Addressing Watershed Health in the Forest Service Planning Rule

The management of water resources in National Forests and Grasslands continues to be an important topic in the development of the new planning rule, and was discussed at last week’s National Roundtable.  While the meeting presentations were intended to focus on the more general topics of forest restoration and resilience, some participants at the meeting wanted to speak specifically about water. 

There is substantial interest in this topic.  The importance of water and watersheds as a unifying principle in the planning rule was discussed previously on this blog.  The Forest Service’s inability to address watershed restoration was also previously discussed, as well as problems integrating scientific information with observed watershed conditions. 

The planning rule website contains some of the initial concepts proposed to be included in the rule for addressing watersheds:

  • Each Forest Supervisor would assess existing conditions and trends of aquatic systems, riparian systems, connectivity, wetlands, floodplains, and the flow processes.  The roles and contributions of each forest would also be determined.  Watershed vulnerabilities and risks would be identified.
  • Each Forest Plan would be required to address the maintenance or restoration of water resources, including protection for lakes, public water supplies, shorelines, source waters, streambanks, streams, wetlands, and other bodies of water from detrimental changes in water temperatures, blockages of water courses, and deposits of sediments.
  • Monitoring would be implemented to evaluate watershed health and status, trends, and risks associated with public water supplies and source water protection areas.

Earthjustice and Pacific Rivers Council released a concept paper last week with additional suggestions about what the planning rule should do.  The proposal suggests that the planning rule should require forest plans to establish riparian reserves, prioritize protection and restoration of key watersheds with the highest aquatic integrity, establish measurable watershed conservation objectives and indicators of aquatic ecosystem integrity that are directly linked to management standards and monitoring, describe road removal objectives and road density standards, provide for connectivity and watershed processses, and integrate monitoring of watershed integrity into project design.

A new General Technical Report from the Pacific Northwest Research Station released in June also lists several planning actions that should be considered to protect watersheds from population pressures, land uses, and rapid climate change.  It suggests that planning should set priorities for watersheds and specific effective protection measures, based on predicted vulnerabilities to climate change and other stressors.   Scenario-based planning should be used to design contingency plans based on plausible events or impacts.   The document also lists considerations in protecting watersheds from energy development, fire and fuels projects, infrastructure development, recreation, water use and diversions, timber harvest, and livestock grazing.

Some researchers have also outlined a “no-regrets” strategy to watersheds and planning for potential hotter and drier conditions.  Based on scenario planning, a Forest Plan could establish baseline protections and make sure that watershed systems are better able to adapt to whatever comes along. 

In a search for a streamlined, easy-to-implement planning rule, the specifics of watershed management may be left out of the proposed text.  However, there is strong support for water planning as a central feature of the rule.  One watershed program manager told me that the rulewriters should avoid making the same error that many in the Forest Service do, assuming that the concept of restoration only appeared on the scene when foresters started writing about it in the 1990’s and 2000’s. Watershed restoration has a much longer history in the agency and the scientific community, and is one of the foundations for why the Forest Service came into existence.  Watershed maintenance and restoration could be the cornerstone of the philosophical underpinning of the rule.

Lessons from Climate Science – Judith Curry Interview

The recent Troubles of climate science have led to some deep thinking (as well as a great deal of vitriol- too bad we can’t use it as a renewable fuel ;)). Here is a thoughtful quote from Judith Curry at Georgia Tech with my italics as she discusses sustainablity. There is an interesting interview with her (from which this quote is excerpted) here.

The point is this. I have gotten hundreds of emails from practicing scientists and engineers in a range of different fields and holding positions in academia, government, and the private sector. I have also had discussions with a number of climate researchers who are concerned about the politicization of the field and the overconfidence in the IPCC. They are encouraging me to continue standing up for the scientific method and against the politicization of science. I’m sure that there are some of my colleagues that don’t like it or wonder what the point is, but they are not talking to me about it. I am getting feedback from scientists that like what I’m doing.

