What Should Plans Do?

Is this “thinning?”

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These photographs accompany a Missoulian article on a vegetation management project on the Lolo National Forest in Missoula’s WUI, showing trees (ponderosa pines?) marked for removal.  Most of the purpose and need is related to reducing fire risk, but there is also an assertion that these marked trees are ecologically inappropriate.  Here is what the decision notice says:

While ecological restoration and resiliency are embedded in WAM, the MCCWPP, Forest Service policy, and the National Cohesive Strategy, there is less agreement from the Missoula community about restoration as the sole basis for wildfire risk reduction fuel treatments. This debate about restoration has been ongoing for many years, as the wildfire hazard and risk to our community continues to increase. As the District Ranger, I considered this challenge and while the purpose and need focuses on fuel treatments to reduce hazard and risk, the project also meets ecological objectives to create resilient ecosystems. Both objectives are met through the actions included in the Selected Action and this decision and are designed to achieve the following restoration and resilience strategies:

  • Reduce surface and ladder fuels; increase crown base heights

  • Reduce and maintain lower tree densities; decrease crown bulk density

  • Increase composition of fire and drought-tolerant species (ponderosa pine and western larch

  • Increase mean diameter and individual tree vigor by retaining large trees with healthy crowns

  • Conserve existing species and genetic diversity

  • Restore horizontal spatial heterogeneity of forest structure, including openings where early-seral species can establish

  • Reintroduce fire to reduce fuel loads, stimulate understory species, and maintain desired fuel beds

  • Reduce/maintain appropriate levels of pathogens, insects, and other disturbances in order to create decadence, mortality, and interactions with fire that lead to regeneration of new tree cohorts and diverse understories

  • Monitor key processes including mortality, regeneration, growth, fuel accumulation and new species colonization to inform management if the project is meeting objectives to reduce hazard and risk and create resilient ecosystems.

Make sense?  Both objectives met?  (Note that board feet is not mentioned here.)  To me this kind of captures the debate about when is it necessary to remove the overstory to provide fuel reduction, which is going to be the “mature” trees that many would like to save.  Should we be striving for historical conditions, or less density than that because there are houses nearby, in which case I would say the ecological goal is not being met?   Keeping in mind that the “natural range of variation” is a requirement for ecosystems, not projects, I hope the forest plan identifies areas where risk reduction outweighs restoration as a desired outcome (purpose and need) of projects.  And that the NRV for ecosystems takes into consideration the areas that won’t have that desired condition.

“Conserving and Restoring Terrestrial Wildlife Habitat Connectivity and Corridors in the United States”

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Center for Large Landscape Conservation

 

One of the hills I died on near the end of my Forest Service career was an attempt to get national forest planning to coordinate with future plans for adjacent ownerships to provide for wildlife habitat connectivity among them, including local government planning and land trust conservation easements.  I thought the Forest Service could play a leadership role in coordinating this.  The response I got was that anything to do with private lands was a “third rail” that they didn’t want to go near.  This sounds different.

On October 21, a Department of Agriculture memo announced “a Department-wide effort to support connectivity of wildlife habitat on working landscapes through the management of National Forests and voluntary conservation assistance on private agricultural lands.”  Specifically, a new Secretary’s Memorandum directs USDA agencies to:

  • Incorporate consideration of terrestrial wildlife habitat connectivity and corridors into relevant planning processes, programs, and assessments.
  • Improve the coordination, compatibility, and delivery of USDA planning processes and programs to improve outcomes for terrestrial wildlife connectivity.
  • Increase inter-jurisdictional coordination with states, tribes and other federal departments.
  • Coordinate within USDA to implement the actions outlined in this memo, with the goal of improved delivery of USDA programs and outcomes for terrestrial connectivity.

Needless to say, I like the recognition in the first bullet that planning, specifically recognized later to include “FS land management planning,” is important to a desired outcome that requires designing bridges connecting multiple owners; otherwise, the result may be bridges to nowhere or with missing spans.

