Scoping By Any Other Name…Would Yield Appropriate Level of Detail for Comments???

by

 

 

I’m definitely going to get back to JWT’s letter (and a guest post on reorganization experiences), and thinning in general, but thanks to Nick Smith I ran across this announcement of a project and comment opportunities.

This project is interesting because apparently a press release (which I was unable to easily locate) gave much information, in some detail, that would usually be found in a scoping notice. In fact, I have seen scoping notices with much less detail.

This is from the Chaffee County Times, a local news outlet. When I clicked on the link, it said that eh story was posted 21 hours ago. Yet the story states that the public comment period ends Feb. 27. Perhaps you had to sign up for emails for Forest projects to get notified in time to comment? It seems to me that it’s a bad look to say “the comment period ends Feb. 27 (although we don’t know for sure that that’s true)” in a story published after the fact. Confusing.

My question to the FS is “shouldn’t generalized outreach approaches be standardized across forests and Regions for potential CEs or EAs?” I’ve been told by (some) leadership that they read TSW, and I think a generalized approach (with documents, posted on the web!) would be less trouble for employees and the public, and generate less potential drama all around.

*****************

The Salida Ranger District of Pike San Isabel National Forest is seeking public comment on a proposed vegetation treatment project near Buena Vista. The public comment period ends Feb. 27.

If approved, the proposed project would use mechanical thinning methods, hand treatments, and prescribed fire to treat vegetation on about 2,993 acres southwest of Buena Vista around Bald Mountain near the base of Mount Princeton, including 898 acres in the Kreutzer-Princeton Roadless Area. The goal of the project is to “improve forest health and reduce the extent of insect infestation,” according to a Forest Service news release.

“On slopes up to 35 percent, conventional logging equipment (i.e., harvesters and skidders), high floatation equipment (i.e., cut-to-length systems) and mastication equipment would be utilized,” a draft proposed action document said. “On sustained slopes between 35-60 percent, high floatation equipment (i.e., cut-to-length systems) or aerial yarding techniques (i.e., skyline or helicopter yarding) would be utilized. Hand treatments would be used throughout the project area and do not have any slope limitations.”

After harvesting is complete, the slash and fuels in the area may be reduced through fuelwood gathering, broadcast and/or pile burning, mastication, chipping, and/or lop and scattering them to lie within 24 inches of the ground.

Additionally, following the regeneration treatments, heavy equipment may be used to scarify the ground to stimulate new plant growth.

In addition to removal, the planned operations also include planting, where appropriate, trees of the species lodgepole pine (Pinus contorta), ponderosa pine (Pinus ponderosa), limber pine (Pinus flexilis), Douglas-fir (Pseudotsuga menziesii), and aspen (Populus tremuloides).

The nature of the treatments described in the proposed action differs by tree species.

The project would involve “regeneration harvesting” on 25 percent of aspen stands in the area, where aspen stands are clear-cut with the goal of initiating new sprouting.

For mixed conifer areas, tree thinning through the group selection method would be done with the goal of reducing tree density, reducing susceptibility to insect infestation and creating age class diversity.

The group selection method clears trees in small groups to create openings in the canopy to stimulate the growth of shade-intolerant trees. In the proposed Bald Mountain Project, groups of conifers of 0.25-2 acres would be thinned.

“In areas that are thinned, the goal is to reduce basal area to an average of 60-80 (range 40-100) square feet per acre,” the project document says. Basal area is a measure of forest density referring to the total surface area of all trees in a cross-section about 4.5 feet above the ground.

The project area has been impacted by spruce budworm, Douglas-fir beetle and possibly mountain pine beetle, the project document says. The salvage of dead trees, removal of infested trees, and overstory removal of green trees where the removal of salvage trees would create conditions where the remaining trees are susceptible to blowdown would be done to mitigate insect infestation.

For areas of ponderosa pine, thinning and group selection would be done “irregular in character to a residual basal area of 20-80 square feet per acre and favor ponderosa pine over other species.”

Areas of Lodgepole pine could see clearcuts of up to 40 acres, the project document says.

“Up to 25 percent of the lodgepole pine is proposed to be in clearcuts,” the document says. “Up to 65 percent would be thinned and contain small patch cuts where vegetation management treatments are allowed. In areas that are thinned, the goal is to reduce basal area to an average of 80-120 (range 60-140) square feet per acre. In areas with small patch cuts, the average basal area could be lower than 80 square feet per acre across the stand.”

Stands of Pinyon and Juniper would be thinned mechanically and by hand in a “mosaic of 1- to 2-acre openings to “reduce density, reduce stocking levels, reduce susceptibility to insect and disease infestations/infections, and improve vigor of the remaining trees.”

Spruce fir stands would be thinned through small patch cuts of up to 2 acres. A minimum of 10 percent of Spruce fir trees would be kept in reserves. Overstory removal would be done in areas with high spruce beetle mortality.

The project would also thin conifers encroaching on areas dominated by grasses and shrubs.

Fuel breaks adjacent to private property would extend 400 to 800 feet from the property line.

Broadcast prescribed fire burns would be utilized in stands of ponderosa pine, mixed conifer, aspen, lodgepole pine, and grass and shrubs.

“The objective is to burn the understory fuels in a low-intensity environment with the expectation that occasional torching of live trees would occur,” the project document says.

**********
The below is not from the project document:

Byan Malek Jr., Chaffee County’s weed management supervisor, said that the project area has a population of Dalmatian Toadflax, an invasive perennial forb on Colorado’s noxious weed list. A single plant can produce up to 500,000 seeds, according to the Colorado Department of Agriculture.

“In general, the usage of heavy machinery on projects dealing with organic material does have the potential to move a seed bank around,” Malek told the Times by email. “In the past, bio-control efforts have been made to help reduce this population. It is our hope and expectation that the Forest Service uses the best possible practices to prevent the spread of this noxious weed. We will also continue to monitor this area to ensure our previous control tactics continue to be effective.”

