Sensitive species and NFMA?

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Los Padres ForestWatch. The California spotted owl is listed as a Sensitive Species by the U.S. Forest Service and by the California Department of Fish and Game as a Species of Special Concern.

This question came up in the fuel treatment post yesterday, but it is worthy of its own post (wonky as it is).  I think there are some misconceptions out there about sensitive species.  This is without refreshing my memory (which I should do more often any more), but I was heavily involved in lots of this.

NFMA does not require identification or protection of sensitive species.  NFMA requires plant and animal diversity.  Habitat for viability is a requirement for diversity in the planning regulations (old and new).  Sensitive species have never been found in the planning regulations.  To the extent there was an implied regulatory requirement in the 1982 regulations, it was for viable populations of management indicator species (MIS).

“Sensitive species” was apparently created by the Forest Service (I’m guessing the Wildlife staff) as a means of both meeting the NFMA viability requirement and preventing listing under ESA, and requirements for sensitive species (including preparation of a Biological Evaluation) were to be applied to both plans and projects. The details may be found in FSM 2670 (which also addresses ESA requirements) and FSM 2620.  The current version of these is dated 2011, prior to the 2012 Planning Rule.  (The agency has frozen up in its efforts to update this manual direction.)

This led to a lot of confusion, even by judges, regarding what was required at the project level.  It sometimes appeared that parties/judges were saying that the NFMA viability requirement applied to each project (like ESA).  At one point (2004ish?), the Forest Service, issued an interpretive rule to clarify that the viability requirement in the 1982 planning regulation applied only to forest plan decisions (unless the plan imposed its own viability requirement on projects, which some did).

It also made this problem a focus of its efforts to produce a new planning rule.  Language now makes it clear that nothing in the 2012 Planning Rule applies to projects, and specifically the new requirements for species of conservation concern (SCC) apply only to forest plans (and projects must be consistent with what the plan says).

Meanwhile, forest plans that are being revised are following the new requirements for species of conservation concern. The Forest Service issued an internal letter to regional foresters on June 6, 2016 explaining that it would phase out the sensitive species designation. It recognized that, “As noted in the preamble to the 2012 planning rule, “[Regional Forester Sensitive Species] are…similar to species of conservation concern.”   It also stated that, “Applying both systems on the same administrative unit would be redundant.” Consequently, “Once a revised plan is in effect, the Regional Forester’s Sensitive Species list no longer applies to that unit.”

The letter acknowledges that a biological evaluation must still be prepared for a revised forest plan.  The letter doesn’t specifically instruct forests that have not revised their plans to keep preparing BEs for projects, but the Manual direction is still in place, so it is still official policy.

One observation I’ve made in reviewing forest plans revised under the 2012 Planning Rule is that sensitive species are often NOT considered “similar to species of conservation concern.”  Many sensitive species (with “viability concerns”) have not been designated SCC (“substantial concern about the species capability to persist over the long term in the plan area”) during forest planning.  Why is that?

The other thing I’ve seen when forest plans are being revised is that the Forest Service is not doing a very good job of explaining to the public that they are no longer going to have project analysis requirements for at-risk (but not listed) species separate from NEPA, and that some species they used to address at the project-level may not be addressed at all after the forest plan is revised.

WA Post: California’s giant sequoias are burning up. Will logging save them?

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Fairly good article overall, except (in my view) its gives far too much space to Chad Hanson’s views, albeit with a note about other scientists’ criticism of them. The title ought to have been “Will logging and prescribed fire save them?” The article is apparently not behind the Post’s paywall….

Excerpt:

The scale of what some foresters and researchers are calling for in places such as the Sierra Nevada amounts to a wholesale re-engineering of the forest. They say the land management policy that prevailed during much of the 20th century — of putting out most wildfires — has led to overgrown forests. During the past two decades, as climate change has intensified, drought in the West has killed many of those trees, leaving downed logs and dead snags — the “fuels” that firefighters say create hotter and more destructive wildfires.

Before colonists settled the West, forest fires caused by lightning, and set routinely by Native Americans, helped thin out forests. Back then, it was typical to have about 50 trees per hectare in the Sierra Nevada and southern Cascades, whereas now some forests have 300 to 400 trees per hectare, according to Alexis Bernal, a researcher with the University of California, Berkeley who studies giant sequoias.

