Environmental Analysis too long to print

by Andy Geissler, AFRC Field Forester

Last summer I wrote an article for AFRC’s blog regarding the status of Environmental Analyses (EA’s) being completed on the Medford District of the Bureau of Land Management (BLM) in order to comply with the National Environmental Policy Act (NEPA) when conducting vegetation management projects, including timber harvest, on their lands.  At the time, I highlighted a 418-page EA and described it as a “mammoth” document.  That description seemed fitting considering that the Council on Environmental Quality (CEQ) described in its 2007 publication A Citizens Guide to NEPA that The environmental assessment (EA) is intended to be a concise document that briefly provides sufficient evidence and analysis.  418 pages seemed excessive and a far cry from “concise” and at the time was the longest EA published by the BLM for a vegetation management project that I had reviewed.  Of course, there is no limit to excess, a rule that I was reminded of this month following the BLM’s publication of a 460-page EA titled “Pickett West”.  Now I’m faced with finding an adjective more extreme than mammoth.  I briefly flirted with the idea of labeling the Pickett West document as “mammoth”, but after placing a phone call into the Medford BLM office I was provided with a more apt description.

Typically, the BLM will provide printed hard-copies of any NEPA document they publish.  Knowing this, I called the Grants Pass Field Office to request a hard-copy of the 460-page Pickett West EA.  The response I received was at first funny and bit surreal, but later simply depressing.  The BLM informed me that they would not be providing the public with hard-copies of the Pickett West EA because it is “too long to print”.  That’s correct, the BLM has officially prepared an EA that is either too costly or too time consuming for them to print on paper.  That’s when I halted my search for a single adjective worthy to represent the Pickett West EA.  If 2016 was the year of mammoth EA’s then 2017 is officially the year of “EA’s-Too-Long-To-Print”.

I can’t say that I’m shocked by where we’re at.  The digression of the BLM into the world of EA’s-Too-Long-To-Print was bound to happen.  This is an agency that constantly hears accusations that their EA’s are “insufficient” in scope and in content by opponents of timber management, regardless of how long they are (If you don’t believe me, call the Medford BLM office and request copies of the 170-pages of formal protests they received last year for all their hard work publishing over 1,500 pages of environmental analysis).  So, if a 300-page EA is insufficient, and a 418-page EA is insufficient, then I’m guessing that a 460-page EA will also be seen as insufficient.  The only relevant question now is what will 2018 bring?  The optimist in me likes to think that it will be the year that the Medford BLM District ignores the absurd claims that their Russian-novelesque EA’s are insufficient, and publishes an EA that is a concise document that briefly provides sufficient evidence and analysis (where have I heard that description before…).  But the pessimist in me suspects that I’ll be searching for a new word to describe whatever type of document gets published by the BLM next June.


BLM Timber Sale Generates Impressive Value

by Andy Geissler, AFRC Field Forester

Over the past twenty years the Bureau of Land Management has met its timber output targets primarily through the thinning of young stands.  This one-dimensional management paradigm has been criticized by several stakeholders for various reasons.  Professional foresters have questioned the validity of a “thinning-only” regime given the fact that such a practice is unsustainable.  Sustainable forestry can only occur in this region through the harvest of mature timber followed by replanting of a new stand.

The forest products industry has questioned this regime as young stand thinnings only supply a single type of raw material that can only be processed into a narrow range of final products.  County governments, who receive 50% of the value generated by timber sales on O&C Lands, have questioned the limitations in value of a thinning-only management paradigm as the value of these offerings is lower than those from mature stands.  However, in recent months the BLM across all Western Oregon has started to progress beyond the status-quo of the past twenty years by offering timber sales that regenerate appropriate stands of timber.  This progression addresses all three of these concerns as regeneration harvest of mature stands provides sustainability, a variety of forest products, and a monetary value that is significant enough to provide stable county budgets.