*************
And finally..

To provide comments, please send information in writing, including attachments, to: (persons named)

 

*****************

Blast From the Past: Jack Ward Thomas on WO Reorganization I of III

by

Stay tuned… I am reflecting on the comments on thinning as well as the Lindenmeyer et al. paper, so we will be back to that in a while.

For now, though, I’m posting a Blast From the Past, in which Chief Jack Ward Thomas talks to WO employees about reorganization (1995). You can read the piece in its entirety on the Forest History Society site (shout out to them!). I picked out the parts that seem similar or different to today. Sometimes I think that older people don’t have “wisdom” as such, but the experience of having lived through time gives us the ability to discern the signal (long term trends) from the noise (the fads or approaches of the current day.)

For those of a political persuasion, here is the political context for 1995. Reinventing Government was a Clinton initiative and both houses of Congress were controlled by Republicans. According to Google AI “Key Conflict: A major budget impasse between the Republican Congress and President Clinton led to two federal government shutdowns in late 1995 and early 1996.”

Many of the concerns expressed by Chief Thomas are still concerns, and hopefully folks who remember will add how they pereceived these changes, and why they think some of them didn’t work as intended over time.

Sidenote: at this time I was a WO drone as the Research Coordinator for the RPA Program, and I don’t remember the Chief’s talk or being reorganized. Hopefully some other retiree, maybe Michael, who remembers better can give some relevant context. I do remember JWT’s mantra “change or die.”

Jack Ward Thomas
Remarks to WO Employees
January 5 & 9 1995
Restructuring the Washington Office

Thirteen months ago, in my first all-employees meeting with you, I said “change or die” and later presented the corollary ~ “change and live. Today, we meet to begin a process of change that will bring us into the 21st century as the leaders in conservation that we want to be.

We face many challenges. We will overcome those challenges together. They include reduced budgets, Congressional mandates to reduce Washington Office and Regional Office staffing, reorganization of USDA, seemingly ever-increasing skepticism of federal government by the American people, mandated increases in supervisor to employee ratios, orders to disproportionately reduce GS-14 and above positions, and other edicts which seem to occur with ever-greater frequency. Global markets and perspectives which have accelerated the “ripples” of change moving through our country. Adjusting to this instability is complicated by the dramatically shifting paradigms in natural resource management.

It is not just the Forest service going through such changes. The entire government is being dramatically changed altered by several interacting factors. It is appropriate to examine some of the reasons.

The civilian work force is declining dramatically — dropping 272,000 government-wide, the Forest Service share is to go from the present level of 40,612 to to 37,523 FTEs by 1999. This is on top of a decline of some 4,000 since 1992. Reductions are targeted in several categories such as personnel involved in policy making in the WO and administrative and supervisory staff throughout the agency. We are supposed to reduce to 1,003 personnel at grade 14 and above by the end of FY95. The Washington Office share off these reductions is to drop at least 25% from FY92 levels. To make the minimum 25% cut, the FTE count must be not more than 680 by 1999. The current FTE count is 850.

Budgets continue to decline. In facing up to the Nation’s $4 trillion deficit, the Forest Service is helping by spending less. Budgets have been generally “flat• for the past several years. This simply means, when inflation is considered, that the Forest Service budget is and will continue, for the foreseeable future, to decline at a rate of 3-5 percent per year. Congressional committees are considering recissions of over $100 million for the Forest Service for 1995 with similar cuts in the 1996 budget.

Public expectations seem to be changing. Political pundits describe the recent elections as indicative of the people’s desire for a changed approach to federal government. People are described as wanting a smaller, more efficient federal government that is more responsive to their needs. It is difficult to not agree. Such agrees with our basic premises set forth in the Reinvention report.

There have been significant effects of law and legal challenges on the way the Forest service does business. Much has been learned from a series of court cases involving the Endangered Species Act and the National Forest Management Act. Our recent victory in the Ninth Circuit Court on the President’s Forest Plan for the federal forests, in the Pacific Northwest is an indicator of what works and where we can go to have a firm basis for our management. Recent set-backs in the Pacific River cases in eastern Oregon and Washington and the Columbia Basin have brought forth similar lessons.

The national policy to undertake ecosystem management changes the way we do things. Our scientific knowledge and technological strengths now make it possible to assess, monitor, analyze, and manage with an ecosystem view. The Forest Service faces vast changes in our work as priorities and budgets have shifted away from production and targets to land condition and ecosystem management. In the face of these challenges — most far beyond our ability to control — we have the will to change and live!

How will this be done? As a way of gaining insight from the experience of others in government and private industry that have gone through the reinvention experience. I have read a number of books on the subject recently. A list of such books and articles is attached to the handout you have received here today.

The January 1st’s Washington Post “Business” section summed up the basics to be gleaned from these sources nicely. Perhaps you saw Steven Pearlstein’s article, “Two at the Top: ’95’s Odd Couple, A Pruning Primer as Gingrich and Company Prepare to Cut,… “. It had eight messages: “Be Bold, Arbitrary is Okay, Decide Your Direction, Reorganize the Work, Change Personnel Rules, Nurture the Survivors, Outsourcing Works, and Honor the Risk Taker.”

First Message: Be Bold
I have called for each team that has served in the progressive attention Reinvention to “be bold.” I told them not to stop at timid half-measures and to settle for incremental changes. Instead, they were instructed to reach for truly sweeping changes — for such change is essential. Those teams have done that. Together, we will continue on course to the future.

Second Message: Arbitrary is Okay
I have said we will avoid “no-brainers” during reinvention such as across the-board percentage staff or budget reductions. We will not do those things for to continue on such course merely produces debilitation and general mediocrity. We will spend the next 75 days consulting with you to help to, simultaneously, prevent “no-brainers” and how to emphasize areas of our mission that are most critical. This implies doing “less with less” while concentrating our efforts on being the very best at those things we do emphasize.

