CAAV Comments to US Forest Service

CAAV Comments on Draft Forest Service Environmental Assessment for North Shenandoah Mountain Restoration and Management Project

by Joy Loving, on behalf of CAAV, submitted 10/25/2019

The Climate Action Alliance of the Valley (CAAV) is a local grassroots non-profit organization whose volunteer Steering Committee members focus and act on a variety of issues that are connected to the current climate crisis.  We are located in the Central Shenandoah Valley.  CAAV’s mission is to limit the impact of humans on Earth’s climate and minimize the effects of inevitable climate change in order to protect the future for Earth and its inhabitants.  The vision of CAAV is to create and nurture climate action in our Shenandoah Valley community so that we can become a regional leader in promoting climate change mitigation and resilience.  Our goals are to 1) train and mobilize community members to engage in local and regional efforts that promote climate change mitigation and resilience and 2) achieve policies and legislation that enable and advance the systemic changes required to promote climate stabilization and resilience.  CAAV’s website is:  https://climateactionallianceofthevalley.org/.

As such, we are concerned with many aspects of natural and human behavior that in some way affect the viability of our air, water, land, health (human and wildlife), and plants.  For this reason, we are offering our comments on the Forest Service’s (FS) Draft Environmental Assessment (EA) for the North Shenandoah Mountain Restoration and Management Project in Rockingham County, Virginia and Pendleton County, West Virginia.  CAAV does not represent itself as having expertise in forest management.  Rather, we offer our thoughts and recommendations guided by general principles of good stewardship of our natural resources, of which North Shenandoah Mountain’s acreage is clearly an important part.  We have reviewed the FS’s descriptions of the Project Purpose and Activity.  We note that the proposed restoration and other actions would occur on about 7% of the planning area.

Following are the considerations we believe the FS must both keep in mind and adhere to in carrying out the restoration and management efforts it envisions. 