The latest such timber sale, called Fawn Two, was sold by the Salem Sustained Yield Unit (SYU) of the Northwest Oregon District north of Mill City for over $2 million.  The stands in Fawn Two are at a seral stage where thinning is no longer effective and regeneration harvest is the only remaining management option.  The sale consisted primarily of Douglas-fir, and sold at a rate of $615 per thousand board feet (MBF).  To put this in proper context, the other five sales that the Salem SYU offered this fiscal year were sold at an average rate of $282/MBF for Douglas-fir (the highest rate was $347/MBF).  This means the Fawn Two timber sale exceeded the average value per board foot of Douglas-fir of all the other Salem SYU timber sales this year by nearly 120%!  As mentioned earlier, the total value of the Fawn Two timber sale was approximately $2 Million.  To put that number in context, the average value of the previously cited five timber sales was $1.2 Million.  The distinction between those two numbers may not seem significant; but consider that the average size of those five timber sales was 228 acres and that Fawn Two was a mere 60 acres!  The Counties will receive $16,666 an acre from the Fawn Two sale and only $2,632 an acre from the other sales.

If nothing else, the results of the Fawn Two timber sale should silence the critics who claim that the BLM’s timber outputs cannot provide the monetary value necessary to keep County beneficiaries whole.


Tuolumne County Struggling with Unprecedented Mortality

Tuolumne County, just north of Yosemite National Park, is representative of 10 mountain counties in the central and southern Sierra Mountains is facing an extreme wave of bark beetle induced mortality covering both private and National Forest lands.  More than 100 million trees are estimated to have died in Sierra Nevada forest since 2011 due to five years of drought and overstocked stands that weakened trees and made them vulnerable to infestation by bark beetles.  Dead and dying trees threaten homes, roads, power lines, canals and other infrastructure across the region.

image001 (2)As an example of the scale of the effort required to respond to this slow-moving disaster, Tuolumne County responded with one of the most active programs to insure public safety and protect its facilities.   The County tree mortality program was recently awarded a 2017 Achievement Award in the category of risk and emergency management by the National Association of Counties, a non-profit organization based in Washington D.C.  The county formed a task force to assess and mitigate the crisis, applied for grants, and is using its reserve funds to mitigate the hazards to its facilities.  It obtained a state of California grant for the removal of dead & dying trees threatening public facilities which pays for 75% of the cost, but leaves the county to fund the remaining 25%.

The county has pledged more than $600,000 from its General Fund reserves to cover its share of the cost.  County officials estimate needing a total of about $12 million over the next three years to remove all the hazardous trees, so 25% of that would deplete the counties $2.3 million in General Fund Reserves. (from the Union Democrat, May 3, 2017)

In addition to the county effort, PG&E has removed thousands of trees from along its power lines and utility corridors, often having to use cranes to remove the trees in sections costing $1,000 to $2,000 per tree.  The state of California had had to mount a similar effort to remove hazard trees along state roads in the County, and owners of private industrial land have salvaged thousands of acres of dying trees using several different permits under the California Forest Practice Act.  Thousands of private homes and facilities in the counties must remove their dead and dying trees at their own expense if the trees do not threaten a power line or county road and have spent thousands of dollars per parcel.

Service clubs including the Lions club of Sonora recognized that elderly citizens on fixed incomes cannot afford the cost of removing hazard trees threatening their homes, and have responded by raising over $100,000 through fundraising and grants.  They developed the Tree Mortality Action Program (TMAP) to qualify, locate, measure, and contract the removal of these hazard trees for senior citizens.  These trees are also often next to houses with limited access and must be removed in sections.

Merchantable logs from salvage operations have been utilized by local mills, although much is blue stained and of low value.  Some of the devalued timber can be chipped for biomass, but the non-merchantable wood must be hauled to disposal sites which have been selected and permitted by the county. -Jerry Jensen, AFRC California Consultant


Northern Spotted Owl Extinction Watch: May 2017 Update

According to the USFWS, the Northern Spotted Owl (NSO) population has declined 52% since 1992.  At its current rate of decline, another 25% will be lost in the next 20 years even though the amount of suitable habitat is expected to increase significantly.  The cause of the NSO decline is the invasion of the barred owl whose population has exploded since 1990 and continues to increase.  Even though the USFWS only recently formally listed the barred owl as a threat to the NSO, their potential impact has been recognized for almost 40 years.