On the other hand, at some point over the next 75 days the National Leadership Team~ decide the future structure of the WO. Inevitably such decisions will seem arbitrary to some of those who do not like the decisions. But, believe me, by then, you will have been listened to and heard — if you take advantage of the opportunity to participate. The National Leadership Team will reflect on and help address the personal or professional problems that arise from restructuring the WO. But, make no mistake, a change in WO purpose, culture, structure, role, and work is already happening and will continue. The opportunity for participation is open to all of you. The time is now.  In 75 days, the die will be cast.

*

Deep Dive into Forest Service Project Info : Making It Easier to Access and to Post

by

Again, this would be a good project for a group to work on as part of the People’s Database.  For my purposes, recent changes made it more difficult to access information.

This post is a bit of a review of recent changes to how the public can view Forest Service projects. I understand completely that many folks left, and that while perhaps our NGO friends are doing more work, maybe the people keeping up the info to the public are probably overwhelmed. I’d be interested in hearing what this looks like from a District or Forest perspective.  Because from here, it looks like “not posting stuff” just makes more work for the public and FS employees.

Let’s go back to the SOPAs (Schedule of Proposed Action). For those who follow FS projects, the SOPA had all you need to know, plus a link to the project website.

Apparently SOPAs aren’t published anymore. I thought they were kind of handy  See above for an example. Note all the info, purpose, status description, link, location, the expected decision time frame, and whom to contact about the project. They are also sorted by whether they apply nationwide, more than one forest, forest wide and then by District.  There were links to the project site, although they all stopped working at some point. They also had contact names, numbers and emails. I think this was around the time the web system was changed. I wrote the FS web people several times and they didn’t seem to understand what I meant (or didn’t tell me that they were getting rid of SOPAs).

Now, I totally understand that some web or political folks might have looked at the SOPAs and said to themselves..”that seems repetitive.” In fact, NEPA people on the Forest who produce SOPAs and the project website might have found them repetitive. Here’s the current standard website  header.

The Forest Service follows NEPA regulations issued by the U.S. Department of Agriculture. Under this rule, Forest Service officials determine which proposed projects are shared for public input.

The agency no longer issues a schedule of proposed actions (SOPA) report. Below is the current list of proposed projects available for review—your opportunity to learn more, share feedback, and stay engaged in decisions that shape the future of our public lands.

OK, so I go to the projects in development and in progress, thinking those could answer my questions about “are folks scoping nowadays?”. Interesting under the “verbenone” project, it says scoping started in December 2025  but there are no documents.  I suppose you could write in and get the scoping document, or maybe the FS can scope without a document? All very confusing. The Sequoia and Sierra Prescribed Fire EA, which we’ve discussed before, had its objection notice published 5/30/25, but is listed as “under development.” So is “in progress” maybe not the decision is in progress but rather the action? They do have the same contact information for a human being as did the SOPA.

Clicking on the project name takes you to this kind of screen

**********

Which brings me to another long-standing pet peeve, which predates this Admin. It’s about objections.  People on some projects post them, and the review response, with the project documents. There is also a site, which appears to be active, where the objection responses are supposed to be posted (???), but not all are, and I have had to ask Forests for both the objection letters and the objection response.

Even stranger, when I query it from two browsers I seem to get different answers for  the same year.

************

Now I am not a fan of “not scoping” for CEs.  In fact, I think what is in a scoping letter (degree of detail) should be more or less standardized and specific. Based on a random sample of random projects on random forests in random regions, it seems that some folks are still doing scoping and posting the letter, and others not.  Some folks may be doing it but not documenting it.

In fact, if all that information were readily accessible, we could put a set of decision memos from neighboring forests for similar projects and ask AI to compare and contrast and possibly get better products and save time (and do better in court?).

Really, in this day and age, couldn’t folks just upload the docs to some kind of application or program? Then we wouldn’t have to write the forests, who have enough to do, and their public affairs folks, who I’m sure have better things to do. So far they have all been very quick and helpful, but a person has to wonder how many times they are responding to the same questions, which could go into a document, which could be (and used to be) posted…

Again, I think there are two issues 1) FS current interpretation of new NEPA regs means “don’t scope” or “don’t document.”  and 2) Putting what docs you have in a place where the public and other forests can easily find them.

Finally, each forest’s project page I found has this.. to sign up for emails about projects. I had read somewhere that a Forest had stopped sending emails? Maybe we need more info on this.

This seems to me to be fodder for bring a group of FS folks and different kinds of users and figuring out a way of showing info that works best for all of us.

Thinning “Science You Can Use” from the Rocky Mountain Research Station

by

Many thanks to folks in Forest Service Research at the Rocky Mountain Station, who reached out with a few more studies… below are some photo series I lifted from the studies..

Other Stations are invited to submit their relevant thinning literature! In their words,

For Western dry, historically frequent fire forests. From the TAMM Review (second link) “There is overwhelming evidence that reducing tree density and returning low severity fire to dry mixed conifer forests reduces the severity of subsequent wildfires” and from the Alchemy of Addition piece: “It’s important to use both cutting and burning together when possible. The mechanical- and process-based (i.e., prescribed fire) approaches work together to quickly and reliably produce good results for restoration and fire hazard reduction”

What do we know about forest treatments and fire? Photos and long-term studies help us understand

Burning Questions Answered: New review examines 30 years of fuel treatment effects on wildfire severity

The below link is based on work in Montana

The Lubrecht Fire & Fire Surrogate study shows that fuel and restoration treatments in ponderosa pine forests of the Northern Rockies can bolster resilience to multiple
disturbances, while buffering risk of high carbon losses.
● The findings of this study support thinning and prescribed fire to increase ponderosa pine forest resilience to both wildfire and bark beetles for up to 20 years, but efficacy decreases over time and additional fuel treatments are needed to maintain forest resilience.
● However, these treatments can increase the number of nonnative species, which may require additional mitigation measures.
● As the site is re-treated, long-term monitoring is planned to document cumulative effects of multiple treatments to inform future management decisions.

