Last Day for ANPR Comments: II. How Can the FS Respond to Rapidly Changing Conditions? (Associated with Climate-Amplified Impacts)

The comments requested in the ANPR seem to me to be pretty much about everything the FS does.  Which is great, in a sense, because I think it’s an open door to make any comments you think would improve the FS.  For example, you could make an argument …. unknown climate changes=changing quickly=flexibility for FS to respond=more trust= better data for the public and more transparency= the People’s Database.

I copied the questions from the ANPR so you can check them out in this post.

Some of it seems like the same old problems.. like adaptive management. Remember Chief Thomas and the inception of the Inventory and Monitoring Institute?  And I think many TSW readers have had their own experiences and ideas which you could write up and send in today, if you haven’t. For me adaptive management always goes down to “how structured? and by whom, to what end?”  We also have examples like the Watershed Condition Framework- how did that work out? Some of us were on the front ends of these efforts.. some seem to have fizzled out and maybe we never hear what happened. Michael Ligquri had an interesting comment on that here when I first posted about the ANPR questions.

Two comments:

1) we tend to bog ourselves down with these kinds of open-ended, subjective, and unanswerable questions. All great questions, no doubt. But they tend to promote more “analysis paralysis”, and often fail to advance any significant “adaptation” to management. I’ve participated on several multi-year committees assigned to resolve these types of questions, and while we end up wordsmithing complex answers, little changes. To anyone who understands design theory, such “overconstrained, over-complex problem sets” is an inherently poor frame for solutions.

2) An effective approach that I’ve used to inform “adaptive management” is using performance-based monitoring/research approaches. This starts with structured working hypotheses that are both measurable and testable. It also includes specific targets and action thresholds based on objectively measurable existing conditions and trends analysis. Ideally, such approaches must include an understanding of geographic diversity. Watershed Analysis was originally designed to help inform such standards, but failed in its implementation (for many reasons, too complex to elaborate here).

And the more structured the framework, the less able to adapt to “rapidly changing” concerns and impacts. Not easy. But here are some quotes from the front end of the ANPR:

Climate change and related stressors, such as wildfire, drought, insects and disease, extreme weather events, and chronic stress on ecosystems are resulting in increasing impacts with rapid and variable rates of change on national forests and grasslands. These impacts can be compounded by fire suppression, development in the Wildland Urban Interface (WUI), and non-climate informed timber harvest and reforestation practices.

Multiple Forest Service plans, policies, and regulations already include direction on climate adaptation. However, given (1) increasing rates of change, and (2) new information and ways of assessing and visualizing risk, USDA and the Forest Service are issuing this ANPRM to seek input on how we can develop new policies or build on current policies to improve our ability to foster climate resilience, recognizing that impacts are different in different places across the country.

There’s a couple of interesting things about this framing.  First of all, apparently according to this, everything bad is climate or climate-related that needs to be adapted to.  So.. if we have a new introduced invasive insect, does that only require attention if it’s “climate-related”? If that’s the case, you can see people making the argument why it is climate-related, even when it isn’t.  Pretty soon everything is climate-related.  Even Covid-related recreation pressure (if it’s hotter in the cities, then more people will go to the mountains?).  If we keep going, then, all resilience is climate resilience, and we’re gone from multiple-use to ecological sustainability to ecosystem integrity to climate resilience, and at the end of the day it’s all the same stuff the FS has been doing with different words. You might also notice that after multiple use in this line-up, people and the social sciences seem to take a backseat. And yes, I understand that “without ecosystem/climate resilience, there would be no recreation” that’s kind of the “ecological sustainability is primary” 2001ish argument. But do all these definitional meanderings actually help any employees and users and neighbors make better decisions about the problems that confront them every day?

The other thing that struck me about this is the “development in the WUI and non-climate informed timber harvest and reforestation practices”.  I retired quite a while ago, and even then silviculturists, fuels practitioners and reforestation folks were considering climate in their work.  And one of the first papers on reforestation strategies and climate was in 1992, over 30 years ago. I also don’t see how “development in the WUI” contributes to “wildfire, drought, insects and disease, extreme weather events, and chronic stress on ecosystems” except for the obvious way that people who live in the area may start fires (but maybe homeowners are more careful than recreationists because it’s their properties.. do we know?), and neighbors not treating their trees could lead to more insects and disease? But why WUI folks and not other neighbors?

The concern about matching adaptation to “rapid and variable rates of change” reminds me of Chief Jack Ward Thomas on forest plans:

“Land use planning should be a meaningful – a guide to management action and funding – achieved within a year at much less costs. Before embarking on new efforts in planning it is critical to determine why such planning has failed so miserably and short comings rectified. Flexibility should be a component so as to deal sudden alteration in conditions – fires, markets, economics, and, insect and disease outbreaks.”

I think he said this about 30 years ago.. but note he mentions fire and insect and disease outbreaks.  Anyway, perhaps this is a good time to consider amending NFMA to help the FS be able to  respond to “rapid and variable rates of change”  and use the latest science at the period a project is proposed.

Recreation doesn’t play much of a role in this ANPR for some reason and it’s probably the #1 important use of National Forests now, so that’s also interesting.  Anyway, if you think they are asking “hey climate resilience is a new and different thing, how should we manage it?,” it seems like an opportunity to respond with any ideas you have for improvement in general.

You can post parts of your comments below or email me.  I’m curious about what people come up with.

