SOS Forests

Climate Change, Bioenergy and Sustaining Forests of Idaho and Montana

Thoughts and comments by Ned Pence
March 3 and 4, 2010
Boise, Idaho

The following are my thoughts and comments on a recent conference sponsored by the Society of American Foresters and the University of Idaho’s College of Natural Resource. Others involved were the Forest Service, the BLM, the Intermountain Forest Association, Idaho Conservation League, the Wilderness Society, Idaho Department of Lands, the Rocky Mountain Elk Foundation, and the Nature Conservancy.  The Snake River Chapter of SAF deserves credit for the hard work that went into the conference.  A similar convention was held in Missoula last fall.

I attended the conference seeking information on the possibility of a bioenergy industry utilizing forest fuels with the possibility of sustaining forests in the inland empire. Attendance at the conference were a mix of foresters, environmentalists, and persons involved in attempts at collaboration between the federal agencies, public, forest industry and environmentalists in an attempt to find a solution to the current gridlock of forest management on federal lands.

The stated purpose was, “This conference will help people connect with global-scale issues regarding climate change, renewable energy, and carbon emissions on forests in Idaho and Montana. Discussions centered on strategies for sustaining our forests and the services people expect from them.”

Sponsors recognized the “sustainability premise” identified as “the current and future conditions of our forests determines their ability to contribute to our society’s energy security, climate change mitigation, and resilience goals.” It was recognized that the current forested conditions put the forests at risk of stand-replacing wildfire and insect and disease outbreaks. A key statement of the conference was that forest management actions must be ecologically sound, economically viable, and socially desirable to be sustainable. It is felt by conference organizers that forest managers can take action to meet “sustainability” only by obtaining a “social license” through collaboration. A few collaborative efforts are currently underway in Washington, Idaho, and Montana and the conference had sessions to discuss what has worked well and not so well.

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Open Letter to Ken Salazar Re WFLC

Letter in pdf format may be downloaded [here]

To: The Honorable Ken Salazar
Secretary of the Interior
1849 C Street NW
Washington, DC 20240

Re: Reconvening the Wildland Fire Leadership Council

Dear Secretary Salazar,

In a letter to western governors dated February 19, 2010, you indicated your desire to reconvene the Wildland Fire Leadership Council (WFLC). You also stated in that letter that you are committed working closely with “key stakeholders at all levels” to address wildfire issues.

Please be advised that the prior manifestation of the WFLC did not work with stakeholders but instead was a closed door, exclusionary, non-transparent Federal advisory group that violated various laws with impunity. The laws repeatedly violated by the WFLC include the Federal Advisory Committee Act (FACA), the National Forest Management Act (NFMA), the Endangered Species Act (ESA), the National Historic Preservation Act (NHPA), the National Environmental Protection Act (NEPA), and the Administrative Procedure Act (APA).

The WFLC excluded the public and the press from their meetings. They did however seat deep-pocket lobby groups including the Nature Conservancy and the Wilderness Society. Federal funds were passed to these lobby groups through the WFLC. The lobby groups also provide a “revolving door” of high-paying positions to former government employees formerly seated on the WFLC.

During closed door meetings in 2008 the WFLC directed the five Federal land management agencies under their purview to adopt Appropriate Management Response (AMR) and Wildland Fire Use (WFU). The agencies did so without implementing any NEPA process, without public comment or review, and in violation of the laws listed above.

As a result, numerous wildfires were allowed to burn without aggressive suppression actions. Tremendous destruction and degradation of natural resource values occurred. Some examples:

* South Barker WFU Fire (2008, Sawtooth NF, 38,583 acres) – The South Barker WFU Fire escaped and burned 38,583 acres. The fire eventually cost over $7 million to suppress. It incinerated miles of riparian zones, stripped erodable hillsides of vegetation, and destroyed forest plantations that had been carefully tended for 50 years.

* Gunbarrel WFU Fire (2008, Shoshone NF, 67,141 acres ) – The Gunbarrel WFU Fire was allowed to burn until it blew up. The fire eventually cost over $11 million to suppress. An estimated 420 residences, 11 commercial buildings, and 149 outbuildings were threatened and 7 buildings destroyed. The highway leading to Yellowstone Park was closed, and numerous residents were evacuated. During the fire USFS officials proudly declared that the MMA (Maximum Manageable Area, or desired incineration zone) was 417,000 acres (652 sq miles) and included public and private properties north and south of Highway 14.

* East Slide Rock Ridge WFU Fire (2008, Humboldt-Toiyabe NF, 54,549 acres) – The ESRR WFU Fire was allowed to burn unchecked until it blew up and threatened the community of Murphy Hot Springs, ID, as well as numerous rural ranches and farms. The fire eventually cost over $9 million to suppress. Riparian zones adjacent to stream habitat for endangered bull trout were incinerated.

* Mill Flat WFU Fire (2009, Dixie NF, 12,607 acres) – The Mill Flat WFU Fire was monitored until it blew up. The fire roared into New Harmony, Utah, forced the evacuation of 170 New Harmony residents, destroyed three homes and damaged eight buildings. The fire eventually cost over $6.5 million to suppress.

