Two Mountain Pine Beetle Stories: Winter Weather and Germination of Old Cones

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We’ve been light on biology stories lately…

This one is from the Cowboy State Daily.  Don Day is a Wyoming meteorologist who, among other things, does forecasts in the Cowboy State Daily.

The story is about how people perceive bad winters through time.

Pine Beetles Aren’t Evidence Of Worst Winters Past

In addition to grafting selective memories of bad winters into supposed long-term trends, people also can mistakenly apply regional patters to other areas, Day said.

That’s the case with pine beetle infestation, he noted. During the 2000s and 2010s, pine beetles cut a swatch of death through forests across Wyoming and the West. To this day, large stands of dead pine trees are reminders of the havoc they wreaked.

A common narrative is that a lack of prolonged winter deep freezes failed to kill of beetle larva, allowing them to hatch during the spring and invade areas they’d never been in before, Day said.

People will use that as evidence that winters used to be a lot harder, he said. As the story goes, sub-zero cold snaps would go on for weeks and kill off pine beetle larva, but that quit happening because our winters got milder.

But that’s based on assumptions that conditions in the Canadian Rockies, where the beetles originated, apply across the American Rockies as well, Day said.

In truth, the Canadian Rockies are actually lower than the American Rockies and can be susceptible to polar air sinking down into them, driving temperatures to 30 below zero or so for extended periods. That’s kept the beetles in check there Day said.

But when the beetles managed to spread southward, they were able to survive winters in the American Rockies in much greater numbers, Day said.

“In southern Alberta and British Columbia, the arctic air masses can go deeper and the tree lines are lower,” Day said. “It can’t get that cold for that long in the central and northern American Rockies, it just can’t.”

So, people have “imprinted” conditions in the Canadian Rockies to mountains in Wyoming, creating the false impression that winters here used to get colder and stay cold for longer than they do now, Day said.

The up-and-down cycles of snowfall in the Cheyenne area. (Courtesy Don Day)

This one is from Chuck Rhoades of the Rocky Mountain Research Station. It’s one of their “Science You Can Use (in 5 minutes)” series. Check out the new RMRS website.

Of course, as he says, if desirable lodgepole stocking levels are 150 per acre, it doesn’t take many cones with 26% germination to provide that number, depending on other site conditions. At this point, I’d still bet on the lodgepole.. unless there’s a reburn before the next generation produces seed. Some of us will be around long enough to find out…

Compared to seeds from live or recently killed trees, seeds from these long-dead trees germinated about half as often. Germination varied across the study sites, ranging from 26 percent to 41 percent. Germination also declined with cone age, and 35 percent of the oldest cones produced no germinants at all. The team also tested germination of seeds in cones stored in the soil seedbank under snowpack. These seeds averaged 36 percent germination, which was comparable to seeds released from the canopy seedbank. Though this is good news, cones in the soil seedbank are susceptible to burning by surface and ground fires and predation by rodents.

For many lodgepole pine forests burned in the recent fires, postfire tree densities will meet or surpass acceptable stocking levels (i.e., 150 seedlings per acre). However, based on these RMRS findings, stands with high bark beetle mortality may not provide enough viable seed to reach the minimum density of seedlings needed for recovery. Thus, the double disturbance of bark beetle outbreaks and wildfire may translate into costly reforestation projects.

PM 2.5 and Prescribed Fire: Great Article from KQED!

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Some people might be getting tired of the PM 2.5 topic… and plus with current fire retardant issue,  the idea that EPA – the agency that, as we have seen, can’t keep track of the money it’s spending, uses un-ground-truthed wildfire risk models developed by an NGO without any transparent government oversight..  doesn’t have enough employees to do what they are already tasked with.. and doesn’t play well with land management agencies. per GAO. And then there’s the perceived need to blame neighboring states for  miniscule amounts of ozone pollution in Denver.

Nevertheless, I thought that this was a super article by reporter Danielle Venton of KQED.  It is long and comprehensive, as befits a piece on such a complicated subject.   I like the way she structured it.

1. Updating the standard is good, say public health, air regulators and the EJ community.  According to a quoted source, it saves lives, especially those of communities of color.

According to the story, it’s particularly a problem om Southern California and the San Joaquin Valley.  As a former resident of Southern California, home of all income levels and races, I think it might be better to target specific producers of whatever pollutants are leading to increased asthma.

“Everyone knows a parent who has brought their baby, or their 2-year-old, into the ER because they couldn’t breathe. You know, the baby’s turning blue,” Amsalem said. “It’s a story you hear across generations.”

If you go to the linked article here, you find about the San Joaquin Valley

Because the region is surrounded on three sides by mountain ranges, pollutants get trapped in the valley. Wildfires — such as the blazes that have dirtied the valley’s air this summer — exacerbate asthma symptoms and send more kids to the emergency room.

Wildfires likely contributed to the high rate of childhood ER visits for asthma in Del Norte County in 2016 — 121 visits per 10,000 children — which represents an increase of more than 40 percent from the previous year. Del Norte, which sits along the Oregon border, had the fifth-highest rate in the state in 2016.

