When I first read Chris French’s memo, I thought, “Well, that’s what you get when you have a timber industry person as the new Chief.” I imagined him meeting with his staff in the WO and
telling them, “I want you to come back tomorrow and come up with a laundry list of ways we can get more timber sold. I want you to cut all corners you can, got it?” It appeared to me that
they were throwing a number of safeguards out the window. I also found it interesting that in the memo, it says, “Our efforts will also result in a better return on investment for the public
we serve by covering more of the costs of the timber program through revenue generated,” when they later provide direction to practically give timber away.

Upon further reflection, I still think there is some sketchy stuff in the memo, but some of it does make sense. I also have to think that the timber industry and more than a few FS employees
are really happy about this memo. That whatever tradeoffs there may be are worth it to get more wood out, and that this is key to the solution of our wildfire problems. There have
certainly been a lot of people pushing for something like this for a long time.

But I digress, I told Sharon that I would talk about DxD and particularly DxP. Firstly, I do not claim to be an expert on these, but I do have some experience with them. I know there are a
lot of people who follow TSW who are much more knowledgeable on this topic, and I would be interested to get their thoughts. The memo says, “These types of timber designations should
be the default approach in implementing timber projects. Exceptions to these designations must be made in consultation with a Regional Forester.” That’s clear direction.

When the 2014 Farm Bill allowed for the use of DxP, the Region asked us on the Black Hills NF to do a trial study on a timber sale using DxP. We identified some issues, but overall, it went
pretty well. The prescription has to be written very well to provide for accountability. The logging operators need some time to learn what is being asked of them, and they have to be
willing to learn a new way of doing business. Obviously, the more complex the prescription, the more difficult it is to get the result you were looking for. At the end of the day, there is no free
lunch; time and money saved by not marking the stands are offset to a degree by increased sale administration duties. Timber Sale administration becomes more demanding and time-
consuming. If DxD and DxP become the “default approach” then there will need to be extra Sale Administrators hired and trained. That is, unless the only goal is to quickly get logs on the
truck and no one cares how the actual sale meets the prescription. I think that there is certainly a use for DxD and DxP in a wide variety of situations. It sure seems like there will be a lot of pressure to use them. With low-value timber and simple prescriptions, they may make a lot of sense. Should it be used with Black Cherry trees on the Allegheny NF?

Probably not. Was there an overreaction to measures like this when things went wrong in the past, and tighter controls were seen as the solution? Possibly. One thing is for sure: there will
be more timber sold on the National Forests over the coming years, and there will be some tradeoffs in making that happen.

Dave Mertz retired from the Black Hills National Forest in 2017 as the forest’s natural resource officer. Over the course of his career, he was a forester, silviculturist, forest fire management officer and a fire staff officer.

 

In the Timber Implementation Memo signed by Chris French discussed in the last three posts, it says

I am delegating the authorization to use timber designations by prescription (DxP) and designations by description (DxD) to Forest Supervisors. These types of timber designations should be the default approach in implementing timber projects. Exceptions to these designations must be made in consultation with a Regional Forester. Additionally, virtual
boundaries should be used in lieu of marked boundaries whenever possible.

I tried to find descriptions of what is meant by DxP and DxD .

Sure enough, there was a handy paper from the 2019 National Silviculture Workshop. Note: organizing this was part of my job when I was in R&D in the WO.  IMHO this is one of the most important roles of FS R&D.. to work directly with practitioners in NFS and States, Tribes and private landowners to help them solve their problems using science and technology.

Warning: this paper is from 2019 so people have moved on in learning since then.. if anyone has a more recent round-up, please put in comments. The 4FRI digital marking shown in the image above was from 2015. I’m sure that knowledge and experience have advanced in the last 10 years.

Designation Definitions

Designation by Description (DxD). Trees are designated to be cut by describing measurable characteristics of individual trees and/or their juxtaposition to each other. Examples of descriptions include spacing, species, diameter, damage class, or a combination of two of these factors. Determining whether the correct trees are cut is done at the individual tree level. When trees are designated by the description, it is possible to look at individual stumps to determine if a tree was authorized to be cut or not.

