Competitive Enterprise Institute | 1899 L ST NW Floor 12, Washington, DC 20036 | Phone: 202-331-1010 | Fax: 202-331-0640
TESTIMONY OF DR. ROBERT NELSON TO THE TASK FORCE ON NATURAL RESOURCES AND THE ENVIRONMENT, HOUSE BUDGET COMMITTEE, SEPTEMBER 13, 2000
The Congress would need to establish a schedule with tight deadlines – perhaps first drafts by next summer, final documents by the summer of 2002 – for the publication of full risk assessments for forest fire for each western community in close proximity to a federal forest. Legally fixed deadlines are desirable because the publication of such risk assessments is bound to be a sensitive and controversial matter. Without an outside forcing action, the Forest Service or other federal agency is likely to be taken up in a long internal discussion and debate, possibly delaying for many years any publication of results.
Commercial Sales of Small-Diameter Trees
Contrary to a widespread impression, the total volumes of wood on the national forests have been increasing steadily for many years – the result of fire suppression acting to build up wood loads, at the same time that levels of timber harvests have been below net growth of wood each year. The composition of the national forests, however, has shifted radically. As many larger and older trees were harvested as part of the traditional timber program, and with fire suppression, western forests have increasingly been stocked by stands of small-diameter trees. In ponderosa pine forests 100 years ago, for example, there might have been 30 to 50 large old trees each three to four feet in diameter. Today, the same forest might have 300 to 500 trees – including ponderosa pine, white fir, grand fir, and lodgepole pine, among other possibilities – packed together in dense stands, most of the trees in the range of 4 to 12 inches in diameter. It is these new conditions of densely packed stands of small-diameter trees – virtual kindling wood for fires -- that create the much greater fire hazard currently being faced.
At present, the small-diameter trees have a limited commercial market. This can be a short term situation, however. The demand for wood and paper in the United States continues to grow unabated. The national forests now contain large supplies of wood fibres that can be used to meet these needs. At the same time, large reductions in the excess fuel loads of small-diameter trees in the national forests are needed to reduce fire risks and improve forest health. It can be a win-win situation economically and environmentally. With appropriate government policies, forest health can be improved, fire risks reduced, and large supplies of wood provided for home building and other purposes. Rural communities in the West – some depressed economically – can also receive a significant income and employment boost.
Much increased utilization of small-diameter trees can also bring in substantial revenue to the federal government. There are various suggestions being made at present for large new commitments of federal funds for a program of thinning of overstocked western forests. This large expenditure of public money is unnecessary and undesirable. There is no need to create a new large drain on federal revenue sources and national taxpayers – and a large accompanying bureaucratic apparatus -- when small diameter trees themselves have a large commercial potential. A recent study published in August 2000 in the Journal of Forestry found that in southwest Colorado, for example, “forest restoration projects can achieve ecological objectives and pay for themselves.”
The potential uses of small diameter trees are numerous. Various wood products -- including oriented strand board, house logs, laminated lumber, studs, excelsior products, waferboard, posts and poles, and firewood – are possible. Oriented strand board was minimally produced until the early 1980s but now supplies 11.2 billion board feet of sheet and other wood products per year, equal to 63 percent of the volume of total U.S. plywood production. The timber industry in the United States has generally been shifting in many areas towards the use of chips and particles from lower quality trees and wood – for example, making increasing use of hardwoods as a wood fibre source. Better glues and other technology make it possible to create newly strong and attractive wood products from such lower quality sources. In 1950, the total wood outputs represented 70 percent by weight of the wood inputs going into the production process. Today, because of increased utilization of all parts of trees, this figure has increased to 95 percent.
Small trees can also supply pulp for paper production. Still another important and potentially profitable use of small-diameter trees is as a source of biomass to generate electricity.
As with any new product area, it will take time to develop the technology of utilization of small-diameter trees and to find the most suitable and profitable uses. The development of new wood processing technology has been most rapid in areas such as hardwoods where much of the wood supply is on private land. In the case of the western United States the supply uncertainties and other problems of doing business with the federal government on federal forests have inhibited a similar pace of technological and industrial infrastructure development. If every computer manufacturer had had to depend on a federal “chip” supplier with the same bureaucracy and reliability as the U.S. Forest Service supplies wood “chips,” the U.S. personal computer industry would likely still be back somewhere in its infancy.