* Iron Complex AMR Fire (2008) – Including this fire, 650,000 acres were incinerated in Northern California on the Shasta-Trinity, Six Rivers, and Klamath National Forests. The fires were allowed to burn vast tracts for three months in implementation of “Appropriate Management Response.” Building firelines miles away from the fires and backburning hundreds of thousands of acres of private and public land alike, including habitat for two endangered species, Salmon and Spotted Owl, were deemed “appropriate.” Despite the indirect firefighting techniques, ostensibly intended to save money and protect firefighters, over $400 million was spent on suppression and 12 firefighters were killed.

* Basin/Indians AMR Fire (2008) – 244,000 acres of the Los Padres National Forest and private lands were incinerated in 3rd largest fire in California history. Despite indirect AMR methods, more than $120,000,000 was spent on fire suppression, making the Basin/Indians AMR Fire the most expensive fire in California history, and the 2nd most expensive in U.S. history (the Biscuit Fire in Oregon in 2002 cost $150,000,000). In addition, 26 private residences were destroyed.

Numerous other disastrous AMR and WFU fires could be cited. The suppression costs noted above do not begin to account for the cost-plus-loss damages inflicted, which were 10 to 30 times the nominal suppression expenses. Nor do they express the tragic loss of human life.

Both Secretary of Agriculture Vilsack and US Forest Service Chief Tidwell have recognized (in public speeches) that an increasing number of catastrophic wildfires are plaguing the Nation, and that a collaborative management approach to restoration and conservation are needed.

The secretive and non-collaborative WFLC has been the cause, not a source of solutions, of our ongoing forest fire crisis.

The Obama Administration has promised transparency, accountability, and tougher restrictions on lobbyists. In his 2009 State of the Union address, President Obama said, “Let me say it as simply as I can – transparency and the rule of law will be the touchstones of this presidency.”

The WFLC in its prior manifestation violated transparency and the rule of law with disastrous consequences.

Please be advised that if you reconvene the WFLC under the previous format and model, you will be doing a great disservice to America.

Sincerely,

Mike Dubrasich
Executive Director, the Western Institute for Study of the Environment

cc: Secretary of Agriculture Thomas Vilsack
Chief of the US Forest Service Tom Tidwell
Bureau of Land Management Director Bob Abbey
National Park Service Director Jon Jarvis
Governor Brian Schweitzer, Chairman, Western Governors Assoc.
Governor C. L. “Butch” Otter, Vice Chairman, Western Governors Assoc.
Ann M. Walker, Forest & Rangeland Health Program Director - WGA
NM State Forester Arthur Blazer, Chair, Western Forestry Leadership Coalition
AK State Forester Chris Maisch, Chair-Elect, Western Forestry Leadership Coalition
Congressman Doc Hastings (WA-04)
Congressman Greg Walden (OR-02)
Congresswoman Cynthia Lummis (WY)
Congressman Wally Herger (CA-02)
Congressman Denny Rehberg (MT)
Congressman Norm Dicks (WA-06)
Congressman Raúl M. Grijalva, (AZ-07)
Congressman Peter A. DeFazio, (OR-04)
Congresswoman Stephanie Herseth Sandlin, (SD)
Senator Ron Wyden (OR)
Senator Maria Cantwell (WA)
Senator John Barrasso (WY)
Senator James E. Risch (ID)
Senator Robert Bennett (UT)

Obama Admin Considering Lock Up of 13 Million Acres

Republicans Request Missing Pages and Documents on Administration’s Targeting of New Monument Designations

House Natural Resources Committee Republicans Press Release, February 26, 2010 [here]

WASHINGTON, D.C., Feb 26 - House Natural Resources Committee Ranking Member Doc Hastings (WA-04); National Parks, Forests and Public Lands Subcommittee Ranking Member Rob Bishop (UT-01); and 14 Members of Congress sent a letter today to Secretary of the Interior Ken Salazar requesting further information related to an internal DOI document that revealed the Administration is considering designating numerous new National Monuments that would lock up at least 13 million acres of land.

Secretary Salazar has publicly said that there is “no secret agenda” and wants to have a “public dialogue.” Therefore, the Department should be willing to answer questions regarding the exact undertakings and status of the potential Monument designations, as well as what outside group and individuals have been involved in the secret planning.

“If this internal document had not been exposed, Americans would still be in the dark about the Obama Administration’s potential plans to lock up millions of acres of land across the West,” said Hastings. “While Secretary Salazar says that the discussions are just ‘preliminary,’ no assurances have been given that the President will not designate these monuments. When you catch someone in the kitchen in the dark of night with their hand in the cookie jar, it’s very hard to believe they’re just checking to see what’s inside and that no cookies were just about to get eaten. The communities and those workers whose jobs could be directly affected by the locking up of these lands deserve to see a full picture of what was happening inside their government. We’ve asked for copies of documents relating to the planning, which includes coordination with outside groups, and all of the missing pages from the document we uncovered last week.”

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Open EAJA Act of 2010

From: Budd-Falen Law Offices, LLC
300 East 18th Street
Post Office Box 346
Cheyenne, Wyoming 82033-0346

Call To Action

Tuesday March 2, 2010 Is the Day!!!

