Statement of

Nancy Graybeal

Deputy Regional Forester

Pacific Northwest Region

Forest Service

U.S. Department of Agriculture

Before the Subcommittee on Forests and Public Land Management

Committee on Energy and Natural Resources

United States Senate

October 24, 2001

Concerning

The Northwest Forest Plan

Mr. Chairman and members of the Committee, thank you for the opportunity to be here today. I am Nancy Graybeal, Deputy Regional Forester, for the Pacific Northwest Region, which covers Oregon and Washington. I am here today to discuss the Northwest Forest Plan (NFP).

BACKGROUND: The Forest Service, Bureau of Land Management (BLM), and other cooperating agencies developed the NFP to bring balanced, long-term management to federal lands administered by these agencies in western Washington, western Oregon, and northern California. Forest plans in effect in the late 1980s contained management direction that allowed the harvest of old growth forests that served as essential habitat for northern spotted owl. The loss of habitat was a primary factor cited for the listing of the owl as a threatened species in 1990. Legal challenges to the Forest Plans primarily involved with compliance of the National Environmental Policy Act (NEPA) and the National Forest Management Act (NFMA) led to court injunction in 1989, 1991 and1992 against preparing new timber sales in northern spotted owl habitat pending adoption of a spotted owl habitat management plan.

The NFP provides a terrestrial and aquatic conservation strategy for forest management on more than 24 million acres of Federal land in the Pacific Northwest. In a 1996 ruling the Ninth Circuit court upheld the legal adequacy of the NFP.

Key principles in the NFP include maintaining a focus on human and economic needs; protecting the health of forests, wildlife and fish habitat, and watersheds; using sound science and management strategies; providing a sustainable timber supply; using an adaptive strategy to update management in light of new information, and improving the way Federal agencies work together.

In your letter you asked for information on implementation of the NFP and the effects on species restoration and timber availability. As you may well imagine, implementing a plan of this scale and complexity brings successes in some areas and provides continuing challenges in other areas where successes have been more infrequent.

SUCCESSES:

The NFP presentss a regional conservation strategy for northern spotted owl populations providing habitat for other species associated with old-growth forests, and restoring aquatic habitat for Pacific salmonids.

Completing federal landscape-wide assessments: The Forest Service and BLM share responsibility for implementing the NFP. The two agencies have successfully completed landscape assessments for managing reserves and watersheds in accordance with Plan objectives on approximately 95% of the Federal land base.

Aquatic habitat and clean water: An Aquatic Conservation Strategy is in place for maintaining and restoring Federal lands within watersheds needed for recovering listed salmonids and for providing clean water. This strategy has implications for state and private land ownerships as well. The Willamette Basin Restoration Initiative relies on the NFP as the Federal commitment towards restoring water quality in this regional river basin. The Oregon Plan for Salmon and Watersheds acknowledges the critical importance of Federal watersheds in the recovery of listed salmonids. The Oregon State of the Environment Report 2000 provides an indication of the success of the standards and guidelines for the Aquatic Conservation Strategy. The report credits revised management plans of Federal and state lands making significant contributions toward improving Oregon’s environment: “…Much of what potentially can be achieved on federal lands is already reflected in new policies and plans for managing forest and range lands” (pg. 3). The report concludes that the greatest opportunity for improving Oregon’s environment is on state, county, and private lands at lower elevations than Federal lands.

Restoration: Much has been done to improve Federal watersheds and forest health. For example, we have stabilized 12,000 miles of roads with improvements including drain dips, bridges, water bars, and culvert replacement to prevent damage from erosion to water quality, riparian ecosystems, and fish habitat. We rehabilitated and improved over 1,500 stream miles for trout and salmon habitat. We decommissioned about 2,000 miles of unneeded roads in Oregon, California, and Washington.

New information: Under the Survey and Manage component of the NFP, we have learned about the distribution of over 400 species about which little was known prior to 1994. The Survey and Manage standards and guidelines were developed as mitigation measures for species that are part of the diversity of plant and animal communities and which play roles in the productivity and functions of old growth ecosystems, and for which long-term persistence was a concern even with the reserves and other components of the Plan. Using the NEPA process, we adopted amendments to Survey and Manage earlier this year, to clarify and simplify the provisions based on new information and experience. Under the amended provisions, we expect to make updates more rapidly, including identification of species that can be removed from Survey and Manage requirements. The disposition of ninety-two species will be decided in December. These species may be moved to less restrictive categories or removed from Survey and Manage. By reducing restrictions, certain species will no longer require predisturbance surveys and we estimate costs may be reduced by up to 20%.

