Hair on Fire (or Not) About Wildfires: Wild Earth Guardians Blast From the Past

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I’ve been thinking about the need to adjust “acres burned” for fire for resource benefits.  Because folks actually use the total acres in climate studies.  If suppression tactics have been changing, then that would need to be integrated into a model (it seems to me) relating weather and climate variables to acres burned. But then are all acres burned “bad”? Maybe we should decide what is meant by “bad” first, and then see if there has been a change in “bad” acres associated with anthropogenic climate change. I’m not saying AGW isn’t a factor; I’m just saying we would understand the complex interactions among fuels, weather, suppression strategies and tactics, ignitions and so on much better if we focused on problematic fires and not counts or acres.

Anyway, if we go back in time, we can see the view that fire suppression itself is a bad thing. Check out this blast from the past- only 10 years ago, a press release from Wild Earth Guardians., posted by Matthew.

As we saw a previous post, suppression folks are doing pretty well in the SW at managing for resource benefits. WEG also mentioned “breathless reporters gave statistics of ever increasing acreages of devastated forestland.” Maybe it’s not as scary as portrayed. Maybe the AGW signal is small compared to other factors. Maybe the FS and WEG are in agreement on this. Like prescribed fire, though, to have social license to manage for resource benefit the FS needs to have a good track record, preferably locally. To do that perhaps sometimes fires need lots of resources. I’m not going to second-guess playing it safe.

New Mexico experienced several expensive fires early this summer, the largest was the Silver Fire covering nearly 217 square miles in the Black Range. Fire costs in the U.S. have topped $1 billion so far this year; less than last year’s $1.9 billion, but the fire season is not over. The Thompson Ridge fire alone cost $16,326,136 before it was declared contained. Rising plumes of smoke could be seen on the horizon of Santa Fe and Albuquerque and breathless reporters gave statistics of ever increasing acreages of devastated forestland.

But, the numbers tell a different story. The four major fires in New Mexico this summer covered a total of 184,024 acres or nearly 288 square miles, but just 16% of that area burned at high severity. In all 213,289 acres have burned to date in New Mexico. While there is still a chance for late season fires, the total burned area for 2013 is significantly less than the 372,497 acres burned in 2012.

“Once the smoke cleared, the environmental benefits of the 2013 fire season were obvious,” Said Bryan Bird, Wild Places Director for WildEarth Guardians. “Though flooding is always a risk, these fires do more to clear fuels and reduce fire hazard than we could do with mechanical treatments and a large chunk of the federal budget.”

Burn Area Emergency Response (BAER) teams take action immediately after fires to analyze the area within the burn perimeter and take action to minimize immediate damage from flooding, which can have severe consequences downstream. The BAER teams measure fire severity to analyze the loss of organic matter from the forest. In areas of low fire severity ground litter is charred or consumed, but tree canopies remain mostly unburned and the top layer of soil organic matter remains unharmed. Areas of moderate severity have a higher percentage of both crown and soil organic matter consumed. Areas of high severity have lost all or most of tree canopy organic matter and soil organic matter is wholly consumed.

The numbers reported by the BAER teams for the 2013 fire season in New Mexico put into perspective the burn results. Of all acres within fire boundaries over 10,000 acres this summer, 59% (109,290 acres) were ranked as unburned or low severity. Another 24% (44,880 acres) was moderate severity. Finally, just 16% (29,125 acres) burned at high severity.

The Joroso Fire, located in the Pecos Wilderness, burned primarily in mature Spruce Fir stands with high levels of wind blown material. These conditions create an environment where high severity burns are much more likely than the other fires, so it is instructive to remove it from summary statistics. When removing this fire from the analysis the overall numbers demonstrate even less severe effects on the vegetation: 61% remained unburned or burned at low intensity, 25% burned at moderate severity, and only 13% burned at high severity.

Fire fighting in the United Sates has become a very costly endeavor. While most fires are extinguished quickly, it is the very small portion of wildfires that are not immediately controlled and result in significant financial burdens to states and the federal government. Already this year the Forest Service has exhausted its fire-fighting budget and has had to tap other budget line items. And yet, it is not clear that committing such resources is necessary or beneficial when human life and property are not immediately at risk.

“Fire is an essential process in western forests and we cannot eliminate it. Resources need to be reserved for protecting lives, not supporting huge operations in the backcountry.” Said Bird. “We can fire proof communities, but we cannot fire proof the forest.”

