Wednesday, December 10, 2008

Critique of TWS Economic Analysis of Blackfoot Clearwater Stewardship Plan

Autumn larch along Monture Creek Valley, Lolo National Forest, Montana

The following is a critique of an economic analysis done by the Wilderness Society that supports the Blackfoot Clearwater Stewardship Proposal. Though I sent the critique in July, I have yet to get a detailed response to my concerns. Keep in mind that I may have misinterpreted the economic analysis, but in the absence of no response to correct any mistakes, I encourage readers not to take my interpretation as the final word and all should review the economic study themselves.

Bob Eky
Montana Office The Wilderness Society
Bozeman, Montana
July 7, 2008

Dear Bob:

Sorry to cause you more heartburn, but I have recently read the economic analysis for the Blackfoot Clearwater proposal and I am troubled and disappointed by what I saw in the report. From what I can deduce, the report seems to find a positive economic return for logging, and ignores many ecological impacts. Here are some criticisms and questions. I welcome your response. I hope I'm wrong, but I fear my critique is correct. But if you would like to respond, I have included all the people I copied on this message. So far this is an internal critique I'm only sending to you and others at TWS and MWA. But you can hit reply to all if you wish to set the record straight.

The TWS economic analysis comes out very positive about the Blackfoot Clearwater proposal. Perhaps in the end it is a net positive gain for the public—but one can’t determine that from this analysis. It seems to miss some important costs, particularly the ecological impacts from logging and its direct negative financial costs (logging loses on average $1400.00 an acre). This is not speculation—there’s a huge volume of scientific literature on all aspects of how logging negatively impacts the landscape and biodiversity—but you wouldn’t know it from this economic analysis—more on that later.

While the report suggests that there will several million in wages, etc. from the Blackfoot Clearwater proposal, it appears to ignore the original input of tax payer dollars that will facilitate much of this economic activity including the proposal to give Pyramid Lumber more than $4.5 million for a co-generation unit? Such a gift from taxpayers directly to a private business does not seem appropriate for any environmental organizations to be promoting. Sure Pyramid Lumber is happy—bought off for supporting wilderness in a place it can’t log anyway—but the taxpayer doesn’t necessarily benefit.

Plus there is an annual appropriation of $750,000 to the FS which is another "cost". These costs must be weighed against the presumed economic benefits. But in my quick review, I did not see these costs subtracted.

Furthermore, there is an underlying assumption that these subsidies are the best way to spend tax payer dollars to stimulate the local economy—even if we agreed that stimulating the local economy was something that we taxpayers should be doing in the first place. Take the economic issue of logging. Unless this proposes something drastically unique, most logging on the Lolo and other forests in the northern Rockies lose money—on average about $1400.00 an acre. Logging in a more sensitive manner would increase the costs, and lead to even greater losses.

Would it be better to spend these millions on something else like hiring more teachers for the schools or maybe just spending all those millions closing all the existing logging roads? Do we need to log the forest to close roads? I don’t think so—especially when the Blackfoot Clearwater proposal is talking about extensive federal subsidies. Stewardship sales are always tied to logging, however, one doesn’t need to log to do things like close and remove logging roads. Indeed, if we used that $750,000 annual appropriation proposed for ten years (over ten years amounting to $7.5 million) combined with the $4.5 million gift to Pyramid Lumber, we could close and restore a hell of a lot of logging roads. And ecologically this would be far superior to new logging.

Perhaps instead of promoting the local timber mill, we could use that federal subsidy to close roads, and promote quiet recreational like cross country skiers in winter and mountain bikers in the summer—making Seeley Lake a major destination for these activities. Perhaps promoting quiet recreation might actually improve Seeley Lake’s economy well beyond the short term benefits that might come with logging. In other words, could we spend a similar amount of money in some other way that might also create jobs in the community instead of logging? No comparison is offered. Instead TWS just goes along with the assumption that the best way to promote the local economy is by stimulating the timber industry with federal subsidies.

