Validated Science versus Unproven Scientific Hypothesis – Which One Should We Choose?

In a 6/13/18 article, David Atkins provides a critique of the assumptions behind the Law et al article titled: “Land use strategies to mitigate climate change in carbon dense temperate forests” and shows how hypothetical science can and has been used, without any caveat, to provide some groups with slogans that meet their messaging needs instead of waiting for validation of the hypothesis and thereby considering the holistic needs of the world.

I) BACKGROUND

The noble goal of Law et. al. is to determine the “effectiveness of forest strategies to mitigate climate change”. They state that their methodology “should integrate observations and mechanistic ecosystem process models with future climate, CO2, disturbances from fire, and management.”

A) The generally (ignoring any debate over the size of the percentage increase) UNCONTESTED points regarding locking up more carbon in the Law et. al. article are as follows:
1) Reforestation on appropriate sites – ‘Potential 5% improvement in carbon storage by 2100’
2) Afforestation on appropriate sites – ‘Potential 1.4% improvement in carbon storage by 2100′

B) The CONTESTED points regarding locking up 17% more carbon by 2100 in the Law et. al. article are as follows:
1) Lengthened harvest cycles on private lands
2) Restricting harvest on public lands

C) Atkins, at the 2018 International Mass Timber Conference protested by Oregon Wild, notes that: “Oregon Wild (OW) is advocating that storing more carbon in forests is better than using wood in buildings as a strategy to mitigate climate change.” OW’s first reference from Law et. al. states: “Increasing forest carbon on public lands reduced emissions compared with storage in wood products” (see Law et. al. abstract). Another reference quoted by OW from Law et. al. goes so far as to claim that: “Recent analysis suggests substitution benefits of using wood versus more fossil fuel-intensive materials have been overestimated by at least an order of magnitude.”

II) Law et. al. CAVEATS ignored by OW

A) They clearly acknowledge that their conclusions are based on computer simulations (modeling various scenarios using a specific set of assumptions subject to debate by other scientists).

B) In some instances, they use words like “probably”, “likely” and “appears” when describing some assumptions and outcomes rather than blindly declaring certainty.

III) Atkins’ CRITIQUE

Knowing that the modeling used in the Law et. al. study involves significant assumptions about each of the extremely complex components and their interactions, Atkins proceeds to investigate the assumptions which were used to integrate said models with the limited variables mentioned and shows how they overestimate the carbon cost of using wood, underestimate the carbon cost of storing carbon on the stump and underestimate the carbon cost of substituting non-renewable resources for wood. This allows Oregon Wild to tout unproven statements as quoted in item “I-C” above and treat them as fact and justification for policy changes instead of as an interesting but unproven hypothesis that needs to be validated in order to complete the scientific process.

Quotes from Atkins Critique:

A) Wood Life Cycle Analysis (LCA) Versus Non-renewable substitutes.
1) “The calculation used to justify doubling forest rotations assumes no leakage. Leakage is a carbon accounting term referring to the potential that if you delay cutting trees in one area, others might be cut somewhere else to replace the gap in wood production, reducing the supposed carbon benefit.”
2) “It assumes a 50-year half-life for buildings instead of the minimum 75 years the ASTM standard calls for, which reduces the researchers’ estimate of the carbon stored in buildings.”
3) “It assumes a decline of substitution benefits, which other LCA scientists consider as permanent.”
4) “analysis chooses to account for a form of fossil fuel leakage, but chooses not to model any wood harvest leakage.”
5) “A report published by the Athena Institute in 2004, looked at actual building demolition over a three-plus-year period in St. Paul, Minn. It indicated 51 percent of the buildings were older than 75 years. Only 2 percent were demolished in the first 25 years and only 12 percent in the first 50 years.”
6) “The Law paper assumes that the life of buildings will get shorter in the future rather than longer. In reality, architects and engineers are advocating the principle of designing and building for longer time spans – with eventual deconstruction and reuse of materials rather than disposal. Mass timber buildings substantially enhance this capacity. There are Chinese Pagoda temples made from wood that are 800 to 1,300 years old. Norwegian churches are over 800 years old. I visited at cathedral in Scotland with a roof truss system from the 1400s. Buildings made of wood can last for many centuries. If we follow the principle of designing and building for the long run, the carbon can be stored for hundreds of years.”
7) “The OSU scientists assumed wood energy production is for electricity production only. However, the most common energy systems in the wood products manufacturing sector are combined heat and power (CHP) or straight heat energy production (drying lumber or heat for processing energy) where the efficiency is often two to three times as great and thus provides much larger fossil fuel offsets than the modeling allows.”
8) “The peer reviewers did not include an LCA expert.”
9) The Dean of the OSU College of Forestry was asked how he reconciles the differences between two Doctorate faculty members when the LCA Specialist (who is also the director of CORRIM which is a non-profit that conducts and manages research on the environmental impacts of production, use, and disposal of forest products). The Dean’s answer was “It isn’t the role of the dean to resolve these differences, … Researchers often explore extremes of a subject on purpose, to help define the edges of our understanding … It is important to look at the whole array of research results around a subject rather than using those of a single study or publication as a conclusion to a field of study.”
10) Alan Organschi, a practicing architect, a professor at Yale stated his thought process as “There is a huge net carbon benefit [from using wood] and enormous variability in the specific calculations of substitution benefits … a ton of wood (which is half carbon) goes a lot farther than a ton of concrete, which releases significant amounts of carbon during a building’s construction”. He then paraphrased a NASA climate scientistfrom the late 1980’s who said ‘Quit using high fossil fuel materials and start using materials that sink carbon, that should be the principle for our decisions.’
11) The European Union, in 2017, based on “current literature”, called “for changes to almost double the mitigation effects by EU forests through Climate Smart Forestry (CSF). … It is derived from a more holistic and effective approach than one based solely on the goals of storing carbon in forest ecosystems”
12) Various CORRIM members stated:
a) “Law et al. does not meet the minimum elements of a Life Cycle Assessment: system boundary, inventory analysis, impact assessment and interpretation. All four are required by the international standards (ISO 14040 and 14044); therefore, Law et al. does not qualify as an LCA.”
b) “What little is shared in the article regarding inputs to the simulation model ignores the latest developments in wood life cycle assessment and sustainable building design, rendering the results at best inaccurate and most likely incorrect.
c) “The PNAS paper, which asserts that growing our PNW forests indefinitely would reduce the global carbon footprint, ignores that at best there would 100 percent leakage to other areas with lower productivity … which will result in 2 to 3.5 times more acres harvested for the same amount of building materials. Alternatively, all those buildings will be built from materials with a higher carbon footprint, so the substitution impact of using fossil-intensive products in place of renewable low carbon would result in >100 percent leakage.”
d) More on leakage: “In 2001, seven years after implementation, Jack Ward Thomas, one of the architects of the plan and former chief of the U.S. Forest Service, said: “The drop in the cut in the Pacific Northwest was essentially replaced by imports from Canada, Scandinavia and Chile … but we haven’t reduced our per-capita consumption of wood. We have only shifted the source.”
e) “Bruce Lippke, professor emeritus at the University of Washington and former executive director of CORRIM said, “The substitution benefits of wood in place of steel or concrete are immediate, permanent and cumulative.””

B) Risks Resulting from High Densities of Standing Timber
1) “The paper underestimates the amount of wildfire in the past and chose not to model increases in the amount of fire in the future driven by climate change.”
2) “The authors chose to treat the largest fire in their 25-year calibration period, the Biscuit Fire (2003), as an anomaly. Yet 2017 provided a similar number of acres burned. … the model also significantly underestimated five of the six other larger fire years ”
3) “The paper also assumed no increase in fires in the future
4) Atkins comments/quotes support what some of us here on the NCFP blog have been saying for years regarding storing more timber on the stump. There is certainty that a highly significant increase in carbon loss to fire, insects and disease will result from increased stand densities as a result of storing more carbon on the stump on federal lands. Well documented, validated and fundamental plant physiology and fire science can only lead us to that conclusion. Increases in drought caused by global warming will only increase the stress on already stressed, overly dense forests and thereby further decrease their viability/health by decreasing the availability of already limited resources such as access to minerals, moisture and sunlight while providing closer proximity between trees to ease the ability and rate of spread of fire, insects and disease between adjacent trees.

Footnote:
In their conclusion, Law et. al. state that“GHG reduction must happen quickly to avoid surpassing a 2°C increase in temperature since preindustrial times.” This emphasis leads them to focus on strategies which, IMHO, will only exacerbate the long-term problem.
→ For perspective, consider the “Failed Prognostications of Climate Alarm

Why we need coordinated planning for habitat connectivity

The Bridger-Teton National Forest amended its forest plan in 2008 to designate the portion of the “Path of the Pronghorn” migration corridor in Wyoming for special management to protect this historic 90-mile route with a northern terminus in Grand Teton National Park used for summer range.  It’s probably the most significant action taken by the Forest Service to plan for wildlife connectivity.

