Planning

Practice of Litigation Friday: Fire in Pacific Fisher Habitat

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U. S. Fish and Wildlife Service

This recently filed case (the complaint is at the end of the article) hasn’t generated a lot of news coverage, but it directly raises some of the questions we have discussed at length about the effects of fuel reduction activities.

On March 26, 2021, three California conservation groups filed a complaint for declaratory judgment and injunctive relief against the Forest Service and Fish and Wildlife Service in the federal district court for the Eastern District of California (Unite the Parks v. U. S. Forest Service).  They are challenging, “the failure … to adequately evaluate, protect, and conserve the critically endangered Southern Sierra Nevada Pacific fisher … on the Sierra, Sequoia, and Stanislaus National Forests …” after a substantial reduction in habitat since 2011 resulting from a multi-year draught, significant wildfires and Forest Service vegetation management.  Many of the variables considered in a prior 2011 analysis have been adversely affected by these changes. The plaintiffs implicate 45 individual Forest Service projects.

This fisher population was listed as an endangered species on May 15, 2020, and the agencies conducted “programmatic” consultation at that time on 40 already-approved projects.  The agencies reinitiated consultation because of the 2020 wildfires, but did not modify any of the projects.  The purported rationale is that the short-term effects of the vegetation management projects are outweighed by long-term benefits, but plaintiffs assert, “There is no evidence-based science to support this theory…,” and “the agencies ignored a deep body of scientific evidence concluding that commercial thinning, post-fire logging, and other logging activities conducted under the rubric of ‘fuel reduction’ more often tend to increase, not decrease, fire severity (citing several sources, emphasis in original).  The complaint challenges the adequacy of the ESA consultation on these projects, and the failure to “prepare landscape-level supplemental environmental review of the cumulative impacts to the SSN fisher…” as required by NEPA.

Not mentioned in the lawsuit is the status or relevance of forest plans for these national forests, two of which (Sierra and Sequoia) are nearing completion of plan revision.  However, the linked article refers to an earlier explanation by the Forest Service that they would not be making any changes in the revised plans based on the 2020 fires because they had already considered such fires likely to happen and had accounted for them.  ESA consultation will also be required on the revised forest plans, and should be expected to address the same scientific questions, arguably at a more appropriate scale.  Reinitiation of consultation on the existing plans based on the changed conditions should have also occurred under ESA.  (This is another area where legislation has been proposed to excuse the Forest Service from reinitiating consultation on forest plans, similar to the “Cottonwood” legislation that removed that requirement for new listings or critical habitat designation.)

(And in relation to another topic that is popular on this blog, Unite the Parks also supports the establishment of the Range of Light National Monument in the affected area.)

Forest management in the climate context

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I thought the graphics from this research article did a good job of illustrating the role of forests and forestry in climate change mitigation.

Even if there is a lot of uncertainty in the assumptions and modeling, forest management is likely where the greatest opportunities are for land management to contribute to climate mitigation.  (Note that fire management is a relatively minor contributor.)  (AFOLU – the new acronym of the day – is Agriculture, Forestry and Other Land Use.)

Thus, ecosystems have the potential for large additional climate mitigation by combining enhanced land sinks with reduced emissions…  We describe and quantify 20 discrete mitigation options (referred to hereafter as “pathways”) within the AFOLU sector …  We refer to these terrestrial conservation, restoration, and improved practices pathways, which include safeguards for food, fiber, and habitat, as “natural climate solutions” (NCS).

Improved forest management (i.e., Natural Forest Management and Improved Plantations pathways) offers large and cost-effective mitigation opportunities, many of which could be implemented rapidly without changes in land use or tenure. While some activities can be implemented without reducing wood yield (e.g., reduced-impact logging), other activities (e.g., extended harvest cycles) would result in reduced near-term yields. This shortfall can be met by implementing the Reforestation pathway, which includes new commercial plantations. The Improved Plantations pathway ultimately increases wood yields by extending rotation lengths from the optimum for economic profits to the optimum for wood yield.