Designation by Prescription (DxP). Trees are designated by describing the desired condition of the residual stand following harvest. The purchaser has discretion within the guidelines of the prescription, as described in the contract provisions, in selecting which trees to cut and which trees to leave. Determining whether the correct trees are cut or left is done at the cutting unit level. Examples include verifying whether a certain residual BA was left in the unit or measuring crown closure throughout the stand. Simple examples of criteria used in a DxP prescription include “leave 50 to 70 sq. ft. of basal area” in a southern yellow pine stand, or “leave two crowns touching” throughout an even-aged mixed conifer stand.

Designation by Marking. Trees are “marked” when individually designated with paint marks above and below stump height. Trees can be marked to cut or leave as distinguished by the color of paint used.

There are also different technologies involved with DxD and DxP. For example, in Region 3.

Another new approach currently being used by the Region is the digital prescription guide. Silviculturists use tablet computers with geo-referenced aerial photos to digitally designate areas for treatment within a stand. For example, areas for group selection, including skips and gaps, are designated on the tablet. Technically they are writing a prescription on the tablet as they walk the stand. The digitally mapped prescription then is sent to the contractor as a shapefile to be used with a tablet in the cab of the harvesting equipment. This shapefile gives the exact location where the group openings, skips, and gaps should be. Early implementation shows good results. Digital prescription guides reduce a complex prescription to an operationally simple approach.

Where did these come from? The 2014 Farm Bill authorized their use.

Section 8303 of the 2014 Farm Bill, entitled “Extension of Stewardship Contracts Authority Regarding Use of Designation by Prescription to All Thinning Sales Under National Forest Management Act of 1976,” amended paragraph 14(g) of NFMA as follows:
(1) IN GENERAL
Designation, including marking when necessary, designation by description, or designation by prescription, and supervision of harvesting of trees, portions of trees, or forest products shall be conducted by persons employed by the Secretary of Agriculture.
(2) REQUIREMENT Persons employed by the Secretary of Agriculture under paragraph (1)—
(A) shall have no personal interest in the purchase or harvest of the products; and
(B) shall not be directly or indirectly in the employment of the purchaser of the products.
(3) METHODS OF DESIGNATION
Designation by prescription and designation by description shall be considered valid methods for designation and may be supervised by use of postharvest cruise, sample
weight scaling, or other methods determined by the Secretary of Agriculture to be appropriate.

Despite the reference to “thinning sales,” the title of section 8303 does not have the force and effect of law. Consequently, section 8303 does not limit the use of DxP solely to thinning sales and is therefore applicable to all timber sales and stewardship contracts, and a broad range of silvicultural treatments. Under section 8303, preparation of the prescription, and supervision of the harvesting activities, must be performed by persons employed by the Secretary of Agriculture.Selection of which trees to cut, consistent with the prescription, may be left to the discretion of the timber sale purchaser or stewardship contractor.

This seems pretty specific, and yet there are A to Z efforts, States, Tribes, and NGOs developing prescriptions and supervising harvests. Maybe because they are reviewed by USDA employees?

For those interested,  below is the summary from the 2019 National Silviculture Workshop panel discussion.

Using DxP on Forest Service timber sales has been an important business change for the agency. All panelists agree that DxP works best when prescriptions are well designed and communicated, and generally, when prescriptions are not too complex and are limited to about three selection criteria. Forest Service personnel using DxP need to focus on the residual stand and not as much on the individual trees being removed, i.e., concentrate on the overall density, species, and structure of the resulting stand, and not so much on individual trees being left in the exact correct spot.
Techniques are available, however, to handle more complex prescriptions (DxP with Reserve Tree Marking, and digital prescription guide). If there are individual trees that are specifically important for biodiversity or other reasons, Forest Service personnel can mark them as reserve trees. Also, digital prescription guides may be used for complex prescriptions, where a tablet is used in the cab of the logging equipment to assist in what type of harvesting should occur in each area.

