“Using our nation’s forest inventory to open carbon markets to family forest owners”

Here’s an announcement from the Forest Service about a program designed to promote use of small, private forests for carbon offsets.  In particular, it’s about the the use of Forest Service FIA data in this program, but I’m always interested in what management practices are considered to be worth getting paid for, and I don’t think I’ve seen them this clearly specified.  The program website says, “When you enroll, you’ll receive payments for implementing forest management practices that increase the carbon sequestered and stored on your land.”  This program seems to be only available in the eastern U. S., but if you track through the links you can find the specific “management requirements” for several states under the “Practice Overview” documents here.   The three groups of states are each a little different.

Michigan/Minnesota/Wisconsin (Payments are higher for “growing mature forests” than for “promoting diverse forests;” these are requirements for the former, while the latter allows more intensive logging, but has requirements for reserve areas.)

  • Harvests may not remove more than 25% of the basal area at the time of the harvest.
  • Harvests may not reduce the average stand diameter by more than 10%.

Maryland/Pennsylvania/West Virginia (Payment is for “growing mature forests” only)

  • If you choose to conduct a timber harvest, it must not remove more than 25% of the basal area per acre
  • High-grading is prohibited during the contract period. High-grading is defined as a reduction in quadratic mean tree diameter of more than 10% from the pre-harvest condition.

Vermont/eastern New York (Payments are higher for “grow older forests” than for “enhance your woodland.”  The former generally requires deferment of commercial logging for 20 years.  The latter restricts timber harvest based on basal area, diameter, trees per acre, snags and opening size.)

Would something like this make sense in the west?  For federal lands (as a best management practice, since they couldn’t be paid for it)?  (I know we’ve had some discussions about thinning requirements based on basal area vs other metrics.)



Opponents of conservation invoke NEPA

Image: Scout Environmental

I have made several comments recently about situations that should not trigger NEPA procedures because they do not have adverse effects on the physical environment.  I became interested in this topic in 1986 when I noticed that development interests were arguing that forest plans adversely affected “community stability” (a euphemism for social and economic impacts), and this was being addressed as an “environmental” impact in NEPA documents.  Given that the goal of NEPA was better environmental protection, I could see how inferring that social and economic impacts of protecting the environment must be addressed through a NEPA process could lead to less environmental protection.

As an example of that actually happening, let’s talk about the proposal to conserve 30% of the nation’s lands (America the Beautiful/30 x 30).

Property rights advocate Margaret Byfield’s strategy for defeating the Biden administration’s aggressive conservation pledge comes with a twist: She wants landowners to embrace the nation’s bedrock environmental law.

Byfield, the executive director of American Stewards of Liberty — and daughter of the late E. Wayne Hage, an icon of the Sagebrush Rebellion II movement — sees the National Environmental Policy Act as a cudgel in her campaign to upend the “America the Beautiful” program.

But Byfield emphasized Friday that the strategy must also embrace NEPA, arguing the Biden administration has skirted its responsibility to execute “a programmatic” environmental review of its “America the Beautiful” plan.

“This is the environmentalists’ great law that they use as a weapon against productive agriculture and actually any kind of project,” Byfield said. “They use it to slow down and stop projects, they use it as a weapon.”

Byfield asserted that the Biden administration has skirted NEPA by moving forward without an environmental review.

“They also know if they do NEPA right, it’s going to take them three, maybe six, maybe nine, maybe 10 years to complete the study the way they make us do it. So why aren’t they living under the same laws they force us to follow?” she asked.

The obvious reason is that NEPA was not passed by Congress to protect “agriculture and actually any kind of project.”  The ASL seeks to turn NEPA on its head.  The interesting thing is that the Center for Biological Diversity did not mention this, instead stating that the President and executive orders are exempt from NEPA, and actually inferred that the future site-specific conservation actions could require NEPA procedures.