Small-diameter trees also are limited in their marketability in the West at present because there are few contractors with the best harvesting equipment for these trees and few local mills with the capacity to handle them. The small-diameter trees thus are often harvested inefficiently and then sent to distant markets where the transportation costs can be half or more of the total costs.
The best future role of the federal government – focused on technical assistance and other facilitation efforts -- in forest management is illustrated by the work of the Forest Products Laboratory in Madison, Wisconsin, a joint effort of the University of Wisconsin and the Forest Service. In recent years it has conducted various studies of the economic potential of small-diameter trees and explorations of potential markets. For example, the Forest Productions Laboratory is working with the Watershed Research and Training Center in Hayfork, California. Experience to date has shown that removal of small-diameter trees costs $208 per thousand board feet for sale as green raw logs and that these logs can earn $200 in revenue per thousand board feet – thus involving a small loss but much lower net costs than simply paying for removal of the logs with no subsequent commercial sale. Use of the trees for processing and sale as flooring increases the costs to $800 per thousand board feet; the revenues, however, rise to $1,200 per thousand board feet, yielding a substantial profit surplus in this form of utilization of small-diameter trees.
The Los Alamos fire this year focused new attention on similar fire prone forests in the watershed area for the nearby city of Santa Fe, New Mexico (the Los Alamos fire started as a prescribed burn on Bandelier National Monument but then escaped and soon spread to the Santa Fe National Forest where it erupted in the tinderbox conditions of this forest and where most of the actual burning occurred). If a similar fire were to burn in the Santa Fe watershed, massive siltation and runoff might threaten the city water supply. Seeking protection against this outcome, the city and its water board are working with various groups to plan a thinning program. Given the large procedural hurdles and delays facing actions on federal lands, the first thinning efforts planned in the watershed will take place on private lands. It is expected that some of the thinned trees will be sold commercially, thereby reducing the expected bids from contractors to complete the job.
It will require new legislation to achieve the full large potential for utilization of small-diameter trees. The legislation will need to authorize planning for forest thinning over a longer time frame and government commitments to make sufficient wood volumes available to justify new local mills designed for processing of small-diameter trees. The supply commitment might have to cover a five to ten year period in order to allow for a sufficient period to pay off an investment in a mill and other facilities. Similar considerations have dictated long term contracts of up to ten years duration with concessionaires in the National Park System. Transfer of the park concession model to fuels reduction programs on the national forests might prove appropriate in other respects – for example, a specific large area for tree thinning could be designated (perhaps as a result of a local collaborative process) in an area surrounding a community and then a long term contract might be awarded to a “concessionaire/tree harvester” to do the job, including the building of a new mill to process the small-diameter trees.
Cost-Sharing of Fuels Reduction
Although commercial sale of small-diameter trees can significantly reduce the public costs of thinning forests to reduce fire hazards, many fuels reduction efforts may still require some element of public funds. The state and local government partners in the planning and development of these efforts should also contribute a share of the costs. Much of the benefit of excess fuels reduction will accrue to the citizens of the states and localities. It is often their actions in building homes and other structures in forested areas that increase the dangers of wildland fire and the costs of fire fighting. States and localities have the regulatory authority to control the location of such development in fire prone areas. In general, states and localities will have an incentive to plan for a more cost-effective approach to fuels reduction in surrounding forests, if they are contributing a share of the costs.
An equal division, 50 percent federal and 50 percent state and local, might be an appropriate cost sharing formula.
Curbing Unilateral Veto Power
Numerous observers have described the current decision making process for the national forests as “broken.” The land use planning system, by most accounts, does not work. It promotes conflict and polarization as much as agreement. The process of planning takes long periods and causes many delays. In the end, the land use plan often fails to provide the basis for actual management decisions. Land use planning thus becomes more a matter of public relations, or litigation strategy, than the basis for rational decision making that was originally the goal of Congress in mandating planning in the 1970s.
The land use planning and other procedural requirements afford so many opportunities for appeals and other delays that outside groups in effect can often exercise a unilateral veto power – if not forever, at least for the duration of the appeal process, and then perhaps through continuing rounds of further appeals. Litigation then often arises which involves its own burdens and delays.
