Warning: Fuzzy Concept in Regulation- “Ecological Integrity”- IV- After the “AND”

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Fortunately for everyone this will be my last post on the concept of “Ecological Integrity”as described in the NFMA Rule. Perhaps unfortunately, not my last post on the planning directives. Other guest posts on the directives are welcome. Wading through the directives was a lonely business, and thanks much to the others on this blog who suffered and shared.

So let’s return to the definition in the regulation of “ecological integrity”:

“The quality or condition of an ecosystem when its dominant ecological characteristics (for example, composition, structure, function, connectivity, and species composition and diversity) occur within the natural range of variation and can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

We have discussed the first part in previous posts, here, here and here… now let’s look at after the “and”:
“can withstand and recover from most perturbations imposed by natural environmental dynamics or human influence.”

Well, that sounds like a good idea. But what “can withstand and recover”? It appears to be the “dominant ecological characteristics” composition, structure and function, species composition and diversity”. That sounds like “everything you can possibly think of.” So everything would have to go back to being the same as it was prior to “most” perturbations. And how is that?

Natural range of variation (NRV). Spatial and temporal variation in ecosystem characteristics under historic disturbance regimes during a reference period. The reference period considered should be sufficiently long to include the full range of variation produced by dominant natural disturbance regimes, often several centuries, for such disturbances as fire and flooding and should also include short-term variation and cycles in climate. “Natural range of variation” (NRV) is a term used synonymously with historic range of variation or range of natural variation. The NRV is a tool for assessing ecological integrity, and does not necessarily constitute a management target or desired condition. The NRV can help identify key structural, functional, compositional, and connectivity characteristics, for which plan components may be important for either maintenance or restoration of such ecological conditions.

But how do we know if something (er.. everything) will “withstand and recover from “most” perturbations?” Who gets to decide what “most” is?

While I thought that the 2000 rule was a full employment program for fire ecologists and historic vegetation ecologists.. this sounds like a full employment program for lawyers and modelers, as well as the fire ecologists and historic vegetation ecologists. I wonder who was sitting around the table or on the phone when this rule was developed, and if there is some correlation between the disciplines of those folks and the disciplines advantaged by this language ;)?

If we agree that climate change is unprecedented, then with climate change, the past cannot be a predictor of the future.. so we don’t really have any information, not do we have any predictive capability other than modeling. Of course, our climate models are not particularly accurate at the scales we are interested in, and humans are constantly not doing what we assumed they would do when we ran the scenarios in the models.

But for me, all this is a distraction from dealing with real environmental problems of today (dirt in streams, invasive species) and acknowledging that time’s arrow only goes one way. Yet this rule and its directives have us spending time digging up the past (sorry, Bob) and modeling the unmodelable. We simply have no clue about the future at the detail required in this rule.

Before climate change, we used to hear a lot the paraphrase of Haldane “ecosystems are more complex than we think, they are more complex than we can think,” with the sense that we needed to preserve species. Which is fine. But if in fact they are that complex, then what are we doing depending on models over observations today in a regulation?

It’s clear that it is not really about “science”. I like to go back to Michael O’Connell’s warning of 1999 in his testimony here (my italics).

Ecosystems are more complex than we think. There are many complexities at all levels of biological organization that cannot be measured, perceived, or even conceived of, that directly affect the viability of conservation solutions. Science can never provide all the answers to questions about conservation, so the response should be to exercise both caution and prudence when designing answers. Wise solutions don’t necessarily try to compensate for factors that cannot be defined, but at the same time they leave room for them. A good example of this is true adaptive management, where the results of ongoing monitoring are used to adjust the conservation program based on new information and changes in circumstance.

Nature is full of surprises. Ecological systems are characterized by non-linear, non-equilibrium and often seemingly random dynamics. Both unexpected events and unanticipated consequences affect the long term viability of any conservation solution. This uncertainty is a given, and its runs directly counter to the political, social and economic desire for predictability in the outcome of conservation plans. It is better to be forthright in acknowledging that the issue of “no surprises” is not a scientific question of predicting the future, but instead a social question of how to deal with those surprises.
Conservation planning is interdisciplinary, but science is the foundation. Creating a long-term solution for species and the ecosystems on which they depend is a complicated exercise in reconciling social, political, legal, economic and biological factors. But if science must be one of several competing interests in the negotiation instead of the method of evaluating how to reach specified objectives, then conservation outcomes will always be undermined. This raises the critical issue of how to integrate both scientific information and scientists themselves into the planning process.