 

Last Day for ANPR Comments I. The MOG Thing

 

Today is the last day for comments on what I used to call the Mature and Old Growth ANPR.  First let’s give the Forest Service some kudos for the differences between it and the BLM proposed rule.  Like the IMBA letter suggests, the BLM could have benefited from collecting ideas (through an ANPR) and then further honing the proposal in a proposed regulation as the next step. Also when time periods were extended the BLM’s were shorter and the BLM had the close on July 5, right after when most people had a holiday weekend.  The BLM had a few public meetings and some online..the Forest Service approach was different, but then there is not a proposed rule yet, they’re collecting ideas in the ANPR.

Since I first posted on the ANPR, I’ve had much time to reread the Federal Register notice and look at some individual and group responses.  It remains puzzling to me as there seem to be two basic threads.  One is the mature and old growth question.. should some regulation be promulgated about not cutting trees in mature and old growth, as recommended by many ENGO’s?  Check out the Climate Forests Campaign here.

There are many ENGO heavy hitters (in the Biden Admin) like Earthjustice, NRDC, and the Sierra Club among the group. Their argument seems to be.. this is the rationale folks are sending in based on  the “take action” letter:

In addition, older forests and trees are far more adaptable to the impacts of climate change, especially compared to industrial tree plantations. Nationally, carbon losses from clearcuts and other logging are up to 5 times higher than emissions from fire and other natural forest disturbances combined. Logging older forests grossly undercuts these benefits.

We urge you to include in any future administrative rules an end to ecologically harmful logging of mature and old growth forests and trees on federal land. While there are certainly other threats to our older forests, including wildfire and drought, the threat of logging is fully under your control and can be quickly acted on.

The first few sentences appears to conflate federal and private lands (I can’t get their link to check it), and the alternative on national forests is not “industrial tree plantations.”

The second is that however tiny the proportion of disturbance due to timber harvest (regardless of purpose, including ecological restoration and fire risk reduction) that is what can be controlled so you should stop.  Presumably even for fire risk reduction and ecological restoration.

The ANPR has some interesting tables for those who haven’t read it, so I thought I’d put them in this post.

There are difficulties though, with the argument of stopping any tree-cutting in mature and old growth forests.  For one thing,  the bipartisan Congress has asked the Forest Service to cut some mature trees for fuels reduction, in part to increase the possibility of protecting old growth trees and stands.  Then there is the need for early successional habitat for diverse tree (species like some oaks and pines) and wildlife species, as biodiversity is thought to be a good thing, and is in the 2012 Planning Rule.

Given the desire and appropriations by a bipartisan majority in Congress for fuel treatments, I don’t see how any such no-cutting mature and old trees rule would end well (except for work for litigators). And for environmental lawyers here at TSW, no, I don’t think that making more work for you all is why these ENGOs are doing this.  Sure, you can say that the Sierra Club has wanted to end commercial logging since 1986 -ish, so perhaps climate is just the latest justification for this same point of view.  And the Biden Admin may seem like a good opportunity to run this up the flagpole.  But I can’t see an endgame where no-cutting trumps fuel reduction treatments and openings for biodiversity at the end of the “separation of powers” day.  And I know that folks in the ENGOs  know more than I do about this, and for sure are smarter and more politically astute than I am.  So what is this really about?

On the other hand,  some Forest Service folks have told me that the “no-cutting rule” idea isn’t going anywhere and the ANPR is really about how the FS should respond to climate adaptation.   But based on the FOIAs I’ve received, the FS isn’t necessarily calling the shots with regard to forest policy in this Admin (nor is USDA).  So I would be inclined to include your thoughts on MOG in any comments you want to send in today.  Next post: the rest of the questions in the ANPR.

 

2023 Oregon Flat Fire: National Learning Opportunity?

Earlier today (July 18) Oregon Representative Court Boice asked for insight regarding the current management actions taking place on the State’s largest active wildfire, the Flat Fire. It is now more than 8,000 acres in size in an area famed for its east winds and known for the past 35 years for some of the largest forest fires in Oregon history.

My fields are forest (and fire) history and reforestation, not wildfire management, and his request was for distribution to a 100+ email discussion group of actual wildfire management experts; which task was just completed. It will be interesting to see what the response will be, and that might largely depend on weather patterns over the next several days and weeks — and particularly the east wind.

Below I have copied this evening’s official report on the fire, and following that I have included the text of Rep. Boice’s letter of emergency to 30+ fellow politicians and USFS reps, including Supervisor Merv George. This fire has great potential for being an important learning experience for all involved, depending on how things develop. Here is the current report:

July 18, 2023 Evening Update

Size: 8,204
Start Date: July 15, 2023
Point of origin: 2 miles south east Agness, OR
Cause: Under Investigation
Total personnel: 378
Resources: 16 Engines
13 crews
2 bulldozers
2 water tenders
7 helicopters

Current Situation: Today the fire spread on the western flank. An infrared flight will be flown this evening to map accurate acreage. Firefighters have been successful in keeping the fire within control lines on the northwest section of the fire. They were also successful in completing small, targeted 10-15 acre burn outs reducing vegetation on the north flank, protecting communities in the Agness area.

Fire managers continued making use of aviation resources today, including helicopters and airtankers dropping water and retardant over the fire. Using water and retardant temporarily slows fire activity assisting crews on the ground.

Tonight’s activities: Nightshift firefighters will continue progress from the day shift, building fireline and laying hoseline.

