NEPA Gone Wild

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This essay by Ezra Klein in the NY Times is worth a look. (I hope this Share link works — the Times says that, as a subscriber, I can send links to 10 articles per month, and anyone can read the linked articles).

In “Government Is Flailing, in Part Because Liberals Hobbled It,” Klein suggests that NEPA and other environmental laws, are necessary and have been successful, but now make it too easy to block needed projects.

Zoom out from the specifics, though, and look at what it reveals about how government, even in the bluest of blue communities, actually works. Why was it so easy for a few local homeowners to block U.C. Berkeley’s plans, over the opposition of not just the powerful U.C. system but also the mayor of Berkeley and the governor of California? The answer, in this case, was the California Environmental Quality Act — a bill proposed by environmentalists and signed into law in 1970 by Gov. Ronald Reagan that demands rigorous environmental impact reviews for public projects, and that has become an all-purpose weapon for anyone who wants to stymie a new public project or one that requires public approval.

There are laws like this in many states, and there’s a federal version, too — the National Environmental Policy Act. They’re part of a broader set of checks on development that have done a lot of good over the years but are doing a lot of harm now. When they were first designed, these bills were radical reforms to an intolerable status quo. Now they are, too often, powerful allies of an intolerable status quo, rendering government plodding and ineffectual and making it almost impossible to build green infrastructure at the speed we need.

…

…environmental victories of yesteryear have become the obstacles of this year. Too many of the tactics and strategies and statutes are designed to stop transformational, or even incremental, projects from happening. Modest expansions to affordable housing or bus service are forced to answer for their environmental impact. But the status quo doesn’t have to win any lawsuits or fill out any forms to persist.”

Coordination with Counties – Lincoln National Forest Plan Revision

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Since Sharon has invoked my name twice recently, and not particularly correctly, with regard to the role of local interests in national forest management, I thought I would refocus that discussion on how this is supposed to work for local governments during forest planning using a current example that came along.  It involves the participation (or lack thereof) by a county in New Mexico in the forest plan revision process for the Lincoln National Forest (where a final revised plan is expected soon).

The 2012 Planning Rule §219.4 requires “coordination with other public planning efforts.”  It requires a review of “the planning and land use policies of … local governments, where relevant to the plan area,” which must be displayed in the EIS for the revised forest plan.  It concludes, “(3) Nothing in this section should be read to indicate that the responsible official will seek to direct or control management of lands outside of the plan area, nor will the responsible official conform management to meet non-Forest Service objectives or policies.”

On March 1, the Eddy County Board of County Commissioners approved a resolution opposing the revised plan.  They stated that, “it is clear that the USFS failed to review, consider and identify planning conflicts between Eddy County and the proposed plan.”  Those alleged conflicts include:

  • would increase restrictions for cattle ranchers with reduced cattle grazing levels and increased financial burdens on cattle producers
  • “creates large areas restricted and potentially inaccessible to the County to fulfill its public health and safety duties”
  • “creates areas that will no longer allow proper wildlife management control increasing the danger to Eddy County citizen’s lives and property”

Eddy County’s resolution asked for a “coordination agreement” between the County and the Forest Service, “To establish roles and responsibilities for both parties, ensuring the citizens of Eddy County are still provided with the necessary services they depend on.”

I would agree that these are all arguably things that should be considered by the Forest Service, depending on what the specific plans or policies of the County say regarding these issues.  (Unlike some earlier attempts at county “coordination,” they do not attempt to claim they have their own plans for national forest lands.)  There is also nothing wrong with a “coordination agreement” to establish roles and responsibilities for “planning efforts,” but this is not something recognized by the Planning Rule, and is not a requirement.  Moreover, the roles and responsibilities for national forest management are established in federal law and regulations; what local residents “depend on” does not dictate national forest management (as indicated by the highlighted language above from the Rule).

In this case, it appears that the County is also trying to close the barn door too late.  According to the Forest, “In 2019 we reached out to Eddy County, inviting them to become a cooperating agency (in accordance with NEPA), which would have allowed them to be more deeply involved in the process of developing the plan, however we received no response from the county. Additionally, Eddy County did not provide any official comments on the forest plan to us.”  (Failure to comment on the plan about the omissions they claim here would disqualify them from filing an objection and probably from suing.)