  • In general CAAV is supportive of integrated resource management that “[i]ncludes timber harvesting, prescribed fire, road decommissioning, aquatic habitat improvements, wildlife habitat improvements, and nonnative invasive species”, provided that such activities do not have unintended consequences that ultimately do more harm to the forest than good.  We question whether the described project design [“to move the existing conditions within the North River Ranger District towards desired conditions described in the 2014 Revised Forest Plan for the George Washington National Forest (Forest Plan)] will yield the most beneficial results given advancements in the science of forest management and climate-change-related environmental impacts that have arisen since 2014.  At a minimum, the FS should document both the advancements and the impacts and address if/how the 2014 plan continues to be optimal.
  • Current relevant scientific consensus on any proposed action should inform and drive FS analysis and decisions around the necessity, location, and extent of any actions, including tree and plant removal, new plantings (including species, varieties, density, and quantity).  Any deviation from this consensus must be documented, including likely consequences; these will be important historical records for future FS actions and decisions.  For example, given what we understand is science to the contrary, should this project attempt to simplify the structural complexity of long-lived but not yet fully developed forest tree species only a century after most of the area was deforested?  If the FS believes it should, then the reasons should be clearly and publicly stated along with a clear plan for monitoring results and remediation if/when clearly necessary.
  • To the extent that the FS will “provide open canopy conditions through timber harvest and prescribed burning”, it must understand and consider the implications of prior de-forestations of the area that have occurred.  For example, where soil loss has occurred from logging and burning, nature needs long periods of time to restore forest stability and function.  The FS must determine, prior to such activities, the extent of soil compaction and degradation and the implications of the loss of leaf litter.  If the FS concludes that the anticipated gains outweigh the negatives, then the reasons should be clearly and publicly stated along with a clear plan for monitoring results and remediation if/when clearly necessary.
  • Overwhelmingly, scientists stress the criticality of preserving and restoring natural, native forests to mitigating the impacts of climate change.  Science also says that deforestation and forest degradation are major contributors to increased carbon dioxide. Thus questions arise as to the carbon emission amounts that the FS anticipates resulting from each of its planned actions and what effect do those amounts have given the lost carbon sequestration from the loss of the trees burned or timbered, especially from what mature trees would sequester if allowed to grow older?  It is our understanding that mature and old trees in temperate, deciduous forests are better at soil storage of carbon than other systems.   Other questions arise relative to proposed burns and timber harvesting, such as what are the projected effects on overall forest balance, a complex and ongoing occurrence from natural forces, especially given that this aspect of forests is so crucial to both carbon sinking and the nature and variety of the many plant and animal species that forests support. Tinkering with these natural processes can alter their innate ability to rebuilt soil, soil that burning and harvesting would likely degrade or even remove from the environment. Most proposed FS actions would result in a “simplified” forest structure.  So the draft EA proposes is not only silent about how much CO2 will be emitted through burning, logging, and soil disturbance, but the proposed actions, presumably intended to “manage” the many acres addressed in the draft may have the negative effects of upsetting the forest’s natural processes that are the basis of its structure and stability.  The FS must understand, quantify, and publicly provide the anticipated impacts on CO2 emissions and sequestration before it proceeds with finalizing and implementing the plan.
  • Clearly, there are situations in which controlled and even repeated deliberate burning of large parts of national forests may be justified.  Two arguments in favor of proactive burning are to remove built-up forest floor debris and to allow for native species to have a better environment in which to flourish.  On the other hand, timber harvesting will leave excessive debris behind.  And, without careful analysis of the proposed areas to be harvested, with appropriate limits on the age, size, and type of trees to be included and excluded, as well as adequate management of logging processes to insurance compliance with requirements, the intended results may not be realized.  If the FS believes the “leftovers” from timber harvesting would not pose a threat because of our relatively humid climate, the question arises as to why naturally occurring forest floor debris that is naturally occurring would pose such a threat.  The draft EA does not adequately explain the FS’s approach to prescribed burning, especially in terms of this seeming contradiction.  Nor is the draft clear as to how the FS will determine which areas “need” prescribed burning or timber harvesting.  Prior to undertaking either, in any part of the coverage acreage, the FS needs to fully understand, quantify, and publicly provide the anticipated impacts on the overall forest structure and balance of these activities prior to undertaking them.
  • Questions also arise about the effects on the forest system from the proposed activities of using “herbicides to treat non-native invasive plant species … and native plant competitors”, creating 2.15 miles of new roads, doing 19.1 miles of reconstruction (presumably repair and upgrade of existing roads), performing 25- 30 miles of “maintenance”, decommissioning 15 miles of roads, and building 15 miles of temporary roads.  Assuming these activities are essential, they will clearly be destructive of various, but unidentified (in the draft) parts of the ecosystems within and outside the forest areas in which they happen.  Even the many other activities that appear to be, and are arguably, both beneficial and necessary could have deleterious effects.  Examples include protecting riparian habitat, restoring fire‑dependent plant communities, applying thinning and regeneration treatments, and acting to create or expand habitats for existing species.  It is also not clear that other proposed activities (such as prescribed burns and timber harvesting) will not have unintended consequences such as habitat destruction of these or other animal or plant species or a negative re-balancing from the new species components that result. The FS must explicitly anticipate these effects and establish mitigation and restoration efforts that will precede and follow their occurrences, as well as plan for and budget ongoing assessment and management of any effects.

Thanks to Chris Bolgiano for her input. More about the project and its environmental assessment here.

Electric Vehicles Are Punishingly Overtaxed in Virginia

In response to James A. Bacon’s post How Should We Tax Electric Vehicles? on October 15, 2019, on his Virginian public policy website Bacon’s Rebellion.

The original post, published on October 18, is HERE.

by Alleyn Harned

In an October 15th post, James Bacon asked the question: How should we tax electric vehicles?

Bacon’s bottom line is reasonable, and it is worth noting that electric vehicles (EVs) and clean fuels already pay more than their fair share in Virginia with equivalent or excessive taxes, according to Consumer Reports. It is easy to agree with Bacon’s ideas of user fees and externalities, where EVs also pay, and where pollution externalities are integrated into state fee structures.

However, Virginia has not ignored the transportation revenue potential of EVs and reaps a high tax on these vehicles. Since the McDonnell administration, electric vehicles been assessed a punishing $64 a year fee in order to gather an approximate amount of revenue equivalent to somewhat more than traditional vehicles pay in gas tax. This fee has been used by the oil industry to justify high fees nationwide.