So let’s take a real world example.. say a ski area. Does having an area suitable for skiing “promote ecological integrity” ? Well, a ski area would be outside the RNV, so that’s out, so we don’t have to go to perturbation. So are we expecting that the next White River Plan revision will be litigated for having ski area suitability and thereby not promoting integrity?

So let’s move on to resilience.. say the climate is warming and drying. You want to thin some ponderosa pine trees so they have enough water to stay healthy and do some fuel reduction. A lower basal area (than in the past historical period you picked for NRV) would be better in terms of resilience to “perturbations” . But as far as the historians tell you, that is not in NRV. So the two requirements for “ecological integrity”, NRV and resilience, could actually be in conflict. (aside: picking a reference period can’t really be “scientific” so this idea of NRV seems like “science” but isn’t really). As in you can have one or the other, but not both.

My question is “are we way overthinking this?” WTH is this doing in a regulation and thereafter in the court system?

Here’s what Mike Dombeck said: just plain English and inspiring. Have we changed so much since he said this? Here’s the link, the whole thing is worth a read.

My expectation is that everything we do—every environmental impact statement we write, every timber sale, recreation plan, mining plan, or allotment management plan we approve—will not compromise the health of the land. I want to make it very clear that no Forest Service program has dominance over another. Timber is not more important than wildlife and fisheries. Nor is wildlife and fisheries more important than timber or recreation, or cultural resources, and so on.

So what happened between Mike’s term and now? Have we really changed this intention (no one is more important than the other), or are we so wrapped around the axle of fuzzy words that we can’t even tell what we mean? Are we adrift in a sea of legal hooks?

Congress Considers Sealaska Bill: An Alaska Big-Tree Old Growth Transfer to Private Corporation

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Increasingly rare volume class 7 old growth on the Tongass National Forest. Note that cedar species can be 1,000+ years old. Photo by Alaska Audubon.
Increasingly rare volume class 7 old growth on the Tongass National Forest. Note that cedar species can be 1,000+ years old. Photo by Alaska Audubon.

The following introduction was written by Greg Petrich with the Alaska Chapter, North American Bear Foundation.  After the intro is a guest column written by Don Cornelius and Jack Gustafson.  Mr. Cornelius and Mr. Gustafson are former Area Biologists with the Alaska Department of Fish and Game Habitat Division; with a combined experience of over 32 years reviewing Tongass National Forest, and private Native corporation logging issues. – mk

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Senate bill S.340 (currently pending in Senate Natural Resources Committee) would transfer premium cherry picked Tongass National Forest lands to the private for-profit Sealaska Native corporation – violating a previous settled contract with the US government to select final land claims inside non-controversial agreed upon boundaries.  A product of political influence it has become one of the most controversial issues ever to hit Southeast Alaska.

Two of the regions most respected and well known habitat professionals:  Don Cornelius, and Jack Gustafson examine this bill’s potential impact on a globally rare and threatened resource – the tiny fraction of the land that holds the massive “giant trees” of the Tongass.   – Greg Petrich, Alaska Chapter, North American Bear Foundation.

Congress Considers S.340.  An Alaska Big-Tree Old Growth Transfer to Private Corporation
By Don Cornelius and Jack Gustafson

Legislation sponsored by Senator Lisa Murkowski (R-AK) would transfer approximately 70,000 acres of public land in scattered locations across Alaska’s Tongass National Forest to the Sealaska Corporation, primarily for extensive industrial scale clearcut logging other commercial development.

The bottom line on S.340 is:
A) It is completely unnecessary; and
B) It is a very poor environmental trade off of lands and resources, and not in the public interest.
C) It sets a precedent, and an inequity, in the transfer of lands outside the public review process, potentially opening new claims by Native corporations across the state.

The proposed legislation (S. 340) would enable the Sealaska Corporation, to reopen and rewrite basic terms of Alaska Native Claims Settlement Act (1971) in order to make alternative land selections in the Tongass, including some of the region’s most valuable large-tree old growth. Under current law, the Sealaska Corporation has already made its final land selections but is now seeking legislation to renege on their original ‘requested’ deal to obtain more commercially valuable Tongass public lands.

