A link in Nick Smith’s email today goes to a press release about the USFS’s Climate Action Tracker, which I have not yet explored. The release also mentions “A revised Mature and Old growth Definition and Inventory revised report released today has new charts that include lands managed by both the Department of the Interior’s Bureau of Land Management and the Forest Service.”
From the exec summary:
Based on the working definitions used in this initial inventory, Forest Service and BLM lands collectively contain 33.1 +/- 0.4 million acres1 of old-growth and 80.8 +/- 0.5 million acres of mature forest. Old-growth forest represents 19 percent and mature forest another 45 percent of all forested land managed by the two agencies. This initial national-scale inventory was conducted by applying the old-growth and mature working definitions to Forest Inventory and Analysis (FIA) field plot data.
Like all of the Nation’s forests, old-growth and mature forests are threatened by climate change and associated stressors. The initial inventory and definitions for old-growth and mature forests are part of an overarching climate-informed strategy to enhance carbon sequestration and address climate-related impacts to forests, including insects, disease, wildfire risk, and drought. Initial inventory results will be used to analyze threats to these forests, which will allow consideration of appropriate climate-informed forest management, which is also required by E.O. 14072.
This is the latest I received from one of my sources..
I asked the question “so it’s the folks covered in FF retirement and who have fire quals that are not being affected?”
Also I got an answer as to “why it’s so hard to count.”
It does get a little fuzzy around the edges. Clearly fire positions with FF retirement coverage are not in any kind of pause. Right now, even some fire-funded positions such as Fire Cache positions are not affected. No current non-fire employee is impacted except in terms of applying for a position for competitive promotion and/or lateral…opportunities may decrease as vacant positions are held vacant due to funding concerns.
Figuring out how many vacancies are out there in the process of being filled is not that simple. For a lot of hiring, for various reasons, an SF-52 is no longer submitted to initiate a hiring action, and is only generated and entered into the system once a tentative selection is made. This cuts down on a tremendous amount of unnecessary front-end work when for whatever reason a hiring manager ends up not making an offer. Intake portals have replaced the early submission of 52s in these scenarios. Also, hiring managers are doing more backfilling at the same time they are selecting for vacancies, so there are often additional hires being done that were not listed in the initial portal inventory. Bottom line is there is no one system to accurately account for how many hires are in process, and no way to quickly assess this, hence the “pause”.
Highlights: increased capacity (hires), planting and seed orchard establishment, one-year anniversary of regional budget organization and drones for prescribed burning. Here’s a link.
An audacious federal plan to protect the spotted owl would eradicate hundreds of thousands of barred owls in the coming years.
Excerpt:
Crammed into marginal territories and bedeviled by wildfires, northern spotted owl populations have declined by up to 80 percent over the last two decades. As few as 3,000 remain on federal lands, compared with 11,000 in 1993. In the wilds of British Columbia, the northern spotted owl has vanished; only one, a female, remains. If the trend continues, the northern spotted owl could become the first owl subspecies in the United States to go extinct.
In a last-ditch effort to rescue the northern spotted owl from oblivion and protect the California spotted owl population, the U.S. Fish and Wildlife Service has proposed culling a staggering number of barred owls across a swath of 11 to 14 million acres in Washington, Oregon and Northern California, where barred owls — which the agency regards as invasive — are encroaching. The lethal management plan calls for eradicating up to half a million barred owls over the next 30 years, or 30 percent of the population over that time frame. The owls would be dispatched using the cheapest and most efficient methods, from large-bore shotguns with night scopes to capture and euthanasia.
Question about how USAJOBS works. A forestry student of mine applied for a technician job with a federal agency. The student was very well qualified, has a related associate’s degree, relevant work experience, and had done related volunteer work for an NGO (a watershed council) in the same watershed, plus had the president of the NGO as a reference. The student also reached out to the agency’s staffer who would make the hiring decision and was well received. The student now has received an email from “usastaffingoffice” saying that “You are tentatively eligible for this series/grade combination based on your self-rating of your qualifications.” But: “You have not been referred to the hiring manager” for the position, and “If you were not referred, you were not found to be among the most highly qualified for the position.” Naturally, this very well qualified applicant is disappointed not to be selected for an interview with a real person.
