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And now for something completely different…

At a recent Breakthrough Institute conference, I was surprised to hear that some agencies consider that the FARS (Federal Acquisition Regulations) hamper their innovation for various reasons, and have an alternative, called “Other Authorities”.  I am the last person to ask about purchasing or contracting or grants and agreements.  But perhaps other TSW-ites are more familiar with this world?  I met an interesting fellow named Arnab Datta who works for a group called Employ America. Here’s a link to a paper his group generated called “Seven Ways the Executive Branch Can Turbocharge Green Industrial Policy.”  Yes, indeed, it was a serious Coastal Wonkfest, and I was invited to add non-Coastal diversity.

I was thinking we’ve been trying to find commercial uses for woody material for some time in terms of fuels reduction on both private and public land,  for the last 30 or so years, and perhaps this authority might be useful to USDA. It seems to be related to green energy, and perhaps that’s not the best use of the material, but as Willy Sutton said.. “go where the money is”. Through bioenergy and natural climate solutions, perhaps USDA has hit the technology big time and should explore the opportunities that playing with the big technology folks unleashes.

The paper also has thoughts on demand-side use of government purchasing power.

By guaranteeing that demand will be there to validate new capacity, the government can ensure decarbonization progress in the event of a recession or other economic downturn.  While now commonly used for vaccine development, advance market commitments are only starting to be contemplated for green uses.

There are other interesting ideas in there, some possibly only comprehensible to economists in the TSW community.

Here’s their  write-up on Other Authorities. Who knew the gory details of DARPA procurement? Or wondered how the fed $ got to Pfizer and J&J?

Given the technological and commercial uncertainty inherent in the green energy transition, agencies should be prepared to use every tool at their disposal to meet contingencies. OTA is one such tool. While it has been most successfully utilized by the Defense Advanced Research Projects Agency (DARPA), it has been granted to 11 agencies (with varying restrictions).43 Table 1, below, lists the agencies with OTA powers. OTAs have been extended to more agencies as the tool’s efficacy was consistently demonstrated. In 1989, Congress passed the National Defense Authorization Act for Fiscal Years 1990 and 1991, which granted DARPA the flexibility to enter into agreements through other transactions.  In the following years, Congress expanded that authority to include prototype development, research, and making advance market commitments.46 In 2016, the OTA was expanded even further to allow follow-on production authority, which permitted successful prototypes to enter full production without the red tape or onerous requirements that tend to benefit larger businesses with compliance budgets. This Congressional expansion was pivotal in the wake of the COVID-19 pandemic, as both the Johnson & Johnson and Pfizer vaccines were purchased using OTAs.

DARPA’s use of OTA for vaccine development is one example of many in the expansive use of OTAs for promotion of technological advancement. In the early 1990s, DARPA used OTA to enter into an agreement with seven jet engine manufacturers, NASA, and the United States Air Force to create a joint-funding agreement for the Integrated High-Performance Turbine Engine Technology program. A major goal of the program was to advance aircraft and missile turbine engines by using ceramic matrix composite components. Today’s most efficient and high-performing jet engines, such as the F119 and F-135, have better oxidation at higher temperatures, fly longer, and weigh less because of these ceramic matrix composite components. There is a vital through line connecting OTA investment in ceramic fiber research and production and today’s cutting-edge jet engines.

OTA contracts can be structured to benefit the government’s balance sheet, rather than simply “giving away” funding to the private sector. DARPA has used its OTA to reap significant returns on its investment and scale up innovative technology for commercial use. In the 1990s, DARPA provided funds to the Environmental Research Institute of Michigan at Ann Arbor (ERIM) to create an interferometric synthetic aperture radar for terrain elevation mapping. The radar provided necessary military capabilities for terrain and elevation data collection and analysis in any weather conditions, day or night. Unfortunately, no DOD office had sufficient operating funds to maintain full ownership of the radar. Rather than abandon the project, DARPA was able to use an OTA to contract out the radar for commercial purposes. In technical terms, DARPA initiated an OTA with DARPA; ERIM; and a private company, Intermap USA, in which the company agreed to pay all operating, maintenance, and upgrade costs of the radar. Intermap paid royalties to DARPA for the radar and DARPA eventually recouped the complete cost of the radar’s development through this licensing agreement.51 The radar formed the basis of Intermap’s mapping technology, and as the company improved the radar, it became a leading firm in geospatial content development. By using OTA to lower operating costs on a ucial radar and receive payment for the investment in the radar, DARPA saved millions of dollars while helping advance the technological frontier.