 

 

Effectiveness of Fuel Treatments at the Landscape Scale: Jain et al. 2022

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I was looking for a “Scientist of the Week” to honor and ran across this JFSP report. I’d like to give a vote of appreciation to these authors, and to the folks at JFSP for funding a useful synthesis of the research.

What I think it interesting about this paper is that the authors used different forms of knowledge (empirical, simulation, and case studies) to look at the question.   I also like that they separated out (1) direct wildfire effects, (2) impacts to suppression strategies and tactics, and (3) opportunities for BWU. Some studies only talk about (1) or, in some cases,  it’s not clear what exactly they are talking about. Here’s one chart.

I particularly liked the section “Identified management and policy considerations and research gaps” on page 25.

Here is an interesting section of that:

Our synthesis focused primarily on how fuel treatments performed in the event of large wildfires, rather than the effect of fuel treatments at keeping wildfires small. Treatments offer suppression opportunities and subsequently influence how many fires are being extinguished in fuel treatments. In the case studies, there were comments that the wildfires ignited outside the fuel treatments and therefore when fuel treatments were burned by wildfires, the wildfires were already large. If fuel treatments allow for effective wildfire management, including successful full suppression compared to untreated areas, our focus may have undervalued their suppression benefit.


Longevity of fuel treatments was mentioned in all three synthesis types. In most cases fuel treatments were short–lived from 1 year to 20 years; however, in most cases the longevity of fuels was focused on surface fuels. Future studies should focus on the longevity of treatment effects in each relevant fuel stratum to test the following hypotheses: 1) surface fuels have the shortest fuel treatment longevity; 2) crown fuels have the longest fuel treatment longevity; 3) ladder fuels longevity decreases when crown fuels are separated creating growing space for latter fuels to flourish. Studies that focus on fuel strata longevity can inform managers when is it necessary to conduct maintenance treatments and choose a method of treatment that extends treatment longevity.


A discussion of research gaps in empirically based studies is premature given the current state of knowledge. Empirical approaches to understanding landscape–level fuel treatment effectiveness are in their infancy. Indeed, the field is at a point where clear and precise terms and concepts are not broadly recognized. The fundamental issue is the varied and  imprecise use of the term ‘landscape.’ Wildfire is a landscape–level process. Fuel treatment effectiveness should be evaluated by how it affects that process, functionally, from a landscape perspective. The terms landscape scale and landscape size have little generalizable meaning. Large wildfires and or large treatments may be called ‘landscape’, but our inference on treatment effectiveness will remain constrained to within–site (i.e., within treatment) effects if the sampling design and analysis are site–level and not also measuring effects outside the treatment footprint. Therefore, instead of identifying gaps in understanding, there should be 1) broad recognition of what is meant by landscape–level fuel treatment effectiveness and how the characteristics of fuel treatments affect wildfire activity outside of treatment boundaries, and 2) long–term commitment to designing and implementing research projects at the landscape level over large areas that can inform questions and test hypotheses about the type, size, density, and configuration of fuel treatments that best affect subsequent wildfire in desirable directions.

The authors say “Wildfire is a landscape-level process. Fuel treatment effectiveness should be evaluated by how it affects that process, functionally, from a landscape perspective.” It seems to me that effectiveness would be measured as “do these treatments make wildfires easier to manage, with management including protecting communities, water and other infrastructure, and protecting species and watersheds from excessively negative impacts.” And I don’t really care about defining “landscape scale” except for the idea that say if you are planning PODs, you obviously have to think at the appropriate scale. But perhaps we all have different definitions. That could certainly make researchers’ lives difficult if we are all operating from different definitions and thinking we mean the same thing.

Litigation loose ends – Januaryish 2022

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These are a few things missed between the last Forest Service summaries.  Links are to court documents or articles.

FOREST SERVICE COURT DECISIONS

Unite the Parks v. U. S. Forest Service (9th Cir.)