The memo recognizes that “A recent revolution in animal tracking, remote sensing, and computational analysis is improving the prioritization of conservation and restoration actions.”  It also notes, “The agency’s 2012 planning rule, which governs land management planning across these lands, included requirements for evaluating, maintaining, or restoring connectivity” (my contribution to posterity).  The directive includes a specific proposal related to forest planning:

  • Improving planning through Forest Service analytic tools, including a Climate Risk Viewer that identifies climate change-driven risks to key resources, such as corridors and connectivity, as well as migration corridor tool development among the National Forest System, Research Stations, and partners.

Because “Federal lands often serve as anchor points for wildlife, but most of the country’s wildlife reside on private lands,” much of the emphasis may be on supporting private land conservation.  However, “this collaboration will build on the crucial connection between public lands and the private lands around them.”  (Or at least to the extent that a Secretary’s memo can accomplish anything.)

The Endangered Species Act turns 50

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You can read any number of articles right now about this that say ESA was adopted by a nearly unanimous Congress and signed by President Nixon on December 28, 1973.  Its supporters find success in its protection of 99% of the species listed from extinction, while critics complain that only 3% have been recovered.  To me, that’s apples vs oranges, because it is much easier for a law to stop bad things from happening than to make good things happen.  I’d love to see those who complain about ESA out there arguing for more money to implement recovery plans.  (And I fail to see the logic of opposing additional listings because recovery is unlikely, when recovery without listing is even less likely.)

But I was curious about what the Forest Service might have to say about this momentous anniversary, and this posting showed up on their website.  It’s written about California, but must represent the agency’s perspective.  The current priority is evident in the second paragraph:

Large, extremely hot fires have ripped through many of these lands, charring if not destroying habitat crucial to species survival. To help reduce the risk of large, devastating fires, the Forest Service is working to remove vegetation that could feed a fire and is working with the U.S. Fish and Wildlife Service to simultaneously support the conservation of listed species.

That would be listed species that depend on “vegetation that could feed a fire,” which would be removed.  We’ve seen that with spotted owls, the Fish and Wildlife says this should mean focusing fuel reduction projects on areas that are less important to the species.  It would be interesting to hear about how this approach is being implemented through agency policy, forest plans, and/or implementation strategies.  This explanation by the Forest Service falls a little short of a “strategy” for accomplishing this.

The U.S. Fish and Wildlife Service, which manages the species program, often partners with the Forest Service on steps to protect species listed under the act. Collaborative efforts carry intertwined goals forward. Wildlife specialists and biologists from each agency review project plans, survey forests for species populations, collect data, and analyze the best available science. The Forest Service often includes wildlife conservation measures in as part of land management planning, which means on-the-ground activities needed to increase forest resilience align with the needs of wildlife.

For example, specific types, sizes and heights of trees are left in areas of a forest known to be actively used as nesting or denning sites by threatened or endangered species. The Forest Service plans work to occur during times of the year that will not disrupt key life stages, such as mating season or when adults are caring for young. The Fish and Wildlife Service reviews these plans before work is started to ensure that species needs are being met.

I like that they recognize the importance of forest plan standards as a key tool for protecting species, but I’d like to know more about “Collaborative efforts carry intertwined goals forward.”

 

New CEQ Guidance on Habitat Connectivity

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Cascade Forest Conservancy

On March 21, the Council on Environmental Quality provided “Guidance for Federal Departments and Agencies on Ecological Connectivity and Wildlife Corridors” to federal agencies.  The Forest Service was a member of the working group that developed this guidance.

“Connectivity is the degree to which landscapes, waterscapes, and seascapes allow species to move freely and ecological processes to function unimpeded. Corridors are distinct components of a landscape, waterscape, or seascape that provide connectivity. Corridors have policy relevance because they facilitate movement of species between blocks of intact habitat, notably during seasonal migrations or in response to changing conditions… Increasing connectivity is one of the most frequently recommended climate adaptation strategies for biodiversity management.”