The barred owl was first detected within the range of the NSO in the 1970’s.  In the 1980’s, researchers started to become concerned about the impacts the barred owl would have on the NSO.  In 1990 when the NSO was listed as threatened, the USFWS acknowledged that the expansion of the barred owl population was of “considerable concern.”

By 2004, the preponderance of evidence led the team conducting a 5‐year status review to conclude “that the barred owl is a significantly greater threat to the spotted owl than originally estimated at the time of listing.”  By this time, the overall NSO population had declined by 30% from its 1992 level.

In 2008, the USFWS released the NSO Recovery Plan that identified competition from barred owls as a main threat to the spotted owl. Roughly a third of recovery actions address the barred owl threat, including consideration of measures relating to a barred owl removal experiment.  By this time, another 8% of the NSO population was lost.

In February 2009, a Barred Owl Stakeholders Group was formed as part of the scoping process for the barred owl removal experiment.  The final EIS and ROD for this experiment was signed September 2013.  By this time another 9% of the NSO population was lost bringing the NSO population down to 54% of its 1992 level. There is no firm schedule for conducting this experiment only that “(R)emoval activities will end when data are sufficient to meet the purpose and need.”  A maximum duration of 10 years of barred owl removal was stated for the experiment.  At the end of this 10 years, another 13% of the NSO population will be lost.

The experimental design called for a total of 3,603 barred owls to be removed from four study areas.  After four years, only 978 have been removed.  At the current rate, it will take an additional 5 years from what was originally planned where another 7% of the population will be lost.

After the experiment is completed (sometime after 2027), if they find that removing barred owls leads to an increase in NSO’s which is likely, the USFWS will then have to go through a lengthy regulatory and legal process to develop a barred owl removal plan.  This could take yet another 10 years at which time the NSO population will only be at about 25% of its 1992 level and perhaps will be extirpated from major portions of its range.

The adoption of a plan, however, does not mean the plan will actually be implemented.  To implement the plan, it will have to withstand lengthy legal challenges from opposing environmental groups and if successful, convince Congress to allocate millions of dollars every year to carry out the plan.  In the 20-30 years it will take to maybe start barred owl removal, the spotted owl will have already become extinct throughout much of its range.

In the meantime, the USFWS is focusing on maintaining and increasing suitable NSO habitat claiming that since the NSO population is declining so rapidly “habitat is more important than ever.”  The fallacy of this concept is that there are already hundreds of thousands of suitable NSO habitat that is devoid of any NSO’s because of the presence of barred owls.  Any new habitat that is created will be occupied by barred owls and therefore of no use to the NSO.  The result of this fixation on “habitat” as opposed to addressing the real problem is that the much needed fuels reduction and restoration work needed on our federal lands is being thwarted by the USFWS insistence on maintaining all of the existing nesting habitat and major reluctance to allow treatment of foraging and dispersal habitat.

It is understandable that the USFWS is reluctant to address the real threat to the NSO as killing barred owls at the level that would make a difference to the NSO will be met with major resistance from environmental groups and Congress is not likely to continually fund a multi-million dollar removal effort.

It should be obvious that to only practical solution to ensuring that the NSO will continue to exist in the wild is to identify refuges across its range that could be maintained through barred owl removal at a level acceptable to the public and Congress.  A captive breeding program should also be started to ensure there sufficient genetic diversity is maintained if NSO’s need to be reintroduced where they have been totally displaced by the barred owl.  These efforts should begin now rather than waiting another 30 years at which time the NSO will be extinct in much of its range. -Ross Mickey


When a Take is Not a Take: The Regulatory Quagmire of the ESA No-Take Provision

The Endangered Species Act (ESA) states that it is unlawful to “take” any endangered species of fish or wildlife.  50 CFR Part 17.31 expands the prohibition to take endangered species to wildlife species listed as threatened. The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct. Harm is further defined in 50 CFR §17.3 to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns such as breeding, feeding, or sheltering. Harass is defined as actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns which include, but are not limited to, breeding, feeding or sheltering. All of the “takings” alleged to have occurred due to habitat modification caused by timber sales on federal land are in the form of harassment. The Secretary is also authorized by the ESA to permit any taking if such taking is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.

