BLM intends to take shortcuts to begin cutting timber after a fire

salvage logging
Skidder and delimber operating on a fuel management research project in the Priest River Experimental Forest in Idaho. Forest Service photo.

The Bureau of Land Management will open a 30-day period during which it will accept public comments on their plans to remove some steps that are required before cutting timber following a fire.

The agency intends to no longer require Environmental Impact Statements or Environmental Assessments on what they call “salvage” operations of less than 5,000 acres — cutting dead or dying trees which can result from insects or wildfires. They would use a Categorial Exemption (CX) to skip some environmental review steps that are usually required.

The BLM’s press release about their plans did not include information about how the public could comment, just that, “[A] a public comment period on the proposed CX closes 30 days after the proposal publishes in the Federal Register. The BLM will provide additional information about when and how to comment when the proposed rule is published. ”

Their press release saw no issues with their planned accelerated timber cutting operations:

The BLM has completed a review of scientific literature and previously analyzed and implemented actions and found no evidence that salvage harvest at the levels proposed would have a negative effect on forest health. To the contrary, removing dead and dying trees can accelerate forest succession and benefit native wildlife species that rely on successional habitat, while reducing the potential for catastrophic wildfires.

An opposing point of view is in a paper written by D.B. Lindenmayer and R.F. Noss, titled “Salvage Logging, Ecosystem Processes, and Biodiversity Conservation.” It was in Conservation Biology, Volume 20, No. 4, August, 2006.

Here is an excerpt:


“Discussion

“Some of the impacts we have outlined may be different from or additional to the effects of traditional forms of logging that are not preceded by large, natural disturbance events. This is because the conditions preceding, during, and after salvage logging may differ from those in areas subject to traditional logging. Moreover, the ecological benefits derived from large-scale disturbances (such as the creation of charred trees and coarse woody debris) can be lost or severely diminished by salvage operations for decades and even centuries (Lindenmayer & Ough 2006). These problems have often been overlooked or poorly understood by conservation biologists, foresters, and other natural resource managers. In some cases salvage impacts may have been so substantial that past interpretations of ecosystem responses to natural disturbance may need to be reexamined. That is, ecosystem processes and biotic responses may have been more influenced by salvage logging than by the initial natural disturbance event. This may be true for hydrological regimes in the northeastern United States following the 1938 hurricane (Foster et al. 1997), aquatic macroinvertebrates in the western United States (Minshall 2003), and arboreal marsupials in the forests of Victoria, Australia, after the 1939 and 1983 wildfires (Lindenmayer et al. 1997).

“Whereas most documented effects of salvage logging are negative from an ecological standpoint, others can be neutral or positive, depending on the response variables measured. Effects are likely to vary over time and among and within vegetation types in response to the type, intensity, and periodicity of natural disturbance and disturbance by salvage logging. Therefore, there can be no generic recipes for salvage logging that can be uncritically applied in all landscapes.

“Perhaps one of the problems associated with the lack of appreciation of the impacts of salvage logging lies in the terminology itself. Dictionary definitions of the term salvage associate it with “recover or save” or “saving of anything from loss or danger” (e.g., Delbridge & Bernard 1989). Although salvage logging removes wood from burned areas, such practices generally do not help regenerate or save ecosystems, communities, or species (but see Radeloff et al. 2000) and often have the opposite effect. Hence, in many respects, the term salvage is inappropriate and misleading from ecological and conservation perspectives. An alternative term might be postdisturbance logging.”

Presidential order sets goals for fuel reduction

The Executive Order also addresses the use of drones and increases timber harvesting by 37 percent.

prescribed fire Custer State Park
Firefighters ignite the Norbeck prescribed fire in Custer State Park. Photo by Bill Gabbert.

With the devastating wildfires in California this summer and the visits by President Trump to the Camp and Woolsey Fires, firefighting and forest management were brought into the national conversation. Mr. Trump showed an interest in the fire siege, criticizing forest management, suggesting rakes as one of the solutions, and threatening on multiple occasions to cut unspecified funding allocated to California.

The magnified interest seen in Washington may have been the impetus for the *Executive Order (EO) signed by Mr. Trump on December 21. The document requires emphasis in a number of areas related to wildland fire, some of which have specific goals. The stated rationale for the EO is identified:

For decades, dense trees and undergrowth have amassed in these lands, fueling catastrophic wildfires. These conditions, along with insect infestation, invasive species, disease, and drought, have weakened our forests, rangelands, and other Federal lands, and have placed communities and homes at risk of damage from catastrophic wildfires.