What Stalled the U.S. Forest Service from Fuel Treatments Around Grizzly Flats? Capradio Article

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This is a really interesting story.. thanks to Michael Wara on Twitter!  It goes into the nuts and bolts of why a project on the Eldorado didn’t get done on time to help a community.  A conversation followed in which the question was asked whether fuels funding is targeted to the communities that need it most or have more people/political clout or matching funds due to people/political clout.  This was a topic of discussion in Colorado even back when I was working.. partnerships are good and to be fostered, but to what extent is there also an environmental justice component and how should that be addressed? For example, the State of Colorado requires less of a match for state wildfire mitigation grants in areas that it has mapped as lower income.

Anyway, really good and lengthy article, lots of interviews with FS folks, no paywall so you can read the whole thing. There’s several pieces about “what slowed the project down that could have helped.”

  • The Forest Service originally committed to finishing the Trestle Project by 2020 — a year before the Caldor Fire would later ignite. Due to a complex web of regulatory delays, logistical challenges and resource shortages, the agency pushed back the completion date to as late as 2032 — three decades after its initial warning to Grizzly Flats.

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Nelson helped devise the Trestle Project as a big step toward his goal. It would create a miles-wide fuel reduction buffer east and south of Grizzly Flats.

When the Forest Service finally announced the project in 2013, the agency sent a letter to residents describing 16,000 acres of planned work. (A miscalculation led to the document overstating the work by nearly 1,000 acres. The actual number was just over 15,000.) It laid out an expeditious — and optimistic — timeline. The analysis was supposed to take about a year, with the forest management work scheduled to wrap up by 2020.

Almost immediately the project encountered an onslaught of hurdles and delays.

“It’s sad to think about what could have been,” said Michael Wara, a climate policy expert at Stanford University who recently toured Grizzly Flats. “[If] all this work was done by 2020, Grizzly Flats might still be there.”

‘We Don’t Have That Kind Of Time Any Longer’

One of the most aggressive objections to the Trestle Project came from Chad Hanson, co-founder of the John Muir Project, a nonprofit that aims to protect biodiversity in national forests and fiercely opposes tree removal. One of Hanson’s primary concerns was the spotted owl, which is designated as “threatened” under the Endangered Species Act.

In a written objection to the Forest Service in 2015, Hanson argued the Trestle Project would “pose a serious and unacceptable threat to owl populations on the Eldorado National Forest.”

Elsewhere, Hanson has argued that commercial tree removal could exacerbate wildfire intensity. Leading fire scientists have publicly pushed back against a number of Hanson’s claims; one expert even called his positions “self-serving garbage.”

The project’s 296-page environmental impact statement devoted dozens of pages to analyzing potential impacts on the spotted owl. The report also invited public comment that demanded thoroughly researched responses from the Forest Service. The agency developed alternative maps, taking into account spotted owls and sensitive species of frog and trout.

The Forest Service also put out other reports, including one that identified a likely ignition point very close to where the Caldor Fire would later start.

As the Forest Service spun out reams of paperwork, Almer reminded the agency that Grizzly Flats remained woefully exposed to wildfires that were growing more severe every year.

“The most aggressive treatment of the [Trestle Project’s] fire fuels is critical to preventing the ‘loss of our community,’” wrote Almer in a 2015 public comment about the project on behalf of the Grizzly Flats Fire Safe Council. “Everything that can be done, must be done.”

He followed up this plea with a 2017 letter addressed to Randy Moore, who at the time led the agency’s Pacific Southwest Region.

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Over the next four years, the Forest Service completed only a fraction of the Trestle Project.

It called for fuel reduction across more than 15,000 acres of land around Grizzly Flats, but completed work on just over 2,000 of those acres.

A cell phone tower disguised as a tree holds some of the only green “foliage” near the center of Grizzly Flats, California, Thursday, August 4, 2022.Andrew Nixon / CapRadio

Prescribed fire, considered crucial by fire scientists, was nowhere to be found. The project called for more than 10,000 acres of intentional low-intensity fire, but the agency only completed 136 acres of “pile burns,” the process of collecting and burning logs and vegetation that is widely considered much less impactful.

