Standards in Planning

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The question of standards in forest planning has emerged as a central issue in the proposed NFMA regulations.  It seems that a common narrative by the press in covering the story thus far is the amount of discretion afforded in the proposed rule versus its lack of “musts and shalls.”

Here is the definition of standards in the proposed regulations: “A standard is a mandatory constraint on project and activity decisionmaking, established to help achieve or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements.” (76 Fed. Reg. 8517).

I have made my pro-standards case in various places, hitting on the usual theme of accountability, while others like Professor Mark Squillace have thoughtfully criticized their use at the forest plan level.  I hear similar complaints about standards from others participating in the draft regulations as well. 

This is an important debate.  But my sense is that we might not all be that clear about the variety of ways in which standards are used in planning.  Maybe we all have different conceptions based on our interactions with forest planning in various parts of the country.  So before making an argument for standards, allow me to first explain what I mean by the term.

Types of Standards Used in Forest Planning 

Different types of standards are used in forest planning.  They can differ in scale, specificity, and complexity.  Some administrative regions of the USFS, for example, use standards cutting across multiple National Forests (this being very relevant to Melissa’s point about standards and scale–many of us agreeing that some standards might best be applied at larger spatial scales).

National Forest plans have also used forest-wide standards that vary in detail and complexity.  Take, for example, the forest-wide range standard in the 1986 Lolo National Forest Plan:

Conflicts between livestock and big game will be resolved so big game are allocated the forage required to meet their needs.  Domestic livestock will be allowed to utilize any forage surplus not conflicting with the planned expansion of big-game populations.  Reductions in livestock numbers will be avoided if possible, but will be acceptable to meet management goals. (II.9). 

To me, this seems more like a nudge than a clear unequivocal standard, but it still provides some direction. 

Forest-wide standards can also be more complicated, such as the Lolo’s forest-wide “snag standard.” This standard requires sufficient snags and dead material to be provided in order to maintain 80 percent of the population of snag-using species.  More detailed prescriptions are provided in this forest-wide standard, such as specifying the number of big snags needed per acre on different forest types on the Lolo.  (I get the sense that critics of standards are thinking about this sort of example). 

Standards are also used for particular management areas or zones as identified in a forest plan.  These sorts of standards can be very straightforward and basically state what is allowed to happen in a particular area. They specify allowed uses, prohibitions, and constraints.  The Lolo Plan, for example, divides the forest into 28 management areas, each with a different set of standards.  Consider the following examples:

Standards used for a municipal watershed area state that “livestock grazing permits will not be issued” and that “chemical herbicides and pesticides will not be used within the Ashley Creek Watershed.” 

A management area including significant historical, archeological, paleontological, and cultural sites uses a timber standard stating that “timber removal will be limited to that necessary to enhance historic values and provide for public safety” and that “timber removal will be under administrative use rather than commercial sale authority.”

A management area consisting of large roadless blocks of land contains standards that disallow most types of motorized access, the construction of developed recreation facilities, and commercial logging. 

These are straightforward, meaningful standards playing an important role in forest planning.  They are not hyper-complex nor do they require super-human analytical abilities to write and implement them.  Nor is there any evidence, that I’m aware of at least, showing that the writing of such standards is what bogs down the forest planning process. 

Why Standards?

The use of standards in a forest plan should be required under the NFMA regulations for several reasons.  We have discussed a few of these already on the blog, often in the context of what is required by NFMA and the importance of accountability.  I’d like to discuss a few issues that have not received as much attention but are very relevant to the proposed rule:

1.  Standards help differentiate one management (planning/zone) area from another.  The above example from the Lolo demonstrates the important relationship between standards and the designation of management areas/zones.  The former gives meaning to the latter.  Why would the Lolo National Forest designate a management area if that area had no different allowed uses or prohibitions than some other area? Or why would the proposed rule require the identification of priority watersheds for maintenance or restoration if those areas had no meaningful prohibitions?  If the agency is going to draw lines on a map, then those lines should mean something. 

2.  Standards facilitate the effective use of adaptive management—one of the principles of the proposed rule.  Standards help define the purpose and boundaries of adaptive management and planning.  After all, adaptive management is a means to an end, and that end needs to be clearly articulated.  Without standards, adaptive management is too susceptible to political exploitation and the dodging of tough political choices. 