A recent Consumer Reports study in September showed that now in many states, electric-car fees often cost far more than what owners of gasoline-powered cars pay in gas tax. Virginia’s fee is 5% higher, even though EVs and clean fuel vehicles have great benefit to the Commonwealth through emissions reduction.

I suggest we should tax electric vehicles no greater than gasoline and diesel vehicles. Other financing mechanisms are great, but punishing cleaner vehicles fueled by domestic energy creates an unbalanced playing field favoring high cost oil.

Bacon suggests calculating and adjusting downward for cleaner air for both pollution and direct CO2 emissions from gasoline combustion and indirect emissions via the electric grid, any such calculations would have to be revisited periodically to reflect the greening of the grid. By this measure, the carbon fee today should be 60% higher on gasoline than on grid electricity, though further discounts could be tied to time of use charging, bringing electricity to zero emissions or negative emissions with GHG sequestration sources.

According to the U.S. Department of Energy, electric vehicles produce very low emissions in Virginia if you compare grid fuel to gasoline emissions.

Electric vehicles are cleaner for the air, with significant health benefits beyond the CO2 reductions. They generate no tailpipe pollution when operating, and pollution from electricity generation can be mitigated with improvements to the grid, timing of charging, and lower cost renewables like Dominion Energy’s announced 2.6-gigawatt wind project which can charge these vehicles at night. Virginia for the most part is not coal intensive, with peak coal back in 1990’s. We are now using coal for less than 10% of our electric energy mix. Renewables like solar and wind are also now lower in cost than coal.

Beyond air quality, I suggest the Commonwealth consider reducing these punishing fees and incentivizing clean fuel vehicles like EVs because clean fuel vehicles are good for Virginia’s energy, economic, and environmental security.

Virginia produces nearly no oil in the state, but we spend around $33 million a day on 13 million gallons of imported gasoline and diesel, an enormous shifting of wealth from Virginians to oil-producers out of the state and in other countries. We produce many things that can produce electricity. This importation of highly polluting oil energy is an enormous drain on Virginia’s economy.

The United States just sent 1,000 troops, likely including Virginians, to Saudi Arabia to help defend Saudi oil. We maintain a fleet in the Strait of Hormuz to facilitate oil shipments. This international military investment is an externality that could be tracked and budgeted into the federal or state motorfuels tax of billions of our dollars.

Electric vehicles are affordable for all people today. Beyond Teslas, most EVs cost well under the $39,000 average price for a new car – with LEAF and Bolt available in VA under $30,000, and the Tesla 3 landing at $39,000 – the average price for a new car. Virginia-headquartered Volkswagen and Audi are planning a future with heavy electric vehicle investments. Ford and Shell just announced major partnership in advance of Ford’s new electric vehicles. Good used EVs are available for around $12,000. You can find new Nissan LEAFs posted for $18,900 and Prius Primes for $22,000 in Virginia on http://www.electrifyyourrideva.org .

Because electricity is low cost (about $1 per gallon equivalent) and vehicles can travel many miles on each $0.12 kilowatt of Virginia-made clean energy, driving electric pencils out to save $10k over 10 years in fuel costs. Fueleconomy.gov lets you see how much it would take to get each EV to 25 miles. Between fuel and initial cost in Virginia, a great EV total cost of ownership over 10 years is half that of the average new vehicle in the U.S.

Bacon is right to raise the discussion on user fees (miles) and externalities (pollution). The comments raised about a Vehicle Miles Traveled fees are sound and worth reviewing. Other states like Washington are phasing in a VMT over 10 years. EVs, which produce zero tailpipe emissions and use cleaner local energy, currently do pay greater than their fare share today in support of Virginia’s roads.

Alleyn Harned is director of Virginia Clean Cities.

Community Perspective: Climate Strike

Harrisonburg’s The Citizen | September 30, 2019

A contributed Perspectives piece by Joy Loving

What a wonderful two days Harrisonburg citizens have just had! On September 20 and 27, our youth came together at Court Square loudly and seriously to say they’re worried about their futures. And they want the “adults in the room” to help them save those futures. I hear they’re planning a third climate strike later this fall.