Sealaska’s controversial proposal has attracted opposition from small towns scattered throughout the southeast Alaska panhandle region as well as a diverse assortment of sportsmen and conservation groups concerned about habitat impacts. Several of the publicly owned areas now being sought for logging by the Sealaska Corporation have exceptional ecological value identified as conservation priorities through a comprehensive Tongass-wide habitat assessment process by The Nature Conservancy and Audubon Alaska.

A letter jointly submitted about the bill from The Wildlife Society, The Teddy Roosevelt Conservation Partnership, Wildlife Forever,  Safari Club International and more than a dozen other sports groups describes the legislation as “fundamentally flawed” and asks that the bill not advance further.  Trout Unlimited also opposes the legislation for not adequately protecting high-value salmon producing watersheds that would be transferred out of the national forest to be logged by Sealaska.

The Tongass National Forest contains a significant portion of the earth’s last remaining significantly-sized tracts of this forest type. Large-tree old growth stands have always been scarce as well as long-targeted by loggers since the first days of commercial logging.  Today, they constitute a very small fraction of the overall landscape. Size class 6 and 7 combined represent 3.4% of the land area. Size class 7 alone, which include stands with up to 200,000 board feet per acre (think of trees 10-12+ feet in girth and worth a quarter million dollars per acre) today occur on just half a percent of the land base.

Past Tongass operations have been exceedingly hard on these unique and rare large-tree stands. These very special stands are far more than just visually impressive, evolved over a millennium, they constitute the richest and most valuable wildlife habitat on the Tongass.

The public lands that would be transferred to Sealaska under S. 340 include some of the region’s most biologically productive areas. The bill would enable the corporation to “high-grade” ― i.e., disproportionately target and clearcut extremely rare, big-tree old growth. Recent analysis of S. 340 shows that Sealaska is selecting large-tree old growth stands (combined volume class 6/7) at 10 times the rate they occur naturally in the Tongass (30% vs 3.4%).  [1]  Even the young-growth (previously logged) forest that Sealaska is also selecting targets the most productive lands.

The Sealaska legislation would high-grade increasingly rare, large-tree old growth and amplify this long-recognized problem. Congress explicitly identified the high-grading concern in 1990 as part of the Tongass Timber Reform Act (TTRA) and enacted an explicit ban on the practice.  [2]  An independent scientific peer review of Tongass forest management practices in 1997 further highlighted the interconnected problems of high-grading, forest fragmentation, and loss of habitat connectivity.  [3]  In its most recent testimony to Congress on S. 340 the Department of the Interior testified that if the Sealaska legislation is enacted as proposed the United States Fish and Wildlife Service may have to review its previous findings not to list the Queen Charlotte goshawk and the Alexander Archipelago wolf under the Endangered Species Act.

Because Sealaska has already made its final Settlement Act land selections under existing law and has officially filed those selections with the federal Bureau of Land Management, no further action is required by Congress for the corporation to receive its full entitlement.

S. 340 is currently pending in the Senate Committee on Energy and Natural Resources, chaired by Senator Ron Wyden (D-OR).  We would encourage you to contact the Full Committee and ask for no further action on this bill.

Mr. Cornelius and Mr. Gustafson are former Area Biologists with the Alaska Department of Fish and Game Habitat Division; with a combined experience of over 32 years reviewing Tongass National Forest, and private Native corporation logging issues.

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[1] Kirchoff, S. 340 Tongass National Forest Comparison, February 2013 (Click Here )  http://www.fileden.com/files/2012/4/8/3289499/S340_TNF_Comparison_Feb2013.xlsx
[2] H.R. 987: Tongass Timber Reform Act, Section 301(c)(2)
[3] Powell, et al., “Joint Statement of Members of the Peer Review Committee Concerning the Inadequacy of Conservation Measures for Vertebrate Species in the Tongass National Forest Land Management Plan of Record,” (September 1997).

See also: 300 Scientists letter critical of Sealaska’s highgrading large tree forest

Bitterroot National Forest logging delayed: Lumber mill has too much log inventory

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According to today’s Missoulian newspaper, the logging slated to begin on the Bass Creek project of the Bitterroot National Forest in Montana has been delayed because Pyramid Mountain Lumber Company’s log yard is too full and they have too much inventory.

An unusually dry spring will keep an extremely popular recreation site open to the public a couple of weeks longer than planned this spring.