The agency instead prioritized commercial tree thinning, which generates revenue that offsets costs.

Generally, commercial thinning and other treatments designed to reduce fuel loads are a necessary precursor to prescribed fires, according to Rogers.

“Largely, we’re not going to be able to put fire on the ground before that work is completed,” he said.

But Trestle Project reports and Forest Service data show the vast majority of the planned prescribed fire was intended as the first treatment.

Wildfire researchers and former Forest Service officials say it’s disappointing the agency would focus on commercial thinning over other forms of treatment.

“The evidence that commercial thinning really reduces risk is not that good,” said Wara, the Stanford climate policy expert. “If you thin and then burn in an area, then you get dramatic risk reduction.”

Meanwhile, areas adjacent to the community that the Forest Service identified as “first priority” were left untouched and overgrown. One stands out: The highly overgrown — and highly combustible — southern border, which would have dovetailed with the buffer zone that Mark Almer and the Grizzly Flats Fire Safe Council worked on for over a decade.

“The part that didn’t get treated was the part we should have been most worried about,” said Hugh Safford, who spent two decades as the Forest Service’s senior ecologist in California before retiring in late 2021.

The steep, dense and dry south-facing terrain made it one of the more complicated parts of the project, but also the most essential, Safford noted.

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And the piece also looks at why it’s easier to complete commercial thinning (plannable) over prescribed fire (risky and not so much plannable)

 

Forest Service employees call them “Goldilocks days” — the brief window when weather, moisture levels, personnel demands and air quality all line up so prescribed burns can be done safely. Those days are becoming increasingly rare as hotter temperatures, severe drought and erratic weather patterns become facts of everyday life.

Rogers, the current Placerville district ranger, said his unit had a prescribed burn planned for spring of 2021, months before the Caldor Fire ignited.

“We had to cancel because conditions just weren’t quite right,” he said. “The historic drought conditions really cannot be overstated.” ….

Then there’s the staffing problem. Setting and managing a prescribed fire requires a lot of personnel. Longer and more extreme fire seasons mean crews ping-pong from district to district and fire to fire, often remaining on the frontlines for weeks at a time with no break. That prevents them from managing prescribed burns and tackling other vegetation reduction projects in their home districts.

Here’s the part about Lake Tahoe:

That doesn’t mean all projects struggle to secure funding. From 2008 to 2019, a partnership of private organizations and government agencies, including the Forest Service, pulled together $150 million and tackled 57,000 acres of fuel reduction around Lake Tahoe, not far from Grizzly Flats.

Dead Trees Sequester No Carbon: What We Learned About Offsets Should Apply to National Forests (or Not?) And A Request for More Voices

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A ponderosa pine seedling peeks out of the Hayman-Fire scarred landscape near Cheesman Reservoir. After the fire, Denver Water spent more than 10 years working with volunteers and Colorado State Forest Service crews to plant about 25,000 trees per year on the 7,500 acres of Denver Water property destroyed by Hayman.

There’s a recent story in E&E news about MOG (Mature and Old Growth), that was framed as being about timber interests versus environmentalists (no one here will be surprised by the mention of Dominick Della Salla and the John Muir Project.. on the other side, we have…”timber interests”, as in Bill Imbergamo with the Federal Forest Resource Coalition.  I’d argue that the timber wars are actually over, and the question today has a variety of voices that need to be heard.  For example, people concerned about old growth and mature forests burning up; dying due to bark beetles and other insects, proponents of Native American burning practices, fire suppression folks who appreciate operating zones, and so on.  I’d like to develop a list of potential sources, possibly including state foresters, entomologists and pathologists, prescribed fire and fire suppression practitioners and academics, Forest Service and BLM partners for restoration and fuels projects, and others.

If you have suggestions for contacts and you feel comfortable, please put them in the comments. If you don’t feel comfortable you can email them to me.  The idea would be to have a list that reporters could select from that would give a more comprehensive framing than “loggers versus Hanson et al.”, which I could ship off to any reporters interested in the issue.

Thank you!  Now on to the story…

Let’s talk about carbon..the erstwhile reason (this time) to go after the same old-same old (no logging on federal lands) with the same groups.

On the other side are advocates for less logging, or no logging, on federal lands, who say more protections will help sequester carbon and fight climate change.