With the same vigor and commitment that characterizes our efforts to fight wildfires, we must actively manage our forests, rangelands, and other Federal lands to improve conditions and reduce wildfire risk.

Both Mr. Trump and his Secretary of the Interior, Ryan Zinke, who also showed up before cameras at fire scenes this summer, denied that climate change is one of the factors affecting the increase in wildfire activity in recent decades.

“I’ve heard the climate change argument back and forth. This has nothing to do with climate change.”

Interior Secretary Ryan Zinke, in an interview after visiting the Carr Fire at Redding, California.
climate assessment wildfires increase
The cumulative forest area burned by wildfires has greatly increased between 1984 and 2015, with analyses estimating that the area burned by wildfire across the western United States over that period was twice what would have burned had climate change not occurred. Source: adapted from Abatzoglou and Williams 2016.

The EO lists a number of areas with specific goals or directives.

FUEL REDUCTION. The four Department of the Interior land management agencies now have an objective in 2019 of treating a total of 750,000 acres to reduce fuel loads. The objective for the Forest Service is 3,500,000 acres. As of December 8, 2018, according to the National Situation Report, the year-to-date accomplishments for acres treated with prescribed fire were 525,659 and 1,307,389, respectively. Presumably, mechanically or herbicide-treated acres were not included in those 2018 figures. The goals appear to be substantially higher than what has been done this year. However, as direction from on high moves the goal posts, federal agencies can sometimes initiate creative methods to keep everyone happy. For example, recently the Forest Service has started “counting” wildland fire acres where light to moderate wildfires have caused vegetation to improve what used to be called “fire condition class”. These then become “treated acres”. In addition, some timber sales are now being counted. So, magic, presto, poof! The number of acres “treated” adds up more quickly than they used to. A person with extensive D.C. experience told us that they expect the land management agencies are not worried about meeting the fuel treatment goals laid out in the EO.

prescribed fire acres accomplished 2018
Prescribed fire data from the December 8, 2018 National Situation Report.

LOGGING. Calling it “health treatments”, the FS has a goal of selling 3.8 billion board feet of timber in 2019, while the DOI’s goal is 600 million. This total of 4.4 billion board feet is a significant 37 percent increase over the 3.2 billion board feet removed from those agencies’ lands in 2017, according to the Sacramento Bee. The EO also requires the Secretaries of Agriculture and Interior to identify salvage and log recovery options from lands “damaged” by fire, insects, and disease in 2017 and 2018. Many people say that logging is not the answer to the wildfire problem, and that areas visited by fire are not necessarily “damaged”. While some rehabilitation is often required, burned areas don’t always have to be fixed or logged.

NATIVE AND INVASIVE SPECIES. Both the FS and the DOI have goals of treating 750,000 acres.

UNMANNED AERIAL SYSTEMS. The Secretaries are ordered to maximize the use of unmanned aerial systems (UAS), or drones, in forest management and in support of firefighting. The DOI has been extremely aggressive in the last two years in establishing a surprisingly robust UAS program. There is a report that a person formerly with the DOI’s Alaska Fire Service is now heading the Forest Service UAS program.

The goals in the EO are an unfunded mandate. It says, “[The agencies] shall review the Secretary’s 2019 budget justifications and give all due consideration to establishing the following objectives for 2019, as feasible and appropriate in light of those budget justifications, and consistent with applicable law and available appropriations.”


*Here is a backup copy of the Executive Order in case the one at WhiteHouse.gov disappears.

Thanks and a tip of the hat go out to Eric. Typos or errors, report them HERE.

A correction was made December 26 about the new leadership of the Forest Service UAS program.

217 scientists sign letter opposing logging as a response to wildfires

The House version of the 2018 Farm Bill would expand logging on public lands

One of the favorite responses of some politicians to devastating wildfires is to call for increased logging on public lands. Their reasoning is that having fewer trees will prevent large fires. The fact is that logging does not eliminate forest fires. For example, in a clear cut there is still fuel remaining, especially if the slash is left untreated, which can spread a fire faster than a forested area and can act as spot fire traps with dry, easily ignitable vegetation that is even more susceptible to propagating a fire from airborne burning embers up to a mile away from the main fire.

