Northwest Forest Plan Review

Plans & Reports

NORTHWEST FOREST PLAN REVIEW

Pacific Southwest Region Findings

Prepared by the USDA Forest Service Pacific Southwest Region

Regional Forester Jack Blackwell led a review of the Northern California National Forests covered by the Northwest Forest Plan (NWFP) to determine how well the Plan was working and to identify what could be done to improve implementation. Other team members included former Chief of the Forest Service, Dr. Jack W. Thomas and Deputy Regional Forester Kent Connaughton. The review occurred during the week of June 23, 2003. Representatives of local tribes, other federal agencies, the national forests and community groups participated...

The review identified ten broad findings concerning the implementation of the National Fire Plan, forest management under the NWFP, and the processes of the NWFP. The findings are related and should be read and interpreted from the perspective that together they convey an answer to the question: “How is the Northwest Forest Plan working in the national forests of northern California?”

Implementing the National Fire Plan under the Northwest Forest Plan

Finding: The National Fire Plan (NFP) and the Northwest Forest Plan (NWFP) are conceptually compatible. However, NWFP standards, guides, and procedures have hampered the implementation of the NFP, and implementation practices and priorities are often not compatible between the NWFP and the NFP.

The Record of Decision for the NWFP recognizes that the forests of northern California are fire adapted and vulnerable if forest fuels are not treated to reduce the threat of severe wildfire. The standards and guides of the NWFP, however, are the same for California as for the rest of the range of the northern spotted owl, and process requirements for survey and manage and consultation with regulatory agencies have not permitted the degree of flexibility to manage hazardous fuels as implied by the Record of Decision and as called for under the National Fire Plan. Post-fire restoration has, in some cases, been complicated and even thwarted by similar process complexities and litigation.

• The 4 Forests contain 1.25 million acres of wildland urban interface (WUI). There are 591,000 acres identified at risk from high and moderate severity fires.
  • Over the last 7 years the California NWFP national forests were expected to treat about 411,000 acres but only treated 116,000 acres.
• Under the NFP the forests need to annually treat 34,000 acres within the WUIs over the next 30 years. An estimated 4,200 acres are currently being treated annually within the WUIs. There is a divergence of emphasis between the National Fire Plan (NFP) and the NWFP. Overall goals are compatible but the objectives and implementing guidelines sometimes are in conflict. Short-term objectives, priorities and types of treatments for fuels reduction versus timber production are different.
• Forests are currently focusing their limited resources on treating projects within the Wildland Urban Interface (WUIs), leaving limited funds for treatments in late successional reserves (LSRs.) Sometimes WUIs are located within LSRs and this can limit what fuel reduction options are considered for treatment.
• Fuel treatments to protect communities from high intensity fire have been complicated and costs have increased as a result of process and consultation clearances.
  • High priority treatments in WUIs take longer and are more costly due to the survey and manage requirements.
  • Forests have willing and eager partners who want to help implement the NFP, but such partners have expressed frustration with the extended planning time, management constraints, and high costs.
  • Traditional needs of tribes (primarily small prescribed burns, but also cultural and ceremonial needs) have not been fully met.
• Northern California LSRs are especially at risk from wildfire if left untreated.
• Although the fire situation in northern California and southeastern Oregon is significantly different than the rest of the NWFP area, the standards and guidelines for treatments are the same, thereby complicating the use of treatments that could be used to protect the habitat values of LSRs.
• Although there has been support from the Regional Ecosystem Office (REO) for treatments within LSRs, some specific requests with beneficial reduction of forest fuels have not been supported. One specific example is the request to remove firewood from LSRs.
• Post-fire salvage and fuels treatments accomplished after wildfires have been difficult to achieve primarily due to the requirements for watershed analysis (WA), survey and manage (S&M) and consultation requirements.

Forest Management under the NWFP

Finding: Timber outputs are not at the predictable and sustainable levels projected by the Northwest Forest Plan

There is a significant difference between what was projected for timber harvest when the Northwest Forest Plan was adopted, what was subsequently projected when the Forests’ Land and Resource Management Plans (Forest Plans) were adopted, what was funded, and what has actually been accomplished.