DxP does not work with all contractors and all prescriptions. Complex conditions such as dwarf mistletoe, other disease situations, and salvage logging after a fire (where live crown ratios are considered) require more careful and time-consuming tree selection processes. Prescriptions that utilize characteristics of individual trees rather than stand characteristics may be more suitable for individual tree marking. Additionally, prescriptions that depend on individual tree characteristics may be more difficult to implement and administer.
DxP can reduce sale layout costs because tree marking is not needed. With DxP, however, sale administration may increase through more field visits during and after implementation, and operator costs may increase if tree selection decisions increase harvesting time. Additionally, the assurance of meeting desired conditions may be lessened when paint is not used. Foresters may be hesitant to try DxP timber designation on small project areas and when the contractor’s expertise and performance history is unknown. Development of a good working relationship is important. DxP can help timber sale purchasers and stewardship contractors achieve better efficiency in harvesting and thinning operations because the operators don’t have to give the Forest Service notification around factors specific to the silvicultural prescription and their operator-specific considerations such as cutting trees for skid trails and landings. Trees are not individually designated for cutting or leaving. Operators are free to make any adjustments they want as long as they meet the prescription criteria.
A DxP prescription must be written clearly and must include specific desired end results that are measurable and understandable by both Forest Service sale administration personnel and timber sale purchasers or stewardship contractors. Silviculturists should ensure prescriptions are clear, well-communicated, and tailored to the appropriate desired end result for the landscape to be harvested. Silviculturists need to consider operational feasibility and stand-level tactical implementation when developing silviculture  prescriptions.
Use of DxP continues to be an ongoing learning process. Using DxP is about trust and partnership. The trust only can be gained from the experience of implementing the prescription on the ground. Experience and confidence will show that DxP can be implemented on a variety of stand conditions and sites.

I think that the National Association of Home Builders is probably a decent source of info. This stsory is from April 3.

The tariff exceptions for Canada and Mexico amount to a major win for NAHB, as Canada accounts for roughly 85% of all U.S. softwood lumber imports and accounts for nearly a quarter of the available supply in the U.S.

But duties, based on a US Department of Commerce analysis (not related to the Trump Admin) may double? This would be those duties required as part of the multi-generational US Canada Softwood Lumber dispute. Here’s a story from CBC.

The U.S. is set to more than double the duty it charges on softwood lumber imports from Canada, with the planned new rate set at 34.45 per cent, up from the previous 14.54 per cent.

While the preliminary determination was not immediately posted to the U.S. Federal Register, it was confirmed in statements from the B.C. premier’s office and the U.S. Lumber Coalition, a trade industry body.

New softwood lumber duties were long-feared amid the growing trade war between Canada and the U.S., and would be the latest blow to B.C.’s beleaguered forestry industry, which has seen thousands of workers laid off over the last few years.

The following discussion summarizes the nature of the dispute.

Under the U.S. Tariff Act, the Department of Commerce determines whether goods are being sold at less than fair value or if they’re benefiting from subsidies provided by foreign governments.

In Canada, lumber-producing provinces set so-called stumpage fees for timber harvested from Crown land, a system that U.S. producers — forced to pay market rates — consider an unfair subsidy.

Indeed, the U.S. Lumber Coalition — which represents softwood lumber producers in that country — welcomed the planned spike in duties in a statement on Friday.

“These unfair trade practices are designed by Canada to maintain an artificially inflated U.S. market share for Canadian products and force U.S. companies to curtail production, thereby killing U.S. jobs,” said Andrew Miller, the chairman of the coalition, in the statement.

The B.C. Lumber Trade Council said in a statement that claims that B.C.’s system provides an unfair advantage “are simply not supported by the facts.”

“Our stumpage system is grounded in market principles, with timber sold through open, competitive auctions,” said Kurt Niquidet, the president of the industry body.

It’s an interesting (and free) article, but I thought that this was particularly interesting..

But amid a series of challenges for the province’s forestry industry — including a mountain pine beetle infestation that killed hundreds of thousands of trees — mills have been closing around the province in recent years, and major forestry companies are opening up new mills in the United States.

So someone thinks that US mills are a good investment?

So I of this series was looking at the details of the order itself. II was looking at the E&E News story and broader picture quotes from notable luminaries such as Nick Smith, Susan Jane Brown, Andy Stahl and an unnamed FS employee.
Now I don’t know where this came from, but I suppose they are examples of Region-specific Actions that someone thought of. I though they might be illustrative of what some FS folks are thinking.
*****************

R1: Expand GNA partnership with MT DNRC to address capacity gaps and expand the available workforce for planning, designing and implementing forest management projects (will need funding to implement).

