Q&A_Attachment_A_Sale_Prep_Report_Final_2013.pdf

[Task Force Report: Sale Prep and Cruising Costs] November 13, 2013

Task Force Report: Issues and concerns on costs of sale preparation and cruising in the U.S. Forest Service

Task Force: Dave Cawrse (facilitator), Rich Aubuchon, Ken Cormier, Carl Maass – Washington

Office-Detached (WOD) Forest Management Service Center; Mike McVeigh – Northern Region

(R1); Kurt Stagner – Rocky Mountain Region (R2); Karen Jones – Southwestern Region (R3);

Earl Kerns, Julia Richardson – Intermountain Region (R4); Craig Bodenhausen – Pacific

Southwest Region (R5); Jeff Penman – Pacific Northwest Region (R6); Linda Brett – Southern

Region (R8); Randy Jost – Eastern Region (R9); and Craig Anderson, Mark Kruse – Alaska

Region (R10).

EXECUTIVE SUMMARY

For the past several years, issues and concerns have been raised about the costs of sale preparation and cruising. These were discussed in a conference call with regional Forest

Management directors in February 2013. The concerns centered on (a) conflicts in current direction for designating and accounting for timber that result in unnecessarily higher costs during this time of low product value and (b) the need to accelerate the pace and scale of restoration. A task force was designated to address these issues and develop recommendations for WO Forest Management directors and the regional Forest Management directors.

Below is a summary of Issues, Findings, and Recommendations.

Summary of Issues

Ten issues were addressed by the task force. They are grouped into three areas: planning;

accountability and sale preparation costs; and training and technology. Issues are further described below.

Planning

1) NEPA costs.

2) Timber sale mitigation costs and complex silvicultural prescriptions.

3) Salvaging timber after a fire.

Accountability and Sale Preparation Costs

4) Designation by description (DxD) and designation by prescription (DxP) opportunities.

5) Weight scaling and load count scaling for low-value material.

6) Tracer paint and tree marking.

7) Cruising sampling error requirements.

Training and Technology

8) Sale administration certification requirements.

9) Cruising certification maintenance.

10) Efficient use of resources and technology.

Summary of Findings

Line officers often lack training and experience for making critical choices regarding sale development and implementation that may result in higher costs. Basic training in sale development, preparation, and administration is needed for line officers, just as they now get specialized training in wilderness management, special uses, and planning. Many, if not all, of the issues in planning, silviculture, and sale design could be improved by better program management and line officer involvement in the program.

Restoration prescriptions are proving to be exceedingly complex, even if they involve low-value material. Many concerns came up about complicated prescriptions and about mitigation requirements that reduce a logger’s flexibility in harvesting. These areas may not be emphasized enough in the National Advanced Silviculture Program—the practical on-the-ground implementation of a prescription. Overlapping mitigation needs to be critically evaluated to ensure desired conditions are met, appropriate protection of resources is applied, and the prescription can be reasonably implemented.

Complicated prescriptions resulting in complex timber designations seriously reduce the effectiveness of DxD and DxP designation tools. These tools cannot be used with any degree of reliability when a complex matrix of decisions has to be made on each tree. Costs are shifted from prep to sale administration and the purchaser, resulting in less revenue and higher costs all around. A poorly marked sale, large errors in estimates of tree measurement sales, or use of DxD and DxP will move costs to the sale administration side, where staffing levels are lower and work must be performed to meet the purchaser’s schedule, compared to planning and preparation, which has greater flexibility in staffing and timing. Achieving desired conditions is more important than just removal of a low value product; what is left behind in the landscape is just as or more important than what is removed. Managers must emphasize the value of achieving the desired condition over the value of the products removed.

More clarification is needed in the use of weight and load count scaling. For DxD and DxP, clarification is needed regarding the legal basis on the use of these methods. Policy needs to be established either through a policy review committee or through staff review.

Forest Service paint costs are related to health concerns associated with the use of past formulations and the requirement to use tracer paint—two elements the agency should not or cannot change. Tracer paint applied by the Forest Service or under Forest Service supervision is the best way for a contract administrator to know if a tree should or should not be cut.

Salvage sales following large disturbance events can be costly to implement and may not generate the needed funds to do much more than repay the salvage sale fund and provide some level of funding for essential reforestation. Rehabilitation and restoration of disturbed areas are much more inclusive goals that may not be met by a “salvage” strategy. The Southern Region has had some success with using the stewardship authority to achieve broader restoration goals for disturbed areas. The authority has the flexibility to reduce sale preparation costs and contains options for using receipts from other stewardship sales, partnerships, and service contracts to achieve restoration goals for disturbed areas.