Incidental Take Guidelines for the Northern Spotted Owl

The USFWS issued “Procedures Leading to Endangered Species Act Compliance for the Northern Spotted Owl” in July of 1990.  This document defined how take would be determined when associated with “degradation or the destruction of suitable spotted owl habitat”.  These guidelines were established based on limited research done in the 1980’s that showed a tenuous relationship between the amount of suitable habitat and spotted owl occupancy and reproductive success.  Based on this limited research, the USFWS determined that there is a high likelihood of take if the amount of suitable habitat within the home range falls below 40%.  The actual research this was based on showed that stands over 21% suitable habitat functioned as well as those with greater amounts of habitat. (Bart, J and E.D. Forsman 1992)  The USFWS formally rescinded the take guidelines in October 1991 but has continued to use the 40% standard as ‘the best scientific information”.

As a result of a ruling in a case called ONRC vs. Allen. The USFWS, USFS and BLM developed the Owl Estimation Methodology (OEM) which updated the habitat conditions that would determine the likelihood of take.  They retained the 40% of the home range determination and modified the threshold conditions within the nest site and core areas.  The OEM also defined that a take would occur if any suitable habitat is removed within a 300 foot radius circle around the nest tree or the amount of suitable habitat falls below 50% of the core area which range in size from 5,720 acres in northern Washington to 500 acres in Oregon and California.  The OEM was formally withdrawn in 2015 after Judge Leon ruled its use by the federal agencies was illegal but the USFWS still utilizes the three habitat criteria to determine if owls will be “taken” due to changes in suitable habitat conditions.

Take Determination on USFS and BLM Timber Sales

When a timber sale is being planned, the action agency (USFS or BLM) must determine how it will affect the spotted owl.  There are three affect determinations.  The first is that the project will have no effect in which case the action agency does not have to notify the USFWS about the project.  The second is a “may affect but not likely to adversely affect” the spotted owl.  In this case, the action agency must obtain a “letter of concurrence” from the USFWS.  The third determination is one that “may affect and is likely to adversely affect” the spotted owl.  Currently, the USFS and BLM have been directed by the USFWS to treat projects that remove or downgrade any suitable spotted owl habitat regardless of the presence of any spotted owls as being “likely to adversely affect” spotted owls.  In this case, the action agency submits a Biological Assessment to the USFWS who then prepare a Biological Opinion that must conclude that the proposed actions will not “jeopardized the existence of the specie” or “adversely modify critical habitat”.  If either of these occur as a result of the project, the project will not go forward.

If the project receives a no jeopardy and no adverse modification determination, the USFWS then determines if any take will occur as a result of the project.  If so, they will prepare an incidental take statement which allows the agency to proceed with the project since the take “is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity”.  In determining take, the USFWS uses the take guidelines found in the Owl Estimation Methodology.  The amount of take that is assumed to occur if habitat is below one of the three thresholds is 2 adults and 1.5 young per home range.

How the Thresholds are used in Determining Take on Timber Sales

Using hard line thresholds for take determination leads to a number of very bizarre situations.  The first of these occur in southern and eastern Oregon and northern California.  In these provinces, over 90% of the historic home ranges do not contain 40% suitable habitat in their natural state.  This is due to climate and soil productivity factors that limit stand density.  It also frequently occurs on land managed by the BLM because of their checkerboard ownership created by the O&C Act.  Since the home ranges in these areas are below threshold levels naturally, removing any “suitable habitat” will result in a take determination of 3.5 owls. This determination will be made regardless of the known presence of any spotted owls.  If even a small amount of suitable habitat is removed a short time later in another project, another 3.5 owls will be said to be taken.  This could go on ad infinitum leading to the ridiculous conclusion that hundreds of owls could be “taken” from a single home range even if no owls were using the area.

Because the take determination for timber sales rely on the prohibition of harassment, the USFWS should be determining if the proposed action will “create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns”.  Since they do not do this and rely on the three hard line thresholds, a take would not occur if a home range currently had 41% habitat and would be reduced to 40% by a project yet a take would occur if a home range had 40% suitable habitat and a project would reduce it to 39%.   The same would occur concerning the 50% threshold for the core area.