“To the maximum extent practicable, Federal agencies are expected to advance the objectives of this guidance by developing policies, through regulations, guidance, or other means, to consider how to conserve, enhance, protect, and restore corridors and connectivity during planning and decision-making, and to encourage collaborative processes across management and ownership boundaries. Any existing corridor and connectivity policies or related policies should be updated as needed to align with the objectives in this guidance. Federal agencies should have new or updated policies ready to implement by the first quarter of 2024 and make their policies publicly available. Federal agencies should also actively identify and prioritize actions that advance the objectives set forth in this guidance.”

“Federal agencies should not limit engagement in restoration activities only to circumstances when restoration serves as a mitigation strategy to compensate for adverse impacts from projects or actions. Instead, Federal agencies should consider where there are opportunities in their programs and policies to carry out restoration with the objective of promoting greater connectivity.”

One of the specific “focal areas” listed in the memo is “forest and rangeland planning and management.”  “Connectivity and corridors should factor into high-level planning and decision-making at Federal agencies as well as into individual decisions that lead to well-sited and planned projects.”  “In carrying out large-scale planning required by statutory mandates (citing NFMA and FLPMA) Federal agencies should consider updating inventories of Federal resources under their associated management plans to assess connectivity and corridors.”

The Forest Service 2012 Planning Rule already includes language requiring that forest plans address connectivity as part of its wildlife viability considerations.  I had something to do with that, but I was regularly disappointed in the agency’s unwillingness to “think outside the green lines” about how species occurring on a national forest depend on connectivity across other land ownerships, so I’m always happy to see someone try to make them do that:

“Ecological processes and wildlife movement are not limited by jurisdictional boundaries. Therefore, Federal agencies should seek active collaboration and coordination with other Federal agencies, Tribes, States, territorial, and local governments, as well as stakeholders to facilitate landscape, waterscape, and seascape-scale connectivity planning and management, and consider appropriate collaboration with other nations. Prioritization and strategic alignment of connectivity efforts across partners improves the effectiveness of each entity’s activities and enables larger-scale conservation, enhancement, protection, or restoration to occur.”

“Federal agencies with investments on Federal lands or in Federal waters adjacent to designated areas that may have conservation outcomes (e.g., National Park System units, national monuments, national forests and grasslands, national marine sanctuaries, national estuarine research reserves, wilderness areas, national wildlife refuges, etc.) should explore collaborative opportunities to enhance connectivity across jurisdictional boundaries.”

These kinds of initiatives seem to come and go, but we should at least expect to see the land management agencies tell us what they think under this administration by next year.  If anyone happens to notice, let us know!

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

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

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

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

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

 

 

Trillion Trees and Natural Carbon Storage Act

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

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

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

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

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

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

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

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

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

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

Good news for wildlife on two national forests

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Here are two different kinds of success stories about restoring wildlife species that have been missing from national forests.

 

 

Grizzly bears – Lolo National Forest.

Current efforts on the Lolo National Forest demonstrate one way that forest plans can improve conditions for at-risk species; in this case the plan is contributing to conservation of the federally threatened grizzly bear. Grizzly bears have been sighted in recent years in this part of the Forest, but none are females or considered to be residents.

In 2011, the forest plan was amended to include what is commonly referred to as the Access Amendment (similar amendments also applied to the Kootenai and Idaho Panhandle national forests, prior to the revision of their forest plans).  The amendment established “standards” for motorized road and trail density in grizzly bear management units (BMUs, there is one on the Lolo).  In many cases, the current conditions did not meet these standards, so in the terminology of the 2012 Planning Rule, these would be desired conditions or objectives to be achieved.  In addition, their achievement was assumed in the biological opinion on the effects of the forest plan on grizzly bears prepared by the Fish and Wildlife Service, and failure to achieve them would likely trigger the need to reinitiate consultation on the forest plan (which had happened on the Flathead National Forest).  So there is a little added incentive, but here is what they are doing now.