People keep saying this, but without intervention in some cases (fuel treatments, beetle sanitation), trees will die. And Dead Trees Sequester No Carbon. So yes, there are places accumulating much carbon that are unlikely to burn up, but this effort is targeted to the entire US.  So it’s not really about that, is it?

It seems logical to me that if keeping out of forests really helped with carbon sequestration, then… people would be all for carbon offsets in western forests! From this NY Times story

Carbon-offset programs, which are designed to fight climate change, typically pay landowners to manage their land in ways that store carbon. Usually, that means paying landowners to not chop down trees.

Wildfires, however, don’t respect those agreements.

An estimated 153,000 acres of forests that are part of California’s carbon-offset project have burned so far this summer, according to CarbonPlan, a nonprofit climate-research organization. Three projects have been affected. In Oregon, a quarter of the Klamath East project, or close to 100,000 acres, has burned in the Bootleg Fire since early July.

(my bold in both spots).

While the rest of the NGOs are working, as the FS asked us, on the definition framework… this group went ahead, made up his own definitions and mapped them.

The use of the NASA information is “an amazing accomplishment,” given its level of detail, said DellaSala, who offered to share the data with the Forest Service.

“It’s not rocket science. It should not take a year,” said DellaSala, who added that 80 years of age is a benchmark for mature trees.

I don’t know how they can tell how the age of trees from NASA information, I have trouble telling how old they are (without knowing the area) without an increment borer.

OTOH

Commenters told the Forest Service on an agency webinar several weeks ago that “mature” defies a simple definition, considering trees that live hundreds of years might not be considered “mature” at 80 years old.

I think what the commenter said was something like “if aspen lives to x years and bristlecones live to y years, you can’t use the same age for each species.”

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The John Muir Project called for a partial moratorium on logging while the Forest Service inventory is underway and until protections are in place, and asked supporters to submit letters to the agency in support of the idea. The Forest Service, though, has said the executive order doesn’t call for any changes in projects underway or planned.

“For the purpose of this immediate moratorium, individual trees and stands of trees, whether burned in a fire (dead or alive) or unburned, that are 50 years old or older, should be excluded from cutting and removal in any areas where logging operations are allowed, and should be prohibited from being cut and removed in any area where logging operations have already been approved,” a sample letter says.

Note the current rationale is for carbon storage and sequestration, the the moratorium includes dead trees.  It’s the same old stuff with different packaging- or dare I say veneer?

Clearly we need more voices for reporters to call on… please append or send.  Thanks again for suggestions.

 

Biden DOJ Defends Bernhardt Decision on King Cove: What Makes Something a “Political” Decision?

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Interior Secretary Deb Haaland, left, is honored at an assembly at the King Cove School. (Marc Lester / ADN)

Saturday I posted about a controversy between Tribal people and a ski area on federal lands.  I’d like to place that story in conversation with another story, the King Cove controversy.  We don’t hear much about it, because it’s about a Fish and Wildlife Service (US DOI) administered area, and we usually talk about the FS and BLM.  But it has many familiar issues.  Native Alaskans in the village want a road to access a hospital.  Some national ENGO’s don’t want the road.

So we often talk about “political” decisions and decisions being “corrupted”.  I’d like to delve into this further.  As a person who has worked on numerous controversial EISs and rulemakings, I think it’s safe to say that there are a number of reasonable options that could be chosen.  What makes something “political”? Obviously there are numerous levels of internal and well as external politics. I think to agency people it might mean “a decision that I don’t agree with that favors interests I don’t like.” But then I think perhaps it’s about politics in the sense of “rewarding your friends and/or punishing your enemies,”   perhaps beyond what is a reasonable approach toward your stated aims.  For example, I think if the Admin’s stated goal is decarbonization, then shutting down US production on federal lands seems like more punishing oil and gas companies, or assuaging NRDC or ??, more than a rational policy call.  Others may disagree.  I would call that a political decision in that sense.  Do you agree or disagree or do you have a different definition?

So let’s look at the King Cove cases, which looks like Native Alaskans who need the road vs. (some) national ENGO’s.  The Admin appears to be picking a side by defending the decision (pro-road). Is this political? Was Sally Jewell’s decision not to political (assuaging ENGO supporters)?  Was Bernhardt’s political? Are they all political?