No-Take Requirement within the Western Oregon BLM RMP’s

The BLM recently adopted new Resource Management Plans (RMP’s) for the lands they manage in western Oregon.  Due to the precipitous decline in the spotted owl population being caused by the barred owl, the BLM agreed to not “take” any spotted owl until the USFWS adopts a barred owl management plan.  If this plan is not done in seven years, the BLM will have to re-consult with the USFWS on their RMP’s causing major disruptions to their land management and perhaps triggering revisions of the RMP’s.  There is zero probability that the USFWS will adopt a barred owl management plan in seven years and it is not likely to occur in the next 20 years if ever.

It should be noted that the USFWS has determined that without a drastic reduction in the size of the barred owl population, the spotted owl will become extinct in most of its range regardless of how much habitat is protected or created.  They recognize the importance of reducing the size of the barred owl population and realize the only mechanism to do this is by lethally removing them.  They therefore embarked on a research project to determine the effectiveness of lethal removal.  This study stared in 2013 and was to remove a total of 3,603 barred owls from four areas within four years.  This effort is going much more slowly than expected.  Between 2013 and 2017, only 819 barred owls have been removed.  Even if the rate of removal doubled, it will take another six years to complete the field work.  This will be followed by 10-15 years of analysis, development of a plan, environmental analysis of the plan and public involvement.  In the best case scenario, a plan may be adopted in 20 years.

The adoption of a plan does not mean the plan will actually be implemented.  To implement the plan, it will have to withstand lengthy legal challenges from opposing environmental groups and if successful, convince Congress to allocate millions of dollars every year to carry out the plan.  In the 20-30 years it will take to maybe start barred owl removal, the spotted owl will have already become extinct throughout much of its range. -Ross Mickey


What I Learned in Court

At AFRC one of our most important tools – and one of the most important services we offer our members – is our legal program.  AFRC not only advocates for responsible forest management on public lands by working directly with the agency and interested stakeholders.  We also have a legal team that aggressively defends good projects in court when challenged by opponents of active management.

Last week, I was at the Federal Courthouse in Eugene to observe oral arguments of a legal challenge to one of those projects.  Within minutes of walking into the courtroom, I was struck by the irony of the exercise.  To my left, to my right, directly in front of me, and directly behind me were 20-foot high wood-paneled walls (probably manufactured locally by an AFRC member).  The lawyers – including the environmental plaintiffs – were sitting behind ornate wood desks and the audience sat on wood benches and wood chairs.  The judge called the hearing to order by wrapping the gavel made of wood on her, wait for it, wood dais.

And the topic of discussion for the day: is it ok to use some of the billions of trees in Oregon, a renewable resource, to make the very things right in front of our faces?

After the judge thanked legal counsel for their extensive briefing materials, which amounted to hundreds of pages of legal analysis, maps, and discussion of all the steps the Forest Service undertook to design the project, the “show” began.  Not knowing the intimate details of the project (AFRC monitors 45 national forests and BLM units on 75 million acres of public land), I was anxious to understand the premise of the plaintiff’s legal challenge.  I was waiting for the fireworks.

Was the plaintiff going to claim the Forest Service was planning a massive “clearcut” of “old growth” near a favorite campground?  Such accusations always get the public’s attention.

Or, perhaps the plaintiff would argue the Forest Service was planning to authorize logging on the banks of Umpqua River near a well-known fishing hole?  That would get people fired up.

Or, maybe the plaintiff was simply going to claim that managing a tiny fraction of the Umpqua National Forest would mean the extinction of the spotted owl?  I mean, no judge wants to greenlight the extirpation of an entire species, right?

As it turns out, the legal challenge had little to do with the substance of the proposed project at all.  In fact, the project was aimed at thinning overstocked forests, restoring meadows, and making the landscape more resilient to fire.  The project was also planned on forestlands zoned as “Matrix” – the very lands intended for timber production under the Northwest Forest Plan.  I was confused.  So, what’s the problem?  Isn’t this exactly what environmental activists want the Forest Service to be doing?

