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…That [trees] can sequester carbon has been much touted in policymaking circles as one tool to help shrink our carbon footprint; and thus trees seem critical to the larger effort to reduce global warming.

Yet it does not necessarily follow … that we must reforest the planet as rapidly as possible….

Sure: if we had a more complete picture of the variations of potential temperature change across ecosystems and typographies; if we could pinpoint when and where alterations in precipitation will occur; and were we able to calibrate the shifting influence that heat, light, and wet will have on differing soil types, then we might have a clue about what tree species to plant in which biota and at what times.

But we don’t. So to plant trees in hopes that they will survive — and thus increase the odds of us doing so — seems, at best, random.

Take a local analogy. In the scorched aftermath of the Station Fire the U. S. Forest Service feared that the erosive force of coming rainy seasons would strip the burned-over district of its soil. It thus launched an aggressive restoration project. Beginning in April 2011, contract labor planted one million seedlings of an expected three million over five years. The goal was to re-green approximately 11,000 acres of the 160,000 that burned at a white heat during August and September 2009. The Angeles National Forest, or at least a portion of it, would be reborn.

It has not happened. Only about 25 percent of the seedlings dug into charred slopes, cindered meadows, and blackened canyon floors have survived, a mortality rate that has stunned agency foresters. “When we planted seedlings, conditions were ideal in terms of soil composition and temperature, rainfall and weather trends,” one of them told the LA Times. “Then the ground dried out and there just wasn’t enough moisture after we planted.”

The Forest Service has gone back to the drawing board, shrinking the number of acres to be planted and, where possible, switching to tree species that are indigenous to the San Gabriel Mountains.

Critics are unappeased. One of them [mused], “The reality we live in is a Mediterranean climate, and there is just not enough water to create what they have in mind. I do not believe they will succeed because this is Southern California, not rain-drenched Oregon.”

This climatic reality is part of the reason why there has been a very long history of flawed regeneration projects on county and federal lands in the San Gabriels….

The Forest Service has never quite learned L.A. County’s hard-won lesson. Despite what federal foresters long have understood about the low fertility of local soils, mercurial weather patterns, and steep canyon walls, they have repeatedly endeavored to re-engineer the San Gabriels’ ground cover. …

Why this institutional memory has not surfaced to check the Forest Service’s current aspirations to reforest portions of the Angeles is an open question.

More to the point, the agency’s century-long inability to rearrange the San Gabriels’ biota to its liking is a powerful rejoinder to those who so confidently believe that planting trees, indiscriminately and in large number, will help resolve some of the challenges that a climate-changed world is bringing. [most hyperlinks omitted here]

Endnote: The evidence Miller cites is not the only evidence that the Forest Service “never quite learned [its] hard-won lesson.” The Forest Service’s Wyoming Study in the early 1970s came to similar conclusions. In the early 1970s, following a bark-beetle infestation and big clearcuts in lodgepole pine in Wyoming, the Forest Service began a massive re-planting effort. The logging went well. The planting did not. And the very large clearcuts raised controversy, in part fueled by the failed planting effort. The saplings died for the most part, scorched by the sun in the barren clearcuts. Many were planted again, and they too died, as documented in “Forest Management in Wyoming, 1971” (cited here). The Wyoming Study, led in part to the Church clearcutting guidelines that made their way into the National Forest Management Act of 1976. You’d have thought that the Forest Service would have been very wary of future adventures in re-planting. But no.

Now, in Southern California the Forest Service has, once again, wandered into a planting effort that has failed for pretty much the same reasons. Only this time they had a ‘partner’ – the National Forest Foundation — and outside money from “carbon offsets” government subsidies.

Update:  According to Cascadia Forest Defenders:  “On Sunday April 22, in celebration of ‘Earth Defense Day’ and in solidarity with Occupy the Trees, Cascadia Forest Defenders installed a tree sit in the Goose Project timber sale known as ‘Golden.'”

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The Goose timber sale on the Willamette National Forest has been discussed on this blog before.  This week, the Goose got some more press as forester Roy Keene wrote an opinion piece in the Eugene Weekly.