The Forest has completed the “BMU 22 Compliance Environmental Assessment.”  In it they have proposed to formally close some roads that are effectively closed already and 21 trail miles currently open to motorized use.  In response to public comments, they are also considering an alternative that would close fewer trails, and instead close some roads currently open to motorized use.  In addition to other closures included with some prior vegetation management projects both alternatives “would bring the Forest into compliance with the Forest Plan motorized access management standards for the Cabinet-Yaak grizzly bear recovery zone.”

Brown-headed nuthatch – Mark Twain National Forest

The nuthatch is not at-risk range-wide, but they have not been found in Missouri for at least a century.  The species requires shortleaf pine and oak woodland forests, which have been greatly reduced from historic levels.  The loss of these forests has prompted an ecosystem restoration effort across Missouri, Arkansas and Oklahoma (notably using the Collaborative Forest Landscape Restoration Program).  Restoration of such forests is a desired outcome of the Mark Twain forest plan.  Curiously, there is no mention of the brown-headed nuthatch in the 2005 forest plan, although it does address other species using the same habitat:

Objective 1.4a Improve open woodland conditions on at least 10,500 acres to provide habitat for summer tanager, northern bobwhite, Bachman’s sparrow, and eastern red bat.

The EIS states that the nuthatch is a Management Indicator Species for forest plan monitoring, but that doesn’t seem to be in the plan itself.  Of course, a species that is absent from a national forest would not make a good MIS.  In any case, it looks like there was no interest by the Mark Twain in reestablishing a species that was not present on the forest under that rules applicable to forest planning in 2005.

However, Forest Service, state and university researchers came to the rescue of the species, determining that sufficient woodlands now exist in Missouri to support a population of Brown-headed Nuthatches, that populations in Arkansas were robust enough to supply birds to Missouri, but that nuthatches are not likely to make the return on their own because of the distance and habitat fragmentation.  The Mark Twain National Forest site was chosen for the release of 100 birds because it is the largest area of open pine woodlands in the state.

Under the 2012 Planning Rule, the Forest Service would probably argue that this species is not “known to occur” in the plan area, so the requirement to provide ecological conditions for it (as a species of conservation concern) would not apply.  However, the separate requirement for ecological integrity requires “species composition and diversity” to occur within the natural range of variation.  That should make the Forest Service more proactive in reestablishing species that historically occurred there.  (The forest plan also omits the listed red-cockaded woodpecker, which also uses these habitats, is also absent, but must be conserved and recovered.)

(For a look at how the natural range of variation might work under the 2012 Planning Rule see Table A-2, “Desired conditions for natural community types.”)

Stanislaus spotted owl plan amendment

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Photo of female and juvenile California spotted owl courtesy of University of California Cooperative Extension (http://ucanr.org/sites/spottedowl/).

We recently looked at the Biological Assessment of Northwest Forests, and the options for proceeding with revising forest plans currently governed by the Northwest Forest Plan. Some of those options involved amendments to existing plans prior to plan revision. I voiced support for amendments that would provide the ecological conditions needed for at-risk species. I thought this might be an example to look at for how that might go.

The Stanislaus National Forest is not in the area covered by this assessment. Its forest plan was originally completed in 1991, but it was amended by the Sierra Nevada Forest Plan Amendment (or Framework) in 2004, which is roughly analogous to the Northwest Forest Plan in that it had its origins in the work done to protect the California spotted owl (it has its own complicated political and legal history). Now the Stanislaus is proposing an amendment for a part of the Forest in conjunction with what it calls the Social and Ecological Resilience Across the Landscape (SERAL) project.

The Forest has identified a need to change the forest plan based on new information about the California spotted owl, as published in 2019 by the Forest Service in the “Conservation Strategy for the California Spotted Owl in the Sierra Nevada.”