Sampling standards were changed in June 2012. A poor estimate of volume in a tree measurement sale could result in a substantial financial hardship, particularly for a small purchaser, because payment is based on the Government’s estimate of volume. Even though the

Forest Service does not guarantee volume estimates and purchasers certify that their bids are based on their own estimate of volume, the Forest Service is required to appraise for fair market value; the only way to do that is with a reliable volume estimates. Standards based on value are in place to ensure that the Government receives full value for the products sold. Use of the new standards for low-value material provides substantial flexibility in the intensity of sampling:

from no required sampling error for small sales, to a high level of reliability for high value or large volume of products. The measurements staff is also exploring methods to associate sampling errors with population values to provide better checks on cruise designs. Accurate volume and area estimates are still crucial in sale implementation even though these accountability standards were developed in times of harvesting large valuable trees. There can still be high costs to the purchaser in harvesting this material, or in other cases, the Forest

Service is paying high amounts for treatment of areas. Not all regions are working with exclusively low-value wood products; consequently a balanced approach to sale preparation and accountability is necessary to protect the interests of the United States and the purchasers.

Forest Service sale administration certification standards and cruiser certification standards were developed because of concerns about accountability in the past for both the product that was removed and the NEPA decision that was made. These concerns are as relevant today as they were 35 years ago when standards were first put in place. For cruiser certification, relaxing certification standards are not recommended here because this may lead to more disputes and claims over contract volumes. Money saved by reducing cruising standards may be overshadowed by litigation costs and damage assessments awarded volume disputes.

The Forest Service needs to build up a pipeline of sale administrator skills. With the increased use of stewardship contracting, the demand for certified timber sale administrators will only grow.

With regard to using the latest technology, the Forest Service lags behind private industry:

virtually 100 percent of industrial cruising is done with handheld data recorders, yet only an estimated 50 percent of Forest Service cruising is done using similar devices. Use of older cruising methods results in a loss of efficiency and accuracy.

Summary of Recommendations

Planning

1) Basic training in sale development, preparation, and administration is needed for line officers, just as they now get specialized training in wilderness management, special uses, rangeland management, and planning. Line officers often lack training and experience for making critical choices regarding sale development and implementation that may result in higher costs. Additionally, implemented projects need to match NEPA decisions; sometimes acres treated or volume harvested is substantially less than what was disclosed in the NEPA decision.

2) Emphasize completing a full-blown Gate 1. This is an important focal point and should be a basis for the NEPA analysis. Gate 1 is a task that could be contracted. The Alaska Region is doing this and can use the feasibility analysis from the contractor as a basis for NEPA. This can save time in the long run by having a better developed proposed action and using the analysis as part of the NEPA documentation.

3) Forest Management needs to be involved at the forest and district levels in the Quality

Assurance Oversight framework that is be part of forest plan revision. This would provide the quickest path to finding efficiencies in NEPA.

4) Forest Management needs to be involved with the NEPA Line Officer Focus Group. This group offers some good opportunities to improve NEPA.

5) Forest Management should support an accurate downscaling of roadless boundaries before an analysis is started. Roadless boundaries have been a problem for planning teams— there have been many problems figuring out where that line is, with the end result of

“padding” the areas proposed for harvest.

6) Forest Management should work with Ecosystem Management Coordination (EMC) in developing an adaptive management approach for forest disturbances. EMC has been working on an adaptive management approach for events such as fire, hurricanes, and tornadoes. For example, a decision on salvage harvesting would be written stating that when these disturbances occur, forest managers would then be able to implement appropriate actions.

7) A consistent approach to geospatial coverages in the planning process is needed. Planning teams lose time when GIS coverages are not consistent, boundaries vary, and lines are not coincident.

8) Evaluate natural resource sampling methodologies, perhaps through a peer review by a private mensurational organization.

9) Marking guides should focus on three or four of the most important factors. Any more than three or four factors tend to be superfluous and generally ignored.

10) NEPA decisions need to be simplified so that their implementation is simple. There is a need to consider the impacts of design criteria and constraints of vegetation management on pre- and post-sale activities. Collaboration efforts and the NEPA preferred alternative (pre-decisional) need to be cross checked so that the desired conditions are implementable on the ground.

11) Projects need to be designed to meet restoration objectives, be implementable, and be cost effective. Restoration is also a business endeavor.

12) Wildlife design criteria need to consider safety, OSHA requirements, and impacts to logging systems. When snags are felled and there are green tree substitutions, there is an impact on sale administrator time and timber sale economics.

13) Better accountability for targets may raise awareness of the cost and consequences of complex NEPA documents and associated decisions. Accountability is a concern in meeting timber targets, along with knowledge of timber sale development and implementation.

14) Foresters are needed on Burned Area Emergency Response (BAER) teams. A forester has a working knowledge of most of the other disciplines and is best suited to comment on protecting the forested resource and influence the feasibility and cost effectiveness of BAER projects.