R2: Expand the CO State Green Sheet commercial sale program on the GMUG. This program empowers the Colorado State Forest Service to administer commercial sales, both timber and fuelwood. The anticipated expansion is primarily focused on taking advantage of NEPA cleared areas between commercial sales the GMUG is currently working or have already completed.

R3: Complete two larger-acre G-Z IRSCs on 4FRI providing the opportunity for both large- and small-scale operators to secure the volume necessary for continued investments. The two G-Z
IRSC contracts represent around 20,000 acres of project area and a potential of ~132,000 CCF.

R4: Expedite timelines to offer salvage sales on the Boise NF. Use as many tools as possible including emergency situation determinations, virtual boundaries, use of orthophotography for
aerial volume estimates, modified cruising sampling error standards, modified utilization specifications, and use of comparison appraisals.

R5: Partner with industry and colleges/tech schools to teach heavy equipment operations. Build upon the MOU with American Loggers Council which was signed last year to identify “training
grounds” where students can train on heavy equipment.

R6: Pilot an “A-Z” timber project under the Stewardship Authority on the Willamette NF in Region 6. Under this novel approach, which has only been implemented twice by the Forest Service (both on the Colville NF, also in Region 6), the timber purchaser-partner takes on the majority of the work from the start to finish of the project, including NEPA analyses, project
design, timber sale layout, and project implementation, to meet the high-level objectives identified by the Forest Service.

R8: Implement digital solutions using LIDAR for timber sale preparation using AI machine- based learning (GAIA) across southern pine forests with expectation of substantial time financial
savings.

R9: Expand use of DxD, DxP, and other scaling methods, as well as virtual boundaries across the region based on industry capacity and need.

R10: Create an Integrated Resource Stewardship Contract that will provide a source of timber for local mills and expand our use of Good Neighbor agreements with the State of Alaska.

Marc Heller wrote a piece at E&E News that I think covers the big picture in the tagline

For all the administration’s talk of boosting the wood industry and saving local economies, the timber gains from national forests may be modest at best.

A more modest and achievable goal might be to support existing domestic timber industry and jobs, and try to promote other uses of waste wood from fuel treatment projects. That may have not been the stated goal of the Biden Admin, but when we look at the NWTF grant for log movement, the Biden Admin’s behavior seemed to support that. In fact, you could say, that there is a big chunk of all this stuff that is bipartisan if you overlook the political rhetoric.

Anyway, let’s dig in.

The Trump administration’s drive to harvest more timber from national forests will lead to a “thriving wood products economy” that doesn’t rely on imports, a top Forest Service official told the agency’s top brass in a memo last week. But the timber goal acting Associate Chief Chris French pinpointed — a 25 percent increase from current levels offered for sale — would fall short of the first Trump administration’s ambitions and barely make a dent in U.S. timber supplies, data shows.

The chasm between the new administration’s rhetoric — cut more trees on national forests to reduce the country’s reliance on wood imports and rejuvenate the economy — and the math behind French’s memo reflect the hurdles to returning to the timber industry’s prosperous times around national forests.

A 25 percent jump from fiscal 2024 levels would translate to around 3.6 billion board-feet of timber. That’s less than the first Trump team’s target of 3.88 billion board feet
for fiscal 2021 and roughly equal to the 3.68 billion board-feet goal the prior year, reflecting the last two years of Trump budget requests.

If achieved, however, it would mark a turnaround in actual sales. The Forest Service said it sold 2.88 billion board-feet of timber in fiscal 2024, down from 3 billion board-feet in 2023. The biggest sales years recently were during the first Trump administration, at 3.23 billion board-feet in 2019 and 3.22 billion board-feet in 2020, according to a U.S. Government Accountability Office report on the timber program.

A table of targets and achievements over time might be helpful. It probably exists somewhere.

Here’s what Nick Smith says:

Timber industry representatives and others familiar with the Forest Service’s timber program point to several flaws in the administration’s timber-boom narrative, although the industry welcomes the Forest Service’s moves to step up production.
“There are some encouraging elements in the Secretary’s order, including direction to prioritize removal of dead and dying trees, but barriers to doing that remain in place,” said Nick Smith, a spokesperson for the American Forest Resource Council, representing timber companies that work in national forests and elsewhere. “The question is whether these efforts can overcome the fundamental barriers of litigation and obstruction, and the cost and time it takes to meet federal regulatory requirements,” Smith said. “Many of the necessary reforms need to come from Congress.”