But even more troubling to me is that nowhere in the analysis did I see any attention given to the negative economic impacts of logging, motorized vehicle use, and other impacts that are going to be promoted by the Blackfoot Clearwater Partnership. All is glossed over and ignored as far as I can see.

The heart of the proposal is to thin the forests around Seeley Lake. The ecological justification for thinning forests in these kinds of ecosystems is questionable at best. This is not the Southwest ponderosa pine zone with its frequent fires. I know the area quite well. It is relatively wet, and even though some ponderosa pine exists in the area, the vast majority of the area included for logging can’t be called a ponderosa pine zone. The lowest elevation forests are transitional from ponderosa pine to western larch/Doug fir forests with extensive stands of lodgepole pine subalpine fir/spruce forests at mid and higher elevations. Thinning is proposed for all these forests on the assumption that fire suppression created unnatural fuel buildups, and thus is responsible for high intensity fires. However, it is questionable whether there is a significant amount of the land in this area that isn’t naturally in at least a mixed severity fire regime, much less dominated by a stand replacement fire regime.

Plus recent research into ponderosa pine forests in Colorado, the Black Hills, the northern Rockies and Cascades questions the assumption that stand replacement fires are always abnormal among the ponderosa pine forests in these locations. And dense pine forests may be as much as a consequence of favorable germination conditions (wet spring ) and a period of generally wetter conditions overall that is unfavorable for fires than as a consequence of fire suppression. Even if we all agreed that thinning of ponderosa pine might be justified in some places, that doesn’t mean thinning is justified in this location since most of the forests proposed for logging here are not even in the ponderosa pine zone. So the under lying assumption that somehow the forest here is out of whack due to fire suppression can be debated, yet TWS doesn’t even raise this as a potential issue.

But beyond those ecological factors concerning fire regimes and consequences for forest stand composition, thinning is still logging. Let's call it what it is. And logging is not a benign activity—it’s impossible to do logging without significant ecological impacts. And these impacts were nowhere mentioned in the economic report that I read. There is wildlife disturbance associated with logging. Sensitive animals like grizzly bears will avoid roads used by logging operations for years. There is the spread of weeds--this alone might cost more than all the presumed positive economic benefits. There is soil compaction. There is sedimentation from logging activities in streams.

One of the more important consequences of logging is the loss of biomass from the forest ecosystem and so forth. Thinned forests typically have fewer snags—and a net reduction in opportunities for cavity nesting birds, small mammals, bats, etc. And biomass on the forest floor is important for ants that are among the major predators on insects that prey upon trees. Fallen logs are important for mollusks that among the major herbivores in the forest ecosystem. I could go on, but it seems that all these costs are ignored. Just the presumed benefits are articulated, but none of the costs.

In yet another area the report suggests that thinning would improve growth rates of ponderosa pine. So what? Faster growing is only a benefit to the timber industry. Slow growing trees have denser wood, and when they die, they don't decay as fast, thus providing a longer period of benefits if the trees are snags or fall to the ground. In any case, the assumption that faster growth is a positive is again something that a good ecologist might question.

Plus even if thinning of the forest were desirable, that doesn’t mean it has to be done by logging. In our national parks across the West, the National Park Service effectively manages to reduce fuels in forests without commercial logging. They do it with prescribed burns. And prescribed burns avoid many of the ecological negatives I mentioned above. Why isn’t TWS promoting the least invasive methods for accomplishing a goal—if indeed, the goal is even correct—which it may not be as I have suggested. Instead it buys into the FS mantra that logging is the cure for everything that ails the forest.

And I do not accept the assumption in the report that thinning would improve water quality if the real impacts associated with logging are included, etc. At least this is another debatable assumption.

It is also questionable whether thinning will reduce fires as suggested since it ignores a growing body of evidence that suggests that thinning may actually increase fires, especially under severe fire conditions—which are the only conditions that matter since under less than severe fire conditions of high winds and drought, fires are easily contained and squelched if that is the desired goal. Thinning will open up the forests to faster drying of fuels, and increases wind velocity. Both of these are major factors in the spread of fires.
Of course, another bias in this analysis is the idea that fires are something to be prevented. Severe burns are ecologically important. We are not having enough severe burns compared to historic averages, so the assumption that we would want to prevent them--if this were possible--is not something that I expect TWS to be promoting.