The effect of the current system is often to impose a de facto management decision of no action. Reforming the current system has been complicated by the fact that some groups have in fact preferred the no action alternative, and thus have strenuously resisted any efforts to curb the existing opportunities for delay and obstruction. It may have seemed that no action was a reasonable approximation to a policy of achieving “natural” conditions on the forests – if no management actions were taken, then the human role would seemingly be minimized and natural forces might appear to be driving the system.
However, the forest fires of 2000 have shown the limitations of a no action strategy, and the fact that it will not achieve “natural” conditions on the forests. Because of a century of fire suppression, the fires that have burned have been much more intense and otherwise far out of the range of “natural” fire. They in fact have imposed a substantial human-caused change on the ecological condition of the national forests. There is in fact probably no management strategy at this point in time – including no action -- that could validly be described as achieving a “natural” result.
Yet, the current system in effect is strongly biased in favor of those who prefer the no action alternative. It is possible for a group of concerned parties to discuss forest management options and develop a fuels reduction plan that has wide community support, and yet any one of these parties will have the ability to prevent its implementation. Indeed, marginal parties who may disagree and who may not have participated in the management decision process will also have this unilateral veto power, if they possess a minimum of money and legal skill.
The existence of an outside veto power partly reflects the distrust of the Forest Service and other federal agencies on the part of many people in the West. They are reluctant to let the agencies act on their own when the agencies have made so many mistakes in the past. However, if management decisions on federal forests reflect a much wider range of participation and buy-in, the existence of an outside veto power is less justifiable and in fact becomes a serious obstacle to effective management actions.
If a veto power on the actions of federal agencies is necessary, it should in any case not be a unilateral veto power available to anyone. It should be assigned to a state or local official who in fact represents politically a much wider segment of public opinion. The approval of the governor of a state, for example, might be required in order to implement any fuels reduction plan on the national forests. Or a similar requirement for approval might be given to the mayor of the community in the immediate vicinity of a national forest where a prescribed burn or thinning were being planned.
In any case, if the Congress wants effective action to improve forest health and reduce forest fire hazards at any time in the near future, it will have to address the problem of the procedural hurdles to management action created by numerous past statutory requirements for planning, environmental impact statements, and other decision making requirements.
1993 – A panel of leading American foresters meets in Sun Valley, Idaho. Its report states that the policy of suppressing forest fire, as has been followed in western forests for most of the twentieth century, has resulted in a large buildup of “excess fuels” As a consequence, “Wildfires in these ecosystems have gone from a high-frequency, low-intensity regime which sustained the system, to numerous high-intensity fires that require costly suppression attempts, which often prove futile in the face of overpowering fire intensity. High fuel loads resulting from the long-time absence of fire, and the abundance of dead and dying trees, result in fire intensities that cause enormous damage to soils, watersheds, fisheries, and other ecosystem components.”
1994 – The National Commission on Wildfire Disasters, created by Congress, declares that “millions of acres of forest in the western United States pose an extreme fire hazard from the extensive build-up of dry, highly flammable forest fuels.”
May 1995 – The U.S. Forest Service publishes Course to the Future: Repositioning Fire and Aviation Management, declaring that under current policies “the potential for large, catastrophic wildfires continues to increase” and when they occur, as they inevitably will, “it will directly conflict with our ecosystem goals.”
December 1995 – The U.S. Secretaries of Agriculture and of the Interior jointly issue a report on Federal Wildland Fire Management, stating that “millions of acres of forests and rangelands [are] at extremely high risk for devastating forest fires to occur.” The Secretaries declare that many forested areas are “in need of immediate treatment” to reduce fire hazards.
1997 – A panel of leading foresters reports to Congress that “fires in the [wetter] Pacific Northwest occur less frequently than in the inland West, but can be even more catastrophic because of the high fuel volumes (dead trees). The limited road system and infrastructure make federal lands in this region increasingly susceptible to catastrophic fires.”
1998 – Barry Hill, Associate Director for Energy, Resources, and Science issues of the General Accounting Office, testifies to the Congress that as a result of past policies of fire suppression in the interior West, “vegetation accumulated, creating high levels of fuels for catastrophic wildfires and transforming much of the region into a tinderbox.”
1999 – The General Accounting Office issues a report on Western National Forests – A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats. The report finds that the Forest Service “has not yet developed a cohesive strategy for addressing several factors that present significant barriers to improving the health of the national forests by reducing fuels. As a result, many acres of national forests in the interior West may [still] remain at high risk of uncontrollable wildfire at the end of fiscal year 2015.”