Months Late Park Service Releases Report on Climate Change

I posted a note on claims of possible censorship earlier, along with a very long time lag in waiting for the report to be released. Now we wait to see if anyone sees anything amiss. And we, at least I, wonder whether the earlier outcry had any impact on the final product that appears to be unsanitized. Here is a snip from The Hill, 5/21/2018:

The National Park Service (NPS) released a major report on rising sea levels after the Trump administration was accused of censoring it.

The Center for Investigative Reporting’s Reveal reported last month that administration officials removed mentions of human-caused climate change in the report, reflecting President Trump’s and Interior Secretary Ryan Zinke’s skepticism that manmade greenhouse gases are the main cause of climate change.

But the report released late Friday puts the blame for sea-level rise squarely in human hands.

“Human activities continue to release carbon dioxide (CO2) into the atmosphere, causing the Earth’s atmosphere to warm,” the report says.

“Further warming of the atmosphere will cause sea levels to continue to rise, which will affect how we protect and manage our national parks.”

NPS spokesman Jeremy Barnum said the report went through the usual editing process, and the agency is confident in its scientific accuracy.

PEER: Tongass “Good Neighbor” agreement goes bad, Alexander Archipelago logging did no restoration and the timber was exported to Asia

Those pesky nosy bodies at Public Employees for Environmental Responsibility (PEER) are at it again. Below is there latest press release. – mk

Washington, DC — A state-federal timber partnership in Alaska’s Tongass National Forest went badly off-course, doing environmental damage in what was supposed to be a restoration project, according to a complaint filed today by Public Employees for Environmental Responsibility (PEER). Rather than improve forest health, the group charges that the sale damaged it.

In 2014, Congress enacted “Good Neighbor” authority for timber agreements between federal and state governments to enable cooperative forest restoration projects on federal lands when similar restoration projects take place on adjacent state lands. The political sales pitch for the suggestively titled Good Neighbor program characterized it as a proverbial “win-win” in that public forestlands receive needed restoration work while local mill economies benefit at the same time.

Employees complained to PEER that the Good Neighbor timber sale conducted on Kosciusko Island in the Alexander Archipelago of southeastern Alaska did not follow the blueprint. Contrary to how the program was supposed to work, in this case –

• There is no restoration of any kind planned on either federal or state lands;

• The U.S. Forest Service contract did not provide for any reforestation, even of parcels that were clearcut; and

• Few jobs materialized at local lumber mills and processing plants because all the timber was exported to East Asia.

To add insult to injury, by law, a portion of the income generated by the Good Neighbor sale must return to the U.S. Forest Service, but in this case, the State of Alaska is apparently set to pocket the income generated by this conventional timber sale masquerading as a restoration project.

“In this timber sale, Good Neighbor authority became a license to loot,” stated PEER Staff Counsel Adam Carlesco, arguing that under the guise of restoration, damaging clear-cutting occurred. “Both the U.S. Forest Service and the Alaska Department of Natural Resources acted more like co-conspirators than collaborators for improving forest health.”

PEER is asking the U.S. Department of Agriculture Office of Inspector General to audit not only this sale but also all the other Good Neighbor agreements. The PEER complaint also asks the IG to review a pattern of timber sale maladministration by the Forest Service.

“This is one of the first Good Neighbor timber sales and we are concerned that unless these problems are cured, as the twig is bent so grows the tree,” added Carlesco. “This Good Neighbor exercise made the case for high fences rather than more cooperation.”

###

Read the PEER complaint

See continuing pattern of taxpayer rip-offs from Tongass timber sales

USFS Applicants For Forest Restoration Program Panel – Southwestern Region

FYI, folks….

 

Forest Service Seeks Applicants For Forest Restoration Program Panel

 

The Southwestern Region of the Forest Service is seeking applicants for membership on the Collaborative Forest Restoration Program Technical Advisory Panel.  This 12 to15 member panel will evaluate proposals for federal grant funding to conduct forest restoration treatments on public land and utilize small diameter trees.  Panel applications are due to the Forest Service by July 18, 2018.