The Goose Timber Sale near McKenzie Bridge is a large Forest Service logging operation posed as a beneficial project for the forest and the people. But local people aren’t buying the sales pitch. They say this giant timber sale will, in truth, be as bad for the forest as it will for them….The reality disconnect of this 38-million-board-foot timber grab reducing wildfire bothers many forest-savvy locals as much as the coming war zone. McKenzie Bridge residents don’t look forward to day-long droning of chainsaws, the roar of jet helicopters, loaded trucks rumbling by in swirling dust or the increase in wildfire danger from summer logging operations….

Instead of logging large trees from distant upland slopes, remove small trees and excess vegetation around residences and thin forest understories along roads. Contract smaller, less-mechanized, but equally effective fuel reduction projects locally. Quit subsidizing distant mega-mills with huge helicopter and skyline logging operations at a loss to the public. Instead, redirect these subsidies toward activities like putting steel roofing on vulnerable community buildings and creating ponds for wildlife that would serve simultaneously as water points for future fire fighting.

The Goose Timber Sale does one thing really well. It highlights the inherent dishonesty, inequity and wastefulness of the archaic federal timber sale program. As one citizen said, “It looks as if you’re going to turn me into a 67-year-old tree sitter with this Goose Project. Bad news for us all!”

Just down the valley a piece, the Salem Weekly also took a look at the Goose timber sale with this article:

Conflict is building between the U.S. Forest Service and residents of a small community along the McKenzie River over a logging plan. Jerry Gilmour, a part-time resident of the McKenzie Bridge community, located in the Willamette National Forest, was astonished to learn in early February that 2134 acres there were about to be commercially logged and 588 acres “non-commercially thinned” by the Forest Service (USFS). Research into the matter left Gilmour angrier as he learned how the Goose Project, as the USFS calls it, came about….

According to critics, the main problems are as follows:

1 – The only warning for the large project was a small legal notice among many others in a Eugene newspaper –more than 50 miles from McKenzie Bridge – in 2010.
2 – The 45-day public comment period passed in 2010.
3 – The USFS chose to log mature forests in riparian reserves where logging is prohibited, and also to log mature trees which provide habitat for the spotted owl, a threatened species.
4 – Despite the fact that the project is located within a major watershed, involves critical habitat and the destruction of old growth trees, the USFS did not prepare an Environmental Impact Statement, but only an abbreviated document called an Environmental Assessment (EA).
5 – In a 2011 notice informing residents of a boundary line survey last year, the USFS did not mention a word about the logging project.

…Gilmour says he quickly learned the project was “massive,” including road-building and spraying of herbicides. It means the cutting of enough timber to fill 9,000 logging trucks in an area rich with elk deer, grey fox, black bear, bobcats and cougars.

Doug Heiken of Oregon Wild also objects to calling the project primarily fire protection. Heiken told Salem Weekly, “900 acres of the sale have nothing to do with fire risk reduction because they are older forests that have most of their fuel suspended high above the ground.” Heiken says logging will actually increase hazard on these 900 acres of mature forest….

Gilmour remains undaunted. “We are hoping that the USFS will do the right thing… put the brakes on and redesign this project with the good of the community, the wildlife and the forest in mind rather than the timber company’s bottom line.” He is “absolutely” in favor of the possible lawsuit against the USFS. “Litigation may be the only real way to bring this madness to a screeching halt.”

For more on community effort to stop the Goose Timber Sale, go to www.savemckenziebridge.com

A copy of the complaint can be found here.  Meanwhile, a copy of the press release from the plaintiffs is printed below and the Bozeman Daily Chronicle’s article can be found here.

Weekend Update: An attorney with the Cottonwood Environmental Law Center – who happens to live directly next to the Bozeman Watershed logging project area – provided this very enlightening comment over the weekend, which deserves to be highlighted here:

I helped write the administrative appeal for the enviro groups on the first round of this. We won on soils issues. I submitted a FOIA request for the project record on the BMW project back in 2010.

Here is language from the agency’s hydrologist that I found in an internal document:

The BMW implemented assumes that the BMW treated acres are totally within
the wildfire area so the reduced %>natural figures are probably an over estimation of potential sediment reduction since the wildfires would burn areas outside of BMW treatment boundaries and not all areas within BMW treatment areas would be subjected to wildfire.

Bottom line is that the BMW project, if fully implemented, could result in a modest reduction in sediment yields from a moderate to large size wildfire in either watershed. Since the sediment standard is 30% over natural for each drainage the resulting sediment yields would still be well over standard and pose a challenge to the Bozeman Municipal Water Treatment Plant.