In terms of something more productive to do, I would encourage climate scientists to reflect on how to dig out from the hole we’ve dug for ourselves. Time to listen to some new ideas and some new experts. This time, I suggest listening to a plurality of viewpoints, and for scientists to make sure their data and methods are transparent to the public. And stop trying to simplify all this into a straight climate change science drives global energy policy strategy, which was misguided and naïve, to say the least. The real problem is sustainability, which is a complex confluence of ecosystems, food, water, energy, population growth, finite natural resources, and the desire for economic development. Sustainability is a value that nearly everyone can share. The fundamental spatial unit of sustainability is the region, which makes it easier for people to identify their common concerns and secure their common interests. Yes, there are global elements to all this in terms of climate change and finite natural resources, and the realization that regional instabilities can have global consequences. It’s not a simple problem, and there is no silver bullet, but there are millions of little solutions that can all add up. Climate change needs to be considered as but a single element in the context of all these issues. And independently of the broader sustainability issues, we need rational energy policies that account not only for environmental issues, but also economic and national security issues.

Once you start thinking about sustainability and the broader issues of energy policy as the main challenges, and not climate change, then the overwhelming barrier of politics and economics becomes less monolithic. And more importantly, climate science can get back to being science rather than being about politics. My citations of Feynmann on the RC thread were to remind people of the difference. Climate science is a fascinating and important scientific problem. Lets step back and figure out how to do a better job so that our field can regain the respect of the Nobel laureates in physics, scientists and engineers from other fields, and credibility of the public. Most importantly we need to stop playing the power politics of climate science by saying “Here is what science says we must do” and start saying “Here is our best understanding, and here is where our uncertainties are . . .”

Note: when Curry refers to RC, she means a blog called Real Climate.

Changes Proposed to NFMA Species Viability Requirements

Proposed changes to the NFMA planning rule species viability provision were presented to the public at last week’s National Roundtable on the proposed planning rule in Washington D.C.  The viability provision, intended to fulfill the diversity requirement of the National Forest Management Act, has been the most contentious element of previous attempts to change the NFMA planning regulations (or rule).

The proposal would make five major changes to the species viability requirement of the existing 1982 rule.

1. The requirement would apply to all species, not just vertebrates. The following categories of species would need specific attention in a forest plan: (1) contribution to recovery of Threatened or Endangered species; (2) conservation of “species at risk” to preclude listing (species at risk are candidate, proposed, and other species for which loss of viability is a concern across the range of the species); (3) conservation of “species of concern” to prevent extirpation from the plan area (“species of concern” are rare within the plan area but are relatively secure throughout their range.)

2. The plan would need to provide “ecological conditions” (rather than “habitat”) to support viable populations of native species in the plan area.  Ecological conditions would include components of the biological and physical environment that could affect diversity of plant and animal communities and the “productive capacity of ecological systems.”  The components could include not only habitat, but roads and other developments, human uses, and non-native invasive species.

3. Rather than selecting “management indicator species” to monitor, there would be a “strategic” selection of a “small set” of focal species. Focal species would be those whose status and trends are likely to be responsive to changes in ecological conditions, permit inference to the integrity of the overall ecosystem, and provide meaningful information regarding the effectiveness of the plan in maintaining diversity of plant and animal communities. The rule would require two levels of monitoring – the first level would be specific to the forest, and the second level would require coordination between the Forest Supervisor, Regional Forester, and Station Director for those species whose range is wider than a forest.

4. The rule would contain language similar to the 2005/2008 rule that provided for species at two levels or “filters.” The first level, is the “ecosystem level”, and the plan would guide the maintenance or restoration of structure, composition, processes and diversity of healthy and resilient ecosystems (lots of buzzwords there – new terms of particular importance are “restoration” and “resilience” – the rule attempts to relate those two terms by explaining that the goals of restoration are to assist in the recovery of resilience and adaptive capacity of ecosystems) Also, the idea is intended to be consistent with NFMA’s diversity provision that uses the notion of “community.” The second level would be the species level, but like the 2005/2008 rule, the intent is that most plan direction would respond to the first level and not the second.