Western Legacy Alliance is proud to announce that on Tuesday, March 2, 2010, Congresswoman Cynthia Lummis (R-Wy) and Congresswoman Stephanie Herseth-Sandlin (D-S.Dak) will introduce the “Open EAJA Act of 2010.” This Act is a start to bringing transparency and accountability, and level the playing field in the payment of attorney fees. Research has documented that radical environmental groups are reaping millions and millions of dollars of taxpayer funding from suits against the federal government which push their radical agendas and beliefs — $42 million and counting. These groups are being paid by the federal government to sue the federal government using American taxpayer dollars.

If passed, the “Open EAJA Act of 2010″ would require the federal government to create a publicly searchable database of all attorney fees awarded under the Equal Access to Justice Act (”EAJA”) including the total amount of attorney and expert fees paid in each case, the hourly attorney fee charged and who is collecting the American taxpayers’ money. This is the first step to leveling the playing field and stopping the abuse of the legal system.

I have a short-term request and a long-term request for you.

Short-term: By Tuesday morning, March 2, 2010, please e-mail or mail a note of support for this legislation. We need as many groups and organizations as possible to support the introduction of this bill.

Long-term: Upon introduction, please contact your Congressmen and request that they co-sponsor this legislation.

Shedding light on the payment of taxpayer money under EAJA will start to bring the transparency and accountability to this system. Please help to get this bill started on the right track.

Letters of support from organizations and individuals may be sent to me for forwarding or can be sent directly to Congresswoman Lummis. Please also copy <WesternLegacyAlliance at gmail.com> on your letters.

Thank You!!
Karen Budd-Falen
February 25, 2010

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Nicholas Dennis: Put National Forests To Work For Community

Note: This guest editorial appeared in the February 14th edition of the Redding Searchlight [here], and at Evergreen Magazine Online [here]

By Nicholas Dennis

Last August, Agriculture Secretary Tom Vilsack visited Seattle to deliver a speech laying out the Obama administration’s goals for conserving the national forests. Vilsack noted that polarization has long dominated the national forest agenda, but that the threats currently facing the forests make it imperative to move toward a shared vision “that conserves our forests and the vital resources important to our survival while wisely respecting the need for a forest economy that creates jobs and vibrant rural communities. Our shared vision begins with restoration. Restoration means managing forest lands first and foremost to protect our water resources, while making our forests more resilient to climate change.” Closer to home, California Regional Forester Randy Moore lists five strategic priorities for managing the state’s national forests on the region’s Web site. Unfortunately, sustaining rural communities isn’t mentioned.

Restoration forestry is not the way national forests were managed before the spotted owl listing. Restoration does not involve clear-cutting, at least not in our mixed-conifer forests. It involves selecting smaller trees from crowded patches in the forest understory, patches that if unmanaged would likely fall prey to insects, diseases or stand-replacing wildfires. Who would oppose forest restoration? Professional appellants, such as the Montana-based Conservation Congress, who make their living filing claims for legal fees have used appeals and litigation to stop or stall several local restoration projects that would otherwise have improved forest health and created dozens of well-paid jobs. These self-serving outsider legal challenges have increased unemployment, decreased revenues for schools and county governments, and undermined economic opportunities in our rural communities.

Last year, a Natural Resources Defense Council spokesman lauded the 700,000-acre addition to the federal wilderness system in California, proclaiming wilderness the “gold standard for forest protection.” Shasta-Trinity and Klamath National forests neighbors will see the irony in this statement after the fires that burned uncontrolled through the forests, including wilderness areas, in three of the past four summers, causing sickening air quality. Protecting forests takes more than Congress redrawing maps. It requires the hard work of restoration by a skilled forest work force.

Rural communities in Shasta, Siskiyou and Trinity counties are not economically vibrant today. The recent recession has only deepened a downward trend that’s continued since federal timber harvests plunged in the early 1990s. Layoffs and social service cutbacks have taken a heavy toll on families. Essential public infrastructure repairs have been postponed indefinitely. Empty storefronts are gradually dominating our main streets. The Siskiyou County district attorney recently opted not to prosecute an alleged child murderer based on fiscal considerations. But bad as things are, wait until Secure Rural Schools and Community Self-Determination Act funding runs out in three years, as it surely will. Then the pinched budgets for the three counties will have to absorb an additional $18 million hit and our collective belt-tightening will take on a different specter.

All conceptions of forest sustainability give social and economic resources equal priority to environmental resources. The Northwest Forest Plan was intended to restore national forests and rural communities. Yet of all the major commitments in that plan, only one has never come close to being met: the commitment to harvest enough timber to sustain reasonable levels of forest-sector employment. Over the past decade, the Shasta-Trinity and Klamath National forests have sold less than half the timber called for in their land management plans.

The need to manage our national forest assets so as to provide sustainable income sources is as valid today as ever. A 2009 economic study for the National Association of Forest Owners found that the average per-acre contribution to gross domestic product from public forests in California was only 18 percent of the average contribution from privately owned forests. When public forests don’t do their share to create wealth, they become more of a liability and less of an asset for rural communities.

