16 Feb 2010, 10:25am
Federal forest policy
by admin

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. …

The best proactive and innovative action the USFS can undertake to respond to unknown climate changes is to actively pursue and implement forest restoration. The re-creation of historically diverse and resilient forests, with reduced susceptibility to pathogens and large fire, is the best insurance against future climate perturbations.

Throughout the Holocene, human-mediated landscapes have proved to be resilient. The evidence includes the presence of old trees, some as much as 600 years old or more. Trees that grew in open, park-like forests (maintained by anthropogenic fire) persisted through whatever climate changes occurred in the past, including the Medieval Optimum and the Little Ice Age. …

Uncertainties about the future cannot be reduced, but resiliency can be enhanced through forest restoration. …

Some forest structures (open and park-like forests maintained with anthropogenic fire) have proved to be resilient to a variety of stressors. In the face of uncertainty about the future, restoration to those resilient historical structures is the most precautionary path. …

Watershed health is, or should be, critical to the mission of the USFS. Water is the most important and valuable resource produced on USFS lands. Water is of economic importance to forest-influenced communities, rural residents, farmers, hydropower generation, fisheries, and downstream to urban populations and economies.

The single greatest threat to watershed health, and by extension to water users and aquatic resources, is catastrophic wildfire. The new planning rule must lead to the mitigation of wildfire risks and hazards, including the misguided “use” of unplanned wildfire. …

In addition to catastrophic wildfire, “wildfire use” (aka “wildfires used for resource benefit”) have had significant detrimental effects on water quality, stream flow, forest hydrology, and riparian and aquatic conditions. Additional acreage has been unnecessarily burned, and additional impacts have ensued.

“Wildfire use” has been adopted into many Land and Resource Management Plans (LRMPs) without appropriate NEPA processes. In no case has a single Environmental Impact Statement (EIS) been written for “wildfire use.”

The expectation that “using” wildfires will “benefit” resources indicates that significant impacts and effects on resources will occur as a result. NEPA is clear that significant effects require an EIS, whether or not those effects are characterized as detrimental or beneficial. …

The locations of the unplanned wildfires are unknown and unpredictable. Planners cannot plan the location or date of “wildfire use” wildfires ahead of time. They cannot evaluate the potential effects on watersheds.

Unplanning is not planning. The adoption of unplanning has supplanted the identification of suitable lands, the collection of inventory data on the various renewable resources, and the identification of special conditions or situations involving hazards to the various resources. …

The lack of active management and scientific forest restoration has allowed massive fuel build-ups. A-historical fuel conditions have led to a spate of megafires that have decimated, degraded, and severely damaged water quality and quantity. The negative impacts of catastrophic fire are both immediate and long-lasting.

Over the last 20 years the largest and most damaging wildfires in state history have occurred in every state in the West. Passive and reactive management have exacerbated the still growing danger of catastrophic wildfires.

The responsibility for those disasters, and for predictable and preventable future disasters, rests squarely on the USFS. There has been a remarkable lack of accountability on the part of the Agency.

That has to stop. The USFS leadership needs to assume responsibility and pursue active management to lessen the size and intensity of wildfires. The era of management passivity and “Let It Burn” must come to an end now. …

Planning should focus on project level watershed or landscape-scale units. Species diversity provisions should be addressed as specifically directed in the NFMA; that is, in the context of and conditioned by overall multiple-use objectives, where appropriate, and to the degree practicable. …

Other than the deliberate incineration of forests with “wildfire use,” there has been no more significant abrogation of the law over the last 20 years than the collapse of the USFS timber sales program.

That collapse has led to severe economic hardships in rural and forest-related communities across the Nation. The economies of entire regions have been negatively impacted because USFS planning has failed to abide by the statutory mandates of NFMA and the Multiple-Use, Sustained-Yield Act of 1960 (MU-SYA).

The New Planning Rule must direct NFS units to conform to the requirements of NFMA and MU-SYA: to provide for multiple use and sustained yield of products and services and to consider the economic stability of communities whose economies are dependent on such national forest materials. …

There is no provision in the NFMA for “sustained development of ecosystem purposes.” Indeed, there is no mention of the word “ecosystem” in the NFMA.

From Cork, Travis 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 [see References].

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.

There is no statutory mandate to plan for “ecosystem purposes.” Indeed, there is no way to plan for such a non-mandated, undefined, and nebulous concept. …

Natural resource conservation and restoration do not constrain or diminish the multiple use and sustained yield of products and services. On the contrary, conservation and restoration increase sustained yields through active management.