On January 25, the Ninth Circuit Court of Appeals ordered a district court to reconsider its denial of a preliminary injunction against 31 logging projects in endangered Pacific fisher habitat on the Sierra and Sequoia National Forests.  The district court decision had not properly taken into account recent information.  (The 9th Circuit did not issue its own injunction, however.)   (The article includes a link to the opinion.)

Neighbors of the Mogollon Rim v. U. S. Forest Service (D. Ariz.)

On January 26, in a case filed by intermingled private landowners, the Arizona district court upheld the decision to restart livestock grazing on inactive allotments and the Heber-Reno Sheep Driveway on the Tonto National Forest with a new allotment management plan and term permit based on an EA.  The court found no violation of NEPA or ESA.  It found the decision consistent with the forest plan even if it did “not move the Tonto National Forest towards the long-term resource goals set out in the Forest Plan,” because, “the Proposed Action would not have a significant adverse effect on these elements, and because, “grazing is a permissible and contemplated use under the Tonto Forest Plan.”  (I don’t see the logic here, since neither of these reasons address the issue raised by plaintiffs.)

SETTLEMENT

Center for Biological Diversity v. Bernhardt (D. Nevada)

On January 19, the parties settled this case, allowing the implementation of the Lee Canyon Ski Area Master Development Plan on the Humboldt-Toiyabe National Forest (introduced here).  The settlement agreement calls for habitat buffer zones where construction of mountain bike trails would not be allowed under most circumstances and a $250,000 pledge from the resort to UNLV for research.

NEW CASES

Strawberry Water Users Association v. U.S.A. (D. Utah).

On January 3, plaintiff sued the Forest Service for allegedly letting two lightning-ignited wildfires burn on the Uinta-Wasatch-Cache National Forest in 2018, resulting in $200 million in damage to its water infrastructure.  (Details on the fires are available here.)

Center for Biological Diversity v. Haaland (D. Minn.)

On January 25, five plaintiff organizations sued USDI, the Forest Service, Fish and Wildlife Service, and the Army Corps of Engineers over decisions to exchange lands and permit the PolyMet copper mine on the Superior National Forest based on a 2016 Biological Opinion’s conclusions that the Project is not likely to jeopardize the Canada lynx, gray wolf, or northern long-eared bat, and is not likely to adversely modify the designated critical habitat for the Canada lynx or gray wolf.  (The article includes a link to the opinion.)

Meanwhile, a second mine on the Superior National Forest was derailed on January 26, when the Interior Department’s principal deputy solicitor, wrote in a legal opinion that the Trump administration fell short in its legal obligations by conducting an inadequate environmental analysis and by sidestepping the Forest Service in its decision-making regarding the proposed Twin Metals project.

OTHER AGENCIES

Friends of the Earth v. Haaland (D. D.C.)

On January 27, the District of Columbia district court vacated a sale of 1.7 million acres of oil and gas leases in the Gulf of Mexico because the Interior Department miscalculated the greenhouse gas emissions from drilling.  It held that the 5-year program EIS should not have concluded that emissions would be higher under the no-action (no drilling) alternative because, “the record in this case includes papers from the Stockholm Environment Institute that underscore the likely decrease in foreign consumption and provides a methodology for translating the reduction in barrels of oil into a reduction in greenhouse gas emissions…” (my emphasis).  (The question of substitution effects has come up on this blog.)   (Here is an article discussing the case.)

Louisiana v. Biden (W.D. La.)

However, on February 11, the Western District of Louisiana enjoined an Executive Order that would have required government agencies to also account for the social benefits of reducing carbon pollution, such as changes in net agricultural productivity, human health, property damage from increased flood risk, and the value of ecosystem services.  The court held that, “the President lacks power to promulgate fundamentally transformative legislative rules in  areas of vast political, social, and economic importance,” he failed to follow rulemaking procedures required by the APA, and the estimates included in the order are arbitrary and capricious.

Bradford v. U. S. Department of Labor (D. Colo.)