The U.S. Forest Service has been doing its best to get forest management projects approved and implemented, but it’s fighting a losing battle. The ground rules are stacked against it, varying from abuses of the Equal Access to Justice Act, which rewards nearly all litigants, to planning rules addressing sensitive species that are so complex that even in-depth expert assessments can’t pass legal muster. Former Forest Service Chief Dale Bosworth aptly described this as “analysis paralysis.”

Two things need to happen to put the national forests to work for our communities. The agency’s planning rules must be changed to make it feasible to get projects through the environmental compliance process. And we must align behind a shared vision for forest restoration and make clear to its opponents that their obstructionism is counterproductive and unwelcome.

Nicholas Dennis is chairman of the Northern California Society of American Foresters. He lives in Weed.

NEPA Process to Include Climate Change and Greenhouse Gas Emissions

THE CEQ announced today in the Federal Register that “climate change and greenhouse gas emissions” must be considered in future NEPA processes.

The Council On Environmental Quality (CEQ) is the Federal board charged with implementing the National Environmental Policy Act (NEPA).

Enacted in 1970, NEPA mandates that Federal agencies consider the environmental impacts of their proposed actions before acting, principally through the preparation of Environmental Impact Statements (EISs) or Environmental Assessments (EA’s).

The announcement [Federal Register: February 23, 2010 (Volume 75, Number 35)][Notices][Page 8046] requests that public comments be submitted before the CEQ adopts the new “guidance” regulations.

The proposed new regulations also modify language related to Categorical Exclusions (CEs) and mitigation and monitoring.

More information is available at the following CEQ websites:

New CEQ NEPA Guidance [here]

In conjunction with NEPA’s 40th Anniversary Celebration, CEQ is publishing three draft NEPA guidance documents for review and comment. Below are links to the draft guidance documents and instructions for submitting comments:

- ESTABLISHING AND APPLYING CATEGORICAL EXCLUSIONS [here]

Comments are due 45 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

- MITIGATION AND MONITORING [here]

Comments are due 90 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

- CONSIDERING GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE [here]

Comments are due 90 days after publication of the Federal Register notice.

Submit Comments to http://www.whitehouse.gov/ceq/initiatives/nepa

Additional information is available at www.whitehouse.gov/administration/eop/ceq/initiatives

The Fire Next Time

By Jim Petersen, Co-founder and Executive Director, the non-profit Evergreen Foundation

Remarks at the Annual Meeting of Intermountain Forestry Association, Coeur d’Alene, Idaho, December 10, 2009

Full text [here]

Selected excerpts:

…[M]y friend Dick Bennett asked me recently… if I knew where we might find a map showing all of the timberland ownerships in northern Idaho — not just an ordinary map, but one that had an overlay that shows at risk federal forest lands — these being lands that pose an insect, disease or fire risk to adjacent private and state timberland owners.

I thought for sure that the Forest Service’s Region 1 office in Missoula would have one, but they don’t.

How strange that the very public agency charged with protecting our region’s great forests from catastrophic fire would not have such a map. …

If we had the map Dick hoped I would find we could illustrate the problem with the very cavalier attitude the federal government seems to be taking toward dying national forests and resulting big fires.

Among other things, we could show the public what will happen when the Day of Reckoning finally arrives — and we have another 1910-scale fire or perhaps something even larger, which I think is entirely possible. …

I have photographs of my grandfather’s first mill. It doesn’t look like much, but it was all that he had, so I can’t begin to comprehend what he must have felt on the afternoon of August 20, 1910. That was the afternoon when all hell broke loose in northern Idaho: Day 1 of the three-day holocaust we still call the Great 1910 Fire.

Much has been written about the 1910 fire, not just in Evergreen Magazine but also in many other publications by other fine writers who were drawn to it as I was — all of us like moths to a flame. …

I won’t bore you with the reasons why the West’s forests are burning in horrific wildfires because you already know the story as well as I do. But if you are one of the fortunate few who saved their copies of The West is Burning Up, our first big 1910 story — portions of which still grace the Idaho Forest Products Commission website — you know that the fire made front page news all across the nation. …

In two terrifying day and nights, more than 3 million acres of timber and grassland in northern Idaho and western Montana was incinerated. It is all very difficult to comprehend until you realize that the Great 1910 Fire was not one big fire when it started. It was several hundred smaller fires that were blown together by the force of 80-100 mile an hour winds that blew in from the Palouse on the afternoon of August 20. It was the wind that transformed all of those little fires into one big blowtorch.

Along the Idaho-Montana border, south of the Lookout Pass ski area, there are still spots were nothing grows. Heat from the fire melted the organic layer in which early succession plants normally take root after a fire. The area is windswept, so it may be hundreds of years before the slowly accumulating soil is again deep enough to support plant life.

People who know that I know a little bit about the 1910 Fire sometimes ask me if I think there is another fire like it in our future. The odds certainly favor it. All we need are a few hundred spot fires - probably set by lightning - and a big wind. The stars in this terrible constellation have been in near-perfect alignment several times in recent years.

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Dry Rot Eating Away At Ron Wyden’s Eastside Forests Bill

Told you so! Sen. Ron Wyden’s proposed “Oregon Eastside Forests Restoration, Old Growth Protection, and Jobs Act of 2009″ (OEFROGPJA) is dead in the water and sinking fast. Dry rot is eating away the timbers, and worms are attacking the hull.