Work remains to better constrain uncertainty of NCS mitigation estimates. Nevertheless, existing knowledge reported here provides a robust basis for immediate global action to improve ecosystem stewardship as a major solution to climate change.

Unfortunately, the major role of forests in NCS mitigation strategies is pretty minor with regard to overall climate change mitigation needs.  (I.e. planting a trillion trees won’t do the trick; we need significant emissions reductions.)

 

Climate tipping point for forests

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www.e-education.psu.edu

Add to this diagram – “Respiration (when overheated).”

We’ve talked about how older forests may sequester less carbon and dead forests release carbon (for example, here).  New research indicates that forests also sequester less carbon and start to release carbon (while they are still alive) if the temperature gets too high.  As reported here:

‘We’re in Bigger Trouble Than We Thought’

The data show a clear temperature limit, above which trees start to exhale more CO2 than they can take in through photosynthesis, said co-author Christopher Schwalm, an ecologist and earth system modeler at the Woodwell Climate Research Center. The findings mark a tipping point, of sorts, at which “the land system will act to accelerate climate change rather than slow it down,” Schwalm said.

“Seeing such a strong temperature signal globally did not surprise me,” he said. “What I was surprised by is that it would happen so soon, maybe in 15 to 25 years, and not at the end of the century.”

Other researchers commented on management implications of drought-stressed dying trees:” 

It may come down to looking at options for saving valuable, individual stands of trees,  and protecting genetically distinct and more resilient species. It could also be important to conserve corridors and patches of woodland to reduce the distance seeds must travel to enable forests of the future to spread or reconnect under more favorable climate conditions, he explained.

“We think a lot of these areas are going to go down, so where can we save some of it?” he asked.

There are obviously implications here for national forest planning.  It seems like it should be the role of the national headquarters to review and interpret the implications of new research for forest management, and to advise national forests regarding its implications for their plans and whether they should consider making changes.

Some New Ideas For Forest (and BLM) Planning: Mark Squillace

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Does this sound like something I might write (if I were a better writer?):

“The public land use planning process is broken. The land use plans of the principal multiple-use agencies—the United States Forest Service and the Bureau of Land Management (“BLM”)—are unnecessarily complex, take too long to complete, monopolize the time and resources of public land management agency staffs, and fail to engage the general public in any meaningful way. Moreover, the end result is too often a plan that is not sufficiently nimble to respond to changing conditions on the ground, a problem that appears to be accelerating due to climate change.

It might seem easy to chalk up these problems to the inherent complexity of public land management. But what if public land management were not so complicated? What if the relevant agencies could rethink their current planning models and break down their decisions into more accessible and more manageable chunks?

In this article, I suggest a new public land use planning framework with the potential to make planning more logical, more efficient, and more effective at achieving the goal of the smart management of our public lands that everyone wants. Moreover, this new approach can be carried out in a way that makes planning more accessible to interested members of the general public, thereby enhancing opportunities for meaningful engagement with public land decision-makers.

The ideas proposed here should not be viewed as final or inviolate. Rather, they are offered as an opening bid worthy of testing and debate. We cannot address the crisis facing the current land use planning program if we are unwilling to try new things. Perhaps the ideas presented in this article, even if tried, will be found wanting. But it is my hope and belief that we can and will learn much from rethinking the current public.”

What’s interesting to me is that the problem as framed could lead to completely different solutions as in the 2005 Rule, the 2012 Rule, and Andy Stahl’s KISS Rule. It also reminds me of when planners talked about forest plans as a “loose-leaf notebook” due to the need to deal with changing conditions. We’ve been talking about the same problems for at least 30 years (1992 OTA Report).