NASA has also used OTA to stimulate the commercial market for innovative technologies. In 2006, NASA created the Commercial Orbital Transportation Services program with the goal of advancing private technologies for space transportation services. NASA awarded funding under its OTA through the Commercial Orbital Transportation Services program to SpaceX, which resulted in the Falcon 9 launch—“the first private rocket capable of carrying humans to space.” From 2006 to 2014, NASA obligated more than $2.2 billion of appropriated funds under OTA to spur public-private partnerships and advance national space initiatives.

Finally, OTA can be used to overcome hurdles that are limiting private participation in federal contracts. In 2010, the Department of Energy’s Advanced Research Projects Agency-Energy (ARPA-E) entered into an OTA agreement with an oil company to research and develop new drilling technology with the goal of improving the performance of geothermal energy wells.  ARPA-E estimated that this technology could unlock 100,000 or more megawatts of geothermal energy by 2050. However, the company was concerned about “march-in rights” that allowed the government to take control of a patent if certain conditions were not met. In response, ARPA-E crafted an OTA that addressed the company’s concerns. While there are sound reasons why the federal government may want to “nationalize” intellectual property in certain situations,  OTA provides the flexibility to go in another direction if existing intellectual property restrictions are severely limiting private participation.

Furthermore, ARPA-E included a clause requiring any invention developed under the agreement to be substantially manufactured in the United States—promoting domestic manufacturing through an OTA agreement.
These examples demonstrate that OTA provides agencies the authority to engage in creative contractual structures in a manner that can overcome roadblocks to private investment and development while achieving important public policy purposes. The 11 agencies face some limitations on their OTAs; a helpful summary is available in Table 1 below.  Decarbonization is an all-hands-on-deck challenge, and each agency should strive to use their OTA alongside flexible appropriations to connect their missions and goals with the steps needed to advance the green energy transition.

I posted Table 1 in an image above.

While every agency should review their OTA in alignment with the green energy transition, DOE and ARPA-E’s missions are well aligned to the goals of green industrial policy. With permanent OTA, ARPAE is in the best position to ensure long-term, innovative, clean energy solutions. The ARPA-E director has complete discretion in utilizing OTAs. Though Congress provided the DOE with ample oversight in entering into agreements through other transactions, DOE has not taken full advantage of its authority. From 2010-2014, DOE entered into 14 OTA agreements and ARPA-E had 12 OTA agreements, while NASA completed more than 13,000 OTA agreements in the same four-year span. 8 ARPA-E was appropriated $450 million in FY 2022 and currently has $755 million unobligated that could be used to further ARPA-E’s mission to “decrease our nation’s dependence on foreign energy sources, reduce greenhouse gas emissions, improve energy efficiency across the board, and maintain or reestablish U.S. scientific leadership in the energy sector.” Department of Energy Secretary Jennifer Granholm and Dr. Jennifer Gerbi, the Acting Director of ARPA-E, should be exploring opportunities to “stretch” the appropriated and unobligated funds to enhance the United States’ energy security by advancing green industrial policy to ensure resilient and long-lasting clean energy  infrastructure.

Decarbonization is a far heavier lift than the Space Race. Back then, we only had to put one ship on the moon. Today’s challenges require the government to engage with nearly every sector of the economy. As in 1958, when OTA was first authorized, we face a generational challenge that will require unprecedented coordination, collaboration, and dedication between the federal government and private industry. As the price of energy continues to rise, families across the country remain subject to the market risks that cause inflationary pressure and price volatility in fossil fuels. It is time for every OTA to be scrutinized and utilized to promote economies of scale through deflationary sources of energy by accelerating investments in the green energy transition.

From a press release, Thursday, October 13, 2022

Washington, D.C. – Oregon’s U.S. Senator Jeff Merkley, Chairman of the Interior Appropriations Subcommittee, and Senator Michael Bennet (D-CO), Chairman of the Subcommittee on Conservation, Climate, Forestry, and Natural Resources, sent a letter to U.S. Forest Service Chief Randy Moore highlighting the significance of Tribal stewardship over lands and waters that make up the National Forest System, and the need to continue collaborative participation from Tribal leadership and governments and the federal government. In their letter, the Senators request the development of a policy for Tribal co-management and stewardship of federal forests and grasslands.