The law regarding application of NEPA to non-environmental consequences of environmental protection measures is less clear than it should be.  The Supreme Court framed this question in Metropolitan Edison Co. v. People Against Nuclear Energy in 1983

But we think the context of the statute shows that Congress was talking about the physical environment — the world around us, so to speak. NEPA was designed to promote human welfare by alerting governmental actors to the effect of their proposed actions on the physical environment.

But, here’s a confusing discussion by the Ninth Circuit in the 2000 case of Kootenai Tribe of Idaho v. Veneman, which challenged the procedures used to adopt the Forest Service’s Roadless Area Conservation Act (the “Roadless Rule”).  (Other plaintiffs in this case were Boise Cascade Corporation, motorized recreation groups, livestock companies, and two Idaho counties.)  The Forest Service did not appeal the district court’s injunction of the Roadless Rule, but an appeal was filed by environmental intervenors, who argued that the Rule did not alter the natural physical environment and require an EIS under NEPA.

Under NEPA, a federal agency is required to prepare an EIS for all “major Federal actions significantly affecting the quality of the human environment.” 42 U.S.C. § 4332(2)(C) (emphasis added). “Human environment,” in turn, is defined in NEPA’s implementing regulations as “the natural and physical environment and the relationship of people with that environment.” 40 C.F.R. § 1508.14. See also Wetlands, 222 F.3d at 1105. The dispositive issue here is whether the Roadless Rule sufficiently affected the quality of the human environment to trigger the procedural requirements of NEPA.

We have explained that NEPA procedures do not apply to federal actions that maintain the environmental status quo. See Burbank Anti-Noise Group v. Goldschmidt, 623 F.2d 115, 116-17 (9th Cir.1981) (NEPA does not apply when an agency financed the purchase of an airport already built); Nat’l Wildlife Fed’n v. Espy, 45 F.3d 1337, 1343-1344 (9th Cir. 1995) (NEPA does not apply when agency transferred title to wetlands already used for grazing); Bicycle Trails Council of Marin v. Babbitt, 82 F.3d 1445, 1446 (9th Cir.1996) (closure of bicycle trails does not trigger EIS). In other words, “an EIS is not required in order to leave nature alone.” Douglas County, 48 F.3d at 1505 (citation and internal quotation marks omitted). The touchstone of the EIS requirement is whether the change in the status quo is “effected by humans.” Id. at 1506.

Because human intervention, in the form of forest management, has been part of the fabric of our national forests for so long, we conclude that, in the context of this unusual case, the reduction in human intervention that would result from the Roadless Rule actually does alter the environmental status quo.

This perverse rationale (for this “unusual” case) has no citations, and I think it is only justified by a desire to decide the case on the merits of the EIS (which it upheld) rather than on a procedural question.  Moreover, it ignores the additional requirement that the environmental status quo must be adversely affected (the term “adverse” is used many times in the CEQ NEPA regulations).  Here is a 2012 paper on “beneficial effects” under NEPA.  Its conclusion echoes my concern from 35 years ago (which has become a reality).

Third, the policies underlying NEPA are in tension with a Beneficial Impact EIS requirement. Such a requirement would produce unnecessary cost and delay for environmentally beneficial projects and create perverse incentives for federal agencies without any compensating informational benefits.

Agencies that are using NEPA to justify delaying environmental protection are probably not violating the words of NEPA, but clearly violate its spirit.  Moreover, anti-environmental plaintiffs should not be able use the courts to facilitate this violation.

National Forest State Park

Sweetwater Lake, located in remote northeastern Garfield County in the Flat Tops Wilderness Area, is set to become Colorado’s first state park on federal land after it was acquired by the U.S. Forest Service in August 2021.

“Colorado’s first state park on federal land.”  This came across as an oxymoron, but why not?

This land acquisition followed a common pattern, where a non-profit conservancy (The Conservation Fund) acquired private property until the federal government had the funds (Land and Water Conservation Fund) to purchase it and add it to a national forest (White River).  (From Colorado Parks & Wildlife, linked below.)

