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

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

I) BACKGROUND

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

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

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

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

II) Law et. al. CAVEATS ignored by OW

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

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

III) Atkins’ CRITIQUE

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

Quotes from Atkins Critique:

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

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

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

You say “logging,” we say “thinning,” “mechanical treatment” or “stand improvement”

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And Trump says “tree clear.”  This article got my attention for a number of reasons.  It’s a follow-up to the story about the Trump tweet regarding forest fires.  It is another case of “upping the cut” under the Trump administration (doubling in this case on the Los Padres).  And it looks like the Forest is trying to disguise what it is actually doing with this project.  And using a questionable categorical exclusion to boot.

Critics contend the proposed logging in the Los Padres is a signal that the balance of power in national forests is shifting under the Trump administration. Such projects could open the door to commercial logging in other public forests currently managed as watersheds rather than timberlands, such as the Angeles, San Bernardino and Cleveland national forests.

Agriculture Secretary Sonny Perdue raised annual timber production targets for the Los Padres National Forest from 200,000 cubic feet of wood in 2017 to 400,000 cubic feet this year.

“We are witnessing a historical change unfolding in the national forests in our own backyard,” said Richard Halsey, founder of the nonprofit Chaparral Institute in Escondido, Calif. “Timber was never part of the equation, until now.”

Here’s the way the article introduced the project:

The federal government is moving to allow commercial logging of healthy green pine trees for the first time in decades in the Los Padres National Forest north of Los Angeles, a tactic the U.S. Forest Services says will reduce fire risk.

The scoping letter described the project as a “shaded fuelbreak.”

Treatments would include a combination of mechanical thinning, mastication of brush/smaller trees, and hand treatments such as hand thinning, brush cutting, pruning and piling of material.

That sounds fairly benign, but the proposed action sheds a little more light on it:

Mixed conifer and pinyon juniper stands would be thinned to a range of 40 to 60 square feet basal area per acre…  Trees would be removed throughout all diameter classes and would include the removal of commercial trees. Residual trees would be selected for vigor; however, larger Jeffrey pine would be retained per Forest Plan direction unless they pose a hazard or are infected with dwarf mistletoe. All black oak would be left unless they pose a hazard.

But the scoping letter states an intent to use this categorical exclusion:

(6) Timber stand and/or wildlife habitat improvement activities that do not include the use of herbicides or do not require more than 1 mile of low standard road construction. Examples include, but are not limited to:

(i) Girdling trees to create snags;

(ii) Thinning or brush control to improve growth or to reduce fire hazard including the opening of an existing road to a dense timber stand;

(iii) Prescribed burning to control understory hardwoods in stands of southern pine; and

(iv) Prescribed burning to reduce natural fuel build-up and improve plant vigor.

And then there’s this:

Ashley McConnell, a spokeswoman for the U.S. Fish and Wildlife Service, said her agency plans to work with the Forest Service to help protect active California condor nest sites or roosting areas. Logging, she said, could “benefit California condor habitat because the larger and older trees where condors typically roost are preserved.”

That’s what “thinning” means, right?

So has it been so long since the Los Padres has had a timber sale that they don’t know what to call it?  Or is this an attempt at sneaking by the NEPA requirements that go along with it?  Maybe you can technically call it “thinning” if you leave any residual trees, but that is clearly not what this CE was intended to cover.  There is another CE for hazardous fuel reduction, but it’s limited to 1000 acres of “mechanical treatments.”  And another for “harvest of live trees” (limited to 70 acres).  Is this the kind of misleading corner cutting the Forest Service is going to go back to when it is under pressure to “get the cut out?”

Some August FS court cases

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The Forest Service recently won two lawsuits involving timber projects in Montana.

  • In Native Ecosystem Council v. Marten, the district court upheld the Telegraph Vegetation Project on the Helena Lewis and Clark National Forest.
  • In Native Ecosystem Council v. Erickson, it upheld the Smith Shields Forest Health Project on the Custer Gallatin National Forest.  One of the issues involved an amendment to the forest plan that modified standards applicable to elk habitat and old growth. In both cases, the court found that Forest was not arbitrary in concluding that the effects of the amendments were not significant and did not require an EIS.