The House version of the 2018 Farm Bill being considered now would expand logging on public lands in response to recent increases in wildfires. A group of 217 scientists, educators, and land managers have signed an open letter calling on decision makers to facilitate a civil dialogue and careful consideration of the science to ensure that any policy changes will result in communities being protected while safeguarding essential ecosystem processes.

Below is an excerpt from the scientists’ letter:


What Is Active Management and Does It Work to Reduce Fire Activity?

Active management has many forms and needs to be clearly defined in order to understand whether it is effective at influencing fire behavior. Management can either increase or decrease flammable vegetation, is effective or ineffective in dampening fire effects depending on many factors, especially fire weather, and has significant limitations and substantial ecological tradeoffs.

Thinning Is Ineffective in Extreme Fire Weather – Thinning is most often proposed to reduce fire risk and lower fire intensity. When fire weather is not extreme, thinning-from-below of small diameter trees followed by prescribed fire, and in some cases prescribed fire alone, can reduce fire severity in certain forest types for a limited period of time. However, as the climate changes, most of our fires will occur during extreme fire-weather (high winds and temperatures, low humidity, low vegetation moisture). These fires, like the ones burning in the West this summer, will affect large landscapes, regardless of thinning, and, in some cases, burn hundreds or thousands of acres in just a few days. Thinning large trees, including overstory trees in a stand, can increase the rate of fire spread by opening up the forest to increased wind velocity, damage soils, introduce invasive species that increase flammable understory vegetation, and impact wildlife habitat.  Thinning also requires an extensive and expensive roads network that degrades water quality by altering hydrological functions, including chronic sediment loads.

Post-disturbance Salvage Logging Reduces Forest Resilience and Can Raise Fire Hazards – Commonly practiced after natural disturbances (such as fire or beetle activity), post-disturbance clearcut logging hinders forest resilience by compacting soils, killing natural regeneration of conifer seedlings and shrubs associated with forest renewal, increases fine fuels from slash left on the ground that aids the spread of fire, removes the most fire-resistant large live and dead trees, and degrades fish and wildlife habitat. Roads, even “temporary ones,” trigger widespread water quality problems from sediment loading. Forests that have received this type of active management typically burn more severely in forest fires.

Wilderness and Other Protected Areas Are Not Especially Fire Prone – Proposals to remove environmental protections to increase logging for wildfire concerns are misinformed. For instance, scientists recently examined the severity of 1,500 forest fires affecting over 23 million acres during the past four decades in 11 western states. They found fires burned more severely in previously logged areas, while fires burned in natural fire mosaic patterns of low, moderate and high severity, in wilderness, parks, and roadless areas, thereby, maintaining resilient forests.

Consequently, there is no legitimate reason for weakening environmental safeguards to curtail fires nor will such measures protect communities.

Closing Remarks and Need for Science-based Solutions

The recent increase in wildfire acres burning is due to a complex interplay involving human-caused climate change coupled with expansion of homes and roads into fire-adapted ecosystems and decades of industrial-scale logging practices. Policies should be examined that discourage continued residential growth in ecosystems that evolved with fire. The most effective way to protect existing homes is to ensure that they are as insusceptible to burning as possible (e.g., fire resistant building materials, spark arresting vents and rain-gutter guards) and to create defensible space within a 100-foot radius of a structure. Wildland fire policy should fund defensible space, home retrofitting measures and ensure ample personnel are available to discourage and prevent human-caused wildfire ignitions. Ultimately, in order to stabilize and ideally slow global temperature rise, which will increasingly affect how wildfires burn in the future, we also need a comprehensive response to climate change that is based on clean renewable energy and storing more carbon in ecosystems.

Public lands were established for the public good and include most of the nation’s remaining examples of intact ecosystems that provide clean water for millions of Americans, essential wildlife habitat, recreation and economic benefits to rural communities, as well as sequestering vast quantities of carbon. When a fire burns down a home it is tragic; when fire burns in a forest it is natural and essential to the integrity of the ecosystem, while also providing the most cost effective means of reducing fuels over large areas. Though it may seem to laypersons that a post-fire landscape is a catastrophe, numerous studies tell us that even in the patches where fires burn most intensely, the resulting wildlife habitats are among the most biologically diverse in the West.