The Alchemy of Addition: Cutting and burning together most effective in reducing fuels and improving forest resilience

 

The North Yuba Landscape Resilience Project EIS- On Big Trees and Diameter Limits

by

Brad Seaberg mentioned the North Yuba Forest Resiliency Project in a comment.  The NEPA is an EIS linked to specific RODs. Shout out to them for their NEPA experimentation (2023 ROD), for their work with partners, and for their rapid reply to my questions. There has been no litigation.

My questions are in bold and District Ranger Tom Parrack’s answers in italics.

Were there any objections to this project?  
There were no formal objections. The North Yuba Forest Partnership was created during planning and was able to address constituent concerns during the initial environmental impact statement.  This developed a tremendous widespread support for the project.
Has implementation started? 
Yes.  Technically, implementation has been ongoing for several years as pre-existing NEPA was incorporated into the overall project and was immediately acted upon.  The first Record of Decision (ROD) was signed in 2022 and the second ROD in 2024.  Most implementation in the ROD 1 project area is just beginning, with projects in ROD 2 currently in layout and nearing implantation.  ROD 3 is being planned for signature in January of 2028.
Is this an example of condition-based NEPA? In other words, were all the units mapped and analyzed prior to the decision?  
Yes. During each Record of Decision, surveys are conducted to ensure that the initial analysis is still accurate and applicable.  The partnership also has an “monitoring team” whose purpose is to review prior decisions, implementation, and effects to help guide future decisions and planning efforts.  As conditions change across the landscape, the planners are able to adapt within the scope of the initial environmental impact statement and determine the best means to reach desired condition

*********************

Here’s some of the rationale for thinning some large trees:

A century of excluding fire’s ecological role in this Landscape has resulted in high stand densities and continuous tree canopy cover in areas that would have not historically supported these densities.
The historic role of fire as a frequent, widely occurring ecological process has been largely absent. The lack of fire, combined with human activities and management, has led to alterations in forest structure and species composition. Tree densities are higher compared to historic conditions and overall tree species composition has shifted to more shade tolerant, less fire-resilient species (Knapp et al. 2013, Safford and Stevens 2017, Stephens et al. 2018).
Generally, the number of large trees (greater than 24 inches dbh) have declined by at least 50% in the Sierra Nevada ecoregion (see Figure 1 from McIntyre et al 2015, see also Dolanc et al 2014, Stephens et al. 2018, Easterday et al. 2018). Broadly, this has led to forest management goals that prioritize retention of large trees, restricting removal of all trees greater than or equal to 30 inches dbh. However, species composition has also shifted toward shade tolerant trees, which in some stands may dominate the growing space. In these types of stands, the targeted removal of some larger shade tolerant trees can provide growing space for the shade intolerant pines, recruiting the large diameter pines of the future. Moreover, trees greater than 30 inches dbh in the dripline of even larger pine trees may pose a fire hazard to the larger trees, and their removal may bolster the potential to maintain the desired larger pines on the landscape. Finally, the ability to create heterogeneous stands with openings is challenging with strict diameter limits. Collectively, this suggests that treatment needs may be more complex than the application of a strict diameter limit allows for yet given the importance of large trees on the landscape, the proposal includes stand-level field verification, documentation and disclosure, and formal public comment opportunity prior to implementing this
plan amendment. Currently, a lack of forest diversity/heterogeneity; limited seral-stage variation; and deficiencies in very large, old trees are compromising California spotted owl habitat resiliency (Forest Service 2019). A summary of references of natural range of variability (NRV) conditions for yellow-pine and mixed-conifer forests across the Sierra Nevada can be found in PSW-GTR-256 (Safford and Stevens 2017, pages 177 to 181; table 11, pages 178 and 179). Promoting development of existing large trees into very large trees and retaining existing very large or old trees aligns with the purpose and need for this proposal.

Below is what I could find in the FEIS about 30-39 inch trees. Note that the purpose and need involved both thinning, and making 1-3 acre openings.

Treatment Units with Removal of Some Shade Tolerant Conifers between 30 and 39.9 inches
My decision includes application of TERR-NORTH YUBA-STD-01 to remove shade-tolerant conifers between 30 and 39.9 inches dbh, consistent with this standard and all other applicable Forest Plan standards and guidelines, including modified SNFPA ROD Standard and Guideline #7, on approximately 408 acres in four units in the Galloway area (Units 141, 142, 150, and 151). Figure 2 displays these treatment units in the Galloway area. Consistent with project-specific forest plan amendment TERR-NORTH YUBA-MA-01 (Final EIS Appendix B), a silviculturist has reviewed field conditions in these four units. Stands within these four units are extremely dense and at risk of imminent tree mortality. Data collected in these stands show basal area averaging 400 square feet per acre with a stand density index (SDI) of 550, which is 120 percent of the maximum SDI for mixed conifer stands.6 (To avoid substantial tree mortality, SDI levels should be below 50 percent of a maximum SDI of 450 for mixed conifer stands in
this Landscape, i.e. SDI of 225 or less.7) These stands have between 36 and 44 trees per acre 30 inches dbh or larger,8 and approximately 57 to 67 percent of the trees between 30 and 39.9 inches are shade tolerant conifers9. Large pines within these stands are either dead or at high risk of loss due to high stand densities and there is the possibility of immediate, short- and long-term mortality of fir. At least half of the largest shade intolerant pines and some Douglas-fir trees have already died in these units. White fir is experiencing disease and density related mortality as well, and will continue to see high mortality rates due to root disease as the other species die out. Extensive tree mortality in these units may result in complete large tree stand loss over time without appropriate treatment, including removal of some shade tolerant conifers between 30 and 39.9 inches dbh. Removing some shade tolerant conifers in this size class is needed to retain and promote the growth of larger shade-intolerant trees by more effectively meeting project objectives for tree species composition and forest stand density. An estimated average of 2 to 8 shade tolerant trees between 30 and 39.9 inches dbh per acre could be removed, leaving an estimated average of 30 to 36 trees per acre greater than 30 inches dbh on site. Shade tolerant trees selected for removal would generally be of low vigor (less than 30 percent crown ratio), and reductions in overstory canopy cover would be limited. Removal of some shade tolerant trees between 30 and 39.9 inches in these stands would effectively reduce stand densities within approximately 55 percent of