In Sierra Club v. USFS, the 4th Circuit Court of Appeals ruled against the Jefferson National Forest for improperly amending its forest plan to create an exception to forest plan standards to allow the construction of the Mountain Valley Pipeline.  This was the first direct judicial test of the 2012 Planning Rule, but it was actually a test of a 2016 amendment to the Planning Rule that governs the application of the 2012 Rule to forest plan amendments.

That addition to the Planning Rule said:  Forest Service “shall . . . [d]etermine which specific substantive requirement(s) within §§ 219.8 through 219.11 are directly related to the plan direction being added, modified, or removed by the amendment,” and then “apply such requirement(s) within the scope and scale of the amendment,” and an agency’s “determination must be based on the purpose for the amendment and the effects (beneficial or adverse) of the amendment,” 36 C.F.R. § 219.13(b)(5).  The Preamble to the 2016 changes said, “When a specific substantive requirement is associated with either the purpose for the amendment or the effects (beneficial or adverse) of the amendment, the responsible official must apply that requirement to the amendment.”

The Forest Service said that because the pipeline project would mitigate effects on soil and riparian resources they would not be “substantial,” and therefore the Forest did not apply the requirements of the 2012 Planning Rule related to soil and water resources, including “the ecological integrity of riparian areas” (36 C.F.R. § 219.8(a)(3)(i)).  The court held that, “the clear purpose of the amendment is to lessen requirements protecting soil and riparian resources, so the amendment was directly related to these requirements, and the Forest must apply the applicable Planning Rule requirements. It also held that the Forest had not adequately analyzed the effects of the pipeline on soil and riparian areas. The court remanded the amendment to the Forest “for proper application of the Planning Rule soil and riparian requirements to the Forest Plan amendment.”

Wildfire: Politics Lag Behind Science

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Article from Oregon Public Broadcasting: “When It Comes To Wildfire, Politics Lag Behind Science.”

The public doesn’t want smoke, period, and is leery of fire in the woods.

“Political barriers might explain why some forest restoration projects complete the thinning but not the burning part of the plan. “

Note the “About This Story” section at the bottom of the page.

Why Does This Story Matter?

Politicians have the power to influence how the West manages wildfire by directing tax dollars toward suppression and forest restoration. This story focuses on where politicians stand relative to the science that says forest managers should be letting more wildfires burn and using more prescribed fire to reduce the likelihood of catastrophic wildfires in the future.

The Dilemma of Simplification: Bears Ears and CNN

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A long time ago, in the context of Colorado Roadless, I raised the question of whether some natural resource/public lands issues are simply too complex for the news media to tell the story. When that happens (“it’s too complex”), it seems like the natural reaction is to find a simpler story.. usually good guy vs. bad guys. If we believe these stories, though, and trust “the media”, we naturally end up thinking that there are a lot of “bad” people out there, (including people in the industries that keep our buildings heated and cooled, and provide the electrons that power the internet) and get more worried/despairing/angry about the state of the world today.

Kevin Franck sent this by Jim Stiles in the Canyon Country Zephyr.

More than three years have passed since the idea of a “Bears Ears National Monument” was first introduced to the general public. One of the most far-reaching and expensive coast-to-coast marketing campaigns ever promoted by the powerful outdoor industry and their allies in the mainstream environmental community clearly contributed to the decision by President Obama to create the monument in the last days of his administration. Obama’s interior secretary, Sally Jewell, had previously served as CEO of REI, Inc, one of the largest outdoor retailers in the world.

(Jewell’s predecessor, Ken Salazar, promised Utahns in 2011 that monument designation was not being considered by the Obama administration.)

Those two forces came together to sell an agenda to the American Public and the mainstream media, from the national level to the local, often became a willing mouthpiece for that agenda. It became an un-debated, unchallenged “fact” that only monument status could save the area from rampant and imminent destruction from the energy industry and archaeological looters.

I don’t claim to be knowledgeable on many issues, and I try to limit my participation to stories that I know enough to comment on. But I have lived in southeast Utah for more than 40 years, I have been intimately connected to the vast wild country in San Juan County and to the two buttes known as “the Bears Ears” for even longer. I was once a strong proponent of the environmental lobby in Utah and many years ago even served on the board of directors of the Southern Utah Wilderness Alliance. But in the past 20 years, environmentalists have forged alliances with the outdoor industry and turned a blind eye to the impacts their partnerships were creating.