Elsewhere in the analysis, TWS suggests that doing thinning will reduce “fire fighting costs”. Again this assumes that it’s desirable to fight fires. Why isn’t TWS questioning this assumption, and pointing out that most of the justification for fighting fires in the Seeley Lake area is because people have unwisely built homes in the forests and urban-wildlands interface. Here’s a real chance to make the point that it is inappropriate development that is driving public policy. Instead TWS adopts the basic assumption that we should be fighting fires in such a place—and thus if thinning really works (which it may not as I argue above) than it is a net benefit to thin.

And the analysis goes on to say that studies show enhance land values in thinned forests compared to burned forests. It says that recreation users prefer to use thinned forests rather than forests with crown fires. So what? Many recreational users also don't like having grizzly bears around. Should TWS start promoting the elimination of grizzlies because many recreational users s prefer to be in bear free country? TWS is supposed to be an environmental organization. Fires are a net positive ecological function of the forest. Instead of accepting that people prefer thinning to burns, perhaps TWS should spend more time educating the public why burned forests are great places to recreate to change the existing perception, instead of validating a misguided perception.

Or the statement that the 2000 acre winter recreation (snowmobiling) will provide enhanced benefits is another flawed assumption. You might find that if there were fewer snowmobiles, there would be greater economic benefits because more people attracted by quiet recreation might use the area. And like the logging assumptions, this analysis does not mention any negative ecological impacts resulting from the so called "enhanced winter recreation." Please read the chapter I wrote in Thrillcraft on snowmobiles if you want a few ideas about how snowmobiles can impact the land--and costs all of us. Again to see TWS promoting snowmobiling as a positive good is very disheartening.

Basically this analysis externalizes most of the ecological costs and/or assumes thinning and logging are a positive effect on the land and only includes the so called benefits. It appears to be designed to substantiate a predetermined conclusion, rather than a genuine attempt to really figure out whether this is a public benefit or loss.

Furthermore, there is no context or comparison. What would be the economic benefits if you just designated the 87,000 acres of wilderness, and had no logging? Or designated 87,000 acres of wilderness closed the existing logging roads on much of the rest of the public lands and promoted quiet recreational uses? We aren't given any comparatives that might provide far more public benefits. Maybe this will ultimately prove to be even better for the local economy--especially if all the real costs of logging were considered. But this is not mentioned because TWS wants to make a deal with Pyramid Lumber.

Basically this analysis is like something I would expect from industry. It promotes logging and even some thrillcraft use without articulating any of the real harm and ecological costs associated with these activities. In fact, it seems to promote all of these harmful activities as net economic benefits, in part, because none of the negative environmental impacts are included in the accounting. By this kind of accounting, Plum Creek and Weyerhauser butchery of its forest lands should get accolades from TWS for their outstanding economic contributions to the PNW economies.

I can understand there is some logic to these collaborative efforts. One can assume that logging is going to occur anyway, and we (wilderness activists) might as well try to extract some protection for roadless areas out of the deal. But in validating things like logging, thinning projects that don't work and are unnecessary, snowmobile use, etc. you actually make it harder to protect forests in the end. I know this is a more difficult uphill battle to inform the public where logging, for instance, won't prevent large blazes and/or that logging, snowmobile use, ORVs, etc. have many nuanced, but important ecological impacts. But in the end isn't that what environmental groups are supposed to be doing--educating the public.

I want to see wilderness designated as much as anyone, but I don't want it to be done dishonestly. And I believe your economic analysis is--for want of a better word-- a snow job. It ignores and/or glosses over many of the real costs of logging, and ORV use in trying to put a happy face on this proposal. If TWS won't honestly state what costs are being externalized, who will?

I would be happy to give you more input on ecological costs if you are open to hearing about them. However, I get the sense that you are more interested in closing a deal rather than honestly appraising the real costs of this proposal. Please prove me wrong.

George Wuerthner

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