Current Status of the Boundary Waters Motorized Towboat Controversy

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A towboat operator tied a canoe to an overhead rack ahead of taking a camping party into the BWCA. TONY KENNEDY, STAR TRIBUNE

Ah.. Wilderness.  Based on the ongoing discussion here, I looked up the Act and at amendments.

There seems to be a 1978 amendment on the Boundary Waters that said existing motorized boat use could continue.

Then I looked up the current status and it looks like there is a court case to reduce the number of motorized towboats.

“Older visitors and visitors with limited mobility-use towboats, and an injunction would risk reducing these visitors’ opportunities to experience the BWCAW,” Brasel wrote in her 27-page decision on the injunction. “Moreover, a total ban would likely disrupt Forest Service’s work of gathering and analyzing data regarding motorboat and towboat usage.”

The judge had ordered Wilderness Watch and the U.S. Forest Service, which manages the BWCAW, to work out an agreement on towboat use before a trial is held. But the two sides so far haven’t been able to agree on how much use is too much, and Brasel said she wouldn’t make that ruling at this point.

“Because the record is completely muddled as to how such a limit should be calculated, the Court declines to pick what would be an arbitrary number,” Brasel noted. “But a limit may be appropriate upon a further‐developed record.”

To me,  it seems like the court case should start a public process in deciding how many boats and where, with NEPA and public comment.  Such  decisions, about federal lands,  would be best informed by all the experiences, views and research that can be brought to bear not a few folks in a closed room. That’s how it often works.. litigation kicks off a public process, and doesn’t replace one.

Environment Oregon Fundraising: Our oldest forests are on the chopping block

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In my Inbox this morning….

 
Environment Oregon 2023 Fiscal Year-End Drive

 

2023 Fiscal Year-End Drive

Goal: $50,000

Deadline: Midnight on June 30

 

 

Steven,

 

There’s nothing like walking through an

old-growth forest.

 

Magnificent Douglas firs, red spruces and white pines stand like giants against the sky, while ferns, shrubs, mosses and wildflowers dot the understory.

 

But right now, 20 logging projects from the Monongahela National Forest in West Virginia to the Kootenai National Forest in Montana are putting mature and old-growth trees in imminent danger.1

 

We’ve set a goal of raising $50,000 by June 30 to keep our mature and old-growth forests off the chopping block in the year ahead. Will you donate to our 2023 Fiscal Year-End Drive today?

 

Last year, President Biden ordered a first-ever inventory of America’s mature and old-growth forests on federal lands and directed federal agencies to then develop policies to protect them. But the U.S. Forest Service and the Bureau of Land Management have continued to allow timber companies to log older trees at an alarming rate.

 

Right now, logging projects are targeting more than 300,000 acres of mature and old-growth forests.2

 

We know that the longer a forest remains untouched by human development, the more that life can grow and thrive there.

 

But these old-growth forests aren’t just irreplaceable habitat for countless animal species (though they are). They’re also our best allies in the fight against climate change — allies we lose the minute we cut them down.

 

The older a tree is, the better it is at storing carbon. Nearly 70% of all carbon stored in trees is absorbed in the second half of their lives.3

 

We simply can’t afford to chop down our oldest trees. But if we don’t act quickly, we could soon hear the chainsaws and see our beloved forests reduced to stumps.

 

Donate to our 2023 Fiscal Year-End Drive to be a guardian for our oldest trees in the year ahead.

 

We won’t let these forests be chopped down. Here’s what we’re doing to keep trees standing for generations to come:

 

  • We’re asking the Biden administration to put mature and old-growth forests on federal lands off-limits to logging. Our national network has already generated more than 40,000 public comments and are continuing to raise the voices of community members, scientists and activists around the country to tell the U.S. Forest Service to defend these trees.
  • We’re urging Congress to pass the Roadless Area Conservation Act, which would keep our forests intact — permanently. This bill will safeguard millions of acres of America’s national forests, permanently protecting roadless areas from logging and road-building by strengthening the 2001 Roadless Rule.
  • We’re also working to protect the North American boreal forest from logging. Our supporters and advocates are calling on major companies — including Procter & Gamble, The Home Depot, Amazon and Costco — to not use wood from the boreal for their products.