Pyramid Mountain Lumber Co. has pushed back the start of its logging operation at the Bass Creek Recreation Area to about June 1 because its log yard is fuller than expected this time of year.

“We didn’t anticipate this very dry spring weather,” said Gordy Sanders, Pyramid Lumber’s resource manager. “Our decision to delay the start of the logging operation has to do with the overall management of our log inventory.”

The drier-than-normal spring allowed Pyramid’s loggers and contractors to bring in more timber than their mill could accommodate.

So the mill’s log yard is full.

Spotted Owls Redux, Again: The High Costs of Genetic Purity

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Here is an editorial about spotted owl economics that has been going the rounds of a number of email networks since it was published four days ago, on May 3rd:

http://www.conservativeblog.org/amyridenour/2013/5/3/the-shameful-and-painful-spotted-owl-saga-shooting-stripes-t.html

This was posted on Amy Ridenour’s National Center Blog, and was written by Teresa Platt, who is listed as the Director of the Environment and Enterprise Institute at the National Center for Public Policy Research. I’m guessing “right wing think tank,” by the title of the organization and Ridenour’s history, and note that Platt often blogs about topics regarding our nation’s natural resources:

http://www.conservativeblog.org/amyridenour/author/blogplatt

I’d never read this blog before, but apparently some of my wildlife biology, range sciences, and rancher friends do — those are the circles in which this has been making the rounds, including a personal email from Platt requesting a wider distribution.

In general, I am in agreement with Platt’s thoughts – however, I think these animals are more rightly referred to as “hoot owls” (the most common type of owl in North America), rather than “wood owls.” I’m going to stick with Wikipedia on that one, until someone explains to me why they think spotted owls have been here “since the last ice age,” whereas historical evidence indicates they may have arrived just a few decades in advance of the more common striped hoot owl.

The Shameful and Painful Spotted Owl Saga: Shooting Stripes To Save Spots

By Teresa Platt

Posted May 3, 2013 at 1:20 PM

Our federal government prefers spots and is moving forward with a million-dollar-a-year plan to remove 9,000 striped owls from 2.3% of 14 million Western acres of protected spotted owl habitat. Our government is shooting wood owls with stripes to protect those with spots; to stop the stripes from breeding with the spots.

It had to come to this.

The 1990 listing of the Northern spotted owl under the federal Endangered Species Act (ESA) gave the bird totem status in management decisions.

It didn’t work. Spotted owls declined 40% over 25 years. Timber sales on federal government-managed lands dropped too. Oregon harvests fell from 4.9 billion board feet (1988) to less than 5%, 240 million board feet (2009). Beyond the jobs and business profits from making lumber, the Federal and County governments used to benefit from these harvests too. Harvests down: tax receipts down. Today, with cutbacks in Federal budgets and sequestration, the States are arguing about how much of your tax dollars the Federal government should give them to keep impoverished County governments afloat in timber-rich areas.

Beyond competition from barred owls, and after years of not enough logging, mega-fires fueled by too many trees now threaten spotted owl survival. An exhausted veteran of the spotted owl wars, who lives dangerously close to a federally-“managed” forest that is expected to go up in smoke soon, explained:

“You have to realize that even moving a biomass project forward takes a court battle. No salvage of dead or burned timber — it just rots. Not much thinning or fuel reduction – without a two-year court fight the Forest Service usually loses. Hell, the agency is still fighting lawsuits over the Sierra Nevada Forest Plan Amendment started in ‘97 — after four revisions and several court decisions — the Greens just keep suing until they get what they want.”

Taxpayers pay for the conservation plans, recovery plans, and action plans, many stalled in court.

Taxpayers pay for all the lawsuits too, on both sides.

Taxpayers pay the salaries and pensions of government workers fighting fire and those shooting striped owls in order to give, temporarily, an advantage to ones with spots.

All this sacrifice and the spots just keep declining and the stripes just keep on coming.

The Northern spotted owl might very well be the most expensive avian sub-species on the planet.

Invasive or just mobile?

It is theorized that striped and spotted owls were once the same species of wood owl before separating into East and West Coast versions during the last Ice Age. The common striped barred wood owl (Strix varia) has expanded its range westward, establishing itself at the expense of the less aggressive, less adaptable and smaller spotted wood owl (Strix occidentalis).