5 Prescribed fire is not proposed as a follow up treatment for thinning on any of the 345 acres of hydraulic mine sites in the
Galloway and Rattlesnake Skinner areas.
6 Silviculture/Forest Health Technical Report, pg. 20 and pp. 30 -32
7 Silviculture/Forest Health Technical Report, pg.9
8 Silviculture/Forest Health Technical Report, pg. 28
9 North Yuba Drone Based Stand Mapping (available in the Project Record)
Record of Decision – North Yuba Landscape Resilience Project

maximum SDI, thereby largely mitigating density-related tree mortality, including loss of large pines. In contrast, applying a 30-inch diameter limit in these four units would continue to keep stand density levels in the zone of imminent tree mortality (greater than 70 percent maximum SDI) following thinning.10
Opportunities to create 1- to 3-acre openings to enhance stand structural heterogeneity are extremely limited in these four units due to the high density of trees greater than or equal to 30 inches dbh, TERR- NORTH YUBA-STD-01 could be used to create approximately four to eight 1-acre openings across the four units due to the high densities of trees (30 inches dbh and greater) in these units.

Is that enough explanation? Seemingly the same discussion (if considered sufficient)  could be made (in an appendix to) an EA or a CE.

It’s also of interest that four forests to the north of the Tahoe, with similar PP/true fir combos, the forests are required to follow the E side screens “21 inch rule.”

Is that because the Forests (and scientist amicus-filers) didn’t adequately argue their case? The absence of a relevant GTR?

Or is it simply an artifact of  vegetation management by courts?

To Thin, or Not to Thin? When, Where and Why? Those Are the Questions

by

Let’s look some more at thinning.

First, I’ll say that I don’t know about wet areas.  I remember a class at an Area 4 Silviculture Workshop in the 80’s, taught by Chad Oliver and Bruce Larsen (then of U of Washington). All the models were based on competition for light. I asked “but what if the trees are competing for water?”.  That wasn’t part of modeling at the time.  So much of forest ideas and models were generated from wet forests and don’t apply to dry forests.  The point being that any discussion of thinning needs to be grounded in specifics of when, where and why.

At one end we have “no thinning is ever ecologically necessary.”  Well, that’s a high bar, and not one that’s in law anywhere as I know for activities on National Forests.  I don’t know that campgrounds or ski areas are ecologically necessary either. So the term “ecologically necessary” has to carry quite a bit of weight, especially if different fuels-related assumptions are involved. Are fuels prescriptions ecological? What if the fuels practitioner is trained as a fire ecologist? What do we mean by the term “ecological” in that sense?

Anyway, I’ll make a series of claims that we can discuss.

1. Thinning in forests is very common, at least here in Colorado, outside of a wood products context – purely for fuel treatment or wildfire mitigation. Then there are the folks in Arizona and the Lake Tahoe area, trying to find and encourage wood products companies to take their thinned material.

2. Some people thin in dry areas to reduce density of trees, because more trees can get started than the site can ultimately support.  Thinning gives the remaining trees a better chance to get enough water to grow.

3. Some people thin (at least in California) to return to HRV (with the side benefits of fewer stems on health and resilience as above.)

4. Healthier trees (with stem reduction) are often, but not always, more resistant to bark beetles.

5. Removing biomass (cutting trees and removing them from the site by burning or other removal) reduces fuels.

6. Thinning can be done to help trees grow larger faster, as with west side plantations trying to get bigger trees for habitat, or in many places for wood products.

7. Some species, in some situations, have a tendency to stagnate rather than develop into stands such that without thinning trees don’t become large (“doghair”)..

To engage with previous comments:

Jon said:

It looks like this was looking at basal area rather than the size of trees removed, so I don’t think it proves the point that removing large trees is necessary to protect large trees from drought (or fires?) – unless large trees are all that were growing here.

Yes, I would say if all trees are large in a stand are large, and you want to thin, you would need to remove some large trees.

Jon also said in an earlier comment:

we should minimize it and be choosy about where that is done. Not to mention clearly explaining all this in the rationale for a project. This is what I’m not seeing discussed.

As we shall see in the next post, at least some environmental documents do have rationales and different ways of monitoring “choosiness” have been proposed.

Jake had some interesting comments:

While mortality from MPB was significantly less in the thinned areas (3% vs 13%), when the trees killed by the thinning (which also removed infested living trees) were included in mortality, total mortality is much greater in the thinned areas.

Let’s think about this some more.. (I didn’t go back and look at the study).  When the thinning occurred, they removed more trees than might have been killed by beetles. But the way the stand develops, with more standing and falling dead trees (with MPB death) would be different, and more fuel would be in the stand. I’m not sure that those prescriptions were intended to reduce fuel loadings at the time, but I think it would be hard to argue that such a prescription would not reduce fuel loads.

Is that really “shady accounting” as Jake states?  If the goal is to reduce MPB kill, then thinning would generally be successful.  That would be in the framing of the study itself (reduce MPB mortality) rather than (how to maximize living trees on a site).

Also, the Negron et al (2017) study reported that 4 of their 21 thinned stands had much greater MPB mortality than the paired unthinned stands

That’s the “it doesn’t always work” argument.  We’ve discussed that before with regards to fuel treatments in general.

