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How Many National Park Rangers Does It Take to Cut Down a Tree?

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While this dead tree might be viewed as hazardous due to its close proximity to the West Entrance Road in Yellowstone National Park, that eagle's nest in the treetop might have gained it a stay of execution. Kurt Repanshek photo.

How many national park rangers does it take to cut down a tree? Of course, before you can answer that burning question, you need to prepare a 100+ page document that not only identifies which trees need to be cut down, but explains how to go about cutting them down.

(Disclaimer: Before you get the wrong idea about this story, know that the Traveler holds national park rangers in the highest regard, and believes they should be spared some of the bureaucracy involved in identifying and removing hazardous trees. Now, back to our story...)

Now, cutting down a tree in a national park can be a particularly tricky process when you realize the paperwork and analysis that precedes that seemingly straightforward action. When they conducted an environmental assessment on a new and improved Hazardous Tree Management Plan, the folks at Glacier National Park didn't just go out into the park and, through their keen skills of observation, deduce which trees by their tilt, lean, or swagger just might present a hazard to buildings, roads, rigs in the parking lot, or passing tourists.

No, while that might have been quick and efficient, due to the various rules, regulations, and laws the National Park Service and Congress have seen fit to pass in protection of Mother Earth and park resources, Glacier's planners had to go through just a few more steps before taking out the offending trees with chains, chainsaws, axes, or, in extreme cases, explosives.

For instance, they had to "provide guidelines to identify and assess what represents a hazard tree and identifies a range of management actions to select from to reduce the hazard within all management zones while considering ecological concerns. While most hazard tree work takes place in the visitor service zone, some structures and designated campgrounds in the backcountry zone require protection from damage caused by hazard trees."

On top of that, they had to figure how just who would do the tree-toppling deed.

Now, what, you might ask, is a hazardous tree? The EA tackled that question up front: Hazard trees are those trees that, due to disease or structural failure, are at imminent risk of falling and striking stationary targets.

The EA also identifies those "targets," such as public restrooms, that could suffer from the ill-timed collapse of a hazardous tree that was not properly felled in time.

Now, you're probably starting to get the idea that chopping down ominous trees in a national park is not a quick procedure, not even when they might present a hazard. It's not. First you have to examine a few issues and look at potential impacts of said chopping. According to the draft environmental assessment:

Impact topics analyzed were vegetation, wildlife, threatened and endangered species, ethnographic resources, public health and safety, and recommended wilderness. The Preferred Alternative would have minor, temporary, localized and adverse impacts on vegetation as some trees from developed and backcountry areas of the park would be felled. Wildlife, including bald eagles, would experience minor, long-term, localized and adverse impacts from implementing the preferred alternative as a hazard tree treatment action has the potential to fell a tree that is inhabited by a wildlife species. The Preferred alternative could have minor, long-term, localized and adverse impacts to ethnographic resources if culturally scarred trees became hazard trees and had to be treated. The preferred alternative would have moderate, long-term, localized and beneficial impacts to public health and safety as hazard tree treatment would fell trees and limbs, alleviating the potential to harm visitors, staff or property. Negligible to minor, long-term, localized and adverse impacts would be imposed on recommended wilderness values as a result of visible remaining stumps and the potential for temporary unnatural noise.

And then, of course, problems like a waning budget or spare workforce could result in the culling of hazardous trees being put off 'til next season.

To illustrate how bureaucracy has tied the hands of the rangers, read this paragraph from the EA:

The Hazard Fuels Management Plan (NPS 2004a), required by the park’s Fire Management Plan, is part of the park’s fire program (not to be confused with the Hazard Tree Management Plan). Although some trees that might be considered hazard trees could be removed during fuel reduction activities, the objective of the Hazard Fuels Management Plan is to create a defensible buffer around developments to allow firefighters to effectively suppress fires threatening structures. This is done through removal of understory fuels and thinning of trees within 500 feet of structures. Hazard trees created as a result of wildland fire would not be addressed in this plan as they would be evaluated separately under a Burned Area Emergency Rehabilitation (BAER) Plan or earlier as part of normal mop-up operations. This will be done under the direction of the park’s resource advisor. (Traveler emphasis)

Now, with that groundwork laid, here are some of the issues Glacier's planners had to address before they could send a ranger, or two or three, out to cut down a tree:

* Vegetation. How might removal of a hazardous tree impact the surrounding vegetation?