By 1909, barred owls were found in Montana. They made their way to the coast, taking up residence in British Columbia (1943), Washington (1965) and Oregon (1972).

The owls, striped or spotted, are so closely related they successfully interbreed and their fertile offspring, “sparred owls,” are hybrids that look just like spotted owls. The ESA does not protect the hybrids or their offspring so the birds are breeding their way out of the ESA!

Says Susan Haig, a wildlife ecologist at the U.S. Geological Survey, is exasperated by the interbreeding:

“It’s a nasty situation. This could cause the extinction of the Northern spotted owl.”

The ESA measures and categorizes, then stands steadfast against change. It is attempting, by shotgun, to separate the birds.

Are these kissing cousins from the East invasive and unwanted when they turn up out West? Or just mobile and happy to mix it up with their spotted relatives?

Whatever, and wherever, they are, striped and spotted owls are not the only birds moving around.

111 species, almost 20% of the total bird species in North America have expanded into at least one new state or province with 14 species expanding into more states and provinces than the barred owl. Changing climates and habitats are the cause of 98% of range expansions. The birds go where the food is. 38 states or provinces have gained at least 10 new bird species, some moving into a niche inhabited by an ESA-listed avian cousin.

Beyond birds, the last Ice Age killed off the North American earthworm. It’s since been reintroduced, only to be labeled — by our government scientists — as an invasive species, an undesirable. And — oh no! — earthworms are beating millipedes in the game of survival.

The policy we embrace today for striped and spotted birds can be transferred to other birds and other animals, even earthworms. If this continues, will we be reduced to digging up and killing earthworms to save millipedes?

The ESA is written thus and lawsuits by “green” groups — many paid for by our tax dollars — are herding us in this direction.

Stripes, spots, species, subspecies and stocks

In the Kingdom of Animalia, the Phylum of Chordata, the Class of Aves, the Order of Srigiformes, are two Families of birds of prey: the typical owls (Strigidae) and the barn owls (Tytonidae).

The Strigidae Family is the larger of the two Families with close to 190 species, covering nearly all terrestrial habitats worldwide, except Antarctica. 95% are forest-dwelling; 80% are found in the tropics.

The Strigdae Family includes 11 species of the genus Strix, characterized by a conspicuous facial disk and a lack of ear tufts. They are known as screech owls, wood owls, the great gray, the chaco in South America. The Ural wood owl alone boasts 15 sub-species in Europe and Northern Asia.

Within this Strix genus, in North America, the barred wood owl is broken into three sub-species (the Northern varia, georgica in Florida and helveola in Texas), with a fourth (Strix sartorii) found in Mexico.

The spotted owl species (Strix occidentalis) is broken down into three sub-species ranging across the western parts of North America and Mexico. The “threatened” Strix occidentalis lucida of Arizona and Mexico, the California spotted owl subspecies, Strix occidentalis occidentalis, and the endangered Northern spotted owl, Strix occidentalis caurina, the sub-species of greatest concern. The Northern spotted owl ranges from California, through Oregon and Washington, and up into Canada.

You can break this down even further, if you’d like, into regional sub-stocks of sub-species. If you have the time (our government does) and the money (our taxes), you can follow family units, individuals, and all the new hybrids, the result of striped owls breeding with spotted ones.

The Wise Old Owl Asks, “Who Pays?”

This summer there will be more megafires in our overstocked Western forests, often followed by mudslides from the denuded hillsides next spring.

Another “green” group will file suit to stop another timber sale or attempt to stop government workers from shooting stripes to save spots.

Since the spotted owl wars resulted in the export of so many timber jobs, Northwest timber communities contribute far fewer tax dollars to the communal treasury, so the costs of megafires, mudslides and lawsuits will be borne by Eastern and urban taxpayers. That’s where the people—and the taxes—are.

The striped owl may be relentlessly working its way West, but its costs are steadily moving East.

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Teresa Platt is the Director of the Environment and Enterprise Institute at the National Center for Public Policy Research.

Forest Service Inflamed By Brooklyn Anti-Fracking Artist’s Smokey the Bear

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Lopi LaRoe
Lopi LaRoe

Really.. she said it was in a national park and the Voice also said it was in a national park??? Editor, where art thou, editor?

