California Calls for USFS Management Changes to Prevent Wildfire

by Larry H.

A California state senator has introduced a resolution calling for the USFS to “change management structure.”

BILL NUMBER: SCR 75 [here]
INTRODUCED BY Senator Hollingsworth
FEBRUARY 18, 2023

This measure would declare that there is an ongoing emergency due to the threat of wildfire, call on the federal government to take immediate measures to prevent imminent catastrophic wildfires, and request Governor Schwarzenegger to advocate at the federal level for the United States Forest Service to undertake prevention and maintenance work in the state’s federal forest lands and to encourage a change in management structure in the United States Forest Service to coordinate decisionmaking authority over state project decisions inside the state.

Lots of very interesting “whereas” clauses are included in this bill. Example:

WHEREAS, Insurance losses for each fire season run into the billions of dollars, and insurers have paid out in excess of eight billion dollars ($8,000,000,000) to thousands of policy holders from just the top 10 state wildfires since 1970;

And a “resolved” cause to change the structure of the USFS:

Resolved, That the Legislature, together with the state’s local governments, requests that Governor Schwarzenegger advocate at the federal level for the United States Forest Service to undertake prevention and maintenance work in the state’s federal forest lands, and to encourage a change in management structure in the United States Forest Service to coordinate decisionmaking authority over
state project decisions inside the state;

California Sen. Holligsworth is evidently fed up with his state being a burn zone for the Feds. He’d rather not incur any more disastrous wildfires due to Federal incompetence. He’d prefer that the USFS figure out how NOT to promulgate any more megafires because the cost-plus-loss to California is outrageous.

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The Tumblebug Fire

On September 12, 2010, two lightning-ignited fires were reported to be burning in Tumblebug Creek, a tributary of the Middle Fork of the Willamette River. Three weeks later 14,570 acres had burned, including ~5,000 acres of old-growth spotted owl forests, and $100 million in timber had been destroyed. The real tragedy, however, is that the Tumblebug Fire is a harbinger of larger, more severe, and more damaging fires to come.

How this fire happened, and why it is a prelude to even greater disaster, is the subject of this essay.

The 1.7 million acre Willamette National Forest [here] extends from the Calapooia Divide in Douglas County, Oregon, to the Santiam Divide in Marion County. It encompasses the headwaters of following major watersheds: the Middle and North Forks of the Willamette River, the McKenzie River, and the North and South Forks of the Santiam River. East to west the Willamette NF begins at the crest of the Oregon Cascades and slopes westward to the foothills of the Willamette Valley.

Situated as it is on the west side of the Cascades, the Willamette NF is one of the most productive forests in the world. Temperate climate, abundant rainfall, and rich volcanic soils engender forests that are capable of growing nearly a billion (with a “b”) board feet per year.

In 2009 28 million board feet (MMBF) were harvested, less than 3% of the annual growth. In prior years the harvest was:

2008 _ 30.6 MMBF
2007 _ 29.6
2006 _ 49.8
2005 _ 71.1
2004 _ 59.9
2003 _ 20.5
2002 _ 20.2
2001 _ 18.8

Source: Region 6 Cut and Sold Reports and Volume Under Contract [here]

In no year in the past decade has more than 7.1% of annual growth been harvested. Yet the forests have continued to grow, not only the trees but also the brush, and the biomass has built up.

Biomass is fuel — the accumulated growth is accumulated fuel that will burn. The more fuel, the hotter and more intense the fires.

The Willamette NF is primed to burn in a forest fire larger and more intense than any in state history.

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16 Mar 2010, 10:03pm
Federal forest policy Saving Forests
by admin
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D-bug Hazard Reduction and Timber Sale Project DEIS Comments Requested

Notice of Informational Public Meeting, Umpqua NF, posted March 4, 2023 [here]

It has been nearly a year since the Forest sent out the D-Bug Draft Environmental Impact Statement (EIS) for public comment and review. Since then changes in regional and national policy have kept the project in a state of flux, and the Forest has been evaluating and responding to these policy changes along with the public comments received on the Draft EIS.