15) Additional training may be needed in implementing existing direction on assessing post-fire conditions and developing a program of work for restoration and recovery. Salvage and reforestation cannot be funded with a BAER appropriation. Tools such as LaSER and

RAVG provide a good approach for salvage and restoration for large-scale disturbances but appear to be not widely known or used.

16) Encourage the use of stewardship authority for salvage sales because of added flexibility in funding, timber marking, and implementing additional options in fire recovery and rehabilitation.

Accountability and Sale Preparation Costs

17) Forest Management needs to clarify the legal basis for and establish standards in the following areas:

Standardize the application of DxD and DxP.

Simplify the instructions for provision fill-ins.

Develop regional silvicultural guidelines for the application of these provisions;

regions have been doing “policy by letter,” which is a poor way to do policy.

Determine whether the use of non-tracer paint by contractors and purchasers as required in DxP provisions is in line with direction for use of tracer paint.

Clarify FSH direction from the National Forest Management Act (NFMA) on the use of purchaser marking and contract marking with regard to Forest Service supervision of designation on non-stewardship timber sales.

Clarify the reasons for requiring or allowing contractor marking in stewardship contracts. Establish criteria for species and product grouping to simplify scaling requirements and increase accountability. (Note: scaling is required on DxP sales.)

18) Units using DxD and DxP must commit to providing the increased sale administration staffing required by these methods. Also recognize that the increased workload occurs whenever the purchaser is operating, not just when it is convenient for the Forest Service to schedule additional help.

19) Modify FSM 2440, Ch. 2442.03, to allow regions more flexibility in the use of total weight and load count scaling. Recommended wording is: “Thinning, low-value material, and salvage sales may be sold as scaled sales if cruising to tree measurement sampling error standards is precluded by on-the-ground conditions, or if it is not cost-effective to cruise to tree measurement standards. Document this decision in the cruise plan.”

20) Develop national direction that outlines applicable situations where total weight and load count scaling could be used. Clarify direction related to mixing species, load configurations, weighted prices, multiple products, and procedures for determining load count volume calculations.

21) Current tracer paint requirements are reasonable and are supported by the field. Paint costs are related to health concerns in the use of past formulations and the requirement to use tracer paint. Tracer paint applied by the Forest Service or under Forest Service supervision is the best way for a contract administrator to know if a tree should or should not be cut.

22) Provide training to sale prep personnel in currently approved alternatives to paint designation. Encourage field personnel to take full advantage of designations without marking, including the use of DxD; DxP; clearcut, overstory, and understory removal alternatives to paint designation; and appropriate use of natural or constructed boundaries.

23) Recommend the Paint Committee consider dropping citrus-based paint from the tracer paint formulations. Based upon its limited use in the field, citrus-based paint may not be necessary and could result in some savings.

24) Recommend the Paint Committee develop a longer lasting paint and a brighter orange color (neon or fluorescent color).

25) Exercise the flexibility that exists in the current sampling standards that were recently revised in 2012 and wait until FY 2015 to revisit whether sample error standards are still a concern.

26) Develop an evaluation method in the cruise design software that displays the strength of sampling relative to each value group included in a cruise. Include in the Cruise Design

Program a report to check sampling errors by population values during the cruise design phase. This report can also be used during the office check of the cruise design.

Training and Technology

27) Develop a coherent strategy for comprehensive sale prep training. There is no comprehensive training schedule described in FSM/FSH for sale preparation personnel. This results, in some cases, inefficient use of resources or incomplete results on the ground, or both.

28) There is a need to retool training and certification for the administration of stewardship contracts. Stewardship contracts blend two different contract authorities and training, and certification has not kept pace. To maintain these standards and make them relevant into the foreseeable future, standards need to recognize the wide array of contract tools available and in use to accomplish management objectives.

29) Timber sale administration training could be adapted to certification of contracting officer representatives (CORs) specifically for product removal stewardship contracts; likewise, timber sale administration personnel should be cross-trained and certified as CORs for

Acquisition Management (AQM) stewardship. Certification for AQM COs and CORs is largely aimed at procedural, fiscal, and legal aspects of the contracts. There are few if any technical certification requirements based on on-the-ground performance. There is a need for on-the-ground, performance-based certification.

30) Emphasis should be placed by regional directors to fund and administer certification programs for all types of contract administration, to ensure a pool of trained individuals capable of performing up to standard. New techniques require a higher level of competence in sale administration and timber sale program knowledge. Product value and removal is not the only thing at stake; sales must be designed and contracts implemented (administered) properly to achieve the desired conditions addressed in the NEPA decision.

31) Financial management needs to be part of foundational training requirements for timber sale administrators, as well as for all stewardship contract administration personnel.

Establish standard financial management training modules and performance requirements for everybody involved with timber sales and stewardship contracts.

32) Use a strike team format to meet the needs of the timber sale preparation needs in at least one more region, possibly in the Rocky Mountain, Southwestern, or Intermountain Region.