A commonalty found in most adaptive management literature is the need for a structured decision making process and the identification of clear and measurable management objectives.  The Interior Department’s Technical Guide (as discussed at the Science Panel) emphasizes both as crucial to the success of adaptive management:

If the objectives are not clear and measurable, the adaptive framework is undermined…Objectives need to be measurable for two purposes: first, so progress toward their achievement can be assessed; second, so performance that deviates from objectives may trigger a change in management direction.  Explicit articulation of measurable objectives helps to separate adaptive management from trial and error, because the exploration of management options over time is directed and justified by the use of objectives.  U.S. Department of the Interior, Adaptive Management: The U.S. Department of the Interior Technical Guide (2009), at 11. 

Standards can be used to help define these objectives while providing a relevant metric in determining their achievement.  More basic is the fact that adaptive management projects will take place in particular management areas of a National Forest, as identified in a forest plan, and these zones/standards will guide the questions and purpose of any adaptive management project. 

3. Standards can help the USFS, and other federal agencies, meet the goals and mandates of other environmental laws. There are important interconnections between NFMA and other laws like NEPA and the ESA and CWA.  NFMA regulations should thus be considered as part of a larger regulatory framework.  And these environmental laws and regulations should be viewed as goals, not constraints. 

Consider, for example, the role standards play vis-à-vis the ESA.  The proposed planning regulations properly emphasize the agency’s obligation to conserve endangered and threatened species.  The proposed rule “would require the responsible official to explicitly recognize the recovery of T&E species as an important part of land management plans…” (76 Fed. Reg. 8494). 

Standards can play an important role in this regard.  Consider, for example, the unsuccessful delisting of grizzly bears in the Greater Yellowstone region.  At issue in this case was the Grizzly Bear’s Conservation Strategy, which included the amending of multiple national forest plans.  The Court found the Conservation Strategy short of being an “adequate regulatory mechanism,” as required by the ESA, partly because the forest plan amendments included few meaningful standards and too many discretionary and unenforceable guidelines.  Cases like these demonstrate how meaningful standards can help the USFS meet all of its legal obligations, not just NFMA.(see Greater Yellowstone Coalition v. Servheen, 672 F. Supp. 2d. 1105, (D. Mont. 2009).

Time for a Bold Statement?

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It’s starting to look like “A New Century of Forest Planning” may ultimately come to refer to the hundred years or so it takes to get a new planning rule implemented. Will the “Hundred Years War” come to signify the length of the timber wars?

Way back in the 1900’s, Chief Dale Robertson was convinced that a bold policy statement was necessary to address the big concern of the day– clearcutting of national forests.  In a policy letter (not the best way to make policy, but a lot quicker than rule-making), Dale established that clearcuttting would no longer be the primary means of regeneration on national forest lands. There were howls of protest from silviculturists and tree-improvement specialists. There were exceptions for species like Jack Pine and Sand Pine.   There certainly was no end to the timber wars, but it was a start down a path towards armistice.

Getting a new planning rule implemented will take more than just agreement about the wording of the rule.  It’s going to require an environment that will insure the intent of that wording can be carried out. Perhaps now is an appropriate time for the current Chief to make some bold statements.

My suggestions are:

1.       Declare that restoration of ecosystem resiliency is not just an important part of the mission; it’s the most important part.

Management actions would be all about producing desired ecological conditions in order to restore and maintain resilient ecosystems and help protect human communities from undesirable things like intense wildfires in the wrong places or downstream impacts from deteriorating road systems.  There would be no need to calculate ASQ or argue about “lands unsuitable for timber production”. (There may still be a need to “zone” for other uses.) “Below-cost” timber sales would no longer be a meaningful calculation.  And, if the South is any indication, a lot more timber would become available for local mills.

2.       Declare that planning at all levels will be a truly open and collaborative process.

All phases of planning would be “open source” with draft documents and supporting information easily accessible on-line.  Raw data from inventories and monitoring as well as interpreted data, maps, and models would be open to all. I can’t think of any other policy change that would do more to improve the level of trust among stakeholders.  A side benefit would be a tremendous savings in responding to FOIA requests.

3.       Declare that the Forest Service will commit to a process of establishing a shared vision for the entire agency.

With the National Forest System, Research, and State and Private Forestry all working towards shared goals, using an “all lands” approach, imagine what might be accomplished at landscape scales?  This is the sort of partnership between managers and scientists that will be needed to truly ensure that “best science” is incorporated into decisions at all levels.

