High Valley Integrated Restoration Project LN&C Period 3/29/2016 to 4/28/2016 Comment Analysis High Valley Integrated Restoration Project Comment Analysis
This document analyzes public comments received during the legal notice and comment period for the High Valley Integrated Restoration Project (High Valley) The EA mailed to individuals, agencies, and/or groups on March 23, 2016, and legal notices soliciting comments were published in The Idaho Statesman on March 28, 2016. Thirty organizations, individuals, and/or agencies were sent hardcopy letters with attachments requesting input regarding the project and another 255 emails were sent with the same information via GovDelivery
Tribal consultation was completed according to the consultation protocols established with each tribe. The Nez Perce Tribe and Shoshone Bannock Tribes were notified of this project in writing on February 24, 2015. The Shoshone Paiute Tribe was consulted during the Wings and Roots meeting March 12, 2015. This summary outlines the process that was used to analyze comments, potential issues, and alternatives that were suggested by the public for the Project. Interested or affected individuals, groups, and other agencies were sent notification of the availability of the EA for the High Valley Integrated Restoration Project. The announcement was sent to those who responded to the Boise National Forest Schedule of Proposed Actions (SOPA), subscribed to GovDelivery, or would otherwise be potentially affected. This project has been listed in the SOPA since January 2015. Six responses were received by the closing date of the comment period.
Table 1. List of Respondents to Public Scoping for the High Valley Project.
Letter # Agency, Organization, Business, or Individual Date 1 Irene Jerome, American Forest Resource Council (AFRC) 4/28/2016 2 Lindsey Warness, Boise Cascade 4/22/2016 3 Aaron Scheff, Idaho Dept. of Environmental Quality (DEQ) 4/21/2016 4 Alan Ward, Roger Jackson, and Laura Baker Boise County Commissioners 4/12/2016 Jeff Cook, Idaho Parks and Recreation (Outdoor Recreation Analyst, 5 4/12/2016 Recreation Bureau), 6 Dick Artley, Individual 4/12/2016
Table 2 identifies and documents specific statements from each of the letters received from the public in response to the comment period. The R esponsible Official identified statements as comments, questions, and requests for information, alternative suggestions, potential issues, and literature citations. The Responsible Official then provided rationale for determining the status of the comment. Copies of the le tters ear in the High Valley planning record located at the Emmett Ranger District Office. For literature citations a comment is provided by the Responsible Official on how the literature will be addressed. For each issue, the cause and effect for the issue topic as put forth by the respondent was noted. The Responsible Official then made a determination of t he status of each issue by evaluating
1 High Valley Integrated Restoration Project Comment Analysis them against the following criteria to determine whether or not the concern would be a major factor in the analysis process: • Has the concern been addressed in a previous site-specific analysis, such as in a previous environmental impact statement or through legislative action? • Is the concern relevant to and within the scope of the decision being made and does it pertain directly to the Proposed Action? • Can the concern be resolved through mitigation (avoiding, minimizing, rectifying, reducing or eliminating, or compensating for the proposed impact) in all alternatives? • Can the issue be resolved through project design in all alternatives? Major issues are points of unresolved conflict with the Proposed Action identified during external public involvement efforts. A description of alternatives suggested by the respondents is documented. The Responsible Official then determined if these proposed alternatives should be studied in detail using the following criteria: • Those that fail to meet the purpose and need, • Are technologically infeasible or illegal, or • Would result in unreasonable environmental harm.
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Table 2. Summary of Letters Received during the Opportunity to Provide Public Comments
Comment # Identification Summary of Comment Responsible Official’s Disposition
Respondent #1: Irene Jerome, American Forest Resource Council (AFRC), letter dated 4/28/2016
1-1 Comment On behalf of the American Forest Resource Council (AFRC) and its Thank you for your support. members, thank you for the opportunity to comment on the High Valley Integrated Restoration Project (High Valley). AFRC is a regional trade association whose purpose is to advocate for sustained yield timber harvests on public timberlands throughout the West to enhance forest health and resistance to fire, insects, and disease. We do this by promoting active management to attain productive public forests, protect adjoining private forests, and assure community stability. We work to improve federal and state laws, regulations, policies and decisions regarding access to and management of public forest lands and protection of all forest lands. Many of our members have their operations in communities within and adjacent to the Boise National Forest and management on these lands ultimately dictates not only the viability of their businesses, but also the economic health of the communities themselves. AFRC strongly supports Alternative B with suggested improvements outlined below. We have the following comments on the High Valley Project:
1-2 Suggested AFRC appreciates the detail that was put into the Purpose and Need, Comment Acknowledged wording which spans a full four pages. However, at the project level the Purpose At this stage in the process making major edits to edit and Need should be relatively concise. AFRC recommends shortening the Purpose and Need statements could create the scope and scale of the language. Please strengthen the language in confusion with the public and other interested purpose 4 on supporting local infrastructure. parties. Purpose 4 has detailed language of how this project would contribute to supporting the local infrastructure. It also discusses how this contributes to restoration objectives of the Forest Plan. Economic analysis in chapter 3 of the EA describes the economic effects of the project, and addresses potential jobs supported by the alternatives, economic viability of the project, and potential wood products created as a by-product of the vegetation restoration activities.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
1-3 Comment AFRC supports work in Riparian Conservation Areas (RCAs) and strongly Support of the Proposed Action is Acknowledged. encourages those activities, including the removal of commercial material, Alternative B would remove commercial material as described in Alternative 2. As a matter of perspective, “commercial” from the 2nd SPTH within RCA’s as described in material is defined as trees equal to or greater than eight inches at Table 2 of the EA. Alternative C would not remove diameter breast height (DBH). The minimum length requirement for commercial material from the RCAs. Alternative B utilization specifications is six feet. These are small pieces and their would produce an estimated 1.9 mmbf more removal from the RCA is to help meet the objectives of the High Valley sawtimber than Alternative C. Project. The Forest Service will implement mitigating measures, such as not allowing heavy equipment in the RCA, to protect the resource values in the RCA. Limiting RCA activities to the removal of “noncommercial material” only would not meet the project objectives. Additionally, though the economic value of commercial material from the RCAs will not be large, it will provide revenues that will help accomplish other resource restoration projects on the High Valley Project.