…

We encourage the Forest Service to initiate a process for engaging tribal perspectives on co-stewardship, making recommendations for statutory language to further the goals of co-stewardship and to better integrate the core principles of tribal co-stewardship into federal land management.

For years, cattle have illegally entered the Valles Caldera National Preserve from neighboring U.S. Forest Service grazing allotments, damaging riparian areas and important wildlife habitat. As one public lands advocate points out below, “Livestock trampling riparian areas of these protected lands has gone on far too long with federal land managers doing too little to stop it.”

Seems like this is example of a “hot potato” being passed between the National Park Service and U.S. Forest Service. This week, conservation groups—including the organization I work for—initiated legal action over trespass livestock grazing in Valles Caldera National Preserve. Below is the press release and link to the notice of intent to sue.

SANTA FE, NEW MEXICO—WildEarth Guardians, Western Watersheds Project, and Caldera Action today filed a notice of intent to sue the National Park Service over Endangered Species Act violations related to illegal livestock grazing in the Valles Caldera National Preserve (VCNP) in the Jemez Mountains of northern New Mexico.

The Valles Caldera was set aside as a National Preserve to protect its unique ecosystems, headwaters, and thriving elk herds. For years, cattle have illegally entered the VCNP from neighboring Forest Service grazing allotments, causing damage to streams, riparian areas, and important wildlife habitat. Despite public outcry from a spectrum of public land users, the Park Service has failed to address the issue.

In his October 2021 confirmation hearing, Park Service Director Charles “Chuck” Sams III promised New Mexico’s Senior Senator Martin Heinrich; “I am committed to figuring a way to ensure that there are no trespass issues.” So far, this promise has gone unfulfilled as over 100 cattle have been documented in the VCNP meadows for most of the past summer.

“I feel a deep sense of betrayal” said Madeleine Carey, Southwest Conservation Manager for WildEarth Guardians. “We were promised this persistent issue would be dealt with and if anything, things have gotten worse. No one from the Park Service has responded to our emails about the cows this summer.”

Even the New Mexico Livestock Board agrees the issue needs attention. In June 2019, NMLB passed a unanimous motion to hold a meeting with the Park Service to develop a solution. Still, the issue of trespass persists. As recently as October 8th, dozens of cattle were spotted in the Valle San Antonio and Valle Toledo, an area closed to cattle grazing under NPS regulations.

“We worked for years with others to get the Valles Caldera into the National Park System because the Park Service has the highest standards of land protection of any federal agency,” said Tom Ribe, Executive Director of Caldera Action, a nonprofit focused on the Jemez Mountains. “We trusted they would protect the Caldera from all sorts of possible damage. They closed the majority of the Preserve to cattle grazing but then looked the other way while cows flooded in across vandalized and damaged fences. We have no idea why the management doesn’t respond to this blatant trespass. It is not consistent with Park Service policies.”

At the beginning of the grazing season in May, volunteers documented the condition of the northern boundary fence between National Park Service and U.S. Forest Service lands. Much of the boundary fence was laying on the ground, cut, or otherwise rendered inoperable. Though the National Park Service has replaced miles of fence, vandalism, tree-falls, and aging fencing continue to allow cattle trespass.

By federal contract, U.S. Forest Service permitted ranchers are not allowed to graze outside of their specific grazing leases. The Forest Service does not enforce the terms of these contracts when the cattle trespass on National Park System lands.

“Livestock trampling riparian areas of these protected lands has gone on far too long with federal land managers doing too little to stop it,” said Cyndi Tuell, Arizona and New Mexico director of Western Watersheds Project. Livestock entering the VCNP have been documented by the Park Service and Forest Service since at least 2017. “It’s frustrating that the Park Service is breaking its promise to New Mexicans to protect the natural resources in Valles Caldera and has let this situation fester for more than five years. Species on the brink of extinction like the Jemez Mountain salamander need swift action, not agency foot-dragging.”

Photos for media use are available here.

[This is a guest post by Leia Barnett, WildEarth Guardians’ Greater Gila New Mexico Advocate.]

There is a collection of poetry by Indonesian American poet Cynthia Dewi Oka titled Fire is Not a Country. I stumble across it while searching for poems about fire. I search for poems about fire because I’ve just been to the Greater Gila where, in all its dynamic unfolding, fire most certainly is a country, is Gila country. I want words that express such a force, lines to describe the wild paradox of destruction and regeneration that come in a fire-affected landscape. Alas, Dewi Oka does not explore such natural regimes; hers are wrenching descriptions of migration, familial love and obligation, political repression, and resistance. And while each human drama could be woven into a metaphor for the processes of the natural world, I’d rather not reach so far. I think the country of fire possesses lessons that apply to life in a different way.

