Revising the WOP
September 24th, 2007
The Bureau of Land Management has proposed revisions to their Western Oregon Plan (WOP). The WOP covers approximately 2,550,000 acres of public lands. About 2,100,000 of those acres are lands revested from the Oregon and California Railroad and are managed under the O&C Lands Act of 1937.
A Draft Environmental Impact Statement (DEIS) was released for public review on August 10, 2007. The Formal Public Comment Period goes until Nov. 9, 2007.
The BLM has made it easier (than usual) for the public to make comments on the DEIS for the revised WOP by creating a website for that purpose (here).
Links on the website lead to an Interactive Map, DEIS verbiage, some explanatory documents, and an e-form to make your comments online.
We are preparing comments for our public input. There are a number of issues we think are very important. In this post we address the first of those, Site Potential Tree Height.
A key regulatory element in the old WOP, and in the Northwest Forest Plan as well, is something called Site Potential Tree Height (SPTH). Both plans isolate all acres within two site potential tree heights of running water. This ground is set aside for riparian protection. Sounds scientific, doesn’t it?
The problem is that SPTH is pseudo-scientific fraud. It does not exist. There is no such phenomenon. The concept cannot be measured. It is not a metric.
The BLM might as well use 400 frog hops, or 37.4 watermelon seed spits.
SPTH was made up out of thin air during the secret, invitation-only, public-excluded meetings following the Clinton Timber Summit of 2003. [Whoops, I meant 1993]. SPTH appears nowhere in forestry or forest science literature prior to those meetings.
SPTH had never been measured or correlated to riparian conditions, because the concept did not exist. SPTH had never even been thought of, let alone studied.
And it hasn’t been studied since, either. There are still zero scientific reports of studies on SPTH. None, zip, nada. It’s not science. It sounds like science, but it most assuredly is not.
Implementation of the NWFP caused confusion at the USFS and BLM local levels. No one knew how far two SPTH’s was, since the concept had not been, nor could it be, measured. Big numbers were dreamed up, for political correctness purposes, and lines drawn on the maps. As a result, 85 percent of Federal forest was set aside in “riparian zones”. In effect, most Federal forest in the Pacific Northwest has been dedicated to catastrophic fire, based on an out-and-out scientific fraud.
SPTH is voodoo forestry. SPTH is destroying forests. It’s a fake concept, it cannot be measured, and yet it is used as the most important yardstick in forest planning in Oregon, Washington, and California.
Bogus frauds make for improper and unworkable guidelines. It is time to bury this bogosity.
Unless the BLM can come up with some scientific basis for SPTH, and they can’t, then it has NO PLACE in management plans.
We will convey said comment to the BLM via their website. We ask you to please make similar remarks, because a preponderance of testimony is required to snap the BLM out of their dream world.
In future posts we will highlight other CRITICAL COMMENTS that are desperately required for the BLM WOP DEIS, to inject some science and sanity into the planning process, and to halt the incineration of our priceless, heritage forests.
September 24th, 2007 at 12:53 pm
SPTH is a term I never heard of in 34 years as a professional forester. However, intuitively this would mean the potential height of mature trees given the appropriate site index for the dominant species. This is probably not a good way to define stream buffers. Some combination of stream gradient, land slope, channel type and coefficient of roughness within 200 ft. of the stream channel would make more sense.
I’m sure the reason why the high percentage of land area included in the stream buffers (85%) is NOT due to the SPTH concept, but due to the definition of “stream channel”. I have been through this same dilemma while working on the Sequoia NF in CA. Inclusion of ephemerals (seasonal streams) is the problem, especially in steeper and highly dendritic watersheds where there are hundreds of ephemeral streams. Upon field verification of many of these (USGS mapped or otherwise indicated by terrain modeling), they simply don’t exist, having no evidence of a defined channel, no evidence of scouring, etc.
My opinion is that this buffer concept applied equally to all “stream channels” stems largely from those individuals looking for ways to eliminate timber harvest from federal lands. There is also a problem with a lack of field verification of office mapping and modeling on federal lands due to the reduced workforce.
The bottom line is that THERE IS NO SUBSTITUTE FOR FIELD VERIFICATION - I don’t care how high the resolution is on any remote sensing imagery - these stream channels must be at least sampled on the ground to veryify that a mapped channel is actually there (or not!).
btw, I am USFS Retired, Forest Silviculturist and Giant Sequoia Specialist
September 24th, 2007 at 2:35 pm
Lewis — Intuitive, but not real. Site index curves (King’s, Hann-Scrivani, etc.) are based on trees aged 40 to 80 years. The curves are mathematical equations (models) that fit those data. It is not scientifically proper to extend site index curves beyond the range of the data.
Who knows what the potential tallest tree might be? How many years is the outlook? The BLM uses 140 years as their target SPTH age. Why? And there is no data for 140 year-old tree heights, anyway.
Tree that old have experienced numerous events that damage height growth. No one knows what the “potential” is.
Site class diminishes with distance from the stream. At 200 feet away the growth potential could be two site classes lower. What potential SPTH should be selected?
All these factors make SPTH a big guess. There is no way to verify the number. That means the “yardstick” is fuzzy. Ergo, is it a LOUSY metric, subjective, and open to LITIGATION in all cases.
Pick a distance that can be measured, and I can find the line. Give me a fuzzy distance and there is no way to demarcate it on the ground.
Your suggestion is the best, however. We should demarcate riparian zones based on actual ecosystem functionality in the specific cases. And further, logging in riparian areas, if done with care, can IMPROVE functionality as well as protect the riparian zone from catastrophic fire.
September 24th, 2007 at 5:06 pm
Also, Lewis, you are absolutely correct about ephemeral streams, which were also included in the NWFP maps.
If you take SPTH to be 225 feet, and the buffer is two SPTH’s on either side of the stream (4 x 225 = 900 feet total buffer width) and include all the empherals, then it is easier to see how 85 percent of the land got designated “riparian zone”.
September 25th, 2007 at 12:21 pm
Having actually read and been confused by the INFISH and PACFISH language about site potential voodoo, I would also like to point out that implementation of such limits (cooked up in 1993, not 2003, Mike) leaves some funny-looking chimney strips up and down the landscape.
In short, fuel. Lots of fuel. So, if you get ignition down in the bottom of a drainage, where is your most intense fire? You betcha.
September 25th, 2007 at 2:17 pm
FG — Thanks for the date correction. I fixed it. Sometimes it’s hard to read and correct one’s own writing. I see what I meant to say instead of what I actually did say.