And if we look at the map, Imperial County has the problem of dust from the Salton Sea drying up.  I’m not sure that wildfires or the Salton Sea will be helped by a new PM2.5 regulation.

If you go to this story you can click on the counties.

2. Wildfires are bad for PM 2.5

It still amazes me that people never noticed this until wildfires were blamed on climate change. All those discussions in California about why wildfires are good.. and this didn’t come up until the last few years.

Today, with emissions from the worst pollutants down by more than 70% (PDF), the EPA estimates the Clean Air Act saves 230,000 lives annually and hundreds of thousands more from asthma, bronchitis and heart attacks. Public health experts estimate the benefits of all these lives saved and hospital visits avoided into the many trillions of dollars.

Wildfires are now a major producer of both carbon emissions and tiny specks of sooty pollutants known as PM 2.5. A 2022 study from the National Center for Atmospheric Research found that wildfire pollution was beginning to reverse decades of clean air gains. (Researchers at Stanford in 2020 had similar findings [PDF].)

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The EPA estimates a third of the PM 2.5 we breathe in this country is from wildfires. For those in the West during wildfire season, it can be 90%.

And if wildfire trends continue and worsen, as climate models suggest they will, then we’ve seen nothing yet.

2. But to reduce wildfire smoke, we need to have prescribed fire (or burn excess fuels in some kind of smoke free environment, which seems possible, but not at the scale we’re talking about). And here’s a process the EPA has:

However, EPA officials recognize that sometimes air districts are out of compliance through no fault of their own. In this case, they are allowed to file for an “exceptional event.” In this bureaucratic process, the “event” is linked to the cause of pollution going over the legal limit. It is meant for events that are unforeseeable and are unlikely to occur in the same location again, like a volcanic explosion. If the link can be made, then emissions from that event can be subtracted from the total, and the air district is no longer in trouble with the EPA.

It is a long, technically involved process. A California Air Resources Board (CARB) exceptional events filing (PDF) for ozone concentrations during the Northern California wildfires of 2020 runs 228 pages.

You’re kidding me.. California taxpayers paid for CARB employees to write about ozone from forest fires?  Isn’t there anyone who is interested in “useful and efficient” regulation rather than unclear and wasteful regulation?

The problem, as seen by many in the wildfire science community, is that while this process essentially means air districts are not on the hook for wildfire smoke, they are on the hook for prescribed fire smoke. And prescribed fire — the most affordable, effective inoculation against future wildfires — has never been used as a basis for an exceptional event in California.

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The EPA also seems aware of these concerns. In its proposed rule, it says it acknowledges stakeholder concerns about the importance of prescribed fire and intends to work with stakeholders to address these issues. It also says prescribed fires have the potential to qualify for exceptional events (PDF), which could encourage their continued and expanded use.

However, this has environmental lawyers very concerned. Sara Clark of the law firm Shute, Mihaly and Weinberger works with nonprofit organizations and supports prescribed fire and Indigenous cultural burners. She thinks the EPA’s reasoning as written might not hold up under a judge’s evaluation.

“[The EPA] does a lot of linguistic acrobatics to try and clarify how a prescribed fire is … not reasonably preventable or controllable. But it’s called a ‘controlled burn,’” said Clark. “I’m concerned about the legal underpinnings there.”

She also believes that the time and technical expertise needed to file for an exceptional event exemption would make air regulators wary of using it. Extensive documentation and analysis is needed to submit for an exceptional events determination from CARB or the EPA.

A recent Government Accountability Office report echoes these concerns. The report says the EPA could do a better job working with other agencies to reduce impacts from wildfires (PDF), including making it easier to conduct prescribed fires.

Stakeholders interviewed by the GAO said that state and local agencies aren’t likely to use the exceptional events provision for prescribed burns because “the agencies would not likely approve prescribed burns that could cause National Ambient Air Quality Standards exceedances in the first place.” And they said that “exceptional event demonstrations are technically complicated and resource intensive.”

Put another way, it’s more likely that prescribed burns would never happen if air regulators thought they might have to file for an exceptional event.

It is also legally uncharted, or nearly uncharted, territory. The EPA has received only one exceptional events demonstration for a prescribed burn (PDF) — too much ozone was associated with prescribed burns in the Flint Hills of Kansas in December 2012. But since then, no tribal, state or local agency has submitted an exceptional event demonstration for a prescribed burn, according to EPA officials.

The air districts (who need to keep EPA as much on their side as possible) aren’t worried

Neither Bay Area nor California air regulators seem to share the worries of the fire community that the EPA will hamper the increased use of prescribed fire, however.

She expressed hope that the rule’s implementation phase, which it now heads into, would be the time for nitty-gritty details to be worked out.

“Even though they can be expunged from the data, residents are still feeling [the effects of wildfire] very much so,” said Amsalem, of the Central California Environmental Justice Network. She hopes agencies will work out this issue, she said, “because we do need to do more prescribed burning to reduce the catastrophic events.”

It seems unlikely to me that an agency would willing give up fairly unconditional power over other agencies’ activities, but we’ll  see how this all works out.