Evacuations: Please monitor the Curry and Josephine County Sheriff’s Offices for official evacuation notices. https://www.co.curry.or.us/government/county sheriff/index.php
https://www.josephinecounty.gov/government/sheriff/index.php

Weather: Clear with low humidity on ridges.
Closures: The Rogue River Siskiyou National Forest has issued a closure order for the fire area including trails, roads, and a portion of the Illinois River. Please be careful when driving in the area due to increased fire traffic.
Restrictions: Fire Restrictions are in place https://www.fs.usda.gov/rogue-siskiyou

Information Line: 541-216-4579 8am-8pm
Media inquires: 541-237-6369 8am-8pm
Facebook: https://www.facebook.com/flatfireoregon2023

Twitter: https://twitter.com/FlatFireOR2023
Inciweb: https://inciweb.nwcg.gov/incident-information/ xx1002-flat fire

Email: [email protected]
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The Subject Line in Rep. Boice’s Email of Emergency was entirely in caps, as were several key words in the text:

CURRY COUNTY FLAT FIRE – IMMEDIATE AND BOLD ACTION NEEDED – URGENT…

Please give our Hero Fire Fighters Historically Proven Plans to Win – Stop another Curry Monster Wind Driven Fire!

Lessons Learned: The Afternoon Winds are upstream… generally towards the east on the Rogue and Illinois river drainages. As the sun sets offshore, the atmosphere becomes kinetic per the temperature change. The Chetco River has a weather anomaly. In the afternoons – the winds are toward the ocean, pushing west; This effect is why the town of Brookings has such nice warmer winter weather.

As and If the Flat Fire likely continues burning generally Southwest… upstream on the Illinois; it tops out into the Chetco drainage which is commonly known as the “Chetco Effect”… It will take the fire in the exact opposite direction… about due west to the town of Brookings. Already happened once – almost twice. This time it undoubtedly will happen faster. Communities of Pistol River and Gold Beach of course are also at risk and potentially even Smith River California.

The 2017 Chetco Bar took 191,000 and the 2018 Klondike likewise destroyed 176,000 acres. EACH cost a staggering $80 plus million dollars to fight! (Yes – Fact: combined $ 170 million in 18 months!) The fuels now are quicker and more volatile per brush regrowth due to multiple previous Mega Fires; Biscuit, (Still the largest Fire in Oregon History), the Collier, Chetco Bar, and repeatedly prove this.

ACTION NOW: Declare wise and legitimate emergency – Override Congressional Laws stopping designated wilderness areas – No Equipment Allowed. This mis-guided approach is brutally dangerous to our communities. Also we know without debate – millions and millions of our wildlife are incinerated – their instincts help them normally escape healthy fires, but they cannot survive our tragic Curry Nuclear Fires. History proves what follows will work and Save Lives, Property, Wilderness, Watersheds, Fish and Wildlife. ACTION NOW!

Immediately open and improve all relevant and advantageous roads

Seasoned Loggers and Fire Fighters (now in their 60’s and 70’s) – men on D-7 dozers…cutting lines on critical ridge tops

Hand crew ‘Back Burns’ can help off the ridges, but are very risky. That work must have unanimous consent between USFS, ODF and CFPA prior

Aviation work to cool both sides down

Hand crews catch the spots

Our Curry Fire History is invaluable. Our outlined steps either happen OR we know the fire will not be stopped… We cannot again wait for late October Rains – futile and unacceptable !

The risk of loss of property and life is immense. We could lose towns or worse.

Court Boice
State Representative – Oregon District 1
[email protected]
Phone (503) 986-1401

Fervo Enhanced Geothermal Breakthrough and WGA “Heat Beneath our Feet” Recommendations for BLM and FS

Drilling rig at Fervo Energy’s Project Red in Nevada (source: Fervo Energy)

 

 

Fervo Energy says it has geothermal energy breakthrough. This was a story in Bloomberg News, but can be seen on the Financial Post website here.

Fervo has an interesting explanation of how their technology is different here. But I think the news story is about more general successful testing.

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How Fervo Expands the Geothermal Landscape

Fervo leverages horizontal drilling, distributed fiber optic sensing, and multi-zonal completion techniques to introduce fluid and increase permeability in the subsurface. By injecting water underground and creating pathways in the rock for that water to flow, Fervo no longer has to worry about finding perfect, naturally occurring hydrothermal resources.

Instead, Fervo can focus on analyzing the temperature profiles of different prospects. Geothermal electricity generation is typically economic at temperatures greater than or equal to 150C. With existing drilling capabilities, Fervo seeks to tap into these resources less than 4 km  beneath the surface, which offer nearly 300,000 MW in capacity.

Looking for land with subsurface temperatures greater than 150C at less than 4 km is significantly easier than looking for land with the same temperature requirements and ample permeability. When temperature is the sole constraint, geothermal becomes a much more scalable resource.

Next-generation geothermal technology could deliver over 250,000 MW of 24/7 carbon-free power to the grid, more than 8 times the amount of estimated capacity associated with undiscovered hydrothermal resources and more than 25 times the amount of capacity provided by identified hydrothermal reservoirs. With strong transmission, this power could support communities across the country, far beyond the western U.S.

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Here’s what the Western Governors did with their geothermal initiative. I bolded the parts of particular  interest to us. Going back to our data theme this week, thought, perhaps “people’s views and concerns” should be in a database somewhere along with the technical data. But maybe those get incorporated in the “priority leasing area” development effort?