Questions:
Did a human being evaluate the student’s application at any point? Or was it completely automated?
Can hiring managers request that USAJOBS re-evaluate the student’s application?
The Chief mentioned the Community Wildfire Protection Program, which reminded me of this article (thanks to Nick Smith!). Bay Nature is sensitive about my excerpting too much from their pieces but the piece is available without a paywall here. There’s also a great chart showing how long it took for different grants to go through.
The Community Wildfire Defense Grants are a brand-new program that was kickstarted by the Bipartisan Infrastructure Law last year. Nationwide, the program will provide $1 billion dollars over five years to help communities manage their fire risks. Grants are meant for the communities in greatest need, and applicants are weighed by socioeconomic factors as well as fire risk—work happens on private or tribal trust lands, not federal properties. “Some people might be saying, ‘It’s delayed.’ But on the other hand, it’s a new program that they had to stand up very quickly,” says Evan Burks, spokesperson for the USFS. “And it’s been an absolute game-changer.”
Galleher and his colleagues weren’t the only ones who encountered delays. Elsewhere in Plumas County, the Feather River Resource Conservation District, a nonregulatory local agency that works on post-fire restoration, waited 10 months for its $8.5 million grant. Outside of Plumas, the Forest Service says, three of California’s 33 grantees have yet to receive awards totaling over $10 million—and it’s been a year and counting since that round of awards was announced. These include northern California communities in Mendocino, Trinity, and Kern. On average, grants took about 250 days, or about eight months, to execute.
“High-risk communities have to fret through fire seasons, while they just sort of hope to God that they don’t have a fire come through the neighborhood,” says Hugh Safford, a former regional ecologist who left the Forest Service in 2021. He now works on forest resilience as chief scientist at a tech startup, Vibrant Planet, and holds an ecology research position at UC Davis. “It means that they’re gonna go another fire season without having the work done.”
USFS officials say grants were held up due to small, bureaucratic delays—such as checking signatures were valid, or budget back-and-forths. But Adrienne Freeman, a spokesperson for the grant program, also acknowledges two factors: an agency-wide staffing shortage, and a lack of an external clearinghouse to get the money moving on the beleaguered Forest Service’s behalf. “The Forest Service, [which] has extremely limited capacity, is doing all of these grants. So, fundamentally, it’s gonna be a challenge,” Freeman says. Some states have taken over administering the grants, and CalFire has distributed some federal money originating from the USDA. But for this round of funding, the state of California opted out, putting the onus back on the federal government.
Safford likens the funds to water pouring into these communities—the nozzle that they’re coming through just isn’t big enough. “It has a really big opening where the federal government has poured in billions and billions,” he says. “It’s stacked up and overflowing at the top but there’s nothing coming out of the bottom.”
So all that was interesting, and here’s an interesting on-the-ground perspective about post-fire treatments. Each forest’s condition is different post-fire.
“In a large amount of the areas we work in there is 100% tree mortality,” Hall says. “Just completely cooked.” These are rural areas, at places where dead trees meet with burned-down residences—but despite the lack of green, these areas are presently just as much of a fire risk as the unburned areas—if not more. The ground is dry. The smoked trees, like charcoal at the heart of a hearth, are ready to rekindle at the smallest spark. When a reburn goes through a patch like this, “It’s hotter and quicker,” Hall says. “There’s not a lot of smoldering because the material is so combustible. So [fires] burn quick and move through fast.”