• The NWFP the Probable Timber Sale Quantity (PSQ) was estimated at 1.8 billion board feet (224 million board feet annually) for the past eight year period. Under the Forest Plans the PSQ for same eight year period was re-estimated at 1.5 billion board feet (188 million board feet annually).
  • The differences were largely due to the effects of visual quality objectives, projections of cumulative watershed effects, riparian reserve designations, and litigation and appeal decisions on timber harvesting.
• Land available for timber production (1,260,000 acres in matrix and 409,000 acres in adaptive management areas) has been reduced by riparian reserves, recent roadless area policies, survey and manage protection buffers, and northern spotted owl baseline protocols such that slightly less than 408,000 (24%) acres are fully available for the timber management activities originally envisioned under the NWFP.
• Thinning, rather than regeneration harvest using Green Tree Retention (GTR), has been the dominant practice yielding timber volume.
  • The Forest Plans called for timber harvest on an estimated 99,000 acres over the past eight years, but harvest has actually taken place on 153,000 acres.

Finding: Management treatments are needed in many Late Successional Reserves (LSRs) but have not been aggressively pursued

Late-Successional Reserves were designed to maintain and enhance late successional forests as an old-growth forest ecosystem. The NWFP Record of Decision acknowledges, however, that LSRs in the Klamath Province are susceptible to stand-replacing fires and states that silviculture and fuels treatments may be appropriate to protect them. LSR Assessments have indicated that many LSRs in Region 5 are in jeopardy and not only need treatment to reduce risk of catastrophic fire, but the stands are dying from insects and disease. Treatments have not been pursued on a large scale. REO, regulatory agencies and some Forest Service biologists have taken an overly precautionary approach to management activities inside the reserves.

• Late-Successional Reserves (LSRs) Assessments have identified 546,000 acres for treatment. Forests have accomplished treatments on 17,236 acres (3% of what was identified.).
• Forests are reluctant to spend funds allocated for commercial timber harvest in LSRs because such treatments do not contribute to Allowable Sale Quantity (ASQ) goals (commercial timber sale volume goals).
• LSRs are vulnerable to high intensity fires.
• Silvicultural standards and guidelines allow for treatments in young stand less than 80 years old. This may be overly constraining for the treatments needed in the degrading conditions of many LSRs, which are old decaying stands that are no longer suitable habitat.

Finding: Management of the matrix has emphasized thinning rather than Green Tree Retention and has been more expensive than planned

Forest management on the 1.26 million acres of matrix is not occurring as predicted under the NWFP due to factors internal and external to the Forest Service. Specifically, the lands that are Capable, Available & Suitable (CAS) for timber production are not being managed for commodity production as projected in the NWFP.

• Ecological succession is affecting the vegetation within the matrix more than timber harvesting. The growth rate on the regulated CAS matrix lands is 308 million board feet (mmbf) annually, while the PSQ is 188 mmbf annually and the harvest has averaged 113 mmbf annually. Growth exceeds cut by a factor of three.
• The number of acres available for treatment on matrix lands has decreased due to: (1) limitations set by roadless area policy; (2) size and location of survey and manage protection buffers; (3) cumulative watershed effects; (4) protection of old growth that was prescribed for harvest; (5) amount of unsuitable lands and plantations, riparian reserves, and overlap from other land allocations such as LSRs.
• There has been a lot of effort to meet habitat protection objectives for species covered under the NWFP.
• Regeneration harvest using Green Tree Retention (GTR) prescriptions was the primary silvicultural treatment originally envisioned in matrix lands and AMA’s (66,400 acres) to reach the projected PSQ. Only a fraction of that has actually occurred during the last 8 years. Because of silvicultural, fuels reduction, and other considerations, more thinning has been done, in lieu of GTR.
• In some cases, private land use and management affect options for managing federal lands. Management of private lands is considered in evaluating cumulative watershed effects, and such evaluations may affect the choice of management options for federal forests, effectively trading off planned, but more intensive federal land management against management already occurring on private land.
• The effects of survey and manage, roadless area management policy, cumulative watershed effects, northern spotted owl baseline analysis, and riparian reserves limit the availability of acres in the matrix for any type of silvicultural activity or fuel treatment.
• Current focus is on timber sales that involve thinning rather than GTR due to public scrutiny, which is reflected in appeals and litigation.
• When treatments within GTRs include trees with large diameters (more than 20”), more appeals and litigation are generated, thus increasing costs.
• Survey and manage protection buffers have affected approximately 30% of the project areas proposed. The majority of fuels treatments and timber management activities are excluded within protection buffers.