Public Lands Litigation – update through April 10, 2023

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New lawsuit:  Western Watershed Project v. U.S.D.I (D. Nev.)

On March 23, Western Watershed Project and the Center for Biological Diversity sued the BLM to stop a vegetation removal plan for over 380,000 acres near Great Basin National Park in the eastern part of Nevada near the Utah border.  The South Spring Valley and Hamlin Valley Watershed Restoration Plan would remove “invasive” pinyon pine and juniper trees.  The lawsuit says the EA failed to adequately analyze harm from the project, partly because it did specify where the activities will occur nor provide site- or species-specific information about the affected environment, and the project failed to comply with land use plans.  (The article has a link to the complaint.)

Court decision in North Cascades Conservation Council v. U. S. Forest Service (9th Cir.)

On March 27, the  circuit court issued a memorandum opinion affirming a district court decision upholding the South Fork Stillaguamish Vegetation Project on the Mt. Baker-Snoqualmie National Forest.  It will harvest trees younger than 80 years, but in areas designated as late successional and riparian reserves.  The court held that the Project will not violate the 1994 Northwest Forest Plan’s prohibition against a “net increase in the amount of roads” in the Project area. It also held that the forest plan required habitat to be evaluated for the forest as a whole rather than within a project area, and it upheld the Biological Evaluation for the Project.  The project also did not violate a plan amendment requiring pre-disturbance surveys because the Puget Oregonian snail is not documented to occur in the Project Area.  The Project complied with NEPA requirements for effects on wildlife and for a range of alternatives.  (However, the court also strangely faulted the plaintiffs for offering “no explanation of how their alternatives would be funded.”)  This article provides more details.

Court decision in North Dakota v. U. S. D. I. (D. N.D.)

On March 27, the district court ordered the BLM to resume quarterly sales of oil and gas leases on public lands in North Dakota after holding that the agency “very likely violated their mandatory statutory duties to plan and timely complete mandatory analyses of individual parcels in North Dakota.”  It had made no ‘determinations of availability’ in North Dakota during Q4 2022, following President Biden’s executive order in 2021 “pausing” the quarterly lease sales required by the Mineral Leasing Act.”  (The article has a link to the opinion.)

Court decision in Cascadia Wildlands v. Bureau of Land Management (D. Or.)

On March 27, the district court granted summary judgement in favor of the BLM and upheld a 2020 rule eliminating the agency’s protest process.  Intervenor American Forest Resources Council stated, “Even without the BLM’s process, the agency’s level of public engagement during project planning is consistent with the procedures of other agencies, like the U.S. Forest Service, and continues to provide for an administrative appeals process to the Interior Board of Land Appeals.”  (The article includes a link to the opinion.)

On March 27, the Center for Biological Diversity notified the U. S. Fish and Wildlife Service of its intent to sue the agency for failure to respond within a reasonable time to the “Petition for Rulemaking to Protect Endangered Species from Pesticides by Restricting Pesticide Use in Critical Habitat” (Petition), dated January 7, 2019.  It mentioned the California spotted owl as one of the species affected by pesticides, and cited 40 “highly imperiled, narrowly endemic species that would receive the greatest benefit from a prohibition on the use of pesticides within critical habitat.”

Supreme Court decision Wilkins v. United States

On March 28, the U.S. Supreme Court issued a 6-3 decision allowing a Quiet Title Act lawsuit to proceed by two landowners attempting to close off public access to Bitterroot National Forest lands.  The court found that the statute of limitations on a 1962 easement with the Forest Service did not deny the landowners standing to pursue their claim that the Forest Service allegedly altered the terms of the easement to allow public use of the Robbins Gulch road.

Preliminary injunction in Monroe County Board of Commissioners v. U. S. Forest Service (S.D. Ind.)

On March 29, the district court issued a preliminary injunction against the Houston South Vegetation Management and Restoration Project on the Hoosier National Forest, in particular against an imminent prescribed burn.  The project is expected to last between 12 and 20 years, during which time approximately 13,500 acres of forest will be burned, 4,000 acres will be logged and herbicide will be applied to 2,000 acres.  Plaintiffs are concerned about effects on Lake Monroe, a drinking water source, and claim that the Supplemental Information Report does not comply with the court’s earlier reversal of this project. The court agreed that plaintiffs are likely to succeed on the merits, but also ordered the plaintiffs to pay an $11,596 bond, 10% of the amount Forest Service said it was losing due to the delay.  (The article includes a link to the opinion.)

Court decision in Ohio Environmental Council v. U. S. Forest Service (S.D. Ohio)

On March 30, the district court ruled that the Forest Service violated NEPA with its decision to log 2,700 acres, including 1,600 acres of clearcutting, in the Wayne National Forest’s Sunny Oaks Project.  The judge wrote, “The Forest Service has not provided any quantifiable criteria for assessing oak regeneration, either before or after a harvest.  Instead, the Project relies on vague quantitative triggers, like “enough” oak regeneration or a “need” for more.”  The court ordered additional briefing on remedies.  (The article includes a link to the complaint.)