The Forest would like to re-engage with the public to share information on the current status of the D-Bug project and allow an opportunity for comment and dialogue on an implementable path forward for this important fuels reduction project.

To facilitate this information sharing and discussion, a facilitated public meeting is planned for:

Friday, March 19, 2023
1:00 pm to 4:00 pm
Douglas County Library
Ford Community Meeting Room
1409 NE Diamond Lake Blvd

Note: Extending Comment Period to Monday June 8, 2023

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The Great Montana Land Swindle, Phase II

To put the following USFS Press Release in context, also see:

The Great Montana Land Swindle of 2008 [here]

The Montana Legacy Project: Worth the Price? [here]

The Great Montana Land Swindle Sleazes On [here]

Montana Legacy Project Phase II Conserves [formerly] Working Forests

NEWS RELEASE: USDA Forest Service — Northern Region. March 15, 2023 [here]

Missoula, MT. – The Lolo and Flathead National Forests are assuming management of approximately 112,000 acres of former Plum Creek Timber Company lands purchased by The Nature Conservancy (TNC) and The Trust for Public Land (TPL) as Phase II of the Montana Legacy Project comes to a close today with the official transfer of ownership to the Forest Service.

“It’s such an honor to witness the addition of over a hundred thousand acres of occupied lynx, grizzly bear, and bull trout habitat brought under the umbrella of public land management,” said Northern Regional Forester Leslie Weldon. “There is significant wetland habitat and a great diversity of plant species on these lands. Acquiring these parcels allows us to restore whole landscapes, assist wildlife in adapting to climate change by reducing habitat fragmentation and conserving water flows as these [formerly] working forests are placed in permanent public ownership.” … [more]

A Short History of the WFLC

Questions have arisen regarding my Open Letter to Open Letter to Ken Salazar Re WFLC [here]. By way of clarification, I have prepared the following.

Note: this essay refers to the Wildland Fire Leadership Council, not the Western Forestry Leadership Coalition, which shares the same initials but is an entirely different organization.

The Wildland Fire Leadership Council (WFLC) was established in April 2002 by the Secretaries of Agriculture and the Interior to provide an intergovernmental committee to support the implementation and coordination of Federal Fire Management Policy. [here]

The Wildland Fire Leadership Council (WFLC) was established in April 2002 to implement and coordinate the National Fire Plan, the Ten-Year Strategy (a component of the National Fire Plan) and the Federal Wildland Fire Management Policy. WFLC consists of senior level department officials, federal, state, tribal and county representatives, including all five federal wildland firefighting agency heads. WFLC was established to address interagency, interdepartmental differences to ensure seamless delivery of a coordinated fire protection program. The Council brings together wildland firefighting organizations to implement the 10-Year Comprehensive Strategy and Implementation Plan. WFLC meets regularly to monitor progress of the Ten-Year Strategy, to discuss current issues, and to resolve differences among wildland firefighting agencies.

Authority.  The Departments of Agriculture and the Interior are authorized to enter into cooperative agreements by the Protection Act of 1922 (42 Stat 857; 16 U.S.C. 594) and the Public Land Administration Act of 1960 (74 Stat 506; 43 U.S.C. 1361-1364).

In addition, the Secretaries entered into a Memorandum of Understanding dated January 28, 1943, and  February 21, 1963, to provide adequate wildfire management and protection to the lands under their respective jurisdictions.  State representation is authorized by the Clarke-McNary Act of June 7, 1924, Sec. 1 (43 Stat 653, 16 U.S.C. 564).  [here]

In Fall of 2006 it came to my attention that lobbying groups, specifically the Nature Conservancy (TNC) and the Wilderness Society (TWS), were participating in WFLC meetings. I made an inquiry to the Committee Management Secretariat (CMS) of the GSA which oversees the Federal Advisory Committee Act (FACA). They informed me that the incorporation of registered lobbyists on Federal Advisory Committees was a “gray area” of the law, and that I could file a lawsuit if I so desired.

I consulted with my attorney and he asked me how much money I had. That killed that idea.