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As part of the bipartisan Heat Beneath Our Feet initiative, the Western Governors’ Association (WGA) has published a comprehensive report detailing the group’s recommendations and strategies to accelerate the deployment of geothermal technologies across the Western U.S. states. The full report can be viewed here.

The Heat Beneath Our Feet initiative was launched by the WGA under the leadership of Governor Jared Polis of Colorado in mid-2022. The goal was for the WGA to evaluate geothermal energy technology development in the Western States and assess the potential benefits it would offer. This was followed by a rigorous process of engaging with over 500 stakeholders through online surveys, tours, work sessions, and a webinar series.

The report also highlights several case studies of geothermal development in various U.S. states, as well as recaps of the many tours and workshops conducted as part of the Heat Beneath Our Feet Initiative.

After examining the various market, technology, and policy factors that affect the development of geothermal resources, the report proposed the following recommendations:

Improve resource assessment and data collection

  • Increase federal funding for resource assessments – “Congress should provide USGS and DOE with funding to increase the pace and scale of data collection, mapping and resource assessments and facilitate collaboration with state geological surveys. DOE should also leverage synergies with other programs, such as USGS’s Earth Mapping Resources Initiative (MRI) that are complementary efforts and in which states are already partners, to expedite efforts to assess geothermal resources. “
  • Coordinate with states to target resource areas with greatest potential – “States serve a critical function as primary sources and stewards of geospatial, scientific, and technical datasets that support the development of renewable energy resources. State geological surveys should have the opportunity to provide input and recommendations on where USGS and GTO prioritize resource assessment efforts in their states. “
  • Improve the federal repository of relevant geothermal development data and the ability to interact with it – “The federal geothermal data repository should seek to incorporate data relevant to those factors, such as mapping overlays of critical habitat for endangered species, hydrological data, and existing transmission capacity… This federal repository could build on NREL’s Geothermal Prospector and should be publicly available and easily accessible online.”
  • Leverage data from the oil and gas industry – “Both (oil and gas, and mining) industries rely heavily on subsurface expertise that could help reduce the exploration and drilling costs of the geothermal industry. These operators should be encouraged to share data from existing operations with geothermal developers. Further, public-private partnerships with DOE should be encouraged to reduce the cost of drilling for geothermal wells through project demonstration grants.”

Mitigate risk in drilling and exploration

  • Continue federal investment in reducing uncertainty in geothermal exploration – ” Congress should extend authorization and increase funding for the Hidden Systems Initiative… for the research and development of innovative subsurface technologies.”
  • Explore models to help developers secure financing for exploratory drilling – “DOE should explore the feasibility of cost share programs, such as guaranteed loans, insurance, and grants, and assess the effect these mechanisms would have on the geothermal industry.”
  • Extend existing tax incentives for the oil and gas industries to geothermal development – “Despite the similarity of exploration activities in the geothermal and oil and gas industry, some regulatory and tax incentives that currently apply to exploratory wells drilled for oil and gas do not apply to geothermal exploration. Congress should extend this tax treatment to the geothermal industry.”

Optimize permitting and improve regulatory certainty

  • Provide tools and resources to help proponents navigate the geothermal development process. – “DOE should coordinate with states to maintain publicly available resources detailing the state and federal requirements that apply to geothermal development in each state.”
  • Increase agency capacity for leasing and permitting. – “The Department of the Interior (DOI), USFS, and Congress should ensure that the relevant agencies are adequately staffed to review permits in a timely fashion. DOI and USFS should also ensure agency staff have access to technical experts to build staff expertise in geothermal development.”
  • Develop streamlined processes for geothermal leasing on par with other energy categories. – “BLM should establish priority leasing areas for geothermal energy, as it has done for wind and solar energy in Instruction Memorandum No. 2022-027.”
  • Expand oil and gas exploration regulatory efficiencies to geothermal development. – “Congress should expand Section 390 (of The Energy Policy Act of 2005) to include geothermal exploration, which would allow agencies to use the existing categorical exclusion to facilitate increased geothermal exploration and the discovery of new resources without compromising environmental protections.”
  • Fund research on the water usage of EGS. – “DOE should fund water efficiency research as part of the Enhanced Geothermal Shot and related EGS efforts.”
  • Collaborate with tribes and communities, including consultation prior to and during project development. – “Where relevant, it is important to consult tribes at the beginning of a potential geothermal project and ensure that the resource is developed in a way that does not damage sensitive historical and cultural resources.”

Expand funding opportunities

  • Expand funding for demonstration projects. – “Congress should expand funding for programs that support geothermal demonstration projects such as those under the DOE Loan Program Office’s Title 17 Clean Energy Financing program… Congress should continue to fund the FORGE project and establish additional EGS demonstration projects in the West.”
  • Encourage development in energy transition communities. – “DOE should target funding towards these (energy) communities for the conversion of existing oil and gas wells to geothermal energy as part of a just transition.”
  • Increase funding levels for the Geothermal Technologies Office. – “Congress should appropriate sufficient funds to the GTO to establish a strong research and development capability and to execute the recommendations contained in this report… Appropriations in recent years have been significantly below the authorized level.”