Pursue financial authorities so dollars could be obligated in one fiscal year and carried over to the next fiscal year for use by these strike teams.

33) Create multi-grade positions with specific requirements for grade increases. An interregional group should work on these position descriptions rather than ad hoc regional approaches.

34) Create Aglearn training specific to measurements to help meet the 4-year training requirement.

35) Create a “check cruiser assistant” certification to help overloaded check cruisers while providing training opportunities and a career path to the check cruiser position.

36) Encourage use of data recorders ($2,000–$2,500), lasers ($700), and hypsometers ($1,700) in the field. Ideas include taking money off the top to modernize equipment or earmarking carryover dollars for equipment modernization.

37) Continue developing new methods for efficient estimation of biomass and small-diameter material, such as two-stage sampling and remote sensing imagery to estimate biomass

(2PRS). Also included are:

Unmanned aerial vehicles (UAVs) to collect inexpensive imagery (on hold–need to update Forest Service policy), and

Use of existing color infra-red photography in many areas.

38) Continue training people on use of new methods. Most of the new methods require a data recorder.

39) Continue to develop virtual classrooms for training in new technologies and new procedures to disseminate the information to the field.

40) Continue to monitor new technology and make the information available to the field as appropriate. San Dimas Technology Development Center is currently testing some of the technology, including the following:

Timber GuideTM—A fully integrated system providing data transfer between equipment in a timber harvesting operation to locate boundaries using a dual-purpose

GPS guidance – GIS data management system.

LiDAR cameras—useful for estimating biomass.

Some Overall Recommendations

41) Ensure program reviews are being accomplished in a timely manner. National, regional, and forest reviews of strategy and program implementation, and systematic reviews of support functions ensure the effectiveness and efficiency of forest management programs.

42) Share success stories and innovative ideas in forest restoration and management to improve efficiency in forest management. Many ideas exist to share success stories

(newsletters, on-line forums, eForester, Twitter) but care must be taken to not overload a field-oriented workforce.

43) Renew the Forest Products Rewards Program to recognize individual or team workforce accomplishments in forest management.

ISSUES, DISCUSSIONS, AND RECOMMENDATIONS

The issues are grouped into three main areas: 1) Planning; 2) Accountability and Sale

Preparation Costs; and 3) Training and Technology.

Planning

Planning includes issues around NEPA costs; timber sale mitigation and complex silvicultural prescriptions; and salvaging timber after a fire.

NEPA Costs

Issue: NEPA (Gate 2 costs) is the predominant cost in preparing timber sales. How can NEPA costs be reduced? In some cases NEPA runs $125 per acre; layout and marking are less than $15 per acre. Having and maintaining NEPA shelf stock is important to meet sustained flow of products. Additionally, implemented projects need to match NEPA decisions; sometimes acres treated or volume harvested is substantially less than what was disclosed in the NEPA decision.

Discussion

There have been many improvements over the years.

NEPA training. The old 1900-1 Plan to Project training has been retired because of adjustments in NEPA regulations and high cost. New courses include Introduction to NEPA; a team leader course; and online modules that include how to work collaboratively.

Digital approaches to NEPA. The EMC group did a big-picture look at streamlining NEPA about 10 years ago. This led to PALS (Project, Appeals, and Litigation System)—a Web-based data entry and reporting tool that captures key planning and decision-making documents.

National forests are now required to provide input into the system, which is used for reporting, data requests, Schedules of Proposed Actions (SOPA), and environmental documents. PALS has saved a lot of time and money through automatic publishing and report generation. For example, CEQ reports on cooperating agencies are now done in a matter of minutes. Content analysis is shorter because the public can comment online and the interdisciplinary team can work online by using the Content Analysis Response Application (CARA). The public can self-subscribe or unsubscribe to any project. All the documents—including specialists’ reports and EAs—are entered in PALS. If you want a document viewed by the public, just click a button and PALS makes it into a pdf and posts it on the Forest Service Internet Web site. This will be a standard approach. Project records and preparation of litigation records have been shortened. These improvements were done with field input.

New (2008) NEPA regs and directives. Put them in regulations. Should include items that put sideboards on processes. Should also be able to update regs and directives without needing to go back to CEQ. For example, minimum requirements for an EA could have a learning group that looks at focused EAs. Learn how people are doing this and pass it on. Regs are similar to the

Department of the Interior’s.

Line Officer Focus Group. This group was recently initiated to address: 1) program management

(strategic approaches to small NEPA projects, for example); 2) line officer leadership (core competencies); and a line officer tool box (standardized approaches and protocols). This group will have some deliverables by the end of summer 2013.

Quality assurance oversight framework. All units will be required to have this framework in place. NEPA oversight and quality assurance framework elements include:

1. Oversight Assessment

a. Assesses current NEPA capacity and evaluates program strengths and weaknesses.

b. Identifies management concerns.