Ideally, Hall says, you take a crew into the dead zone within the first year of a devastating fire. At that stage, you can still use herbicides and hand-held tools to clear the burned trees and young shrubs. But when rot starts to set in, branches will weaken. The canopy becomes a hazard of its own. “After four years, large trees become really dangerous,” Hall says. “Your only hope is to maybe knock them over with an excavator.”
When the federal funds finally arrived in January, the ground in Plumas was snowy, and too wet for tree removal to begin. Hall plans to start the project in the fall instead—a little more than three years since the Dixie Fire. He doesn’t fault the Forest Service for the long delays, saying it’s “pretty darn typical” of a federal agency to be slow, and adds that the conservation district’s been managing fine with other sources of funds.
They’ve done this before: remove dead trees and brush from private property, and then step in to replant the forest with baby ponderosa pine, incense cedar, sugar pine, and Douglas fir. That’s the way to break the burn cycle, Hall says.
But he is worried. There’s an eight- to 12-year post-fire window, he says, during which the dead trees and the shrubs growing around them pose a serious threat of reburning—and, with large wildfires coming more frequently nowadays, they are more likely to do so. That’s the real clock they’re up against. “It can burn again,” he says. “It will burn again.”
I earlier posted a piece on the Forest Service’s Keystone Agreements with a variety of NGOs. These agreements are meant to accomplish a wide variety of tasks that would normally be done either by the Forest Service itself or through normal contracting procedures. I said that we had submitted several questions to the Forest Service and we were awaiting their response. Last week, we received that response from the Forest Service’s Office of Communications.
The following shows our numbered questions along with their responses in bold:
(1) We have obtained copies of the Master Agreements with the various NGO’s through FOIA’s. We are interested in the details contained in the associated SPA’s, particularly the financial information. Shouldn’t this information be available to the public? We believe it is important to know how the Forest Service is spending federal dollars through these agreements. Do we need to file FOIA’s to obtain this information or could it just be available online? If not, why not? We realize there would be some proprietary information that would need to be redacted.
Each Forest and Region that has executed agreements that are tied to the Master Keystone Agreements has specific plans to implement those projects. Some are at various stages of implementation and readiness and a financial plan does not depict the context necessary to appreciate the implementation of the agreement goals fully. Due to the constantly changing nature in the status of work, we don’t post this information online, as it is not static. We suggest working with individual units to understand their Forest’s or landscape’s holistic partnership and collaborative goals so that entire project areas and landscape goals from A-Z can be seen rather than a snapshot of one financial plan. Those program managers will also be able to speak to financial planning and other relevant plans and appendices or modifications the agreements have associated with them so that these iterative agreements can be fully understood.
(2) How are accomplishments being tracked through these agreements? Who is providing oversight, Grants and Agreements? Partnerships Office?
Accomplishments are being tracked at a local, regional, and national level through our agency’s authoritative data sources. We are monitoring financial burn rates and programmatic outputs, among other things. Forest staff, program managers, and grants and agreements staff collectively provide oversight to ensure the successful implementation of the agreement with our partners.
(3) What is the process of awarding the NGO’s funding? Do they receive the dollars and then projects are developed? What are the overhead rates of the various NGO’s?
The need to treat hazardous fuels across the United States has been identified in great detail and is addressed in the Wildfire Crisis Strategy outlined by the FS Wildfire Crisis Strategy published in 2022. Regions and Forests with identified needs have received funds to implement project work through contracts and agreements. Some of these agreements are with partners that have a Keystone Agreement, who may have established relationships with the region or forest to address these needs. While the “umbrella” or Master “Keystone” Agreements with partners are held at the Washington Office, the actual project work and funds that are added to the agreements are often done at the regional level, Wildfire Crisis Strategy landscape level, or at the Forest level. The projects are developed at the local level and then appropriate funds for the work, once identified, are awarded to the Supplemental Project Agreements in conjunction with inputs from the partner. Each NGO has its own Negotiated Indirect Cost Rate Agreement (NICRA). Each NICRA is negotiated with the cognizant agency for the partner. The federal agency that provides the most in direct funding is normally the organization’s cognizant, unless specifically assigned by the Office of Management and Budget.