Implement incentives for consumer adoption:

  • Expedite the deployment of tax incentives, rebates, and end-user applications. – “The Inflation Reduction Act both increased and expanded the tax credits and rebate program for the installation of geothermal heating systems. The Internal Revenue Service should move quickly to implement these programs so that consumers can begin taking advantage of them as soon as possible and define domestic content requirements in as expansive a manner as permissible under federal law.”

Develop workforce and contractor ecosystem

  • Create opportunities for workers and communities affected by the energy transition – “Congress should establish a mechanism within DOE that leverages existing expertise and relationships in the national labs to conduct education and workforce development. Congress and DOE, in conjunction with other federal agencies, should also consider opportunities to target these communities with resources and training, and collaborate with relevant trade unions to expedite its deployment in communities.”
  • Support workforce development in the geothermal industry. – “Policymakers should support the development of industrywide training opportunities and collaborate when applicable with trade unions that perform this work. The industry should work closely with states to develop and scale up training pathways to meet this workforce demand.”

Increase awareness and education to develop geothermal markets

  • Develop guidance for policymakers, regulators, and utilities to conduct cost-benefit analyses of geothermal energy – ” Greater awareness of the firm, clean nature of geothermal energy could build more confidence in the resource and lead to utilities encouraging geothermal solicitations in their bids. DOE should develop guidance on how to incorporate the full value of geothermal projects into resource planning.”

2021 carbon stock changes: Some USFS regions are net emitters

Folks, this April 2023 paper is full of interesting data. For example, this shows that some USFS regions are net CO2 emitters (positive numbers), while others are sinks (negative numbers). (Full title: “Greenhouse Gas Emissions and Removals From Forest Land, Woodlands, Urban Trees, and Harvested Wood Products in the United States, 1990–2021.)

2021 carbon stock changes (net flux) from forest land remaining forest land within the National Forest System (NFS) by NFS region and year (MMT CO2 Eq.):

Alaska-4
Eastern-11.5
Intermountain11.5
Northern0.9
Pacific Northwest-28.3
Pacific Southwest-5.7
Rocky Mountain12.2
Southern-25.5
Southwestern6.9
Net emissions and removals-43.5

Summary:

2021 Estimates at a Glance
Summary statistics for 2021 from the compilation of the forest land, woodlands, HWP, and urban trees in settlements in the U.S. EPA (2023) report:

• Economy-wide GHG emissions increased from 2020 to 2021 by more than 6.8 percent.
• Forest land, HWP, woodlands, and urban trees in settlements collectively offset more than 12.4 percent (785.0 MMT CO2 Eq.) of total GHG emissions or 15.6 percent of CO2 emissions in 2021.
• Private forest land accounts for nearly 84 percent (-493.9 MMT CO2 Eq.) of the estimated net sink strength in the conterminous 48 States and coastal Alaska in 2021.
• Land conversions to and from forest land continue to result in net emissions and/or transfers of carbon to other land uses (33.1 MMT CO2 Eq.).
• Soils store more than 55 percent of all the carbon in forest ecosystems, with small stock changes annually.
• Forest land area burned was nearly 1.7 million ha, and GHG emissions were among the highest reported over the time series from 1990 to 2021.
• Forest uptake averages 0.6 metric tons of carbon per hectare per year (MT C ha-1 yr-1), with live vegetation accounting for more than 83 percent (0.5 MT C ha-1 yr-1) of the uptake.

Repost From the Past: Time for the People’s Database?

from a presentation at the 2019 FIA User Meeting https://www.ncasi.org/wp-content/uploads/2019/02/Prisley1.pdf

 

Yesterday’s discussion of all the possible information about fires and datasets that might be useful for different reasons reminded me of  a post from 10 years  ago  (April 27, 2013, to be exact).. Needed: Coalition for Public Access to Information on National Forests (AKA The People’s Database)

In the past, TSW had a category called “the People’s Database” that talked about how the way the FS produces information could be more helpful to the kinds of questions the public is asking. If you’re interested, you can click on the category way down among the widgets on the right hand side.  It’s probably easiest to do this on a computer rather than a phone.

A colleague of mine when we worked in the now-defunct RPA Program, Terry Tipple, used to give me on-the-job training in his field, public administration. He always said “policy is like a merry-go-round, you keep going around and at some point stars will align such that you can grab the brass ring.” It’s in the spirit of potential brass-ring-grabbing that I repost the below piece from 2013.

Anyone who is writing a comment letter for the Forest Service ANPR (that I used to call the MOG ANPR, but I’ve been told more recently that it is really about improving procedures and practices) can add ideas like this.. .

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Volunteering for SAF gives me many opportunities for insight and opportunities to compare private and public forests, and regions of the country.

Recently, SAF signed on to an effort to get funding for FIA- forest inventory and analysis- which collects information about forests across the US. A couple of times I served on two “Blue Ribbon Panel” of users of the information who (excerpted from this):

The American Forest and Paper Association has organized two Blue Ribbon Panels (1991 and 1997) to review the national FIA program and provide recommendations to the Forest Service on needed changes to the content and capabilities of the program. The most recent panel recommended that the Forest Service should 1) elevate the priority of FIA in the Forest Service program, 2) convert the FIA program from a periodic inventory to an annual inventory, 3) fulfill the congressional mandate of reporting on all lands regardless of ownership, 4) concentrate on the core ecological and timber data, and 5) develop a strategic plan to implement the full FIA program.

FIA also has regular meetings with user groups to help guide their activities and generate support.