Are these declarations really all that bold?  Not really, The Forest Service has been moving in these directions since before Dale Robertson penned his letter.  A clear commitment to these principles might be what’s needed to finally move the National Forest System into the New Century.

Spotted Owl Fallout?

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Last week, after attending the NFMA roundtable in DC, my 12-year-old daughter McKenzie and I had dinner with Dan Sarewitz, his wife Erica Rosenberg and their 10-year-old son Jonah. Erica and I have known each other since her tenure on the House Natural Resources Committee staff where she helped shepherd the first iteration of Secure Rural Schools through Congress. Jonah and I have played ping pong a couple of times — he’ll be really good some day!

Although I have read several of Dan’s writings on science policy, this was our first meeting (actually, we met the day before dinner on Connecticut Avenue as McKenzie and I walked to the metro after visiting the national zoo — small world, indeed).

Dan asked me a question that has defied easy analysis for twenty years. Did winning the spotted owl lawsuits do more harm than good? I invite your thoughts. I’ll save mine for the next post.

Ecosystem Diversity Requirements: The Challenge of Maintaining Everything

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The above chart is from the Convention on Biological Diversity website here.

My question: do we really understand what requiring maintenance and restoration of ecosystem diversity means under 219.9 ? At least we have some idea of what vertebrate species are or aren’t (except for them crossing with each other, but at least that is something concrete and observable (genetically, at least)).

From the proposed rule:

(a) Ecosystem Diversity. The plan must include plan components to maintain or restore the structure, function, composition, and connectivity of healthy and resilient terrestrial and aquatic ecosystems and watersheds in the plan area, consistent with § 219.8(a),
to maintain the diversity of native species.

I had a definition of ecosystem composition in my head, but here are a couple from the internet.. I italicized the composition-relevant parts. Caveat: I did not independently track these to their origins, but simply copied from this site.

# Edward Grumbine, “Ghost Bears: Exploring the Biodiversity Crisis,” 1993:

“There is much more to biodiversity than the numbers of species and kinds of ecosystems. Ecologist Jerry Franklin portrays ecosystems as having three primary attributes: composition, structure, and function.

Ecosystem components are the inhabiting species in all their variety and richness. Many different species, gene-pool abundance, and unique populations are what most people think of when they hear the term “biodiversity”. But there is much more to consider.

Ecosystem structure refers to the physical patterns of life forms from the individual physiognomy of a thick-barked Douglas-fir to the vertical layers of vegetation from delicate herbs to tree canopies within a single forest stand. An ecosystem dominated by old, tall trees has a different structure than one comprised of short, quaking aspen. And there is more structure in a multilayered forest (herbs, shrubs, young trees, canopy trees) than in a single sagebrush grassland, prairie, or salt marsh…

Ecosystem functions are hard to see in action. “You can’t hug a biogeochemical cycle,” says one ecologist. But without the part of the carbon cycle where small invertebrates, fungi, and microorganisms work to break down wood fiber, the downed logs in an ancient forest would never decay. Natural disturbances also play a role. Wildfires release nutrients to the soil, weed out weak trees, and reset the successional clock. The energy of falling water creates spawning beds for salmon even while it carves a mountain’s bones. Plants breathe oxygen into the atmosphere. Ecological processes create landscapes and diverse environmental conditions out of life itself.

Ecosystem components, structures, and functions are all interdependent. To understand biodiversity, one has to think like a mountain and consider not only the biotic elements of plants, animals, and other living beings, but also the patterns and processes that shape volcanoes and forests.”

# Reed Noss, “Indicators for Monitoring Biodiversity: A Hierarchical Approach,” Conservation Biology 4(4):355-364. 1990:

“Biodiversity is not simply the number of genes, species, ecosystems, or any other group of things in a defined area…A definition of biodiversity that is altogether simple, comprehensive, and fully operational (i.e. responsive to real- life management and regulatory questions) is unlikely to be found. More useful than a definition, perhaps, would be a characterization of biodiversity that identifies the major components at several levels of organization.

…(C)omposition, structure, and function…determine, and in fact constitute, the biodiversity of an area. Composition has to do with the identity and variety of elements in a collection, and includes species lists and measures of species diversity and genetic diversity. Structure is the physical organization or pattern of a system, from habitat complexity as measured within communities to the pattern of patches and other elements at a landscape scale. Function involves ecological and evolutionary processes, including gene flow, disturbances, and nutrient cycling.”