(4) Are the Keystone Agreements being used to avoid Federal Acquisition Regulations and federal hiring difficulties?
No, the Keystone Agreements are not being used to avoid Federal Acquisition Regulations nor federal hiring difficulties. Keystone agreements were developed to implement projects at a pace and scale aligned with the objectives of the Forest Service. The Forest Service is taking this opportunity to achieve our mission in new ways, building on long-standing partnerships and creating large, national-level agreements—or Keystone Agreements—for BIL and IRA implementation. These agreements will allow us to execute priority projects quickly and efficiently while we grow Forest Service institutional capacity. Importantly, these Keystone Agreements facilitate new local agreements or complement existing agreements at the region and unit levels, creating a suite of partnership arrangements that collectively give our national forests and grasslands a range of tools for program implementation. These agreements can increase capacity, to help accomplish crucial work on the ground in an expedited manner.
(5) We are hearing that Forests are having budget difficulties this fiscal year and that it will impact their ability to hire employees. In hindsight, was it wise to put so much funding into the Keystone Agreements rather than into NFS? Could a lot of this funding have been put into IDIQ contracts instead?
The agency has invested a tremendous amount of BIL and IRA funding in the WCS landscapes, high risk-firesheds, and to a much smaller extent, funding for state agencies, tribes and Keystone Agreements. Some of the BIL and IRA funding did go into IDIQ contracts. Due to the significant workload and goals of the Wildfire Crisis Strategy, an array of tools were utilized to help accomplish the work. In addition, a large number of new employees were hired within the agency to address the workload.
(6) Are Keystone Agreement accomplishments being claimed when the funding is awarded rather than when the work is actually accomplished?
Accomplishments are recorded when the work is completed. The exception is when timber is sold through a contract or stewardship agreement. The “timber volume sold” accomplishment is recorded when an agreement or contract is fully executed. Funding obligations and are also tracked for budget expenditure purposes.
Understanding that you may want additional documents that are not publicly available, we recommend you request the data through the Freedom of Information Act. This link provides contact information for the WO processing center: FOIA Contact Service Centers | US Forest Service (usda.gov). The more detailed the request the better.
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I certainly appreciate the Office of Communication responding to our questions and I feel that I have somewhat of a better understanding of these Keystone Agreements. However, I think those of us who are interested in Forest Service operations should still have some concerns regarding their implementation.
It’s just my opinion but these huge funding bills have had a really mixed outcome regarding the Forest Service. I remember the National Fire Plan in 2000, which promised a significant increase in funding into the future, but much of that increase dried up after a couple of years. The 2009 Recovery Act provided a lot of money and we were scrambling on how to get it spent. I know some good things were funded, but personally, I saw some projects that had the appearance of just spending money to get it spent.
Is the Forest Service doing the right thing with these Keystone Agreements? I don’t know but if they are resulting in a significant bump in accomplishments, the Forest Service is not doing a great job in telling that story. You would think with all of the money being spent, the Forest Service would have an excellent public relations plan regarding these agreements. It should not be difficult to find out what is happening with them. Do you think the Forest Service has done well at explaining their value? Are they a good use of taxpayer dollars?
New Tahoe Forest Products Sawmill (courtesy of Bloomberg)
There were many interesting things to explore with the hearing on the Westerman Bill yesterday. As we saw in previous posts, it’s a compendium of many different ideas we can explore in greater depth. What I thought was one theme in Chris French’s testimony was what we might call another Wood Wide Web (broader than the mycological one discussed here a few weeks ago), this one of people, workers and organizations making useful products of wood.
