The “Single Use Sustained Yield Act”: A Thoughtful Proposal
A proposal by forester Barry Wynsma concerning the Single Use Sustained Yield Act (SUSY) as a means of improving the management of our National Forests.
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The “Single Use Sustained Yield Act”: A thoughtful proposal for improving the management of our National Forests
By Barry Wynsma, U.S. Forest Service Retiree Member, National Association of Forest Service Retirees Bonners Ferry, Idaho
Editor’s note: Mr. Wynsma’s essay appears here as the latest installment in our ongoing series of articles concerning collaboration as a means for resolving public disagreements relative to the management for federally owned National Forests. Your questions or comments are most welcome at email@example.com.
Are you tired of the continuing lack of active forestry treatments in our at-risk National Forests, tired of attending collaborative meetings that seem to be having - at best - anemic success in treating millions of acres of overstocked and dying timber stands within our National Forests, tired of legal gridlock created by environmental organizations that don’t participate in collaborative efforts and tired with the media putting out misinformation and inciting controversy over various proposals for improved management of our public forests?
I’m tired too.
I come at collaboration from two perspectives – that of a participant in a local, northern Idaho collaborative, and that of an observer of other collaboratives across the West, including Arizona’s much-touted Four Forests Initiative (nicknamed 4FRI).
Collaboratives have met with mixed success, which gives reason for hope. But the truth is that very few private citizens have the time or patience to participate in a process that can take years to produce measurable success. This is the main reason participation in most collaborative groups is limited to federal, state and local government personnel who are required to attend and forest products industry and environmental organizations that are all paid to attend these meetings. Thus, John Q. Citizen, who isn’t paid to participate and doesn’t have the time anyway, is underrepresented in collaborative negotiations that accompany significant project planning.
I believe there is a better way to free the shackles of the Forest Service foresters and allow them to get busy managing a portion of our National Forests. I’d like to propose that Congress enact a new environmental law titled the “Single Use Sustained Yield” Act. “SUSY,” for short.
“SUSY” would designate 25 per cent of every National Forest for sustained yield timber management. These areas would be exempt from the project level NEPA process, and exempt from Endangered Species Act (ESA) and National Forest Management Act (NFMA) sensitive species considerations including critical habitat designations. The lands would be managed solely for sustained yield timber production, meaning harvest would never exceed annual growth.
Let me be clear, this is not a proposal to “log without laws”. These timber management areas would be required to adhere to Forest Plan direction for suitable vegetation management areas, minus the exemptions under the proposed SUSY Act, and would also be required to follow state best management guidelines to protect watersheds, soils and other resources.
The mechanics here would be pretty simple. On the designated 25 percent, Forest Service foresters could move forward without delay for site-specific analysis, site specific public comments and objection periods and potential lawsuit delays on NEPA/NFMA/ESA issues. They would write site specific silvicultural prescriptions and logging plans, send out the sale preparation crews and offer the timber for sale to the highest bidder on a consistent level of acreage and volume of timber in perpetuity.
Here is an example how this could work on the Idaho Panhandle National Forest, on which I worked for about 23 years and am most familiar with: The recently released revised Forest Plan for the IPNF (January 20151) reports that the Forest spans about 2.5 million acres. Of this land base, the Forest Service designated 38 percent – about 950,000 acres – as “suitable” for timber production. SUSY would set aside 25 percent – some 625,000 acres - for timber production on, say, a 70-year rotation. This means that once small patches of these designated acres are harvested and replanted, they would not be harvested again for another 70 years, though they would probably be pre-commercially thinned when they are about 15 years old and commercially thinned at age 35. Thinning promotes faster growth.
Assuming a level growth-harvest and a 70-year rotation, the Idaho Panhandle NF could harvest about 8,928 acres per year. How much volume would such a model produce? Assuming a very realistic 15,000 board feet of timber per acre, about 134 million board feet per year…with no delays for NEPA, NFMA or ESA procedures, including objections and lawsuits.
For comparison, the 2015 IPNF Forest Plan has an allowable sale quantity (ASQ) of 120 million board feet. That number has been reduced to an estimated 40-50 million board feet per year because of inadequate federal funding. In other words, Congress hasn’t allocated sufficient funding to reach the 120 million board foot target. Because SUSY is more efficient and less expensive, I suspect it would free up enough money to allow the IPNF staff to reach its 120 million board foot target.
The resulting steady and predictable flow of timber would have a very positive impact on financially struggling county governments and timber community economies. Resulting stability would also spur new investments in wood processing facilities, allowing for more efficient and complete utilization of wood fiber removed from the Idaho Panhandle National Forests. A win-win all around, I’d say.
Based on my 30-plus years with the Forest Service, I’ll hazard a guess that SUSY could save billions of taxpayer dollars simply by eliminating the expense of conducting project specific environmental analysis and the included public involvement/objections/lawsuit process. And remember that the areas currently designated as suitable timber stands have already gone through extensive public comment and the NEPA process with the issuance of the new IPNF Forest Plan.
If Congress were to ratify SUSY, it would quickly silence those who continue to suggest that the only solution to the economic and environmental crisis rests in states or counties taking ownership of federal forests. I understand the frustration many are feeling, but I think the proposals are unrealistic and unlikely to gain much public traction.