* Wildlife. Might the use of chainsaws in the removal of hazardous trees bother wolves or other wildlife? Might the removal of a snag that had become a preferred perch for a bald eagle or two adversely impact said eagle's perching habits?

* Ethnographic resources. Do you, or do you not, cut down a hazardous tree that over the years has collected cultural significant "scarring"?

* Public health and safety. How to go about removing trees or tree limbs that might present a hazard to unwary park visitors as they go about business in front-country campgrounds as well as designated backcountry campsites where untimely falling hazard trees could inflict injuries and require medical evacuation.

* Recommended wilderness. Just how do you cope with hazardous trees in recommended wilderness where humans are not supposed to interrupt natural processes?

Ordinarily, recommended wilderness would be exempt from hazard tree inspections and removal but since the park has designated campgrounds and has historic cabins in recommend wilderness it is obligated to remove unnecessary risks such as hazard trees. The proposed plan would involve the use of various tools (see Section 6 – Minimum Requirement/Minimum Tool Analysis Worksheet) to fall hazard trees in designated campgrounds and around historic structures in the backcountry zone. Therefore, wilderness is analyzed in this EA.

Not only did the park's planners have to decide what topics to analyze in arriving at a new and improved hazardous tree removal plan, but they had to decide which topics didn't need to be visited. One that got crossed off the list (hopefully quickly) was the plan's impact on museum collections, which the planners came around to conclude "would not be affected by hazard tree management actions."

And, thankfully, they agreed that they wouldn't have to address whether their hazardous tree removal plan would impact farmlands.

In August 1980, the Council on Environmental Quality (CEQ) directed that federal agencies must assess the effects of their actions on farmland soils classified by the U.S. Department of Agriculture's Natural Resources Conservation Service (NRCS) as prime or unique. Prime or unique farmland is defined as soil that particularly produces general crops such as common foods, forage, fiber, and oil seed; unique farmland produces specialty crops such as fruits, vegetables, and nuts. According to NRCS, there are no soils in Glacier National Park classified as prime and unique farmlands. Therefore, the topic of prime and unique farmlands was dismissed as an impact topic in this document.

Also discarded from consideration where the "socioeconomic environment," "environmental justice," "soils," "floodplains," "wetlands," "air quality (The only pollution releasing activities associated with tree removal would be from infrequent use of chainsaws. These releases would be negligible and temporary...)," "natural soundscapes," "park operations," and "visitor experience."

Of course, no tree removal program is complete without a form for rangers to fill out while assessing which trees are, or might soon be, a hazard:

2. Examination surveys• Decay would be conducted by trained IPM (IPM: Somehow this translates into Hazard Tree Crew, according to page 10 of the EA) crew members under the direction of the Program Manager. They would be done concurrently or as soon after a surveillance inspection as possible. Examinations would be systematic, specimen by specimen evaluations of all potentially hazardous trees identified in the Surveillance Reports. The purpose of examination surveys is to make a risk assessment of detectable hazard trees. The examination and rating include species identification, description, measurement, defect assessment, wildlife use, hazard rating, documentation of location, recommended mitigation and date mitigation would occur. The examiner might choose to rate the hazardous portion of the tree, rather than the whole tree (i.e., dead top or branches). The hazard tree rating system would be used to evaluate potentially hazardous tree conditions, and provide a guide for making decisions on treatment methods. It is an assessment of risk that considers the probability of damage to a target. It also takes into account the target value. The hazard rating system is comprised of analysis of these factors, which are added as points recorded on the Hazard Tree Examination Form (Section 4), and kept on file in the Program Manager’s office. Based on the examination survey, interim warnings or closures might be put into effect.