This Land and Water Conservation Fund purchase followed the acquisition of the property in 2020 by The Conservation Fund, which was made possible by a loan from Great Outdoors Colorado and local fundraising efforts such as the “Save the Lake” Campaign organized by Eagle Valley Land Trust.

A little less common (to me any way), the Conservation Fund is also continuing to fund management, according the Eagle Valley Land Trust:

“We’re also excited to announce our Sweetwater Lake Stewardship and Equity Fund, which will assist the Eagle Valley Land Trust and our agency partners in activating the property for public use and enhancing opportunities for underserved communities to enjoy the space for years to come.”

There is an existing Forest Service campground on adjacent land.  The Forest Service had this to say in the formal announcement from Governor Polis:

“Sweetwater Lake has tremendous ecological and cultural values and outstanding opportunities for recreation.  This partnership allows the White River National Forest to incorporate the local expertise of the Eagle Valley Land Trust and the recreation management and wildlife expertise of Colorado Parks and Wildlife to best serve visitors to the area,” said Rocky Mountain Regional Forester Frank Beum.

Colorado Parks and Wildlife added:

“Colorado Parks and Wildlife is excited to modernize facilities and provide updated and sustainable recreational services through this partnership. Our main priority is to conserve the unique character of the area while improving access to this incredible property,” said Colorado Parks and Wildlife Director Dan Prenzlow.

None of this said much about the State’s authority and responsibility, but I don’t know why they couldn’t lease the site and manage it as a permittee.  I don’t know if any other states have done anything like this, but as questions continue to come up about how to manage growing outdoor recreation this might be an option in some other places.

Large landscape connectivity – could the Forest Service be a leader?

I watched a webinar provided by the Center for Large Landscape Conservation titled “Legal Protections for Large Landscape Conservation,” part of which focused on “Habitat Connectivity and the U. S. Forest Service.”  That segment can be seen here from 4:15 to 19:05.  The presentation goes over the elements of Forest Service planning that could be useful for habitat connectivity.  It includes a couple of examples of “innovations” from the Flathead and Carson/Santa Fe forest plan revisions, but concludes that few plan components that address connectivity are likely to be very effective.  It cites a familiar refrain that the agency is “unwilling to commit to specific direction,” and “lack of commitment and interest from line officers.”  However, the presenter observed that the movement of the Forest Service toward more centralized planning organizations might provide an opportunity to look at connectivity as a broader regional issue, and to develop regionally consistent approaches to planning for connectivity.

What if the Forest Service was actually interested in conserving the species that use its lands but require connectivity across other jurisdictions and ownerships (as it is required to do, “in the context of the broader landscape,” a phrase used seven times in the 2012 Planning Rule ), and what if the Forest Service played a leadership role in facilitating such cross-boundary connectivity by promoting large-landscape conservation strategies?

Maybe it would look something like what the Yellowstone to Yukon Initiative has accomplished since it began promoting large-scale landscape conservation in 1993.  As Rob Chaney reports in the Missoulian, they have recently evaluated the effectiveness of their program in “Can a large-landscape conservation vision contribute to achieving biodiversity targets?”  They found that in the Y2Y region where landscape connectivity was actively promoted, more public lands were dedicated to protection, more private lands were protected, wildlife highway crossing structures proliferated, and occupied grizzly bear habitat (as a proxy for actual benefits to wildlife) expanded.

Come to think of it, wouldn’t that be a great assignment for the Biden Administration to give the Forest Service (both the National Forest System and State and Private Forestry divisions) to promote its 30 X 30 conservation agenda?



Planning for protection from recreation

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.

Make forest plans great again (for wildlife)


I often point out how the Forest Service is shirking its responsibility to adopt forest plans that provide ecological conditions needed for diversity and viability of at-risk species.  Most recently, I listed some examples from the recently released Rio Grande revised forest plan.  Here is one guideline (there weren’t really any relevant standards):

EPC-G-1: To avoid or minimize adverse effects to listed species and their habitat, management actions should be designed with attention to threatened, endangered, proposed, or candidate species and their habitats. 