On January 24, the Colorado district court dismissed a lawsuit filed by Colorado rafting companies seeking to block a new rule that raised the minimum wage for federal contractors to $15 an hour. (The article includes a link to the opinion.)

ESA LISTING BONUS

On January 25, the U. S. Fish and Wildlife Service proposed listing the Sacramento Mountains checkerspot butterfly as an endangered species under the Endangered Species Act.  Primary threats include unregulated off-road vehicle use and fire suppression on the Lincoln National Forest.  (Comments are due march 28.)  (The article includes a link to the Federal Register Notice.)

On December 27, 2021, the U. S. Fish and Wildlife Service proposed listing four of six distinct population segments (see map) of the foothill yellow-legged frog under the ESA – the South Sierra and South Coast DPSs as endangered and the North Feather and Central Coast DPSs as threatened.  Logging and grazing are among the threats to the species, and the North Coast and North Sierra populations were not listed in part because of the Forest Service requirements for sensitive species (which will go away when forest plans are revised), and because, “the species in northern portions of California and the species’ range in Oregon on National Forest or BLM lands currently receive protection through conservation measures and best management practices under the Northwest Forest Plan’s Survey and Manage program” (which is currently required by forest plans).  (Quoting the Federal Register Notice linked to this news release.)  (The comment period is closed.)

Call for Wildfire Commission Member Applications

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FYI, Smokey Wire folks….

 

Biden-Harris Administration Issues Call for Wildfire Commission Member Applications

Members will recommend prevention and restoration strategies to tackle national wildfire crisis

The Departments of the Interior, Agriculture, and Homeland Security through the Federal Emergency Management Agency (FEMA) are now accepting membership applications for the Wildland Fire Mitigation and Management Commission.

President Biden’s Bipartisan Infrastructure Law authorized establishment of the Wildland Fire Mitigation and Management Commission. Announced in December 2021, it will play a key role in recommending federal policies and strategies to more effectively prevent, mitigate, suppress, and manage wildland fires, including the rehabilitation of affected lands.

The commission is seeking volunteer members from diverse backgrounds, with a specific focus on members who represent non-federal interests, as required by the Bipartisan Infrastructure Law. Members will commit to serve for the life of the commission, which is estimated to be a year and a half, with the first meeting targeted for late spring 2022.

The commission will prepare policy recommendations and submit them to Congress within a year of its first meeting. Members should expect to devote between 10 and 15 hours a month to commission duties, which include attending meetings, strategic planning, and development of the reports. The Departments of the Interior, Agriculture, and Homeland Security through FEMA will provide support and resources to assist members with coordination and facilitation of their duties for the duration of the commission.

Non-federal membership, as required by law, will include state, local, Tribal, territory, and non-government partners with experience in preventing, mitigating, and managing wildland fires and the wildland-urban interface. Preference will be given to applicants from areas of high wildfire risk and areas with a high level of wildland-urban interface.

Applications for membership must be submitted via the online form by 11:59 pm Pacific Time on March 25, 2022. To ensure the process is equitable for all applicants, those who have previously expressed interest in membership must still apply via the online form.

For more information, visit the commission website or email wildlandfirecommission@usda.gov.

In addition to establishing the commission, the Bipartisan Infrastructure Law provides historic funding to address wildfire hazards, including $8.25 billion for a suite of programs aimed at reducing wildfire risks, detecting wildfires, instituting firefighter workforce reforms, and building more resilient infrastructure.

Let’s Discuss: Performance Measure Recommendations from RVCC Report

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As usual, the folks at RVCC have come up with a thoughtful and experience-based report, this one called Fighting Fire With Fire.

I was reminded of this section by our discussion around the Pisgah-Nantahala Forest Plan and timber targets.

P O L I C Y O P T I O N S :

PERFORMANCE MEASURES AND BUDGETING
• Immediate action can be taken by elevating the existing “acres mitigated” KPI to a principal target on par with the two existing timber volume and acres treated targets. “Acres mitigated” is a better measure of the comprehensive action needed to reduce fire risk on one footprint acre than the current “acres treated” target. While any annual output target still suffers from the risk of prioritizing the easiest acres for treatment, use of the existing “acres mitigated” KPI would serve as a good bridge to more outcomes-based performance measures.