The court dismissed a claim related to the mycorrhizal network associated with oak trees because plaintiffs did not properly raise it in their administrative objection.  The court also found no violation of a forest plan standard “to retain a minimum of 12 live trees per acre (averaged over the cutting unit) of any species that are six inches or more dbh with large areas of loose bark…”  The Forest Service had found that there were currently only six live trees per acre meeting these requirements, that oak trees did not provide the desired bark condition, and the current majority of live trees with more than six inches dbh and large areas of live bark are shagbark and shellbark hickory trees, which are already required to be retained under another forest guideline.  The court accepted the survey data over arguments offered by plaintiffs that oak trees should be protected because they provide the desired bark conditions, and accepted that protecting these other trees would meet the intent of the standard where the specified conditions could not be met.

(I’ve mentioned a concern about this issue in the case before.  I would have to interpret this opinion to mean that in this case the forest plan standard prohibits them from logging any oak trees that have the requisite bark conditions (but there aren’t any).  This would be similar to site-specificity issues involving large trees – the project analysis for NEPA and forest plan consistency needs to look at individual trees that would be logged to determine plan compliance and effects.)

  • Mountain Valley Pipeline

Court decision in Sierra Club v. West Virginia Department of Environmental Protection (4th Cir.)

On April 3, the circuit court found several defects in the review the West Virginia Department of Environmental Protection conducted before issuing a Clean Water Act permit for the Mountain Valley Pipeline that would cross the Jefferson National Forest.  The court found that 139 prior state stormwater permit violations and dozens of state water quality standards violations warranted closer scrutiny, and, “In the face of such a history, it is arbitrary and capricious for an agency to predict compliance without a rational explanation.”  (The article has a link to the opinion.)  (The history of this litigation is long, including here, and here.  But wait, there’s more …)

New lawsuit Appalachian Voices v. U. S. DI. (4th Cir.)

On April 10, lots of environmental organizations filed another petition in the circuit court (pursuant to the Natural Gas Act) challenging a recently issued new biological opinion and incidental take statement under the Endangered Species Act for the Mountain Valley Pipeline.  The BO addressed six threatened or endangered species and critical habitat for one of them.  (Previous consultation was reversed twice.)  (The article has a link to the petition.)

On April 3, the Idaho federal district court sentenced an Idaho man to one month in federal prison, payment of $8,000 in restitution and banned him from entering all National Forest System lands for a period of three years.  He had been removing more trees than his permit allowed to sell as firewood, and creating unauthorized roads and campsites in the Payette, Nez Perce and Boise National Forests.

New lawsuit:  Orutsararmiut Native Council v. U. S. Corp of Engineers (D. Alaska)

On April 5, three Yukon-Kuskokwim Delta tribes challenged the EIS used to support the U.S. Army Corps of Engineers’ 2018 wetlands (404) permit for the proposed Donlin open-pit gold mine on BLM lands.  Specifically, tribes are asking that the federal agencies be required to study impacts to downstream waters and villages from a potentially catastrophic tailings dam failure.  If developed, Donlin, located in the headwaters of the Kuskokwim River system, would be the largest open pit gold mine in North America.  (The article includes a link to the complaint.)

The Pueblo of San Felipe is suing the BLM for allegedly violating a federal land patent from 1864 by changing the boundary with the Pueblo to remove 695 acres of their patented land in New Mexico.

Court decision in Alliance for Hippocratic Medicine v. U. S. Food and Drug Administration (N.D. Texas)

On April 7, the district court for Northern District of Texas reversed the Food and Drug Administration’s approval of the abortion pill mifepristone, concluding the agency ignored safety concerns due to political pressure.  This is a high profile case involving the Administrative Procedure Act, which will likely get Supreme Court review of the amount of deference courts should give to administrative agencies.  The relevant holding from this court:

But the agency “must cogently explain why it has exercised its discretion in a given manner,” and that explanation must be “sufficient to enable [the Court] to conclude that the [agency’s action] was the product of reasoned decisionmaking.” A.L. Pharma, 62 F.3d at 1491 (quoting State Farm, 463 U.S. at 52). Defendants have not done so here. FDA’s 2016 Actions were not the product of reasoned decision-making.

The American College of Obstetricians and Gynecologists lambasted the decision as “inflammatory” and “brazenly” substituting “the court’s judgment for that of trained professionals.” Other agencies may find that the outcome of this case affects their discretion as well.

 

The Meta-Fire Retardant Dialogues : How Best to Manage Practice Improvements?

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https://wildfiretoday.com/2021/04/16/a-9-year-usfs-aerial-firefighting-study-left-many-questions-unanswered/

 

So the current fire retardant issue is  interesting, not least because the current and past fire retardant lawsuits have been brought by one of our very own TSW contributors, Andy Stahl.  Who may or may not be able or want to talk about it much. It doesn’t seem like the agency “cone of silence” around litigation applies to plaintiffs.

Anyway, I’ve spoken to current wildland firefighters, retired fire folks, and Andy, and as usual tried to fit all the points of view into a whole zone of agreement.  I was listening to, of all things, a podcast called  “The Witch Trials of J.K Rowling” developed by The Free Press.  On one episode (Chapter 6), a teenager named Noah spoke about (on a completely different subject) encouraging the good things that can happen and discouraging the bad things that can happen.  And of course, isn’t that applicable to many policy issues?