Another of Jake’s comments:

Thinning, of course, had the benefit of providing saw logs to the mill, but it also probably came with significant costs to the ecosystem.

“Costs to the ecosystem” “ecologically necessary”.   I thought the “ecological integrity” part of the 2012 Planning Rule suggested managing for NRV- related to HRV. But not if HRV is too open or requires thinning. It’s all very confusing.

Instead of “ecological integrity” perhaps the FS should have targeted “forest resilience” which would definitely have a fuels (both for the trees on-site and to support suppression via PODs and other fuelbreaks.

But what “costs to the ecosystem” come from thinning specifically? Wouldn’t it depend on when, where and why?

*************************

 

Of Tortoises, OHVs in the Mojave and Imputing BRC’s Intentions

by
Vehicles driving on- and off-road on Feb. 2 on Bureau of Land Management land in Johnson Valley, Calif. (Ethan Swope / For The Times)

The LA Times had a comprehensive story on OHVs on BLM in Southern Cal.

Here’s the summary:

  • A federal judge ordered the Bureau of Land Management to close off-road vehicle trails that cut through tortoise habitat in the western Mojave Desert.
  • The ruling follows years of legal battles between environmental groups and the BLM.
  • Resistance to the decision remains fierce both among Californians that recreate in the area, and the small businesses they support.

It is interesting to note the color in the beginning of the article..

Biologist Ed LaRue, who has taken up the cause of the animals, watched the other day as a lifted pickup truck with a large American flag and a utility task vehicle raced down a trail in the Mojave, sending up plumes of dust. The two vehicles barreled over a road and careened into the Ord Rodman Area, which the federal government has deemed critical to the desert tortoise’s survival. One appeared to then drive off the designated route.

Why use “drove” when you could use “raced” “barreled” and “careened”? Oh, well.

“These public lands are our shared heritage. They provide important habitats for these species and they’re important for many people who love to recreate,” said Lisa Belenky, attorney for the Center for Biological Diversity. “But right now, one form of recreation, motorized recreation, is dominating these lands and literally ruining them.”

So there are ORVs with trails going off-trail (bad)  but it kind of sounds like a slippery slope about vehicles (OHVs and cars) and roads.

LaRue used to work for the BLM as one of two biologists who helped create the West Mojave Plan, which crafted a strategy to conserve more than 100 native plants and animals, a plan that included a survey of the threats affecting local tortoises. The list included upper respiratory tract disease — which scientists attribute to people releasing infected tortoises kept as pets — as well as habitat loss and degradation from a variety of sources, including development, military maneuvers, livestock grazing and offroading.

Vehicle access is linked to more vegetation destruction and soil disturbances, according to the report. That in turn leads to the spread of invasive weeds, which can crowd out the plants tortoises eat and fuel wildfires.

People are also more likely to dump garbage alongside established roads, which can then attract ravens that feed on baby tortoises.

Here’s my favorite part..

Climate change-supercharged droughts, and large-scale solar development across the Mojave have also emerged as growing threats, LaRue said, standing atop the tawny Cinnamon Hills in the Ord Rodman Area. But OHV use is different, he said, because it’s “one of the threats that we could ostensibly control.

So “we” can’t control development, military maneuvers, livestock grazing or large-scale solar development.  That seems problematic. Also problematic is enforcing the route closures. So can “we” really “control” them?

It’s unclear how the agency plans to enforce the route closures across such a massive and remote area. The Barstow and Ridgecrest field offices have 15 law enforcement rangers tasked with overseeing about 5 million acres of land, which includes most of the critical tortoise habitat in the western Mojave.

“I fear that recent staffing cuts and budget reductions are going to make this a difficult challenge for the BLM,” said Randy Banis, president of Friends of Jawbone, a nonprofit that promotes off-roading in Kern County’s Jawbone Canyon.

****

The story does talk about the loss to individuals and businesses in the area.

Most painful is the prospect of losing access to cherished places, Travis said. He and his wife may no longer be able to take visitors to Cuddeback Dry Lake Bed, a massive playa they describe as magical, or to some of the nearby hiking trails they’ve grown to love.

“The vastness and the quiet and the peace you get here is unlike anywhere else you can find in California,” Lorene said. “It is devastating to realize a massive amount of land will be completely inaccessible.”

Many off-roaders are good stewards of the environment and shouldn’t be blamed for the continuing decline of the tortoise, the Frankels said, pointing to the ravens as the real issue. The intelligent corvids were once hard to find in the desert but their numbers have exploded due to increases in food, water and perching opportunities that came alongside human development.

I’d be interested in what kind of “human development” occurs on or near BLM land.  Is it just campers that lead to corvids, or towns or ???

************************

So, just another controversy over uses and impacts.

Except Center for Western Priorities in their newsletter this AM, quotes Jonathon Klein as saying that the BlueRibbon Coalition is a “disinformation group” (I guess that’s code for “someone we disagree with”) and that BRC is only complaining about the closure to  fuel the agenda to sell off public lands.

He notes that BlueRibbon Coalition is led by Ben Burr, a former staffer and relative of Senator Mike Lee, who has a long history of attempting to dismantle public land protections. “They are stooges to these public lands sell-off ghouls and haven’t spoken out about anything but these distractions since the Trump administration’s war against public lands has begun in earnest,” writes Klein.

The article warns that the real threat to Americans’ access to outdoor recreation isn’t the temporary closure to protect wildlife, but the broader movement to dispose of public lands. Klein urges riders not to support groups like Blue Ribbon Coalition, which he says “are fighting against your interests, plain and simple.”

I don’t think that was the CWP’s intent, but the article makes me want to send bucks to BRC.  And I have never ridden an OHV. , Waving the “Mike Lee selling off public lands” fearmongering banner is getting increasingly tiring.  I suppose I should be glad they didn’t bring up the Bundys- this time.