It’s pretty clear from the preamble that species are not included in the ecosystem definition in the proposed rule, although the usage of the term generally of “ecosystem composition” may include species as one of the components.

Here’s the preamble, which is very clear.

Ecosystems are described in terms of their composition (vegetation types, rare
communities, aquatic systems, riparian systems); structure (vertical and
horizontal distribution of vegetation, stream habitat complexity, and riparian
habitat elements); function (processes such as stream flows, nutrient cycling,
and disturbance regimes); and the connection of habitats (for breeding,
feeding, or movement of wildlife and fish within species home ranges or
migration areas). Healthy ecosystems are indicated by the degree of ecological
integrity related to the completeness or wholeness of their composition,
structure, function, and connectivity.

Nevertheless, I have to wonder if we have moved from an interest in the concrete vertebrates to being responsible for aspects of the ecosystem we don’t even know, understand, and possibly can’t measure. Will we have case law around maintenance of nutrient cycling? Disturbance regimes? How are we supposed to maintain or restore them if they are changed through climate change? This section bristles with a variety of potential legal hooks and complex analytical and monitoring requirements.

Stop Killing Messengers

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There is really little chance that we will, anytime soon, stop “killing the messenger” in the natural resources arena. But we might do it first in another important arena: banking and finance. Later, perhaps the many sad tales of public lands whistleblowers losing all trying to stand up for truth and justice will finally come to an end. Or maybe I was just dreaming today, at Economic Dreams-Nightmares in Stop Killing Messengers: Banking and Finance Edition.

Killing the messenger has been around for a very long time. In our day, we mostly don’t shoot them (at least not in so-called “civilized countries”), but “it is still worth a man’s neck to disturb an emperor’s image. Nowadays the axe falls more subtly and the execution may be postponed, but sooner or later it comes.” (citation in Wiki link above.)

Why not reward whistleblowers instead? If we were to reward whistleblowers, rather than killing them—figuratively, if not literally—we would have to reward them handsomely. Why? Because in most cases whistle blowing is a career-ending if not a job-ending move. Over at Macroeconomic Resilience Ashwin Parameswaran champions whistleblowing:,

Compared to other whistleblowers, employees have the best access to the information required to uncover fraud. They also possess the knowledge to analyse and parse the information for any signs of fraud. This is especially important in a field such as banking where outsiders rarely possess the knowledge to uncover fraud even when they possess the raw information….

[M]onetary incentives have an even stronger role to play in uncovering fraud in banking. The extremely high lifetime pay expected in the course of a banking career combined with the almost certainly career-ending implications of becoming a whistleblower means that any employee will think twice before pulling the trigger. Moreover, the extremely specialised nature of the industry means that many senior bankers have very few alternative industries to move to. …

The focus must be not to keep whistleblowers from losing their jobs but to compensate them sufficiently so that they never have to work again. As it happens, the scale of fraud in financial institutions means that this may even be achieved without spending taxpayer money. The whistleblower may be allowed to claim a small percentage of the monetary value of the fraud prevented from the institution itself, which should be more than sufficient for the purpose.

There is little doubt that if Brooksley Born had been listened to by Robert Rubin, Alan Greenspan, and Larry Summers during the Clinton era, the 2007-8 US financial meltdown might have happened sooner, but would arguably have been milder.

Rewarding whistleblowers can serve as a compliment to an idea The Epicurean Dealmaker, put on the table to attract some highly-talented people into government service. To TED:

Staff the SEC, or whatever “Super Regulator” the government decides to deputize to oversee this mess, with a bunch of highly-paid, tough-as-nails, sonofabitch investment bankers. You will have to pay them millions, just like regular bankers. (You can tie their incentive pay to improvements in the value of securities held under TARP and TALF, if you like.) Pay them well, and investment bankers won’t be able to treat them like second-class citizens at the negotiating table. Pay them like bankers, and your regulators won’t hesitate to read Jamie Dimon or Lloyd Blankfein the riot act, because they won’t give a shit about getting a job from them later.