Having been part of a group of adults who worked with students from Harrisonburg High School, EMU, JMU, and Turner Ashby High School who organized the two events, I found the experience profoundly inspiring and energizing. Although I’ve worked with others on many projects to educate legislators and citizens about our climate emergency, never have I witnessed so many determined youngsters working cooperatively to get their message across. And I’m so pleased that local media covered both events.

The Second Climate Strike was followed the next day by the International Festival. This annual coming together of so many community members was just as inspiring as what the students did the day before. The “joie de vivre” on Saturday was evident on all the faces I saw. I was fortunate to speak with many attendees while volunteering for several local organizations who serve and work to improve our community—Climate Action Alliance of the Valley, Renew Rocktown, Earth Day Every Day, and Skyline Literacy. To a person, everyone was friendly, curious, and clearly happy to be enjoying the event.

It’s gratifying to know that events like these happen in the area. And I express my sincere thanks to all the students and volunteers who made them happen.

Joy Loving lives in Grottoes.

Find the original version in The Citizen HERE.

Community Support For Local Students’ Climate Strike

Daily News-Record, October 3, 2019

We should be proud of our youth who organized two recent local youth climate strikes. Whether you agree with them or not, they worked together to literally shout to all of us that they fear for their future and want us to help them save it. We should not disparage their efforts.

I met kids from Harrisonburg High School, Eastern Mennonite University, Turner Ashby High School, and James Madison University.

Two candidates running for office, April Moore and Brent Finnegan, were there. Their presence encouraged me because I expect all Virginia legislators to enact legislation to address our children’s concerns. I did not see their opponents, though perhaps they were there. If they were not there, we need to ask them why not.

The fervor and energy I saw inspired me and gave me some hope for my grandchildren’s future.

Joy Loving, Grottoes

Responsibility On Climate Change

Daily News-Record, September 13, 2019

Open Forum: H. Bishop Dansby

For a number of years now, local citizens have urged our representatives at the local, state and federal levels to develop policies on climate change and the related issues of renewable energy and energy efficiency. The city of Harrisonburg has been relatively receptive; for example, it formed the Environmental Performance Standards Advisory Committee. A key issue for the city is whether its municipal electric company, HEC, will transform itself to be part of the renewable energy future. The city School Board took a big step forward in building its new elementary school to a high level of energy efficiency, but then it missed a golden opportunity to outfit the new school and others with solar energy.

At the state level, Sen. Mark Obenshain has taken the position that nothing can be done as to climate change at the state level, and that it will be decades before solar energy is practical. At the federal level Rep. Goodlatte and his successor, Ben Cline, believe that action taken on climate change, “if it exists,” would unduly damage the economy.

Meanwhile, Rockingham County, skeptical that policies related the climate change have anything to do with county governance, has been confronted sooner than they ever imagined with climate related issues, such as unprecedented stormwater management challenges, the need for a solar system ordinance, and at least one application for the installation of utility scale solar system (solar farm).

The county denied the application of the solar farm ostensibly on the grounds that it would not be the best use of agricultural land, which presumably means the use is not consistent with the county’s comprehensive plan. If the county had a climate change policy, it would weigh the impact on agriculture against the value of providing renewable energy to the electric grid.

What is Rockingham County’s obligation with respect to climate? For starters, you could say that Rockingham has an obligation to produce enough renewable energy to meet its own energy needs. The state of Virginia has a population of 8,500,000 which consumes 111 billion kWh of electric energy per year. Rockingham County has a population of 85,000, which suggests it consumes about 1.11 billion kWh. If you do the math, the amount of acreage required of utility scale solar to provide all of Rockingham’s electric energy would be in the order of 5,000 acres. The county Board of Supervisors could say that it is reasonable for Rockingham to allow as much as 5,000 acres to be consumed by solar farms. Rockingham has a total area of 545,000 acres, of which 222,000 is agricultural land, so the 5,000 acres of solar would represent only 1 percent of the land in the county, or 2 percent of the agricultural land.

