This
is a long and convoluted topic which is explored in a number of articles on this
web site. For the purposes of
brevity, we will break this issue down to just a few of its very hotly contested
issues.
The
extent to which excessive analyses and procedures impede the Forest Service from
doing its job is intolerable, and the result has been an unprecedented wasting
of taxpayer money and a forest resource decimated by neglect.
Therefore, BHFRA believes any legislative or rulemaking effort designed
to enable the Forest Service to complete more fuels reduction and forest health
projects must contain some meaningful updates to the current NEPA analysis
requirements.
2.
Appeals and litigation: much
conflicting information has been set forth pertaining to whether or not the
administrative appeals and legal suits filed by environmental interest groups
against the Forest Service really prevent the agency from getting fuels
reduction and forest health projects completed.
One thing is incontrovertible, however: since 1997, every single forest
management project proposed on the Black Hills National Forest has been appealed
by at least one such interest group. Every
single one. The effect, on the Black Hills and on other national forests,
is that the Forest Service spends significant time and resources attempting to
“bullet-proof” their projects from appeals and lawsuits.
Much like the way case law works in our Court system, each time an appeal
is successful the Forest Service must add another layer to their analysis,
further extending the time and resources needed to successfully complete a
project.
It
is important to remember, contrary to the arm-waving of some interest groups,
that no piece of ‘healthy forests’ legislation that put forth to date has
proposed the removal of interest group’s right to appeal or litigate projects.
Instead, the issue afoot is fairness.
Under
the current appeal regulations, groups can appeal on issues that were never
raised at any other time during the development of a project.
This means that the Forest Service did not have a fair chance to address
the issues through its analysis, and can be easily blind-sided in the 11th hour
of a project’s development. Similar
inequities exist in the way lawsuits against forest projects are considered.
Judges can only take into account the immediate environmental impacts a
project could potentially have. They
are not permitted to consider what the long-term effects of not completing the
project might be, such as the environmental damage a wildfire or insect outbreak
can cause. Another important issue
is time: many forest projects are time-sensitive, and the legal process is not.
Lawsuits can drag on for years upon years – management in the Norbeck
Wildlife Preserve on the Black Hills, for example, was mired by legal
proceedings for almost thirty years.
The
healthy forest legislation that has been offered in Congress addresses the
issues of appeals and lawsuits by establishing some fairness in the appeal
regulations, by leveling the playing field of issues that can be considered in
legal proceedings, and by placing reasonable time lines on the completion of
such proceedings. BHFRA supports
bringing some measure of reason to bear on the appeals and litigation processes
facing the Forest Service.
3.
Wildland-Urban Interface:
one particularly volatile part of the debate on healthy forests
legislation has been whether or not hazardous fuels and forest health projects
should be confined to the Wildland-Urban Interface (WUI) area around forest
homes and communities. Proponents
of restriction to this area propose drawing an arbitrary half-mile line around
at-risk human settlements and confining the Forest Service’s activities to
this area. The alternative is a
more broad approach that places a priority on the WUI, but also recognizes the
inherent variability in resource concerns and land ownership patterns that
forest managers will be confronted with as they attempt to implement these
projects.
BHFRA
believes the position advocating WUI-only treatments ignores several important
facts, and any healthy forests legislation that seeks to have a meaningful
impact should include a more adaptable approach. The first fact ignored is that the WUI-only approach does
nothing to protect wildlife habitat, watersheds, or air quality.
The issue in play is ‘forest’ health, and simply thinning around
trophy homes will not accomplish this objective.
Second, much of the WUI is privately owned, and the Forest Service
can’t do anything about the fire risk conditions on those lands.
The third issue is that much of the WUI does not exist in what could be
categorized as tangible towns or communities.
Instead, homes are scattered throughout the WUI in subdivisions and
unincorporated areas that would not fall into the category of “worthy of
protecting” under most definitions of WUI.
Lastly, when we talk about “catastrophic fire”, we are talking about
fires that can consume tens of thousands of acres each day, moving at speeds up
to 60 miles per hour, fires that can generate sufficient radiant heat to make
glass windows explode and melt aluminum siding from 200 feet away, fires so
large that they create their own wind and weather, spitting hot embers as far as
two miles out in front of the main fire line, and fires whose progression can
only really be halted by an act of God. Simply
put, these fires, catastrophic fires, will laugh in the face of a small
thinned-out buffer strip around mountain towns.
To limit fuels reduction to a small area in the WUI is to create a
completely false sense of security for those in harm’s way, and to ignore the
larger problem of why these fires happen to begin with.