Trust me, these are the kind of people you will need on your team: highly educated, financially sophisticated, psychotically hard-working, experienced professionals who know or can figure out CDOs, SIVs, balance sheet leverage, and credit default derivatives just as easily as the idiots who created and trade this shit. …

If these two measures were used to compliment other reform measures, we would go a long ways toward preventing future financial catastrophes.

[Personal Disclosure: I serve on the board for a little organization (FSEEE) set up to protect whistleblowers as a part of a three-part mission. What I’ve learned over 20 years is that there is little protection for whistleblowers. Despite high-sounding rhetoric in several Acts of Congress, whistleblowers usually lose most everything: jobs, families, property, etc. FSEEE, PEER, and GAP (three organizations I know that attempt to protect whistleblowers) all advise prospective whistleblowers not to blow the whistle, at least not publicly. Even though all three organizations know well the value of whistleblowers, they advise against the practice because the personal price to be paid is too high. Only crazy people blow the whistle, but FSEEE, PEER, and GAP (among others) stand ready to help by getting the message out (either anonymously or with what meager protection that can be offered by “going public in a big way”).]

NY Times Editors Need New Nemesis

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Here’s the link and here’s what is says about the planning rule:

The other piece of news is more complicated. Last month, the Agriculture Department proposed long-awaited forest-planning rules. The rules, mandated by 1976 National Forest Management Act, are supposed to guide forest managers as they decide which parts can be logged and which should be fully protected.

The act’s bedrock principle is that the health of the forests and their wildlife is to be valued at least as much as the interests of the timber companies. The Clinton administration’s rules firmly embraced that principle; the industry-friendly Bush rules did not.

The Obama administration’s proposed rules improve on the Bush rules and are full of high-minded promises about maintaining “viable” animal populations. But they are disappointingly vague on the question of how — and how often — the biological diversity of any particular forest is to be measured and what actions are to be taken to ensure its survival.

The net result is to give too much discretion to individual forest managers and not nearly enough say to scientists. This is dangerous because, over the years, forest managers have been easily influenced by timber companies and local politicians whose main interest is to increase the timber harvest.

As secretary of agriculture, Tom Vilsack has been more attentive to the needs of the forest, so far, than any agriculture secretary since the Clinton days. He should make sure these rules are strengthened.

When we had the law students visit earlier this week, they also talked about “industry,” and I asked them who do they mean? The ski industry, the oil and gas industry, the ranching “industry” (not sure anyone uses that expression, but..). Is there anything they are all united on? Do they actually work together to “open up” NFs to all uses? No.

Earth to NY Times editors- timber wars are over! They need to find new evil empire or federation of empires. Timber industry folks just aren’t very scary- see this press release about the Montrose mill.

Of course, my favorite part of this editorial was this quote

“The net result is to give too much discretion to individual forest managers and not nearly enough say to scientists. This is dangerous because, over the years, forest managers have been easily influenced by timber companies and local politicians whose main interest is to increase the timber harvest.”

Now, if we were on this side of the Hudson looking in that direction, we might suggest that the NY State Legislature, or perhaps the Mayor of New York could also be replaced by scientists. Because, after all, their “local” elected officials can be too easily influenced by industries of various kinds, instead of listening to those who know better, perhaps the editors at the Denver Post ;)?

Forest Wars: From Multiple Use to Sustained Conflict

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When we sometimes tire of our “word wars” here, we need to remember that they are just one manifestation of broader holy wars being waged in and around our public lands.

Long Road to War

Utilitarian ideology has been a mainstay in forest policy development since the early 1900s when Gifford Pinchot and Bernhard Fernow introduced forestry into American government. Samuel Hays’ Conservation and the Gospel of Efficiency, alongside David Clary’s Timber and the Forest Service both build on self-righteousness to the point of religious fervor among many who chose to work on the land, notably foresters and engineers, and their evangelists (pundits, professors, etc). Similar books could be written — likely have been — talking about the religious-like fervor of the environmental community. [See, e.g. Environmentalism as Religion, Wall Street Journal, 4/22/2010.]

For many years, what later emerged as forest wars were never more than disagreements between mainstream forestry practitioners and malcontents like John Muir, Aldo Leopold and Bob Marshall. Such “disagreements” were deep-seated ideological splits, but contrarians of that era didn’t have the political/legal muscle to make for war. Later, however, the very same disagreements intensified into ideological war with the dawn of the environmental movement.