Mark T. Story
Hydrologist
Gallatin National Forest
PO 130 Bozeman, Mt
59771
406-587-6735
[email protected]

This project is particularly troubling for me because it is nearly adjacent to my home, which is in Cottonwood Canyon, the drainage west of Hyalite. The agency is seeking to log in Cottowood. How is sediment going to be reduced by logging in a different drainage that is six miles away from a reservoir? I bowhunt for deer and elk in the Cottonwood side of the project area. This project will destroy my hunting grounds.

I took photos of the project area, approximately six miles away from the drainage in the Cottonwood side. The photos are on our website: http://cottonwoodlaw.org/work.html

Finally, The Wilderness Society submitted comments against this project years ago. They had a former UM soil scientist working for them that heavily criticized the project. They just aren’t talking about it now because it would be politically unpopular and they are worried about funding.

Bozeman, MT –The Alliance for the Wild Rockies and Native Ecosystems Council, filed a lawsuit on Tuesday in Federal District Court against two proposed logging and road-building projects.  The Bozeman Municipal Watershed (BMW) timber sale is a 10-year logging project which authorizes more than 3,000 acres of logging, including 200 acres within the Gallatin Fringe Inventoried Roadless Area, 1,575 acres of prescribed burning, and 7.1 to 8.2 miles of new road construction.  The East Boulder Timber sale would authorize 650 acres of logging and 2.1 miles of new road construction.

“The last thing you want to do in a healthy watershed is bulldoze in 7 miles of new logging roads,” said Michael Garrity, Executive Director of the Alliance for the Wild Rockies.  “This is the fifth time the Forest Service has tried to push the Bozeman Watershed timber sale which has been successfully challenged four times since the 90s, including our successful administrative appeal last April.  Simply stated, the agency’s proposal breaks a number of laws and this time around is no different.”

The groups also say the two timber sales would log lynx critical habitat, core grizzly bear habitat, and destroy habitat for other old growth dependent species.  “The two timber sales do not comply with the best available scientific threshold to maintain open road densities of one mile or less per square mile of habitat in grizzly bear habitat,” Garrity said.  “Moreover, the logging and road building will also dump sediment into creeks that contain native westslope cutthroat trout, Montana’s State Fish, which is already listed as a ‘Species of Special Concern’ due to habitat destruction and rapidly declining populations.”

“The Forest Service is determined to force bulldozers, logging trucks and helicopters into the Sourdough Creek, Hyalite Creek and South Cottonwood Creek drainages,” said Steve Kelly.  “We are equally determined to protect the outstanding wildlife habitat, water quality and recreational opportunities these federal public lands provide to Bozeman residents and visitors who rightfully expect to encounter nature in a peaceful and quiet forest landscape.”

“Bozeman Creek and Hyalite Creek are already listed as ‘impaired,’ meaning they’re not in compliance with state water quality standards or the provisions of the federal Clean Water Act,” Kelly explained.  “Yet, despite an already degraded aquatic environment, this project will increase sediment loads in the streams both during and after logging.  Sediment sources from past logging projects should be cleaned up first to protect both native westslope cutthroat trout and Bozeman’s drinking water supply from harmful sediment pollution.”

“The supreme irony of this project is that while Montana’s fish and wildlife agency is spending tons of money struggling to recover the population of this native fish and keep it from being listed as an Endangered Species, the federal government is promoting the primary cause of its decline — more logging and sedimentation in its remaining range,” concluded Kelly.

Sara Jane Johnson, PhD., is the Director of the Native Ecosystems Council and a former Gallatin National Forest wildlife biologist.  Johnson contends the Forest Service is converting its emphasis for both areas to fuels management, which violates the agency’s own Forest Plan.

“The Forest Service loves fuels management because it promotes logging – and now, apparently nothing else matters,”  Johnson said, noting that the federal agency is ignoring the adverse impacts the timber sales will have on water quality, fish, wildlife, and recreation.  “The Bozeman watershed timber sale is scheduled to last 10 years. What that means is that the people of Bozeman are going to have to deal with logging trucks, road building and helicopters in their favorite back yard recreation area for the next decade.”