• Deprioritize the core performance measure of “timber volume sold.” This metric has long guided agency budget allocation and has been used as a benchmark of individual employee career success. While the agency tracks many KPIs, the timber volume target plays a disproportionate role in agency behavior. Addition of new KPIs is insufficient to motivate agency change without also relaxing the timber volume target. Furthermore, the timber volume target should not be conflated with a fire risk reduction outcome.

• Incentivize exceeding fuels reduction targets. So long as annual output targets remain in effect, performance measurement systems – and accompanying budget impacts – should incentivize overperformance, not penalize it. Currently, if a unit exceeds a fuels reduction target, they are expected to perform to the same advanced level in future budget years, essentially disincentivizing innovation and excellence. Performance above target could be rewarded with additional funding.

• The Forest Service should work with the Office of Management and Budget and key external partners to propose new outcomes-based targets that capture the complex, modern
mission of the agency. While outcome measures are more difficult to achieve than simpler annual output targets, there are models for such practices already in existence (see on-the-ground example below).

Here’s the example:

The Colorado Forest Restoration Institute has led participatory mapping to develop fire risk reduction maps that balance multiple values and account for local concerns and knowledge. Such a process could form the core of an outcomes-based performance measure. Agency performance could be evaluated based on annual reports from the agency to local stakeholders demonstrating accomplishments based on priority maps, showing progress towards locally determined goals. Such a performance measure would serve to provide accountability to local stakeholders as well as agency leadership and Congress.

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These raise three questions in my mind.

1. What would “deprioritizing” timber targets look like in practice?  Are FS employees more accountable for them than other KPIs?  How accountable are employees in meeting any kinds of targets? Which reminded me of the Mills Accountability Report. I couldn’t find it, but I did find this… in this GAO report from 2003.

Forest Service Has Made Little Progress in Resolving Known Performance Accountability Problems, unlike Other Federal Land Management Agencies.

On another issue, some retirees have questioned how management reviews are conducted nowadays compared to say the BLM.

2. As Jon reminds us, these are national forests,  not locally managed, so the idea of local outcome-based performance measures might not fit with (powerful) groups that support the more nationalized policy view.

3. How could you meaningfully accumulate those measures in a report to Congress? I’m not saying it couldn’t be done, but this seems like the old “consistency vs. decentralization” tension.  Ideas?

 

4FRI By The Numbers- January 2022 Accomplishment Report

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Why it 4FRI important?  At our Region 2 Wildfire Strategy Roundtable, I heard “entrepreneurs need some guarantees for supply.” Which makes sense. But as we have seen, that and “having NEPA done” hasn’t necessarily worked out as well as expected for a variety of reasons that are important to understand.  Since they are the main pioneers in the efforts to do fuel treatments at scale in places without existing infrastructure sufficient to process the material (a common problem across the west), I think it’s worth understanding their context to help understand how replicable it is in other places.

Here’s a handy chart of what they accomplished by year.

 

Here’s the January accomplishment report. It includes a list of NEPA projects and NEPA status.

$200 million bond issued to ramp up forest restoration in northern Arizona

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The title of this post is the title of an article by an Arizona public radio station, KNAU. The link to the bond is a “Sustainability-Linked Bond Framework” that details what the bond entails. I didn’t see information about what would happen if treatment targets are not met.

The company tasked with thinning hundreds of thousands of acres of northern Arizona’s forests has been issued a $200 million bond to ramp up work. It comes as large-scale restoration in the region has moved at a slow pace for nearly a decade.

Goldman Sachs issued the bond to NewLife Forest Restoration. It’s included in what’s known as the U.S. green bond market, and mandates specific targets for thinned acreage every year.

NewLife holds the nation’s largest U.S. Forest Service stewardship contract at 300,000 acres for the Four Forest Restoration Initiative. But the company has struggled to keep up with the pace and scale of the thinning work averaging only about 1,700 acres annually for the last nine years. Under the bond, NewLife’s targets will be 8,000 acres this year, ramping up to 20,000 by 2025, though the company hopes to thin more when it reaches full operation.