Here’s the link and below is an excerpt:

As a kid raised by environmentalists, she grew up with him, she says, and feels a particular connection to the affable, but informative cultural touchstone invented by the US Forest Service in 1944. “So I thought it was a perfect culture-jamming opportunity to take this very familiar conservationist and turn him into an anti-fracking activist,” she told the Voice.

The Forest Service, on the other hand, isn’t a fan of LaRoe’s representation of a Smokey who tries to prevent “faucet fires.” Nearly a year after LaRoe began carrying images of a newly-radicalized Smokey Bear to protests, selling t-shirts, and circulating what soon became a viral meme online, the Forest Service asked LaRoe to cease and desist.

“The feds want to frack our national parks,” LaRoe said. “It’s not surprising that they’re coming after me to try and censor my political speech.”

For nearly two years, the Forest Service has been embroiled in a debate over whether to allow hydraulic fracturing in western Virginia’s George Washington National Park.

Personally, I think the Park/Forest convolution was very poor journalism. Not just accidentally wrong, but egregiously wrong on something very easy to understand and easy to check (like from the link within the article to the GW national forest).

Which lead me to this story the cited, which has nothing to do with the Forest Service but seems to be about giving loans to poor rural people for their homes. Weird convolutions.

Synthetic biologists and conservationists open talks- Nature News

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I ran across this while doing some other work…
Here’s the link and below is an excerpt.

Sounds like a bonanza of “EIS’s we’d rather not review”! I remember some folks wanted to genetically engineer wood fungi so they would break down logs faster in the woods and reduce fuel loads quicker..I wonder if that ever got funded..

Soil saver

As an example of what the field can offer conservation, Kitney cites an undergraduate project he supervised that was presented at the 2011 International Genetically Engineered Machine competition, a kind of synthetic-biology science fair. Christopher Schoene, now at the University of Oxford, UK, and his team engineered Escherichia coli so that the bacterium would migrate into plant roots and produce the growth hormone auxin. In greenhouse tests, roots of cress plants that contained the engineered bacterium grew longer than those without, and the soil retained more water. Such a bacterium might help to combat desertification — the degradation of fertile land into desert when soil nutrients are lost.

But synthetic biology worries some observers, who fear what might happen if genes or organisms escape from their intended niches. Paul Falkowski, a geomicrobiologist at Rutgers University in New Brunswick, New Jersey, sees value in microbes that can turn carbon dioxide into fuel or make fertilizers from atmospheric nitrogen, but he worries that industrial-scale production could have drastic consequences, such as the inadvertent production of greenhouse gases.“I am rather amazed at the naivety of synthetic biologists at the way the world works,”he says.

Many attendees also expressed nervousness about the potential of synthetic biology to influence land-use patterns. Microbes that reduce greenhouse-gas levels might lessen the pressure on governments to maintain rainforests, they said. Technologies that make marginal lands more productive could turn undeveloped land into single-crop farms.

Such shifts are already beginning to occur. A project begun by Jay Keasling, a synthetic biologist at the Lawrence Berkeley National Laboratory in California, coaxed yeast to produce the antimalarial drug artemesinin at industrial levels (see Nature 494, 160–161; 2013). Much of the drug currently comes from cultivation of sweet wormwood (Artemisia annua), but Keasling believes that synthetic sources will eventually force A. annua growers in China and elsewhere to cultivate other crops. “I don’t make the decision about what gets produced,” says Keasling, whose company, Amyris in Emeryville, California, aims to produce industrial products with engineered microbes. “The marketplace decides. What I do is provide more options.”

Concerns could be mitigated by designing ways to limit the spread of synthetic microbes. Schoene’s team, for example, added a genetic safeguard to its E. coli that stops other microbes from acquiring the auxin-producing gene. “If [safeguards] are being developed with as much creativity as other technologies, that would reassure me a lot,” says Stephen Palumbi, a marine biologist at Stanford University’s Hopkins Marine Station in Pacific Grove, California.

Bill Sutherland, a conservation biologist at the University of Cambridge, agrees that his colleagues need to take synthetic biology seriously. But he says that a small poll he took at the meeting shows that the gulf between the two disciplines is not so wide. Both agree that more-efficient use of natural resources could be an important boon from synthetic biology. Both worry about the potential for synthetic organisms to harm natural ecosystems.