It seems to me that we are missing a group (a Peoples’ Coalition) that can reach across different interest groups and ask for information that we might agree that we all need about National Forests. We don’t have an AF&PA to speak for us and get things started, so perhaps we have to organize ourselves.

We could ask the Chief to convene a panel of citizens representing different groups to ask 1) what information is important to be collected in a standard format across forests and regions? and 2) how best do we make that accessible to the public? For example, PALS has searches that internal folks can do but not external.. should it remain that way?

Stakeholders outside of the FS could then lobby strongly for this information the same way that groups (very successfully) lobby for FIA.

Some topics we’ve mentioned here are budgets and outputs, costs of environmental document developments, number of acres treated, etc., as in the “vegetation management” thread here and here. it seems to me that we could take advantage of having an Administration which promotes transparency to set such a framework of an advisory committee.

At first, I was thinking volunteers could find and enter the data, but then I thought “if the public wants this information, why doesn’t the agency just provide it?”. I’m sure that the agency could save some bucks by stopping collecting information on a variety of things that someone used to be interested in, and focus on things the public is currently interested in. The public could actually help the Forest Service prioritize information across silos, something that is problematic internally.

But we can’t ask poor Region 1 to do more work on their own.. when these are national forests, and data should be captured and made available consistently across regions. Besides, they appear to already be doing more work than some other regions, based on the GAO reports and Derek’s observations.

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Collecting information based on what the public perceives as a need (the vacuum approach) and involving the public in how the information is developed has many advantages in terms of building trust in the information. Sometimes it seems as if some science folks and NGOs use the blower approach for information- they put out what they already have or what they think is useful which may or may not be. And perhaps don’t ground truth the data with the public.. which doesn’t increase trust.  If anything needs more trust, it would be prescribed burning and WFU, IMHO.

 

 

Surprising Flat Line: 20 Years of Unwanted Wildfire Acres (Total Acres with WFU Subtracted)

Dear TSW Readers,

This is the beginning of a new approach- DIY analysis and data interpretation.  I will present my data and findings, and you get to reanalyze them and come up with your own conclusions.

Here’s what data I asked for from the FS- I asked for WFU (Wildland Fire Use) acres by year.  The nice folks at the National Press Office sent me this handy table, which includes prescribed fire, mechanical treatments, and other. Here’s a sample:


Here’s what “other” is..”Treatment Category that describes work involving the use of chemicals, grazing, or biological methods to achieve Fire Management Plans objectives.”

So I made an Xcel spreadsheet of the WFU acres, and added the NIFC total acres for that year.

Then I subtracted the WFU from the NIFC total for each year, to get what I call “unwanted wildfire acres.” Here’s the Xcel spreadsheet. It’s altogether possible I did something wrong, so perhaps you all can check it.
Here’s what I plotted.

If the data are accurate and my spreadsheet used the correct data,  then the fitted line for unwanted fire acres (UWF) is almost straight from 2003 to 2022.  Which means that there has been little or no increase in unwanted acres burned through time.  Which is quite against what you read in the press, so check my figures!

If my data is true, here is my narrative.  Despite everything we’ve read about increased fire weather and so on, our fire suppression folks have done an amazing job at keeping the unwanted acres burned basically the same for the last 20 years.  They deserve a great big thank you from all of us.. oh and the correct policy solution is to… Pass The Tim Hart Act!!!!

I’m sure there are other interesting things that could be found in both the FS accomplishment table and the WFU/UWF  (I think UWF should be pronounced “oof”.. just kidding).  And what happened in 2016 where the WFU was almost as large as the UWF acres?

 

Forest Service wildfire management policy run amok: from suppressing fires, to confining fires, to expanding fires, to igniting fires- by Sarah Hyden

This is posted with the permission of the author, Sarah Hyden. Here is a link to the original. I thought she raised some interesting questions worthy of discussion.

 

 

 

 

Black Fire, May 16, 2022 — Photo: US Forest Service

Forest Service wildfire management policy run amok

From suppressing fires, to confining fires, to expanding fires, to igniting fires

One of the most important roles of the US Forest Service is to contain wildfires. Firefighters can often help to prevent wildfires from becoming disastrous to the human environment — they can help to protect communities, along with homeowners’ own efforts to fireproof their properties. However, Forest Service wildfire management policy can also cause the destruction of communities, and result in excessive and overly-frequent burning of some of our most valuable natural resources such as old growth, sensitive species and their habitats, and watersheds.

Conservation scientists strongly support “managed wildfire for resource benefit,” which means allowing naturally ignited wildfires to burn when safe to do so. When this is done, fire lines are built to protect communities and other values that could be impacted by the wildfire. This helps to return the natural role of fire in our forests, because fires of all intensities have a role in forest ecology and can promote biodiversity. However, there is also a limit on how much fire is beneficial to forests – too much fire can occur too fast when fires are intentionally ignited.

An increasing trend in Forest Service wildfire management tactics has been to combine intentional burning (prescribed burning) with emergency fire suppression. During at least three fires in New Mexico in just a little over a year, the Forest Service has utilized aerial and ground firing operations to expand wildfires, and to implement intentional burns on landscapes that would not have burned otherwise. These are the Black Fire in the Gila and Aldo Leopold Wildernesses, the Pass Fire in the Gila National Forest and Gila Wilderness, and the Comanche Fire in the Carson National Forest.