NewLife says the funds will help ramp up thinning work by allowing the completion of its facility in Bellemont that opened last year, and increasing capacity at its Lumberjack sawmill near Heber.

4FRI is one of the nation’s largest forest restoration projects and aims to eventually thin 2.4 million acres across the Coconino, Kaibab, Tonto and Apache-Sitgreaves national forests to reduce the risk of catastrophic wildfire.

International Women’s Day: Women’s Work – Collaboration and Peace-Seeking?

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From Boise State Public Radio’s new series https://www.boisestatepublicradio.org/podcast/womens-work

When I was working for the Forest Service as the Region 2 Planning Director, one of my favorite parts of the job was reviewing the Regional Forester’s Honor Awards. Awardees, both internal and external, came from all over the Region; the entertainment was superb (Dave Steinke videos) and a good time was had by all. It reminded me of Mr. Fezziwig’s ball from The Christmas Carol.

If we read many media reports, they focus on the problems and not the successes. Each one of the awardees deserved their own news coverage, and maybe some of the local papers did cover them. The larger media… not so much. Anyway, I remember a particular time awardees with The Nature Conservancy, something to do with the BFF and/or prairie dogs and ranchers I think in South Dakota, came to our morning meeting. It struck me what one of the folks (a woman) said, “we’re not enemies, we all want to do the right thing.”

I wondered at the time whether there was something about our biology, family experiences, or the broader culture (or the interaction of those factors), that makes women more likely to engage in peace-seeking and relationship-building, and being able to see potential middle ground.  Possibly struggling within your own group/discipline for recognition might make you feel less more inclined to question and less inclined to toe the group/discipline line. Or if we’re not likely to ever make it to the decision-making level, we have less to lose by being outliers.  I think of free thinkers like Tisha Schuller and Patty Limerick here in Colorado, and Susan Jane Brown in Oregon.  Or Judith Curry, or Bari Weiss in the broader world.  But perhaps those are older women’s experiences of non-inclusion and those have changed drastically in the past 20 years.  Sadly, it does not appear so in the science biz. Example, this 2019 issue of Lancet.

That is certainly not to say that all women are one way and all men are another, like anything else, there’s a broad range within each group. Still, there is a broad range of literature in a variety of fields from the biological to the anthropological to foreign policy studies, that does describe differences. For example, from the Council on Foreign Relations:

A growing body of research suggests that standard peace and security processes routinely overlook a critical strategy that could reduce conflict and advance stability: the inclusion of women. Evidence indicates that women’s participation in conflict prevention and resolution advances security interests. One study found that substantial inclusion of women and civil society groups in a peace negotiation makes the resulting agreement 64 percent less likely to fail and, according to another study, 35 percent more likely to last at least fifteen years. Several analyses suggest also that higher levels of gender equality are associated with a lower propensity for conflict, both between and within states. Despite growing international recognition of women’s role in security, their representation in peace and security processes has lagged.

My observation is that women in our neck of the environmental conflict woods are well represented in the partnership and collaboration world. Perhaps as the stakes get higher, less so, although that would be interesting for researchers to examine further.  Does anyone know of researchers looking into this?  This Harvard study is also interesting and possibly worthy of discussion- it’s about males potentially having more post-conflict affiliation. How or does that play out in our world?

And of course we’ve previously posted on gender as related to litigation:
Litigation and Mediation: Exploring the Gendering of Touchy-Feely Options

In 2013, Laura van Riper published this article in Rangelands. There’s a pdf available that I think you can access here. If not, let me know.

On the Ground
• In recent years women have become more visible as leaders of collaborative range management in the western United States. Drawing on the experiences of four such women, gender aspects of leadership and community activism are explored.

• The four women leaders consider their efforts as “nothing special” and “business as usual”; gender considerations are not prominent in how they view their success.

• Personality traits are important determinants of exceptional leadership. Although such traits are found in both men and women, there may be cases where the more feminine attributes that emphasize peacemaking, community welfare, networking, and consensus building facilitate the management of complex problems.