In order to fully adopt and implement the management direction described in the Conservation Strategy and increase landscape resiliency as guided by NRV the Stanislaus National Forest’s forest LRMP must be amended. The proposed forest plan amendments would allow the SERAL project’s proposed landscape restoration treatments to best meet the purpose and need of the project and implement the guiding principles of the 2019 California Spotted Owl Conservation Strategy. The proposed amendments include standards and guidelines which will provide some immediate stability for individual owls while allowing forest management the ability to conduct treatments designed to help develop resilient habitat conditions that provide CSO conservation in the long term.

Unfortunately, the CSO Conservation Strategy was apparently written for a narrower purpose than its name implies:

The California spotted owl (Strix occidentalis occidentalis) Conservation Strategy is a strategic framework for active conservation of the California spotted owl on National Forest System lands in the Sierra Nevada.

It appears to be something less than a scientific strategy. By limiting the focus to “active conservation” it has failed to address the central debate about managing spotted owl habitat regarding when active management should even be used. Passive management is one obvious alternative to this amendment that the Forest is going to have to address in its amendment process. But I looked at some of the proposed changes in the forest plan.

The current plan designates spotted owl Protected Activity Centers (PACs) as management areas in the forest plan (which could be changed only by amending the forest plan). This proposed amendment would replace current management areas with guidelines to designate PACs later “in advance of any management activities that would reduce CSO nesting and roosting habitat quality.” The guidelines include criteria for delineating and changing PAC boundaries.

My opinion: This is not a coarse filter management strategy based on vegetation because it depends on actual owl presence based on surveys, or one might call it “condition-based.”  If owl presence is the kind of thing that changes frequently, this may be a reason to not designate permanent management areas at the plan level.  However, this creates the risk of cutting the public out of the part of the process that actually determines the locations for management.  The plan is no longer saying, “here is where we’ll manage for owls,” but instead, “we’ll manage for owls where we think we need to manage for owls, trust us.”  The criteria must be explicit and objective enough to fully evaluate at the plan level, and the decisions about whether and how to apply them at the project level must include the public. Given the importance that surveying would take on, there is no excuse for these being guidelines rather than standards. It seems to me that the certainty of owl protection, and therefore the viability of the species, is going to be reduced.

There are a lot of new plan components in the amendment, and the CSO Conservation Strategy is page-referenced for most of them. That’s how any conservation strategy should be used, so maybe this is a good example of that. Except that it strikes me that this “conservation strategy” may have actually been written as a “drop-in” amendment to be used this way (which makes that kind of cross-referencing a lot easier). This is similar to what would happen if plan amendments were developed that could be later “dropped in” to forest plan revisions. The problem is that if the “conservation strategy” is already a management-influenced document and not a science document, there would still need to be a reference to the actual scientific basis for these conservation recommendations that are being adopted.

Anyway, this project/amendment will be worth watching as it applies the 2012 Planning Rule diversity requirements to California spotted owls. And it may be setting some precedents for what could happen regarding how to plan for management of spotted owl habitat on other national forests.

Has the Helena-Lewis and Clark got jobs for you

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source: gustavofrazao / Getty

The Helena-Lewis and Clark National Forest revised forest plan was released recently and is now in the objection period.  A local newspaper decided to profile the benefits of the revised forest plan to “jobs” – 400 new ones are projected as a result of the revised plan.  As a former forest economist, I know how meaningless the economic analysis of forest plans can be, and this seemed a little far-fetched, so I thought I would take a look at it.

The EIS discloses the number of jobs resulting from recreation, grazing, timber, minerals, transfer payments and Forest Service expenditures.  That last item (which I think is mostly federal employees) makes up about half of the total employment benefit depending on alternative.  Actually, the number of jobs is the same for all of these categories in all alternatives, except for jobs related to timber harvest.  There, the preferred alternative (F) increases the timber jobs by five times over current levels (EIS Table 243, I get an increase of 497 from current levels), while roughly doubling the projected timber harvest volume over that resulting since 1980.  Elsewhere the EIS says, “An estimated 804 private industry timber jobs exist in this multi-county area.”  That doesn’t match the 119 shown in this table, but would mean the Forest would only increase industry employment by 50% or so, but still …  My point is just that this is suspicious and confusing.