APHIS rulemaking on imported plants – opportunity to comment

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Before the fall: American chestnuts in the Great Smokey Mountains of North Carolina in 1910. COURTESY OF THE FOREST HISTORY SOCIETY, DURHAM, NORTH CAROLINA
Before the fall: American chestnuts in the Great Smokey Mountains of North Carolina in 1910.
COURTESY OF THE FOREST HISTORY SOCIETY, DURHAM, NORTH CAROLINA

Received this from Faith Campbell of The Nature Conservancy. This rulemaking could have more impact on our forests than a plethora of thinning projects. Not to speak of invasives meddling with “range of natural variation”.. er.. they’re definitely “natural” but not “historic”ally in the U.S. Here’s her email…

Imports of living plants have historically been one of the most important pathways by which tree-killing insects and pathogens have entered the country. Examples of pests introduced via this pathway include chestnut blight, white pine blister rust, hemlock woolly adelgid, and sudden oak death.

On April 25th, USDA Animal and Plant Health Inspection Service published a proposed regulation [https://www.federalregister.gov/articles/2013/04/25/2013-09737/restructuring-of-regulations-on-the-importation-of-plants-for-planting] that would restructure its regulations governing imports of plants. Among the several proposed changes is language in proposed Section 319.37-21 that would establish APHIS’ authority and a framework under which plant producers overseas could be required to implement “integrated pest management measures” to ensure that plants shipped to the U.S. would be pest-free. APHIS would require use of such integrated measures when the pest risk associated with those plants could be addressed only through the use of such measures.

While the specifics of any integrated pest management measures program would be developed through negotiations by APHIS with the exporting country, the proposed overall framework would have the following components:

· Production facilities would generate plants from propagative material that is free or nearly free of pests.

· Production facilities would have an approved set of standard operating procedures that include adequate pest control, regular inspection and testing, and detailed recordkeeping of all aspects of plant production, including the origin of plants that will eventually be exported so that they may be traced back if a pest is detected by the importing country.

· The phytosanitary agency of the producing country oversees the production facility and performs regular audits to ensure that all elements of the production system comply with program standards.

· APHIS may perform on-site audits of the production system. APHIS also audits imports to ensure that these plants meet the approved standards for the clean stock program.

· Penalties and remedial action in the case of noncompliance are negotiated by APHIS and the exporting country’s phytosanitary agency.

· APHIS will require plant brokers to keep records facilitating trace-back and follow specified procedures to ensure the continued phytosanitary status of plants under their control.

The deadline for comments is June 24, 2013.

I encourage you to review the proposal and submit comments. Points you might want to make:

The proposal is one of the most important actions APHIS has taken in decades to close down the plants for planting introduction pathway. The combined actions will enable APHIS to act more quickly, even pro-actively, to minimize the risk of pest introductions. The important innovations include:

o Creating the new authority to require foreign plant suppliers to implement integrated measures (as outlined briefly above);

o Integrating the proposed new strategy with the recently finalized NAPPRA strategy,[1] under which APHIS can pre-emptively prohibit the most high-risk plant imports until effective safeguards are adopted;

o Shifting most of the specific provisions out of the regulations and into the Plants for Planting Manual should allow more rapid adaptation to changed pest situations;

o Consolidating regulatory provisions that apply to all or nearly all plant imports will improve the shipping public’s understanding an compliance.

You might also suggest that additional clarity is need re: conditions for “post-entry quarantine”. The provisions in this proposal [Proposed §319.37-23] apparently apply to only a limited number of taxa for which extensive periods in post-entry quarantine are already required. In comments on past components of this rulemaking, some of us have urged expansion of post-entry quarantine to additional taxa in order to further reduce the pest risk from a wider variety of plant and pest taxa. We called at the same time for strengthening conditions of post-entry quarantine in these expanded situations in order to ensure efficacy. Our comments were inspired in part by 2001 episode in which citrus longhorned beetles – a very large insect – escaped from bonsai trees kept in “post-entry quarantine” in a commercial nursery.

Planning Rule Directives Comments- New 15 Day Comment Period

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I picked this up from the Teton Valley news here.

If you thought the 400 pages or more of directives were too daunting to review (and who didn’t, really?), you can now get pointed in a direction to check out certain parts, by the other comments in the reading room here...

I tried to check out Bill Imbergamo’s comments and it said that they were being checked for offensive content.. so you may not be able to see all of them. Or maybe it was just my computer?