Finding: Management of the Adaptive Management Areas (AMAs) has been, to varying degrees, disappointing, complex, and lacking in the flexibility originally intended

There are two designated AMAs in northern California. Adaptive Management Areas were established to develop and test new management approaches to integrate and achieve ecological, economic, and other social and community objectives. Early attempts to try new management practices found it difficult to gain the concurrence of the Regional Ecosystem Office (REO); REO emphasized the need to adhere to the existing standards and guidelines. Units were discouraged from experimenting with modification of standards and guides by difficult approval processes, environmental controversy, production demands and funding/staffing limitations. There have been some successes, but they have been less dramatic than envisioned.

The degree of compliance with the purposes of the Adaptive Management Areas varies.

• To date management direction and expectations for AMAs have been unclear.
• The process for review and approval of new or different standards or prescriptions has been difficult and complex. Early attempts were made to try new management practices and gain the concurrence by the Regional Ecosystem Office (REO); REO stated the Forest needed to adhere to the existing standards and guidelines.
• There has been very limited support for the experimentation envisioned in the NWFP.
• There has not been a priority put on entering AMAs, in part, due to high cost of management within an AMA, perception that it would be too controversial and subject to strong opposition, and the standard of review by the regulatory agencies when listed species are involved is much higher.

The Goosenest AMA was established for the “development of ecosystem management approaches, including use of prescribed burning and other silvicultural techniques, for management of pine forests, including objectives related to forest health, production and maintenance of late-successional forest and riparian habitat and commercial timber production”.

• The forest was able to achieve commodity output (averaging 9 MMBF per year) on the AMA.
• Research has worked closely with AMA staff to meet objectives in the NWFP for reaching late seral forest condition on the east side.
• Land capability and timber industry infrastructure have made accomplishments simpler for this AMA.

The Hayfork AMA was established for the “development, testing, and application of forest management practices, including partial cutting, prescribed burning, and low impact approaches to forest harvest, which provide for a broad range of forest values, including commercial timber production and provision of late-successional and high quality riparian habitat”.

• Commodity outputs have not met expectations of the 17 dependent communities (70 MMBF of harvest was planned and 30 MMBF accomplished)
• The forest focused on the Forest Products Lab as research partner because of desire to have quick results and return.
• Community assistance funding has led to successful value-added incubator businesses. Twenty-three jobs have been created in the last two years.
• Other expectations of the 17 dependent communities within and around the Hayfork AMA have only been partially met.
  • Strong community partnerships have occurred with the Watershed Center, Resource Conservation District, Coordinated Resource Management Plan and Resource, Conservation &Development Council.
  • Demonstration projects for small diameter utilization have been shared throughout Northern California and Southern Oregon.

Finding: Budgets have been less and management costs have been higher than anticipated

Funding levels have been below what was needed to fully meet the intended output levels displayed in the Forest Plans. The four Forests received funding sufficient to produce 1.09 billion board feet (approximately 136 million board feet annually) and actually produced 905 million board feet (approximately 113 million board feet annually). Costs have been higher than planned.

