Friday, January 21, 2011

Former Krassel District Ranger Speaks Out

Ned Pence, former USFS employee and district ranger on multiple forests, speaks out regarding how the USFS is mismanaging the forests and destroying jobs at the same time.

Ned has more than 40 years experience working for the USFS and more than 50 years experience in forestry. He and his brother Carl (another former USFS official) have written a book called "Lost in the Forest" which they publish and print. To order copies, email Ned Pence.

Join the cause on Facebook to stop illegal USFS practices



The Boise National Forest comprises nearly 1.68 million forested acres. A current Forest Plan was completed in 2003; however since 2000 the forest has experienced extensive wildfire, affecting about 380,000 acres (17% of the forest). The purpose of the project is to complete a comprehensive Wildlife Conservation Strategy (WCS) for the forest and amend the 2003 Forest Plan (Summary, page 6). The Wildlife Conservation Strategy is being completed in conjunction with the Sawtooth National Forest and the Payette National Forest that have also experienced similar extensive wildfires.
The DEIS explains that Forest Plan amendments are necessary for eight reasons (Summary, page 8):

1. Add to or modify existing management direction to emphasize retention
of most forest stands that meet the definitions of old-forest habitat or large tree size class.
2. Add to or modify existing management direction to focus restoration in forest stands classified as large tree size class and medium tree size class to promote desired old-forest habitat or large tree stand conditions and reduce hazards and risks to these habitats.
3. Delete wildlife standard WIST01 and replace it with a more comprehensive and diverse strategy for wildlife conservation that relies on scientifically accepted conservation concepts and associated principles.
4. Move the 400,000 acres in the planning unit that fall within Management Prescription Category (MPC) 5.2 (Commodity Production Emphasis) to a restoration emphasis.
5. Add or modify existing management direction to emphasize retention of large snags while balancing other objectives associated with a given MPC (e.g., the desire to provide for economically viable timber harvest on lands suitable for timber production).
6. Prioritize vegetative and associated wildlife habitat restoration treatments to increase the overall probability of restoration success.
7. Identify the location of priority or key habitat areas for wide-ranging carnivore species, such as wolverine, and retain linkages between these habitats. Based on the best information available, identify where potential conflicts between this species and human use may exist and whether further review is warranted.
8. Balance wildlife habitat restoration needs with multiple-use objectives, and allow treatment exemptions for treatments that respond to emergencies, provide for public health and safety, and allow for the exercise of existing rights and other statutory requirements.
The Boise National Forest desires to return the vegetation to "historical conditions" believing that past forest management – wildfire suppression, and timber harvest have "directly and indirectly affected habitat quality, quantity, and distribution" (Summary,
page 7). It is not possible to know what "historic conditions" (prior to human settlement) were; however, the Forest Service believes past management practices have resulted in:

1. Substantial reduction in the abundance and extent of large trees size class and old forest habitat.
2. Substantial reduction in the abundance of legacy ponderosa pine and western larch, and large snags.
3. Substantial increases in tree densities and ladder fuels resulting in reduced habitat quality.
4. Reductions in habitat quality due to an increase in climax tree species.
5. Reductions in forest cover from uncharacteristic wildfire, insects and disease.
6. Reductions in habitat quantity and quality due to historic and/or continued human use.
The above concerns prompt me to ask, which is more important, habitat or human use to satisfy current and future needs? The Forest Service must recognize that it is not possible to change current human needs and the impossibility of returning the historic conditions that existed prior to European settlement. However, the desire to return the historic role of fire has to make one wonder.
There is considerable evidence that Native Americans regularly burned the forest to satisfy their needs prior to European settlement. The "mosaic" that the Boise National Forest seems to desire was the result of hundreds of years of deliberate human caused fires combined with allowing lightning fires to burn. It is doubtful that current management can duplicate those conditions due to existing fuel loading without mechanical treatment and then frequent prescribed fire. A major question and concern should be: "Will current attitudes and needs allow the Forest Service to return the historic role of fire?" Current attempts using Wildland Fire Use (WFU) and Appropriate Management Response (AMR) have resulted in catastrophic fire and the expenditure of
millions of dollars.