But the article was actually written by Mark Squillace, Professor at U of Colorado Law School, so we can assume that he might come up with something quite different. For those of you have been with TSW since the beginning, you might remember that Mark and his students participated in many stimulating practitioner/academic discussions of forest planning with me, John Rupe (forest planner extraordinaire) and Rick Cables. This paper is 65 pages (in the Harvard Environmental Law Review!) and it’s possible you might not want to read the whole thing, so you might want to focus on the proposed solution Squillace begins to describe on page 437, or applying that to the White River National Forest on page 463. Or you might want to start and see if you agree with his “problems with the public planning process” on page 433. I’ll pull out ideas that strike me to highlight in one or more subsequent posts, but if you want to support or take issue with something in the paper, you are invited to provide a post or post a comment as well. Just send any posts to me at terraveritas at gmail.

Let’s take Squillace at his word, as an “opening bid worthy of testing and debate.” I always thought that (since the 2000 Rule) that the Committee of Scientists should have been charged with with “how can we design a process that minimizes the burden and maximizes the utility of filling statutory responsibilities for NFMA and in addition helps build supportive relationships for plan implementation?” In dealings with the legal folks though I’ve generally found them to operate from the presumption that planning is useful. Perhaps it was all that reading on strategic planning when I worked in RPA that led me to be questioning… e.g. what exactly about it it useful or necessary? Are there simpler ways to achieve the same outcome? Do approaches adequately consider uncertainties (known unknowns and unknown unknowns)? And how does Squillace’s proposed solution fit in with your own forest planning (and landscape planning) experiences?

Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington

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One of the many things that went into the Trump dump the last couple of weeks was the amendment of the Forest Service Eastside Screens old growth protection standard:  “Forest Management Direction for Large Diameter Trees in Eastern Oregon and Southeastern Washington.”    We discussed that at length here.  The Forest Service documentation for the amendment is here. The standard prohibiting harvest of trees >21” dbh has been replaced by this guideline (“LOS” is late and old structure, and it refers to “multi-stratum with large trees” and “single-stratum with large trees”):

Outside of LOS, many types of timber sale activities are allowed. The intent is still to maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible, by adhering to the following plan components: Managers should retain and generally emphasize recruitment of old trees and large trees, including clumps of old trees. Management activities should first prioritize old trees for retention and recruitment. If there are not enough old trees to develop LOS conditions, large trees should be retained, favoring fire tolerant species where appropriate. Old trees are defined as having external morphological characteristics that suggest an age ≥ 150 years. Large trees are defined as grand fir or white fir ≥ 30 inches dbh or trees of any other species ≥ 21 inches dbh. Old and large trees will be identified through best available science. Management activities should consider appropriate species composition for biophysical environment, topographical position, stand density, historical diameter distributions, and Adapting the Wildlife Standard of the Eastside Screens 5 spatial arrangements within stands and across the landscape in order to develop stands that are resistant and resilient to disturbance.

The proper way to read a guideline is that its purpose is a standard: “Managers must maintain and/or enhance a diverse array of LOS conditions in stands subject to timber harvest as much as possible.”  It’s not clear to me how you maintain LOS “outside of LOS,” so maybe only “enhance” is applicable, but even that term assumes what you are enhancing is already there to a degree.  This is also weakened by the qualifier “as much as possible.”  This could be interpreted to allow timber harvest even if enhancing LOS conditions is not possible.

The rest of the boldface language should be interpreted as actions that would always be allowed because they would always promote the LOS purpose.  This means that a decision to NOT retain all old and large trees could only be made if it is demonstrated that LOS is enhanced.  “Generally emphasize” allows probably unlimited discretion regarding recruitment.  A decision to NOT prioritize old trees (i.e. to log any old tree before logging large trees) could also only be made if it is demonstrated that LOS is enhanced.  This could be reasonably effective, but it puts a significant burden on project analysis and documentation to deviate from the terms of the guideline.  This is as it should be.  The last part of the guideline lists things that “should be considered,” which shouldn’t be given much weight.

There are also changes in standards and guidelines for snags, green tree replacement and down logs.

The last part of the “decision” is to adopt an “Adaptive Management Strategy.”  This strategy proposes monitoring and thresholds intended to trigger additional restrictions on large tree removal:

  1. If large trees are not increasing in number with appropriate composition, the Regional Forester will impose the Age Standard Alternative across the whole analysis area or by national forest or potential vegetation zone.