Provisions in the comprehensive plan that reflect this kind of obligation would allow the county to grant applications for solar farms without the fear of threatening agriculture, while at the same time doing its part to fight climate change.

H. Bishop Dansby lives in Keezletown.

Champions of Us All

Daily News-Record, April 1, 2019

Open Forum: Irvin Peckham

I read Michael Meredith’s open forum, (“Tony Wilt A Champion for Business,” March 14) in which he promoted Tony Wilt’s 26th District voting record, calling him “a champion for business.” Certainly, our representatives should support local business owners; but they should also support other citizens, education, community infrastructure and environmental preservation. At times, these elements may seem in conflict with one another; how a candidate negotiates these conflicts influences how many of us will vote.

Like Wilt and Meredith, I am not a fan of big government; but I do support government that works in the interest of all citizens, protecting consumers against fraudulent business practices, prioritizing public education, supporting community development and protecting the environment.

Wilt says he supports a “balanced approach to environmental and water quality issues.” A “balanced” approach implies that he might tolerate some degree of water pollution and environmental destruction if government regulations would hamper business profits. To suggest that we should balance current benefits at the expense of environmental preservation takes one down the infamous slippery slope. At what point is environmental destruction less important than business profit? Are we not concerned about preserving our environment for our children? Or is it: After us, the storm?

Because concrete contributes to CO2 production, global warming and water run-off, it should go without saying that Wilt, the owner of a concrete company, has an interest in voting against bills protecting our environment. Although loosely related through energy consumption, Delegate Wilt’s adherence to a “balanced” approach might explain his recent votes restricting solar development in Virginia, siding with Dominion and Appalachian Power over organizations promoting renewable energy.

Wilt’s vote is one example of how he might resolve issues when different interests, including his own, are in conflict. I am equally concerned about his positions on public education, the minimum wage, and Medicaid expansion. Although I applaud his position on testing, his attempts to divert monies from public education will undermine local schools, accounting for his low rating of 50 percent from the Virginia Education Association.

In support of Wilt’s positions on the minimum wage and Medicaid expansion, Meredith says that a wage of $15 an hour is “ridiculously high,” a claim that makes me shiver, and that Medicaid expansion would increase health cost, a claim not supported by the Kaiser Foundation research and the experience of other states in spite of recent efforts to undermine the Affordable Care Act. But even if Medicaid expansion increases costs, I believe that in the interest of the whole community, such an expansion would be worth supporting.

Although I respect champions of small business, I am looking for a representative who will be champions of us all. Mr. Meredith suggests that these priorities are socialist; I see them as caring for others, including our children and their children.

Irvin Peckham lives in Harrisonburg.

Irvin serves on the Steering Committee of the Climate Action Alliance of the Valley.

Common Sense Vs. Partisan Nonsense

Daily News-Record, March 23, 2019

Open Forum: Dave Pruett

On Feb. 13, 26th-District Sen. Mark Obenshain voted for an extraordinarily shortsighted bill. House Bill 2611 “prohibits the governor or any state agency from adopting any regulation establishing a carbon dioxide cap-and-trade program … ”

The bill intentionally hamstrings Virginia from joining the Regional Greenhouse Gas Initiative. It passed narrowly on party- line vote.

What is RGGI? It is a market-based consortium of 10 Northeastern states—Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont— organized to reduce greenhouse gases by capping overall emissions and trading “allowances.” Since 2005, carbon emissions in RGGI states have fallen by 40 percent while their economies have grown by eight.

What’s so disagreeable about RGGI? Carbon reduction? Economic growth and new jobs? Health benefits? Were no climate catastrophe looming, RGGI would still make sense in terms of energy efficiency, economic impacts, and health. But in the wake of two recent and terrifying climate studies — the National Climate Assessment and the 2018 Report of the International Panel on Climate Change — not to commit to a proven program of carbon reduction borders on indefensible.

Yet, at national and state levels, the GOP seems firmly committed to the fantasy that climate change is a hoax. Never mind that 73 percent of Americans think global warming is happening now, and most are worried, according to a national survey called Climate Change in the American Mind.