Go to the Greater Gila and you will come away with fire in your eyes, fire in your heart. There is nowhere you can venture within the forest that does not bear the scars of fire. It is the breath and the wind and the soil of the landscape. It is the hand that shapes the tree and the river and the grass. Fire and its aftermath pervade even the loneliest mountain top, the darkest drainage, the rocky outcropping where the she-wolf dens, the mesa top where a bevy of Montezuma quail bed down. You cannot turn away from it. But in your forced witnessing, you discover something magic.

In her poem The Fire, Katie Ford writes:

When a human is asked about a particular fire,
she comes close:
then it is too hot,
so she turns her face–

and that’s when the forest of her bearable life appears,
Always on the other side of the fire.

In the forests of the Greater Gila, I think about what ecologists call disturbance events, the drivers of ecological dynamics that, when taken cumulatively, dictate biodiversity by influencing important structures and processes on the landscape. Like forests, we humans, both individually and as a collective, experience our own disturbance events: the birth of a child, the death of a loved one, political revolutions, wars, pandemics. And similarly, those events are often the drivers of transformative change. But when the fire is too hot, the change too painful, we also often turn our face and look to the forest of our “bearable life,” where our experience takes a more recognizable shape.

Yet our turning away does not smother the fire. It is the same irrational response as a child putting her hands over her face to hide from the monster right in front of her. The hillsides above Willow Creek are devoid of trees save a smattering of charred trunks. I feel exposed and discomfited in their presence. But when I resist the urge to turn my face, when I slow down and look and listen, a different story unveils itself, one of life in a different form. More species of grasses than I can give count to, various leguminous bushes, bugs, birds, and beetles. I think, “Perhaps this is the bearable life, the one that perdures and even thrives in the aftermath of the burn.”

In the Gila, I wonder, what does fire ask of us? Over the summer, we experienced the two largest wildfires in state history burning simultaneously. We grieved and wrung our hands and wondered if our forests would ever be the same. But the thing is, our ideas of sameness are fallacies we’ve created in service of some familiar “bearable life.” The discomfort of the disturbance and uncertainty of the world has led us to fabricate a form of stasis that doesn’t suit a resilient self, a resilient ecosystem, a resilient planet. In our quest for control, we’ve perpetuated stagnation, not to mention genocide, theft, and violent disposession. The Greater Gila teaches us that worlds are sometimes forged in flame. That change often requires us to look at the landscape through a new lens. That life is more resilient than perhaps we give her credit for, and therefore, by design, we are too.

Ford concludes:

You will not know all about the fire
simply because you asked.
When she speaks of the forest
this is what she is teaching you,

you who thought you were her master.

I do not know all about the fire simply because I asked. But I make a promise to the forest to listen when she speaks. And to disclaim the myth of mastery. This is what she is teaching us.

Leia Barnett is the Greater Gila New Mexico Advocate for WildEarth Guardians. 

WildEarth Guardians has submitted an Administration Procedures Act petition for rulemaking to create a national framework for management of conflicts between livestock and native carnivores on National Forest System lands. Below is the press release with additional information, including a link to the actual APA petition.

WildEarth Guardians to Forest Service: Stop allowing killing of tens of thousands of native carnivores

Petition urges U.S. Forest Service to fulfill its legal obligation to mandate carnivore coexistence measures in its grazing program, saving wolves, bears, and other carnivores from slaughter

MISSOULA, MONTANA—WildEarth Guardians has called on the U.S. Forest Service to incorporate wildlife-livestock conflict mitigation measures into its grazing program on over 70 million acres to protect native carnivores from death due to conflicts with privately owned livestock on public lands.

Retaliatory killing of carnivores in response to livestock conflicts—including the mere presence of a carnivore in the vicinity of livestock—is a leading cause of death for species including wolves, grizzly bears, and coyotes. WildEarth Guardians filed a petition to fundamentally change that paradigm, protecting native carnivores’ inherent right to exist on federal public lands.