In the meantime the WFLC received some sort of communication from the CMS regarding my inquiry, and in early 2007 they asked Federal attorneys to draw up a Memorandum of Understanding that would declare them NOT to be a Federal Advisory Group and to allow registered lobbyists to continue to participate. From the WFLC minutes of February 22, 2023 [here]:


* Request Secretaries to extend MOU
* Revise MOU language for NGO participation consistent with WFLC goals. WFLC should not become a Federal Advisory Committee. Consider addition of a fire chief’s representative as WFLC member, in a manner consistent with FACA. Confer with legal counsel. Draft business rules for review.
* Circulate draft, convene conference call to discuss. (WFLC Staff)
* New MOU at June meeting

TNC and other NGOs will assist with communication plan for wildland fire use as part of TYIP Goal 3, Task 2.

On April 3, 2023 I reported all this at SOS Forests [here]. As a direct result, on April 5, 2023 the WFLC removed the Feb. 22 minutes and their entire directory at, a URL that no longer exists.

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11 Mar 2010, 3:34pm
Federal forest policy Saving Forests
by admin

Wilderness Recognized As Fire Hazard

Well, what do you know? It turns out that some other folks (beside us) have recognized that wilderness designation does not “protect” resources; instead it endangers them.

Forest Service assesses effects of Wilderness on firefighting

Opinions differ among feds, firefighters and Wilderness advocates

Scott Condon, The Aspen Times, Thursday, March 11, 2023 [here]

BASALT — Turning Basalt Mountain into Wilderness wouldn’t prohibit firefighting there but it would eliminate opportunities to reduce dead trees and fuels that have built up for decades, the top official in the White River National Forest said Wednesday. …

Basalt firefighters and Wilderness activists disagreed with parts of the assessment made by Forest Supervisor Scott Fitzwilliams, showing how difficult it is to sort through some implications of the Hidden Gems Wilderness Campaign.

Fitzwilliams said the Forest Service assesses and makes an appropriate response to every fire in the national forest, regardless of whether or not it is in Wilderness.

In a location like Basalt Mountain, the decision to fight a fire will be made most of the time, Fitzwilliams said. “Whether that’s Wilderness or not, the response is probably going to be the same,” he said.

Whenever a fire poses a threat to the town of Basalt or homes in Missouri Heights, the decision would be made to fight the fire, he said. Fires in Wilderness areas are allowed to burn when they don’t pose a threat to lives, houses or infrastructure.

Fitzwilliams conceded that federal land managers are responsible for leaving Wilderness “pretty much as it is.” Using heavy equipment to gouge a fire break in the earth, for example, might require an extra call for clearance, he said.

That’s why the Basalt Fire Department is concerned. Fire Chief Scott Thompson said that, with all due respect to the Forest Service, the written rules and the application of rules aren’t always the same. Written rules that appear to provide flexibility can actually provide an extra hurdle.

The fire department typically handles the first response to wildfires on Basalt Mountain. Requiring an extra step of approval to fight a fire in a Wilderness area might take “hours or days,” Thompson said.

He said his assessment comes from practical, in the field experience in dealing with the Forest Service on Wilderness issues for 15 years as a former Pitkin County deputy sheriff and for 10 years as the fire chief. That experience indicates it won’t always be a speedy process to get approval to fight a fire in Wilderness. And that, he said, could result in a catastrophic fire for the homeowners of Basalt.

Here we have an experienced Forest Service person, White River NF Forest Supervisor Scott Fitzwilliams, admitting that wilderness fires do not (cannot) receive the same aggressive rapid response that non-wilderness fires do. Mr. Fitzwilliams also notes that fuel build-up in wilderness areas cannot be dealt with under current laws. And he warns that fires in wilderness area can (and do) propagate beyond wilderness boundaries and subsequently endanger communities.

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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.


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, 2023 [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, 2023 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> on your letters.

Thank You!!
Karen Budd-Falen
February 25, 2023

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25 Feb 2010, 11:13am
Federal forest policy Saving Forests
by admin
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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, 2023 (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:


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

Submit Comments to


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

Submit Comments to


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

Submit Comments to

Additional information is available at

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, 2023

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.

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. …

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