 

Environment Oregon and our national network have a long history of defending our forests. We helped deliver landmark protections for 60 million acres of roadless areas in national forests, and we helped restore these roadless protections to all 9.2 million acres of Alaska’s Tongass National Forest earlier this year.

 

Now, we’re sending a strong message to the Biden administration to let our oldest trees grow. And we’re just getting started. With your help, we can protect mature and old-growth forests in the year ahead.

 

Will you stand with us as we stand up for our oldest trees?

 

Thank you,

 

Celeste Meiffren-Swango
Director

1. Ellen Montgomery, “Threatened Forests,” Environment America, May 19, 2023.
2. Ellen Montgomery, “Threatened Forests,” Environment America, May 19, 2023.
3. Torah Kachur, “As trees age, their climate benefit grows,” CBC News, August 18, 2017.

 

 

Your donation will be used to support all of our campaigns to protect the environment, from saving the bees and protecting public lands, to standing up for clean water and fighting climate change. None of our work would be possible without supporters like you.

 

Environment Oregon, Inc.
1536 SE 11th Ave., Suite B, Portland, OR 97214, (503) 231-1986
Member questions or requests call 1-800-401-6511.
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Forest Service denies pleas to chainsaw logjams in Pasayten Wilderness

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By Rich Landers For The Spokesman-Review

Backlogs of maintenance and routes littered with massive numbers of toppled trees have dramatically decreased trails available for exploring the Pasayten Wilderness in Washington.

Some horsemen say equally impenetrable barriers of bureaucracy are keeping the U.S. Forest Service from addressing the need for emergency use of chainsaws.

They say a one- or two-season blitz with restricted tools would help wilderness managers catch up to the ravages of wildfires.

Trails aren’t just becoming inaccessible, the horsemen say. They’re being lost, maybe forever.

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Some Info from the NICC Wildland Fire Summary and Statistics Annual Report 2022

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Here’s the 2022 NICC Wildland Fire Summary and Statistics Annual Report.
If you want to look at their tables, it helps to know their abbreviations.. so here’s a map.

This one raises some questions about more starts and average acres, maybe to be answered later.

It looks like annual wildfire acres burned is not necessarily jumping up from year to year. Also, 2022 had above average number of fires and below average acres, which might be due to the fire suppression folks doing good work. There may be elements of weather and resource “good luck,” as well. As far as I know, all these acres include WFU acres.

Since each region is different, this one shows more (above average count) of wildfires in the Southeast, and more acres burned in Alaska.

Later in the report is a great deal of information on the management of fires and resources that might be of interest to other TSW readers.

Carbon Capture on National Forests?

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Proposed rule:

“To support responsible deployment of Carbon Capture, Utilization, and Sequestration (CCUS), the Forest Service is proposing an amendment to its regulations at 36 CFR 251.54 — Proposal and Application Requirements and Procedures to allow exclusive or perpetual right of use or occupancy (36 CFR 251.54(e)(1)(iv)) of National Forest System (NFS) lands for CCUS. This proposed rulemaking would amend initial screen criteria in existing regulations to allow for permanent carbon dioxide sequestration on NFS lands to support CCUS-related activities and will help meet the Administration’s priority of tackling the climate crisis.”

From an EnergyWire ($) article:

John Winn, a Forest Service spokesperson, emphasized in an email that the proposal “does not authorize the use” of carbon capture, use and storage (CCUS) on Forest Service lands. It just opens the door to consideration; any storage proposals would still have to go through environmental review and public scoping.

To Intervene, or Not to Intervene? The Case of Isle Royale, Wolves and Moose

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A pack of wolves after they killed a moose at Michigan’s Isle Royale National Park. (January 24, 2023) AP Photo/Rolf Peterson, Michigan Technological University.

AP had an interesting story about the reintroduction of wolves on Isle Royale, a National Park that is an island. Wolves apparently had only been there since the 1940’s. Even in Wilderness, there are disagreements about when intervention should occur and to what end.

Scientists believe the island’s first moose swam to Isle Royale around the turn of the 20th century. Wolves arrived in the late 1940s, apparently crossing the frozen lake surface from Minnesota or the Canadian province of Ontario. Though technically part of Michigan, that state’s shores are farther away.

Moose provided an ample food supply for the wolves, which in turn helped keep moose numbers in check. Both populations rose and fell over the years, influenced by disease, weather, parasites and other factors. But inbreeding finally took its toll on the wolves, whose numbers plummeted between 2011 and 2018.