During the more than 325,000 acre Black Fire which ignited on May 13, 2022, it appears from ArcGIS aerial fire hot spot maps, that a very large area of the Aldo Leopold Wilderness was ignited by the USFS up to 10 miles to the south of the main fire with aerial firing operations – meaning dropping incendiary devices from helicopters or drones. See map below. This was clearly not any kind of large-scale back burn intended to contain the main fire, due to its distance from the main fire and its position relative to the wind direction.

This intentionally-ignited fire was herded to the north over several days until it joined the main fire. Then, on the Forest Service’s official fire perimeter map, both fires were suddenly joined together as one fire. There was no distinction made between the original fire which was not caused by USFS actions, and the sections of the fire to the south, amounting to a separate fire, that were directly ignited by the Forest Service. The agency had also expanded the main fire in other directions.

The intentional fire was only stopped by monsoon rains and by the intervention of a Sierra County Commissioner. Shouldn’t there have been a public analysis process before burning most of the Aldo Leopold Wilderness?

The ignitions by the Forest Service, along with the main fire, created a boxing-in formation — fire burning in almost every direction, so that which was in the midst of the formation was surrounded by fire. During wildfires, and also during traditional prescribed burns, wildlife has the opportunity to escape because the fire is generally approaching from just one direction. In a boxing-in fire formation, wildlife can become trapped and either injured or incinerated. There are no opportunities before such on-the-spot firing operations to seriously consider habitats of sensitive and endangered species, or to protect old growth forest and other values.

During the Pass Fire, which was ignited by a lightning strike on May 18, 2023, a substantial section of pinon and juniper in the Beaver Points area was intentionally burned through aerial firing operations, and many other areas were burned in ground firing operations. The ground firing operations were described by the Forest Service as burn out operations, in order to contain the fire and to protect structures. However, those burn out operations seemed very excessive, and some observers considered them to also be intentional burning.

This fire was managed as a “confine and contain” operation – an operation intended to allow a wildfire to burn within a determined fire perimeter for the purpose of reducing the intensity of future fires and to ecologically benefit the landscape. At the beginning of the fire, the Forest Service published on the Gila National Forest Facebook page a map of an approximately 75,000 acre planned fire perimeter. The current fire perimeter almost exactly matches the originally published planned perimeter. See overlay of both maps here.

The Comanche Fire, which began on June 8, 2023, was essentially a prescribed burn, except that the USFS utilized a 20 acre lightning strike ignition as the “match” that lit the fire. They stated in a fire update on June 21 that they have completed, not contained, 1% of the operation at 99 acres, making it clear that they were burning intentionally. The designated “focus area”, which appears to be a planned containment perimeter, was about 10,000 acres, broken into burn units. The intent was to expand a small lightning strike fire to at least 100 times its original size, utilizing both aerial and ground firing operations. The current size of this fire is 1,974 acres.

Such operations are now a substantial part of the work of firefighters across the West. Firefighters are essentially being used as intentional burn crews to implement fuels treatments, carried out with emergency fire suppression funding and no National Environmental Policy Act (NEPA) analysis. Some Forest Service personnel believe that we conservationists, by “holding their feet to the fire” to analyze intentional burn operations according to NEPA, are slowing down implementation of burn treatments. So, by expanding wildfires, or even starting new ones in the vicinity of wildfires, the Forest Service is able to greatly expand the implementation of burn treatments, and thereby meet agency quotas.

Any statistics or research about the extent of wildfire in recent years, in relation to climate change or presumed increases in wildfire activity, may be distorted by a substantial portion of total reported wildfire acreage being actually ignited by the Forest Service. This occurs while managing wildfires under full suppression, and in confine and control operations.

The Forest Service has put the concept of managed wildfire for resource benefit on steroids, often using wildfires as opportunities to ignite yet more fire, and to broadly burn landscapes. This is not managing wildfire, but essentially creating fires. They are now using our firefighters as agents to carry out this dangerous and possibly illegal policy that sometimes causes severe unintended consequences to forests and communities. That some burns are ultimately ecologically beneficial does not make it acceptable to carry out fuels treatments without a NEPA process.

Forest Service Chief Randy Moore’s “Wildfire letter of intent 2023” provided direction to agency staff regarding wildfire suppression, stating “We will also continue to use every tool available to reduce current and future wildfire impacts and create and maintain landscape resilience, including using natural ignitions at the right time and place in collaboration with tribes, communities, and partners.” While there is not necessarily a legal basis at this point even for this direction, Forest Service firing operations that expand wildfires cannot be considered to be using natural ignitions. Drones or helicopters dropping incendiary devices are clearly not natural ignitions. And firing operations miles from a wildfire cannot reasonably be considered back burns that are necessary to contain a wildfire.

We have no national wildfire policy that either allows, or places any limits on such operations, and emergency fire suppression funding is not allocated for implementing fuels treatments. The Forest Service has given themselves virtually a carte blanche to conduct intentional burns over a wide area nearby wildfires — all without NEPA analysis or any public involvement in the planning process.

A genuinely cohesive national wildfire policy is essential, analyzed through a comprehensive and open NEPA process. It is necessary to make sure fires are managed safely, and that values like old growth trees, wildlife and their habitat, water quality, and soils are protected. Public health in relation to the smoke generated during intentional burns must also be considered.