• Financial and human resource costs of survey and manage requirements were not modeled in Forest Plans. They have proven to be financially expensive, and they have consumed a significant portion of available funds.
• Litigation, including the Pacific Coast Federation of Fishermen’s Association (Rothstein) and the Gifford Pinchot Task Force lawsuits has increased costs and the time to prepare projects. The national roadless area management policy, management recommendations for survey and manage species, and adjustments in the size of survey and manage protection buffers have also affected costs. The forests were unable to plan for these additional expenses when budgets were formulated and submitted.
• Competition for funds to meet different policy objectives affects outputs and acres treated. For example, as forests prioritize their limited fuels funds to meet National Fire Plan (NFP) objectives by placing treatments in the wildland urban interface (WUI), there is little available fuels funding left to focus on additional treatment options in LSRs. WUIs are often not within LSRs, thus the affect again is that less is available for fuel reduction options and treatments within LSRs.
• Treatments in LSRs are to achieve wildlife habitat and watershed objectives. These types of treatments are expensive. Wildlife and watershed funds are used for these treatments, and these fund levels have been inadequate to meet need. Forests are reluctant to spend timber dollars in LSRs because they do not contribute to Allowable Timber Sale Quantity (ASQ) goals.
• Costs to implement the NWFP are relatively high in monetary terms, as well as high in negative impacts to employee morale and productivity.
  • Unit costs are among the highest in region.
  • Primary Purpose budgeting is causing problems (e.g., inappropriate decisions).
• Appeals/litigation, consultation, NEPA process, and the survey and manage program are all very expensive.
• Short-term loss of economic offerings is reducing the capacity to make long-term land investments. In particular delays in project planning and preparation on salvage efforts reduce the value of the salvageable timber. The higher value that would have been realized without delays would have allowed for more complete treatments.
• · Special funding for NWFP implementation has been reduced and/or eliminated.

NWFP Processes

Finding: Survey and Manage Protocols Have Increased the Costs and Complexity of Implementation

Implementation of pre-disturbance surveys and management recommendations are expensive, time consuming and of unknown value in conserving the species.

• The costs associated with implementing pre-disturbance surveys ranges from $36 -$115 per acre depending on the number of species requiring survey.
• Survey protocols are time consuming to implement and survey windows are often less than several weeks in length due to inclement weather conditions.
  • Project delays are often due to survey windows being too short.
• Surveys require a high level of training and expertise to implement (including the identification of species.)
  • Accurate identification often relies on the use of laboratory skills to distinguish minute differences between taxa.
• Strategic surveys are more efficient in generating habitat associations and species life cycle needs than utilizing an approach focused on pre-disturbance survey information.
• The majority of project surveys occur within the matrix and do not allow for species distribution projections across other land allocations
• The management recommendations and protection buffer delineations are restrictive and limited options are available to line officers in making local decisions.

Finding: Watershed Analysis has frequently been expensive and time consuming. Its effect on implementation is not as originally envisioned under the NWFP

Watershed analysis (WA) “...is a procedure used to characterize the human, aquatic, riparian, and terrestrial features, conditions, processes, and interactions within a watershed”. WA was intended to provide an easy and inexpensive means to identify opportunities for protection and restoration or watershed values. WA was the means by which riparian reserve widths were to be adjusted to local environmental conditions. Experience has, however, been different than the intended analysis, greater cost and complexity have resulted, and riparian reserves, which were deliberately created with extra width and with the expectation that those widths would be reduced to reflect local environmental conditions, have not been adjusted.

• Each forest has a different percent of their WA’s completed.
• Treatments are limited in key watersheds if a WA is not completed. Conceptually, the WA provides useful information for preparing Biological Assessments, though the two are not always mutually compatible.
• There have been differences in expectations from the regulatory agencies on what is to be included in a WA. Also these agencies have interest in which watersheds are selected for analysis, which has complicated the completion of WAs, whose completion schedule was determined in prior years by each national forest.
• Riparian reserve widths have, by and large, not been reduced as was intended under the NWFP. There are, however, some silvicultural treatments, including thinning and fuels treatments, occurring within riparian reserves.
  • Interdisciplinary teams have found it difficult to meet the standards of analysis that would support adjusting Riparian Reserve widths. For example, one of the functions of riparian reserves described in NWFP Appendix B6 is to serve as connectivity corridors for terrestrial animals and plants, but specialists do not have this sufficient connectivity information to support adjustment of reserve widths.
• Some Forests are using the WA to accomplish other analysis needs, and have added items to be considered in the document.
• There are significant costs and discrepancies between units on how watershed analysis (WA) is being applied today.
  • WA costs range from $50,000 to $270,000 on individual units.
  • Funding for conducting WAs has decreased.
• The Federal Guide (”Ecosystem Analysis at the Watershed Scale – Federal Guide for Watershed Analysis”) contains 6 steps, one of which is Recommendations. This can cause concerns in NEPA documents as the recommendations lack the line officer involvement and endorsement that would make them official policy and yet the recommendations can be interpreted as if they represented official direction.
• Line officer expectations for WA teams are not always clearly articulated.