What makes fire retardant more interesting than many of our TSW debates, I think, is that we agree on what good things and bad things are.. or do we?  Good things would be helping fire suppression folks save valuable human and ecosystem assets, and for human health and safety- of firefighters and residents.  Bad things would be dumping in streams or on firefighters. So first TSW discussion question… Do we agree on good things and bad things? Are there more good things or bad things I haven’t considered?

But the meta-dialogue is “how best to increase the good things and decrease the bad things?”  Who should be in the room to decide? Should there be carrots or sticks or some combination?  How are wildfire practitioners and the air resource industry involved?

If I had to guess about Andy’s motivations, it would be to put pressure on the USG to work harder to decrease the bad things.  But the danger with this approach is that involving another federal agency- in this case the EPA-may not be actually all that helpful in terms of adding value to the work- the ultimate work of trying things and doing lessons learned that the fire community is generally better at than most.

So let’s think about some other examples.  For some reason, I thought of healthcare-associated infections. The below is from the Florida state website.

The Agency for Healthcare Research and Quality has shown that the implementation of recommendations for HAI prevention from the CDC Healthcare Infection Control Practices Advisory Committee (HICPAC) can reduce HAI by 70% overall and virtually eliminate some specific types of infections.  Broad implementation of the CDC guidelines saves lives, reduces suffering, and decreases health care costs.  Through partnerships and the commitment of stakeholders, the Florida Department of Health (FDOH) HAI Prevention Program supports health care facilities implementing best practices for preventing the spread of health care-associated infections. Health care facilities are asked to conduct surveillance or track HAI infections, ensure health care workers perform hand hygiene before and after patient contact and when they come in contact with body fluids, use personal protective equipment such as gowns and gloves, minimize use of devices (i.e. catheters), and ensure the patient care environment has been cleaned including the proper cleaning of shared medical equipment such as blood pressure cuffs and glucometers.

So suppose a similar approach was taken for fire retardant. Maybe we would disagree on who would be the best people to put on the advisory committee (HICPAC)   Or would we?

It seems as if in this health case, it is assumed that everyone wants HAIs to be reduced and the academics and practitioners work together to figure out ways to do that. On the other hand, what might make the fire retardant issue is that big bucks are involved and specialized technologies in extreme and dangerous conditions.  Not exactly handwashing or antiseptics.

An Advisory Committee of knowledgeable and experienced people could help add to knowledge and dive into the weeds of specific practices, jointly look at accidents or errors, different formulations, new technologies and lessons learned.  And actually with the big bucks out there for new technologies (drones, AI, and so on) maybe an advisory committee should tackle all that? And no, I don’t think the current Wildland Fire Commission has the right folks to take that on.

With open meetings, public comment and all that.  Because it seems like trust is super-important.  As in the classic difference between the chicken and the pig at breakfast- the chicken is involved, but the pig is committed.  Similarly, communities in wildfire areas (which can be much of the US) may not want to be guinea pigs for new technologies- nor may wildland firefighters.  So it seems to me in this case, the more involvement and trust-building the better.

To me, this would seem like a more useful approach than asking the (in their words) overburdened and (in my words) currently non-expert EPA to do a rule and then apply for a permit.

Do you have other examples of mechanisms for how agencies work to increase the good, and reduce the bad, of practices?

And people have studied aerial firefighting.. I think if you read Bill Gabbert’s post here you’ll get some idea.  What I got from it was that you need to actually know the business to know what needs to be improved and how. Which most of us do not.

 

Smokey Bear on Parade

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Bridgeport Ranger District Fire Control Officer Marion Hysell welcomed Smokey Bear to the Bridgeport Ranger Station on July 4, 1964. (Note: The 1960s-1970s era U.S. Forest Service shoulder insignia did not arrive in this corner of the Intermountain Region until 1966.)

As fire prevention guard on the Bridgeport Ranger District, Toiyabe National Forest, from 1963 through 1966, I continued the district’s practice of having Smokey Bear appear in Bridgeport’s famous Fourth of July parade. This small town of less than 400, nestled in a verdant valley of the same name at the foot of the eastern Sierra Nevada 85 miles south of Carson City, Nevada, and 85 miles north of Bishop, California, is county seat of Mono County, California, and a popular outdoor recreation center.

One of the larger guys on the fire crew or trail crew was cajoled into wearing the Smokey costume shipped our way from the regional office in Ogden, Utah, for this annual walk or ride down Main Street—U.S. Highway 395—lined by hundreds of local residents and summer visitors.

Smokey sometimes rode on a float accompanied by ranger station kids. On this occasion, as coordinated with the local 4-H Club and led by two of its members, he marched and waved to the parade’s appreciative onlookers.

After the parade, a properly-escorted Smokey always mingled with the crowd in town and then visited with kids in the Toiyabe National Forest’s large Twin Lakes area campgrounds.