Yesterday an eco-litigious group, the Hells Canyon Preservation Council (HCPC), sent Ron an 11-page letter [here] that says, in short, goodbye Charlie.

Previous posts regarding Wyden’s bill (OEFROGPJA) are:

Wyden Proposes the End of Forest Stewardship in Eastern Oregon [here]

AFRC Sells Out [here]

The Principal Defects in Wyden’s Forest Bill [here]

Harris Sherman on Jon Tester’s Forest Bill (same problems in both bills) [here]

What’s wrong with the eastside forest compromise (by Jack Ward Thomas) [here]

Summarizing the Defects in Wyden’s OEFROGPJA [here]

That last one lists and numbers all the flaws in OEFROGPJA. The eco-lits missed all those, except for #11: will not limit or preclude obstructionist lawsuits. The HCPC plays the litigation card in a few places in their letter:

If a main purpose of this Act is to reduce litigation over timber harvest projects, then the elimination of the administrative appeals process during the Interim Period is, simply put, a mistake. HCPC has a long-history of successfully using the appeal process to negotiate with the Forest Service and to ultimately avoid litigation in the vast majority of cases.

The vast majority? But of course, not all. Have lawyers, will sue. That EAJA pot o’ gold is just too tempting.

The HCLP also played the climate change card (no surprise there) and bemoans the switch from a 20-inch-diameter cut limit to a 21-inch-diameter cut limit. Horrors!

Perhaps most amusing is the backbiting against Oregon Wild, the eco-litigious extremist group that engineered the “compromise”.

The non-inclusive process by which the bill was developed was not an auspicious start. We find it highly ironic that a bill encouraging eastside local collaboration was developed without input from any eastside conservation groups. While we have much in common with our westside conservation partners, we could have brought well-needed on-the-ground knowledge to the drafting of this bill. …

In our opinion, excluding eastside groups from the drafting of the bill was also a strategic error. When we have discussed the bill with other interest groups they have reacted strongly to the exclusion of eastside groups. As this bill makes clear, to be effective, collaboration must include all stakeholders, especially those with a long history of committed involvement in the issues and areas at stake. To proceed without the involvement of local stakeholders has undermined the very goals that the bill purports to establish.

HCLP fails to mention that everybody in Eastern Oregon was excluded, not just the wackos. In fact, everybody everywhere was excluded, except for a handful of eco-nazis from Eugene.

Even the fawning Oregonian, which kisses the ground Wyden walks upon upon, had to admit his bill is twitching and gasping [here]:

Despite the unique coalition backing the bill, its chances in congress are uncertain.

“Uncertain” is a code word for all but six feet under. Is that the dirge music I hear?

Told you so. And good riddance, too.

W.I.S.E. Comments on the USFS Planning Rule

We have discussed the US Forest Service intention to create a new Planning Rule [here] and offered some guidance, written by NAFSR Exec Dir Darrel Kenops, for drafting comments [here].

Now we present our own Comments, submitted today [here].

Some other excellent comments include those written by W.I.S.E. member Randy Shipman [here], by the National Association of Forest Service Retirees [here], and  by Julie Kay Smithson of Property Rights Research [here]. And comments by Tim Bailey, Natural Resource Project Planner, Willamette National Forest are [here]. And the comments from the Coalition of Local Governments of Wyoming are [here].

Some excerpts from the W.I.S.E. Comments on the Scope of Analysis for the DEIS [here]:

*****

The biggest threats to forest and grassland health are catastrophic fires that alter ecosystems, destroy forests, and convert forests to fire-type brush. … Those impacts are immediate and also accumulate over the long-term. …

In addition, other threats to forest and grassland health are insect infestations, disease epidemics, and passive-reactive management. Litigation due to over-reliance on the unnecessary National Planning Rule and LRMPs instead of project-by-project EISs is also a major threat to forest and grassland health. …

Forest restoration means active management to bring back historical cultural landscapes, historical forest development pathways, and traditional ecological stewardship to achieve historical resiliency to fire and insects and to preclude and prevent a-historical catastrophic fires that decimate and destroy myriad resource values.

Forest restoration requires active management to remove, through mechanical means and with scientific silviculture, a-historical fuel loadings. Follow-up treatments with prescribed fire are also required, but not until forests are prepared to receive fire without catastrophic results.

Landscape-scale forest restoration is an alteration of the USFS mission. More attention must be paid to restatement of the mission, preferably by Congress. As it stands, the USFS has lost sight of any coherent mission. …

Landscape-scale forest restoration is an alteration of the USFS mission. …

The current Secretary of Agriculture, Tom Vilsack, and the current Chief Forester, Tom Tidwell, have both made public vision statements that specifically incorporate forest restoration as the overriding goal of their respective tenures.

The Planning Rule must state or restate the mission of the USFS. …

In addition to articulation of the mission, to foster restoration the concept of Historical Range of Variability (HRV) must be dropped.

There is no such thing as HRV. Each watershed has a real and specific history. There is nothing random or stochastic about history; it is what really happened. Historical conditions were what they were. There is nothing flexible or malleable about history. It is non-fictional.