BHFRA
agrees that a large proportion of Forest Service resources and emphasis for
fuels reduction work should be allocated to the WUI, but not to point of
excluding all other areas. Forest
managers must have the flexibility to decide the ‘what, where, and how’ for
projects that best protect our communities and resources.
4.
Big trees don’t burn:
some have argued throughout the forest health debate that fire protection
and forest health objectives should be accomplished by the sole means of
cleaning up forest debris and clearing brush and small trees.
Proponents of this viewpoint contend that large trees are
“fire-resistant”, and if harvesting these trees is part of fuels reduction
projects, then the real motive behind all this could only be to allow
‘unfettered logging in the backcountry’.
This
line of posturing is a convenient attempt to drag the debate about healthy
forests legislation into the political gutter, and doesn’t have anything to do
with protecting communities or forest resources. The root of the forest health debate is simply this: how do
we enable the Forest Service to restore healthy, fire-resistant conditions on a
greater proportion of our forest lands? This
objective has nothing to do with “increasing logging” or “cutting down all
the big trees”.
That
said; there will almost certainly be a few “big” trees harvested during the
course of any truly meaningful hazardous fuels reduction project.
This is because there are a number of different components to fire risk.
Among them, are the amount of on-the-ground dead fuels and small trees,
the structure in which those fuels are arranged (i.e., in “ladder” fashion
that facilitates the movement of fire from the ground-level up into the tree
canopy), the distance between the crowns of large trees on-site, and overall
forest density. A good fuels
reduction project addresses all these issues, whereas a project that addresses
only one component of the fire risk situation is doomed to impotence.
In the end, vast, contiguous tracts of dense, unhealthy forest – big
trees or not – are what breed catastrophic wildfires.
Because
each forest situation varies in the specific nature of its fuels reduction
needs, limiting Forest Service managers to addressing only one component of
those needs is another recipe for disaster.
Therefore, BHFRA does not support such limitations as part of any forest
health legislation.
There
are some interest groups who believe the practice of forestry ought to be banned
from national forests. They allege
the timber sale programs on these lands amount to a subsidy of the forest
products industry, and that they create an incentive for the Forest Service to
make decisions on the basis of generating revenue rather than on the basis of
sustainable management principles and environmental stewardship.
Typically, rhetoric such as ‘logging-on-demand’ or ‘cutting our
last remaining ancient trees’ are bandied about in an attempt to paint the
Forest Service as nothing more than servants of the forest products industry, to
the detriment of all other forest resources.
BHFRA
strongly supports forestry and timber sales programs on the Black Hills and all
other national forests, and we rebuke the above contentions as spurious and
intentionally misleading:
First,
every Forest Service timber sale is bid upon at competitive auction among any
number of different prospective buyers on the basis of its honest fair market
value; we fail to see how this could be construed as a subsidy.
Third,
in addition to generating revenue for the National Treasury, national forest
timber sales accomplish all manner of other resource management objectives that
the Forest Service might have in mind. Everything
from maintaining roads for public access, to improving wildlife habitat and
watershed health, to providing recreational opportunities, to removing hazardous
fuels that stoke catastrophic wildfire can be accomplished using timber sales as
the tool. The point is that there
is much more associated with forest management on national forests than
“feeding a greedy, timber-thirsty industry”, as some would suggest.
Above
all the preceding arguments, there is a still-greater reason to manage public
forests that is often omitted from discussions like these:
we owe it to the rest of the world.
We in the United States have the largest economy on the planet and we
consume great quantities of natural resources to support our society.
We ought to set an example for other nations on how sustainable natural
resource management is done, and no better showcase exists for such an
opportunity than on our national forests.
BHFRA
opposes the Roadless Rule as an illegal end-around maneuver by the Clinton
Administration to satiate its environmental special interest campaign
contributors.
The
issue of roadless area protection is not a new one. The Forest Service and local stakeholders (the enviros and
the industry included) across the nation worked for nearly thirty years to
identify, agree-upon, and protect roadless areas on national forests - these
were what’s referred to as the RARE I and RARE II analyses.
The product of the RARE I/RARE II analyses was supposed to be that the
Forest Service would make recommendations in their individual forest planning
documents based upon the consensus of the local participants.
The Roadless Rule was an act of underhanded treachery wrought upon those
who participated in good faith with the earlier analyses.
The
Rule itself is replete with problems and inadequacies.
For all intents and purposes, the Roadless Rule precludes any sort of
forest management from occurring in inventoried roadless areas whatsoever.
Without some roads, the Forest Service cannot fight fire, treat fuels
before a fire can occur, or quell the damage of insect epidemics, such as the
one in the Beaver Park roadless area on the Black Hills.