Finding: Consultation with regulatory agencies can be complex and expensive. Streamlining has helped speed the process

Biological Assessments, which are the basis for consultation between the land management and regulatory agencies, are more complex and technically demanding than they have been in the past. Level 1 teams have frequently been successful in designing projects that will meet the expectations of the parties to the consultation, though projects have not reflected the original intent of the NWFP to manage the matrix through GTR. For various reasons, the Forest Service feels compelled to design projects to achieve Not Likely to Adversely Affect determinations. There has been a strong tendency to focus on short-run adverse environmental effects of a project, rather than recognize longer-run environmental benefits that that would justify such short-run effects.

• It takes a long time to get agreement on a Biological Assessment (BA), which adds additional costs to the effort. The existing process involves a high level of coordination, effective communication, and the determination definitions are not always well defined and agreed upon by both parties. Elevations of disagreements during consultation are rarely occurring.
  • 517 consultations with NOAA-Fisheries were accomplished and 4 were elevated.
  • 251 consultations were accomplished 251 with US Fish and Wildlife Service and 9 were elevated.
  • The goal of elevation is to speed up and improve the consultation process where substantial disagreement exists; elevations for quality control may help improve this process.
• As directed in the “Streamlining Consultation Procedures Under Section 7 of the Endangered Species Act”, elevation is expected to occur, and should not be viewed as failure. However, elevation to level II is not always necessary because we have such early involvement with the regulatory agencies and early agreement on terms.
• In complying with litigation requirements, consultation documents have become very large and very expensive.
  • Litigation has affected both the regulatory and land management agencies involved in consultation. Specifically, incomplete and often changing (due to litigation, not being clear on what we want from the begining, changes caused by consultation process or Interdisciplinary Team field analysis, etc.) proposed actions cause delay.
• There is uncertainty over the application of new information for listed species (e.g., habitat and occupancy for northern spotted owl and new analytic framework for anadromous fish).
• Line officer expectations for Level 1 teams are not always clearly articulated. Roles of line and staff are sometimes not understood.
• Outcomes of consultation often fail to consider long-term benefits and focus more on short-term effects. Much of the concern about short-term effects is driven by litigation (this is more true with NOAA Fisheries due to Rothstein) and it does alter the objectives of the proposed project.
  • A fundamental difference in the approach to consultation is identified with NOAA Fisheries. Their primary focus is more on why we are proposing the project rather than what we are proposing.
  • Some interpretations of the ESA prevent using long-term benefits to modify determinations and terms and conditions derived from short-term risks and losses.

Finding: Oversight, litigation and higher-level add to the complexity and cost

Considerable oversight, litigation and higher-level concurrences and approvals have characterized the NWFP since it was adopted. Efforts have been made to reduce the burden and delay of oversight and higher-level involvement. Forest managers observe that they devote considerable attention and effort to processes seeking approvals and concurrences, and should instead be given authority to secure the results expected from implementation of the NWFP, with monitoring of their decisions to ensure accountability.

• The Region Five Regional Office has not been sufficiently engaged with field managers to help them work towards solutions that are barriers to successful implementation.
• The Regional office needs to be supportive of shifting these priorities through funding and BFES (Budget Formulation and Execution System) process. Need to recognize there is no new money to apply to this need.
• The standard for adequate analysis under NEPA is continually being raised due to appeals and litigation.
• The Rothstein litigation has impacted our ability to conduct GTR prescriptions due to lack of Biological Opinions being issued by NOAA Fisheries.

USDA Forest Service - Northwest Forest Plan Review
Last Modified: Tuesday, 05 August 2003 at 13:58:24 EDT