• Collaborative leadership is vital for rangeland management. Recruiting and training such leaders should focus on identifying those with appropriate personality traits and aptitudes—regardless of gender—and providing them with the tools, skills, and support networks for success. The four successful women ranchers described here give us tangible models to replicate.

Thoughts? Experiences?

Forest Service Disaster Relief Funding: Planning vs. Implementation

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This note from the American Forest Resource Council‘s February 2022 newsletter may be of interest:

Forest Service Receives Disaster Relief Funding; Timber Outputs Continue to Diminish

The Pacific Northwest Region of the U.S. Forest Service was allocated $291.2 million in disaster relief supplemental funding to be directed to recovery actions associated with wildfires, floods, and other natural disasters. This allocation is a component of the $1.36 billion of supplemental appropriations provided to the Forest Service through the Extending Government Funding and Delivering Emergency Assistance Act of 2021. Most of the funding directed to the Pacific Northwest will be allocated to National Forests in Oregon, specifically those in western Oregon impacted by the 2020 Labor Day fires. The Mt. Hood, Willamette, Umpqua, and Rogue River-Siskiyou National Forests will receive 85% of the $252.9 million directed to Oregon. A complete breakdown of the funding allocation can be found here.

According to a press release on February 16, a portion of the $30.4 million allocated to the Rogue River-Siskiyou National Forest will be directed to the removal of fire-killed trees posing a safety hazard to forest roads caused by the Slater Fire. Similar expenditure of funds is certain for the Mt. Hood, Willamette, and Umpqua National Forests. Each attempted to removed hazard trees by selling them to the local timber industry for manufacturing into wood products; but were met with lawsuits from special interest groups that halted the removal and utilization of those fire-killed trees. Other activities proposed include road resurfacing, culvert replacements, bridge repair, hazardous material/waste removal, and nursery upgrades.

Counter to conventional thinking, this type of funding influx will likely cause the Region’s timber and vegetation management programs to shrink rather than remain stable. For example, as of December 1, 2021, the Willamette National Forest’s assigned timber target was 65 million board feet (MMBF). Less than three months later that target was reduced by nearly 50% to 35 MMBF following the allocation of $78.6 million in disaster relief funding. The cause of this decline is partly of function of reprioritization to address critical disaster relief needs and partly a function of how this supplemental funding can be used.

There are generally two operative sides to every project on U.S. Forest Service land: the planning side (NEPA analysis, wildlife & heritage surveys, timber sale layout, etc.) and the implementation side (completion of the work). Since each side is dependent on the other to achieve project success, each side must be adequately funded in a well-balanced manner. Infusions of supplemental funding, such as the disaster relief fund, have a tendency to disrupt this balance since its allocation is typically limited to the implementation side of the equation and not to the planning side.

For example, the Forest Service may allocate $10 million of supplemental funding to resurface damaged roads. That money will be directed to the material and labor necessary to do the resurfacing. However, none of that money will enable the Forest Service to hire a new engineer to plan and oversee this work, or a new soil scientist to analyze the impacts of the roadwork. The Willamette National Forest recently pointed to engineering gaps as partial cause for the reduction of their timber outputs, as engineers are redirected from timber sale planning to disaster relief planning.

Another scenario that is currently playing out on several National Forests impacted by wildfire is related to their inability to remove and sell fire-killed trees posing a hazard to roads. The Rogue River-Siskiyou National Forest will allocate funding to fell and dispose of those hazard trees, but none of that funding will support the planning and analysis necessary to facilitate such work. Once again, the Forest Service will be compelled to redirect its current staffing resources and by doing so will likely suffer shortfalls in their vegetation management and timber programs.

If the vast majority of supplemental funding continues to be directed solely to the implementation side while the planning side is neglected, we will likely see future renditions of this year’s Willamette National Forest program, only at a much larger scale. This should be a troubling sign for anyone who is interested in seeing the $4 billion from the Infrastructure Investment and Jobs Act directed to forest management result in more acres treated for hazardous fuels reduction or elevated timber outputs. /Andy Geissler