For these reasons, we urge you to reject misplaced logging proposals that will damage our environment, hinder climate mitigation goals, and will fail to protect communities from wildfire.

How will the Forest Service change to deal with the “fire year”?

The USFS says we no longer have “fire seasons”. They are now “fire years”.

Victoria Christiansen forest service
Victoria Christiansen

In addition to asking the interim Chief of the Forest Service, Vicki Christiansen, why the agency cut the number of large air tankers on exclusive use contracts by 35 percent, we also asked her what changes the agency is making now that they say longer “fire seasons” have become “fire years” due to climate change.

Question: Since the Forest Service is now using the term “Fire Year” rather than “Fire Season”, will a large number of seasonal firefighters be converted to work year round?

“An effective response to the more severe fire seasons we have experienced for the past few years requires strong cooperation between federal agencies, states and tribal organizations. No one organization can do it alone. With these strong partnerships, we are prepared for what we expect to be another active fire season.  The Forest Service, along with assistance and cooperation with our federal, tribal, state, and local partners and volunteers, is well prepared to respond to wildfires in 2018. This year, the agency has more than 10,000 firefighters, 900 engines, and hundreds of aircraft available to manage wildfires in cooperation with federal, tribal, state, local, and volunteer partners. At this time, there is no national direction to change seasonal tours.”

Question: How will the Forest Service change to deal with the “Fire Year” — the longer fire season?

“Early indicators are predicting that 2018 will be another active fire year. The USDA Forest Service is committed to ensuring adequate assets are available for a safe and effective wildfire response. In preparation for the existing and potential wildfire activity, preparations continue to ensure a robust workforce of firefighters, engines and aviators will be available for nationwide wildfire response throughout the fire year. Assets will continue to be moved around the nation as activity shifts from one geographical area to another throughout the fire year. We continue to do what we have for each and every season, and that is to prepare, plan for, and respond to wildfires throughout the fire year, while supporting our federal, state, local and tribal partners and cooperators.”

Question: On another topic, what are your thoughts about salvage logging after a fire vs. allowing nature to take its course in a burned area? Will we be seeing more salvage logging?

“Salvage logging of dead and dying timber after a fire or other disaster is one way to capture the value of the damaged timber. This timber provides much needed products to the American public. Salvaging the timber can also reduce the fuel loading after harvest creates “slash.”  Otherwise, over time, these trees could potentially fuel future fires.  The value of the trees harvested can be used to treat the burned area. This treatment may include various restoration projects, including planting trees, shrubs and grasses for wildlife and domestic grazing, and watershed restoration projects such as brush dams to reduce sediment flow.  In many instances, there is not a seed source left after an intensive burn to allow an area to return to desired vegetation state naturally. Planting allows an area to return to this desired vegetation state in a much shorter time.  Typically only about 20-30 % of the burned area is salvage logged, depending on the intensity of the burn.  The rest of the area may not be logged because of nearness to perennial streams, soil stability concerns, or that very few of the trees were damaged in the fire.  When evaluating the total burn area, the concern over a lack of snags becomes less problematic.  Unless forests are treated to reduce the number of stems and the resultant fuels, future fires will continue to create problems.

“In many of our market areas there is a need to maintain at least a portion of the green timber sale program as the mills are designed for certain tree species or certain products.  These mills cannot afford to reconfigure the mill for some of the products that come from salvage material. In addition some defects like blue stain in pines does effect the structural integrity of the product. However, many Americans do not like the looks of this defect. Fortunately, some of this lumber can be used in Cross Laminated Timber (CLT) where this feature is covered up.”

Forest Service intends to salvage log over 30,000 acres in their Northern Region

The U.S. Forest Service has plans to conduct salvage logging operations in areas in their Northern Region that experienced wildfires this year.

salvage logging
File photo of a log deck on a salvage logging operation on a national Forest. Photo by Dave Powell, USFS retired.

The U.S. Forest Service expects to award salvage logging contracts totaling 30,254 acres in 11 locations scattered over three National Forests in Western Montana. The burned areas affected are on the Kootenai, Lolo, and Beaverhead-Deerlodge National Forests. The Northern Region will be requesting approval for Emergency Situation Determinations for some of the areas which would streamline the environmental analysis process.