I will also post on a few things on this blog, in addition to my ecological integrity posts, here here and here.

Western Caucus Field Hearing May 2

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Photo by Sharon
Photo by Sharon

I have a set of notes, which I have been unable to locate, however here is some information about the hearing I attended last week. In general, the dialogue among Coloradans was more focused on specific practices than the generalized partisan nature of some D.C. hearings. The point of the hearing, after all, was to find out what Coloradans are thinking and doing. But I will give my impressions after I find my notes.

The first panel was Gale Norton and Mike King..Mike is the Director of Natural Resources for the State of Colorado, in the Hickenlooper Administration (D). He started off by saying that that forest health and wildfire issues are beyond partisanship (or similar words).

Here’s a link to his testimony as well as others. Below is an excerpt from Mike’s testimony here.

Recovery From 2012 Wildfires

As the Committee is likely aware, Colorado had an intense fire season in 2012. It started uncharacteristically early and led to a great deal of damage. The Lower North Fork, the High Park, and the Waldo Canyon fires all occurred along the highly populated metropolitan corridor from north of Fort Collins down south to Colorado Springs. Collectively, those fires resulted in six fatalities, scorched 110,368 acres, and destroyed 744 structures.

Recovery efforts began before the fire season was over last summer, and has continued. Federal support in the form of increased funding for the Emergency Watershed Projection program was recently included in the Continuing Resolution for the FY13 federal budget, and will be instrumental in helping our local governments. Nearly $20 million is expected to come to the state as a result of this measure, and treatments will include mulching, seeding, channel stabilization, and contour tree felling. However, with so many resource values in need of attention – water quality, erosion, road corridors, revegetation – even this robust federal support is insufficient to meet the need completely.

Local governments began meeting a few months ago to coordinate their fire recovery efforts, share information about funding, and learn from each other’s experiences. As a part of those conversations, entities that have been engaged in the range of recovery activities have tracked those expenditures. To date, state and local public funds spent on recovery from the Waldo Canyon fire in Colorado Springs has totaled $10.5 million; recovery from the High Park fire in Fort Collins has totaled $9 million. Those funds don’t include the millions that were lost in private property and insurance claims. It is with
this damage in mind that Colorado has worked to elevate forest health and wildfire risk reduction to the highest policy levels.
Federal Role
Authorities
Governor Hickenlooper, in sync with other Western Governors, has identified two federal authorities that have played a key role in Colorado as we work to find a private market for forest products, enhance the health of our forests, and reduce the risk from wildfire. Those provisions are Stewardship Contracting and Good Neighbor Authority.

Stewardship Contracting allows the USFS to focus on goods (trees and other woody biomass) for services (removal of this material), and helps the agency make forest treatment projects more economical. Individuals who seek to build a business that requires a reliable supply of timber have consistently reported that long term Stewardship Contracts provide them with the security they need to secure investments. We support permanent authorization for stewardship contracting.

Good Neighbor Authority allows states, including our own Colorado State Forest Service, to perform forest treatments on national forest land when they are treating neighboring non-federal land. This landscape-scale approach is essential for achieving landscape-scale forest health. Fires don’t respect ownership boundaries. We support permanent authorization for Good Neighbor Authority.

Fire Suppression
Early response to wildfires is essential to ensure public safety, reduce costs, and minimize damage to natural resources. Western Governors have repeatedly noted their concern with the ongoing pattern whereby land management agencies exhaust the funds available for firefighting and are forced to redirect monies from other programs, including, ironically, fire mitigation work. Raiding the budgets for recreation in order to pay for fire suppression presents a significant problem in Colorado, where our outdoor recreation opportunities on public land are unparalleled. We support minimizing fire transfer within the federal land management agencies, and more fully funding existing suppression accounts.

As far as I can tell, there were no professional journalists at the hearing.If you see news stories that were generated from a journalist attending, please let me know.

Forest Service to states: Give subsidies back

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Why the Forest Service? Of all the agencies who gave all the bucks to all the other entities already, why would you pick the Forest Service bucks and States to try to get money back from? Really?

I’ve been known to be “politically impaired,” so if someone with better sensitivities would explain why it is considered a good idea to poke both red and blue governors and states with a sharp stick, please enlighten us.


Here’s an AP story..
So far I’ve seen stories where Alaska and Wyoming are not giving it back..