This says essentially nothing.

An important purpose of identifying and planning for at-risk species is to reduce the chance that they would need to be listed under the Endangered Species Act.  If this were a private landowner, conservation measures for at-risk (but not yet listed) species would be discretionary.  However, they could choose to sign a Candidate Conservation Agreement with Assurances (CCAA) with the listing agency to adopt conservation measures that would reduce the likelihood of listing in exchange for a commitment that the listing agency would not require anything more if the species did become listed.

Here is an example of one such enhancement of survival permit for Chinook Forest Partners, LLC Candidate Conservation Agreement with Assurances for Fisher in Oregon (until recently, a candidate for listing).  From the NEPA document (CE):

Activities that are covered by this CCAA and the associated section 10(a)(1)(A) permit are on-going and commonly practiced forest land management activities. These include timber harvest and hauling, site preparation and reforestation, and road maintenance and construction. Additionally, there may be some collection of minor forest products, fire suppression, and recreation (including legal hunting and trapping).

Goals and objectives for fisher include: improving our understanding of fisher distribution, densities, and habitat use, especially on non-federal lands where information is more lacking; conserving active fisher den sites to increase the survival of young; increasing public participation and support for fisher recovery and reintroduction by providing long-term assurances; and, monitoring potential future reintroduced fishers as they disperse from their release sites to determine success rates and provide information for improving success rates.

And here is what the private landowner committed to do in the CCAA to achieve those objectives for fisher (note: some are saying that this still isn’t good enough).  Given that the Forest Service is obligated by NFMA to provided ecological conditions for a viable population of at-risk species on national forests, why shouldn’t they be making at least this kind of commitment in their forest plans for public lands?  (This could make them adequate regulatory mechanisms to reduce the likelihood of listing under the ESA criteria.)

  • Specifically, CFP/CFM shall not conduct or authorize any of the activities described in the forest management activities in Section 4 (including but not limited to timber felling, pre-commercial thinning, reforestation, salvage of trees, prescribed burning, and brush control) within 0.25 miles of a den site, because those activities could result in disturbance or harm to denning fishers. CFM shall not authorize helicopter or fixed wing application of herbicide or fertilizer within 0.25 miles of an occupied den site between 15 March and 30 September until CFM is informed by USFWS or its agent the denning female has vacated the den site.
  • Provide protection of denning female fishers by restricting trapping and nuisance animal control activities on enrolled lands within 2.5 miles of den sites.
  • Report to USFWS, and ODFW or mutually agreed upon designated agents, within 48 hours upon finding any potentially occupied den sites or any dead, sick, or captured fishers on enrolled lands.
  • Cover all man-made structures on enrolled lands that pose an entrapment risk to fishers (e.g. large water troughs, old rail cars, or other containers from which fishers cannot escape) or place a device within the structure (e.g., wooden pole to allow fishers to climb out) to prevent mortality of fishers from drowning, starvation or dehydration
  • Where suitable habitat exists and where agreed upon by CFP and USFWS, allow the release of translocated fishers on enrolled lands
  • CFP will seek to have all of its timberlands third party certified to the Sustainable Forestry Initiative® (SFI),
  • CFP will take fisher habitat characteristics into consideration when assessing parcels for transfer or sale into permanent or semi-permanent conservation status.
  • Subject to safety, operability, fire hazard considerations, and salvage of timber following fire, windthrow or other natural or man-caused casualty, CFM will conserve existing and future standing deadwood, and, where available, focus leave tree retention on damaged, decayed, or deformed trees that are likely to provide or promote decay processes and structures beneficial to fisher or their prey.
  • CFM meets or exceeds the Forest Practices Act (FPA) live tree and snag retention, and down woody debris. For clearcut harvests greater than 25 acres, FPA requires that at least 2 snags or 2 green trees 30 feet tall and at least 11 inches DBH, at least 50% are conifer, plus at least 2 down logs or down trees at least 50% of which must be conifers that are at 6 least 6 feet long with a total volume of 10 cubic feet must be retained. CFM commits to retaining a minimum of 3 snags or green trees per acre on clearcuts larger than 25 acres, and these trees/snags will be retained for the life of the CCAA.
  • Trees >32” DBH will be retained the greatest extent possible, provided they do not pose safety hazards
  • CFM will instruct logging contractor to avoid whenever possible, driving machinery over, or otherwise damaging large down woody debris, thereby maintaining the integrity of stumps and logs that may be used by fishers and their prey.
  • CFM will seek to leave down woody debris and other structures important to fishers and their prey distributed throughout the unit instead of piling them into slash piles, will attempt to avoid mechanical damage or disturbance, and will locate skid trails around them where safety and operability considerations permit.
  • For slash piles documented as being used by fishers for denning on the enrolled lands, CFM shall not burn or otherwise mechanically alter such slash piles for a period of 5 years after the last year of known occupancy and use by a denning fisher.
  • CFM will avoid the use of rodenticides on lands enrolled in the permit area.
  • CFM will prohibit lessees from recreational trapping.