Another Predictable Colorado College Poll Touted in Predictable Media Outlets

by

Colorado College has come up with its usual poll results, touted in the usual outlets.  From Center for Western Priorities:

Bipartisan majorities in Western states oppose Trump’s rollback of public lands protections

Missoula Current | Axios Denver | Axios Phoenix | News from the States | Aspen Public Radio | Wyoming Public Media | Grand Junction Daily Sentinel [editorial]

Here’s what Steve Wilent posted about it in 2018 and my comments.

Below  are the funding sources for the effort. I’m ambivalent about bringing up funding sources, but Dee in response to the Breakthrough’s piece commented that Breakthrough was funded by East Coast billionaires. At the time I thought, so what? Isn’t everything funded by East or West Coast billionaires? It’s unlikely that large organizations can be run on the bank accounts of FS retirees, for example.

The State of the Rockies Project at Colorado College is primarily funded by the William and Flora Hewlett Foundation, which recently renewed its support with an $800,000 grant in 2024. Other key supporters include the David and Lucile Packard Foundation, Western Conservation Foundation, and Trinchera & Tercio Foundation, along with private donors and alumni.

If you’re interested in following funding, it’s easier nowadays I think via AI on google searches. Interesting that the Western Conservation Foundation is funded by a DAF (so we don’t know the funders) and by RF Catalytic Capital which is in turn funded by the Rockefeller Foundation.
Here’s a link to Hewlitt’s current plan.. I thought this was interesting..

To date, we are approximately 65% of the way toward the foundation’s long-term goal of protecting half of the North American West. In the past five years, our grantees achieved new protections on approximately 10 million acres, which was our goal. The strategy’s goal in this respect was intentionally modest, as we focused more on the new work of building inclusive coalitions, which is slower to show progress but will, we believe, produce greater and more durable gains over time.

You can also check out what they are granting and to whom for how much. I wonder whether they might support some aspects of federal lands recreation programs if they could be argued to fit with their conservation or communication goals. Example page:

That was a bit of a rabbit trail, but I have recreation funding on the brain. They could probably fund a volunteer coordinator on each NF and BLM unit, training and equipment without batting an eyelash. Which would have direct real-world positive impacts on the environment. I would guess more so than strategizing or coalitioning or communicating to reduce carbon emissions by 2050.

Engaging With Denise’s Claims About Wildfire, Beetles, Thinning, and the Forest Service

by
Fuel mitigation work, including thinning, is frequent in Colorado’s Front Range county open spaces. In answer to Denise’s comment “the only reason to cut trees is for lumber.” https://www.douglas.co.us/dawson-butte-open-space-closed-weekdays-for-fire-mitigation-work/

Apologies for the previous post that might have shown up in your inboxes.. I pressed the wrong button before I was done. This post is to engage with some of Denise’s comments.

Removing trees because of beetle kill also removes the trees that are the most resistant and therefore should not be removed. There is also evidence that logging has actually spread beetles from one area to another. Regardless, beetles are nature’s way of natural thinning of the forest. It’s a natural process. Thinning dries out the forest and does not help with drought. Lush forests retain water. Nothing will stop a wildfire under the right climate conditions and we are in the midst of a warming climate. Forests survived for millinea without “management” and looked a lot better than they do today.

The Black Hills was actually fairly successful at thinning and reducing beetle kill, and this paper suggests that it was successful in mitigating tree mortality due to MPB.

Many of us remember these kinds of conditions and photos from the early teens:

Dave Mertz can tell us whether these results held up over time.

But thinning doesn’t work for all tree/beetle combos and under all conditions. For example, back in the 80’s we thinned around our selected (for cones) trees in a massive MPB outbreak thinking that the vigor would protect them (they could pitch out the bugs). As it turned out, though, at that point in the outbreak the beetles were not to be fazed. That’s why I am hesitant to generalize about bark beetle management. On the other hand, if we remove the Timber Wars context (say for Colorado private landowners, who have a timber industry deficit) we can see on the Colorado State Forest Service website:

Large outbreaks of mountain pine beetles are difficult to control. One of the best ways to mitigate the effects of beetle outbreaks is to manage for overall forest health and resiliency. Thinning overly dense stands of trees to reduce competition and promote tree age and species diversity is the most successful forest management strategy to increase tree vigor.

Maybe there’s a difference between “thinning” and “logging”? It seems to me more likely that a FS timber contract would include provisions about timing to not move bugs around, rather than Amber the Homeowner who is taking it to the county slash pile. Maybe those terms (thinning vs. logging) are not all that helpful and we could talk about “thinning and burning piles” “thinning and chipping onsite” “thinning and transport to different places, including sawmills?” Then there’s the scientific consensus in the 10 Common Questions paper we’ve discussed partially here at TSW and is summarized in this fact sheet by Pritchard. I’m always up for discussing these, and I think the FS does fairly well in responding to these kinds of statements in their “response to comments” section of CE, EA and EIS documentation.

When I worked in R-2, we’d sometimes get appeals where the appellants hadn’t changed the project name since the last one. I’m thinking that AI might be very helpful in developing generic responses to generic literature cites. It could rummage through existing project docs and do quite well (and of course be edited by FS folks).

“Thinning dries out a forest and does not help with drought”. Studies and real-world experience show otherwise. Again, it’s all about the site, the species and the conditions. I don’t really see the need to generalize to the globe (???), as these 2025 authors did- since local silviculturists know the specifics. Like what species on what soil types are likely to blow over post-thinning.

Generating broad-scale conclusions to inform forest management decisions in the face of global change is highly challenging. Although our analyses showed that negative responses may occur, in general, thinning can be expected to increase the resilience and resistance of forests to multiple stressors across North America and Europe.

And others (OK a science writer at CU Boulder) says that current MPB levels are a symptom of climate change

As the climate continues to warm, these sorts of ecological issues are going to happen more often. So we need to make sure that instead of only treating the symptoms of climate change, we are reducing the amount of carbon that is going into the atmosphere.