Never mind the consensus of America’s premier scientific bodies that burning fossil fuels is the primary cause. Among these agencies: The National Academy of Sciences, American Physical Society, American Geophysical Union, NASA, National Oceanographic and Atmospheric Administration and National Center for Atmospheric Research.

Never mind as four decades of predictions by climate scientists materialize before our very eyes. Seasons are shifting, ice caps melting, hurricanes stronger and wetter, wildfires larger and more devastating and tides are inundating Miami and Norfolk.

Never mind the assessment of our armed forces that changing climate is a global “threat multiplier” and rising sea level puts Norfolk Naval Base at risk, according to a Pentagon report from 2014.

Why then deny? Because denial pays handsomely. According to the watchdog agency vpap.org, eight of Obenshain’s top 25 campaign contributors are linked to fossil fuels, including Koch Industries, Dominion Energy and Consol Energy.

And so Obenshain and GOP colleagues: Heed former Virginia Air Quality Board member Rebecca Rubin: “If you cannot lead from a position of environmental justice in this day and age, then you cannot lead.”

Come November, I will cast my vote for a senatorial candidate of integrity who refuses the fossil-fuel lobby’s 30 pieces of silver, blood money for selling out the futures of our children and grandchildren. I will vote for April Moore, a candidate of common sense, not partisan nonsense.

Dave Pruett lives in Harrisonburg.

Delegate Wilt Votes Against Jobs

The Daily News-Record (Harrisonburg, VA) – February 22, 2019

By Sally Newkirk

On Jan. 24, I went to Richmond for Solar Lobby Day, together with several Harrisonburg and Rockingham County residents. We sat through seven hours of the House of Delegates’ Commerce and Labor Subcommittee for consideration of over 40 bills related to energy efficiency and renewable energy, broadband and other matters related to Virginia’s utilities. The subcommittee members’ votes would determine what bills would be passed on for consideration by the full committee and, if passed there, eventually would be voted on by all Delegates. Del. Tony Wilt is a member.

I was interested in about a dozen bills that were introduced to help Virginia’s distributed solar industry continue to grow by removing existing barriers. Energy and solar kept being pushed back to late into the day. Finally, after 6 p. m., they were introduced, and then advocated for by businesses ( Google and Microsoft, and installers), environmental groups, and political groups ( Conservatives for Renewable Energy, Earth Stewardship Alliance, and the Green Party of Arlington, to name a few). Dominion and Appalachian Power voiced consistent opposition to bills designed to remove barriers to solar.

One example: Virginia law now sets a 1 percent cap on distributed solar ( rooftop) that can be “ net- metered” in a utility service area. Under net metering, utility customers who produce their own energy from solar or wind can receive credit for that production against electricity usage, thus lowering their bills. The catch is that, if one lives in a service area in which the 1 percent cap has been reached, the utility can deny net metering. Another example: There are limits in Virginia’s law on third- party financing using power purchase agreements that hamper efforts by nonprofit and municipal institutions to reduce their energy costs.

Advocates for these and other bills considered that day made the clear points that these barriers represent unnecessary and market- unfriendly rules that discourage growth of solar companies and, by extension, jobs. Solar and wind industry jobs can’t be outsourced and local installers who employ these workers can boost their local economies because the wages earned will be spent locally.

Needless to say, all these bills were voted down along party lines, most Republicans voting nay, including our local delegate, Wilt. Let me make this clear: With his vote, Mr. Wilt opposed jobs, job creators, schools, nonprofits, lower- and middle-income folks who could benefit from lower electricity bills — in other words, many of his constituents. Instead, he voted in favor of government regulations and the for- profit monopoly for- profit utilities ( that put investor interests first).

My question for Mr. Wilt: How he would have grown his business if the state slapped a cap on how much concrete he could pour? I would also challenge the voters to look at what your representative stands for before you cast your ballot. It seems like just because Tony Wilt has an “ R” after his name doesn’t mean he is for growing our local economy, and antigovernment regulations, because in this case, he didn’t.

Sally Newkirk lives in Mount Crawford.

Sally serves on the Steering Committee of the Climate Action Alliance of the Valley