The problem, according to the plaintiff, was the process.  The Forest Service had only spent hundreds of hours and tens of thousands of taxpayer dollars preparing an “Environmental Assessment” (EA).  The plaintiff argued such analysis and public outreach was insufficient – the Forest Service should have prepared a longer, more expensive document called an “Environmental Impact Statement” (EIS).  Forget that an EA is more than legally sufficient to disclose the impacts of the project to the public.  Forget the Forest Service made changes to the project to accommodate concerns from the public.  The plaintiff wanted an EIS (the same document used when analyzing a massive, permanent infrastructure project like building an interstate), not an EA.

Why, you ask?  That’s the question the judge was trying to get to the bottom of.  The Forest Service had already completed a comprehensive, multi-year, six-figure, taxpayer-funded EIS for the overarching forest plan that governs management of the entire Umpqua National Forest.  Should the Forest Service be required to complete a second EIS for every project that is tied to the forest plan?

Would such a requirement lead to significant changes to the project? Highly unlikely.  The requirement would lead to the very same outcomes but take significantly more time and cost more money.

Would such a requirement encourage more members of the public to learn more about the project and engage with the Forest Service?  No.  In fact, the opposite is likely to occur.  The public will be even less likely to read a 500 – 1,000 page document than a 200-page document.  Public disclosures required by the National Environmental Policy Act should be more accessible and consumable by the average person interested in public lands, not less so.

So, what is the whole point of this exercise?

As someone who served in Federal government for eight years, I deeply respect the checks and balances of our government.  Holding our government accountable, demanding that it be transparent, and petitioning the government when it blatantly violates the law provides the very foundation of our democracy.

But in this case, and in dozens of cases AFRC defends in court, that rarely seems to be the point of the legal challenge.  It’s not about the owl.  It’s not about clean water.  It’s not about public access, or even about “protecting” our forests.  Unfortunately, all too often, legal challenges focus on extremely technical components of the process, rather than on the substance of the project and whether or not the project violates the well-intended Federal statutes to protect the public, the environment, and those that depend on our public lands.

And that’s not a good thing for the judicial system (what happens when there’s a truly legitimate claim or grievance?), for engaging and educating the public about land management decisions, the taxpayer who foots the bill for the legal proceedings and often the plaintiffs’ attorney fees, the morale and expertise of the Forest Service, or for the timely and science-based management of Federal forests in response to climate change, fires, disease, and insect infestations.

We need a better process.  There has to be a more equitable way of holding our government accountable while not incentivizing or rewarding obstructionist behavior.  At AFRC, we want to work with those truly interested in a different, more efficient, more accessible, more transparent approach. -Travis Joseph


The U.S. Forest Service and the "T" Word

As AFRC’s field forester in western Oregon I am responsible for reviewing vegetation management projects with a timber harvest component across four national forests.  All four of these Forests provide some level of timber products every year as a component of these projects.  I stress the word ‘component’ here as these are integrated projects, meaning that their objectives are numerous and diverse.  A garden-variety project may aim to improve wildlife habitat, expand recreation opportunities, and provide timber products.  A good project strives to strike a balance of these diverse objectives and offer up a sort of symbiotic relationship amongst them.  Naturally, the first step in achieving this symbiosis is to identify and acknowledge the various objectives.  For many years, the Forest Service took this first step in a straightforward and tacit manner: they knew what their objectives were and they listed them in no particular order.  Over the past few years I have noticed a change.  The change is simple: the omission of timber as an explicit objective alongside the other objectives.  Timber products are still being provided on these projects, they’re just not being acknowledged in the blueprints.  It’s almost as though the Forest Service is a bit ashamed of harvesting and selling logs.

Faced with this trending practice of veiling timber harvest from small-scale projects, I decided to turn to the forum where the agency is most visible and accessible at the large-scale: their website.  This is where most people would go if they were interested in what the Forest Service does and what its mission is.  Sure enough, the agency’s mission is identified clearly on the web:  The mission of the USDA Forest Service is to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.  Like most mission statements, this one is a bit abstract.  What are these “needs” that our generation gets from our forests?  Fast-forwarding past my trudge through the agency’s webpage I came to the conclusion that our generation apparently does not need wood products; at least not according to the Forest Service, otherwise I would have been able to locate the word “wood” or “timber” somewhere on their website.  I read about other resources: air, water, soil, recreation, wildlife, etc.  In this regard, the Forest Service’s website mirrors those vegetation management projects that I review in western Oregon.  By that I mean they provide wood products to the American public, they just don’t like to boast about it.