Additional benefits to forest-dependent communities include:
SUSY eliminates the uncertainty of having the Secure Rural Schools (i.e. Craig-Wyden) subsidies renewed by Congress by reverting to the 25 per cent payments to counties from timber sale receipts. Current SRS payments expired in September 2014, and the 25 per cent fund payment for timber sales, which dates from 1908, is back in play.Boundary County, Idaho county commissioner, Dan Dinning, reports that the SRS 2014 payment to our county was $1.453 million. With SRS gone, the estimated 2015 IPNF 25 percent payment to Boundary County will be about $220,000. This estimate is based on the volume of IPNF timber sold within the county. Thus, the loss of SRS payments will have major negative impact on our county and on every county in the West that has been the recipient of SRS payments.One could rightly ask how Boundary County can make up for this loss given the fact that more than 70 percent of land within our county is federally owned timberland that cannot be taxed by local governments in the same way private lands are taxed.
SUSY would alleviate some of the financial stress rural western counties are feeling by producing a steady and predictable flow of 25 per cent funding from harvest. On the IPNF, about 130 million board feet of timber could be sold annually, more than twice the 40-50 million board feet sold now because of the IPNF lacks sufficient funding to meet their annual timber target. Bear in mind that additional timber sales could also be occurring from the remaining suitable timberlands that would be subject to site specific NEPA/NFMA/ESA etc. procedures.
- SUSY would provide more certainty for loggers to be able to secure bank loans to purchase and maintain the equipment and hire the people that would be required to ramp up their production capabilities to accomplish a higher harvest level. SUSY would also likely help prevent the loss of existing sawmills and other forest products businesses that are currently on the verge of having to close down due to lack of raw materials.
- Within the wildland urban interface areas surrounding communities, currently overstocked, dead and dying stands of timber in dire need of thinning and fuels reduction work would be accomplished in a much shorter time frame than the current situation near most of these communities. Continuing long-term maintenance of these same areas would also be a certainty.
Is this a radical idea or just common sense? Maybe the SUSY Act is a radical idea BECAUSE it’s a common sense solution. For most Forest Service employees who have been working for the agency for many years, I’m sure it would be a shock to their systems to be given a piece of ground and told to just go conduct sustainable forest management on it without having to conduct analysis for several years and struggle through the objection and litigation process.
Once recovered from their shock, I’m sure most would revel in the opportunity to show the public how well they can manage our forests without being micromanaged. This would also be a huge morale boost for agency personnel, and low employee morale is still a major problem for Forest Service leadership.
Consider this, ever since the National Environmental Policy Act was passed in 1970, site-specific environmental analysis and public involvement has been required before timber harvests and many other activities could be implemented. So we are now at a point approximately 45 years later where the Forest Service is required to analyze timber stands that have already been analyzed at least once before if not more and that have had silvicultural prescriptions implemented that prescribe treatments for an entire rotation period of approximately 80 to 120 years, depending on habitat types and growing potential for specific timber stands. NEPA currently requires even scheduled pre-commercial thinning of plantations that are the result of previous regeneration harvests approximately 15 years ago to undergo additional analysis before they can be thinned today. How many times should the same piece of ground be subjected to analysis and public comment???
I think it is crazy and a huge waste of time and taxpayer money to continue to analyze what’s already been analyzed at least once since NEPA procedures have been in place. If a timber stand has had previous NEPA analysis conducted and a silvicultural prescription implemented for a rotation period, it should not be required to have any additional analysis done during that period. It is these types of areas on the National Forests that should be included under the SUSY Act.
But would passing a SUSY Act really be all that radical?
I don’t think so.
An example of where site specific NEPA/NFMA/ESA procedures aren’t required is for “let burn” wildfire decisions within Wilderness, Roadless and other back country areas. These areas are frequently and consciously allowed to burn when wildfires are ignited within their boundaries. The decisions to let these wildfires burn are often for “resource management objectives” (sometimes for fire fighter safety) and do not undergo prior analysis or public comment and appeal procedures.
These “let burn” decisions do not address any of the major effects on threatened, endangered and sensitive species or their habitat, nor on other natural resources such as soils, watersheds, other wildlife and fisheries, or on air sheds. In my opinion, these massive fires have more impacts on the environment than do sustainable forest practices. I’m not saying that is good or bad, I’m just saying that SUSY would not set a precedent for permitting certain activities to take place within National Forests without having to adhere to NEPA/NFMA/ESA policies and procedures.
To identify areas for inclusion in the 25 per cent land base, I’d suggest we start with areas within communities’ wildland urban interface areas. Within these areas, include existing plantations and other previously harvested units. If the 25% level can’t be reached by including just those areas, then work out farther but within those areas the Forest Service has already designated in their forest plans as “suitable” for timber harvests.
This proposal is just in concept stage and fine details need to be fleshed out. The actual percentage of ground designated for management under SUSY could be adjusted up or down. But for SUSY to work efficiently and effectively, the main components of the designated 25 percent acres must be exempt from site specific NEPA procedures and as well as ESA and NFMA sensitive species considerations.
If you like this proposal and want to help make it a reality, I suggest you forward this article to your congressional representatives, state and local government leaders and ask them to pursue this legislation. As they say, the squeaky wheel gets the grease!
If you have any suggestions for improving on my proposal – or if you have an alternate proposal you’d like to toss in the hopper – please forward your thoughts to firstname.lastname@example.org.
1 2015 IPNF Forest Plan http://www.fs.usda.gov/detail/ipnf/landmanagement/planning/?cid=stelprdb5436518
Another point I’d like to make is that all the acreage designated under a SUSY Act would likely include areas that have already been under management and have had investments made for planting, pre-commercial thinning and other intermediate harvest treatments. These designated areas would also likely be within community wildland urban interface areas.