Johnson also says that the increase in road density will adversely affect grizzly bears and lynx, which violates the Endangered Species Act.  “Under the Gallatin National Forest Service’s lynx conservation strategy, 55,000 acres of lynx critical habitat can be logged before they claim there is any impact to lynx, “ Johnson continued. “This is an insane, irrational extinction strategy, not a recovery strategy. The government is supposed to work to protect lynx critical habitat, not destroy it.”

“If we want to recover the grizzly bear and lynx and remove them from the Endangered Species list, they need secure habitat on public land,” Johnson explained.  “Otherwise they will be forced onto private land where they often end up dead.”

“The Forest Service is also ignoring all road density standards for grizzly bears” Johnson concluded.  “The last place the agency should build more roads is in critical lynx habitat and occupied grizzly bear habitat – especially when it is also Bozeman’s municipal watershed.”

The East Boulder project is being litigated for many of the same reasons, Garrity explained, “except in addition to more road building, the Forest Service also blatantly ignores its own Forest Plan requirements to preserve big game winter range standards.”

“The Project area contains important winter range for mule deer and moose,” Garrity continued.  “The Forest Plan requires the Forest Service to manage big game winter range to meet the forage and cover needs of deer, elk, moose, and other big game species. Winter range provides important canopy cover that intercepts snow, blocks wind, and reduces snow crusting, making movement for big game less difficult.”

“The elimination of hundreds of acres of winter range in the project area coupled with the disturbance effects of winter logging will negatively affect the already below-average population of mule deer in violation of the Forest Plan, the National Forest Management Act and the National Environmental Policy Act,” Garrity concluded.  “We have been involved in every step of this process, made the agency aware of our concerns and it continues to push the projects forward.  So now, for the good of the fish, wildlife, big game and water quality, we’re forced to take them to court.  It’s not something we prefer to do, but in the end, judicial review is part and parcel of our system of government and we are using it to challenge the government’s actions exactly as it was intended.”

The entire report, Large Predators Limit Herbivore Densities in Northern Forest Ecosystems, is available here.

ScienceDaily (Apr. 9, 2012) — A survey on the loss in the Northern Hemisphere of large predators, particularly wolves, concludes that current populations of moose, deer, and other large herbivores far exceed their historic levels and are contributing to disrupted ecosystems. The research, published recently by scientists from Oregon State University, examined 42 studies done over the past 50 years.

It found that the loss of major predators in forest ecosystems has allowed game animal populations to greatly increase, crippling the growth of young trees and reducing biodiversity. This also contributes to deforestation and results in less carbon sequestration, a potential concern with climate change.

“These issues do not just affect the United States and a few national parks,” said William Ripple, an OSU professor of forestry and lead author of the study. “The data from Canada, Alaska, the Yukon, Northern Europe and Asia are all showing similar results. There’s consistent evidence that large predators help keep populations of large herbivores in check, with positive effects on ecosystem health.”

Densities of large mammalian herbivores were six times greater in areas without wolves, compared to those in which wolves were present, the researchers concluded. They also found that combinations of predators, such as wolves and bears, can create an important synergy for moderating the size of large herbivore populations.

“Wolves can provide food that bears scavenge, helping to maintain a healthy bear population,” said Robert Beschta, a professor emeritus at OSU and co-author of the study. “The bears then often prey on young moose, deer or elk — in Yellowstone more young elk calves are killed by bears than by wolves, coyotes and cougars combined.” In Europe, the coexistence of wolves with lynx also resulted in lower deer densities than when wolves existed alone.”

In recent years, OSU researchers have helped lead efforts to understand how major predators help to reduce herbivore population levels, improve ecosystem function and even change how herbivores behave when they feel threatened by predation — an important aspect they call the “ecology of fear.”

“In systems where large predators remain, they appear to have a major role in sustaining the diversity and productivity of native plant communities, thus maintaining healthy ecosystems,” said Beschta. “When the role of major predators is more fully appreciated, it may allow managers to reconsider some of their assumptions about the management of wildlife.”

In Idaho and Montana, hundreds of wolves are now being killed in an attempt to reduce ranching conflicts and increase game herd levels. The new analysis makes clear that the potential beneficial ecosystem effects of large predators is far more pervasive, over much larger areas, than has often been appreciated.

It points out how large predators can help maintain native plant communities by keeping large herbivore densities in check, allow small trees to survive and grow, reduce stream bank erosion, and contribute to the health of forests, streams, fisheries and other wildlife.