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The scientists’ annual report, based largely on aerial observations last winter, estimated the rebuilt population at 31 wolves— up from 28 last year. It said the wolves appeared to be forming three packs, with others wandering alone or in smaller groups. The moose total was roughly 967, down from 1,346 last year and 54% decline from about 2,000 in 2019. Ecologists are celebrating what they hope will be a healthier herd.

“It’s been hugely successful,” said study co-leader Sarah Hoy, a research assistant professor and animal ecologist. “That’s what everyone was hoping for.”

But the early results haven’t settled a debate over whether people should rescue struggling species at Isle Royale or other designated wilderness areas, where federal law calls for letting nature take its course.

“We have felt and still believe that the National Park Service should not have intervened and set up this artificial population of wolves,” said Kevin Proescholdt, conservation director for the advocacy group Wilderness Watch.

Some experts said they should be allowed to die out, as have other species that once occupied the island, including Canada lynx and woodland caribou, which had the same predator-prey relationship as today’s wolves and moose.

“Species come and species go,” Proescholdt said, arguing that the federal Wilderness Act “directs us to let nature call the shots and not impose our human desires.”

Park officials and Michigan Tech scientists contend the absence of a top-of-the-food-chain predator of moose and beaver would have been ruinous for the island’s forest. Even now, its balsam firs continue to deteriorate from moose browsing and an attack of tree-killing spruce budworm, the report said.

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The moose population’s 28% drop from 2022 is one of the biggest one-year collapses ever seen at the park, it said. While wolf predation is partly responsible, necropsies indicate the biggest cause was starvation from overpopulation.

Even though relatively few moose calves appear to be surviving to adulthood, there’s no reason to worry about the moose’s immediate future, Michigan Tech biologist Rolf Peterson said. They’ve fallen to 400-500 before and bounced back. But the warming climate, tick infestations and other long-term challenges will remain.

For now, the park’s ecosystem is getting healthier thanks to the wolves’ return, he said, suggesting the decision to intervene was correct.

“The old hands-off approach to managing national parks, figuring everything will turn out OK, is probably not sufficient,” Peterson said. “Our footprint is all over the entire globe.”

If hands-off is not sufficient for National Parks, then, why would we think it is for Forest Service or BLM? Or perhaps it’s not a question of hands-offness so much as who gets to decide when to be hands-on and for what reasons.

Not All Acres Burned Are Bad Nor Due to Climate Change- White House Factsheet Misses Region 3 WFU Successes

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Wooden Corral sustains no damage from the Pass Fire
Firefighters strategically used fire to reduce the existing fuel load as the Pass Fire approached the area, which saved the wooden corral structure.

So, wildfires used to be bad. Enter Smokey Bear.  But we wised up and discovered that we need to live with fire, and if we don’t want to have destructive wildfires, we need to manage fuels on landscapes including using prescribed fire and wildland fire use (see photo above). But as far as I can tell, if we’re not careful, we mix up WFU acres with “true” wildfire acres, and then use the total in statements about wildfires and climate.  And if we do, we’re back where we started, assuming all wildfires are bad. Let’s not do that.

Or we could use numbers of wildfires like the EPA..

 

Is number of wildfires an indicator of climate change? Seems like before you made that claim you would have to separate human ignitions from lightning..

We hear that (1) wildfires are caused by (anthropogenic contributions to) climate change.  And yet we know that not to be true, in a plain English sense of causality, as wildfires have long predated humans.  If we pushed back, we might hear (2) “wildfires are made more likely due several factors, one being an increased frequency in some weather conditions conducive to wildfires and those that make firefighting more difficult, some or all of which is due to anthropogenic climate change (AGW).” So how does 2, which I think most of us agree on, mutate into 1? Sloppy public affairs folks?

Here’s what the White House said on June 8

More than 100 million Americans are under Air Quality Index Alerts due to smoke drift from historic wildfire activity throughout Canada, which is facing one of its worst wildfire seasons on record.  There are over 425 active wildfires in Canada and nearly 10 million acres have burned, 17 times the 20-year average.  Since January 1, 2023, 19,574 wildfires have burned 616,486 acres across the United States.  Most current large fire activity in the United States is concentrated in the Southwest.

These latest events are another stark reminder of how the climate crisis is disrupting communities across the country. That’s why from day one President Biden recognized climate change as one of the four crises facing our nation, and why he made historic investments to tackle the climate crisis and strengthen community resilience.