Research: Research findings were crucial in developing and supporting the Plan since inception. The Pacific Northwest Research Station's activities have included both research on key questions raised by the Plan, and also participation of scientists in activities that have supported Plan implementation (for example, developing protocols for monitoring and survey/manage species). The Station has developed tools for identifying species, scientifically valid survey methodologies, habitat maps and models, and conservation measures, all of which are being used in NFP implementation.

Research on stand-level dynamics in old forests, including the roles of a wide suite of organisms and structural elements (for example, large down wood, understory plants, and mycorrhizal fungi) has demonstrated the benefits of various thinning regimes for the development of old growth structure and processes. This information suggests thinning in young plantations in Late Successional Reserves may benefit development of old growth structural characteristics. These findings have been published only recently and are under consideration.

Implementation monitoring: Since 1996 we have been conducting an annual, regional-scale monitoring of plan implementation by interagency teams that include PAC members. This monitoring of plan implementation over the past five years has shown a 95 percent level of compliance with standards and guidelines.

The economic dimension: A sustainable, predictable level of timber output has been a goal of this plan. Starting from a near-shutdown of the timber sale program due to court ordered injunctions in the early 1990’s, the Forest Service was able to gradually increase the level of timber outputs to the point where the FY 1997 timber program sale offering was nearly equal to the amount projected. However, this decreased dramatically since, primarily as a result of additional litigation and adverse court rulings (Appendix 1).

The Northwest Forest Plan included two major efforts to address economic change --Jobs in the Woods, and the Northwest Economic Adjustment Initiative (Rural Community Assistance). Between 1994 and the end of 2000 the Forest Service delivered technological assistance and grants to over 400 communities, including 40 Native American tribes. Much of the environmental restoration described earlier has been accomplished through local contractors from small communities and tribes which either created new jobs or retained existing jobs. Community based success ranges from small log sort yards and value-added manufacturing to commercial native plant nurseries, increases in locally owned businesses, and more diversified economies.

CHALLENGES

Public issues, public acceptance: The Northwest Forest Plan was designed to address specific issues related to species dependent on late-successional and old growth conditions, while providing a predictable supply of timber and economic assistance to local communities. With this limited focus, other public issues were not addressed, and those that were often reflected compromise among competing values. Consequently, the NFP is only partially accepted by the involved publics with competing groups often accepting only those parts fitting their values and rejecting others. Some groups find the failure to meet the timber targets unacceptable. Other factions question the need to harvest old-growth trees or even any trees from the national forests. Adaptive management practices, which could result helping to meet timber goals, are also rejected. Road management and road closures also cause polarization among forest users.

The lack of acceptance described above is expressed in a variety of ways including NEPA appeals and litigation. It is also sporadically expressed in the form of criminal actions, such as arson, resulting in property damage, damage to resources and infrastructure (roads, research and administrative facilities, equipment) and personal threats.

Economic dimensions: Economic declines continue in many communities in the area covered by the Plan. Many of the most isolated and heavily dependent timber communities are still struggling. Many lack the basic economic infrastructure necessary for new development and financial opportunities. Even with business recruiting underway, restructuring, retooling, and retraining take time, and the jobs that have been created are still not comparable in pay to traditional timber industry jobs.

Complexity and legal challenges: The Northwest Forest Plan is a highly complex plan for managing resources. As a result, there are opportunities for multiple interpretations of its objectives, standards, guidelines, and implementation processes by the various Federal agencies and the courts specifically related to survey and manage and aquatic conservation strategy implementation. We continue to receive legal challenges based on these differing interpretations. The Northwest Forest Plan attempted to provide a balance between resource protection and commodity outputs – primarily timber. While there was limited initial success in meeting expected timber sale quantity levels after the Northwest Forest Plan was implemented, we have experienced substantially less success in recent years. The FY 2000 timber sale offering of 87 million board feet represented just 13% of the probable sale quantity forecast in the Plan.