I suppose in an age where it seems that image is everything and substance is an afterthought, the Forest Service’s policy of hiding the fact that they permit the cutting of trees to provide wood products to the American public shouldn’t come as a shock.  Although it does to me.  Why not take pride in the fact that they are providing a renewable resource that every member of the public uses every day?  Why not take pride in the fact that this provision comes via integrated projects that achieve a swath of other resource objectives?  These are loaded questions of course.  I’m not that naïve.  The cutting down of trees, regardless of the reason, makes most people at worst distraught and at best a bit uncomfortable.  This is fine.  What isn’t fine is that the lead government agency tasked with providing the nation with all of its needs from our national forests seems to be tailoring it’s messaging to assuage these sentiments rather than tailoring it to reflect what the nation’s needs actually are.  In other words, their website, and the messaging it contains, seems to be handling the public with kids gloves.  Not only is this approach disingenuous, and a bit insulting to their audience, but it’s also leading down a questionable path.  If the Forest Service treats their timber products resource with such shame, why shouldn’t the rest of the American public? -Andy Geissler


The Worst Type of Government Waste

National Environmental Policy Act (NEPA) compliance is typically the most costly part of implementing any type of vegetation management project on federally managed land.  Documents exceeding 200 pages are commonplace to comply with NEPA.  In 2015 the Roseburg District of the Bureau of Land Management completed one such analysis called Olalla-Camus.  This analysis focused on treatments designed to fulfil the BLM’s O&C mandate to provide a sustained production of timber on lands allocated for such production as directed by their 1994 Resource Management Plan.  Like all NEPA documents completed by federal agencies attempting to conduct active forest management and timber harvest, Olalla-Camus included an in-depth analysis on everything from wildlife habitat to carbon storage and beyond.  The timber sales analyzed under this document were estimated to provide about 16 MMBF of timber.

Next month the BLM will be offering the only timber sale generated off the Olalla-Camus EA for a total of 6.7 MMBF.  The remaining 10 MMBF considered in this EA will never be implemented.  This is due to the BLM’s new management plan completed in 2016, inconveniently finalized between the publication of the Olalla-Camus EA and the planned implementation of the treatments it considered.  Like the 1994 RMP, the 2016 RMP set aside many acres where sustained timber production cannot occur.  The only difference is that these “set-aside” acres grew exponentially.  Part of this “growth” includes the majority of the land included in the Olalla-Camus EA.  The BLM could have included a “grandfather clause” that would allow projects conceived and analyzed under the old management plan to move forward, but they didn’t.  The unfortunate result is the worst type of government waste-investments consuming large sums of money and time being squandered. -Andy Geissler


Winter Logging

The months of December, January and February are very important to sawmills trying to get their winter decks of logs in before the rains and wet conditions of spring arrives.  These months of winter logging provide sub-freezing temperatures that allows loggers to operate over frozen ground conditions in the forests and remove the timber with little damage to the soil and to the roads they are driving on.

During these winter months, sawmills must deck up enough logs in their yards to allow them to operate during the months of March, April and part of May when conditions in the forests are wet and the soil and roads are too moist to operate on.  Winter logging can be tough on equipment and tough on the loggers working in the woods, often in sub-zero temperatures.  Equipment can freeze up, more breakdowns occur during this time, and with the deep snow and ice, accidents are more prevalent.

So the next time you see a log truck going down the road with snow on top of the logs, think about the loggers working hard in the woods helping the sawmills get in their winter decks before the spring breakup takes place and all of the loggers and their equipment have to exit our Forests.

Below are some pictures from Vaagen Brothers Lumber log yard, as they are building up their winter decks.  On a recent trip to the Colville and Kettle Falls area, the temperatures were dropping to -15 degrees Fahrenheit.

