Firery Comment

By Dave Sweitzer, Secretary/Manager, Western Hardwood Association

As my wife and I prepared to evacuate our Stevenson, WA property with 25 animals because of the Eagle Creek Fire across the Columbia River in Cascade Locks, OR, we became hot over the lack of management of our forests. We watched the fire grow and progress up the Columbia Gorge lighting up the evening skies.

For decades, the forest products industry has advocated for selective logging, cleaning the forest floor of fire starter debris, and replanting seedlings. I applaud US Rep Greg Walden’s House Resolution 3715 which calls for fast-tracked salvage logging in the burned areas of the Gorge, with the idea of removing burned and damaged trees and quickly replanting the area afterward. Walden said on the House floor, “year after year after year after year we have these catastrophic wildfires on federal lands, some of which have been set aside and managed in a way that they have no management”.

Too bad the naysayers (Friends of the Columbia Gorge) headquartered in Portland don’t see the benefits of salvage logging. They seem to think any entry into the forest, other than recreational, is detrimental to the forest recovery. The facts do not support their claim. In fact, whether logged or unlogged, researchers find there is not much difference in forest plant regeneration after a wildfire. The findings were the result of more than a decade of studying plant regeneration after the 2002 Cone Fire in California.

Salvage logging, cleaning the forest floor, and replanting will rejuvenate the forest and provide forests for our grandkids and their grandkids. Now is the time to contact your representative and suggest they support House Resolution 3715. If we don’t start managing our federal and state forest, we won’t have any forest to manage in the future.


Sarcastic Lawsuits

by Andy Geissler, AFRC Field Forester

Last month, three organizations (Oregon Wild, Cascadia Wildlands, and Klamath-Siskiyou Wildlands) filed a lawsuit against a Bureau of Land Management (BLM) timber sale called Lower Grave in southwest Oregon.  Among the claims filed was that the BLM “failed to take the requisite “hard look” at the project’s potential environmental impacts to the northern spotted owl.” 

The term “hard look” is subjective and can thus be interpreted many ways.  Here, the challenge is specific to the agency’s “hard look” at the impacts to the northern spotted owl (NSO), a species listed as threatened under the Endangered Species Act.  The primary method that the BLM uses to take this hard look is through consultation with the Fish & Wildlife Service (FWS).  The vehicle for this consultation is called a Biological Assessment (BA) which is prepared by the BLM for every single vegetation management project that has a potential impact to the NSO or its habitat.  The BA summarizes the project’s impacts to the NSO following an analysis that includes surveys, habitat condition analysis on the landscape & local scale, and population trends.  Following its publication, the FWS reviews it and provides their feedback.  Typically, a single BA is prepared for each BLM vegetation management project and they average around 60 pages.  For the Lower Grave project, the BLM issued three BA’s.  Following the publication of the initial 59-page BA, the BLM made significant amendments over the next year and re-published that document twice.  These 100+ pages of analysis come in addition to a 250-page Environmental Assessment (EA).

And ultimately, this abundance in analysis and paperwork was greeted with a lawsuit claiming that the BLM failed to take a hard look.  It’s difficult to predict how a judge is going to interpret the term “hard look”, but I imagine that most rational minded people would find it hard to believe that three separate in-depth analyses in addition to a single larger analysis for a single project would fail to pass muster.  In light of what seems to be more than sufficient analysis, this lawsuit also begs the question as to whether such a claim even warrants judicial review.  It almost seems comical.  In fact, the claim resembles the kind of sarcastic response typically reserved for only the most absurd situations; i.e. “Only 350 pages of analysis?  C’mon BLM, I thought you were going to take a hard look!”  Unfortunately, these organizations are not being sarcastic, and they are likely hedging their bets on the possibility that whatever judge reviews this case won’t sense the irony in their claims.


Missing the Forest for the Fake News

by Lawson Fite, AFRC General Counsel

Hillary killed Vince Foster.  Obama was born in Kenya.  Trump is going to let Big Timber cut down the Sequoias.  Which one is “Fake News”?  The answer is “All of the Above.”

The new Administration’s review of a number of National Monument designations has emotions and rhetoric running high.  Unfortunately, the debate has become unmoored from the facts in some quarters.  One of the monuments under review is the Giant Sequoia National Monument (GSNM) in California.  A recent Sierra Club fundraising message makes false claims about review of this monument.

sierraclub

The statements above are false.  The timber industry has never expressed any interest in logging giant Sequoias.  Nor has anyone in the administration suggested any such thing.  In fact, a coalition of forestry associations recommended changes to GSNM to better protect Giant Sequoia groves.  Within the current monument area, there are 38 Giant Sequoia groves constituting about 27,830 acres of forest.  When zones of influence (buffers) are included the total acreage increases to just over 90,000 acres.  While undoubtedly well-intentioned, President Clinton’s designation of 327,760 acres went far beyond these unique forests and now restricts the ability of the U.S. Forest Service to use science-based, active forest management to thin the adjacent forests to protect the Giant Sequoia groves.

Over the past two years over 20 percent of the GSNM has burned, including over 62,000 acres in the 2015 Rough Fire and substantial portions in the 2016 Cedar Fire.

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While it is fortunate that we have not yet lost Giant Sequoia groves in these fires, it is only a matter of time unless action is taken to reduce fuel loading and restore forest resiliency to the adjoining forests.

At a time when public confidence in the media and government is threatened by fake stories and rumors spread through social media, it is important to keep the debate grounded.  Reasonable people can disagree, but people who can’t agree on a common set of facts can never agree on more important questions.  Our whole system of government is undermined by the lack of trust.  An environment of disinformation and paranoia empowers extremist voices, leading to poor policies and suffering communities.