In contrast, abandonment of the land through roadless and wilderness designation is a form of un-management and anti-conservation. Not only are sustained yields of products and services eliminated, catastrophic fires arise that destroy resources both within and beyond designated legal boundaries.

Designating wilderness and roadless areas is not restoration, either. History teaches us that our forests and grasslands have been homelands to resident humanity for thousands of years. It has been active human stewardship that has maintained and perpetuated resilient forests, savannas, and prairies over millennia. Restoration restores stewardship: traditional active human mediation that produces the products and services required for human survival while maintaining and enhancing the productivity of the land.

The economic stability of communities whose economies are dependent on national forest materials are enhanced by conservation and restoration. …

The USFS has lost the ability to communicate with the public because the Agency does not understand that communication is a two-way street. The tone and wording of this question betrays that fact.

The USFS is not a learning institution. That is, they cannot listen and therefore cannot learn or adapt to public input. It is a fool’s errand to attempt to teach the USFS. The irony of that is not lost on this commenter, since the effort put into these comments will undoubtedly reach deaf ears only.

A better example: many of the queries in the NOI deal with “restoration.” Evidently restoration is a new mission for the Agency. Yet the USFS cannot define restoration, has not organized any symposia on the topic, has not consulted with recognized forest restoration experts, has not pursued research in restoration, cannot cite a single successful or exemplary restoration project, and is groping for direction on restoration.

Yet you ask, “How can we (the Agency) educate you (the public)?”

It is the Agency that needs the education.

The public is well-aware of the consequences of the USFS planning process. We have seen our forests incinerated, our watersheds destroyed, our wildlife populations decimated, our local economies ruined. We have seen a once capable institution shattered by conflict, litigation, loss of expertise, and tragically inept leadership. …

Since the USFS is incapable of learning from public input, the public has no recourse to poor decision-making but to resort to legal objections and appeals. Often our public forests, private lands, homes, livelihoods, and even our lives are a stake due to unreasonable, irrational, and illegal actions initiated by the USFS.

We presented earlier in these comments examples of “wildfire use” that resulted in enormous damages to public and private lands. Those actions were undertaken by the USFS in direct defiance of local public desires and without any appropriate NEPA processes. In after-action declarations, the Agency has admitted no mistakes and expressed no remorse.

The USFS is deaf and blind to the suffering they have inflicted on private citizens and communities. It is the Agency that has engendered a culture of conflict and adversarial relationships, not the public. …

It may come as some surprise to Washington D.C. officials of the Agency, but the public is tired of forced evacuations, backburns on private lands, summers filled with choking smoke, road closures, incinerated watersheds, ever-rising user fees, and other strong arm tactics promulgated by the USFS.

The public fears that Agency efforts to “recycle forests,” the common USFS euphemism for catastrophic forest incineration, will be imposed on private lands in the name of “open space.”

It is common knowledge in forest-adjacent communities that the USFS wishes to burn out the “Wildland-Urban Interface,” a euphemism for private property. The latest Quadrennial Fire Review calls for “Leave Early or Stay and Defend” fire response, the Let It Burn tactic that led to 200 deaths last year in Australia.

The Agency is viewed as an outside, occupying, and malevolent force. They have sullied their reputation and are distrusted and feared. The Agency would be well-advised to stay off and away from private property or they will engender a backlash that could be terminal for the Agency and hugely disruptive to society at large. …

The top-down bureaucratic planning model has failed miserably. Unless and until the USFS realizes that all decisions are local, that local citizens bear the brunt of decision outcomes, and that local citizens are the ONLY effective constituency available to the Agency, then the planning process will continue to be inefficient, opaque, and adversarial.

Abject repeat failure should be instructive to the Agency. It certainly is to the local public. …

The New Planning Rule should recognize and empower local choices and extensive local involvement in units of the NFS.

The Agency needs to guide local NFS units to communicate and learn from local constituencies. Centralized planning is a failure. The insular and exclusionary practices of the past must be discarded and replaced with a well-designed and implemented program of local empowerment.

17 Feb 2010, 9:30am
by Larry H.

Wonderful response! I wouldn’t change a thing. Chances are, this comments process will turn into a counting of “votes” instead of focusing on applicable scientific content. Let’s hope that these rule changes will reflect Vilsack’s speech last summer (which fell on deaf eco-ears).

It seems that “addressing climate change” is a very vague goal for this process and could allow for a “spin doctor” to come in and mutate the process into yet another way to promote “unstewardship”. This is consistent with the “smoke and mirrors” culture of forest management “deniers”.