And....

This list is not meant to be inclusive of all potential hazardous tree conditions but to provide guidance for what defects might be present. Trees with defects would be rated no, low, medium, high, or very high (0-4) as to the likelihood of their failure during the current season (USDI 1991). An extra point might be added if a tree exhibits other defects in addition to structural problems (i.e. lean). Trees with no defects would automatically fall into the no hazard category. If a tree has fallen, the suspected cause of the fall as well as any defects would be noted. Documentation on species, size, any defects present, and cause of failure or date of removal would be maintained on each tree. The potential impact to the target would also be rated low, medium, or high (1-3) according to the value of the structure and/or human use levels and the probability of hitting a target. Basic tree failure ratings are included here with more detailed guidelines in Section 2 (modified from Wallis et al. 1980). Tree Failure Potential A tree would be rated as to its potential for failure as follows: 0 – minimal potential for failure, no defects present 1 – low potential for failure, some defects present 2 – medium potential for failure, moderate defects present 3 – high potential for failure; dead trees, trees with serious defects, and those with multiple defects 4 – very high potential for failure, a tree with several serious defects and a lean resulting from causes other than natural growth.

Now, don't worry that the removal of hazardous trees might deforest Glacier. The plan also calls for "two young trees" to be planted for every felled tree.

Fortunately, the planners did their job and the folks in the Intermountain Region office in Denver signed off on the hazardous tree removal plan in December. But the seeming extremes the planners had to go to justify the removal of a tree that very likely was an obvious threat to submitting unexpectedly to gravity prompted the Traveler to call James Doyle, the regional office's spokesman, to explain the need for such scrutiny.

“Does it seem like it may be a little lengthy, the documentation? Yeah, I suppose it may have cost a tree or two, but when it comes down to management decisions we try to be as thorough as possible,” said Mr. Doyle.

Thorough indeed. However, neither Mr. Doyle nor the folks at Glacier could immediately say how much it cost to be so thorough when it comes to cutting down hazardous trees.

Oh, as to the initial question? I'm afraid I couldn't make it all the way through the 105 pages, so if you know the answer....

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Comments

I looked back at my pictures from June 2003 and found a picture of the same tree and probably the same bird. I am sure that lots of pictures would be taken of this since it is right by the road.


Kurt & all,

Having some familiarity with bait & its use, I'll bite:

a.) how well & meaningfully would you think the punky regulations and tottering structural-organization of the Parks-regime compare with the accumulation & hazards of deadwood in the forest-regime?

b.) if chainsaws & dynamite are effective against forest-decrepitude, what tools might be similarly useful against the decay at Parks?

Does a Stihl fit Sec. Salazar's hand, or is it more-suited to glad-handing?

How does President-elect Obama feel about the drip-torch?
-----

We do have fundamental guidance for such issues & questions as these.

For deadwood in the forest[sup]1.[/sup]:

"[The Secretary of the Interior] may also, upon terms and conditions to be fixed by him, sell or dispose of timber in those cases where in his judgment the cutting of such timber is required in order to control the attacks of insects or diseases or otherwise conserve the scenery or the natural or historic objects in any such park, monument, or reservation."

Forget the Rangers: we have lots of skilled & underemployed loggers who don't fall under NPS asininity.

And for deadwood in the office[sup]2.[/sup]:

"[The Secretary of the Interior] may also provide in his discretion for the destruction of such animals and of such plant life as may be detrimental to the use of any of said parks, monuments, or reservations."

Well, at least it's certainly poetic. ;-)

[sup]1, 2[/sup] Both from National Parks Organic Act, the basic law of our Parks, and short enough to read in a few minutes. Recovery from the shock & nausea may take longer.


Amazingly enough there are a couple of reasons for going through a planning and NEPA process, even to cut down hazard trees.

