pence, Teton Basin District Ranger for the Caribou-Targhee National Forest, said the resort was “towards the upper end.” “It’s always been that way,” Pence told the Jackson Hole Daily. But, he added, “the new development just adds additional people and additional values at risk.”
To mitigate wildfire risk, Pence asked commissioners to require a few things of Targhee. It would be “helpful,” Pence said, to have “a clear and agreed-to emergency plan for the entire resort” as well as a “loop road” within the resort, and more information about “how the entire development is envisioned to be constructed.” He also asked for fuels reduction work to be done while the cabins are built. And Pence asked commissioners to “insist” on a 300-foot setback from the U.S. Forest Service’s property line, hoping to prevent the forest from having to clear vegetation on public land to protect the cabins from fire.
But Pence said any fuels reduction done on the forest will require separate permitting under the National Environmental Policy Act. It would likely require a separate analysis from the ongoing analysis of Targhee’s request to expand its boundaries.
This commercial development of an inholding is kind of an extreme case, but the kinds of things the Forest Service is asking for should be considered in any WUI development. The National Cohesive Wildland Fire Management Strategy identifies “fire adapted communities as one of three goals, and “Protecting homes, communities, and other values at risk” as one of the four “broad challenges. The Forest Service has a “Fire Adapted Communities Program,” which includes “tools of fire adaptation” like, “Wildland urban interface codes and ordinances can define best practices for construction and location of new development in a WUI community …”
I would like to know if there is also any agency guidance for Forest Service land managers for how to promote achieving these desired outcomes. They need to be able to effectively participate in local planning for private land developments that will become “values at risk” for national forest fire management. This ranger is doing the right thing, but is there any agency leadership that would encourage more of it?
Are large, eastside grand firs friend or foe?
A new release from a some of our favorite authors about the proposed amendment to the Oregon and Washington Eastside Screens forest plan requirements – the “21-inch rule.” The primary focus is summarized here (and there is a link to the research paper):
“Interest is growing in policy opportunities that align biodiversity conservation and recovery with climate change mitigation and adaptation priorities. The authors conclude that “21-inch rule” provides an excellent example of such a policy initiated for wildlife and habitat protection that has also provided significant climate mitigation values across extensive forests of the PNW Region.”
Until I saw this photo, I had imagined an army of evil grand fir trees sneaking up under pines and larch, and stealing their water and threatening to burn them up. They seem to be the Forest Service’s Enemy #1 these days in eastern Oregon and Washington. So dangerous, in fact, that the agency undertook another dreaded forest plan amendment process to give the agency more weapons to fight off this scourge.
This paper portrays them in a much different light, as providing benefits to both carbon storage and resilience to fire (along with their original wildlife protection benefits targeted by the original Eastside Screens amendment) – and NOT posing a substantial barrier to fuel treatment.
“The key rationale for amending the 21-inch rule is that increased cutting of large-diameter fir trees (≥53 cm DBH and <150 years) is needed to facilitate the conservation and recruitment of early-seral, shade-intolerant old ponderosa pine (Pinus ponderosa) and western larch (Larix occidentalis) by reducing competition from shade-tolerant large grand fir (Abies grandis) (USDA, 2021).
This represents a major shift in management of large trees across the region, highlighting escalating tradeoffs between goals for carbon sequestration to mitigate climate change, and efforts to increase the pace, scale, and intensity of cutting across national forest lands. The potential impacts of removal of large grand fir on wildfire are unclear, although a trait-based approach to assess fire resistance found that the grand fir forest type had the second highest fire resistance score, and one of the lowest fire severity values among forest types of the Inland Northwest USA (Moris et al., 2022).
Large ponderosa pine co-mingle with large grand fir about 14% of the time (259 plots), leaving 86% of plots with large ponderosa pine without large grand fir (1616 plots). Similarly, large western larch co-mingle with large grand fir about 56% of the time. Large ponderosa pine and grand fir are found together on only 8% of all plots in the region, while large larch and grand fir are found together on only 4% of all plots in the region. (I added the emphasis for clarity.)
Enhancing forest resilience does not necessitate widespread cutting of any large-diameter tree species. Favoring early-seral species can be achieved with a focus on smaller trees and restoring surface fire, while retaining the existing large tree population.”