Private land conservation easements benefit national forest wildlife

In 2009, the owner of a golf course in Georgia donated a conservation easement to a non-profit land trust.  The easement included roughly 57 acres of primarily bottomland forests and wetlands along the Savannah River that would not be developed.  That land is directly across the river from the Sumter National Forest, 700 feet away.

To obtain a tax deduction for the conservation easement, it has to be “exclusively for conservation purposes” based on one or more of the criteria in the Internal Revenue Code.  They include:

(ii) the protection of a relatively natural habitat of fish, wildlife, or plants, or similar ecosystem,

(iii) the preservation of open space (including farmland and forest land) where such preservation is–

(I) for the scenic enjoyment of the general public, or

(II) pursuant to a clearly delineated Federal, State, or local governmental conservation policy,

and will yield a significant public benefit,

These issues were recently litigated by the IRS for this easement in the 11th Circuit Court of Appeals, which found the donation to be eligible as both habitat (ii) and scenic open space (iii)(I).  IRS Treasury Regulations elaborate on these requirements with regard to habitat by including “natural areas which are included in, or which contribute to, the ecological viability of a local, state, or national park, nature preserve, wildlife refuge, wilderness area, or other similar conservation area.”  However, the court accepted expert testimony from the IRS that the easement did not support the forest’s ecological viability.

There is no mention of testimony from the Forest Service. The 2012 Planning Rule stresses that, planning for ecological integrity must take into account “conditions in the broader landscape that may influence the sustainability of resources and ecosystems within the plan area” (36 CFR §219.8(a)(1)(iii)).  In addition, where a national forest plan area can not maintain a viable population of a species of conservation concern, “the responsible official shall coordinate to the extent practicable with other Federal, State, Tribal, and private land managers having management authority over lands relevant to that population” (36 CFR §219.9(b)(2)(ii))).

The also court determined, regarding open space (iii)(II), that, “There is no qualifying federal, state, or local government conservation policy that applies to this land…” In fact, the Forest Service Open Space Conservation Strategy includes this vision: “Private and public open spaces will complement each other across the landscape to provide ecosystem services, wildlife habitat, recreation opportunities, and sustainable products.”

In this case, private land adjacent to a national forest was conserved, but there is no evidence that the Forest Service was even paying attention.  The Forest Service needs to be more alert to these opportunities that would benefit national forest resources as well as contribute to greater national conservation needs.  Maybe if the Forest Service promoted its conservation policies better, they would facilitate more donated easements and protect more habitat for wildlife species that also use national forests.

Along somewhat the same lines, conservationists in Florida are striving to conserve the Ocala to Osceola Wildlife Conservation Corridor, which would connect the two national forests of those names across 50 miles of multiple other ownerships (including a military base).  Here is a presentation by the U. S. Natural Resources Conservation Service, which uses funding from the federal Farm Bill Resource Conservation Partnership Program to purchase conservation easements and create wildlife habitat on private lands within the corridor.  (This is the kind of “governmental conservation policy” that should also support federal tax deductions for donated conservation easements.)