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Forest Service Roads: Why We Need a New Road Maintenance Model

I was in the middle of writing this piece when Russ Vaagen posted “Roads are not the Enemy” on his blog, theforestblog.com. At first I thought about scraping my article but after reading his, I think the two pieces are complementary to each other. Mine is from the perspective of a forest engineer who has spent most of my career dealing with forest roads, both new construction and maintenance. Nearly all this work was on private and state trust lands in Washington State. I think this provides a unique perspective on the forest road issue, especially on U.S. Forest Service lands.

If you look around much of the road infrastructure – road surfacing, culverts, bridges, etc. of federal forests are crumbling away, much as we see across the federal highway system. For the most part this is not due to a lack of will or desire on the part of the hard-working field level staff of the Forest Service. Really, it is mostly due to the significant underfunding of road maintenance needs nationally on the Forest Service road system. This lack of maintenance of key infrastructure, admittedly primarily built for timber but providing access now for a broad range of users, has and continues to have negative impacts on access and the environment. Failed culverts, washed out roads, plugged ditches, and aging culverts and bridges are just a few examples of the type of issues impacting water resources or limiting access. Often cutting off recreational and economic opportunities in the forest.

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What can we do about this?

Many people look at the success of the Washington State Forest Practices Road Maintenance and Abandonment Plan (RMAP) process and wonder if it can be applied elsewhere. Perhaps even on the National Forest? According to a Washington Forest Protection Association 2015 report, private forest landowners and state lands (mostly DNR Trust Lands) have spent over $300 million dollars since the year 2001 in Washington state, “resulting in removal or repair of more than 5,600 barriers to fish migration, which has restored nearly 3,900 miles of historic fish habitat.” While this figure primarily captures the investment in fish passage, there is another monetary metric that was not well captured in how DNR collects data.

That metric is non-fish passage road maintenance work, such as adding or installing larger cross drain culverts, road surfacing upgrades, and road abandonment. Additionally, there is the routine maintenance, not tracked through the RMAP program. Ongoing road grading work, culvert and ditchline cleaning, and road side vegetation management. All work to maintain a transportation system not only for regulatory reasons but also operational reasons.

As an engineer, I have spent much of my career identifying, designing, and complying this type of work. I have lost track of the number of truckloads of culverts I have overseen the installation of, but it is a substantial number. Private landowners and DNR trust lands have and are investing millions of dollars into the ongoing maintenance and upgrades of their transportation systems. This benefits, water quality, provides economic benefit from the work, and in many cases, enhances recreational access.

Is this a potential model for Forest Service transportation systems?

Ultimately, yes! A similar model on Forest Service lands can be developed, but some hurdles need to be overcome. Roads are such a contentious issue, especially on the National Forests. Can interest groups with such diverse opinions, those that want to keep every road and those who would like to see significantly less if not all roads obliterated come together on common ground? Some roads may need to go away, but conversely there may need to be new permanent road constructed to maintain access needs. Relocating roads out of flood plains or similar areas to higher ground are one example of the need to build new road while eliminating some existing road. Can agreement be reached?

Funding is the major road block to getting work done. Some Forests are using Stewardship dollars to conduct restoration level road maintenance, but this does not meet the overall need. Private and state trust lands harvested trees to pay for much of the RMAP work they conducted. A similar program can be used on Forest Service grounds, while still meeting ecological goals and within the confines of federal land management regulations. But it will require increasing “pace and scale” while also seeing congress add more funds to the Forest Service budget to accomplish this work.

In the end a new model needs to be built for the Forest Service because it is the right thing to do for many stakeholder interests. The RMAP program grew out of the Washington State Forest Practices Forest and Fish HCP. It was an effort to balance the needs of water quality and fish habitat with a viable and sustainable forest products industry. An effort that to date appears to be very successful on state and private forest land ownership.

On Forest Service lands this work would not only benefit access needs for recreation and vegetation management but also water quality and fish habitat. A successful program would enhance the environment while helping to maintain and enhance the economic infrastructure of road maintenance, logging, and milling. This could go a long way in working to create family wage jobs in rural communities.  – Matt Comisky