Certainly mycorrhizal fungi help trees. But also people help trees, at least around here, by thinning them and protecting them from fires, planting them and so on. And trees provide us with useful products, often more environmentally friendly than those produced from minerals of various kinds. So, in fact, we as humans have some mutualism going on here with trees. And within that mutualism, we have a complex interrelationship of businesses and workers (from sawmills to CLT to paneling to furniture to horse bedding to sawdust to biochar to bioenergy) that depend on each other. And people who depend on the products they produce, plus employment, plus taxes. So indeed people have their own Wood Wide Web, and while Chris didn’t talk about it in those words, he made the point that this Web is important to forests surviving and thriving into the future, come climate change, wildfires and a variety of other stressors. Or at least that’s how I heard it. We are, indeed, all in this together.
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Housing is a crisis in many places in the US. And the US is allowing large numbers of migrants in (at least 2.5 million according to NPR) (not judging, just observing). It seems logical that we would need even more housing. Housing tends to be built using wood for various reasons, including cost. We have lots of extra wood from fuel treatment and restoration projects, but it tends to be small. Will new materials like CLT help us build our way out of the housing crisis? Certainly if we look at the Wood Utilization grants of USDA, there is much effort (and funding) going toward Mass Timber, CLT and other efforts. Maybe the future is small, local mills, with local employees scattered through the landscape. Which is kind of what we had, previously, except in the past they focused on larger dimension lumber.
I’m not a fan of top-down industrial policy, but if the wildfire folks can have a Cohesive Strategy, I don’t see why, given the massive amounts of biomass to be otherwise burned, we can’t have a Coherent (and what the heck, let’s throw in Cohesive also) Strategy.
Current Dimensions Used (from AFRC)
I was curious about the size of material being used by current timber industry (including CLT mills). I know there are university and Forest Service experts out there, so hopefully they will add information here or you all can add good contacts.
AFRC generously provided me with their perspective on dimensions:
Log utilization is an ongoing point of contention between the federal agencies and AFRC. The Forest Service in Region 6 generally classifies minimum specifications for sawtimber as an 8-foot log with a small-end diameter of 5-6 inches for most conifer species. The only exception is ponderosa pine where they use a 16-foot log. AFRC has been advocating that the Forest Service use a 16-foot log for all conifer species for several years since most all of our members assert that 8-foot logs with 5-6 inch diameters do not get processed as saw material, but rather end up as pulp or chip material. Most of our members whose mills are designed to utilize small logs are capable of sawing or peeling down to 5-6 inches, but some minor variations exist. However, when delivered as an 8-foot piece, the economics of doing so becomes marginal—hence our advocacy to change that length.
The CLT facilities that I’m familiar with (Freres in Lyons and DR Johnson in Riddle) do not actually process raw logs—instead they secure veneer that has previously been peeled or boards that have previously been cut at other mills and then manufacture them into larger products by gluing them together. Generally speaking though, the products that are delivered to CLT facilities can be cut/peeled from small, medium, or large logs.
From loggers to end users – all of whom are currently involved in a complex exchange of material and value. Fiddling with a part may cause a series of consequences throughout the web. And 16 foot logs with 5-6 inch diameters are pretty small. With, no doubt, transportation costs being a big thing. Again, the web. Again, the need for a Double C (cohesive and coherent) strategy.
Academic Horsepower and Successful Industry-Chicken or Egg?
If your state has a prominent forest industry, generally (but not always) universities hire experts to help them, and conceivably the rest of us who use wood or want to get rid of biomass. But if your state doesn’t, then they probably don’t have experts. Which could be a problem if you want to support new industries, in that there are no/few experts to help entrepreneurs.
As I was writing the above on transportation costs, I received an announcement of a webinar by Drs. McConnell and Tanger who seem to be forest economics/wood utilization/operations experts.
Wood-using sawmills prioritize availability of raw materials, their accessibility, and associated transportation costs as the main drivers of new mill constructions and financial viability of existing mill operations. One of the major hurdles faced by the forest sector is hauling costs. Hauling costs have commonly been cited as comprising 35 to 45% of the delivered cost of round wood. Join us to learn how road network repairs could benefit both the forest sector and the broader Mississippi economy.