Environmentalists gained traction in forest debates, appeals, litigation, etc. after people began to wake up to environmental concerns in the late 1960s. The first of a series of Wilderness Acts became law in 1964. The Endangered Species Preservation Act of 1966 predated and set a stage for the Endangered Species Act of 1973. Earth Day began in 1970. In 1969 the National Environmental Policy Act (NEPA) became law. In 1976 The National Forest Management Act (NFMA) and the Federal Lands Policy Management Act added to the mix. The environmental battles gained legal footing. But it is not clear that the legal footing was ever recognized, or at least accepted by the US Forest Service. At least if actions speak louder than words, we must question whether the Forest Service and its USDA overlords ever accepted these legislative mandates.

Disdain for legislative mandates runs deep, but there is an alternative path — a road not taken. Sally Fairfax set a stage for continued disgust for NEPA among forest practitioners with her 1978 Science article titled A Disaster in the Environmental Movement. Countrast Fairfax’s view with that from Jim Kennedy’s NEPA note: Legislative Confrontation of Groupthink.

Environmental Wars

Beginning in the 1970s, environmentalists waged war on timbering, grazing, road building, mining and oil & gas development, developed recreation, and more. Warriors on the “enviro” side typically vilify corporations, else government “lackeys” for the corporations. Warriors on the practitioner side vilify the enviros. In war there is little room for thoughtful discussion or dialogue. The rift between the two camps will likely remain very deep for a long time.

It is not clear that the Forest Service ever gave much heed to the “legislative confrontation of groupthink” ideas in NEPA. It seems that the Forest Service has been evading/avoiding NEPA responsibilities from the get-go. They continued “go-go timbering” up to the point of shutdown following the Monongahela and Bitterroot controversies. After things were sort-of opened up again via NFMA, the Forest Service wanted “once and for all NEPA”, i.e. the forest plan would be a catch-all NEPA container, allowing all projects to flow without any further NEPA review. When that didn’t work, the Forest Service played various shell-games pointing either upward (e.g. forest plans, regional plans) for NEPA compliance, else downward toward projects depending on what was being challenged. Finally, during the Bush/Cheney period, they sought to “categorically exclude” as much as possible from NEPA review.

In 1999 I wrote up a little thing titled Use of the National Forests. I noted four distinct periods of Forest Service history: Conservation and “Wise Use” — 1900-1950, Multiple Use — 1950-1970, Sustained Conflict — 1970-2000, and Collaborative Stewardship — 2000+. Although we might quibble over the dates as well as the categories, I now realize that I was over-optimistic as to the dawn of the Collaborative Stewardship era. At minimum there was a dramatic backlash — not necessarly against collabortion but clearly against environmetalism — commencing with Bush/Cheney Administration and their ABC (“anything but Clinton”) campaigns. The Bush/Cheney war on the environment was a reenactment of an earlier war waged by the Ronald Reagan Administration.

Bob Keiter (Univ. of Utah Law School) chronicled the emergence of both ecological awareness and collaborative stewardship in Keeping Faith with Nature. Keiter later chronicled the Bush/Cheney reactionary footnote in a 2007 article, Breaking Faith with Nature. Taken together, the two trace certain aspects of emergent gospels that were part of the ideological wars. The former traces what I’ll call the “ecosystem awareness” movement in the Clinton era of government, and the second the Healthy Forests Initiative and the Healthy Forests Restoration Act reactions during the Bush/Cheney era.

An era of “collaborative stewardship” may yet be emerging, albeit slowly and as already seen, with pushbacks. Enviros are still quite leery of “collaborations” and high-sounding agency rhetoric. They are warriors, after all. So the wars are not yet over, and may not be for a very long time. Timbering continues, albeit a a much lower volume than in the go-go days, and reframed as “ecological restoration” or “forest restoration”. New forest evangelists appear on the stage. Now we have both Wally Covington and Jerry Franklin preaching the gospel of forest restoration. I’ll leave it for further discussion as to how the two brands compare, and as to who buys into one, the other, both, or neither.