The panel includes: a New Mexico natural resources official; at least two representatives from federal land management agencies; at least one tribal and/or pueblo representative; at least two independent scientists experienced in forest ecosystem restoration; and equal representation from conservation, local communities, and commodity interests.  The Forest Service is currently seeking applications to represent commodity interests, local communities, tribal and pueblo interests, federal land management agencies, and independent scientists.

The Technical Advisory Panel will review project proposals for: wildfire threat reduction; ecosystem restoration, including non-native tree species reduction; reestablishment of historic fire regimes; reforestation; small diameter tree use; and the creation of forest-related local employment.  The grant proposals must include a broad and diverse group of stakeholders and may occur on federal, tribal, state, county, or municipal forest land.

Meetings will be held one to two times per year in Albuquerque.   Selected panel members will not receive compensation, however, they may be reimbursed for travel and per diem costs.  Panel selection procedures and meetings will be conducted under the Federal Advisory Committee Act.

Walter Dunn is the Designated Federal Officer and will serve as the point of contact for information on the nomination process as well as for the Technical Advisory Panel.  His phone number is 505-842-3425.

Application materials and other information on the Collaborative Forest Restoration Program can be found on the program website at http://www.fs.usda.gov/goto/r3/cfrp .

Completed application packets should be sent to the following address by July 18, 2018:

 

Walter Dunn

Cooperative and International Forestry

USDA Forest Service

333 Broadway SE

Albuquerque, NM 87102

Fax (505) 842-3165

Email: [email protected]

Background Information on Collaborative Forest Restoration Program:

Title VI of Public Law 106-393 creates a mechanism for local community collaboration with federal land managers by establishing a cooperative forest restoration program in New Mexico.   The law provides cost-share grants to stakeholders for experimental forest restoration projects to be designed through a collaborative process (the Collaborative Forest Restoration Program).

Projects can occur on federal, tribal, state, county, or municipal land and must address specified objectives.  These objectives include wildfire threat reduction; ecosystem restoration, including non-native tree species reduction; reestablishment of historic fire regimes; reforestation, including preservation of old trees; small diameter tree use enhancement; creation of forest-related local employment; and stakeholder diversity.

The law also provides that a review panel be formed to evaluate proposals for funding.  The Secretary of Agriculture chartered this panel under the Federal Advisory Committee Act.  Panel nominees will be evaluated based on their familiarity with forest management issues in New Mexico, including:

  • experience working with the government planning processes,
  • knowledge and understanding of the various cultures and communities in New Mexico,
  • ability to actively participate in diverse team settings;
  • demonstrated skill in working toward mutually beneficial solutions to complex issues,
  • respect and credibility in local communities; commitment to attending Panel meetings, and
  • their contribution to the balance and diversity of the Panel.

Equal opportunity practices, in line with USDA policies, shall be followed in all membership appointments to the Panel.  To ensure that the recommendation of the Panel have taken into account the needs of the diverse groups served by the Department, membership shall include, to the extent practicable, individuals with demonstrated ability to represent minorities, women, and persons with disabilities.

Thank you,

Walter

USDA USFS

Walter Dunn, Program Manager
Collaborative Forest Restoration/Southwest Ecological Restoration Institutes

Forest Service

Cooperative & International Forestry, Southwestern Region

p: 505-842-3425
c: 505-301-1291
f: 505-842-3165
[email protected]

333 Broadway Blvd., SE
Albuquerque, NM 87102
www.fs.fed.us
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Caring for the land and serving people

California’s Tree Mortality Task Force- Dealing with 128 Million Dead Trees

Thanks to Mac McConnell for sending this in. You may have seen the posts “128 million dead trees in California” from last December. Here’s a quote:

Though California received record-breaking rains in the winter of 2016-2017, the effects of five consecutive years of severe drought in California, a dramatic rise in bark beetle infestation and rising temperatures have led to historic levels of tree die-off. The Tree Mortality Task Force (TMTF), with support from the Governor’s office and comprised of more than 80 local, state and federal agencies and private utility companies, continues to remove hazardous dead trees. To date, the TMTF members have collectively felled or removed over 860,000 dead trees; this includes over 480,000 dead trees felled or removed by the U.S. Forest Service.
The TMTF members are using a triage approach to this tree mortality crisis, first focusing on public safety by removing dead and dying trees in high hazard areas. To further improve forest health, the U.S Forest Service and CAL FIRE have increased their pace and scale of prescribed fire. The U.S. Forest Service has treated over 55,000 acres and CAL FIRE has completed over 33,000 acres in fuel treatment projects. By combining tree removal with prescribed fire, crews will be able to decrease overly dense stands of trees, reduce greenhouse gases, and protect communities across the state.

“Tree mortality at this magnitude takes on-going cooperation between public, non-profit and private entities,” said Chief Ken Pimlott, CAL FIRE director and California’s state forester. “California’s forests are a critical part of the State’s strategy to address climate change. By working together and using all the resources at our disposal we will be able to make more progress towards our common goal of healthier, more resilient forests that benefit all Californians.”

With record breaking levels of tree die-off, the TMTF has used this event as an opportunity to collaborate on several fronts: from public workshops about reforestation, public outreach in urban and rural areas, and awarding over $21 million in grants aimed to protect watersheds, remove dead trees and restore our forests. The TMTF continues to collaborate on the efficient use of resources to protect public safety and build consensus around long-term management strategies for California’s forest lands.

“The Tree Mortality Task force has provided an essential venue for coordination of response efforts, exchange of ideas, reporting, and accountability for the ongoing statewide response to this incident,” said Supervisor Nathan Magsig of Fresno County. “Leadership from the Governor’s Office, CAL FIRE and Office of Emergency Services has helped to ensure county issues are heard and addressed. Monthly coordination of the 10 most impacted counties has resulted in a more effective use of resources and has allowed counties to share ideas and successes.”

Colorado experienced much tree mortality in the recent past (as did Central Oregon in the 80’s). It’s always interesting to see how different states handle the problem. Perhaps because of the importance/funding of Calfire, there seems to be a strong integrated push at the state and county level. It seems (perhaps related) to be less on the ideological side and more pragmatic than the discussions we often have here. Due to the emergency, they simply seem to have made exceptions to the State Forest Practices Act without much pushback (documented here) (or it’s not obvious from here).

They have a multiagency Tree Mortality Task Force linked here, which has many interesting links including this very cool zoomable map with interesting layers tree mortality viewer (below is a screenshot).

There are a variety of working groups including prescribed fire, insurance, regulations, utilization and so on here. For those interested, the Task Force has a webinar on June 11. As always, I’m particularly interested in the perspective and observations of the Californians here.

National Forest Foundation Kicks Off “Summer of Trails” Campaign

Kicking off a summer-long celebration of the 50th Anniversary of the National Trails System Act, the National Forest Foundation (NFF), today, announced its “Summer of Trails” campaign. Summer of Trails is a five-month long campaign to raise awareness and funds for maintaining and improving trails across America’s National Forests and Grasslands. The National Forests and Grasslands host the largest trail system in the country, with more than 158,000 miles of trails—including the iconic Pacific Crest, Appalachian and Continental Divide Trails and shorter trails beloved by communities from Alaska to Florida.

The Forest Service has struggled to maintain this vast trail system. Budgetary constraints, driven largely by ever-increasing wildfire-fighting costs, have hampered the agency’s maintenance efforts and have led to a significant trail-maintenance backlog. In 2016, Congress passed the National Forest System Trails Stewardship Act, directing the Forest Service to improve its trail maintenance, but the bill provided no additional trail funding to the agency.

The Summer of Trails goal is simple: improve conditions on the National Forest’s incredible trail system. By educating Americans about National Forest trails, and by capitalizing on the 50th Anniversary of the legislation that established America’s world-class system of National Scenic and Historic Trails, the NFF hopes to turn the love that Americans have for their trails into a source of funds to improve trails in each of the nine Forest Service regions.