  2. If effectiveness monitoring does not occur, the Regional Forester will impose the Age Standard Alternative across all six national forests.

However, under the Planning Rule, these are not plan components and are not mandatory.  While there are “requirements” for regional forester review every five years, this is not a plan component either.  Since none of this “strategy” is enforceable it is of much less benefit than if it had been included as plan components like standards.

(For those interested in how the “natural range of variation” (NRV) is used in forest planning, there is a desired condition for the amounts of LOS in different habitat groups and it is based on NRV.  These new amendments leave in place the desired conditions for LOS previously determined in accordance with the original amendments in 1995.   An appendix in the decision notice includes a “Table 3” that is “only an example” of NRV because, “The number and kind of biophysical environments and the historic and current distribution of structural conditions vary by landscape.”  In order to fully understand the effects of this amendment on a particular landscape, we would need to see the definitions of LOS and actual desired conditions for LOS incorporated into a plan for that landscape.  I didn’t find them in or see them referred to in the amendment documentation, I suppose because they are not changing).

 

Vegetation Change and Vegetation Management: A Potential New National Forest Report Format

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I remember Chris Iverson, noted expert in wildlife and forest planning, saying something once about forest plans like “if you don’t do much, you shouldn’t spend as much time planning.” As I recall, he was talking about the Chugach compared to the Tongass forest plans. But what exactly is “doing much”? What seems to be most controversial and widespread is vegetation management for forest management.

I thought it would be interesting to see where the Rio Grande (with a recent plan revision) fell on that scale, and many thanks to them for their help in collecting this information. I think it would be great to have this information available for all forests. First, the total acres of the Rio Grande is 1.83 million acres to give context. You could easily do this table with percentages and be able to compare the acres impacted by management across different National Forests, as well as vegetation changes due to human and other factors.

What we got from the Forest was total acres of all vegetation treatments, not duplicating the same acres with different treatments (double counting).

According to the forest, the average timber harvest has been around 3100 acres per year. All of that has been insect salvage except for 120 acres in 2017. So that’s about 2% of the forest per year. Of course, salvaging spruce beetle trees that are dead may have different impacts than green sales, but this table is about all acres impacted by vegetation management and other vegetation change.

After collecting this information, I realized that a 10 year timespan may have been better. In 2013, the West Fork Complex Fire burned 87,662 acres of the Rio Grande. Then there’s the spruce beetle outbreak itself over time, accumulating to 617,000 acres. I didn’t fill in that row in the table, but the information is available from the aerial survey folks.

It would be interesting to see at least 10 years with the acreage by type plotted over time, including large events like bug and fire acres, for each National Forest. I think it would be very informative to compare forests, both in total acres of different kinds of human and other vegetation changes, and percentages of the total acres impacted.

I’m not saying that this is the perfect formulation for people to get a grasp of “relative vegetation management” I’m just asking “doesn’t this way of looking at it tell us something of value”?

What would you add or change?

Also circling back to the forest planning question, if some forests, say in R5, have had up to 80 % of their forest affected by wildfires over the past 5 to 10 years, should everyone else stop planning so that they can go into revision? And if “fires are going to get larger due to some combination of fire suppression, increased ignitions and climate change” should then the amount of vegetation modeling done during plan revision be scaled back for fire-prone Forests as not a great investment? Perhaps less energy on modeling and more energy on responding to fire and other changes via amendment?

Chief Thomas on NFMA Planning and Paid Gladiators: Has Thirty-ish Years Brought Progress?

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While on the timely topic of Administration transitions, we were remembering Chief Jack Ward Thomas. I ran across this classic speech he gave in 1992, an Albright lecture at Berkeley (30-ish years ago, now can you believe it?), and thought I’d place it in conversation with Carrie Menkel-Meadow’s thoughts from yesterday.

