Responding to the President's 2013 budget proposal for the Forest Service

Since 2007, Wildlands CPR has been advocating for increased funding for watershed restoration on Forest Service lands. The Forest Service also has a restoration goal, but its approach has had a more landscape-oriented approach.  Over the past few years, the Forest Service has been flirting with a new “Integrated Resource Restoration” (IRR) idea. Simply put, IRR is a new funding approach. Instead of having individual line items, the Forest Service will merge several different funds into one large restoration funding bucket. IRR was first proposed in the President’s budget a few years ago, but Congress wasn’t so keen on it and it wasn’t adopted. The Administration made some changes and proposed it again last year, then Congress made some additional changes and adopted a three-region pilot to test IRR on the ground. When a pilot is tested, it is also usually assessed to understand what worked and what didn’t. However Monday’s release of the President’s budget for 2013 proposes skipping the assessment phase and adopting IRR wholesale across all Forest Service lands in 2013. This would mean no assessment of the challenges and opportunities presented by implementing the pilot.

While increasing Forest Service restoration funding is a common goal, it has to be done right. What if it doesn’t work at all? And what’s the point of a pilot if you don’t take any time to assess before adopting it across the country?

But perhaps most significantly to Wildlands CPR, we have serious concerns about the intersection of Legacy Roads and Trails funding and IRR. In the FY2012 pilot regions, all Legacy Roads and Trails money was pooled into the IRR. Because IRR is an integrated budget line, the Legacy Roads and Trails funds just become part of that big bucket of money, along with fish and wildlife funds, vegetation and watersheds funds, timber funds and fuels/fire hazard reduction funds. Once an individual fund is pooled into the IRR, that individual fund ceases to exist. Since these individual funds have now vanished into the big funding bucket, the money can be used for any activity that occurs within the IRR. The pooled Legacy Roads and Trails funds can be used for timber harvests, but so too can pooled timber funds be used for road decommissioning. In the pilot regions, therefore, Legacy Roads and Trails money has effectively disappeared this year. But the road problems that led to its creation have not.

The agency is promoting IRR because they think it will work better than the current system. The rationale: pooled funding will be more efficient and the agency can accomplish more with the same amount of money. While we support this in theory, we want to see if its true on the ground. Unfortunately, in the FY12 pilot regions, the agency isn’t just trying to accomplish more with the same amount of money, they’re actually trying to accomplish more with less funding – because their overall funding went down. This makes the pilot a little challenging to test.  

The agency is trying to address a plethora of stakeholder concerns by setting hard targets for accomplishments in the pilot regions. They’ve adopted five specific performance measures related to the IRR pilot:

• Number of watersheds moved to an improved condition class
• Acres treated annually to sustain or restore watershed function and resilience
• Volume of timber sold
• Miles of road decommissioned
• Miles of stream habitat restored or enhanced

We are generally positive about the performance measures. They illustrate that the agency is starting to reframe the concept of restoration and that they are starting to look at restoration from a broader perspective than silvicultural management. We’re most pleased, of course, that road decommissioning is one of their hard targets for IRR, and like to think that our persistent engagement with the agency regarding road reclamation as a critical restoration tool is one of the reasons they included this target. In addition, a significant portion of the “stream habitat restored” measure could come from fixing culverts and restoring aquatic passage – another significant road issue. As a matter of fact, the performance measures could actually be an improvement over the Legacy Roads and Trails independent line item, because it never included specific targets for road decommissioning (though for the years we have assessed, it seems that about a third of the funds were used for decommissioning).

But shortcomings remain. We’re not thrilled that timber volume sold is one of the target performance measures, though we recognize the need to address fire/fuels and unnaturally dense forest stands. We support restoration through logging when it is ecologically justified, but we are concerned that the timber targets could create a perverse incentive to promote timber sales that are not restorative.

In addition, for the “acres treated for watershed function” category the agency is compiling a set of existing performance measures, including range condition, weeds and other things. These require more attention than they are currently receiving and we aren’t clear that they will get the attention they deserve if a series of activities are all combined together. We are also concerned that acres treated could become a euphemism for additional timber harvest that may not be ecologically justifiable from a restoration perspective.

We are very concerned that under IRR roads might fail to garner the attention they so desperately need from within the agency, as staff work to achieve the many competing mandates set out for them.  While we have significant questions about IRR, we also recognize it could provide some new opportunities.

But to achieve those opportunities, they have to maintain and assess the pilot – ideally for a full three years. This can help us understand how concerned we should be about our favorite program, Legacy Roads and Trails, which would be swallowed up if the IRR is adopted across the board. This will help other stakeholders understand if their concerns are being met, and it will provide the agency an opportunity to improve the pilot based on the results of the assessments.

Our goal is not just to sustain Legacy Roads and Trails, but to ensure that the work for which it was created is prioritized and accomplished. The Forest Service estimates a multi-billion dollar road maintenance problem that is damaging fisheries habitat and municipal drinking supplies. In the state of Washington, for example, it will cost a minimum of $300 million to bring Forest Service roads up to minimum Clean Water Act standards. While road work makes sense as a part of an integrated restoration approach, the problem is so enormous that it has justifiably received its own dedicated funding for the past five years, and that funding has only been a drop in the bucket. The Legacy Roads and Trails program goals have not yet been met, and it’s unclear whether or not IRR will be the right mechanism for meeting these goals over the long-term.

The budget only came out a few days ago, so we have a lot more research to do. Obviously the President’s budget never gets adopted as is, so let’s hope that road issues continue to get the attention they deserve as the budget is debated in Congress. We’ll keep you posted as we learn more.