Here’s what Andy Stahl says:

“’Worthless wood’ is synonymous with ‘hazardous fuels,’” said Andy Stahl, a former timber industry lobbyist and executive director of Forest Service Employees for Environmental Ethics.
French’s memo hints at the trouble, Stahl said, by promising “direct financial support programs to industry” including grants for transporting timber taken off national forests — Biden-era programs that suggest the work isn’t profitable and needs taxpayer subsidies.

Stahl said he’s not sure the administration seriously wants to dramatically increase harvests on federal land, given the competition that could pose to big timber companies that produce the vast majority of the nation’s wood from privately held land. Even a 25 percent increase from national forests would be little more than a rounding error in the national wood supply, he said.

If something’s drop in the bucket, it’s probably not of interest to the big companies, would be my guess. They don’t care much about communities or even countries in some cases. Here’s what Susan Jane Brown says:

For another reality check, so many mills near national forests have closed in recent decades that even higher-quality logs would have to be transported longer distances, at
increased costs.
While some recently closed mills could reopen — welcome news in areas that have lost them — “no businessman is going to invest millions of dollars in a new mill or in retrofitting an old mill,” said Susan Jane Brown, an environmental lawyer and principal at Silvix Resources in Oregon. “That will be another bottleneck.”

One Forest Service manager who works with the timber program told E&E News that such economic realities and government funding are more often barriers to timber production than environmental regulations, at least outside of Montana, Oregon and parts of California.

Yes, and that’s also where many mills currently are.

“Markets, forest road maintenance costs, forest staffing and available funding are most often the barrier to more timber volume going down the road,” this manager said, requesting anonymity to offer a frank assessment of the Forest Service’s situation.
…
As ambitious as the administration’s language sounds, it largely reinforces what many forest supervisors already do, the Forest Service manager who requested anonymity said. That includes working with nonfederal partners to maintain forests through contracting.

“Nothing in it bothers me except the ability to meet the expectations post-RIF,” said this manager, referring to the reduction in force that employees fear could hit a few thousand people in the coming weeks.

Indeed, that’s where the proverbial rubber will meet the road.

This is a long letter with many different things in it. I’m hoping we’ll have time to discuss it from a variety of different perspectives.
Last week, I thought Governor Newsom seemed to be channeling HFRA. I took a look at the Implementation letter, and it resonated backward in time ith the language in HFRA and forward as described in FOFA (Fix our Forests Act), which I think it being discussed in the Senate this week. In fact, we can look at FOFA and the Admin’s Timber effort as being somewhat complementary approaches to the same problem that HFRA tried to deal with- expediting fuel treatments in the “right places.” HFRA had condition classes, FOFA has firesheds, the Secretarial ESD order has a map, they all identify conditions worthy of fuel treatments. The Implementation Letter focuses on the how-to’s and also focuses on places with existing timber industry.

The goals we will seek to achieve in actively managing our forests are:
• Support rural economies and forest product industry partners
• Reduce the risk of destructive wildfire by creating and sustaining healthy and resilient forests and watersheds
• Build capacity through workforce alignment and partnerships

If we think about the previous Admin, they were also supporting bullets 2 and 3 (especially building capacity via the Keystone Agreements). They might have just switched the order of bullets.
1. Reduce the risk of destructive wildfire by creating and sustaining healthy and resilient forests and watersheds
2. Build capacity through workforce alignment and partnerships
3. Support rural economies and forest product industry partners

But what does the FS plan to do? In this post, we’ll look at the details.. next posts will go into the details more and also talk about the big picture.

I am directing the Deputy Chief for the National Forest System, in consultation with other Deputy Chiefs, Regions and Forests, to develop a national strategy that outlines our agency’s goals, objectives and initial actions related to increasing active forest management. This will be completed in 30 days.