It also concludes that human hunting, due to its limited duration and impact, is not effective in preventing hyper-abundant densities of large herbivores. This is partly “because hunting by humans is often not functionally equivalent to predation by large, wide-ranging carnivores such as wolves,” the researchers wrote in their report.

“More studies are necessary to understand how many wolves are needed in managed ecosystems,” Ripple said. “It is likely that wolves need to be maintained at sufficient densities before we see their resulting effects on ecosystems.”

“The preservation or recovery of large predators may represent an important conservation need for helping to maintain the resiliency of northern forest ecosystems,” the researchers concluded, “especially in the face of a rapidly changing climate.”

The Xerces Society for Invertebrate Conservation is an international nonprofit organization that protects wildlife through the conservation of invertebrates and their habitat.  They have just released this new literature review summarizing the effects of logging, road building and burning on snails and slugs, which was funded by the Forest Service/BLM Interagency Special Status and Sensitive Species Program.

Summary:
Snails and slugs are essential components of forest ecosystems. They decompose forest litter, recycle nutrients, build soils, and provide food and calcium for birds, amphibians, reptiles, small mammals, and invertebrates. Although mollusks have been a crucial part of the ecology of temperate forests for millennia, recent loss and fragmentation of natural habitats due to clearcut logging, road-building, and altered fire regime have resulted in both extinction and extinction risk for many mollusk species (e.g., Curry et al. 2008). Mollusks (including aquatic species) represent 20% of all threatened animals, and 37% of known animal extinctions since 1600 A.D. (Seddon 1998 in Dunk et al. 2004). In an era where the extinction rate is an estimated 400 times the natural rate (reviewed in Werner & Raffa 2000), it is important for land managers to take mollusks into consideration when developing or re-evaluating strategies for managing forests ecosystems to achieve forest health and biodiversity conservation goals.

Key findings of the review include:
•    While some level of exposure in the physical environment is tolerated by certain mollusks, most species are extremely sensitive to temperature and moisture extremes.
•    Research suggests that the majority of snails and slugs are dependent on litter from deciduous trees and have higher abundances in multispecies forests with strong broadleaf components. Additionally, mollusks in deciduous forests appear to rebound from disturbance more quickly than in coniferous forests.
•    Forests with old-growth characteristics supply microhabitat and microclimate conditions capable of supporting a diversity of mollusks, and forest age is often positively correlated with mollusk richness and abundance.
•    Numerous studies stress the importance of refugia in gastropod recolonization potential and community resilience following forest disturbance. Since land mollusks are small animals with limited mobility and dispersal capabilities, the maintenance of refugia in disturbed habitat is particularly important for this group. Refugia should include logs, snags, fallen branches, and other forms of coarse woody debris, as well as areas with thick leaf-litter. Woody debris and litter provide islands of habitat, food, and protection from microclimatic extremes, increasing species’ tolerance of temporarily inhospitable environments.
•    Research suggests that in order to reduce microclimate extremes and protect gastropods, partial cuts should be favored over clearcuts, aggregated (group) retention over dispersed retention or thinning, and larger group retention over smaller group retention. In particular, harvesting with large group retention helps to maintain pre-harvest boreal gastropod assemblages and will likely conserve boreal gastropod species if used as a tool for biodiversity management.
•    Fragmented habitat limits the dispersal and post-disturbance recolonization potential of gastropods. Tracts of intact forest and connected groups of old trees help provide dispersal corridors for gastropods and can lead to significant increases in the survival of disturbance-sensitive species.
•    Research suggests that techniques that minimize soil compaction and damage to (or removal of) the organic layer favor survival of gastropods. For example, Timberjacks have been found to cause less damage to the organic mat and resident invertebrate populations than feller bunchers, single-grip harvesters, and grapple skidders.
•    Due to the tendency of mollusks to avoid non-vegetated and/or dry environments, even narrow, unpaved roads with low traffic densities are barriers to the dispersal of mollusks.
•    Numerous studies have found negative and long-lasting responses of gastropods to fire, including population extirpation and reductions in abundance and species richness. Small burns surrounded by unburned plots have been most successful at maintaining gastropod community structure. Although there is little information comparing gastropod responses to differences in burn severity and frequency, it is presumed that a fire regime involving low-intensity burns at infrequent fire-return intervals (>5 years) would best maintain gastropod communities.