5. Specific language would be added to the rule to explain that the species viability obligation is “within the authority of the Forest Service” and the “capability of the land.” This addresses cases where factors affecting viability are outside of the agency’s control. Note that these provisions may also be relevant when changes in climate would change the capability of the land.

The draft proposed rule will begin the clearance process in the Forest Service and the Department throughout August and Sepctmber. In October, it will be submitted to OMB and other federal agencies. The proposed rule and DEIS will be published in December, with public comment from January to March.

Further information is available on the planning rule website.

Planning Rule Text Reviewed at Fourth National Roundtable

Proposed text for a new Forest Service planning rule was shown to the public at a Fourth National Roundtable last Thursday and Friday in Washington D.C.  Approximately 90 public participants and about 35 Forest Service employees discussed the specifics on how the rule might guide Forest Plan revisions and amendments.  About 20 people also watched the proceedings online and participated in a “virtual” discussion forum.

The meeting began with the Forest Service rule-writing team discussing what they had heard at previous meetings, and what concepts they were proposing.  They focused on five key areas: collaboration, monitoring, recreation and other multiple uses, plant and animal diversity, and ecosystem restoration and resilience.  Then participants were broken into smaller groups for further discussion.  On the second day, the Forest Service planning team talked about the overall planning framework (assessments, revisions, monitoring) and addressed additional questions about climate change, water, social considerations, fire, roads, and the objections process.

Several key issues emerged from the discussions. 

There is considerable confusion about how a planning process will address multiple uses given several ecological concepts that are embedded in the rule, such as restoration, ecosystem resilience, ecosystem services, and sustainability.  For some, those ecological concepts are too fuzzy and are confusing. 

There is general agreement with the principles of collaborating with the public and other governments, but many felt there isn’t much in the proposed language about how collaboration will be conducted.  There are questions about basic requirements, how all views will be considered, and how it will be related to decision making. 

There is also agreement about the increased emphasis on monitoring, especially the requirement to include broad-scale monitoring larger than a specific National Forest.  However, there is confusion about how monitoring data will be used, and what role monitoring will play in triggering plan revisions and amendments, or changes to projects.  There are questions about how to respond fast enough once a problem is identified through monitoring.  There are also questions about how monitoring data will be available to the public.

A complete report of the discussion is available on the planning rule website and blog.

The development of the planning rule is moving quickly.  Using feedback from the Fourth roundtable, the planning rule blog, a National Tribal Roundtable, and internal Forest Service discussions, the Planning Rule Team will finish a draft of the proposed rule and write a Draft Environmental Impact Statement.  The draft proposed rule will go through clearance in the Forest Service and Department of Agriculture throughout August and September.  In October, the Department will submit the proposed rule and DEIS to the Office of Management and Budget and for review by other federal agencies.  The proposed rule and DEIS will be published in December 2010, with public comment from January to March 2011.

The Forest Service and Recreation- A Cinderella Story?

Discussions with my coworkers are among my favorite parts of going to work each day. One thing they regularly do is ask challenging, stimulating questions.

Last week, one asked “why is there such a push to get FS recreation or heritage facilities moved to the Park Service?” “It seems to be a pattern, and what underlies that?” Here are my thoughts in response to that question. I’d be interested in others’ thoughts.

First, there are actually three patterns. One is “place based legislation divvying up areas for uses” that we have discussed on this blog, and Martin has done some fine work. The second is “Wilderness legislation” which also takes pieces of land and makes specific prescriptions. Here is a letter posted today that talks about what that feels like to a local outfitter. The third is “transfer to the Park Service” which also takes pieces of land and gives them certain kinds of management (usually recreation/visitor oriented).

Second, in some discussions on the planning rule I have gotten the impression that somehow the FS doesn’t take recreation as seriously as we might- which could lead to the idea that facilities will be better handled and budgeted for by the Park Service. When we have brought up the recreation interests of various stakeholders, sometimes the discussion goes to “we can’t treat it differently than the other multiple uses” or “we are handling that through social science.” If I were a recreationist and heard that, I would feel, to some extent, like I was being blown off.