If nothing else, these conclusions clearly refute the Forest Service argument that reducing fire risk is “impossible” without logging the few (but important) large grand fir trees.
Nantahala-Pisgah forest plan revision – done
The Nantahala-Pisgah National Forest has completed revising its forest plan. The final plan was released on February 16 and implementation began last week. The revision website is here, and the response to the objections is here.
Said Sam Evans, leader of the National Forests and Parks Program for the Southern Environmental Law Center (and Smokey Wire contributor) “A big disappointment for me here at the end of the process is that it is more of the same. It’s going to drive a wedge between stakeholders that had found consensus.” “We can sue over the plan,” Evans said. “We can oppose projects as they come up under the new plan. I would say the only thing that’s not an option for us is letting this plan roll out and be implemented in a way that continues to degrade those same resources — unroaded areas, healthy, intact forests like the state Natural Heritage Areas and existing old growth.” The ”stakeholders” would be the Nantahala-Pisgah Forest Partnership of 20 interested organizations. This article continues to discuss these disappointments in more detail (though apparently not all of the stakeholders are unhappy).
The Partnership wanted to see various tier objectives tied together so that, for instance, the Forest Service couldn’t move on to Tier 2 timber harvest goals without first meeting Tier 1 goals in other areas, such as invasive species management and watershed protection. Additionally, the Partnership said, the plan should require ecological restoration treatments to be paired with any commercial timber harvest occurring on the forest landscape.
The group was also concerned that 54,000 acres of state Natural Heritage Natural Areas were placed in management areas open to commercial logging and road building, and that the plan didn’t allow for protection of old growth patches found during timber projects. The group wanted to see a “cap and trade” approach to the 265,000-acre Old Growth Network identified in the plan, so that lower-quality patches in the network could be swapped out for higher-quality patches encountered during projects.
According to Evans, only 30,000 acres of the 265,000 acres is at the minimum age level to qualify as old growth, and the remainder is middle-aged forest of 60-100 years. Meanwhile, known old growth stands were not included in the network. The Forest Service does not have a figure for the number of acres in the network that currently qualify as old growth. “We’re trading young forest that maybe will become older one day for existing old growth now,” Evans said, “and that isn’t a good trade for the species that live in old growth forests and don’t move around.”
The forest supervisor had an interesting response to this old growth issue: “Because of the complexity of the forest, there’s always going to be places that we might find a particular stand that is in that older forest type, and we can say, ‘You know what, that’s an area that’s special, and that we want to favor for those types, and that’s part of a larger project that’s holistic in a given area,’” he said. They CAN say that project-by-project, but by allowing that flexibility, does the PLAN comply with the requirements for it to affirmatively provide habitat for at-risk species?
There is also disagreement about whether it does what it should to address climate change. It apparently pits carbon storage (mitigation) vs “resilience” (adaptation). Shouldn’t carbon storage projections include any additional risk of having less “resilient” forests? There was a recent question on this blog about how forest plans are dealing with climate change. This article (which also highlights the criticisms of the plan) lists the Forest Service’s seven main goals for “dealing with the impacts of climate change” (which are about adaptation rather than mitigation)
- “Where there are species at risk that are susceptible to the effects of climate change, promote activities that support suitable habitat enhancement.
- “Consider and address future climate and potential species range shifts when planning restoration projects, facilitating species migration and adaptation when possible.
- “Monitor for new invasive species moving into areas where they were traditionally not found, especially in high-elevation communities. Utilize the monitoring information to assess threats and prioritize treating highly invasive infestations.
- “Restore native vegetation in streamside zones to help moderate changes in water temperature and stream flow and enhance habitat.
- “Anticipate and plan for changes in natural disturbance patterns.
- “Prepare for intense storms and fluctuations in base flow using methods that maintain forest health and diversity, including controlling soil erosion, relocating high risk roads and trails, and constructing appropriately sized culverts and stream crossings while retaining stream connectivity.
- “To maintain genetic resiliency, consider locally adapted genotypes for use in restoration projects.”