So I suppose you can pivot from the Canadian fires to climate change but the US story is not exactly pivotable.    And here’s what NIFC said on June 22, 2023 about the US.

Since January 1, 22,052 wildfires have burned 636,031 acres across the United States. These numbers are below the 10-year average of 25,006 wildfires and 1,478,575 acres burned.(my bold)

But to further complicate things, some of these fires here (and in Canada) are being managed for resource benefits.. or whatever the current terminology is.. (thanks to the Hotshot Wakeup for info on the Pass Fire) so more acres (without destroying things of ecological or human value) are actually a good thing. That’s what our folks have trained for, and what we all want done. As far as I know.

The largest fire is the Pass Fire in NM that shows 55, 683 acres as of today.

The overall strategy on the Pass Fire is to allow the low to moderate intensity of the fire to play its natural role on the landscape as firefighters take appropriate actions to keep the fire within the designated planned boundaries while protecting private land, infrastructure, and natural resources. The Gila National Forest is a fire-adapted ecosystem. It is dependent on fire to play a natural role in restoring the landscape to more natural conditions while preventing the occurrence of extreme fires in the future.

So for this fire, the largest one currently on the board, lots of acres are a good thing, attributed to good management and possibly to some good luck with weather conditions.

NIFC on the 22nd had this one, the Pulp Road fire, at 15,642, I think it’s at 16K or more now.
This fire was an escaped prescribed fire by the North Carolina Forest Service. Escapes tend to be caused by other things than AGW, but perhaps AGW could play a role.. we’ll have to see what the investigation discovers. Anyway, for this one acreage over the target is a bad thing, but dubiously attributed to climate change.

The next largest is the 10,279 Wilbur Fire on the Coconino

The Wilbur Fire is being managed with multiple strategies to meet suppression and resource objectives. Those objectives include the release of nutrients back into the soil and the reduction of hazardous fuel accumulations. Objectives also include protecting critical infrastructure, watersheds, wildlife habitat and culturally sensitive areas from future catastrophic wildfires.

Again, more acres here are good.  I wonder if there’s a place where WFU acres are tracked separately from total acres, or how difficult that is to do. Wouldn’t it be great if we had a table that included:

Prescribed fire acres

Wildfire Use Acres

Unintentional Wildfire Acres

The sum of the above two (WUA plus UWA)  would be the total wildfire acres.

Then the Unintentional Wildfire Acres (or True Wildfire Acres) could be broken down by

Lightning

Human  with subcategories that included:

Escaped prescribed fires

Escaped WFU fires.

Arson

Accidents by individuals

Equipment (powerlines etc.)

Or maybe that table already exists somewhere?

For now, it’s June, the season’s off to a slow start here in the US, and let’s celebrate the folks who are successfully using managed wildfire!

Court vacates Colville NF project and parts of its revised forest plan

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This was going to be a “featured” case in a litigation summary post, but it turned out to be long enough for its own post.  Besides, forest plan litigation is rare, especially Forest Service losses, and this case covers a number of NFMA and NEPA issues that are frequent topics on this blog.  (And, full disclosure, I had something to do with it.)

  • Court decision in Kettle Range Conservation Group v. U. S. Forest Service (E.D. Wash):  Sanpoil clean

On the first day of summer, the district court vacated the decision for the Sanpoil Project on the Colville National Forest, and also vacated the relevant portions of the 2019 revised forest plan.  The portions of the revised plan at issue replaced the Eastside Screens 21-inch diameter limit with a guideline to protect large trees, but included many exceptions.  It also did not designate a minimum amount of old growth habitat to retain.

The court held that, “the agency failed to explain how the 2019 Forest Plan maintains the viability of old-growth-dependent species.”  More specifically, “the agency erred by failing to demonstrate that its data and methodology reliably and accurately supported its conclusions about the viability of old-growth dependent species under each planning alternative, and depicted the amount and quality of habitat.”  (Note that the Colville plan was revised under the 1982 planning regulations, which had somewhat different language describing wildlife viability.  However, this court did not rule on substantive compliance with the NFMA requirement, but rather found a failure to demonstrate compliance due to an inadequate administrative record based on the APA.)