California’s Wildfire and Forest Resilience Task Force Market Development Program
I don’t know how many economics and utilization professors California has (I know there’s some in Extension) but they have a market development program that’s interesting. They have five pilot programs:
to establish reliable access to forest biomass through a variety of feedstock aggregation mechanisms and organizational innovations. The pilots will develop plans to improve feedstock supply chain logistics within each target region through the deployment of a special district with the authority and resources to aggregate biomass and facilitate long-term feedstock contracts. Each pilot will assess market conditions, evaluate infrastructure needs, and work to enhance economic opportunities for biomass businesses in their project regions. The pilots are distributed across 17 counties in the Central Sierra, Lake Tahoe Basin, Northeast California, North Coast and Marin County.
Their rationale is:
Diverting forest residues for productive use can help increase the pace and scale of forest restoration efforts in California, reducing vulnerability to wildfire, supporting rural economic development, and promoting carbon storage. The Wildfire and Forest Resilience Action Plan identifies the development of, and access to, markets for these residues as a key barrier to conducting necessary treatment activities across priority landscapes in the state. The development of such a market for residues has been hampered by the lack of any centralized broker capable of entering into long-term feedstock supply contracts.
Washoe Sawmill Opens
I posted about this last year, The Tahoe Fund, Tahoe Forest Products LLC, and the Washoe Development Corporation worked together to build a new mill. Here’s a link to a Bloomberg story. Region 5 has a good story about it opening, with some interviews and a historical perspective. Shout out to writer Andrew Avitt!
“The truth is, the forest, it needs our help,” said Serrell Smokey, Tribal chairman for the Washoe Tribe of Nevada & California, at the Tahoe Forest Products sawmill opening Dec. 18, 2023, “Our people have intervened in these areas since the beginning of time, because otherwise, if we don’t take care of it, it will take care of itself.”
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There is a mutually beneficial relationship here – land management agencies need to treat landscapes and the timber industry needs timber. There used to be an old saying of “trees paying their way out of the woods.” That meant the value of the timber would help offset the cost of treating an area. While that’s not the reality on the eastern side of the Sierras, having a mill infrastructure in proximity drastically improves the economics of the type of work that’s needed to restore landscapes in the West.
When timber business makes assessments about when and where to take on a contract, they look at a number of factors — fuel and labor costs, and market prices for timber. But there is one factor that tends to be the most prohibitive — distance.
The further a log has to travel to arrive at the nearest mill increases fuel and labor costs and decreases a business’s profit. Depending on all the variables, the breakeven distance is about 50-80 miles from forest to mill.
Before the opening of Tahoe Forest Products mill in Carson City, the closest mill was in Quincy, California. That’s more than 100 miles from many of the areas that need work on the Humboldt-Toiyabe National Forest.
“Since the mill has opened the conversation has definitely changed,” said Monti, “Now contractors are calling and saying, ‘hey, I heard this new mill went in. I’m really interested in doing work on this side of the mountain.’… We have not had that option for the last several decades.”
Note the transportation costs, and the shimmering of the beginning of a new working-wood-wide-web. I always wonder why California seems to be different from Oregon in its appreciation of the Web- maybe the Timber Wars are still resonating.
Biden-Harris Administration Finalizes Strategy to Guide Balanced Management, Conservation of Public Lands
Public Lands Rule will help conserve wildlife habitat, restore places impacted by wildfire and drought, expand outdoor recreation, and guide thoughtful development
A skeptic might wonder how the Forest Service could possibly “conserve wildlife habitat, restore places impacted by wildfire and drought, expand outdoor recreation, and guide thoughtful development” without such a rule? Here’s a link to the Rule. There are also fact sheets and other information here.
So let’s take a brief look to see what has changed based on the comments received. Hopefully, paid legal folks will look more intensively at it. Just in case you’re curious, they received “over 200,000 comments, the vast majority of which supported the effort. In response to the substantive comments received, the BLM clarified and refined concepts laid out in the proposed rule.”