Thoughts on DxP and Some Cool New Technical Innovations for Tree Marking: Guest Post by Eli Jensen

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Note from Sharon.. Based on the earlier discussion Jon started here of DxP,  I asked Eli Jensen of Ironwood Forestry to add his two cents and also talk about some of his cool technologies. I wanted the technologies highlighted, so am putting this up as a guest post.

On DxP

Great discussion so far. I own one of the contract marking crews in N-AZ. Inexperienced crew technicians marking trees definitely is a problem, on both contract crews and district crews. It boggles my mind that TSP technicians are not given even one day of operations training. We go out with the loggers any chance we get.. And yes, tracer paint is very expensive, and is perishable, meaning the sale is only really good for 5-7 years. That makes it problematic to prep the massive acres needed for industry. If something goes awry (again), the cost to remark is the same as the initial remark.

That being said, I am an open critic of DxP. I won’t say that it’s never appropriate, but it is not the magic bullet for forest restoration. There are some key shortcomings.

1) As alluded to above, it shifts the cost from sale prep to sale admin. I don’t know the numbers on the district side, but for the rates I charge for daily harvest inspection and the frequency the USFS wants me out there, I think it would math out the same to just mark it.

2) Uncertainty. This is the biggest shortcoming in my opinion. You don’t know the outcome. Sometimes it’s great, sometimes its not. If its not, there’s nothing you can do. To me, the cost savings to not mark a sale pales in comparison to botching a sale. It feels too much like gambling, except we’re gambling with something that belongs to the public, not us.

3) Accountability. The USFS can claim all day long that the contracts have teeth. The truth as I know it, aside from basal area and eyeballing the spacing, the USFS has almost no way to tell the logger they messed up. The logger can take all the nice trees and leave all the crap, and there won’t be any way of knowing. The evidence is gone. The USFS barely knows whats out there when it’s marked. They don’t map the mark in any way. No drones. No mobile LiDAR. Low frequency point sampling to inspect the contractor and low frequency cruise plots and that’s it.

4) Tree quality. And how do you determine what’s “crap”? When I’m marking, I spend A LOT of time looking at tree tops. I train my crew to incorporate win/win scenarios in their decision making. If there’s a crooked tree with a vigorous top and a straight tree with a trash top, we leave the healthy top and give the logger the straight log. I’ve talked to a lot of loggers and they all do their best. There’s not a single one that I think poorly of. However, the idea that they’re going to have the same awareness as someone on foot, while also paying attention to cutting, and trying to be productive while burning fuel, and with an obstructed view? That would take some convincing.

5) Conflict of interest. I get a lot of flack for this, but the USFS needs to face this one head on. Anytime you mention this in a meeting, they change the subject or brush it off. Having a financial interest in which trees are being cut, and being able to decide which trees are cut IS A FINANCIAL CONFLICT OF INTEREST. I am NOT saying the logger will high grade it. I am NOT saying the logger will try and pull a fast one. I am NOT saying the outcome will be poor. That’s not what that means. And it doesn’t matter if the trees are high value or low value. It simple means a conflict of interest exists, and its a BIG liability to ignore that. My main concern is one day some environmental group will cause up some ruckus about something or another, as they do, on a DxP sale. Look at the Jacob Ryan sale on the North Kaibab. A pretty decent sized controversy on the regional scale. CBD was upset too many big trees were being cut. Luckily it was a marked sale so the USFS ultimately was responsible. If it had been DxP, the logger could easily have been blamed, and who knows how widespread that smear campaign could be. If I were a logger, I wouldn’t want the liability.

For these reasons and others, DxP has fallen out of favor with some districts in N-AZ. We’re actually submitting a bid on Monday to mark DxP stands in a sale we remarked last year, before they re-offer.

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Leave Tree Mark using Ironwood’s System (left) and from a competitor using a Panama system (right)

New Technologies for Better Quality Marking at Lower Cost

This sets me up for what I really came here to share with you all. I have been working very hard for a very long time to present alternative options to the USFS and stakeholders. In the last 3 seasons, we have saved the USFS almost a HALF A MILLION DOLLARS on paint. I developed and built my own paint sprayer that saves 75% on paint, and it looks way nicer too. That’s about $30+ an acre. I have presented this to every level of the forest service, from district to the national modernization board. I have not found anyone that cares about saving money on paint, even though it would be just about enough to fund all of the road packages that everyone was so concerned about.

Furthermore, I’ve been introducing increasingly advanced digital tools. In 2020, we started GPSing every tree we marked, with DBH, at no extra cost. That means we can map the planned post harvest stand and know the basal area to the foot. Then I linked it with aerial LiDAR, so you can see a canopy cover map of the planned future stand. Last year, I upgraded that to mobile LiDAR, giving you a high resolution 3D map of the post harvest stand, with census level data (dbh, height, crown height, width, volume) on ALL leave and cut trees. We can turn +-40% cruise data to nearly 100% accurate. We plan to throw a camera module on the scanner to colorize the point cloud for increased realism. It will look like a 3D photograph because it literally IS a 3D photograph.

The neat thing is, the paint savings is less than the cost of the additional remote sensing. It sounds too good to be true, but its not, its just been a lot of hard work and risk taking.