1. The National Environmental Policy Act, as well as the NPS Management Policies (remember that issue?) require the NPS to fully consider potential impacts on resources. This applies even when the NPS does some things as simple as removing hazard trees.

2. Sometimes simple things, aren't that simple. A few years ago I worked with a National Park that had an energetic hazard tree removal program and an equally energetic hazard tree program manager. In talking with the manager of the program I asked what standards he used to evaluate whether the tree was hazardous and whether removal was called for. I expected to hear a detailed description of considerations of location, condition, visible damage, etc. Instead his reply was "I know them when I see them." In looking at the program he managed we found that his park removed more "hazard trees" than the adjacent National Forest removed through timber sales. Unfortunately the law that established the National Park he worked in called on the NPS to preserve and protect the same trees and habitat that he considered hazardous. (The trees were hazardous because they were "big and old" the same reason the park was established). The park was advised to reconsider their hazard tree removal program. It went through a planning process and came up with a set of standards to apply rather than gut feeling to act on.

3. Over the last couple of years Glacier went through a planning process to address avalanche control issues related to the operation of the adjacent Burlington Northern train tracks. It was burdensome (just ask the BN people who employed a host of lawyers and lobbyists to plead their case). However, it needed to be done. (See #1 above). The BN folks complained that it was a burden and the issue was a simple one--snow removal and safety. But in examining the real issue, it was more complex than that. It also involved pesky things like wilderness, endangered species habitat, and core issues surrounding how National Parks should be managed. Should the NPS have given BN a pass to on their snow removal project?

4. In the end, however, these plans and environmental documents should be written in English and not the language of bureaucrats. Maybe what's needed is not a wholesale planning pass on seemingly simple projects, but a crash course in clear writing. The Park could probably use a volunteer like Kurt to teach it.


Well put, Anonymous, well put.

We're not suggesting the NPS overlook or sidestep NEPA, the Organic Act, or the Management Policies -- indeed, there are many times when we wished the agency would closely adhere to them (see Yellowstone snowmobiles) -- but couldn't the agency in Glacier's case have simplified the process some way, some how, spared the EA authors some long days, and spent more time on getting to work on the problem rather than running up printing costs?

You raise an interesting point when you cite another park that developed its own hazardous tree removal criteria. Why can't the NPS simply make copies and pass them out to the other 390 parks? Granted, there are differences from park to park (I wouldn't imagine there are too many hazardous trees in Arches), but the survey forms and rating criteria should be similar, no, as with soundscapes, air pollution, and museum impacts?

As for my volunteering, judging from some of the language I've seen I'd have to insist on being paid;-)

Beyond that, there are many, many fine writers in the Park Service. Amy Vanderbilt at Glacier is one, recently retired Bill Tweed another, and don't overlook Dick Sellers and his fine books on the NPS. Indeed, we'd love to see some ranger contributions here at the Traveler.


Your observation, "...Hazard trees are those trees that, due to disease or structural failure, are at imminent risk of falling and striking stationary targets. The EA also identifies those "targets," such as public restrooms, that could suffer from the ill-timed collapse of a hazardous tree that was not properly felled in time," made me smile. When I was at Big Bend NP in Oct, several Port-A-Potties at the Cottonwood picnic area/campground had been washed off their mooring platforms by floods. If the comment section could accept images, I'd one or two.


I'll be smiling for days thinking of your very clever & amusing post, Ted. Thanks!


Sorry, you lost me on this one. I myself are more than happy that federal agencies, like the NPS, are required to go through such a thoughtful process, because the alternative often seems to result in harm to the parks and resources. This is also the only way that the public can play a meaningful (or at least theoretically meaningful) role in oversight and involvement in the management process. Streamlining when it comes to things like this usually benefits a single user or group to the detriment of the public.


That's funnier than most attempts at humor I've read recently! You ought to submit a version of this story to national magazines like The Atlantic or the libertarian-oriented Reason. I wouldn't bother with Harper's, though; unless it's changed, the editors wouldn't see the humor.


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