2. Quality Assurance Plan

a. Provides compliance oversight.

b. Corrects problems identified in the oversight assessment.

c. Continually helps to improve NEPA processes over time.

Performance indicators and measures have been developed as a separate tool to assist units and programs at all levels and branches of the agency in assessing their NEPA program capacity, project management and efficiencies, document quality, legal compliance, and oversight responsibilities.

New approaches to writing environmental assessments (EAs) and environmental impact statements (EISs). A learning group has been implemented around how to put together an EIS when working with a collaboration group. Ideas include reducing the overall size of an EIS by putting draft material and reports into the project record but not into the EIS.

An adaptive management approach for disturbances. Folks are working on an adaptive management approach for events such as fire, hurricanes, and tornadoes. A decision would be written stating that when these conditions occur, appropriate actions could be implemented— basically writing the decision ahead of time. Blowdown after a timber sale is another example; it should be included in the original decision because it is likely an expected effect of timber sale harvesting.

Alaska Region’s NEPA Continuous Improvement Project. The Alaska Region is tracking the due dates of every project output and documenting reasons for delays. In general, the main reasons projects are delayed are internal ones, not external ones such as appeals or litigation. Although external reasons do cause delays, they are mainly related to controversial national-level items such as the roadless rule. Appeals and litigation occur infrequently (every several years or so) but when they do occur they cause lengthy delays (the latest roadless exemption removed set us back

1 year).

Older approaches. In 2007 a NEPA feasibility study was done that tracked all NEPA-related costs for the Forest Service. The intent was to see if the work could be contracted. The Forest

Service first had to do an estimate of the cost incurred by the agency, which required a breakdown of those costs. Business Genetics conducted the analysis of processes and costs, which is something that Congress frequently requests as they encourage us to reduce costs. The estimate in 2007 was about $365 million to do NEPA each year. There is a high interest in doing this kind of analysis again, and there was a recent request on the Hill to look into these costs.

The Administration launched the Healthy Forests Initiative (HFI) in 2002 to reduce barriers to the timely removal of hazardous fuel. Sixteen months later, Congress passed the Healthy Forests http://www.fs.fed.us/im/directives/fsh/1909.15/wo_1909.15_70.doc

Restoration Act (HFRA) to reduce delays and remove statutory barriers for projects that reduce hazardous fuel and improve forest health and vigor. Other provisions of the HFRA are designed to address forest and rangeland health on private lands. The HFI expedites administrative procedures for hazardous-fuel reduction and ecosystem-restoration projects on Federal land. The administrative actions undertaken through the HFI included new categorical exclusion categories that allow certain fuel-treatment projects (such as mechanical thinning and prescribed fires) and rehabilitation projects after a fire (such as reseeding and tree planting) to proceed in full compliance with NEPA, but without lengthy environmental and sociological documentation.

Note: the Healthy Forests fuel reduction categorical exclusion provision is enjoined. These categorical exclusions require agencies to identify projects through a public process undertaken in collaboration with State and local governments, Tribes, landowners, and other interested persons and community-based groups.

The U.S. Department of Agriculture also amended the rules for project appeals to hasten the review of forest health projects. Early and meaningful public participation in the decision making process benefits communities and makes the appeals process less cumbersome. Early public participation will result in timely project decisions and allow faster implementation.

Given the complexity of NEPA and timber sale planning, line officers often lack training and experience for making critical choices regarding sale development and implementation that may result in higher costs. There is a distinction between NEPA and timber sale planning—they are related but not the same. NEPA is environmental disclosure, while timber sale planning is moving a landscape from existing condition to a desired condition, as described in the timber sale Gate process. Line officers are required to sign off on each gate, with Gate 1 being the feasibility analysis. Some line officers are not aware of the Gate 1 process and there are instances where sale prep staff has never actually done one. Getting line officers engaged in the process is very important. Rangers need to be aware of their decision space and stay involved; they also need to decide how much analysis is required to make an informed decision, in order to keep costs down.

Region 10 made a business decision to contract Gate 1 feasibility analysis to ensure they do not have a catastrophic failed project or planning cycle. Region 10 considered these factors when contracting Gate 1:

In house forest service folks generally do not have the same level of expertise or experience as Region 10 contractors.

Most of the harvest areas left available is quite difficult to plan and typically have lower volume and value and the sales are getting bigger and more complicated.

The contracts are written with training in mind. The sale prep staffs are administering the

Gate 1 contracts and hopefully learn how to do one in the process.

The financial analysis is very important. Outside contractors with more experience have been able to offer very helpful suggestions that saved money in the logging and transportation plans.

The contractors and the FS inspectors are able to come up with and verify a good prospective and often times ground-truthed units.

Following the Gate 1 process helps ensure the plan fits the ground. This issue has a huge impact on sale prep and sale admin costs as planners are spending less time in the field to verify the information.