We finally have a project planned for this summer to deliver all of this on a 3500 acre pilot sale. In addition to the above mentioned, we’re testing out a new marking designation, which we are calling Hybrid Flex (HF). It basically a combination of CTM and DxP+ (tablet marking). We expect additional paint savings, now approaching ~93% (97% if we can use commercial paint), significantly increased technician productivity (shooting for 100 acres/day per person), and it comes with all the digital mapping.

We cannot meet the needs of 4FRI with the old methods, but we can with the new. I’m starting to sound like Billy Mays, but there’s more! We’re working towards abandoning paint all together. Augmented reality individual tree marking. No paint. Doesn’t fade. Census level data. 3D photographs of current and FUTURE stands. We could have introduced this over a year ago if we had the buy-in. We’ve got two partners that can do it – one that will do it for free if the USFS will buy the end result, and another that will develop it for a fee and the USFS owns it. Either way, the development would pay for itself in less than a year from the paint savings, just from AZ timber sales.

If you’ve gotten this far, I appreciate your patience in reading all of that. We’re a small company and we’re looking to serve the needs of the USFS and forest restoration in the southwest, but its been phenomenally difficult despite the technical successes we’ve had.

Here is a link to a video we produced after our Dec 2021 demo.

https://www.youtube.com/watch?v=oZDV81EeIYU&t=21s

Chag Sameach and Happy Easter!

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I may have posted this on a previous Passover, but this  video about the schools of Hillel and Shammai and arguments “for the sake of heaven” is one of my favorites. It’s done by the Pardes Center for Judaism and Conflict Resolution.

According to a source cited in Wikipedia (who knows?) Hillel worked as a woodcutter while studying the Torah.

For Christians, some people see that Jesus’ teachings were reflective of the Hillel school.  There’s actually a spendy book from 1997 on this topic called “Hillel and Jesus: Comparisons of Two Major Religious Leaders“.

In another part of the New Testament (Acts 22:3) Paul claimed  that he had been a student of Gamaliel, who was Hillel’s grandson.

Anyway, wisdom is wisdom and Hillel and Shammai both had it. Plus humility.  Virtues still needed today. And this reminds me a bit of TSW discussions.

Mordcha: Why should I break my head about the outside world? Let them break their own heads.
Tevye: He’s right. As the Good Book says, “If you spit in the air, it lands in your face.”
Perchik: That’s nonsense. You can’t close your eyes to what’s happening in the world.
Tevye: He’s right.
Avram: He’s right and he’s right? How can they both be right?
Tevye: You know, you’re also right.

— Fiddler on the Roof

Chag Pesach Sameach! and Happy Easter!

DxP

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Indianapolis Indiana Dead Tree Removal 317-783-2518

One of the threads of this discussion went off on a topic of how much discretion loggers should have in deciding what trees to cut down.  “Tricky Dick” offered that, “The USFS in its office attired lazyness doesn’t want to have to cruise the forest landscape piece by piece and thru honest Forestry discretion , uninhibited by profit motives, mark the bigger trees as ” leave or cut…”  Larry replied with regard to marked trees, but what if they are not marked?  I think there’s a name for that – “designation by prescription,” or DxP.  Here is how the Colville National Forest explains it (2020):

The Colville National Forest in Washington began using Designation by Prescription (DxP) in 2009 in order to become more efficient in timber sale preparation. Marking individual trees with paint in a sale area can be a time-consuming and costly process. DxP saves time preparing a timber sale and money spent on paint by allowing the logger to select which trees to harvest based on a timber stand prescription, which defines the desired condition after harvest.

With DxP, the operator may need to know tree species, how to measure tree diameters, forest health indicators, or how to achieve desired stocking level. This has the potential to initially slow operations. However, the flexibility that DxP provides (the contractor needs only to meet the prescription and that outcome can be accomplished in different ways) can create efficiencies for both the USDA Forest Service and the contractor

Is Tricky right?  But wouldn’t “allowing a logger to select which trees to harvest” allow them to do whatever they want within the broad confines of a “desired condition” in the “timber stand prescription?”  I have lots of questions about this.  How common is this?  Is the “timber stand prescription” part of the NEPA disclosure process in a way that all possible effects of the loggers’ decisions are accounted for?  If they only have to achieve the desired condition, could they do that in a way that is inconsistent with standards or guidelines in a forest plan?  Those aren’t included in the Colville’s “need to know” list above.

Asking for a friend.  Thanks.

New York Times Story on the Alaska Willow Project

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Caribou near ConocoPhillips oil pipelines, which are elevated to allow herds to pass beneath.

 

There are several different lenses I’ve been looking at news stories through. One is a regional lens- so let’s take a look at this story about the Willow Project in Alaska.  This project has had major ENGO forces arrayed against it, and the State folks united for it. Apparently it had bipartisan support in Alaska, plus support of many Alaska Native groups.

As per this quote from Rep. Peltola (D-AK)

 “I am grateful that the court has recognized the fact that Willow is a well-planned and beneficial project for Alaska and the nation, and that this most recent lawsuit should not be allowed to overrule the wishes of Alaskans and the President while it is being litigated,” said Rep. Peltola. “With this decision, the court acknowledges the years that the Willow Project has already spent under extensive litigation and environmental review, the approval of multiple levels of government, and the strong support for the project from the majority of affected Alaska Native groups. It’s finally time for Alaskans to get to work, and I look forward to seeing construction begin as we await the final resolution of this case.”