An interesting aspect of this case is that  he same argument (the federal property rights trump other considerations) seems to be made by these groups for Native people as for any local people.

Does this sound familiar?From an Anchorage Daily News story on Secretary Haaland’s visit.

Others complained to Haaland that outsiders can access Izembek to hunt and fish, and that much of the opposition to the road comes from conservation groups based on Alaska’s road system or in the Lower 48.

“Those folks live there,” said Skoey Vergen, chief executive of Aleut Corp., the Native corporation for the King Cove region. “These folks live here.”

Those dissenting groups were not present Wednesday in King Cove. But they’re still examining last month’s court ruling approving the Trump-era land exchange, and an appeal is an option, said David Raskin, president of Friends of Alaska Wildlife Refuges.

“This refuge is not owned by the people of King Cove. It is a great, valued possession of the people of the United States,” Raskin said in a phone interview Thursday. “And to have a small community like that reap horrible damage on one of the jewels of the refuge system would be a travesty, and a terrible blow to the American people.”

It appears that 11 miles of the road between King Cove and Cold Bay have not been built and that is what this decision is about. People from King Cove want a road to the hospital in Cold Bay.

Would we say that if the road goes through it is politics, or if the road doesn’t go, through it’s politics.  Do we feel more sympathy for the native Alaskans, or for far away people with environmental concerns.  If the Biden Admin were to give in to them, would that be undue political influence.

What groups, might we ask, are concerned about this road (desired by local Native Alaskans) to the extent that they are litigating it? Well, plaintiffs include The Wilderness Society; Defenders of Wildlife; National Audubon Society; Wilderness Watch; Center for Biological Diversity; National Wildlife Refuge Association; Alaska Wilderness League; and Sierra Club (collectively “Plaintiffs”). Many of these are powerful friends of the Obama/Biden Administrations.  Perhaps why Sally Jewell made her decision (political influence?).

And how did our friends at the New York Times cover the Jimmy Carter angle?  “The legal battle over the gravel route could gut an environmental law that the 39th president called one of his highest achievements.”

They are arguing the precedent of course, not the actual road.

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Another interesting angle is how political decisions get validated or invalidated by the courts.

I got hopelessly confused over the legal questions involved.  At first it sounded a little like that Sec. Jewell made a decision from an EIS, and Sec. Bernhart couldn’t make a different decision off the same EIS by weighing things differently.  Then the judges became frustrated at having their time potentially wasted because conceivably Sec. Haaland could make a new decision (with a new EIS?) .

But then there’s this explanation in the Anchorage Daily News article.

Trump’s administration was good to King Cove. After a federal judge invalidated a land exchange aimed at authorizing the road, Trump’s Interior Department redid the plan and tried it again. A different judge rejected it a second time, in 2020. But last month, a federal appeals panel reversed that decision and said the land exchange could proceed,..

In the NYT article:

The exchange was authorized by Congress during the Obama administration, but was rejected by Sally Jewell, then the interior secretary, after a review found it would cause irreversible damage to the refuge and its wildlife.

If Congress asks the Admin to do something, it can just decide not to?  Hopefully someone knowledgeable can explain.

Judge Kim McLane Wardlaw, a Clinton appointee, disagreed with her two colleagues, writing in a dissenting opinion that Bernhardt never explained the reasoning for this policy shift from Jewell and that she would have found that the land swap violated the Administrative Procedure Act and other federal laws.

DOJ argues in its brief that Bernhardt’s explanation placing public welfare over other concerns “sufficiently explained the change in policy,” in compliance with the Administrative Procedure Act, and that no other documentation was needed.

I thought that it was interesting that of three judges two thought (and DOJ thinks) that it was adequately explained, and one thought not.  That’s why to us observers, it sometimes seems like when we go to court the decisions are more or less random.  If I were redesigning the system, the judge would have to explain what they thought would be an adequate explanation. Otherwise it’s like “bring me a rock”; decisions can’t be improved without constructive feedback.

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Here’s one from E&E News, part of a long interesting article from 08/08/2022, if you are interested in more background.