A contracted Gate 1 can be quite large. The feasibility analysis includes a full logging system and transportation plan, unit specific financial and volume information, and a clean GIS coverage ready for analysis.

In Gate 2, which is considered the NEPA process (environmental analysis and NEPA decision), implemented projects need to match NEPA decisions. Sometimes acres treated or volume harvested is less than what was disclosed in the NEPA decision. This issue may vary by the type of marking used in implementing the NEPA decision, with cut tree marking yielding less volume as a percent of the NEPA decision than leave tree marking.

Basic training in sale development, preparation, and administration is needed for line officers, just as they now get specialized training in wilderness management, special uses, rangeland management, and planning. The class should provide an assortment of topics such as: an overview of the legal mandate and authorities that pertain to forest management on National

Forest System (NFS) lands; an overview of timber sale contracts and compliance; the art and science of forest management (silviculture); the line officer role in sale development and implementation; related resources and ecological processes; and the importance of interdisciplinary collaboration, monitoring, and accurate reporting. The Forest Service

Handbook indicates at least 7 different areas where a line officer signs or certifies in the development of a timber sale including: Gates 1 through 4; a project initiation letter; the NEPA decision; and the cruise report. A line officer needs to be familiar with all these steps.

Other concerns were identified related to inventory and monitoring of vegetation management activities. These concerns are related to natural resource sampling issues and are not limited to forest management. For example:

Point cruising incorrectly (wrong basal area factor used), Expensive sampling methods for estimating down woody debris, and

Traditional stand exams with additional data requirements that sometimes triple cost per plot.

Statistical expertise for these areas is no longer available, as it was in the past in regional offices or research stations. The Forest Management Service Center Biometrics group provides assistance on the forest products side only. Statistical expertise is once again needed to provide oversight and assistance in developing natural resource sampling methods. The cost effectiveness of sampling methods for other resources should be evaluated, with consideration given to a peer review by outside mensurational organizations or perhaps even the establishment of a national statistician position to aid national forests and regions in natural resource sampling designs.

Finally, there is a concern that money and energy are going into GIS technology with very little time or money being spent on the accuracy of the data. Most GIS issues come from legacy data in different formats and from trying to use those data in current software that has different requirements. Regionally, there are significant differences in the quality of GIS data and the application of those data. For most timber projects, only a few accurate coverages are needed, such as a digital elevation model and coverages for vegetation, roads, and streams. The focus should be on on-the-ground data collection and sampling to correct old data and address new data needs.

Recommendations

Basic training in sale development, preparation, and administration is needed for line officers, just as they now get specialized training in wilderness management, special uses, rangeland management, and planning. Line officers often lack training and experience for making critical choices regarding sale development and implementation that may result in higher costs.

Additionally, implemented projects need to match NEPA decisions; sometimes acres treated or volume harvested is substantially less than what was disclosed in the NEPA decision.

Emphasize completing a full-blown Gate 1. This is an important focal point and should be a basis for the NEPA. Gate 1 is a task that could be contracted. The Alaska Region is doing this and can use the feasibility analysis from the contractor as a basis for NEPA. This can save time in the long run by having a better developed proposed action and using the analysis as part of the

NEPA documentation.

Forest Management needs to be involved at the forest and district levels in the Quality

Assurance Oversight framework that is be part of forest plan revision. This would provide the quickest path to finding efficiencies in NEPA.

Forest Management needs to be involved with the NEPA Line Officer Focus Group. This group offers some good opportunities to improve NEPA.

Forest Management should support an accurate downscaling of roadless boundaries before an analysis is started. Roadless boundaries have been a problem for planning teams—there have been many problems figuring out where that line is, with the end result of “padding” the areas proposed for harvest.

Forest Management should work with Ecosystem Management Coordination (EMC) in developing an adaptive management approach for forest disturbances. EMC has been working on an adaptive management approach for events such as fire, hurricanes, and tornadoes. For example, a decision on salvage harvesting would state that when these disturbances occur, forest managers would then be able to implement appropriate actions.

A consistent approach to geospatial coverages in the planning process is needed. Planning teams lose time when GIS coverages are not consistent, boundaries vary, and lines are not coincident.

Evaluate natural resource sampling methodologies, perhaps through a peer review by a private mensurational organization.

Timber Sale Mitigation Costs and Complex Silvicultural Prescriptions

Issue: Are timber sales overly mitigated so that value is reduced to a minimum? Care and thought must be used in mitigation requirements; these requirements can change stumpage values and often find their way into timber sale contracts that result in increased logging costs.

Some prescriptions may be expensive to implement because of the way cut tree marking or leave tree marking was used. Silviculturists need to be efficient in the way a sale is marked, and not have prescriptions that are too complex.