The Forest Service is legally obligated to mitigate the threat that livestock grazing poses to native carnivores. Currently, however, the Forest Service permits taxpayer-subsidized livestock grazing on 74-million acres of land that it manages—including in prime wildlife habitat—without any binding, enforceable conflict reduction measures in place. When conflicts ensue, carnivores die. The federal government kills tens of thousands of native carnivores every year, killing over 68,000 in 2021 alone, many in response to reported or suspected livestock-carnivore conflicts, and many others are killed preemptively before conflicts occur. And the federal government slaughter figures tell only a portion of the story. In national forests across the American West, state entities and hired contractors are also brought in to kill wolves and other carnivores in response to livestock conflicts.

“The Forest Service has both the legal authority and responsibility to create a proactive, science-based national grazing management framework that prevents these conflicts,” said Lizzy Pennock, carnivore coexistence advocate at WildEarth Guardians. “The agency should take this opportunity to prioritize carnivore coexistence with livestock instead of continuing to rely on its outdated grazing program, which too often results in the retaliatory shooting, poisoning, and strangling of carnivores in their native habitats.”

Wolf-livestock conflicts in Washington State provide an example of how this plays out on the ground. The Forest Service permits livestock grazing in most of the densely forested, rugged terrain that comprises the Colville National Forest. Conflicts between livestock and wolves occur here year after year, and yet the Forest Service has not made any changes to its livestock management to accommodate gray wolves expanding into their historic territory. Over 90% of wolves killed statewide in Washington between 2012 and early 2021 were killed in response to claims of predations on privately owned livestock permitted by the Forest Service in the Colville National Forest.

“For far too long, the Forest Service has simply thrown up its hands and said ‘not it’ when it came to accepting responsibility for the obliteration of wolf packs on federally-managed public land,” said Lindsay Larris, wildlife program director at WildEarth Guardians. “The Forest Service is responsible for creating this problem on the land it manages by issuing grazing permits, yet somehow the agency also claims it has no power in setting regulations for how to manage conflicts between native species and invasive livestock. This rationale defies both the law and basic principles of logic.”

The petition urges the Forest Service to modify its grazing program to incorporate specific, science-backed measures to prevent and mitigate livestock-carnivore conflicts and to stop the carnivore killing that follows, including:

• Creating a minimum one-mile buffer zone between livestock/livestock attractants and known wolf den and rendezvous sites;

• Prohibiting the turnout of young lambs, calves under 200 pounds in weight, and sick or injured livestock, to minimize predation potential; and

• Limiting grazing to open, defensible spaces and prohibiting livestock from grazing unattended by human range riders in remote, heavily treed areas.

A large and growing body of science shows both that non-lethal measures are more effective than killing wildlife for reducing conflict and that the majority of the American public supports the use of non-lethal conflict reduction measures instead of cruel and unnecessary killing.

Excerpt (subscription):

GREENWIRE | Hundreds of Bureau of Land Management staffers have voted to join the National Treasury Employees Union, partly in response to the Trump-era relocation of the bureau’s Washington headquarters and the movement of hundreds of D.C. jobs to the West.

The decisions by about 200 non-supervisory headquarters employees in May, and another roughly 200 in the New Mexico state office in February and in the Taos and Rio Puerco field offices there last spring, were also spurred by the Biden administration’s efforts to undo the Trump BLM reorganization.

They likely will not be the last bureau employees to join the union, NTEU President Tony Reardon said.

“We continue to hear from a lot of BLM employees, not only in New Mexico, but really in states throughout the Western part of the country,” he said. “And so we are right now in the process of determining what the level of interest in those various locations are.”

Today’s under-the-fold news reported on an amicus brief the Onion filed urging the U.S. Supreme Court to protect smart-alecks from state-sanctioned bullies. When a not-very-funny parody of Parma, Ohio’s police department appeared on Facebook, self-righteous cops brought the full force of the state to bear against the perp. Armed with search warrants issued by an equally clueless municipal judge, the city’s finest raided the comic’s house, confiscating his and his roommate’s computers, cell phones, and, horrors, even the gaming console! The SWAT team tossed the miscreant into jail for four days, charged him with the crime of disrupting public services using a computer, prosecuted, and, wait for it . . . LOST when the jury found him innocent (the good citizens of Parma prevail).

After the victim recovered from eating Ohio jail food, he sued the city for violating his First Amendment rights. A Sixth Circuit Trump/Trump/Bush panel dismissed the case on the grounds that “qualified immunity” protects even the dumbest jackbooted thugs from accountability. Now the Supreme Court is being asked to weigh in.