The BLM chose to not play along at the southern end where major oil and gas fields are found in the species’ winter range, and the migration route lacks recognition, and protection, through BLM lands along its southern reaches.  Now they have issued an EIS for oil and gas development there.  Ideally, the EIS will disclose the effects on pronghorn migration and on the national park (using the best available science), which could include exterminating this migration and its pronghorn herd.  But I wanted to comment on the planning aspect of this problem.  BLM blames the State of Wyoming:

“It would help us out if the [Wyoming] Game and Fish were to formally designate something in there,” said Caleb Hiner, who manages the BLM’s Pinedale Field Office.

The Forest Service didn’t wait for state action to protect national forest lands.  As an environmental activist said, “The BLM has all the authority it needs to protect what it wants to protect in a site-specific document,… The BLM could decide tomorrow that it doesn’t want to lease or develop any of the NPL.”

The 220-square-mile project has major economic potential, and could generate 950 jobs and produce somewhere in the range of 3 trillion cubic feet to 5 trillion cubic feet of natural gas, Hiner said. It would add up to 350 wells to the landscape annually for the next 10 years, a level of development that equals the number of wells permitted for drilling in the BLM’s entire Pinedale Field Office during 2017.

The argument by the proponent seems to be that they can figure out mitigation well-by-well, but at that point there is little opportunity to develop an effective strategy for pronghorn to navigate the system of wells, especially with no plan-level requirement to do so.

It is important for federal land managers be leaders in coordinating connectivity conservation planning, if for no other reason that that may be what is necessary to provide for viable populations of migrating species to continue to use federal lands.  The absence of a plan based on an overarching strategy for the full extent of the herd’s range could now be fatal to a ecological phenomenon that has been occurring, in part on national forest lands, for thousands of years.

 

Ranchers intimidate science they don’t like

Data source: “Cattle Death Loss,” a report by the USDA National Agricultural Statistics Service

A wolf researcher at Washington State University has resigned as part of a settlement of a case alleging that the university infringed on his academic freedom.

“Wielgus angered ranchers with his research of wolf behavior. He concluded the state’s policy of killing wolves that preyed on cattle was likely to increase cattle predation because it destabilized the structure of wolf packs.

Ranchers complained to the Washington State Legislature, which cut Wielgus’ funding and demanded he be removed as principal investigator on his ongoing work.”

And they got what they wanted.  So, if you’ve got enough money and political power, not only can you buy your own researchers, but you can silence publicly funded independent research.  Do you suppose they might be able to influence the research conclusions, too?  (Somehow it’s a little hard to see “powerful” environmental groups making this trick work for them.)

 

 

 

New lawsuit to protect red tree voles from logging project

(Complete story here.)

Three environmental groups are suing the U.S. Forest Service to stop an 847-acre logging project on the Umpqua National Forest in southern Oregon, about 22 miles southeast of Cottage Grove.

Red tree vole surveys were also conducted during the fall of 2016. According to the lawsuit, the Northwest Ecosystem Survey Team found 75 vole nests in the forests slated for logging, but the Forest Service decided to proceed with the project.

The North Oregon Coast population of voles is considered a candidate for listing under the Endangered Species Act by the U.S. Fish and Wildlife Service, from the Siuslaw River north to the Columbia River, due to habitat loss and fragmentation.

(A candidate species is warranted for listing, but precluded by higher priorities.)

But here’s the part I thought might be interesting:  “The Bureau of Land Management also lifted survey and management guidelines for the species in 2016.”  As things get worse off for a species everywhere else, the national forests will necessarily be under more pressure to provide regulatory mechanisms to protect the species, and conditions external to a national forest will make it harder and more important to provide conditions on the national forest that promote a viable population.  (Implications for revising the northwest forest plans?)

The mysterious disappearance of sensitive species – Flathead plan revision example

Harlequin duck (Histrionicus histrionicus)

The Forest Service created through its directives (FSM 2670) a program to manage sensitive species, which it defined as species “identified by a regional forester for which population viability is a concern.” Sensitive species “must receive special management emphasis to ensure their viability and to preclude trends toward endangerment that would result in the need for federal listing.” Up until now, forest plans had to include direction for sensitive species “to ensure viable populations throughout their geographic ranges.” In addition, all plans and projects required a biological evaluation (BE) for each sensitive species “to ensure that Forest Service actions do not contribute to loss of viability … or contribute to trends toward Federal listing.” The BE became an important tool for biologists to use at the project level.

