By Brandt Mannchen
On February 26, 2019, the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) had a conference call with the U.S. Forest Service (FS), National Forests and Grasslands in Texas (NFGT) and the Texas Conservation Alliance (TCA) about site-specific projects and the National Environmental Policy Act (NEPA) in the NFGT.
The FS requested the meeting because it had been awhile since there had been communication with the Sierra Club and TCA. The NFGT is still recovering from the 35-day federal government shutdown. The FS stated that the Sierra Club would soon get a reply in response to a letter it sent to the Regional Forester (Region 8) about Longleaf Pine, Shortleaf Pine, and other regional restoration initiatives.
The FS will not change NEPA but there will be an accelerated schedule for restoration projects. The FS wants to collaborate with the Sierra Club and TCA. The NFGT has been encouraged to use categorical exclusions (CEs, weaker environmental analysis) wherever possible. The document will drive the process. It is not appropriate to decide before scoping whether a CE or environmental assessment (EA, stronger environmental analysis) will be needed. Information from the public could determine whether a CE or EA was done.
The FS said that collaboration included the exchange of ideas between the public, partners, and the FS. The intent has not changed but the timeline has changed for collaboration and NEPA. The FS will listen and try to implement public ideas. TCA said that a 2012 FS teleconference stated that collaboration included meeting early and often to resolve conflict, accomplish goals, and incorporate the public’s values in projects.
TCA said that it attended a meeting on February 25, 2019, about the Bannister Project for Angelina National Forest. No specifics were provided to TCA about the project. TCA was told no stand exams would be done ahead of time. This means no relevant data will be prepared ahead of time so TCA can review and use it in analysis and in-the-field work.
The FS said that treatments (logging, burning, etc.) must be identified so that an EA can be written. TCA said that Longleaf Pine lands are involved and that natural stands with old growth hardwoods are found in the 28,000-acre area including Yellowjacket Branch. There is too much emphasis on one model of pine restoration. TCA is concerned the FS would go into mixed pine-hardwood stands and turn them into pine stands.
The FS said that if a project area is identified then you should be able to say what treatments may be used. TCA stated that in Sam Houston National Forest (SHNF) for the Montgomery County Wildlife Habitat Improvement Project (MCWHIP), that the FS has proposed to go to 40 to 60 basal area (BA, a measure of tree density) instead of a higher BA.
TCA said there was concern that timber targets were driving the process. The FS said that timber targets should not drive a project but that other reasons, like forest health, should. The 40 BA was proposed because the FS thins (logs) to 60 BA and stands are not cut for another 50 years. The BA grows to 80 or more in 5 years as if the logging had not occurred.
The FS said that 40 BA was an attempt to have a treatment where the FS could underplant an area with pine seedlings. TCA said in the MCWHIP in some cases the BA would go from over 100 to 40 BA and that this would affect the forest. This is not ecosystem management and makes the forest look like a hurricane hit. The FS often called projects restoration, Longleaf or Shortleaf Pine, when all it did was plant seedlings rather than really restore an area.
The Sierra Club said that in the MCWHIP it looked like several stands of very old pines were already naturally clumpy and sparse and that Stand 1 of Compartment 33, via the Sierra Club’s efforts, had been found to be a riparian blackland stand that should not have been included in the project. The Sierra Club has not heard back from the FS since the meeting it had with the Sierra Club and TCA in late fall. The Sierra Club does not know what the FS supports or does not for the MCWHIP.
The Sierra Club also stated that the White City First Thinning Project was worded so that logging could occur for 20, 30, or more years with no more public input. The Angelina/Sabine Prescribed Burn Project scoping notice has no time limit.
The FS said that the shutdown and a lack of people had created difficulties. The FS is now hiring people to fill jobs. The FS needs to do a better job at scoping. Since there were so few people in the NFGT, the FS had to use people from out of state. The Sierra Club said that it was much better when people on the SHNF prepared projects and EAs because they know what is on-the-ground.
The FS said it would have a leadership team meeting on NEPA so that everyone understands what is needed. The FS said how the environmental analysis and decision-making model works is being changed and that more contract work for NEPA would be done. The MCWHIP is a contractor project.
Brandt Mannchen
March 2, 2019