The NFF hopes to raise $1 million for trail maintenance and improvement across the National Forest System through a crowd-funding campaign. The NFF will invest the funds in local conservation organizations through a competitive grant program. These groups will then use the grants to help maintain and repair National Forest trails across the country. The NFF’s $500,000 crowd-funding goal will be matched with an additional $500,000 by the U.S. Forest Service. The NFF plans to award grants to local conservation groups to begin work improving America’s trails in 2019..

This is from the CrowdRise crowd funding site here:

It’s an ambitious goal, but with your help, we can make a real difference for our trails in 2018. For the price of a post-hike beer or a bottle of Gatorade, you can help us reach our goal.

Think back to the last time you hit up a trail on your local National Forest. Did you climb to a shaded overlook? Did you beat your friend to the top? Did you just amble along and enjoy the hike? What are these memories worth? $5? $10? $50? $100? The campaign runs through the end of September, 2018, so donate every month. Every bit helps!

If you find this campaign inspiring, share it with your trail-loving friends and family. Challenge them to give. Set a goal for your hiking group, maybe $1 for every trail mile you tackle in June. The Forest Service estimates that 84 million people use these trails every year. Imagine how much we could help if every person gave just one dollar!

Lone Rock Timber Receives Threat

From the News-Review, Roseburg, OR:

Lone Rock Timber Management Company has asked the Douglas County Sheriff’s Office for additional patrols in response to a threat made against the company by conservationists, according to the sheriff’s call logs.

The call, made just before 6 p.m. Thursday, said a group of conservationists are upset that Lone Rock is logging in the Susan Creek area, land managed by the Bureau of Land Management, and are threatening to burn Lone Rock “to the ground.”

Lone Rock requests extra police presence in wake of threats

Doesn’t mention the name of the group.

[ADDITIONAL INFORMATION BELOW, POSTED BY MK]

Posted on Facebook on May 7, 2018 by Francis Eatherington:

“Yesterday we hiked into the BLM forest that Lone Rock Timber had threatened to cut down for a new road, and we found it just cut down. Very sad. All the big trees were horizontal on the ground. We counted the rings on some stumps and found them to be 400 years old. On the hike in we went past LRT’s 19-acre plantation they had just cut and yarded, and we could see about an acre of tiny trees they had left to cut at the top of their unit. Even though it was clearcut 40-years ago, this time LRT insisted they had to cut this 70’-wide road through BLM land to get a mechanical harvester into that little acre they had left. They couldn’t cut it manually like they did before. This is an obvious scam by Lone Rock – they will get far more timber from our public old growth forest then they will access from their land. Not only are the old-growth trees gone, a new road bulldozed across this ancient forest will be a horrible scar, spreading it’s edge-effect far into the remaining old growth forest.”

Posted on Facebook on May 7, 2018 by Doug Heiken:

“The reason that Lone Rock Timber gave for needing access through this stand of ancient trees, was they needed to get a mechanical harvester (tree killing robot) into the area so they could log a stand of small trees on their own land. However, before the road even got built Lone Rock was able to log all but about 1 acre of their land. Which means these ancient trees fell just so they could bring their robot in to fell an acre of second growth. This is SO wrong! I smell a scam. The timber industry is to blame and BLM is complicit.”

[ADDITIONAL INFORMATION BELOW, POSTED BY SF]

Here seens a fair-minded piece that looks at (and talks to) both sides (and explains the O&C rights of way). But be careful, as there are a couple of interesting stories and you only get five free ones.

In this case they claim that BLM has embarked on a ‘back-room deal with Lone Rock Timber to log ancient forests,’ when the truth of the matter is that Lone Rock Timber has the legal right under our reciprocal right-of-way agreement with the BLM to construct the road to gain access to our property,” Luther said, adding some of the trees in the posted photos are outside of the proposed logging area.

If I lived in the area, I would be tempted to go see for myself (and share the photos here).

NFS Litigation Weekly May 11, 2018

Litigation Weekly May 11

Following its earlier denial of a TRO, the district court also denied a preliminary injunction for the North and South Pioneer salvage logging projects on the Boise National Forest. (D. Idaho) (See below also.)