Discussion

Silviculture is defined as “the art and science of controlling the establishment, growth, composition, health and quality of forests to meet the diverse needs and values of landowners and society on a sustainable basis” . The operative words of this definition, as it applies to the issue “silviculture prescriptions are too complex and expensive to implement, are: “…to meet the diverse needs and values….”

Desired conditions described in NEPA documents are complex; they incorporate a variety of design criteria and mitigations and are increasingly difficult to describe and implement. In the past, silvicultural prescriptions were simple, clearly understood, and efficient to implement.

Today, however, there are many more considerations in achieving desired conditions, resulting in greater complexity and increased implementation costs. Forest plans are describing more complex desired conditions. Collaborative groups, specialist input, and public comments and expectations also influence the complexity of silvicultural prescriptions. Silviculturists are being asked to implement actions that are non-measurable or non-quantifiable, which makes for wordy and complex descriptive prescriptions. For example, canopy closure is a metric that is difficult to measure consistently and implement on the ground. Furthermore, complex prescriptions may affect sale economics, because timber markers must quickly decide whether to mark or not mark a tree hundreds of times a day, and they tend to focus on factors that they can quickly apply to each decision. Any more than three or four factors tend to be superfluous and generally ignored.

Collaboration efforts and the NEPA preferred alternative (pre-decisional) need to be cross checked so that the desired conditions are implementable on the ground. Collaboration efforts and interdisciplinary involvement need to be reconciled with operational feasibility prior to the line officers decision. Implemented projects need to match NEPA decisions.

Wildlife design criteria need to consider safety, OSHA requirements, and impacts to logging systems. When snags are felled and there are green tree substitutions, there is an impact on sale administrator time and timber sale economics (for example, volume deleted from the sale or slower production, both of which result in higher logging costs).

Forest management personnel often are implementing restoration activities, which generally have more complexity and higher pre-sale and post-sale costs than those activities that implement primarily regeneration harvest activities. Increased costs occur in restoration harvests because volume is a result of timber removal used to achieve restoration objectives, yet pre-sale, post-sale, and silviculture accomplishments are measured by timber volume. Restoration treatments frequently cover more acres for the same volume target than in past sales.

Line officers today come from diverse resource backgrounds and many do not have a timber, forest measurements, or silviculture background. Accountability is a concern in meeting timber targets, along with knowledge of timber sale development and implementation.

Recommendation

Marking guides should focus on three or four of the most important factors. Any more than three or four factors tend to be superfluous and generally ignored.

Helms, J.S. 1998. The dictionary of forestry. Bethesda, MD: Society of American Foresters. 210 p.

A forest management/silviculture course for line officers should be required for those line officers who do not have a background or experience in the timber sale development and implementation. (See recommendations in the NEPA issue.)

NEPA decisions need to be simplified so that their implementation is simple. There is a need to consider the impacts of design criteria and constraints of vegetation management on pre- and post-sale activities. Collaboration efforts and the NEPA preferred alternative (pre-decisional) need to be cross checked so that the desired conditions are implementable on the ground.

Collaboration efforts and interdisciplinary involvement need to be reconciled with operational feasibility prior to the line officers decision.

Projects need to be designed to meet restoration objectives, be implementable, and be cost-effective. Restoration is also a business endeavor.

Wildlife design criteria need to consider safety, OSHA requirements, and impacts to logging systems. When snags are felled and there are green tree substitutions, there is an impact on sale administrator time and timber sale economics.

Better accountability for targets may raise awareness of the cost and consequences of complex

NEPA documents and associated decisions. Accountability is a concern in meeting timber targets, along with knowledge of timber sale development and implementation.

Salvaging Timber After a Fire

Issue: Foresters are not part of Burned Area Emergency Response (BAER) teams. An evaluation of the disturbance to the forest resource would be valuable, both for salvage sale evaluation and reforestation purposes.

Discussion

The BAER program is “first aid”—immediate stabilization that often begins before a fire is fully contained. BAER does not seek to replace what is damaged by fire, but rather to reduce further damage due to the land’s being temporarily exposed in a fragile condition. After a fire, the first priority is emergency stabilization to prevent further damage to life, property, or natural resources. The stabilization work begins before the fire is out and may continue for up to a year.

The longer term rehabilitation effort to repair damage caused by the fire begins after the fire is out and continues for several years. Rehabilitation focuses on the lands unlikely to recover naturally from wildland fire damage.

BAER objectives are to:

Determine if an emergency condition exists after the fire.

Alleviate emergency conditions to help stabilize soil; control water, sediment, and debris movement; prevent impairment of ecosystems; and mitigate significant threats to health, safety, life, property, and downstream values at risk.

Monitor the implementation and effectiveness of emergency treatments.