What’s next? Will Harlan, a scientist for the Center for Biological Diversity said (here) communities still not satisfied with the decision will “use every tool possible” including “public engagement, community involvement (and) litigation” to push back against what the plan could do to forests.
However, the Eastern Band of Cherokee Indians was “pleased.”
New CEQ Guidance on Habitat Connectivity
On March 21, the Council on Environmental Quality provided “Guidance for Federal Departments and Agencies on Ecological Connectivity and Wildlife Corridors” to federal agencies. The Forest Service was a member of the working group that developed this guidance.
“Connectivity is the degree to which landscapes, waterscapes, and seascapes allow species to move freely and ecological processes to function unimpeded. Corridors are distinct components of a landscape, waterscape, or seascape that provide connectivity. Corridors have policy relevance because they facilitate movement of species between blocks of intact habitat, notably during seasonal migrations or in response to changing conditions… Increasing connectivity is one of the most frequently recommended climate adaptation strategies for biodiversity management.”
“To the maximum extent practicable, Federal agencies are expected to advance the objectives of this guidance by developing policies, through regulations, guidance, or other means, to consider how to conserve, enhance, protect, and restore corridors and connectivity during planning and decision-making, and to encourage collaborative processes across management and ownership boundaries. Any existing corridor and connectivity policies or related policies should be updated as needed to align with the objectives in this guidance. Federal agencies should have new or updated policies ready to implement by the first quarter of 2024 and make their policies publicly available. Federal agencies should also actively identify and prioritize actions that advance the objectives set forth in this guidance.”
“Federal agencies should not limit engagement in restoration activities only to circumstances when restoration serves as a mitigation strategy to compensate for adverse impacts from projects or actions. Instead, Federal agencies should consider where there are opportunities in their programs and policies to carry out restoration with the objective of promoting greater connectivity.”
One of the specific “focal areas” listed in the memo is “forest and rangeland planning and management.” “Connectivity and corridors should factor into high-level planning and decision-making at Federal agencies as well as into individual decisions that lead to well-sited and planned projects.” “In carrying out large-scale planning required by statutory mandates (citing NFMA and FLPMA) Federal agencies should consider updating inventories of Federal resources under their associated management plans to assess connectivity and corridors.”
The Forest Service 2012 Planning Rule already includes language requiring that forest plans address connectivity as part of its wildlife viability considerations. I had something to do with that, but I was regularly disappointed in the agency’s unwillingness to “think outside the green lines” about how species occurring on a national forest depend on connectivity across other land ownerships, so I’m always happy to see someone try to make them do that:
“Ecological processes and wildlife movement are not limited by jurisdictional boundaries. Therefore, Federal agencies should seek active collaboration and coordination with other Federal agencies, Tribes, States, territorial, and local governments, as well as stakeholders to facilitate landscape, waterscape, and seascape-scale connectivity planning and management, and consider appropriate collaboration with other nations. Prioritization and strategic alignment of connectivity efforts across partners improves the effectiveness of each entity’s activities and enables larger-scale conservation, enhancement, protection, or restoration to occur.”
“Federal agencies with investments on Federal lands or in Federal waters adjacent to designated areas that may have conservation outcomes (e.g., National Park System units, national monuments, national forests and grasslands, national marine sanctuaries, national estuarine research reserves, wilderness areas, national wildlife refuges, etc.) should explore collaborative opportunities to enhance connectivity across jurisdictional boundaries.”
These kinds of initiatives seem to come and go, but we should at least expect to see the land management agencies tell us what they think under this administration by next year. If anyone happens to notice, let us know!
The “Climate in Forest Plans” Roundup- What Are Your Observations and Why?
I thought this was funny, it’s from Guido Núñez-Mujica of The Breakthrough Institute and used with his permission. No, I don’t addressing climate mitigation in forest plans is like this, except we could substitute emissions from recreation, wildfire, grazing, timber and so on..not to speak of what we used to call “sustainable operations” or the workings of the agency itself.
Now it’s time to share your examples of climate in forest plans.. I posted on some possible ways to look at “how well” forest plans deal with climate change last week. As I said before, one of my contacts had been asked “what forest plans do you consider to have handled climate change best”. So this thread is an opportunity for anyone to weigh in on the forest plans you have worked with, and what you think.