Recreational opportunities are greatly diminished, since all access other
than foot travel is essentially removed. Furthermore,
the boundaries of the roadless areas themselves were finalized in a Washington,
DC office building - not on-the-ground, where they should have been - and the
result is that many ‘roadless’ areas aren’t roadless at all.
Mapping errors resulted in cutting off access for private landowners
dependent upon roads that crossed Forest Service land.
On the whole, the Roadless Rule amounts to a lock-up of one-third (over
60 million acres) of the National Forest System lands in the United States.
Recently,
the Bush Administration proposed some changes to the Roadless Rule.
They would allow the Governors of each state to seek exceptions to the
restrictions on road building and forest management under circumstances that
threaten human health, extreme fire risk conditions, and to correct mapping
errors. However, the BHFRA feels
this is a ‘Band-Aid approach’. Ham-handed
proclamations at the Washington DC-level like the Roadless Rule need to end, and
the ability to designate roadless areas should return where it belongs: at the
level of Land and Resource Management Plans on individual national forests.
Since
2000, mountain pine beetles have killed approximately 2,000,000 trees, impacting
tens of thousands of acres on the Black Hills National Forest.
Many years of dedicated scientific research established a clear cut-off
point for susceptibility to mountain pine beetle attack based on the density of
trees in a given area; above this point you get beetles, and below it you do
not. The reasons mountain pine
beetles have taken off in the Black Hills of late is two-fold.
First, we’ve had a prolonged drought, which weakens trees to the point
that their ability to fight off beetle attacks is diminished.
Second and more importantly, too much of our forest exists in tightly
packed, bug-susceptible conditions. The
beetles have a big green buffet in front of them, and they show no sign of
slowing down.
The
most effective method of stemming the beetle tide is thinning the forest - plain
and simple. Insecticides don’t
work for a variety of reasons, are expensive, and have negative environmental
consequences. Cold weather will not
kill the beetles, nor can their natural predators, such as woodpeckers, work
fast enough to catch-up with the exploding beetle population to bring it under
control. The best defense against
bug outbreaks in the Black Hills is a diverse, vigorous forest condition - BHFRA
supports achieving such a condition, using timber sales as the vehicle.
Please see our 2006 Photos and article on Mountain Pine
Beetles for more information.
Much
has been made of the practice of clear-cut forestry. No significant clear-cutting occurs or has ever occurred in
the Black Hills National Forest. Occasionally,
the Forest Service desires to make openings in the forest canopy in order to
generate forage (grass) growth for wildlife species, but these do not exceed an
acre or two in size.
There
is a reason we don’t clear-cut here, and it’s probably not the one you
think. Clear-cutting is a
management practice that is usually prescribed within the context of a few
specific forest types. These forest
types (aspen and lodgepole pine, for example) require full sunlight in order to
grow, and therefore evolved with a system of forest disturbance that causes
large clearings. In the instance of
lodgepole, this system involves large fires that completely wipe out a forest
stand. Only then, when all
competition for sunlight is removed, can lodgepole pine seedlings successfully
grow. Clear-cuts are designed to
mimic this system, because removing all shade is the only way to get the forest
to grow back. This system of
management, properly applied within an appropriate forest type, is a perfectly
valid management tool. Much of the
uproar about clear-cutting as a forestry practice has everything to do with how
it looks, and nothing to do with environmental damage.
As
to the reason we do not clear-cut in the Black Hills, it’s about biology.
Ponderosa pine, the tree species that dominates our area, does not
require complete sunlight for its seedlings to grow and generally did not evolve
with a system of disturbance (fire) that created large openings.
Therefore, we conduct our forest management through a series of
progressive thinning treatments, always keeping trees on the site.
Bottom
line: forestry, in all its forms,
is designed to fit within the context of a specific forest ecosystem.
Clear-cutting, though it can be an ugly sight for the first few years
after it’s performed, it is the only way to accomplish management objectives
for certain forest types.
The
Forest Service has a problem with their ‘process’ - they can’t perform
their intended role as public lands stewards and professional resource managers
while they’re straight-jacketed in red tape.
The BHFRA believes that any progress toward reducing redundant,
unnecessary, or unreasonable analysis requirements for certain types of Forest
Service projects is a step in the right direction. However, we also believe that in order to form a long-term
solution to public forest management issues, a complete overhaul of the way the
Forest Service administers the National Environmental Policy Act is necessary.
We believe that the fundamental tenets and intent of NEPA were honorable,
necessary, and laudable. However,
the maze of precedent, administrative procedure, and rulemakings the Forest
Service has either created for itself, or been forced into instituting as a
result of appeals and litigation, must be thrown out the window in favor of a
clean sheet.