Other Wars

Even if wars between environmentalists and industrial and government practitioners were to ever end, these are just the tip of an iceberg of forest wars. We must add in the budget and staffing wars (hereafter budget wars) that have been ongoing in the Forest Service for a long time. Timber and Engineering reigned supreme in budget wars for many years, particularly after World War Two and the housing boom that fed rapid increases in timbering and associated road-building after WWII. Recreation, Wildlife, Soil and Water, even Fire, Personnel (later, “Human Resources”), Planning, Budget, Fiscal, State and Private Forestry, etc. were always struggling for funds. After go-go timbering days were a thing of the past — i.e. Environmentalists effectively shut down “go-go timbering”, Recreation and Fire gained an upper hand in budget wars. Somehow Engineering always seemed to keep its share of the money. [Note: Someday, maybe I’ll get these budget categories approximately right. For now, they are “good enough for government work”]

Finally — not trivially — Public Lands Wars have raged more of less continuously for many years. Remember the “Sagebrush Rebellion” and the so-called “County Supremacy Movement”? Now those have transformed into more of a “States’ Rights” movement. In all cases, part of the action has been an assault on federal lands.

I’ve probably missed some of the “wars” here. But if I’ve captured any of this even partially correctly, the landscapes, biophysical and political, have been transformed in the process. Some argue, as did Fairfax way back when, that the legal-administrative gridlock that has been a reality in federal lands management during the last 30-40 years, has done significant harm to the environment, and only resulted in wasted paper (EISs and dollars/time spent on forest planning, project planning, related NEPA work, appeals and litigation). Others like me argue that sometimes it is necessary to grapple with vexing social issues, even wicked problems in a very public way. Such “civic discovery” is a necessary part of a working democracy. Would that we could move from “war talk” to “fierce conversations“.

Related:
NEPA is Not the Problem, Forest Policy – Forest Practice, Oct 2007
The Blame Game

Squillace’s Thoughts on Proposed Rule –Post National Forum

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Professor Squillace, director of the Natural Resources Law Center at University of Colorado Law School, Professor Joe Feller, and Michael Saul from NWF and various law students came to visit us yesterday to discuss the proposed planning rule. Both he and John Rupe had been at the national forum.. so far I haven’t heard much from folks who had been there. He posted his thoughts here on the Red Lodge Clearinghouse blog. IMHO, his thoughts are worth reading and very comprehensive.

As he says

This current iteration of ideas was developed at the conclusion of the National Planning Rule Forum held in Washington, D.C. on March 10, 2011. To the extent possible, it reflects some of the comments and questions addressed at that forum.

I’d be interested in what others think- he’d also like to hear from you directly.

Planning for Fire: Beyond Appropriate Management Response

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In 2009, I had the opportunity to be involved in an effort known as the Quadrennial Fire Review.  Here is an excerpt from the final report explaining what the effort is about.

The Quadrennial Fire Review (QFR) is a strategic assessment process that is conducted every four years to evaluate current mission strategies and capabilities against best estimates of the fu­ture environment for fire management. This integrated review is a joint effort of the five federal natural resource management agencies and their state, local, and tribal partners that constitute the wildland fire community. The objective is to create an integrated strategic vision document for fire management.

The document provides a solid foundation for policy discussions within the federal agencies and, importantly, among the federal agencies and state, local, tribal, and other partners. While the QFR is not a formal policy or decision document, it sets the stage for a “strategic conversation” about future direction and change in fire management.

Several assumptions underlie the document’s analysis and conclusions:

The effects of climate change will continue to result in greater probability of longer and bigger fire seasons, in more regions in the nation.

Cumulative drought effects will further stress fuels accumulations.

There will be continued wildfire risk in the Wildland Urban Interface despite greater public awareness and broader involvement of communities.

Emergency response demands will escalate.

A lot of discussion in the document is devoted to “appropriate management response” sometimes miscategorized by the public as “let burn.”

The first QFR core strategy outlines a course forward that moves beyond appropriate management response to strategic management response that creates a framework for a multi-phased approach for incident management. Elements within strategic management response will include ensuring proactive wildland fire decisions with greater transparency and accountability, recalibrating fire planning, and establishing more robust fire outcome metrics.

Appropriate management response is often referred to as common sense fire management, but what may seem like common sense to one set of decision makers can easily run afoul of other stakeholders and decision makers with different missions, competing objectives, and conflicting perspectives on situation information. Moving to strategic management response is designed to ensure a higher level of transparency, accountability, and support for specific fire decisions and to better display the costs and benefits of suppression strategies. This approach would weigh factors such as suppression costs and value of resources lost against the value of ecosystems restored and improved and infrastructure protected.

Some questions:

Is there evidence that   the Forest Service has embraced the concept of strategic management response?