A number of factors have contributed to this including: 1) difficulty in precisely estimating the effects of mitigation measures such as survey and manage, and 2) the effects of several court rulings on our ability to award timber sales. Although rulings from these lawsuits have generally been limited to the forest plan amendments and timber sales, they have the potential to impact all activities in the NFP area, such as projects under the National Fire Plan, the National Energy Plan, and the Secure Rural Schools and Community Self-determination Act. In addition to individual lawsuits aimed at stopping projects, some organizations are now beginning to litigate on the broader Endangered Species Act issues, expanding the scope of lawsuits to include regulatory agencies.

Processes: The Northwest Forest Plan includes many process requirements. They can be categorized into two types: 1) analysis process requirements and 2) oversight process requirements. Analysis process requirements include watershed analysis, Late Successional Reserve assessments, and Survey and Manage. They are intended to improve the quality of decisions. Watershed analysis and Late Successional Reserves provide larger scale ecosystem context to project level decisions. Survey and Manage provides information and protection for little known species that depend on late successional habitat. Oversight process requirements provide interagency review of certain analyses and activities by the Regional Ecosystem Office or the Regional Interagency Executive Committee. The intent is to improve information exchange, help coordinate various agency policy requirements, and surface interagency disagreement on issues. Interagency coordination, which is essential to the maintenance of a coherent land management program, requires a great deal of work that is not reflected in the actions on the ground. Different agency missions and policy interpretations have often become barriers to achieving the coordinated actions intended by the Plan.

Costs: When the decision was made in 1994 to implement the Plan we knew it would increase our management costs. Public and interagency collaborative processes, additional interagency oversight (such as that provided by the Regional Interagency Executive Committee), new and changing analysis requirements, and a complex Survey and Manage program have all contributed these higher costs.

The processes under the Survey and Manage requirements were largely conceptual at the time of the decision. After working for several years to put the necessary processes in place it became apparent that implementation was time consuming and at times impractical, and very expensive. We attempted to simplify the process and make it more flexible though a Plan amendment in 2001. However, the sideboards used for developing this amendment resulted in a decision which is still expensive to implement, and not yet proven through efficient changes to the Survey and Manage requirements.

Adaptive Management: The authors of the Northwest Forest plan along with the Secretaries that signed the Plan envisioned a resilient plan where changes to standards and guidelines or land use allocations based on monitoring and new information could be readily made. Agencies and the scientific community still embrace the concept, but challenges to resilient change remain.

Two factors appear to affect our ability to change based on what we have learned from monitoring and new information. The first is disagreement among agencies and involved publics over what constitutes adequate information for a decision to change. Although our information base continues to improve with each year of monitoring and research, it is impractical to gather enough data to eliminate all risk and all uncertainty. The second factor influencing adaptive management is the existing framework of laws and regulations, particularly ESA, NEPA and NFMA. The Plan does not supercede existing treaties, laws, or regulations, of course, so adaptive management decisions must be made in accordance with the applicable laws.

SUMMARY

The Northwest Forest Plan is a regional conservation strategy involving complex legal, scientific, and policy issues and questions. The basic intent of the Plan is worthy. Varying interpretations of policy and laws, differing agency missions, procedural requirements, and high costs challenge the achievement of the intent of the NFP authors.

Chief Bosworth, and I welcome opportunities to work with you and the subcommittee to address the challenges of implementing and achieving all the goals of the Northwest Forest Plan Amendments.

Mr. Chairman, this concludes my written statement. I would be happy to answer any questions you or members of your subcommittee may have.

Appendix 1. Trends in R6 Northwest Forest Plan Timber Offer
Timber Data		FY 95	FY 96	FY 97	FY 98	FY 99	FY 00	FY 01
Total Timber Budget	M$	$43,331	$49,000	$48,787	$49.863	$44,634	$48,411	$53,901
Total Timber Financed	MMBF	367.8	514.1	533.0	566.3	566.0	484.0	430.9
Total Volume Offered	MMBF	393.3	510.0	538.6	417.0	164.0	62.0	N/A
Unit Costs
Volume Financed	$/MBF	$117.81	$95.32	$91.53	$88.06	$78.86	$100.02	$125.09
Volume Offered	$/MBF	$110.17	$96.08	$90.58	$119.57	$272.16	$780.81	N/A

For more information contact Gary Yeck