So according to some, beetle outbreaks have ceased to be “natural”. It seems to me people should pick a lane, natural or not? Of course, we’ve done many unnatural things like logged for railroads, the mining industry, and when trees grow back from that, suppressed fires so trees get old and maybe overstocked based on soil and climate conditions. Wouldn’t it be hard to tease apart the “natural” from the “unnatural”?

Denise also said:

Nothing will stop a wildfire under the right climate conditions

I’d say that perhaps “weather” conditions is more accurate. Like high winds. In my part of the country we get frequent wind-driven wildfires in the winter, and the strategy is rapid initial attack. So, yes, most of the time fire suppression works, and developing PODs and fuelbreaks can help with fire suppression in addition to reducing fuels in other areas and helping trees be more resilient.

The FS has butchered our National Forests and you don’t have to be any kind of natural resource expert to see it.

Last fall, my family and I visited California on a road trip. I lived there in the 80’s and worked for the Eldorado. What I noticed (coming west on US50 was major removal of trees due to… wildfire. Then drove up to the coast via 299 again massive wildfire area. Then to the redwoods, which I had forgotten (from my forestry education at Cal) are fire-adapted.

Save the Redwoods League views wildfire as a top priority in our larger effort to protect and restore California’s redwood forests. We’re moving quickly to ensure that the properties we manage are prepared for a future with more extreme wildfire, and we’re encouraging state and federal land managers to ramp up efforts to make their coast redwood and giant sequoia landscapes more fire resilient

Up through Grants Pass, to Shasta and then to Lassen and to Reno, more landscapes (not devastated but definitely de-treed) by wildfire. So no, the FS has not “butchered” the NFs. Maybe climate change causes “more extreme” fires and fuel loadings and dead trees have nothing to do with it.

It seems to me that most of us agree on what makes forests resilient. Most of us agree on the need to protect communities, because fires running even through hardened and evacuated communities is not good. Not to speak of the fact that evacuation is difficult and stressful. Some of us would like more timber or other industry using our thinned material. For example, Douglas County just opened a county-operated biochar facility.

Or the new Tahoe Forest Products sawmill in Carson City:

Reducing the risk of wildfire devastation in the Sierra Nevada is a daunting and multi-faceted task. Much of the effort is focused on reducing fuel load in the forest so that fires that do flare up don’t turn into catastrophes like the Caldor Fire of 2021.

One sticking point in this effort for the Tahoe region has been the lack of a nearby sawmill. The further away a sawmill is from the logs, the more expensive they are to transport, which can make necessary tree thinning operations prohibitively expensive.

If most of us agree on the need for fuel treatments or some kind of management for wildfire and/or climate resilience, with zones of agreement and forest collaboratives, perhaps in places like the Sierra Nevada or Colorado the Timber Wars can be declared over. And as Jack Ward Thomas said in 2001:

One of my favorite JWT observations came in 2001, five years after he’d left his Forest Service post. He was urging conservation peace and progress after environmental groups had turned the tide on overcutting on the national forests.

“Fierce in battle, many of the eco-warriors have been unable to come to grips with the consequences of victory and are now reduced to wandering about the old battlefields ‘bayoneting the wounded.’ Their counterparts from the resource extraction community, likewise, cannot come to terms with defeat and hold ‘ghost dances’ to bring back the good old days when they were the undisputed Kings of the West.”

Chief Schultz on Strengthening Recreation Services For the Season Ahead and Hiring Seasonals

by
Photo of Chief Schultz visiting with folks on the Shasta-T, pulled from ST Facebook page.

I have seen job advertisements on X for Forest Service temporary positions (and earlier wildfire seasonals). Apparently the FS plans to hire 2000 nationwide.

From the Chief’s Desk:

*********************

As we look ahead to the upcoming summer recreation season, I want to share an important update about our workforce and the support you can expect.

Today, we announced plans to hire up to 2,000 seasonal workers nationwide. This is a big step forward for our agency and the communities we serve. Last summer, many of you took on extra work without the usual seasonal help. We saw your long hours, creative solutions, and the way you supported each other and the public. Your dedication truly made a difference, and we are proud of how you showed up for your communities.

Because of the progress we made this past year toward fiscal solvency, we’re now able to hire our seasonal workforce in a more stable and sustainable way. These positions will help support active management work and keep our campgrounds, trails, and recreation sites open, safe, and welcoming—work that directly supports our mission and the gateway communities that rely on the world-class recreation our forests provide.

We have also taken steps to speed up our hiring process so seasonal employees can start earlier and provide support when it’s needed most. This year, we are focusing our recruitment within the communities we serve. Local residents bring invaluable knowledge, pride and a strong connection to the places we care for. We are excited to offer more opportunities for people who want to work close to home.

These recreation positions are in addition to ongoing seasonal fire hiring. Together, they represent a meaningful investment in our workforce and in the visitor experience.

If you know someone who wants to join us this summer—whether to start a career in natural resources, get hands‑on experience or spend a season working outdoors—please encourage them to apply. All applicants must apply through USAJOBS.gov. You can find more details about seasonal jobs and upcoming local recruitment on our website.

Thank you again for everything you do. This hiring effort is about supporting you, strengthening our recreation services and trail system, and ensuring we’re ready to welcome millions of visitors to their national forests and grasslands this summer.

**************

It does make sense to me to focus on local recruiting.. conceivably, people already have some kind of housing so that reduces stress on the employee. There is also the chance to build relationships within the community, possibly increasing trust.

The strangest year for temporary hiring I remember was during the Obama Admin, when our Civil Rights staff and a DRF had to review and approve every temporary hire in the Region. As I recall, no one was very happy about that.

Then there was last year, when “no temps” was a way to help with the $750 or $500 mill deficit. And speeding up (and maybe reducing wrinkles) in the hiring process should be helpful.