 

Tribes, a Ski Area, a Sacred Mountain and a Former Forest Supervisor: Plus, What Does it Mean to Consult Exactly and Who Decides?

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Laura Jo West stands outside the Coconino National Forest headquarters, where she served as forest supervisor for more than seven years.
Jake Bacon, Arizona Daily Sun

Many thanks to an Anonymous for sending this piece in! So many interesting facets.

Tribes, political issues, ski areas, how politically hot topics are managed internally by the Forest Service, the difficulty of developing collaborative relationships with shifting people, how the line officer is uniquely responsible relative to others on the forest, due to the line/staff structure. Questions.. would we feel differently were environmental interests pushing someone out of their responsibilities rather than a for-profit permittee? Would we feel the same way about, say, a rare-earth mining operation or a wind energy facility exerting political power? What does consultation actually mean if it doesn’t mean “we can’t go ahead without your sign-off”? If the same decision had been made during the last Admin, would the coverage have been different? The Forest Service is in the Executive Branch, so clearly elected officials get to decide ultimately.  Which can be extremely frustrating for employees who have sunk their hearts, souls and extra hours into a project or a relationship.

Because the article is so long, and interesting, and with no paywall, I’ll only post one excerpt. Check it out for yourself. And thanks again, Anonymous!

“The new agreement

Presented with the chance to create consensus and collaboration around a sacred site that had long been the “epicenter” of controversy, West had no illusions about the difficulty of the work ahead.

“It was going to be messy, it was going to be hard, we were probably going to have fights in various places along the way,” she said. “It was going to be a challenge. But I think it was the right challenge.”

For these reasons, West wasn’t willing to unilaterally promise a timeline for approving the new MOA. As recommended by federal directives, she went in with an “open mind” and wanted to develop a timeline through the consultation process.

“I wasn’t promising anyone, including the tribes, an outcome because I didn’t know what was going to develop,” she said. “It was a completely wide open, kind of scary place. But I thought, ‘That’s OK, we’re going to travel it together.’”

From Jocks’ perspective, West “saw an opening and took it.” Her efforts seemed “sincere” when he met with her about a new MOA.

“She wanted to do the right thing,” he said. “She understood there were limitations, but wanted to do what she could.”

But West’s approach of elevating tribal consultation soon caught the attention of Mountain Capital Partners (MCP), which owns Snowbowl. She said her refusal to offer a definite timeline was unacceptable to MCP and Snowbowl executives.

“I told them it could take at least a year and a half, maybe even two, to get a new MOA down because we’re opening up a conversation with tribes,” she said. “They said, ‘No, it only takes three months.’”

Snowbowl put forth the MOA timeline built around “minimum legal requirements,” but this did not satisfy West.

“We have the discretion to do so much better than that,” she said.

What happened next was somewhat expected, West said: Snowbowl complained. In January and February this year, MCP, the largest ski area collective in the Southwest, scheduled meetings with Forest Service Chief Randy Moore. In a Feb. 17 phone call with West’s superior, quoted in a grievance letter provided to the Arizona Daily Sun by West, regional forester Michiko Martin informed West that MCP stated it did not “believe [West is] a neutral and trusted agent. They believe that you are orchestrating a master plan to upend them.”

West was accused of being “pro-tribe” and “biased toward tribes” and otherwise “deliberately stalling to prevent MCP from implementing approved projects.”

“I asked regional forester Martin if MCP provided any evidence for their allegations,” West wrote in her grievance letter. “She replied they had not.”

While West expected that Snowbowl would complain, she did not expect how these complaints would be received by the Forest Service. On March 17, right after the conclusion of the meetings between MCP and Moore, West received a letter from Martin informing her that her authority to address the expiration of the Snowbowl MOA was rescinded “effective immediately,” and re-delegated to Steve Hattenbach, supervisor of the Cibola National Forest in New Mexico.

West said she was shocked that in one fell swoop, the Forest Service chose to accommodate MCP rather than defer to her judgment, despite the fact that she was a devoted employee and agency leader with 33 years of experience.

When asked to estimate the reason behind this decision, West speculated that it could have something to do with the influence of the National Ski Area Association (NSAA), whose board overlaps with MCP leadership.