Anyway, the NYT story leads off with (in the tagline):

“Scientists say nations must stop new oil and gas projects to avoid climate catastrophe.”

Which scientists? There’s a link to the new IPCC report.

While scientists have warned that nations must stop approving new oil and gas drilling or face a perilous future on a dangerously heated planet, the people involved in the Willow project are eager to get going.

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At the earliest, the crude would begin flowing in about six years. By that time, the Biden administration hopes that demand for oil will have plummeted because of federal investments to encourage use of renewable energy and to encourage a transition to electric vehicles.

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Of course, that’s not what the Energy Secretary is saying..

The world will need fossil fuels for decades but they must be paired with technologies that capture their greenhouse gas emissions, Energy Secretary Jennifer Granholm said Wednesday.

The Biden administration wants the U.S. to reach net-zero emissions by 2050 to help limit global warming. It is seeking to displace oil, gas, and coal with renewable energy and electric technologies, but forecasts, including those by the Energy Information Administration, indicate prolonged demand for traditional energy sources.

“We know that even the boldest projections for clean energy deployment suggest that, in the middle of this century, we’ll be using abated fossil fuels,” Granholm said during remarks at CERAWeek by S&P Global, an annual industry conference in Houston.

“Abated” refers to fossil fuel combustion linked with carbon management technologies, which capture emissions so they can be kept from entering the atmosphere.

“We need both traditional and new energy,” added Granholm, who, along with President Joe Biden, has asked the oil and gas sector to increase production to alleviate high energy prices at home and in the larger global energy marketplace.

Her pronouncement comes as many environmental interest groups and some lawmakers in Congress push for policies to block new oil and gas development and related infrastructure to slow climate change.

The administration has supported increased oil and gas production in response to higher prices and the war in Ukraine.

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My bold, decades vs. six years. Maybe the difference is between “hopes” and “beliefs”.. but maybe different people in the Biden Admin have different views.. and it’s not speaking with one voice on this?

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Still, projected emissions from Willow would be a small fraction of the 5.6 billion metric tons of carbon dioxide emitted annually by the United States, the second biggest polluter on the planet after China. ConocoPhillips and the Biden administration both say that if Willow were not permitted, supply to meet demand would just shift to oil drilling elsewhere.

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It doesn’t take a Ph.D. in economics, plus recent experience, to say that reducing supply without decreasing demand leads to higher prices. Which affect the poorest people the most.  It would be interesting if the reporter found someone who would go on record as explaining the mechanics of how supply would not go elsewhere.

Burning all that oil could release nearly 254 million metric tons of carbon emissions. On an annual basis, that would translate into 8.4 million metric tons of carbon pollution, equal to adding nearly two million cars to the roads each year.

Again, it’s not clear to me why reporters continue to make these statements.. I guess anything “could” happen and there is a world in which folks wouldn’t have used those 600 million barrels if they hadn’t been produced in this project.

 “When do you get off fossil fuels?” said Abigail Dillen, the president of Earthjustice, which is leading the lawsuit against the project. “After you destroy one of the most important and fragile ecosystems for wildlife in the world, or before?”

This seems like rhetoric, not an actual path to decarbonization.  The “just say no” campaign directed at producers, not users.

I thought this was curious.. perhaps while the oil fields are “giant”,  500 acres to suck it out is.. not.

To drill profitably in the North Slope, the oil fields have to be “giant,” Mr. Marks said. Although the Biden administration reduced the size of ConocoPhillips’s original plan, Willow will have a footprint of almost 500 acres and at its peak could generate about 180,000 barrels of oil a day.

This was also curious..

The benefits to Alaska, which remains dependent on fossil fuel revenues because it has no statewide sales tax or personal income tax, will be somewhat limited. Willow is on federal land, which means that Washington will receive royalties but that Alaska will be able to collect only oil-production taxes, which would be offset by company tax deductions for expenses. For a few years, until the oil starts flowing, Willow could even have a small negative impact on state revenues.

I’m confused.. aren’t some of those royalties returned to the States? I looked at the BLM website and it says:

All Federal oil and gas royalty, rental fee, and bonus bid revenue is split about half between the U.S. Treasury and the states where development occurred. The amount of annual revenue that Federal mineral development provides to the U.S. Treasury is second only to that provided by the Internal Revenue Service.

In fact, it looks like New Mexico made 2.74 billion from the feds for oil and gas in 2022, and Alaska 45 mill.  Thank you helpful DOI site!

What I like about this story is that Native Alaskans who support the project are interviewed in addition to those concerned about it (and the great photos).

Their attitude seems to be .. if we are going to be using it (oil and gas) why shouldn’t it come from here?  And we get taxes and economic benefits and our own environmental regulations. This seems reasonable to me.

And why isn’t the Energy Secretary’s approach (or maybe it’s the entire Admin, who can tell?) good enough for Earthjustice?