What kind of public involvement/collaboration will be needed to implement such an approach?

Can those who have opposed appropriate management response find something to like in strategic management response?

Does the the new planning rule provide appropriate guidance regarding the relationship of forest plans to fire suppression strategies?

Post- Beetle Species Change in Colorado

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These may be spruce and not fir, but couldn't easily find photo

I know there are those of you out there who can never have enough beetle info (especially Colorado beetle info) so here you are. Here’s a link to the report itself.

Colorado: Beetle-kill a catalyst for dramatic forest changes
Posted on March 15, 2011 by Bob Berwyn

Subalpine fir will replace lodgepole pines as the dominant species in many areas affected by mountain pine beetles. Lodgepoles dominating regrowth in harvested beetle-kill stands; subalpine fir replacing lodgepole in untreated areas

By Bob Berwyn

SUMMIT COUNTY — One of the first solid studies on forest regeneration in beetle-stricken areas shows that there will be a dramatic change in the forest landscape. Subalpine fir will come to dominate huge areas previously covered by lodgepole pines, with as-yet uncertain consequences for the forest ecosystems.

Pine and aspen recruits are three times more abundant in harvested stands, while subalpine fir dominated in uncut stands. Based on their field measurements, Forest Service researchers said lodgepoles will once again become the dominant species in treated areas, with a more diverse mix of trees where there has been no logging.

Forest structure, including tree density, is projected to return to pre-outbreak levels in 80 to 120 years in both treated and untreated areas, with aspen becoming a significant part of the overstory for the next 50 years, before conifers once again dominate the canopy.

“It’s a system re-set,” said Forest Service researcher Chuck Rhoades, who worked in the field at the epicenter of the pine beetle epidemic around Gore Pass and in the forests near Walden and Granby to try and understand how the forests will heal. “There’s a lot of stuff going on underneath,” he said, explaining that additional studies will help pinpoint how different types of treatments may affect what comes next.
The four-page paper, “Signs of Recovery for Colorado Forests in the Wake of the Mountain Pine Beetle,” was published by Colorado State University’s Forest Restoration Institute, which partnered with the U.S. Forest Service’s Rocky Mountain Research Station to do the research.

Rhoades said regrowth is strongest in areas where there were already some young trees sprouting beneath the lodgepole canopy. Some of the areas where subalpine fir are set supplant lodgepoles as the primary species will be quite different from the monoculture that has dominated the forest landscape for decades.

The firs are not susceptible to mountain pine beetles, but they can be killed easily by other insects and diseases. Rhoades said he would expect to see “more clumpiness,” with patches of different-aged trees rather than the common dog-hair stands of lodgepole.

From the report:

“The species (subalpine fir) is relatively short-lived and is susceptible to a number of insects and diseases, so it unlikely to form dense, evenpage stands, in spite of the high density of fir seedlings and saplings we measured. It is, however, reasonable to expect a shift from the uniform age and size conditions common in lodgepole pine-dominated forests to stands with more fir and greater size, age and overstory species diversity.”

But areas where the lodgepole was so thick that it prevented other species from taking hold — which includes big parts of the forests in Summit County — are more worrisome, he said. So far, there’s been little sign of new growth in those stands, whether they’ve been treated or not. Lodgepole may re-establish itself as the dominant species in those areas, but it may take a little longer.

The biggest change will be in the huge swaths of unharvested dead lodgepole stands, covering about 85 percent of the area affected by mountain pine beetles. Based on the field research subalpine fir will replace lodgepole pines as the dominant species in those areas, Rhoades said.

That holds true especially for the upper-elevation areas of the subalpine zone, where spruce and fir already had a foothold, said the Wilderness Society’s Grep Aplet.

“The real challenge is the lower elevation areas of Summit and Grand counties,” Aplet said. “Where mortality was less severe, the forests will recover quickly. In areas where it was most severe, the future is a little more uncertain,” he said.

There was no difference in seedling density colonizing clear cuts in live or in beetle-infested stands. But in harvested areas, lodgepole pines will once again become the dominant overstory species and grow back into stands similar to those that were attacked by pine beetles.

From the report:
“The implications of greater abundance of subalpine fir on High Country forests and communities remains uncertain. These findings represent the first stage in development of new forests following the beetle outbreak during a period of dramatic change that will have consequences for Colorado ecosystems and economies for many decades to come.”