“I was told by my boss that [the NSAA] lobby on behalf of the Forest Service for additional funding for recreation, infrastructure and things like that,” West said. “It was made clear to me in a conversation I had with my boss that it was a relationship the agency wanted to protect.””

RVCC And Some Products of Interest: Recommendations for Performance Measures and Budgeting

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Emery Cowan of the Rural Voices for Conservation Coaliton (RVCC) posted this link to their tools, including a June 2022 report called Forest Service Project Planning to Implementation on another thread, so I’d like to highlight their work with a separate post. RVCC is one of my favorite NGOs. I always learn a lot from their webinars, plus “meet” interesting, dedicated, knowledgeable and enthusiastic people. They are one of my favorite sources of position papers on various topics. I don’t always agree with them, but their positions are always well thought out and well written, IMHO.

They are also looking for a Coalition Director, here’s the link. Which would be a great opportunity!

All this reminded me that I had planned on posting their Fighting Fire with Fire report when it first came out last fall. And was thinking today of the below section because of the discussion yesterday of the problem of hazardous fuel reduction metrics. What do you think of these ideas? (Or other ones in the paper?)

PERFORMANCE MEASURES AND BUDGETING

• Immediate action can be taken by elevating the existing “acres mitigated” KPI to a principal target on par with the two existing timber volume and acres treated targets. “Acres mitigated” is a better measure of the comprehensive action needed to reduce fire risk on one footprint acre than the current “acres treated” target. While any annual output target still suffers from the risk of prioritizing the easiest acres for treatment, use of the existing “acres mitigated” KPI would serve as a good bridge to more outcomes-based performance measures.

• Deprioritize the core performance measure of “timber volume sold.” This metric has long guided agency budget allocation and has been used as a benchmark of individual employee career success. While the agency tracks many KPIs, the timber volume target plays a disproportionate role in agency behavior. Addition of new KPIs is insufficient to motivate agency change without also relaxing the timber volume target. Furthermore, the timber volume target should not be conflated with a fire risk reduction outcome.

• Incentivize exceeding fuels reduction targets. So long as annual output targets remain in effect, performance measurement systems – and accompanying budget impacts – should incentivize overperformance, not penalize it. Currently, if a unit exceeds a fuels reduction target, they are expected to perform to the same advanced level in future budget years, essentially disincentivizing innovation and excellence. Performance above target could be rewarded with additional funding.

• The Forest Service should work with the Office of Management and Budget and key external partners to propose new outcomes-based targets that capture the complex, modern mission of the agency. While outcome measures are more difficult to achieve than simpler annual output targets, there are models for such practices already in existence (see on-the-ground example below).

What if we don’t want to protect our homes?

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We have discussed the role of home sites and homeowners in reducing wildfire risk.  In doing so I think we have made an implicit assumption that homeowners care about reducing wildfire risk.  Here is some evidence that protecting their homes from fires is less important to some people than protecting them from the government.

Oregon has adopted new legislation following the barrage of fire storms across Oregon in September 2020 that burned more than 1 million acres and destroyed 4,000 homes, many of them in rural areas.  It assigned tax lots one of five wildfire risk levels, and updated and refined the state’s “wildland-urban interface” map.  Starting next year, property owners on tax lots designated “high” or “extreme” risk that also fall within the updated wildland-urban interface must comply with minimum defensible space requirements.

“(The new map) generated so much pushback from angry homeowners that officials abruptly retracted it, saying they had not done enough local outreach before publicizing the ambitious project.

The rapid reversal, announced late Thursday, capped weeks of mounting frustration in mostly rural areas as the map emerged as a new flashpoint for conservatives who call it government overreach and “climate change evangelism.”

Fierce opposition bubbled up at community meetings prior to the state’s step back. Residents and some local officials worried it would lead to insurance rate increases or coverage loss, while others bridled at new mandates for defensible space and rules for future construction that flow from the map’s designations.

One information session in the conservative southwest corner of the state was canceled after someone threatened violence.”

There can certainly be legitimate concerns about factual errors, but this is being overshadowed by this new norm for how to respond to anything the government does that tells people what to do (especially if it’s because of climate change).  And just like Covid, if you leave it up to individual “personal responsibility,” some people’s lack of that will affect other people’s lives.  Achieving societal agreement on fuel reduction may be another casualty of this ongoing breakdown of social order.