The reality is that jobs created by Forest Service outputs are usually a very small part of a regional economy (the total number of jobs in this region is over 100,000, so that the total timber-related jobs is less than 1%) and the actual number of jobs will usually vary because of many factors that that Forest Service has no control over.  This is a good example of stuffing an EIS with information that does not help with the decision, and in fact may confuse it.

Then there is the question of why should we care.  The “regulatory framework” for social and economic benefits (p. 189 of the EIS) provides no authority for “creating jobs.”  (I doubt if there is one for doing something about “poverty levels” either, as Mac McConnell intimated here.)   The “findings required by other laws” included in the draft ROD do not include any related to social or economic growth.   And under NEPA, creating jobs would be a bad thing, since indirect adverse effects “may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems” (40 CFR §1508.8).

Of course, considering a specific effect on a specific industry or employer, might be a reasonable and relevant factor to consider for a long-term planning decision, if it were related to meaningful criteria about the “right” number of jobs and why, and properly disclosed in a record of decision.  I’m just not seeing that here, in this draft ROD:

The Plan also contributes to social and economic sustainability by providing plan components that collectively support an array of public benefits including jobs and income, … (p. 20)

This statement would have been true for any alternative, so the economic analysis contributed nothing.  It’s unfortunate that this was picked out as “news,” giving the wrong message about what our national forests are for, as well as raising questions about what is really going to happen.

The latest on forest plan revisions (and wildlife)

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In the past couple of months the Forest Service has increased its family of forest plans revised under the 2012 Planning Rule to six.  The Chugach and Rio Grande national forests have joined the Francis Marion, Flathead, El Yunque, and Inyo.  The Forest Service revision schedule is over six months old, but the Helena-Lewis and Clark National Forest may be next.

Here’s what looks like a news release from the Rio Grande.

The plan prioritizes the use of active management to foster sustainable and productive use of the forest. Compared to the 1996 plan, this new plan is less prescriptive and emphasizes flexibility and commitments to working with the public. Management direction has been updated for all plant and wildlife species.

This seems to capture the mood of the Forest Service these days.  The only commitments it has ever liked are those they have to do any way, especially if they are check-the-box kinds of procedural commitments like “working with the public.”  In their “update” for wildlife, rather than commit to protecting wildlife as required by NFMA and the Planning Rule, they infuse the plan with discretion.  Here’s some examples of what the Rio Grande seems to feel (based on the best available scientific information) would “provide the ecological conditions necessary to: contribute to the recovery of federally listed threatened and endangered species, conserve proposed and candidate species, and maintain a viable population of each species of conservation concern within the plan area” – which plan components “must” do (36 CFR §219.9(b)).

DC-SCC-2: Structure, composition, and function of coniferous forests, including late seral forests, meet the needs of associated species, including species of conservation concern. (Forestwide)

There is a series of these desired conditions for different ecosystems that all say the same thing, which is “we’ll figure out what these species need later.”  The Planning Rule requirement is for “plan components” to meet the forest plan requirement, not for project-by-project decisions about how to protect at-risk species.  Let’s see if the standards and guidelines add anything …

G-SCC-3: To maintain viability of species of conservation concern, reduce habitat fragmentation and maintain structural conditions of sagebrush ecosystems through design of management activities. Patch sizes should not be less than 5 acres. (Forestwide)

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

Wow.  Apparently any “structural conditions” will do, but they at least appear to concede that there is a minimum patch size needed for some species in sagebrush ecosystems (this is actually the kind of “specific” desired condition the Planning Rule envisioned), but conversely there is not enough science to tell them what is needed for anywhere else.  If the courts say this is good enough, then the Forest Service has essentially excised the diversity requirement for forest plans from NFMA.  (Never mind the question of “how much did the Forest Service spend on forest planning to get THIS?”)  (This is a continuation of a pattern discussed here, and may lead to some of the same kinds of problems under ESA.)