Kind of sounds like they didn’t change anything, just clarified and responded.
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I’m not a fan of the temporary ACEC idea, from the FAQS:
If the BLM finds the area meets the criteria for ACEC designation and determines that the relevant and important values could be irreparably harmed if not protected, then the BLM may implement temporary protections that could maintain the condition of identified resources until a potential ACEC can be fully evaluated through land use planning. The public would be notified of any temporary protections.
In response to comments received from individuals, state, Tribal and local governments, industry groups, and advocacy organizations, the BLM clarified that ACECs should typically be evaluated in land use planning because their designation is intended to be a proactive decision made in concert with other considerations that affect the same lands and resources. The Final Rule also refines procedures for ACECs that are nominated outside of the land use planning process, recognizing that the BLM can defer consideration of those areas and, in the rare instances when it may be necessary, can also implement temporary protections.
So the response to the comments was to state that they expect it to be used rarely? And so some group of whatever location and funding could nominate the area, and the public would be “notified”.
This does not sound like a robust public involvement process with considerations of Tribal view; I guess that would be OK because it’s “temporary” only until the next RMP.. and what is the RMP schedule, again?
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I also wonder about the offsite mitigation idea. It doesn’t sound like there’s a role for both sets of communities to weigh in. Of course, the communities near the siting will weigh in, but what about the community receiving the mitigation lease?
Appropriate places for restoration and mitigation leasing on public lands include degraded habitats in need of restoration, as well as intact landscapes and functioning ecosystems that can serve as compensatory mitigation for a particular action. For example, as part of authorizing a renewable energy project on public lands, the BLM and the project proponent may agree to compensate for loss of wildlife habitat by restoring or enhancing other habitat areas on public lands. A mitigation lease could be used to protect the restoration and enhancement actions.
But who and what are the lessees protecting the “restoration or enhancing” from, other than existing users? Just logically, if the project doesn’t need to be protected from existing users, why do you need a lease? If it does need to be protected, then from whom or what exactly? Some other new use such as another solar or transmission line? This puzzles me. But if it’s a new use, it would have to go through permitting and perhaps the “restored or enhanced” area could have been avoided (or mitigated elsewhere, perhaps via chains of mitigation..).
The Bird Example
The environmental analysis for an interregional transmission line finds the project would have unavoidable impacts on a bird species that is managed as imperiled by the BLM and by state governments where the transmission line is proposed. The authorizing agencies determine that compensatory mitigation is warranted to address impacts to the species, and the best remaining habitat is found on BLM-managed public lands.
In this case, the BLM could consider an application for a mitigation lease to conserve the bird’s habitat on public lands. The lease would identify conservation measures that address the unavoidable impacts to the bird species and would help ensure that these measures remain effective for the duration of the transmission line’s impact. The mitigation lease could be terminated or modified in response to changing habitat conditions.
Why would a lease be preferred to something more flexible? Suppose BLM goes to all the work of doing a lease for an area for some bird. But then the area is burned over. Wouldn’t it make more sense to have something more flexible and robust to change? Or maybe it makes more sense to make one intervention for a species in one place, and then make that same intervention in another place as opposed to making a series of interventions in the same place.
I am reminded of my first run-in with ideology. I was working in US Congresswoman Carrie Meek’s (17th District Florida) office in the mid-1990s. The issue was deregulation of power in Florida. No matter what questions I asked, deregulation was always the answer. It was impossible to engage with the proponents in a down-to-earth way- it was like pragmatism vs. ideology. Deregulation is great. Deregulation is better than sliced bread. Deregulation will only have positive effects. If you point out negatives, let me assure you the positives will outweigh the negatives. No, we don’t need those protections included because… Deregulation is great. It is better than sliced bread…
I have the same feeling about these leases, even if they changed the name.