Figure Out Where the Problems Are and Imagine Fixes

I am directing all Regional Foresters to develop 5-year strategies, tiered to the national strategy, to increase their timber volume offered, leading to an agencywide increase of 25% over the next 4-5 years. These regional timber strategies will include an assessment of their current 5-year program of work (POW) that includes timber volume, opportunities to expand that POW, a wood utilization facility risk assessment, barriers to achieving a 25% increase in volume (including information beyond funding needed), and potential solutions to overcoming those barriers. As part of your regional strategy, you’ll be required to explore the opportunity to designate Sustained Yield Units required for industry investments where active management is needed. Strategies must be completed in 60 days following the release of the national strategy.

Sustained Yield Units..haven’t thought about those in a while! So this directs the Regions to round up what their issues are and potential solutions. These should be interesting to read, and I will try to get them or FOIA them.

DxP, DxD, D-Fault

I am delegating the authorization to use timber designations by prescription (DxP) and designations by description (DxD) to Forest Supervisors. These types of timber designations should be the default approach in implementing timber projects. Exceptions to these designations must be made in consultation with a Regional Forester. Additionally, virtual boundaries should be used in lieu of marked boundaries whenever possible.

People with more experience can speak to this..Dave Mertz is planning to write a post.

Direct Sales

Further, I am directing District Rangers and Forest Supervisors to, in addition to regular timber sale solicitations, utilize direct timber sale opportunities with interested purchasers operating on and around forests. Line officers with interested partners must initiate industry engagement within 60 days to integrate these opportunities into your short- and long-term programs of work.

I don’t know what these are, so hopefully folks will tell us more.

Base and Appraisal Rates

Finally, all agency timber sales will use base rates or minimum rates, where appropriate, based on the Emergency Authorizations outlined by the Secretary. In addition, within 90 days, Regions will establish standard appraisal rates that can be applied and used over a geographic area where similar conditions exist. The Washington Office is available to assist in this process.

Two Years of Shelf Stock

Within the next 24 months, I expect each Regional Forester to establish 2 years’ worth of “shelf stock” of timber volume coming from project decisions for out-year implementation of their timber related program of work. These decisions should be in place within the next 24 months.As a part of this, within the next 3 months, and every 6 months thereafter, Districts with suitable timber base and active industry partners will develop projects that can be analyzed using appropriate Categorical Exclusions (CEs) to address active forest management needs. These projects will not only reduce fire risk and support local economies but also result in timber volume sold. National assistance will be made available where needed though the Planning Services Organization and Field Services and Innovation Center (FSIC).

It would be interesting to know (map) how many Districts have a “suitable timber base and active industry partners.”

NEPA :If You’ve Got Em, Use Em and Push the Envelope

I further direct all Line Officers to use innovative and efficient approaches to meeting the minimum requirements of the National Environmental Policy Act (NEPA), Endangered Species Act, National Historic Preservation Act, and other environmental laws, including categorical exclusions, emergency authorities (including the Secretary’s recent expanded Emergency
Situation Determination), condition-based management, determinations of National Environmental Policy Act (NEPA) adequacy, and staged or tiered decision-making. In addition, I direct compliance with the NEPA statutory time limits for, completing environmental assessments and environmental impact statements.

If we go back in time to HFRA, I remember doing reviews of why folks weren’t using the CEs provided for in legislation. At least in those days, there was a strain of conservatism in some NEPA teams. And our industry contacts did not want us to use CEs due to uncertainty, they wanted the sales to proceed with alacrity. It will be interesting to see how the tension between experimentation and certainties are resolved as time goes on. Certainly many small projects might challenge the abilities of the litigatorily-inclined groups to respond. Harder to hit all of a fleet of small boats rather than a few large ships.

To this end, I am directing the Deputy Chief of the National Forest System through the Director of Ecosystem Management Coordination, within 14 days, to release direction for using Emergency NEPA, Endangered Species Act (ESA), and other regulatory authorities to streamline and simplify our permitting processes. This guidance will include mandatory minimum approaches to scoping, extraordinary circumstances analysis and decision documentation requirements.

My old boss and Director of EMC, Fred Norbury, used to say that NEPA in the Forest Service was more like a bunch of cobbler shops, and to be efficient, it should be more like a Nike factory. This was very unpopular. Who wants Kroger brand when you could have artisanal cheese? At the same time, I see this as an effort to make NEPA work less artisanal. Results might be making it easier for new people to learn, to have line officers and NEPA teams working off the same page, and make it easier to teach new NEPA people and partners. Which could be extremely important if NEPA people are RIFed or take buyouts. I’d only advise the FS to make sure they have a phone line to a team of NEPA advisors who are familiar with the direction.