The life of a forest & wildfire resilience project

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Thanks to Nick Smith for this link to a Sierra Nevada Conservancy page.

“Forest restoration and wildfire risk reduction projects are complex, involving many steps and moving parts that determine whether a project will succeed and how long it will take. In the infographic below, we take a look under the hood of forest restoration projects to understand each of the steps necessary to get a project on the ground and through completion.”

Blast from the Past: Hazardous Fuels Program Accountability

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Thanks to Matthew for posting the NBC report.. I’ve posted some things here and here about this issue. The article states correctly that this push has been going on for some years.. I went back to some docs from the past and was surprised how much the discussion resembles that of the present day. Maybe there should have been some bucks for revising accountability measures in the IRA? I think using the scenario planning prioritization was an effort to address some of the concerns. Perhaps there are others? Budget structure? Of course the FS may be too busy responding to the many zillion other things it’s supposed to do, with employees retiring and difficulties hiring..

Guess which year this was written by whom? First correct answer gets.. to write a TSW post on their topic of choice.

Accountability Must Now Become A Priority

With the Congress and the administration now prepared to double or triple the Forest Service’s and Interior’s funding for reducing hazardous fuels and with up to five times the current fiscal year’s appropriation already available from within the Forest Service’s existing budget for these activities and related research, we believe that the Forest Service and Interior must act quickly to develop a framework to spend effectively and to account accurately for what they accomplish with the funds.
For example, according to the Forest Service, priority for treatments to reduce hazardous fuels should be given to areas where the risk of catastrophic wildfires is the greatest to communities, watersheds, ecosystems, or species. However, currently neither the Forest Service nor Interior knows how many communities, watersheds, ecosystems, and species are at high risk of catastrophic wildfire, where they are located, or what it will cost to lower this risk. Therefore, they cannot prioritize them for treatment or inform the Congress about how many will remain at high risk after the appropriated funds are expended. According to the report on managing the impact of wildfires released by the administration last Friday, regional and local interagency teams will be
assigned the responsibility for identifying communities that are most at risk.

Moreover, rather than allocating funds to the highest-risk areas, the Forest Service allocates funds for hazardous fuels reduction to its field offices on the basis of the number of acres treated. Thus, the agency’s field offices have an incentive to focus on the easiest and least costly areas, rather than on those that present the highest risks but are often costlier to treat, including especially the wildland-urban interfaces. Similarly, both the Forest Service and Interior use the number of acres treated to measure and report to the Congress their progress in reducing the threat of catastrophic wildfires. For instance, they report that they have increased the number of acres treated to reduce hazardous fuels from fewer than 500,000 acres in fiscal year xxx to more than 2.4 million acres in fiscal year xxxx. However, they cannot identify how many of these acres are within areas at high risk of long-term damage from wildfire.

The Forest Service and Interior note that reducing the threat to communities, watersheds, ecosystems, and species can often take years and that annual measures of progress must, therefore, focus on actions taken. We agree, but believe that they must be able to show the Congress and the American public that these actions, such as the number of acres treated, occur within the highest-priority areas. Furthermore, over time, they should be able to show reductions in areas at high risk of long-term damage from wildfire.

Finally, although we have not examined this issue as thoroughly at Interior, our work to date at the Forest Service has shown that, over time, the link between how the Congress appropriates funds and how the agency spends them has weakened as the Forest Service’s field offices have been required to address issues and problems—such as hazardous fuels reduction—that are not aligned with its budget and organizational structures. Forest Service field offices must now combine projects and activities from multiple programs and funding from multiple sources to accomplish goals and objectives related to reducing hazardous fuels. We have observed that the agency could better ensure that the up to $325 million a year that may already be available from within its existing budget to fund hazardous fuels reduction activities and research will be used for these purposes by replacing its organizational and budget structures with ones that are better linked to the way that work is routinely accomplished on the national forests. We have also observed that the Forest Service’s research division and state and private programs should be better linked to the national forests to more effectively address hazardous fuels reduction as well as other stewardship issues that do not recognize the forests’ administrative boundaries. However, according to the Forest Service, it has no plan to replace its program structure with one that is better linked to the way that work is routinely accomplished on the national forests.