The purpose of NEPA is so agencies will “look before they leap,” and therefore avoid causing environmental disasters. We have had more than enough disasters occur, culminating with last year’s Hermits Peak/Calf Canyon Fire. If we allow the Forest Service to largely jettison NEPA and to freely implement fuels treatments under the guise of emergency fire suppression, we are giving up our primary means of protecting our forests and our communities, and it will affect other important conservation priorities. NEPA law acknowledges and supports our right to have a say on what occurs in our forests, and requires comprehensive analysis of the impacts of proposed actions.

The Forest Advocate is investigating USFS firing operations and will report more later. In the Forest Service Southwestern Region, a substantive FOIA request can take years to be fulfilled, so some records are difficult to obtain. The Sierra County Commission made an information request to the Forest Service to provide records of aerial ignitions during the Black Fire, but were told by the Southwestern Region that they have to put in a FOIA request through the standard process.

We need our elected representatives to urge the Forest Service to disclose the extent of all ignitions intended to expand wildfires or ignite new fires, especially during the Black Fire – and to move forward with a revised, comprehensive and clear national wildfire policy, accomplished in a transparent way, in accordance with environmental law.

ArcGis #firemappers hot spot map, south of main Black Fire (main fire in pink) May 28,2022

IMBA on Proposed BLM Regs: Flawed Process, BLM Has Not Made Case, Concerns Over Conservation Leases

 

I was alerted to this comment letter  by this Colorado Public Radio article and the headline : “What do ranchers, oil producers and bike groups have in common? They all want a say in new federal land management rules.”  Bike groups was a new one, so I decided to take a closer look.

Note: if you work for an NGO who submitted comments, please post them on your website. This makes it easier for us to hear your thoughts!

Here’s a link to the IMBA letter.  I thought they did a great job on the letter so I recommend reading the whole letter. I’ve pulled out a few sections that I think are both important, and agreed upon by many groups in the other letters I’ve read, from traditional user groups, renewables folks, the PLF and others.

IMBA Says Process is Flawed

The Proposed Rule is far too vague and undefined in its current form. If the BLM is asking general questions such as how to name new programs, what program duration and terms
should be, what areas should be eligible, what actions should be allowed, and many more questions; this indicates the BLM has not fully developed the proposed rule. What the BLM
ultimately incorporates in the final rule, after considering public comments, will be completely unknown to the public. This is an inappropriate process. This reiterates the need for the BLM to take these public comments into consideration and develop a final draft proposed rule or supplemental draft for comment. While we understand that timing is important and delay is not ideal, the BLM has stated that this is a once-in-a-generation conservation rulemaking opportunity. Therefore the BLM should ensure it gets this right. Oppositional lawsuits and legislative blocking will delay it to a greater extent and if the public does not support the outcome, that will erode public trust.

The proposed rule should have clarified the full range of actions being presented under the proposed rule so that the public can comment on them rather than answer the questions the
BLM has posed. Having the next iteration of the rule be a final rule is an improper way to handle this comment period. The public will not have the opportunity to view and provide feedback on what others may have presented and how the BLM incorporated it, which could lead to unnecessary lawsuits and a poorly considered Rule. The clarification of a supplemental Draft Rule would ensure transparency and predictability for the public and help avoid misunderstandings or misinterpretations of the framework.
Recommendation:
1. The BLM should provide the public with the next iteration of a proposed rule–a supplemental draft or final draft–which incorporates the public comment from this period.
2. We recommend the BLM err on the side of extra public involvement.

I agree with this observation and recommendation. Not only that, I think most of the Groups With Concerns, that is 1. Grazers 2. PEER 3 PLF 4 Renewables Folks and 5. Oil and gas and miners would probably agree.

IMBA Doesn’t See the Case Being Made

Here they sound surprisingly like me, except quite a bit more articulate.

Recommendation:
1. According to the Federal Register Rulemaking process, the BLM must demonstrate the need for the Rulemaking and that the Rule will garner the intended outcomes or the Rule is invalid. The Proposed Rule needs to be more clear why this rulemaking is the necessary solution and more importantly why current regulations are not sufficient in achieving this despite the “ample authority and direction”.
2. What barriers stand in the way of using the existing tools? How will the new framework proposed in the Rule resolve barrier, considering current staff and budget shortfalls.
3. Please provide greater detail on why existing tools are failing the BLM.

IMBA Has Concerns About Defining Non-Use to Be Use

We assume this to mean that the use, in this context, is intended to be a “lack of use.” We find it hard to support the inclusion of protection being considered a use but employed as a lack of use.”

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

Our recommendation:
1. Instead, the Final Rule should seek to ensure that conservation is an actionable management practice to weave throughout all management decisions via mitigation and restorative activities, and the outcome of these actions is land and important resource protection. Conservation as a use in the context of the rule should be about restoration and improvement activities that can often coexist alongside other uses as intended by FLPMA and the multiple use mandate. Effective protection is inherently less capable of coexisting with other uses. Protection relies upon lack of use.
2. Mountain biking is an appropriate use of public lands. It does not need to be allowed everywhere to achieve that, but under FLPMA’s multiple use mandate, mountain biking use can be compatible with resource conservation and intact landscapes.

IMBA Has Concerns About Leases Leading to Privatization

Is the term “conservation lease” the best term for this tool?
IMBA believes the Lease program should be renamed the “Restoration Lease” program and focus its efforts on restorative actions. Leases should not be used to prevent action or prevent use (see comments above). Leases should only be issued to entities for projects that result in direct improved conditions. Leases should not be issued to entities who plan only to protect existing conditions by preventing action/use. That is a slippery slope to privatization.