The 2012 Planning Rule requires identification of Species of Conservation Concern (SCC). They are defined as those for which “the regional forester has determined that the best available scientific information indicates substantial concern about the species’ capability to persist over the long-term in the plan area.” The plan must maintain viable populations of these species, but there are no requirements for future projects to address them; compliance with forest plan requirements for SCCs is presumed to meet the needs of these species. This elevates the importance of plan components for these species.

The Forest Service issued an internal letter to regional foresters on June 6, 2016 explaining that it would phase out the sensitive species designation. It recognized that, “As noted in the preamble to the 2012 planning rule, “[Regional Forester Sensitive Species] are…similar to species of conservation concern.”   It also stated that, “Applying both systems on the same administrative unit would be redundant.” Consequently, “Once a revised plan is in effect, the Regional Forester’s Sensitive Species list no longer applies to that unit.” The letter acknowledges that a biological evaluation must still be prepared for a revised forest plan. (Interestingly, the letter had only a planning file code, so it did not necessarily go to biologists.)

The Forest Service is thus implementing a substantial change in wildlife policy, with no prior public involvement, through individual forest plan revisions. This should mean that the forest planning process would include a clear explanation for the public that some species are no longer sensitive, and that no species will be evaluated for future projects (outside of any effects analysis NEPA might require). In particular, there needs to be a reasoned explanation of what facts have changed for those species where viability was a concern, but isn’t any more. The forest plan EIS must also consider the effects on sensitive species of removing the existing requirements to evaluate and maintain their viability at the project level (in comparison to the no-action alternative).

Instead, the Flathead has mostly hidden any information about sensitive species. Most existing sensitive species (17 animal species) are not designated as SCC (3 animal species), but there is no list of sensitive species in any of the Forest documents (though they can be identified from a list of all species included in an EIS appendix). There is no biological evaluation as required by the Forest Service Manual and the 2016 letter. There is a summary of “biological determinations” for sensitive species, but it is not listed among the planning documents on the website. It cites the forest plan EIS as the basis for its one- or two-sentence summaries. The EIS does not mention sensitive species at all, but it includes effects analysis for species that are/were sensitive.

While it is therefore possible to find some information on sensitive species, the Forest does not explain the significant implications of that information. It does not disclose the changes in scientific information that provide the rationale for declassifying them as at-risk species, and it does not explain how the sensitive species policy changes will affect future management of this Forest. These seem like fatal (arbitrary) omissions.

Oregon to look again at western forest habitat conservation plan

The Oregon Department of Fish and Wildlife and the Oregon Department of Forestry have received a $750,000 federal grant to explore the possibility of a habitat conservation plan for state-owned forests west of the Cascades.  HCPs are authorized by §10 of ESA, and they allow the state to obtain an incidental take permit to kill or injure listed species if that happens in accordance with the plan.   The plan would consider species including the spotted owl and marbled murrelet and set guidelines for timber harvesting and recreational use.  A previous attempt to create a plan ended in 2008 without new guidelines being adopted. Without the HCP and permit, harming listed species is illegal for anyone.  “Harm” is defined to include significant habitat modification or degradation which “actually kills or injures fish or wildlife by significantly impairing essential behavioral patterns, including, breeding, spawning, rearing, migrating, feeding or sheltering” (50 C.F.R. § 222.102).

 

 

The next extinction on the national forests

Based on this year’s winter survey, the federally endangered South Selkirk mountain caribou herd may be down to three individuals – all females.  That would not be good for continued viability of the species on national forest lands.  We can try to blame Canada for what’s happened to this cross-boundary herd, but, “The mountain caribou have struggled as old growth forests have been thinned by logging and other industrial activities, George said. With thinner forests the caribou have become more susceptible to predation.”  There has been a lot of that on the Idaho Panhandle and Colville national forests over the years, though maybe not recently.  However, as recently as 2007, the Forest Service lost a lawsuit brought because of their failure to protect caribou from snowmobiles.

It would be hard to say that national forest management has had nothing to do with their current status.  Mark Hebblewhite, a Canadian wildlife biologist at the University of Montana and a science adviser to the Canadian government put it this way:

“It’s game over …  The functional loss of this herd is the legacy of decades of government mismanagement across caribou range.  It is completely unsurprising. Bad things happen to small populations.”