Certification and Training

We will align our workforce to be efficient in active forest management delivery. I am directing the National Forest System Natural Resources Director to streamline or reduce certification requirements and processes. In the next 4 months, all Forest Supervisors, Regional Forester Teams, and appropriate Washington Office staff will attend a national active forest management meeting to align the goals, objectives and actions associated with the program, followed by regular engagements to ensure continued progress and shared leadership. Within 12 months, all current line officers will complete or refresh Forest Management for Line Officers training. New line officers will complete this training within 12 months of their effective date as a line officer.

I don’t know what certifications are needed now, except for silvicultural certification, which may not count.

Get It Together, Fuels and Timber

There have been significant improvements within the Washington Office with integration of the hazardous fuels, Wildfire Rick Reduction Infrastructure Team (WRRIT), and forest management teams over the last several years and their combined efforts have delivered record accomplishments. Based on the guidance in the Executive Order, I am asking for additional integration to continue building on those successes and chart a new, completely seamless program. Therefore, I am directing the Deputy Chiefs of National Forest System and State, Private and Tribal Forestry to develop a proposal for integration of the teams and funding structures at the Washington Office within 30 days. Additionally, I am directing the same group, in consultation with the Regional Foresters, to develop a strategy field level integration, inclusive of regions and forest, within 6 months.

I think they meant Risk reduction (I am always available for proofreading) and maybe they meant a “strategy for field level integration.” The point seems to be better coordination and less siloing. Which I think most of us can agree would be a good thing.

Prioritize With States, Tribes and Counties

I expect line officers to work with States, Tribes and Counties to establish priorities and identify opportunities to share resources for execution of regional and national active forest management strategies. I expect this to result in an increase in what region’s accomplish through Good Neighbor Agreements. We will emphasize work with industry partners to identify needed, feasible projects on national forests and increase the use of G-Z and A-Z contracting, as well as stewardship agreements and other implementation tools.

Funding for GNA and Other Programs
We will also find additional opportunities to work with states, counties, tribes and non-governmental partners to increase our active forest management activities on the ground. Internal coordination to build capacity will include increasing commercial product delivery in projects that focus on hazardous fuels reduction, implementing direct financial support programs to industry (Wood Innovation Program and Hazardous Fuels Transportation grants), and identifying opportunities to re-direct existing funds toward active forest management.

The agency will fund up to $50 Million in Good Neighbor Authority Agreements that will fund road and bridge maintenance and reconstruction for active forest management projects. This
work will emphasize the minimum standards necessary for safety and removal of wood products.

Salvage and Reforestation
Finally, it is imperative that we plan and execute salvage and reforestation projects as these disturbances happen to accelerate post-wildfire recovery and reestablish healthy and resilient
forests. We have many critical successes to anchor to, including expanded hazard tree removal efforts along roadways, post fire shaded fuel break construction, and Memorandum of Understandings (MOUs) with key industry partners that have helped us model success at local levels. But we need to do more, and as such, I am directing line officers to prioritize and address salvage opportunities, including leveraging opportunities to work with states, tribes, counties, private industry, and partners to increase the pace and scale of recovery and share in achieving cross-boundary results. I’m also directing the use of existing frameworks and tools, such as Potential Operational Delineations (PODS) and the National Alliance of Forest Owners (NAFO) MOU to capitalize on the opportunity to move quickly, capitalize on value, and restore the areas to more fire resilient conditions. Regions, in consultation with the Washington Office and Forests, will integrate their regional 10-year reforestation implementation strategies with the national active forest management strategy. To the maximum extent practicable, use existing and new categorical exclusions for timber stand improvement, salvage, and other site preparation activities for reforestation, consistent with applicable law. I expect that active management, reforestation and stand improvement activities will reduce wildfire risk, ensure sustainable timber supply, promote forest health, and protect our communities and their water supply.

This is interesting as it characterizes some salvage as a prelude to reforestation. Which makes sense in certain conditions.