Clearly, there is some disagreement about the best way to protect Giant Sequoias in GSNM.  But a debate about the best policy is not moved forward by using misrepresentations to raise money.


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


Is the BLM Over Cutting?

It is often said that the BLM is not managing their lands sustainably and they are “over-cutting”.  Elsewhere in this blog we have explained how one determines the amount of timber that can be sustained over time.  Using those concepts, is the BLM overcutting?  The answer is, it depends.  It depends on if the BLM is managing its land consistent with the assumptions made in doing the sustained yield calculation.

For example, if the sustained yield calculation was based on managing 2 million acres and was one billion board feet per year and for various reasons the BLM felt it could only manage 1.5 million acres and they still were selling one billion board feet then, yes, they would be overcutting IF all 2 million acres were established and maintained under the same assumptions as were made when doing the sustained yield calculation.  If on the other hand, the 1.5 million acres contained a higher volume than the managed stand used in the sustained yield calculation, they would not be overcutting and could maintain a sale level of one billion board feet until that excess inventory was gone.  Are you confused yet?

Let’s use an example.  Using the process described in the previous blog, the BLM calculates that the average acre within the one billion board foot sustained yield calculation was based on growing a 21” tree in 60 years for an average volume per acre of 40,000 bf.  If the 2 million acres within their land base consisted entirely of stands under 60 years old and were being managed in a manner that their volume per acre at 60 years was 40,000 bf, then if they continued to harvest one billion board feet per year when their land base was reduced by 25% then they would be overcutting.  If the land base is reduced by 25%, the sustained yield would go down 25% to 750,000 bf if the potential of all acres is identical.

Now let’s assume that the 1.5 million acres the BLM is left with after removing 25% from the land base contained stands that were older than 60 and contained 80,000 bf/ac.  This is way more than what is expected under the sustained yield scenario.  In this case, every acre cut contains twice the volume of a sustained yield acre.  The BLM would not be overcutting if they maintained a harvest of one billion board feet.  They could actually harvest 1.5 billion BF for 60 years from those 1.5 million acres at which time they would have to reduce their harvest to 750,000 bf which is what the managed stands can sustain over time.

Another instance where they could harvest above their sustained yield level is if they aren’t managing their lands using the land management practices that were assumed to be used when doing the sustained yield calculation.  For instance, they might not plant areas with the same genetic characteristic, might not apply fertilizer, might not control stocking or might not regenerate and plant new trees as assumed in the sustained yield calculation.  Under these conditions, the lands would not be growing as anticipated and they could be over cutting.

The industry is worried that this might be the case as the BLM has not followed the management practices that were assumed when they did their sustained yield calculation 20 years ago.  Since the NWFP was adopted, the BLM has not regenerated and planted new trees as anticipated but rather relied on thinning existing stands to produce their ASQ.  While this has increased the standing inventory beyond what was anticipated, it has created a 20 year age gap that will affect future sustained yield calculations.

The BLM has never “over-cut” their lands as the vast majority of their stands contain way more volume than the sustained yield acre as in the example above.  Claims that they are doing so are merely attempts to discredit the agency and deceive the general public and have no basis in reality. -Ross Mickey


NEPA Run Amok

The Council on Environmental Quality (CEQ) states 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”.  In an attempt to meet that guidance and to comply with the National Environmental Policy Act (NEPA), the Medford BLM District compiled 1,559 pages of environmental analysis in 2016 in order to implement that year’s vegetation management program; a program that generated less than 60% of the District’s assigned timber outputs.  So much for brief and concise.

So how did the Medford District digress from this simple guidance by the CEQ?  How did brief and concise morph into embellished and verbose?  The answer can partially be found by skimming through the 170 pages of written protests received in 2016 by the Medford BLM in response to the 1,559 pages of analysis.  Many of the points embedded in these protests begin with phrasing such as “the EA failed to consider…” or “insufficient analysis in the EA…”  Apparently not everyone shares the vision of brevity that the CEQ had in 2007; perhaps brevity is not in everyone’s best interest.  The Code of Federal Regulations permits anyone the right to file a written protest to any BLM forest management decision.  The Code of Federal Regulations does not however limit or cap the scale of these protests.  In other words, you as a citizen can submit a ten-page protest or a 100-page protest; or a thousand-page protest for that matter.  This last scenario is a bit absurd and may seem to be an exercise in futility, but considering that the BLM has taken the position that every single protest point embedded in each protest demands its own written response, you might reevaluate; that is if it’s in your interest to generate more paperwork for the BLM.

To illustrate, put yourself in the shoes of a BLM NEPA writer who just completed a 418 page EA (if you don’t believe me follow this link), who then, in response to the recently completed mammoth document,  receives over 60 pages of protests with over 80 individual protest points embedded that warrant written response.  The term blinded by paperwork comes to mind, or more accurately mired in paperwork.  Now, put yourself in the shoes of an opponent/protestor of the BLM’s forest/timber management program.  Suddenly the mire you created for the BLM doesn’t seem so bad, or futile.  If halting the BLM’s timber management program is unattainable surely slowing it down is the next best thing.

As for our aforementioned BLM NEPA writer: following what must be an exhausting exercise in defending and justifying the recently completed 418-page behemoth in writing, and with the stack of last year’s EA’s, protests, and protest responses still sitting on your desk, that BLM NEPA writer gets started on writing next year’s EA’s.  Make no mistake, the excessive and constantly expanding verbiage generated for each new BLM EA is indeed a function of years and years of protests demanding more and more verbiage.  And really, what better way to undermine an agency’s ability, and desire for that matter, to operate efficiently than to force that agency into generating more paperwork?  With 2017’s timber sale program just around the corner I can already hear the opposition to that program cracking their knuckles in anticipation.

–Andy Geissler, AFRC Western Oregon Forester