(Notice of intent to sue under ESA.)  Plaintiffs claim failure by the Forest Service to include wolverines in their biological assessment, as required by ESA if they are present in the project area, for the North Hebgen Project on the Gallatin National Forest.

Blogger’s note:

The Boise case included a “Cottonwood” style claim that the project could not proceed until completion of the forest plan level consultation that is presently occurring on bull trout critical habitat.  The court held that that was not necessary in this case because project level consultation had concluded that the projects were not likely to adversely affect bull trout critical habitat, and the Fish and Wildlife Service did not base its conclusion on the forest plan.  Therefore these projects could not violate ESA §7(d)’s prohibition against going ahead with actions that had the potential to adversely modify critical habitat.

FS vs. BLM Workload..One Worker’s Point of View

As I’ve been reviewing the EADM workshop summaries, I’ve noticed that one commonality of most of the regional workshops is what you might call “team management”. Things like people leaving, balls being dropped, lengthy efforts that change direction with new additions to the team, even retirements, pose a problem to getting projects accomplished. Yesterday a comment came in on the BLM comparison to FS topic from “Circus Employee”. Here’s a link to her/his comment. Looking even deeper, I wonder if some of these team and management problems are from too high and too many targets, or from activities that draw FS employees away from their work somehow. Both agencies must deal with the hassles endemic to federal land management bureaucracy. It might be helpful to get a team of folks who’ve worked in both agencies to give some recommendations as part of the EADM effort (how can NEPA teams be managed better?). Also perhaps some position classification reviews and workflow analyses comparing the agencies. Perhaps fund some public administration schools to take a look? Perhaps problems with the management of EADM are reflective of overall difficulties in management.

These workload comparisons probably depend, to some extent, on the particulars of location (if a unit doesn’t have timber, or minerals, or has a big recreation program), but but it might be possible and worth it to compare workloads and work processes with similar conditions-perhaps neighboring units. Anyway, here’s one person’s point of view..

“I just switched from the BLM to the Forest Circus, Department of Aggravation. I took a lateral position, GS-0486-11, and I assure you 100% that my job with the FS circus is like doing 5 jobs with the BLM. While working for the BLM I was “a” wildlife biologist (terrestrial). With the FS as a wildlife biologist I also do the duties for a fish biologist, botanist, and a weeds specialist, and in addition, I am also a supervisor, which I did not supervise anyone with BLM. My supervisor, a GS-12 at BLM, supervised ALL the technicians and specialists and did not do NEPA. My current job duties with the FS would be equivalent to a GS-12 with the BLM, at a minimum.

I have to write many more BA/BEs and NEPA for all four of those resources for the FS. While working in an interagency (BLM/FS) office, I learned it is a well known fact that the BLM is much better, with reasonable workloads per person. I just didn’t realize how much of a difference it is. My boss at the BLM came from the FS, and she loves the BLM much more than the FS. She’s a GS-12 and I currently have more duties than she does!

Everything in the FS is way more complicated; budgeting, timekeeping, FACTS, WIT, NRM, the O drive troubles, and now Pinyon, on and on! Literally, I can’t be efficient at any one thing because I have to shift gears daily and re-learn it all because it’s so complicated.

Comparing the two agencies by acres is not a good formula, at all. I managed 10 times more acres for BLM than I do with FS, and my job with BLM was way easier to do quality work and to keep up.

Another thing, BLM HR is far better structured than FS HR!
….
Bottom line, the BLM treats their employees better because they can, they are funded better, and probably hire better supervisors too because of that. Good people don’t want to stay with the FS when they know things are better elsewhere, like the BLM or BOR where they pay better for the duties performed.

Utopia or Dystopia: What comes next?

The other day at lunch with an old friend, our talk turned to optimistic and pessimistic outlooks regarding the future. He has been reading books by authors who are somewhat to highly optimistic about the future—basing their optimism on advances in science and technology. Two books he mentioned are Stuart Brand’s Whole Earth Discipline: Why Dense Cities, Nuclear Power, Transgenic Crops, Restored Wildlands, and Geoengineering Are Necessary (2009), and Steven Pinker’s Enlightenment Now: The case for reason, science, humanism, and progress (2017).