His thinking appears to be that because plan revisions drag on for so long, and the documents are so long and technical, that the process leads inexorably to more conflict. People without professional funding can’t effectively participate, so it’s left to interest groups. And the psychology of representing an interest group may lead to different options than with members of the public. Here’s a history of interest groups and how political scientists think about them, from James Madison onward.

Participation by interest groups in forest planning has proven difficult to organize, receive, evaluate, and act upon. Clearly, average citizens can not or will not devote the time necessary to participate effectively over the long haul. And, as the planning process dragged on for over a decade, many of the initial enthusiastic participants dropped out exhausted by the time required for meeting after meeting and review after review of documents that were increasingly technical and mathematical and evermore voluminous.

Some of the “hard cores” with abiding interest formed well-organized groups that grew and were molded into organizations with the aim of providing resources – political, technical, legal and financial – necessary to ensure increased effectiveness in the forest planning game over the long run. As these involved individuals formed themselves into organized advocacy groups, the professional gladiators came to dominate the arena of natural resource politics and planning, resource allocation, and management.

The process of exerting influence over the management of the public’s forests has became steadily more adversarial, sophisticated, and expensive. Amateurs faded more and more into the background save for providing the resources for the gladiators.

JWT’s observations are fascinating placed in conversation with Carrie Meek-Meadow from yesterday. Interest groups are an important part of our political system. What are the pros and cons of designing large-scale and notably infrequent processes that necessarily (or not?) depend on interest groups’ “paid gladiators”? I read some of the objections to the Colville plan, and ability of the people to participate, as JWT spoke of in 1992, was apparently still an issue. I read one comment from a person hired to represent a certain viewpoint where he stated that even he couldn’t make his way through the documents. My experience with the development of the 2012 Planning Rule was that it was considered a success because interest groups were behind it (at least the more influential ones during that Administration). But in pleasing them, somehow, perhaps, JWT’s concern was overlooked.

I’d really like to hear from some folks who worked collaboratively, or as individuals, on recent forest plans.

Trillion Trees and Natural Carbon Storage Act

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We’ve been talking about developing an actual carbon policy for forest management.  Republicans have been willing to concede that planting trees would be beneficial, but others say that is not enough.  We now have a more comprehensive bipartisan legislative proposal that is getting some attention – The Trillion Trees and Natural Carbon Storage Act.  According to the Washington Post, “The forestry proposal is the first to emerge from the Climate Solutions Caucus, which Coons and Braun launched a little more than a year ago.”  It “directs the U.S. Forest Service to set goals for how much carbon the forests, grasslands, wetlands and some coastal areas should sequester from the atmosphere.”

According to sponsor Senator Young (R-IN), among the things it would do is:

  • Requires that USDA establish objectives for increasing the net carbon stock of American forests, grasslands, wetlands, and coastal blue carbon habitats.

Young’s website provides a link to the bill.  The specific language applicable to the Forest Service is to establish within two years, “objectives for increased net carbon stock for the forest, grassland, wetland, and coastal blue carbon habitat ecosystems of the United States that are owned or managed by the Federal Government.” The objectives “shall be established at levels that assist in achieving (A) the optimally feasible and ecologically appropriate increase in the total net carbon stock.” Those objectives, “shall be based on information relating to the maintenance or restoration of the ecological integrity of the ecosystems described in subsection (a), including maintaining or restoring ecologically appropriate forest, grassland, wetland, and blue carbon habitat structure, function, composition, and connectivity…”  That sounds like it is straight out of the 2012 Planning Rule.  There is no mention of national forest planning per se in the bill, but it is hard to see any other vehicle for implementing this policy and these objectives on national forests.

Young’s website also states that, “This legislation is supported by The Nature Conservancy, National Wildlife Federation, Environmental Defense Fund, World Wildlife Fund, National Audubon Society, Bipartisan Policy Center, American Forest Foundation, American Conservation Coalition, National Association of State Foresters, Conservation International, and Citizens for Responsible Energy Solutions.”