The Forest stated that the selected alternative, Alternative P, provided a “high” viability outcome for these species and that the no-action alternative would not improve viability outcomes.  However, in the EIS, the data showed that “the No Action alternative provides more habitat than the selected alternative for three of the surrogate species,” and “creates the most late structure of any alternative.”  The Forest relied instead on an appendix in an associated Wildlife Report that employed a Bayesian belief model to assign letter grades to viability, which supported the rationale for selecting Alternative P.  The court explained:

Neither the EIS nor the Wildlife Report describe how the agency came to these scores for each species and action alternative. The agency did not define its methodology for assessing the letter grades, such as what factors it considered and the weight they were given. The grades assigned to each planning alternative lack explanation…  the agency acted arbitrarily and capriciously when it offered explanations that ran counter to the evidence before the agency and failed to satisfy the requirements of the NFMA.

The court also found that the Forest failed to discuss the amount and quality of habitat and population trends (a requirement of the 1982 regulations).

The court also held that the forest plan EIS violated NEPA by failing to meaningfully address the original Eastside Screens Report.  The Forest simply argued that it needed more flexibility to achieve the desired conditions, including avoiding numerous site-specific amendments to deviate from the diameter limit in the Eastside Screens.  The Forest failed to include the original Eastside Screens Report in its administrative record, and did not adequately respond to public comments about the Eastside Screens.  The court stated:

Its absence demonstrates that the agency failed consider the scientific rationale for adopting the 21-inch rule before deciding to discard it. The agency did not respond to viewpoints that directly challenged the scientific basis upon which the final EIS rests…  In doing so, the agency violated the NEPA. The absence of the Eastside Screens Report also demonstrates that the agency did not consider an important aspect of the issue, as required by the APA.

… the agency did not consider negative impacts, if any, from (1) elimination of the 21-inch rule or (2) retention of the exceptions in the new guideline. The NEPA requires the agency to discuss and not improperly minimize negative effects of a proposed action…  In this case, the EIS did not assess how often the new guideline’s exceptions will be invoked and how the exceptions may impact the agency’s conclusions about the environmental effects and species viability.”

The Sanpoil Project also violated NEPA.  The EA simply assumed that the new forest plan guideline would protect old-growth trees.  The court held:

This conclusion was contrary to the evidence. The Sanpoil Project EA did not specify the frequency of which the new guideline’s exceptions would be invoked, despite the 2019 Forest Plan’s stated objective of preserving old-growth trees. The agency is not required to catalogue specific trees that will be removed, but in this case, the agency was required to provide site-specific details at the project planning stage to provide a sufficient picture of the Sanpoil Project’s cumulative effects… Without sufficiently specific information about site impacts, the Sanpoil Project’s impact to old-growth trees and their dependent species is speculative.”

(This overlaps to some degree the issues surrounding “condition-based NEPA.”  The court even cites the Forest Service Handbook: “If the Agency does not know where or when an activity will occur or if it will occur at all[,] then the effects of that action cannot be meaningfully evaluated.”  It also is difficult to demonstrate consistency with the forest plan if the project documentation does not provide information about how a project is meeting forest plan requirements.)

The project also violated NEPA and NFMA by conducting “cursory analysis” of the effects of the project on gray wolves, wolverine, sensitive bat species, northern goshawk, and the western bumblebee.  Finally, the court found that NEPA requires an EIS for the Sanpoil Project because it “creates uncertain risks to old-growth forests and the wildlife dependent on them, and “sets a precedent for future actions that utilize the new old-growth guideline, each of which may be individually insignificant, but create a cumulatively significant impact when applying the new guideline.”  Moreover, the lack of quantified or detailed information about the Sanpoil Project’s impacts in this respect “is also highly controversial due to the same questions about its size and nature and effect of the action on old-growth dependent species.”

The court found that this “case” was ripe for judicial review “when the agency issued RODs for both agency actions” “because the Sanpoil Project is a site-specific action governed by the 2019 Forest Plan.”  The plaintiff had argued that forest plan decision challenge was ripe because it dealt with a forest-wide viability requirement rather than timber sale requirements found not ripe by the Supreme Court in its Ohio Forestry decision.  However, the plaintiff also argued that ripeness of forest plan issues could be based on this project decision implementing the plan.  It is not completely clear which rationale the court is employing.  The court also found that the plaintiff had exhausted administrative remedies by identifying large, old trees, wildlife viability and the Eastside Screens “thoroughly and consistently during the public comment process.”