Agriculture Reference
In-Depth Information
environmental assessment process governed by NEPA have been made through
Council on Environmental Quality (CEQ) guidance. Other changes to the appeals
process are found in general Forest Service regulations.
Despite the continuing controversy, HFRA plays a large role in the utilization of
biomass for bioenergy. The Departments of Agriculture, Interior, and Energy signed
a memorandum of understanding in 2003 setting “Policy principles for Woody
Biomass Utilization for Restoration and Fuel Treatments on Forests, Woodlands,
and Rangelands” [ 49 ]. The principles include mapping of potential biomass
resources and encouraging sustainable development as sustainability “measures.” In
2008 the Forest Service issued its “Woody Biomass Utilization Strategy,” which
recognizes the need to develop management practices for sustainability that pre-
sumably would apply to restoration and fuel treatments [ 50 ]. 2 Part of USDA-FS's
national strategy, too, includes the “Woody Biomass Utilization Desk Guide,” which
recognizes the environmental implications of increased harvest but does not recom-
mend specifi c practices [ 51 ]. USDA-FS also contributed funding to a National
Association of Conservation District's “Woody Biomass Desk Guide and Toolkit”
that recognizes specifi cally the environmental disadvantages of woody biomass-to-
energy activities [ 52 ].
Private Certifi cation on Federal Forest Lands
In 2007, the USFS commissioned a study gauging the effectiveness of its existing
forest management practices when compared with certain third-party certifi cation
standards [ 53 ]. While auditors commended the thoroughness of planning, compre-
hensive use of scientifi c data, and stakeholder engagements, shortcomings in
USDA-FS policy were found in relation to practices that related to forest sustainabil-
ity. Delayed silvicultural treatments and unachieved ecological, social, and economic
management goals were the primary lapses cited. The report cites increased pest and
disease infestation, increased potential for “stand-replacing” wildfi re, and the inabil-
ity to achieve desired forest structure and composition (e.g., bird habitat) as some of
the ramifi cations of the failure to manage forests for sustainability. Lack of fi nancial
resources and lack of capacity have led to these delays. Forest offi cials further admit-
ted their inability to adequately enforce rules meant to reduce the detrimental envi-
ronmental impacts of off-road vehicle use. Some inadequacies related to scale and
access also were found with management of late-succession and old-growth forests.
The 2007 study reveals that public laws, standing alone, are in some cases not
enough to ensure the sustainability of forest harvests. Assuming that federal forests
will be opened to harvests for energy biomass, to combat the threat of overharvest-
ing for energy biomass, future general federal forest laws could require regular
2 USDA, Woody Biomass Utilization Strategy (Feb. 2008), http://www.fs.fed.us/woodybiomass/
strategy/documents/FS_WoodyBiomassStrategy.pdf .
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