According the Environmental Defense Fund, it “follows recommendations from climate scientists and nonprofit organizations to focus on measuring climate impact instead of number of trees planted.”  EDF’s summary:

  • Expand existing U.S. Forest Service carbon accounting to include grasslands, wetlands and coastal ecosystems, in addition to forests.
  • Ensure that forests and other ecosystems will be valued not only for harvested materials, but also for important climate mitigation functions.
  • Measure progress using “net carbon stock,” a metric that reflects the dynamic nature of ecosystems and how carbon stores can grow or shrink over time.
  • Direct the Forest Service to share expertise, including technical capacity to increase carbon stored in urban forests, with states and recipients of U.S. foreign aid.
  • Provide funding to alleviate the nation’s 1.3-million-acre backlog of reforestation projects.

One section of the bill intends to provide financing “to facilitate the sale of credits in the voluntary carbon market or other recognized environmental market…”  However (as described in the same Washington Post article linked above), carbon offsets have become an issue in relation to the nomination of Mary Nichols, the longtime head of the California Air Resources Board, to be the new director of the Environmental Protection Agency.

One central point of contention is her achievement of California’s cap-and-trade program for greenhouse gas emissions. The program allows companies to offset harmful emissions by paying for forestation or other projects that decrease gases elsewhere. But opponents say it amounts to a license to pollute with poor and minority communities bearing the brunt of environmental harms.

Carbon has also come up in relation to the nomination of Tom Vilsack to be USDA Secretary.  The chance to work on Biden’s climate agenda may have made the job more attractive for Vilsack to return.  Carbon seems to offer an interesting opportunity for the USDA to actually unite its agricultural and forestry forces behind a common goal.

Planning for protection from recreation

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This blog has discussed the effects of recreational activities on wildlife (here’s one), and whether federal land managers should be doing something different (than basically reacting to overuse).  It might be worth looking at how planning for use of newly acquired land is being done by local governments and land trusts that are interested in wildlife, and there happen to be a couple of current examples from Colorado.

Fishers Peak is a new state park near Trinidad, Colorado.  It was formerly a private ranch with very little recreational use and no trails or other developments.

“This is a property that has not been loved to death,” Dreiling says. “It’s been pretty well protected, and it’s important to us that we put recreation on this property in a wise way, in a thoughtful way. It’s an important ball that we’re not going to drop, that balance of conservation and recreation.”

In practice, that means a trail won’t be built just because it accesses the prettiest views; instead, the project partners are, for example, assessing where wildlife corridors are located and what sorts of impacts motorized vehicles could have so the public can enjoy the land inside Colorado’s second-largest state park without worrying too much about the environmental consequences. The park’s full playbook is still being drawn up, so not all of these questions have been answered, but efforts to bridge the sometimes conflicting ambitions of recreation and preservation could set a new standard for future projects—here and across the country.

Pitkin County has purchased land and granted a conservation easement to the Aspen Valley Land Trust to protect wildlife habitat.

The easement language includes a nod to a 2016 policy adopted by the Pitkin County Open Space and Trails Board, which states that the county shall “rely on the best available science for property-specific study of natural habitat conditions, including the role of the property in the context of larger habitat and wildlife patterns in the Roaring Fork watershed.” That policy also states that “human uses, if any, will be planned and managed to minimize intrusion into breeding/nesting areas and migration corridors … (and) minimize intrusion into the time periods and/or places of special habitat concern.”

Allowances for human use on the property are not guaranteed and would be made only after detailed studies are completed on site-specific conditions, identifying wildlife and habitat needs.

“You answer those questions first and then say what niches are left where you can integrate humans,” Will said in an interview. That could take the form of enacting seasonal closures or making specific areas of the property off-limits year-round. The management plan could take years to come together.

Of course federal lands are already developed to facilitate recreation.  This doesn’t mean they couldn’t be redeveloped (or undeveloped) where effects on wildlife have been identified.