Download the entire literature review here.

Over the past few months, this blog has explored some of the differences between the ways smaller, grassroots non-profit conservation organizations go about their campaigns compared with the actions taken (or not taken) by the largest, most well-funded conservation groups in America. We’ve covered this dynamic as it relates to logging, lawsuits and collaboration…but not how it impacts solar energy development on public lands.

This weekend, the LA Times took at how one smaller grassroots group – the Wildlands Conservancy – working their tails off to protect southern California’s Mojave Desert feels abandoned by many of the biggest, and best known, conservation groups in the country.

AMARGOSA VALLEY, Calif. — April Sall gazed out at the Mojave Desert flashing past the car window and unreeled a story of frustration and backroom dealings. Her small California group, the Wildlands Conservancy, wanted to preserve 600,000 acres of the Mojave. The group raised $45 million, bought the land and deeded it to the federal government.

The conservancy intended that the land be protected forever. Instead, 12 years after accepting the largest land gift in American history, the federal government is on the verge of opening 50,000 acres of that bequest to solar development. Even worse, in Sall’s view, the nation’s largest environmental organizations are scarcely voicing opposition. Their silence leaves the conservancy and a smattering of other small environmental organizations nearly alone in opposing energy development across 33,000 square miles of desert land.

“We got dragged into this because the big groups were standing on the sidelines and we were watching this big conservation legacy practically go under a bulldozer,” said Sall, the organization’s conservation director. “We said, ‘We can’t be silent anymore.’ “

Read the entire LA Times article here.

Last July, we blogged about a lawsuit filed against the Forest Service challenging its reconstruction of the Green Mountain lookout within Washington’s Glacier Peak Wilderness.

A week ago, federal district judge John Coughenour ordered the Forest Service to remove the lookout. It wasn’t a particularly close call either: “The Forest Service erred egregiously by not conducting the required necessity analysis before embarking on such an aggressive course of action,” the judge wrote regarding the Forest Service’s decision “to fully disassemble the lookout, transport the pieces off-site by helicopter, construct a new foundation on site, fly new and restored lookout pieces back in to the site, and reassemble the lookout.”

The judge was unpersuaded that the National Historic Preservation Act was relevant, even though the lookout is on the national registry. He concluded the NHPA imposes procedural, not substantive, duties on the Forest Service and, thus, could not trump the Wilderness Act’s substantive preservation mandate.

However, he did find that “historical use” is a valid management goal under the Wilderness Act. Continuing the line of reasoning first adopted in FSEEE’s High Sierra Hikers case, he faulted the Forest Service for failing to assess whether maintaining the lookout in the wilderness and using helicopters to do so, were necessary to realize the lookout’s historical virtues. For example, he pointed to other historic lookouts that had been preserved by removing them from the wilderness and rebuilding them at ranger stations as visitor interpretative facilities.

We’ve certainly discussed and debated the proposed Rocky Mountain Front Heritage Act from Montana’s Senator Max Baucus on this site before. However, a new article in today’s Great Falls Tribune covers one aspect of this issue that we definitely haven’t discussed before.

You’ll have to read the entire article to more fully understand the issue, but the general gist is that in Teton County, Montana – which includes much of the Rocky Mountain Front landscape – old public County Road No. 380 was unilaterally declared private in 1988, which closed off public access to not only state lands, but also portions of the Lewis and Clark National Forest in the Deep Creek area.  Today, old County Road No. 380 terminates near a large horse barn on land owned by Late Show host David Letterman.  As the Great Falls Tribune reports:

What makes the fight over old County Road No. 380 unique is that it accesses public land that abuts the proposed 17,000-acre “Deep Creek Addition” to the Bob Marshall Wilderness Complex contained in Sen. Max Baucus’ “Rocky Mountain Front Heritage Act.”  If Baucus’ bill passes and becomes law, the new federally designated wilderness area would be inaccessible from the east.

Anderson pointed out that the Heritage Act’s supporters have promoted the measure with assurances that it would maintain access for hunters and recreationists. Anderson said if old County Road No. 380 isn’t reopened to the public, only one landowner will have access to that new wilderness — Late Night talk show host David Letterman — who owns the only piece of private land adjacent to wilderness proposed by the Heritage Act.