The Planning Rule must specify that real landscape history must be studied and elucidated for each planned project. History is an important part of the concept of forest restoration. …

In the case of forests, the previous condition in general was open, park-like, widely spaced trees arrayed in an anthropogenic mosaic of prairies, savannas, fields, and woodlands and maintained by anthropogenic fire. The previous condition was not wilderness but was modified from “natural” by extensive historical human influences intentionally administered by the residents.

The USFS must undertake studies, perform research, convene symposia, and encourage the full and scientific investigation of forest history on a watershed-by-watershed basis within each NFS unit.

The USFS must acknowledge and elucidate the historical human influences that helped to create and maintain historical conditions.

Heritage is not an afterthought; the protection of heritage must be part and parcel of USFS planning and actions. …

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Your Story Is Your Brand

Note: I am busy preparing my comments for the National Forest System land management planning rule DEIS. In the meantime, for your reading pleasure and general edification, I highly recommend:

Your Story Is Your Brand

A speech by Jim Petersen, Co-founder and Executive Director, the non-profit Evergreen Foundation

To the Thirty-third Annual National Indian Timber Symposium, Lewiston, Idaho, April 20-23, 2009

which may be viewed [here].

Selected excerpts:

Scientific forestry has been with us for a very long time. Its principles come to us from the Prussian School of Forestry. They were first taught in our country by Bernard Fernow, who set up the old Division of Forestry, which later became the U.S. Forest Service, and Carl Schrenk, who set up the first demonstration forest at Biltmore, Cornelius Vanderbilt’s fabulous country estate in North Carolina. I believe both Fernow and Schrenk were graduates of the Prussian School of Forestry.

But there are much earlier examples of the successful manipulation of land by people in pursuit of civilization’s most basic necessities: food, clothing and shelter. One of them is referenced in the diary of a soldier who was part of the Desoto Expedition that marched the length of Florida in the 1500s. He wrote about the vast corn fields that he observed - part of the highly advanced maize-based culture Indians established along the eastern seaboard in Lord only knows when.

Archeologists were to later discover remnants of water diversion systems in the Southwest, where some of your ancestors irrigated crops hundreds if not thousands of years ago.

Early white explorers also found you using fire to manage your forests - in many ways a tool every bit as efficient as chain saws and mechanical harvesting systems.

Today, we are again using fire in our forests, and some of us think we invented it. Of course, we did not - you did - and I tend to think its modern-day use is as much for political purposes as it is for reasons have to do with the need to remove excess biomass from forests.

Although you ancestors did not have science in the same way we have science today, they were nonetheless very keen observers of nature - and equally important - they were pursuing a goal or objective, which was to feed, clothe and shelter their number by first manipulating nature. …

Somehow, we need to find a way to build on this idea. What passes for forestry on federal lands today is a travesty. Even so, it’s unlikely that the Congress is simply going to hand you the keys to the national forest system. But they might be interested in setting up some very large demonstration projects that you could manage the way you manage your own forests. What if the Colville tribe had the chance to actually manage say, half the Colville National Forest through the next rotation? What if the same opportunity were given to the White Mountain Apache or the Yakama or any other tribe that owns and manages timberland adjacent to a national forest?

Does this idea have any validity? I’d like to think so, but then I am biased in your favor. Be that as it may, I sincerely believe that a side-by-side comparison of what you are doing on your lands with what the government is doing on federal lands would give the public the opportunity they need to decide once and for all which management program yields the results they prefer: yours or the governments. I can’t help but think they’ll like what you do much better than they like what the government is doing.

As you can readily see, there is a lot to think about in the larger context of what branding is, how brands are created and what branding may bring to tribes that own and manage timberland in these United States. Since 1986, we have made it our mission at Evergreen to tell the forestry story in all of its grandeur - and where forestry converges with cultural, historic and spiritual values I know of no grander story than yours.

Always, always, always remember, your story is your brand, and thus a window on your soul. And always remember that where your story is concerned, we will be with you every step of the way.

Contradicting Missions and the New USFS Planning Rule

Last December the US Forest Service announced their intention to create a new Planning Rule [here]. We presented some guidance, written by NAFSR Exec Dir Darrel Kenops, for drafting comments to assist the USFS in that process [here].

Now we present some excellent comments written by W.I.S.E. member Randy Shipman of Rock Springs, Wyoming. For a pdf version of Mr. Shipman’s comments, click [here].

BTW, comments must be received by February 16, 2010.

****************

February 12, 2010
Forest Service Planning NOI
C/O Bear West Company 172 East 500 South Bountiful, UT 84010
via fspr@contentanalysisgroup.com

Reference: Federal Register/Vol.74, pp 67165-67169 – Notice of intent to prepare an environmental impact statement to analyze and disclose potential environmental consequences associated with a National Forest System land management planning rule.