Recreation is not just another multiple use. Recreation is something that all the people of the US can do on our federal land. We all don’t have grazing allotments, or houses that need fuelbreaks near them, let alone dams, or gas wells, or pipelines or powerlines, but we all can visit and enjoy the national forests. On every forest I’ve ever worked on, from hunting and fishing to hiking to skiing, recreation has been a key use of the national forests. Recreation is different. It is where most of the owners of the national forests interact with the land and the employees. It could easily be considered (with water) a preeminent use. It actually is a preeminent use, but for some reason it seems to be hard for the FS to admit and organizationally get behind.

Is it because many FS employees come from a vegetation background? Is it because the recreation users tend to be in conflict with each other rather than having a united front for getting funding (say, compared to State Foresters)? Is it an artifact of an internal stovepiping? What do we think we’ll have as a #1 priority for most of the landscape in 20 years? 50 years?

As I’ve said before, the number of dispersed campers on weekends in the summer in Colorado and during elk season from New Mexico to Idaho is staggering and probably uncounted. There is an important niche for recreation that is more open to more uses than in National Parks (dogs on trails, dispersed camping, OHVs). What do you think is missing for the FS to give recreation the emphasis it deserves? Or do you agree that it is not “just another multiple use?

Aerial Fire Retardant Court Decision

Yesterday (7/27), in a lawsuit brought by FSEEE, U.S. federal district court Judge Donald Molloy ruled that the Forest Service had violated the National Environmental Policy Act and the U.S. Fish and Wildlife Service and National Marine Fisheries Service had violated the Endangered Species Act in regard to the Forest Service’s use of aerial fire retardant. The retardant is used primarily in the West, with California accounting for half of the over 20 million gallons dropped from airplanes and helicopters annually. The retardant, which includes ammonia-based fertilizer, is toxic to fish and threatens rare plants.

The judge ordered the Forest Service to prepare an environmental impact statement and complete ESA consultation with FWS and NMFS by December 31, 2011. He also warned that failing to do could be met with sanctions, including contempt proceedings, which wouldn’t be the first time.

Read the 79-page court decision.

Seattle Times on Conservation Northwest Proposal

People seem to be working together successfully…

Environmentalists, loggers push new wilderness deal in Northeast Washington
Seattle Times article here.

However, some are unsure if they are satisfied with the proposal, including cattle ranchers and motor-sport enthusiasts.

“They’ve done some groundbreaking stuff, but that coalition has been a teeter-totter between environmentalists and timber companies,” said resident Eric Weatherman, who is organizing backcountry vehicles users so they have greater voice in the debate. “Our opinion is it should be a triangle, not a teeter-totter, and the third piece is recreational users”

Fitting Protections to Program Size- A Timber Volume Retrospective

Here’s a link to FS volume sold from 1905 to 2008. The longer term graph (page 2 of the previous link) is more illustrative than the one above.

In my view, the historical table and graph definitely raise the question about whether the analytical and monitoring needs for protection of the environment and species for an 10-12 BBF program should be scaled back for a 2 BBF program. If we stopped “bayoneting the wounded” (in Jack Ward Thomas’ terms) what funding could that potentially free up to pursue other environmental goals?

Here’s a quote from Charles Wilkinson of the University of Colorado Law School (member of 1999 Committee of Scientists) in a July 23rd High Country News article on Vermillion Basin oil and gas leasing that acknowledges that conditions have changed since the old timber days…

Over the last year and a half, the Obama administration has made a variety of commitments to protect sensitive landscapes, cut greenhouse gas emissions and develop renewable energy sources. With that, Wilkinson can imagine a “more sensible onshore policy emerging” from the administration, but he adds, “I don’t know if they’ve reached their moment of decision yet.” He equates the issue to the problems the Forest Service faced over four decades, trying to improve forest management while keeping the timber cut high. It wasn’t until timber harvesting came down that environmental conditions on the ground genuinely improved. “We’ve got to bring the barrels down, too,” Wilkinson says.