BAER teams are staffed by specially trained professionals: hydrologists, soil scientists, engineers, biologists, vegetation specialists, archeologists, and others who rapidly evaluate the burned area and prescribe emergency stabilization treatments. There is a very clear focus in the

BAER program, which is to quickly determine whether any unacceptable post-fire risks exist and, if they do, to take appropriate and immediate actions to manage that risk. The assessment portion is a rapidly conducted evaluation of risks done by a select team of individuals dictated by the unique values on the particular fire. Assessments are normally finished in 5 to 7 days, depending on the size of the fire. These timeframes are deliberately short because the real goal of the BAER program is managing risk, not merely identifying it. The less time spent on assessment, the more time to plan and take response actions.

Because of the short assessment timeframe, the BAER assessment team starts its evaluation prior to fire containment. This generates additional fire safety, fire training, protective gear, and work capacity fitness requirements for each team member. The focused mission of the assessment team also necessitates long field days accompanied by morning and evening briefings and team discussions to keep everyone on track.

Funding for BAER assessment and response comes from the same appropriation (WFSU) as fire suppression, with the same emergency intent and oversight on expenditures that suppression has.

It has been suggested that a person with knowledge of tree deterioration, viability and feasibility of projects, and local market conditions be part of a BAER team to coordinate restorative treatments and establish likely volumes and values of timber resulting from the treatments.

However, owing to the nature of funding authorities, this would not be appropriate.

A criticism of BAER is that foresters are often not included on BAER teams. The forested resource is part of the damaged resources, and a forester should be on the team to represent that resource. Foresters can bring a level of expertise in forest resources and practices that the current

BAER model is lacking. BAER teams implement best management practices (BMPs), similar to

BMPs for timber sales, buffers, equipment exclusion zones, etc. People with a logging and equipment background are critical and should have seat at the table. There are several examples where BAER rehab has caused more damage than it prevented. A forester has a working knowledge of most of the other disciplines and is best suited to comment on protecting the forested resource and influence the feasibility and cost effectiveness of BAER projects. A forester should be the first choice for the vegetation specialists. If there is a choice on foresters, a sale prep/sale admin/logging systems forester on the ground is preferable to a silviculturist.

There is already existing direction—LaSER (Large Scale Event Recovery) and RAVG (Rapid

Assessment of Vegetation Condition after Wildfire) —that provide direction on assessing post-fire conditions and developing a program of work for restoration and recovery. The objective of the LaSER is to swiftly identify needed recovery actions through a rapid assessment after an event that causes major substantial damage to natural or cultural resources or infrastructure. The assessment will lead to a program of work for the affected field unit, identifying skill needs, funding sources, accomplishment timelines, and partners to facilitate recovery efforts. Rapid assessment follows close on the heels of suppression activities and may be implemented before the fire is controlled. Additionally, the RAVG process can assist in assessing fires greater than

1,000 acres, beginning with fires that occurred in 2007. RAVG analysis provides a first approximation of areas that may require reforestation treatments because of the severity of the fire. This initial approximation could be followed by a site-specific diagnosis and development of a prescription identifying reforestation needs. Some forests have paid for post-fire analyses through the cost savings of employees who worked on that fire on that forest, although this would last only through the same fiscal year. This approach includes assembling short-term http://fsweb.wo.fs.fed.us/fm/silviculture/LaSER/index.shtml http://www.fs.fed.us/postfirevegcondition/whatis.shtml http://www.fs.fed.us/postfirevegcondition/whatis.shtml http://www.fs.fed.us/r8/emergency/guide/rapidassessment/fire.html http://www.fs.fed.us/r8/emergency/guide/rapidassessment/fire.html restoration assessment teams using appropriated program funds, with the goal of quickly capturing and recording damages, needs, and opportunities.

Finally, the use of stewardship authority for salvage sales should be encouraged because of added flexibility in funding, timber marking, and implementing additional options in fire recovery and rehabilitation.

Recommendations

Foresters are needed on BAER teams. A forester has a working knowledge of most of the other disciplines and is best suited to comment on protecting the forested resource and influence the feasibility and cost effectiveness of BAER projects.

Additional training may be needed in implementing existing direction on assessing post-fire conditions and developing a program of work for restoration and recovery. Salvage and reforestation cannot be funded with a BAER appropriation. Tools such as LaSER and RAVG provide a good approach for salvage and restoration for large-scale disturbances but appear to be not widely known or used.

Encourage the use of stewardship authority for salvage sales because of added flexibility in funding, timber marking, and implementing additional options in fire recovery and rehabilitation.

Accountability and Sale Preparation Costs

The accountability and sale preparation costs issue includes concerns about designation by description (DxD) and designation by prescription (DxP) opportunities; weight scaling and load count scaling for low-value material; tracer paint and tree marking; and cruising sampling error requirements.

Designation by Description (DxD) and Designation by Prescription (DxP) Opportunities

Issue: There may be opportunities to use DxD and DxP more effectively to reduce sale preparation costs and achieve acceptable results on the ground.