How does addressing climate change make a difference in desired conditions (maybe resilience, but I think many folks are managing for that anyway via projects), standards and guidelines, land allocation and other plan-level decisions?
That’s precisely what we should be able to see in some of the new forest plans. So please let us know what you think!
*************
In a research paper to be discussed later this week, the authors state:
Forest planning is a relatively obscure and byzantine policy process for most ordinary citizens. In contrast, it is a high priority to interest groups because of the ability to impact long-term outcomes on the national forests.
I will be interesting to see who has actually read forest plans (and EIS’s) among us. For one thing, they are so very complex (obscure and byzantine, as the authors said). For another thing, an individual’s opinion probably does not matter much, so in the weighting of spending of time, reading plans may not rank highly. There seem to be no powerful interest groups representing “general interest” or “recreation tolerance” or even “resilient ecosystems”- the latter concept seems to get broken down into the same old “manage vegetation or not”; even when there isn’t a timber industry to speak of. So I think it will be interesting to see who among us has taken the time to read what’s in them and why.
Finally, for those who are following individual forest plans, it would also be interesting to track whether and how climate change comes up in forest plan-related litigation. And whether “integrity” and “resilience” are ever in tension- seems like they might be.
Why People Disagree About (How Forest Plans Deal With) Climate Change. II. Some Philosophical Orientations and The Problem of Climate Everythingism
There are many AGW-Climate Change philosophical differences that are out there that may influence forest planning. I’m sure there are more that readers can add. I’ll use “you” to mean a forest or other planning entity.
1. How do you handle uncertainties about future climates? How explicit are you about them? How do you treat model outputs, or like Denver Water, do you use a pretty broad uncertainty envelope? How do you combine uncertainties about climate with uncertainties about other things.. population, recreation use, economics? Do you use scenarios and involve the public, or what is your approach to discussing uncertainties with the public? (this was discussed more generally in the previous post).
2. I give adaptive management its own category here because it is something that the FS (and BLM?) were supposed to be doing, but may have had trouble. At least at the level that some have talked about it (extremely formalized, scientist design, and so on). Perhaps at the District human being observational level or the specialist level (say fuels or wildlife or reforestation) it is working just fine using old-fangled communication- person to person and through professional groups. But maybe different “adaptive management” aficionados simply mean different things by their use of the term. How is adaptive management currently working on the forest, and how is the plan going to help- does it have a role; what are the requirements of the 2012 Rule on this, and how are they being applied?
3. Climate mitigation. Seems like we mostly hear about SOSO (same old same old) with regard to mitigation. ENGOs who didn’t want to cut trees now say it’s bad for carbon. ENGO’s who don’t like cattle grazing say it’s bad for methane. Less fossil fuel leasing seems like it would be mitigation, until you analyze it and discover that the sources simply move to private land or offshore. And what about recreation? Most recreators, myself included, use vehicles to access NF lands that are powered by fossil fuels directly or via electrical sources. What are the key issues in the plan vis a vis mitigation?
4. There’s also a bit of meta-thinking that I call Climate Everythingism.
To some, climate now the mantle for everything- other environmental issues, all natural hazards, as we have seen with EPA, CEQ, and many media outlets now have environment as a subset of climate. Check out the WaPo main page where Environment is a subset of Climate.
Others think that climate another source of uncertainty, like population and economics, which all need to be addressed through planning- and it is the role of each discipline to learn about what CC means for their resource.
Most Everythingists I’ve met consider themselves to be “climate experts” (whether I would consider them that or not). But for every Forest Service Everythingist who thinks we need climate specialists advising on each project, there is someone outside the Forest Service who thinks the agency itself can be done away with and replaced by a Climate Adaptation Agency staffed with.. climate experts.
I often find what is least talked about in these discussions are the disciplinary and authority implications of Everythingism, as well as moving the locus of knowledge and authority away from experts on the ground and the people most affected. At its worst Everythingism could be a systemic antagonist to the idea of empowering disadvantaged communities. I find Everythingists not usually involved with forest planning, but their ideas are in the atmosphere, and may well be among partners and the public, so I think it’s something to be aware of.