In 2018, misinformation about southeast Utah, the monument and the people has been a particular source of frustration. In an effort to set the record straight, this publication has written and posted more than 50,000 words on the subject of Bears Ears National Monument. It’s been a Quixotic effort— not once has a major media source been able to contradict a single word, but the truth is, they won’t even try.

I think the whole piece is worth reading because it shows how difficult it would be (even in an 8 minute video segment) to even describe some of the complexity of the issue. I also wonder whether the same people who think it’s a bad idea for a former uranium/coal/oil and gas lobbyist to head the EPA, think that it was fine for a CEO of a regulated industry (recreation) to serve at the helm of Interior.

Alaska, USFS begin work on Alaska Roadless Rule

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NEWS RELEASE

For Immediate Release
Contact: (202) 205-1005
Twitter: @forestservice

 

 

 State of Alaska, USDA Forest Service begin official work on Alaska Roadless Rule

JUNEAU, ALASKA, August 2 – The State of Alaska and the USDA Forest Service signed a memorandum of understanding this week to develop an Alaska state-specific roadless rule.

An Alaska state-specific roadless rule will determine which currently designated roadless areas would require a different management designation to further Alaska’s economic development or other needs, while still conserving roadless areas for generations to come.

The state-specific rule will amend the 2001 Roadless Rule, which prohibits road construction, road reconstruction, and timber harvesting on certain National Forest System lands across the country. Currently, in Alaska, 67 percent of National Forest System lands are inventoried roadless areas. An additional 26 percent are designated Wilderness, where road construction is also prohibited.

In establishing this new rule, the USDA Forest Service is responding to Alaska’s petition for a full exemption from the 2001 Roadless Rule. The petition was accepted by Secretary of Agriculture Sonny Perdue in April 2018, with the decision to pursue a state-specific roadless rule. National Forest System lands in Alaska that are designated Wilderness would be unaffected by this rulemaking.

“We will continue to work with the people of Alaska, the state government, industry, tribes and Alaska native corporations to maintain the health and vibrancy of our National Forests,” said Secretary Perdue. “The national forests in Alaska should be working forests for all industries.”

The Forest Service and state will work closely together, as the Forest Service did with Colorado and Idaho to develop their state-specific roadless rules.  An important part of this process will be working with stakeholders from across the region to inform development of this state-specific rule.

“The State of Alaska is ready to begin this work. I am confident that state and federal officials will be responsive to input from local residents every step of the way and that together we will account for the diverse needs of people who live, work, and recreate in the forest,” Governor Bill Walker said of the project.

Secretary Perdue aims to sign a final Alaska Roadless Rule within the next 18 months. The preparation process will involve National Environmental Policy Act environmental review and disclosures, gathering public feedback, conducting public outreach, and consultation with Alaskan Tribes and Native Corporations.

A notice of intent to prepare an EIS for the rulemaking is scheduled to be published in the Federal Register later this summer.

For more information please contact Dru Fenster, Alaska Region Media Coordinator at 907-209-2094.

 

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“Fire-prone area of Kalmiopsis ablaze again”

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From the Eugene Register-Guard: “Fire-prone area of Kalmiopsis ablaze again.”

“They are using some of the old lines from the Chetco as well as the Biscuit fire,” said Katy O’Hara, public information officer for the Klondike and Natchez fires.

The Klondike fire is burning within the boundaries of the 500,000-acre 2002 Biscuit Fire and on the edge of the Chetco Bar Fire, a 192,000-acre conflagration that rocked the region last year. The area was also the site of the 150,000-acre Silver Fire in 1987, which like the others was ignited by lightning.

In the years since the Biscuit Fire, light vegetation that is extremely flammable has sprouted, providing abundant fuel for the Klondike, which doubled in size last week.

Rim Fire Recovery Retrospective

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This article, “5 years after massive fire near Yosemite, forest restoration may be in peril,” quotes Chad Hansen; John Buckley, executive director of the nonprofit Central Sierra Nevada Environmental Resource Center; some USFS staffers; and Malcomb North, a scientist at the Forest Service’s Pacific Southwest Research Station. I wish the article had included more info from North on the science!

“Its centerpiece is a federally funded community and watershed resilience program touted as a model for helping small town economies and wildlife habitats bounce back after wildfires throughout the western United States.

“But now, five years after the fire, there is growing concern that the grand partnership is crumbling due to delays, frustration and a tug-of-war between preservationists and logging advocates backed by the Trump administration.”