—–

The USDA-USFS has allowed itself to gradually be placed into a contradiction of missions, in part, by purging itself of professional foresters and engineers to make way for a new grand experiment as explained by the Committee of Scientists. Today, the USFS with the aid of the Congress have provided the taxpayer an agency that:

* has not retained workforce expertise to promote and finalize rule promulgations in concert with local affected governments and sometime the public as is consistently proven through the hiring of 3rd party contractors to disseminate information to the public and the agency;

* allows confusion of purpose within its ranks as proven through inconsistent application of planning methodology and/or policy or directive that currently exists between identical forest regimes in adjacent districts or regions;

* provides excuses to the public rather than a system of accountability when USFS actions impact private, local and state real properties;

* knowingly relinquished the charge of the agency’s Organic Administration Act among others in the promulgation of the 2000 36CFR219 rule and associated rules that require consistency with the ill-conceived 36CFR294 Roadless Area Conservation rule promulgation;

* is increasingly becoming a drag on the entire U.S. economy by devastating local forest dependent community stability through internal dictatorial processes that today is purposely leaving local and state governments out of the loop and on the hook to pay for and pick up the pieces of carnage that have followed three decades of USFS attempts to be “responsive to the challenges of climate change; the need for forest restoration and conservation, watershed protection, and wildlife conservation; and the sustainable use of public lands to support vibrant communities.” No one can be entirely certain what that really means, with perhaps the exception of those individuals or organizations who professionally and constantly litigate USFS processes in order to gain easy access to federal government funds rather than address issues found in the Substantive Principles for a New Rule. But then that is a particular matter for the Congress to account.

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Ecosystem Management and Statist Bureaucracy

Nearly twenty years ago the US Forest Service adopted “ecosystem management” as a primary mission. Ecosystem management is a nebulous term that means whatever they want it to mean, and surprise surprise, it has entailed a massive transfer of power from the individual to the state.

An excellent synopsis of the meaninglessness of the phrase, and of the statist power grab that lies hidden beneath the veneer of “ecosystem management”, may be found in our latest addition to the W.I.S.E. Colloquium, Forest and Fire Sciences [here]

The paper is:

Travis Cork III. 2010. The Fictional Ecosystem and the Pseudo-science of Ecosystem Management. W.I.S.E. White Paper No. 2010-3, Western Institute for Study of the Environment.

This is the third in our new series of White Papers. More are to come.

It has been our practice to place most comments regarding Colloquia papers here at SOS Forests. We don’t wish to clutter the Colloquia with off-topic and less than scholarly comments, but we do encourage your participation in the discussion. So comments on Mr. Cork’s paper should be directed towards this post.

If you have a pertinent scholarly commentary that meets the quality criteria of our Colloquia editors, then we can place it over there. We reserve the right to control placement.

Some excerpts from The Fictional Ecosystem and the Pseudo-science of Ecosystem Management by Travis Cork III:

LAND USE CONTROL has long been the goal of the statist element in our society. Zoning was the first major attempt at land use control. Wetland regulation and the Endangered Species Act have extended some control, but nothing has yet brought about a general policy of land use control. Ecosystem management is an attempt to achieve that end.

In The Use and Abuse of Vegetational Concepts and Terms, A. G. Tansley coined the term “ecosystem.” Tansley rejected the “conception of the biotic community” and application of the “terms ‘organism’ or ‘complex organism’” to vegetation. “Though the organism may claim our primary interest, when we are trying to think fundamentally we cannot separate them from their special environment, with which they form one physical system. It is the systems so formed which, from the point of view of the ecologist, are the basic units of nature on the face of the earth. … These ecosystems, as we may call them, are of the most various kinds and sizes… which range from the universe as a whole down to the atom” 1/

The ecosystem may be the basic unit of nature to the ecologist, that is—-man, but it is not the basic unit to nature. Its proponents confirm that it is a man-made construct. …

The nebulous nature of the ecosystem has not deterred bureaucrats, statist academics, and green advocacy groups (GAGs — The Nature Conservancy, Sierra Club, Audubon, et al.) from pushing it as the basic management unit in nature. …

Lack of a rigid operational definition of an ecosystem gives the designer a blank check. Corruption and exploitation are inevitable. …

Given that Mother Nature does not delineate ecosystems, who will delineate these fictional ecosystems? The answer is obvious, the self-interested elitists in the ruling class. …

Supporters of the fictional ecosystem demand that it be managed. Enter the pseudo-science of ecosystem management. …

A management policy that cannot define its basic unit, the ecosystem, cannot have clear, operational goals. It cannot be based on sound models or understanding at any scale or in any context.

That life is complex is no argument for the ecosystem or ecosystem management, especially by government. No entity is less prepared to deal with complexity or to be adaptable and accountable than bureaucracy. …

Ecosystem management will mean more government control. It will intrude on private property rights. If a justification is to be created using the Constitution, it will result in a further perversion of that document and our long-lost republican form of government. …

The ecosystem management literature is filled with this command-and-control, central planning mentality. Ecosystem management is a process rife with opportunities for exploitation and corruption by government and its allies. …

Palin likens global warming studies to ’snake oil’

Note: Former Alaska Gov. Sarah Palin spoke at the Sierra-Cascade Logging Conference in Redding, CA yesterday. The following is the AP report.

Palin likens global warming studies to ’snake oil’

By JUDY LIN, San Jose Mercury News, 02/08/2010 [here]

REDDING, Calif.—Former Alaska Gov. Sarah Palin called studies supporting global climate change a “bunch of snake oil science” Monday during a rare appearance in California, a state that has been at the forefront of environmental regulations.