Addition: I just ran a across a job ad for a Climate Editor at Vox Media on Linked-In. Under “About the Job” it says:
Climate change is the most important story in the world. It’s no longer a looming consequence in the far-off future, but rather a present challenge that’s forcing all of us to adapt. Wildlife and natural habitats are disappearing, driving a biodiversity crisis.
If you’re an Everythingist, I suppose biodiversity is a subset of climate. It’s a mantle that you can place over everything, except perhaps non-native invasive species. But we don’t hear about the latter much anymore.
Please add your own philosophical differences that may affect the approach to climate change in forest plans.
Why People Disagree About (How Forest Plans) Deal With Climate Change. I. Introduction and How Broad are the Scenarios?
This is the first of a series of posts that lay out a framework for thinking about how forest plans address climate change. Some people are curious as to what we might think are the forest plans that have handled climate change the best, and so we’ll have a post later that will ask that question.
But I think we need to be upfront on where we stand on different approaches or philosophies for how AGW-CC (I’ll just call it CC for the rest of these posts) should be handled. It seems to me that there are two components to this question: first, do you agree with the approach of how they handled it, and second, given their approach, how well do you think they handled it?
I hope by consciously thinking about how diverse approaches might work, we might be able to contemplate the true diversity of approaches in addition to what is in current forest plans.
One of the things I did around 2010-ish was help forests in Region 2 develop their “climate action plans”, I think they were called. I was the climate change coordinator for the Region, so I was on some of the conference calls. The interesting thing about this effort was that it was not tied to NFMA planning, but more about “are there things we are doing we would do differently if we considered climate change?”. In many cases, they already were considering CC and the plan simply documented how they were thinking about it.
Our Regional view was to use generic scenarios based on down-scaled models (I mean really generalized, like “hotter and drier” generalized) and to use a “no regrets” strategy.
Just now I tried to find a definition for “no regrets’ strategies and discovered a plethora of literature with not-exactly-identical definitions.
But I liked this one from Law Insider (!)
no regrets means taking climate-related decisions or actions and/or investments that can be justified from economic, social, and environmental perspectives whether or not a specific climate threat materializes in the future, and this is achieved by building resilience to different hazards/risks (Heltberg, Siegel, Jorgensen, 2009; Siegel, 2011).
Well, Region 2, if I can generalize, has always been a relatively poor Region and employees are pretty pragmatic and don’t tend to overthink things.
So we ran through some of this stuff with one forest (may have been the Nebraska) and the conversation went something like this:
“So we need to protect our riparian areas because it might get hotter and drier?” a Forest employee asked.
“Right,” we said.
“And we need to monitor what we do to be sure it works as the climate is changing?”
“Yes,” we agreed.
“In other words, for climate we should be doing the things we were already supposed to be doing?”
“Well, there are some differences, but.. pretty much.”
*********************
That was perhaps too minimalist for some. Today I’d add consciously managing for resilience.
But why not manage for resilience under a variety of future climate (and other) scenarios? When we visited Denver Water and looked at their scenario planning, climate wasn’t the only unknown. At the time, they also considered different plausible scenarios about populations and their uses of water. If you look at their website, they are not even sure about hotter and drier, but also include hotter and wetter.
Denver Water is adapting to, and addressing, climate change through what it calls “scenario planning.” That means building flexibility into its operations and decisions to prepare for a range of plausible futures climate change could bring. Simply put, those scenarios range from warmer and wetter to hotter and drier.
“Uncertainty is the name of the game going forward,” said Laurna Kaatz, Denver Water’s climate program manager. “We don’t know exactly how it will unfold on the ground, but we do know it’s going to keep warming. Climate change is here and now.”
Then there’s resilience of communities to climate hazards (or things now defined to be “climate” hazards such as drought, wildfire, and flooding). For example, in this Western Watersheds Assessment study plan,
but could take the form of collaborative scenario planning processes that engage diverse stakeholders to explore climate projections, sources of vulnerability, and strategies for increasing resilience.
Which sounds like what the FS may have done a while back (at least some forests did this with the aid of FS R&D) . And of course, community resilience is related to economics, so that ties back to a topic that fits forest planning.
Next time: Some Categories for Climate Approaches in Forest Plans