Chapter 4
General Issues and Concerns
Introduction
This chapter addresses management, policy, and other issues and concerns that did not fit in with the major technical issues. It begins with a section discussing concerns related to implementation of the California Spotted Owl EIS. The chapter concludes with a section on information needs for the Sierra Nevada.
Concerns Regarding the Implementation
of the California Spotted Owl EIS
The Committee fully understands that the Final EIS and accompanying Record of Decision (ROD) will be the basis for amending the Forest Plans for the 10 national forests of the Sierra Nevada. The Committee also understands that additional direction for implementation and accountability will be forthcoming from the Monitoring Program being developed for the EIS. Additional line direction from the Regional Forester will also guide ecosystem management on these forests.
During the process used by this Committee many issues and concerns were raised related to the implementation of the EIS and additional management direction related to future forest management. The Committee therefore feels it is important to convey these concerns and provide suggestions to the Forest Service that may help in addressing them. Those concerns are as follows.
There is not a formal link between the objectives of the preferred alternative and the budget and appropriation process that produces operational funding for the national forests. This problem is not unique to this EIS but creates a serious credibility problem for the agency. It is not clear in the EIS what will be accomplished at various levels of funding and the alternatives themselves were not developed within any specific budget constraints or mix of line item appropriations. The Administration could use the California Spotted Owl EIS commitments as a basis to generate adequate funding for implementation or clearly state priorities within budget constraints.
Concern was expressed about the available professional expertise for appropriate implementation of the preferred alternative. This is especially significant because the EIS is a descriptive document, and does not rely on a "cookbook" of standards and guidelines approach. The effective implementation of the preferred alternative will depend on a diverse, highly professional workforce. The Region could review its pool of available professional expertise and develop a strategy to improve capability if appropriate.
Forest Service policies should be examined for consistency with the preferred alternative. Most likely the Region plans to do this, nevertheless, the Committee would like to document an example of a policy needing assessment prior to the implementation of the preferred alternative. One of the premises of the EIS is that harvesting of timber will reduce the potential for catastrophic fire. This reduction depends upon the level and effectiveness of slash treatment. The current fuel treatment policy only requires that within five years fuel treatment be done to achieve hazard levels equal to or less than pre-harvest hazard. Operationally, in many situations, this results in no net change in fire hazard potential.
The Region should consider changing its fuel treatment policy to require a reduction in post-harvest fire hazard potential as compared to pre-harvest conditions and to do so within one year to avoid increases in fire hazard.
Successful implementation of the preferred alternative depends upon a market for small biomass material. If current policies about minimum sizes of material offered for sale are potentially a barrier to developing new markets, they should be changed.
A long standing problem in developing an adequately funded fuel treatment program is the inability to identify the costs and expected returns in fuel management investments and adequately describe the magnitude of the required program. Additionally, it has been difficult to describe the relationship between future fire suppression costs and potential cost savings due to fuel treatment programs. The Committee also notes no proposed alternative that addresses, in a meaningful way, fire hazard reduction. The Region could develop an alternative that reduces fire hazard to be used to display to society and politicians the potential costs, and benefits of required investments. (See the Fire and Fuel section of this report.)
The successful implementation of the preferred alternative is complicated by the uncertainty of projections of outcomes and lack of scientific information. Additionally, during the timeframe for which the alternative is expected to guide forest management, new information, improved techniques, monitoring feedback, and public values will shift and change. The Committee feels it important that the Region consider implementation of adaptive management processes that help assure appropriate shifts in direction based upon these inputs. Adaptive management should include specific consideration for project design that facilitates learning from management actions.
Many persons and organizations expressed concern about the lack of a completed monitoring program. Because of the qualitative nature of the EIS, it is difficult to determine what will actually be applied to the landscape as forests attempt to achieve the vision. Unfortunately, this issue is complicated by a considerable amount of distrust in resource agencies. Substituting traditional standards and guidelines with performance measures in the monitoring plan also stimulates challenges to the professional and organizational capabilities of the Forest Service. Furthermore, NEPA processes generally do not require completion of a monitoring program prior to final decisions and issuance of the ROD. So in effect, the standards and guidelines issue is linked to the monitoring issue. The Region should evaluate the need for additional standards and guidelines and ways in which to expand the monitoring design in the EIS. This might include the inclusion of performance measures already developed by the monitoring program design team.
The Committee detected a considerable amount of distrust in the Forest Service. There seems to be a fairly widespread belief (some of it internal) that the Agency will not actually do what it says it will do, or will go to great lengths not to implement line and administrative direction. The Committee can not assess the extent and intensity of this distrust, but hopes every step is taken to help regain employee and public confidence. Releasing the RDEIS without addressing the deficiencies identified in this report would probably exacerbate that mistrust.
One way to help increase trust would be to carefully examine how well the RDEIS states the assumptions, describes analysis techniques, and quantifies expected performance. Any constraints on the planning process should be clearly described. The criteria and techniques used to select the preferred alternative should be well documented. The content of the Record of Decision (ROD) could also help with this issue.
Information Needs for the Sierra Nevada
Several resource management questions related to the Sierra Nevada, which are lacking professional and scientific consensus, need special attention. These include:
The Committee suggests that additional focused research, collaborative assessments and synthesis, and analysis by Forest Service staff specialists be supported.