I am impressed with the effort that the Forest Service has invested in the DEIS and understand that the effort continues. The strategy remains to be completed for the Payette and Sawtooth National Forests and there remain three more parts to be completed before the effort is complete. The DEIS consists of several hundred pages and is difficult to read due to the frequent use of acronyms. Although, I was a Forest Service employee for 24 years and accustomed to the Forest Service use of acronyms, the practice can be confusing when one suddenly encounters an acronym like VDDT without explanation. (It stands for Vegetation Dynamic Development Tool, a "user friendly computer tool" that is not explained until Appendix 4.) A person not familiar with the Forest Service use of acronyms would probably give up on reading or understanding the DEIS after a few pages. (Note, the DEIS Appendix Section contains 18.65 MB in five sections and also Appendix A "vegetation" of the original Forest Plan, Chapter III containing 1.28 MB; the reason for two appendixes is not clear. I did not read the entire DEIS document because I was only interested in finding the answer to specific questions.) It required considerable research to answer those questions. I doubt that most persons interested in management of the Boise National would have the time and patience to determine the management intent of the amended forest plan. It is even questionable that most persons working on the Boise National Forest would understand the intent of the very complicated management direction contained in the Forest Plan or this DEIS.
My interest in the DEIS stems from the fact that I was a timber forester on the Boise NF from 1967 to 1971, a District Forest Ranger on the Payette NF from 1971 to 1976 and a smoke chaser on what is now the Sawtooth National Recreation Area early in my career during the summers of 1957 and 1958. I became very familiar with the vegetation, topography, and management problems of the area during those assignments. I no doubt contributed to the departure from the Historic Range of Variability (HRV) which is a subject of much discussion in the DEIS through my efforts at fire control and timber sales. Since retirement in 2005, I have also become concerned with the Forest Service fire management policy and have reviewed the results of the Cascade Complex Fire on the Boise and Payette National Forests that burned over most of my first ranger district assignment.
The DEIS is available at I will frequently reference pages in the document with this analysis and readers are encouraged to refer to the document for a full understanding of my analysis. I completed the analysis because of my professional interest in answering four questions:

1. How much of the Boise National Forest will be managed by active
management (mechanical vegetation treatment)?
2. How much will be managed with Wildland Fire Use (WFU)?
3. How much will be managed with prescribed fire?
4. What is the probable result of the proposed management?
The DEIS analyses three alternatives. Alternative A is the current 2003 plan, Alternative B is the proposed alternative and Alternative C is similar to the proposed alternative with exemptions needed to address hazardous fuel reductions. A summary of alternative analysis can be found in the Summary section pages 21 to page 37. The major change proposed would be deleting Management Prescription Category (MPC) 5.2 in the current plan and moving the commodity emphasis of MPC 5.2 to a "restore and maintenance emphasis" in other management prescription categories. Table 2-10 on Summary Section page 36 illustrates the effect of this change on the Allowable Sale Quantity (ASQ), the Total Sale Program Quantity (TSPQ) and the suitable timberland. Table 2-10 also illustrates the change in "old forest habitat" and trend in the "large tree size class" felt necessary for wildlife conservation. Although, the definition of "large tree size" is not defined until Table A-3 on page A-6 of Appendix A. The definition was a surprise for this old forester because I always thought that large trees started about 30 inches DBH and not the 20 inches defined as a large tree. Many of the new trees currently growing on timber sales I prepared and sold on the Boise NF between 1967 and 1971 would be defined as large trees.
Mechanical vegetation treatment includes timber sales, pre-commercial thinning, commercial thinning, and any mechanical treatment that would reduce the fuel loading resulting in the large wildfires. The historical timber harvest that was practiced prior to 1987 when I was a forester/district forest ranger on the Boise and Payette National Forests is mentioned in Chapter 3 (Affected Environment and Environmental Consequences) page 287. The Allowable Sale Quantity (ASQ) was 319MMBF/year and possibly even higher some years. It dropped to 166MMBF/year in 1987 with the completion of Forest Plans under the National Forest Management Act (NFMA). By 2008 the timber harvest from the two forests had dropped to an average of 33.5MMBF/year. Obviously, the economic impact was substantial for affected communities. Several sawmills that depended on the timber harvest closed. The "substantial" transition in the wood products industry is addressed in Chapter 3, Affected Environment and Environmental Consequences, on page 299. At this time there is only one sawmill left south of the Salmon River in Idaho at Evergreen. This mill was actually considered one of the smaller sawmills when I was a forester on the Boise and Payette National Forests. Much of the timber it now cuts is actually from Idaho State Lands and private ownerships. Table 2-16 in the Summary Section, page 49 illustrates "The Reasonable Foreseeable Future Southwest Idaho Output by Ownership". The reduction in mechanical vegetation treatment represents a significant change from the historic past when mechanical vegetation treatment was the major method utilized to treat forest fuels. As explained on page 299 of Chapter 3, Affected Environmental and Environmental Consequences, there are no serious economic consequences from any of the three alternatives analyzed because the mills closed in 2001 and the economic impact had already occurred when the current Forest Plan was completed in 2003.
The acres planned for mechanical vegetation treatment are explained under Management Direction in Appendix 2, Chapter III, page III-12. "On a decadal basis: a) Harvest timber, other than by salvage, on at least 90,000 acres; b) Reforest at least 20,000 acres, and c) Complete timber stand improvement activities on at least 55,000 acres." Using this direction the Forest Service would treat by mechanical methods about 9% of the 1.68MM acre forest every ten years. I believe that the three national forests will have a difficult time using mechanical vegetation treatments to restore the historic role of fire without increasing timber harvest. It is doubtful that the industry that once existed will return without some assurance of raw material availability.
There is no doubt that the Boise National Forest has a fuel management problem.
The problem is explained in the DEIS summary, pages 45-47. "Restoring" the role of fire is an objective of the Boise National Forest. The "Historic Range of Variability" HRV is a guide to restoration. Fire is explained in the Summary, page 45 as a vegetation management tool. The objective as explained in the Summary on page 46: "the objective is to restore the historical role of fire, including the vegetative conditions that resulted from and contribute to how fire operated in the past."
I have no doubt there is a fuel management problem. Until about 1979 the Forest Service suppressed fire with a 10 a.m. policy that required fire planning for control of every fire by 10 a. m. the following day. About 1950, fire suppression became very efficient with the advent of aerial attack; although, starting about 1940 with the manpower furnished by CCC crews, fire suppression became a factor in vegetation development. Many forest acres in the West have not experienced fire for over 50 years. I could understand the change in vegetation about 1960 as the change from serial vegetation to climax vegetation became obvious to a young forester. By about 1970 the result became obvious as fires burned with greater intensity and were more difficult to suppress. In 1979 the Regional Forester of R-4 allowed a "let burn policy" for Wilderness Areas and "roadless areas" providing an environmental analysis was completed. I was on two of the first "let burn fires" that escaped and developed into major fires that required a major suppression effort. Because the practice of letting a fire that started in July burn with little or no control was obviously a problem, the practice was stopped during the 1980s.
A major factor in the 10 a. m. policy was the "Timber Resource Review" directed by Chief Richard McArdle in 1952 to study the availability of timber that would satisfy the demand. The report, "Timber Resources for America’s Future" was not completed until 1958. Following the report, Chief McArdle summarized the findings: "to meet future demands will take earnest effort. Meeting those needs will require not only early action but an intensity of forestry practices that will startle many of us." While McArdle’s words may seem strange for many today, they were believed for much of my early career. We believed that fire control was necessary and that most of the national forest would be managed with mechanical methods. However, starting during the 1980s public concern over timber harvest stopped or delayed many attempts at mechanical vegetation treatment. The intensity of forestry and forestry practices envisioned by McArdle does not exist in the Forest Service today.
Table 3-1 on page 71 of Chapter 3, Affected Environment and Environmental Consequences, illustrates the Historical Fire Regime by Potential Vegetation Group (PVG) that is an objective for the Boise National Forest. Fire Regime is explained on Table A-5 in Appendix A, page A-8 and the PVG is explained on pages A-21 to A-22 in Appendix A. These tables are important because the question becomes, will the Boise National Forest be able to accomplish the desired objective with the management tools available?