Below is information from the USFS Northern Region:


This past summer, the U.S. Forest Service’s Northern Region experienced one of the hottest and driest fire seasons on record, with 36 fires that burned ~710,000 acres on National Forests in Montana and Northern Idaho, heavily impacting local communities and landscapes.    As a result, recognizing the scope of the fires this year, Regional Forester Leanne Marten saw the need for an expedited approach focused on safety and formed a Regional Post-Fire Response Incident Management Team (IMT).  This team oversees Burned Area Emergency Response (BAER) assessments and implementation, planning for post-fire salvage, and reforestation assessments.

“We’ve had many years where we’ve had fire on the landscape and we’ve learned there is a lot of work left to do on the ground for the resources and for the communities when the flames go out and the smoke clears”, said Marten. “How we do that and work together across landscapes is imperative to our success, and based on feedback we’ve had from our employees and community’s from previous fires… we’ve learned a Regional approach is the most effective.”

Emergency response actions began on those areas posing the greatest risks to human life and property immediately; over 505,320 acres have been assessed.  Specialists came from across the country to expedite this work, and the Forest Service has contracted with local businesses extensively to implement work on the ground.  The work focuses on replacing safety related structures, removing safety hazards and installing hazard warning signs and temporary barriers as needed.  Other work includes erosion and water run-off control structures on roads and trails, mitigating the loss of habitat for threatened and endangered species, helping to prevent the spread of noxious weeds and protection of sensitive cultural resources.

On NFS lands burned this year in Montana, salvage locations are proposed based upon physical conditions on the ground and existing management direction.  Computerized evaluations are being used to rapidly zero in on the areas with suitable timber volume and road access.  Regional guidance is being developed to minimize potential environmental impacts and fulfill Endangered Species Act requirements.

The Region has been talking with members of various conservation organizations, cooperators, stakeholders and volunteer groups about efforts to salvage timber value in burned areas. There have also been numerous conversations with representatives from the timber industry. We are highly committed to engaging the public throughout the process.salvage logging montana list

Eleven fires (see table) are slated for salvage projects and of those, three are proposing to salvage 250 acres or less.  Environmental analysis will determine the final acreage available for salvage for the remaining eight fires.

Additionally, the Region will be requesting approval for Emergency Situation Determinations (ESD) for some of the areas which would shorten the environmental analysis timeline and allow work on the ground to begin sooner.

The Northern Region is strategically focusing its efforts to maximize safety, minimize environmental impacts, and use the available industry capacity to accomplish this work to benefit our communities and resources. Assessments are being conducted for reforestation needs at the same time for the health and productivity of these areas.  As exclaimed by Regional Forester Marten, “We are excited to have our local decision-makers on the Lolo, Kootenai, Helena-Lewis and Clark, and the Beaverhead National Forests working with the Post Fire Response IMT to get this work done safely and quickly”.

Detailed information about the Forest Service post-fire work can be found online.

Disagreements over salvage logging versus natural recovery after fires

black forest fire faller tree
Black Forest Fire near Colorado Springs, Colorado. June 15, 2013. Photo by Bill Gabbert.
The debate has been going on for decades — should loggers rush in after a wildfire and cut down the recently killed trees while they are still merchantable, or could natural processes be allowed to run their course? Timber companies, some politicians, and the U.S. Forest Service often argue for the first option, while some scientists and environmental groups advocate for the natural alternative.

Below is an excerpt from an article in the Los Angeles Times:

…The Forest Service and timber companies say that the dead wood must be removed before the forest can grow and that shrubs have to be killed off with herbicides so the conifers have sun to grow again.

Though part of the Las Conchas fire site was salvage-logged, another section outside New Mexico’s remote Jemez Springs was not.

Four years after the blaze, the Jemez Springs area today is alive with Gambel oak and three-toed woodpeckers, along with occasional conifer saplings growing amid the brush.

“See this?” Hanson said, pulling back a strand of oak to reveal a rubbery green pine sapling just an inch tall. “They said this wouldn’t be here, but we found it. And there’s more.”

By contrast, in places like California’s Rim fire site, salvage crews immediately began felling burned pines and dying trees, spraying the area with herbicide and planting conifer saplings. The result is little ground vegetation but stands of artificially planted conifers returning apace…