This reminds me of my favorite U.S. Forest Service story of idiotic can’t-take-a-joke overreach. In 1992, during the height of the Timber Wars, the “Environmental Air Force” — Lighthawk — purchased newspaper ads showing Smokey Bear with a chainsaw behind his back and the tag-line “Say it Ain’t So, Smokey.”

The Timber/Fire Service was not amused. Forest Service Chief Dale Robertson threatened to sue Lighthawk for unauthorized use of Smokey’s image and name. Feeling its speech chilled, Lighthawk sued first (anyone who knew Dale should not have felt threatened — his bark was mild and his bite non-existent).

Proving that no judge is above punning when given half a shot, Judge Dimmick concluded:

By ruling that the 16 U.S.C. § 580p-4(a) and 36 C.F.R. § 271.3 are unconstitutional as applied to LightHawk the Court by no means intends to create an open season on Smokey Bear. While the question is not before the Court the government can likely regulate commercial uses of Smokey Bear as allowed by USOC. Those portions of the regulatory scheme addressing solely commercial uses remain intact. However, the statute and regulation, which impose content based restrictions on non-commercial uses, cannot be applied to LightHawk’s purely expressive political speech.

Lighthawk, The Environmental Air Force v. F. Dale Robertson, 812 F. Supp. 1095 (1993 W.D. Wash.).

Excerpts from a UC Berkeley Forest Research and Outreach blog post, with info aimed at landowners. It reminds us that thinning and fuels reduction isn’t only about reducing fire intensity/severity: it’s also about forest health.

What is forest resilience? Forest resilience is a measure of adaptability. It focuses on retaining a forest’s essential structure and composition to a range of stresses or complex disturbances. In other words, a resilient forest may lose some trees to drought, fire or insect attack, but the mortality rate will not overtake the forest’s ability to continue growing trees and provide habitat. Some will die, but many will live.

Today’s [Sierra] forests have huge increases in basal area and tree density compared to the historical record. Historically, forests were generally low in density yet highly variable in their structure, with open patches and clumps of trees. Twenty-two trees per acre was not uncommon in the Sierras, but those 22 trees were huge! The older and bigger trees get, the more adaptations they have, like thicker bark, a high canopy and higher levels of resilience to disturbances. We have normalized high density, homogeneous stand structure and high competition forests that would not have occurred historically. Today’s forests are more vulnerable to fire and drought related mortality due to a legacy of timber harvesting in early 1900’s that focused on large tree removal; a century of fire suppression policy and action, and climate change effects such as less humidity recovery in the night.

…

Timber harvesting or commercial thinning:

• Sometimes you have to commercially thin in order to restore lower density forest conditions;
• You can leverage saw logs/forest products to pay for other management activities; and
• It is effective in reducing tree density in the canopy and ladder fuels and reduces competition for the remaining trees.

Commercial thinning plus prescribed fire: Very effective in reducing tree density, ladder fuels and surface fuels.  Combining meaningful thinning and prescribed fire can mitigate fire hazard and improved the growth and vigor of your trees to maximize resistance and resilience to wildfire and drought-related tree mortality!

At the risk of starting another round of acrimonious series of rants, here’s a well-written article from Audubon’s magazine, “It’s the Moment of Truth for Saving the Northern Spotted Owl.” It features some familiar names, such as Susan Jane Brown, senior attorney and wildlands program director with the Western Environmental Law Center, and Paul Henson, who led the US F&WS recovery program for the bird until his retirement in June. But also two folks from Green Diamond Resource Company who are working to save spotted owls on “industrial” timberland — and having some success.

Henson “says the situation calls for action on multiple fronts: Preserve the best remaining habitat, control the Barred Owl, and manage forests to avoid the most serious wildfires.”

These are points we might discuss, respectfully.

On the last point, for example, I agree that we need to manage forests — whether designated NSO habitat or not — to avoid the most serious wildfires. “That does not mean aggressively logging healthy forests, Henson stresses; what’s needed is targeted thinning and prescribed burning.”

IMHO, that includes targeted thinning and prescribed burning in late-successional reserves where stocking and fuel loads are higher than can be maintained going forward. Thinning being “commercial logging.” Like it or not, “commercial logging” is an important tool for conserving not just owls, but many other species and forest types. And Rx fire is risky, of course. To do nothing assures the NSO’s continued decline.

Maybe the folks involved with the NW Forest Plan revision process will consider all this.

Thanks to Nick Smith for including the article in his Healthy Forests, Healthy Communities email roundup today.