Woodman spare that forest (the climate needs it)

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Source: Biodiversity Sri Lanka

I’ve been wondering if there is a straightforward answer to the question of how to best manage forest lands to sequester carbon for the foreseeable future to reduce potential climate change impacts.  We’ve beaten around that bush a few times, such as here.

I thought such an answer might be found in the kind of forest management activities carbon offset programs are willing to pay for.  I recently ran across this example, which describes two new programs for small forest landowners.

“Forest carbon projects have historically faced skepticism around their additionality and potential for leakage — that is, the shifting of tree removals to nearby acreage. The concern is that despite paying a landowner to keep trees on one parcel, the same number will simply be removed elsewhere, resulting in a null offset with no net change in carbon storage. Yet SilviaTerra believes this problem can be addressed by creating a market in which all landowners are eligible to receive carbon payments as an alternative to timber revenues…  Payments are scaled to target the timeframe when forests have matured to a point of likely timber harvest… SilviaTerra believes that timber harvest deferrals hold the potential for removing over a billion tons of atmospheric carbon within the United States in the coming decade, or 4.3 billion tons globally.”

SilviaTerra is paying landowners to not harvest mature trees now, and presumably they would continue to do that indefinitely for a parcel because, (according to this article on the carbon value of old forests), “We now know that the concept of overmature forest stands, used by the timber industry in reference to forest products, does not apply to carbon.”   The Family Forest Carbon Program pays for “improved forest management practices,” “such as removal of invasive species or limiting thinning.”  Both seem to treat the answer to my question as obvious – the best management for carbon is “don’t cut down trees.”

Here is what the Forest Service has had to say about the best available science.  This 2017 General Technical Report covers a lot of the pros and cons and questions and considerations and reservations that we have previously discussed, such as wood products, wood energy and fire risk, but if the goal is to “maintain and increase carbon stocks,” the best answer appears to be “decrease carbon loss:”

“Decreasing the intensity of forest harvest is one way to decrease carbon losses to the atmosphere (McKinley et al. 2011, Ryan et al. 2010). Across diverse forest systems, the “no harvest” option commonly produces the highest forest carbon stocks (Creutzburg et al. 2015, Nunery and Keeton 2010, Perez-Garcia et al. 2007).”

The Report was written for a broad audience of landowners and managers, so it also discusses options for managed stands:

“Managed stands typically have lower levels of forest biomass than unmanaged stands, even though the annual rate of sequestration may be higher in a younger forest. In managed forests, reducing harvest intensity, lengthening harvest rotations, and increasing stocking or retention levels will generally increase the amount of carbon stored within forest ecosystem carbon pools in the absence of severe disturbance (D’Amato et al. 2011, Harmon 2001, Harmon and Marks 2002, McKinley et al. 2011, Taylor et al. 2008b).”

However, they also provide caveats and qualifiers associated with obtaining overall carbon benefits from any strategy that removes trees, which make it clear this would likely be a second-best strategy for carbon sequestration.

With regard to national forests, the Report recognizes the role of NFMA and forest plan revisions:

“Assuming carbon is one of these key ecosystem services, the plan should describe the desired conditions for carbon in the plan area that may vary by management or geographic area. In developing plan objectives, the interdisciplinary team should consider the linkage between carbon and how plan objectives would contribute to carbon storage or sequestration. Standards and guidelines may also be needed to achieve desired outcomes for carbon.”

We shouldn’t have to just assume the importance of carbon sequestration, since that is a decision a forest plan could make.  With an incoming administration that has said it would integrate climate change into everything it does, a good question to ask them would be why should the Forest Service not establish in its forest plans the desired outcome to “maintain and increase carbon stocks.”  This should create a presumption or default that trees should not be removed unless the Forest Service can demonstrate scientifically that it would improve carbon sequestration (apparently difficult to do), or if it would meet some other goal that the planning process has determined is a higher priority than climate change (such as public safety).  Climate change mitigation has typically been diverted to a side-channel during forest planning, but there doesn’t seem to be any excuse now for why at least managing for carbon sequestration isn’t mainstream.