Palin spoke before a logging conference in Redding, a town of 90,000 about 160 miles north of the state capital. The media were barred from the event, but The Associated Press bought a $74 ticket to attend.

Palin said California’s heavy regulatory environment makes it difficult for businesses to succeed, a point that is shared by many business leaders in the state.

She criticized what she said were heavy-handed environmental laws. As Alaska governor, for example, she said she sued the federal government to overturn the listing of polar bears as a threatened species.

As Alaska North Slope wells dry up, the state is examining offshore drilling for oil and natural gas reserves. Protections for polar bears under the Endangered Species Act could thwart those explorations, according to Palin and her successor, Alaska Gov. Sean Parnell, who has picked up the cause.

Palin told the audience that filled the 2,000-seat Redding Convention Center that she disagreed with the science the government used to support the listing.

“We knew the bottom line … was ultimately to shut down a lot of our development,” she said during her 40-minute speech, which was followed by a 20-minute question-and-answer session.

“And it didn’t make any sense because it was based on these global warming studies that now we’re seeing (is) a bunch of snake oil science.”

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Battling Over the Forest Restoration Meme

When does “forest restoration” mean “abandonment to catastrophic destruction”? Answer: in the “Green Budget 2011″ proposal.

A coalition of quangos (quasi-governmental non-governmental organizations) is playing games with words. They want the word “restoration” to mean the opposite of what it actually means, prompting a battle over the meme.

The “Green Budget 2011″ [here] was prepared by 34 “environmental” lobbying groups including perennial litigation-happy bullies such as Defenders Of Wildlife, Earthjustice, Environmental Defense Fund, National Audubon Society, Natural Resources Defense Council, Sierra Club, The Wilderness Society, and the World Wildlife Fund. Note that these same groups are the big pigs at the EAJA trough, raking in $billions from the government to sue the government in order to sabotage restoration programs [here].

The Green Budget 2011 defines “restoration” this way:

Restoration management should be viewed as a way to recover the natural processes, structure, composition and function of a healthy forest ecosystem; it is an intentional effort to restore land, air, and water degraded by human activities to a more natural state, enhancing our forests’ ability to adapt and be resilient to disturbances and change. This is a separate and distinct vision from traditional logging or hazardous fuels reduction; while these activities may have a place on national forests, the goals and objectives are not necessarily consistent with ecosystem restoration, and the terms should not be used interchangeably.

In other words, to the quangos “restoration” means No Touch, Let It Burn, Watch It Rot.

In actuality, real forest restoration means active management to bring back historical cultural landscapes, historical forest development pathways, and traditional ecological stewardship to achieve historical resiliency to fire and insects and to preclude and prevent a-historical catastrophic fires that decimate and destroy myriad resource values.

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Summarizing the Defects in Wyden’s OEFROGPJA

I fear that I have been too florid in my analyses of Sen. Ron Wyden’s proposed “Oregon Eastside Forests Restoration, Old Growth Protection, and Jobs Act of 2009″ (OEFROGPJA). My excess verbiage has obscured the key defects. In this post I simplify and specify with minimal artisticality of prose.

Previous posts regarding Wyden’s bill (OEFROGPJA) are:

Wyden Proposes the End of Forest Stewardship in Eastern Oregon [here]

AFRC Sells Out [here]

The Principal Defects in Wyden’s Forest Bill [here]

Harris Sherman on Jon Tester’s Forest Bill (same problems in both bills) [here]

What’s wrong with the eastside forest compromise (by Jack Ward Thomas) [here]

From those I have extracted the main issues, and who made the particular point:

1. prescriptive language violates NEPA and NFMA (Harris Sherman) (Mike Dubrasich)

2. draws action and funding away from other projects (HS)

3. will NOT result in any increased harvest (HS) (MD) (Jack Ward Thomas)

4. creates unrealistic expectations on the part of communities and forest products stakeholders (HS)

5. provisions are duplicative of existing authorities, such as the Forest Landscape Restoration Act of 2009 (HS) (MD)

6. will not achieve undefined “comprehensive ecological restoration” (MD)

7. proposed management guidance by “plant association” scientifically untenable, unmappable, obtuse (MD)

8. statutory limits on the size of trees removed scientifically untenable, unworkable, will not achieve resiliency goals (MD)

9. proposed management guidance by “site potential tree heights” scientifically untenable, unmeasurable, obtuse (MD)

10. proposed management guidance by “heterogeneity” scientifically untenable, unmeasurable, obtuse (MD)

11. will not limit or preclude obstructionist lawsuits (which have already been threatened by eco-litigious groups) (MD) (JWT)

12. delays and implementation failures will lead to more and larger destructive (severe, high intensity) wildfires (MD)

13. does not protect (increases risks to) heritage, utility, resiliency, sustainability, public health and safety, private property, and other human values (MD)

14. does not protect (increases risks to) vegetation, habitat, wildlife, water, air, soils, and other ecological values (MD)

15. “local forests” managed under separate laws and overseen by advisory panels financed with federal dollars and staffed with federal employees supplant current legally prescribed planning and management processes (JWT)

16. no guarantee of long-term funding (JWT)

17. does not address systemic problems with USFS mission, existing conflicting laws (JWT)

Hope that helps.