Management objectives for fire management are listed on page III-11 of Appendix 2, Chapter III. The objectives are "on a decadal basis, schedule and complete at least 50,000 acres of hazardous fuel reduction and maintenance treatments within the wildland urban interface and on a decadal basis use prescribed fire to treat at least 100,000 acres." In summary the Boise intends to treat with fire about 150,000 acres every ten years. The DEIS becomes somewhat confusing due to the use of fire and terms like "Prescribed Fire", "Wildland Fire Use (WFU)" and "Wildfire". Section 3.2 in Appendix 4 on page 8 somewhat clears up the confusion. Prescribed fire is assumed to be primarily a maintain effect, WFU is a "reset" effect, and wildfire is a "replace" effect. Although, page 8 defines wildfire as an "unwanted wildland fire", one still has to wonder how much wildfire will be utilized as a management tool to "restore the historic role of fire". Considering that 17% of the forest has experienced wildfire since 2000, one has to assume that wildfire will be a major tool. Certainly fire events where major fires burn under "Appropriate Management Response" (AMR) suppression action one has to believe that wildfire will be the major management tool with prescribed fire and WFU used to maintain and reset the effect of major fires.
A summary of activity by management groups is provided on pages 24 to 26 of Appendix 4. Understanding the active management acronyms requires referencing table 18 on page 18 of Appendix 4. By adding up the activities for the first five decades one can obtain a concept of the proposed action. The average yearly acres treated in Alternative B for the first five decades are about 217,550 acres. The treatment by fire use including prescribed fire and wildland fire use is about 118,410 acres a year. One can conclude that wildfire will be used on over 50% of the forest to restore fire to its historic role and then prescribed fire and wildland fire use will be used to maintain and/or reset the historic role of fire. The problem with fire as a tool is somewhat defined on page 96 in Chapter 3, Affected Environment and Environmental Consequences. "Management--such as mechanical thinning or prescribed fire--would likely result in relatively controlled and targeted changes to vegetation, whereas the effects from ecological processes would tend to be more stochastic in space and time." I can certainly agree with this statement. Wildland Fire Use, Appropriate Management Response, and wildfire, especially when fires starting in July or August are allowed to burn with measured suppression activity is characterized by conjecture and what may be theoretically possible. When the Forest Service relies on "ecological processes" as a management tool with little or no interference or advanced planning, nature determines the final result. The public and the Forest Service may not agree with the final result of ecological processes.
Mechanical vegetation treatment and prescribed fire would be capable of producing the desired result with more control. Mechanical treatment is limited by the acres determined to be "suitable". The suitable acres for the proposed action are defined in table 3-61 on page 280 in Chapter 3, Affected Environment and Environmental Consequences, as 516,100 acres or 31% of the forested acres. Table 3-62 on page 281 in Chapter 3 illustrates the Decadal Allowable Sale Quantity and the Total Sale Program Quantity for five decades is displayed on page 284. The change in the type of timber product that will be produced and the affect is recognized on page 322 of Chapter 3. " Alternative B would likely have a greater mix of small to medium log products. The greater mix of lower grade and smaller products would also be expected to result in a higher percentage of stewardship contracts." The change represents a desired condition to increase the number of "large" trees. Large is defined as trees over 20 inches DBH meaning that most of the timber products will be the result of harvesting trees under 20 inches DBH. A problem the Boise NF will face in implementing planned mechanical vegetation treatment is the availability of industrial facilities interested in the small logs. Most of the industry that once existed no longer exists requiring longer haul distances for low value products. The DEIS does not address the possibility of a biofuel industry. Another problem is that the lower value products will likely have a negative value requiring stewardship contracts that are subsidized. Considering the economic difficulties the nation faces, funds to subsidize stewardship contracts will likely be a problem.
The Forest Service and the public have been confused over the mission and purpose of forest management almost since passage of the Multiple-Use Sustained Yield Act in 1960. The plethora of well meaning environmental acts starting with the National Environmental Policy Act (NEPA) in 1969 have only served to increase the struggle to define the purpose of the National Forests. The Forest Service lost its mission about 1985 and has been struggling to define it since that time. The subject DEIS is a good example. Which is more important, habitat restoration or providing the goods and services desired by a confused public? The Forest Service mission defined in the late 1980s as "Caring for the land and serving people" does nothing to answer the question. The complicated and confusing planning process required by NEPA and the National Forest Management Act (NFMA) has proved to be expensive and does little to resolve the management problems facing the Forest Service. The subject DEIS is a good example. Until Congress restores a mission for the Forest Service, no one can answer the question--which is more important, habitat or providing goods and services for the American public.
The subject DEIS illustrates the problem with a lack of clarity of mission. The mission and objective seems to be restoring and maintaining historical habitat (Historic Range of Variability) with fire as a primary tool. However, it does nothing to address the human need for renewable resources today and in the future. The consequences section does nothing to address the affect on soil, fish, water and riparian habitat. One only needs to look at the South Fork of the Salmon River (SFSR) to recognize that the Cascade Complex Fires in 2007 resulted in serious and long lasting impacts on natural resources including sedimentation of the SFSR. Is this result the Boise National Forest envisions from the tools for restoring HRV?
One can not answer that question with the subject DEIS. The subject DEIS does not serve to inform the public of the desirability of restoring the historic conditions existing prior to European settlement or how the renewable resource needs today and in the future will be met by doing so. As a professional forester with 50 years of experience, I have difficulty envisioning how the forest will look in 50 years except it may have more "large" trees with much less density, canopy cover, fewer climax species and more serial species. I can envision that there will be an impact on soil, water, and riparian resources with fewer natural resources available to satisfy human needs. Perhaps this is what the Boise National Forest and the public desires; however, I doubt that the forest in 50 years will look like this DEIS describes or the result is something the public will accept.



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