I mentioned that years ago I was asked to present a set of myths at a Forest Service “adaptive management” workshop in Santa Fe, NM. The first two myths were “Science will find an answer” and “Technology will save us.” I view science and technology as two-edged swords—working both toward our collective good as well as toward our collective detriment. It all depends on how we choose to use them.

When I got home I looked up both books. Brand’s book seems somewhat reasonable—in a Jack Nicholson “Maybe this is as good as it gets” way—judging the book by its title (and a few reviews I found). Both books seem to fall into the trap I identified at the Santa Fe meeting.

I found an interesting review of Pinker’s book by Ian Goldin in Nature.

Here is a snip from Goldin’s review of Enlightenment Now:

Although it is framed as a historically informed template for a new age of reason, Enlightenment Now ultimately becomes something else: an extended dismissal of the arguments of despair that Pinker fears are defining politics and crowding out an alternative approach rooted in rationality and global cooperation. He does not frame the thesis in economic terms. Yet he essentially defends globalization and the growth of market economies by claiming that it has brought more progress than any force in history. As an economist, I agree.

So do I. But I also agree with Goldin’s other arguments:

But globalization has also led to an escalation of risks. What is rational for individuals is increasingly irrational for society. The drivers of progress are rising incomes and connectivity; these also lead to greater negative spillovers and systemic risk. Managing globalization’s underbelly is essential, and the gulf between what needs to be done and what is being done is widening. Economic growth has come at the expense of ecosystems. Because nature does not respond to price signals (rhinos do not reproduce more when their horns are more valuable), increasing freedom of choice has led to overexploitation of a growing number of natural systems. Pinker does cite climate change, but as a worrying exception to a relentlessly positive narrative, rather than as the most glaring example of a wider failure of global commons management.

Goldin concludes with a precautionary note:

I share Pinker’s optimism that this could be our best century, in which poverty and many of the challenges humanity has historically confronted are addressed. Yet there is also a real potential for dystopian outcomes as sea levels, strife, temperatures and resistant infections rise, and biodiversity, democratic institutions, social ties, mental health and resource security are eroded. We need to face up to these and other daunting challenges while nurturing the positivity required to tackle them.

Enlightenment Now is not a balanced account of the present or future. But for the many overwhelmed by gloom, it is a welcome antidote.

I’m more pessimistic than Goldin. Even though I agree that this century could be our best chance to extract ourselves from what may be a lemming-like mass approach toward the edge of a cliff, it seems an unlikely prospect to me. On the other hand the dystopian outcomes seem more likely. But who am I to make such “likelihood” calls. Then again, who is? I regret that I won’t be around long enough to see much of what happens.

I guess I’d have to read Enlightenment Now to see if I agree with Goldin’s call that it is a “welcome antidote” for “the many overwhelmed by gloom.”

As for Brand’s outlook, take a look at what he and coauthors call An Ecomodernist Manifesto (2015).

The Ecomodernist Manifesto is hopeful, if a bit too hopeful as to humanity’s ability to rise above our worst natures. It seems somewhat reasonable at least in these ways: 1) Nature is recognized as a positive good, with suggested safeguarding of both ecosystems and species diversity highlighted, 2) market economics is relegated to secondary role, not a primary driver of all that is good, …. It seems overly optimistic in its portrayal (or lack thereof) of people’s ability to get from the edge of dystopia to the future they propose. And it is optimistic as to the roles portrayed be technology and development. But it was written in 2015, or 1 BT (BT: Before Trump).

On a hopeful note of my own, if we don’t now and continuing forward from here slip into deep dystopia, Trump and others like him on the world stage may ironically give us the wake-up calls we desperately need.

The mysterious disappearance of sensitive species – Flathead plan revision example

Harlequin duck (Histrionicus histrionicus)

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

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

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

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

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

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