So that’s it. What do you think? The next post will be on the bigger picture of “going after timber on the NF’s” and the E&E News story.

• Followup to the acres question earlier. I wrote the AP folks and they said they got the number from the press release, which said

U.S. Secretary of Agriculture Brooke Rollins issued a Secretarial Memo (PDF, 2.9 MB) to establish an “Emergency Situation Determination” on 112,646,000 acres of National Forestry System (NFS) land (PDF, 19.8 MB).

Certainly that’s over half.  Which of course does not obviate other restrictions, like Wilderness, Roadless, etc.  In fact, it only applies to EAs and EIS’s that meet other designation and plan requirements.  But I can see why a press release would not go in to those details.  So that explains it- the origin of what might be considered cascading misunderstandings.

Our friends at Center for Western Priorities were quick to jump on this in their newsletter this AM…

The Trump administration has removed protections for over half of the National Forest System via the issuance of an emergency order related to wildfire risk. The order covers more than 110 million acres of forest land and will fast-track timber production by removing National Environmental Policy Act regulations in the name of wildfire mitigation.

Guess what the link goes to? Not the AP story, the WaPo story.  And so the cascade continues.

 

Today I’d like to focus on the Washington Post story that covers the very same Emergency Situation Determination that we covered here Friday.  Now remember what the ESD does-

1. One action alternative or no action is analyzed in an EA or EIS.

2. No objection process

3. Thanks to Rich J., a special injunctive relief section, which is part of the bill known as Bipartisan Infrastructure Law and IIJA.

The text of section 40807 is here:

https://www.congress.gov/bill/117th-congress/house-bill/3684/text#:~:text=SEC.%2040807.%20%3C%3CNOTE%3A%2016%20USC%206592c.%3E%3E%20%20EMERGENCY%20ACTIONS.

As for “special injunctive relief standards,” section 40807(e) states:

(e) JUDICIAL REVIEW OF EMERGENCY ACTIONS.—A court shall not enjoin an authorized emergency action under this section if the court determines that the plaintiff is unable to demonstrate that the claim of the plaintiff is likely to succeed on the merits.

This section reduces the four part test for injunctive relief used in the 9th Circuit (and perhaps others) to just one element – plaintiffs’ likelihood of success on the merits. Masochistic readers desiring more injunction background info can go here:

https://forestpolicypub.com/2024/10/02/law-concepts-for-the-non-lawyer-rich-j-on-preliminary-injunction-factors-and-the-balance-of-equities/

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Since the WaPo story, thanks to Nick Smith, I found this AP story by reporter Matt Daly which is very good IMHO.

Anyway,  let’s go to the claims made in the WaPo piece (notably filed under “climate”). Let’s start with the headline.

Trump administration orders half of national forests open for logging

An emergency order removes protections covering more than half the land managed by the U.S. Forest Service as the president aims to boost timber production.

Note that this is purportedly a news story, not an op-ed.

The Trump administration has removed environmental protections covering more than half of the land managed by the U.S. Forest Service.

I was curious about this and went to the FS website with acres of IRAs and Wilderness and other special areas. This is definitely a rabbit hole not of general interest, so I put that adventure at the end of the post.

Now if a person knew that there were a variety of environmental laws and regulations, one might be skeptical of the above idea.  I can think of the Bush or Trump 1 folks thinking “hey we didn’t know it was that easy! Pesky old statutes and regs!”

Forest management can help prevent wildfires by thinning the amount of fuel available for blazes to feed upon. But forestry experts often suggest the removal of undergrowth that doesn’t yield timber, and they warned during similar efforts in Trump’s first term that you can’t log your way out of fire danger, The Washington Post reported. Removing large, fire-resistant trees also gives way to young trees that are more susceptible to fires.

I don’t think anyone ever said that we could “log our way out of fire danger”; what people said is that under some conditions, mechanical thinning is a useful fuel reduction tool. In some cases,  there is a market for the thinned material.

Rollins’s memo, which does not make a reference to climate change, instructed Forest Service field leadership to fast-track timber production by removing National Environmental Policy Act regulations, making it easier to obtain permits and reducing “contracting burdens.”

Um…if it were that simple…

Here’s another one:

So another shout-out to reporter Matt Daly and AP for breaking that mold in this case!