The federally endangered red-cockaded woodpecker is an excellent example of a species that the Forest Service needs to coordinate management with others for, and here’s a bit of the success story about that in the O2O Corridor.

A red-cockaded woodpecker (RCW) captured at Camp Blanding in Clay County is evidence that a project led by North Florida Land Trust to preserve land within the Ocala to Osceola (O2O) wildlife corridor is working.  The bird captured at Camp Blanding was the first time this endangered species had moved between one of the national forests and the military installation since they began banding and recording the birds over 25 years ago.

“USDA Forest Service” is listed as a “partner” by NRCS, and the “National Forest Service” by the North Florida Land Trust.  The latter gives me a sense of how deeply the Forest Service has not been involved, and I sure can’t find anything about this effort on either national forest website or using a national search.  It’s too bad the Forest Service isn’t providing more leadership (and getting more of the credit) for conserving its important wildlife resources.

The American Prairie Reserve: Private Ownership and Conservation Writ Very, Very Large


This NPR story has some of the same themes as other topics we’ve been discussing about private lands conservation. What I like about this story is that it puts a different twist on many of the topics we discuss with regard to US government lands.

A privately funded, nonprofit organization is creating a 3.2 million-acre wildlife sanctuary — American Prairie Reserve — in northeastern Montana, an area long known as cattle country.

But the reserve is facing fierce opposition from many locals because to build it, the organization is slowly purchasing ranches from willing sellers, phasing out the cows and replacing them with wild bison. Those private properties are then stitched together with vast tracts of neighboring public lands to create one giant, rewilded prairie. The organization has purchased close to 30 properties so far, but it needs at least 50 more….

But the project’s efforts have garnered a lot of positive attention from those living outside northeastern Montana because, once it’s complete, it will be the largest wildlife sanctuary in the Lower 48 states — about 5,000 square miles, nearly the size of the Serengeti National Park in Tanzania.


(1) What I missed in this article was an understanding of the concerns of the ranchers.  It’s odd that the article focused on the Bible when more pragmatic answers are likely out there. Here are a few of my guesses for rancher resistance.

  1. reintroduction of critters that eat animals they care for and depend on for their livelihood. (personal economics losses)
  2. losing social capital from their already small community (friends, fellow volunteers, neighbors to borrow or help with things).
  3. losing economic capital from their already small community (taxes, donations, etc.)

I’m quite curious as to what kind of convos are going on in these communities about those concerns.  Conceivably the new owners have a plan for being good neighbors, paying for eaten livestock and so on.  What makes a good wildland neighbor? If it’s important for rich people to be good neighbors, how about Uncle Sam?

(2)  Another interesting aside in the story was bringing up where the owners got the money.

Do college profs get to determine the “appropriate goodness” of other people? And why interview a professor from Stanford about a story in Montana?

Some see hypocrisy in this kind of money, including Rob Reich, director of the Center on Philanthropy and Civil Society at Stanford University.

“The structure of global capitalism, which they had a role upholding, is partly responsible for the degradation of the environment,” Reich says.

If we go back to federal lands, Uncle Sam got it by dispossessing Native Americans.  To circle back to the New Testament, seems like stone-casting (John 8:7) has become a national sport.  I don’t think that that’s a good thing.

I also thought it was interesting that Garrity questioned the idea that producers of resources carry more responsibility than users:

But Gerrity says the reserve can’t afford to be that picky because almost all of his donors, big and small, are driving the climate crisis.

“The person who puts the gas in their car, or uses the coal in their house to heat, or the person who gets on a nonessential jet trip to take a vacation or go to a wedding or something like that, is the person actually creating the business and encouraging the oil companies to keep on doing what they’re doing,” Gerrity says.

(3) The owners buy only from willing sellers, so is this just another western “making a living” transition, along with ski areas, population growth (in some places), gas wells, wind and solar farms,  and so on?