29 Mar 2010, 10:27am
by Larry H.

I watched a few hours of the “Science Forum” this morning, with 4 scientists addressing the issues of a new Planning Rule. I missed almost all of the discussion about fire’s role in the forest. They still seem convinced that our forests need widespread fire. There was also a discussion about the “Precautionary Principle”, and I was VERY happy to see that a two of the panelists were very concerned about the misuse of that concept. They felt that doing nothing in the face of probable damage is the wrong thing to do. Clinging to the “PP” to stop necessary and beneficial management ignores science and experience.

They will be in session for the rest of today, as well as tomorrow. You can access the webcast from the website blog.

29 Mar 2010, 11:27am
by Mike

If it talks like a quack and ducks like a quack, then it probably is a quack.

29 Mar 2010, 1:36pm
by Larry H.

I watched part of the afternoon session and it mostly concerned “modeling and monitoring”. They all talked at length about needing vast amounts of data to implement “adaptive management” with a feedback loop of monitoring to keep refining the science and the models. Allowing that these guys make their bucks off “analysis paralysis”, I really wanted to ask them if 7 million acres of bug-killed dead forests is enough data to act upon. If 10 million acres of wildfire annually was enough “modeling” to act. They all wanted to radically-increase funding for monitoring and more analysis, in a financially-challenged government. The panel did seem to stay away from the ideological goals of the preservationist crowd, though. One question from the audience that no one wanted to answer was; What is “ecological forestry” and how can it help us deal with our forests? They didn’t recognize the term and didn’t seem equipped to handle the question.

While they didn’t field any questions from the blog, they did ask for some to be submitted. We’ll see if they will address my questions posted all over that blog.

30 Mar 2010, 2:26pm
by Larry H.

Well, I have 25 of the currently 82 comments on the blog. Of course, none of my comments were addressed, but it seems that a substantial amount of people are indeed looking at the blog. Some probably think I am a lunatic but no one has stood up to my comments yet.

The discussion today was pretty good, with lots of talk about “the process” and Forest Plans, and how they can be altered to expedite appropriate action without compromising scientific truth and integrity. Of particular interest to me is the mention of “Agency Capture”, and how that needs to be avoided with careful planning, guidelines and definitions. We’ve all seen how plans and studies can be abused by a lack of careful wording.

I am definitely thinking about going to the Regional discussion for Region 5, in Sacramento.

Reply: I noticed. Good for you. I missed the R6 meeting today. Too many conflicting time demands. I think I might send a few more comments into the planning blog, though. They set it up for a reason. What that is, I don’t know, but we might as well seize this opportunity to educate them. — Mike

4 Apr 2010, 10:37am
by Larry H.

A summary of the “Science Roundtable” discussions is downright depressing. Out of all of the comments I made on their blog, NOTHING got through their thick skulls and ignorance. Their acceptance of public input is just “going through the motions” and their minds were already made up before this process was started. More allowed wildfire, more “analysis paralysis” and more exclusion of science are the main issues they are pushing. Local issues will get more attention but will be easily trumped by the “right” of nationwide recreation and preservationism. I also predict that they will push for big subsidies for private landowners to do nothing with their timberlands. They glossed over litigation issues, only saying that they should “try” to minimize it.


What can we do when people refuse to accept science and inevitability of catastrophic wildfires??? What they HAVE decided to do is attempt to create brand new “ecosystems” that are untested (except in “models”) that exchange endangered species habitat for whatever arises in the aftermath. Local interests will ALWAYS take a backseat to nationwide issues supported by eco-groups, judges, desk-bound academics and activist lawyers. Someone will also surely take a straw poll and determine that Americans overwhelmingly support the elimination of timber harvesting. The carrot they will offer local interests will be management of the WUI, while sacrificing the “backcountry”.

4 Apr 2010, 11:02am
by Mike

The Roundtable was more of a Mobius Strip — one side, going around in circles. The only worthwhile bullet point was

* Recognize the cultural divide between scientists and the public

The “scientists” (specifically this select group of pseudoscientists) are isolated away from the public, in some bunker somewhere, and exhibit bunker mentality. They are irrelevant.

4 Apr 2010, 5:23pm
by Larry H.

The other thing in there I agreed with was the statement about “the Precautionary Principle cutting both ways”. Doing nothing in the face of unprecedented insect and fire mortality is the epitome of ignorant destruction, hypocritically bypassing the Precautionary Principle to support their flawed views. The Forest Service desperately needs to “manage its ignorance”, a subject of a 10 year old paper dealing with “Institutional Ignorance”.



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