Meanwhile, north of the border, the boreal woodland caribou may become Canada’s spotted owl, as conflicts with logging are driving it towards extinction.   A letter from the Alberta government to Ottawa said “now is not the time to impede” an economic recovery currently underway in Alberta.  Maybe when there are three females left.

Forest plan contributes to recovery of the lesser long-nosed bat

This cave-roosting nectar-feeding bat was listed as endangered in 1988, and has just been delisted.   According to the U. S. Fish and Wildlife Service:

The primary concern regarding future viability of this subspecies continues to be roost site disturbance or loss. This is primarily an issue related to human activities and destructive actions at these roost sites.

One of the three recovery criteria is “Protect Roost and Forage Plant Habitats.”  In its final delisting rule, the FWS cites the recently revised Coronado National Forest Plan as an existing regulatory mechanism that would protect the species (one of the 5 factors to be considered in listing a species, and a key one for this species):

More than 75 percent of the range of this species in the United States is on federally managed lands and these federal agencies have guidelines and requirements in place to protect lesser long-nosed bats and their habitats, particularly roost sites… If the lesser long-nosed bat is delisted, protection of their roost sites and forage resources will continue on Federal lands because agency land-use plans and general management plans contain objectives to protect cave resources and restrict access to abandoned mines, both of which can be enforced by law enforcement officers. In addition, guidelines in these plans for grazing, recreation, off-road use, fire, etc., will continue to prevent or minimize impacts to lesser long-nosed bat forage resources. The Coronado National Forest’s 2017 Land and Resource Management Plan (LRMP) includes standards and guidelines to retain and enhance areas with paniculate agaves in order to benefit the lesser long-nosed bat.

Federal land management plans directly address the main threats to the species, providing assurance that improving trends in population numbers would continue, and allowing delisting to be warranted.  Recovery of listed species should be an important goal for plan components in revisions of the rest of the national forest plans.  (Even where the value of a species is not as obvious as being “vital to the tequila industry.”)

Huron-Manistee forest plan contributes to recovery of the Kirtland’s warbler

The U. S. Fish and Wildlife Service has proposed removing the Kirtland’s warbler from the list of endangered species.  It inhabits young stands of jack pine in the Great Lakes region and was one of the first species listed in 1967 due to fire suppression and parasitic cowbirds.  More background from the FWS is here.

The 2006 Huron-Manistee forest plan includes many plan components designed to promote the species’ recovery.  One management area includes 7 areas identified as essential Kirtland’s warbler habitat or emphasis areas.  In these areas, among other things, the forest plan prohibits grazing, trail construction, and common variety minerals mining, and there are breeding season restrictions on recreation.

The forest plan also says:

A considerable portion of the dry sand outwash plains on the Huron National Forest in Management Area 4.2 will be managed as essential habitat for the Kirtland’s warbler… This prescription area contains approximately 45 percent of all National Forest System lands on the Huron-Manistee National Forests, which includes approximately 136,000 acres of Kirtland’s warbler emphasis areas.

Objectives:

Create approximately 1,600 acres of essential breeding habitat each year. Approximately 15,960 acres of essential breeding habitat will be available at any one time into the foreseeable future. This will enable the Forests to provide for a minimum of 420 pairs of Kirtland’s warblers.

Forest-wide standards and guidelines:

Habitat and population objectives are in accordance with the Kirtland’s Warbler Recovery Plan (USDI-Fish and Wildlife Service 1985) and Strategy for Kirtland’s Warbler Habitat Management (USDA-Forest Service 2001)

Management area standards and guidelines:

  • Develop Kirtland’s warbler breeding habitat by designing and configuring treatment blocks that mimic the regeneration effects of wildfire.
  • Prepare treatment blocks for regeneration by clearcutting.
  • Treatment blocks will be no greater than 550 acres unless reviewed by the Regional Forester.
  • Provide 15 to 25 snags per acre in treatment blocks.

By specifically incorporating science-based conservation and recovery strategies into the forest plan, the plan has guided the projects that have promoted recovery, and has limited activities with adverse effects.  The forest plan may also serve as a regulatory mechanism that the FWS can cite supporting its future outlook for the species.  This is a good example of what the 2012 Planning Rule directs forest plans to do.  (It’s too bad that Forest Service is less enthusiastic about including conservation strategies that restrict timber harvest.)