1-4 Question A field trip to the area with a variety of interested stakeholders, the Boise Proposed vegetative treatments would be Forest Coalition, and various Forest Service personnel on July 14, 2014 designed to retain enough canopy cover to provided a good overview of the project proposal. There is a significant reduce the potential for extensive brush amount of prescribed burning proposed to further reduce fuels in the establishment. project area. However, during the field trip it was highlighted that the An attempt was made to notify all of the shrub and brush response after fire is rapid and prolific in this area and surrounding private landowners during the subsequent issues with natural regeneration from desired species is scoping period. The hard copy mailing list is significant. What measures will be taken to control undesirable brush and available in the project record. Some of the local shrub species after burning? landowners have taken actions to reduce the What steps were taken and what responses were received from the wildfire hazard on adjacent, non-NFS land. Some private landowners in the Wildland Urban Interface (WUI) areas adjacent of the local landowners participated and provided to the High Valley project? Aggressively treating the WUI was discussed recommendations as part of the Boise Forest extensively during the July 14 field trip. Coalition during the project’s development.
1-5 Comment AFRC supports providing road access for the state of Idaho Endowment Thank you for your support. Lands. This access will provide additional opportunities for wood products The road easement to state of Idaho Endowment to support the forest products industry, to support local communities, and Lands has been included in the analysis of effects further reduce fuel loads adjacent to private lands. In addition, access for in chapter 3 of the EA. The project has discussed fire suppression will be improved and enhanced. AFRC supports the state easement and cumulative effects to including and analyzing this access grant in the project environmental individual resources in chapter 3 of the EA. assessment (EA) in light of recent court decisions regarding access grants by the Nez Perce-Clearwater Forest for harvest on state lands.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
1-6 Comment Table 4 on page 27 of the EA clearly demonstrates that Alternative B best Thank you for your support. meets the Purpose and Need of the High Valley Project. Alternative B exceeds Alternative C in increasing ponderosa pine in specified vegetation groups; in changing structure and accelerating progression to large tree classes; in improving diversity in aspen stands; in restoring pine forest habitat for focal species such as white headed wood pecker; in managing vegetation in RCAs to reduce the threat of uncharacteristic wildfire and restore ecological functions; in introducing fire disturbance to promote ecological processes; and in providing a predictable and recurring supply of wood products. Alternative B equals Alternative C in the other needs identified.
1-7 Comment AFRC applauds the Forest Service for expediting the NEPA process on Thank you for your support. the High Valley project, which is consistent with the Chief’s goal of increasing “pace and scale” of forest restoration. The use of an EA is appropriate here as the project and treatment areas are well within the range where courts have approved using an EA, the project uses well- understood silvicultural treatments, and the impact on the environment is not significant. Thank you for the opportunity to comment on this project.
Respondent #2: Lindsay Warness, Boise Cascade, letter dated 4/22/2016
2-1 Comment Thank you for the opportunity to provide comments on the upcoming High Thank you for your support. Valley Integrated Restoration Project on behalf of Boise Cascade, LLC. Boise Cascade manufactures engineered wood products, plywood, lumber, and particleboard and distributes a broad line of building materials, including wood products manufactured by the company's wood products division. The company is privately owned and headquartered in Boise, ID, and operates mills that count on wood produced from the National Forests. I support the purpose and needs identified for the project area and as a member of the Boise Coalition, we also support the comments submitted by that organization. Below are my additional comments.
2-2 Comment • I support Alternative B because it best meets the purpose and Thank you for your support. need by removing excess fuels as well as supporting the local economy through outputs.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
2-3 Comment • I am concerned with the emphasis on old forest. While it I The old forest condition is one of several forest laudable to work towards creating additional old forest, it is structural stages. It is desired to have all important that the Forest Service take into account the variety of structural stages present across the Forest at any stand types that are normal in the forests. Concentrating on one point in time. The Boise National Forest is structural stage is detrimental to the ecosystem and wildlife that currently deficit in the old forest condition, which need the other structural stages to function in the landscape. is one of the reasons for its emphasis in management. Furthermore, it is much easier to manage for earlier stages of structural development than later stages, highlighting the need to develop old forest habitat.
2-4 Comment • I'm impressed that this project will actually cover the additional Thank you for your support. project costs as well as provide revenue. These are the types of projects that the Forest Service should strive to produce at all times because it shows that restoration and economic returns are not mutually exclusive.
2-5 Comment • I support the use of Temporary Roads to access and remove Thank you for your support. excess fuels. These roads are necessary to meet the ecological needs of the national forest as well as assist in removing excess fuels.
2-6 Comment • I also support the use of prescribed fire in the project area. The Forest Service would design an However, I'd like the Forest Service to prioritize the work on this implementation strategy to effectively and landscape with regards to prescribed fire, I'm concerned that the efficiently manage prescribed fire across the Forest Service will be unable to implement the prescribed fire in a project area. This would often include treating timely manner due to regulatory restrictions. suitable locations, as identified within the Vegetation and Fire/Fuels Technical Reports, following thinning and slash disposal treatments.
2-7 Comment • I fully support the use of the "Good Neighbor Authority" that Thank you for your support allows the state to manage some of the implementation on The Forest Service will be working with the Idaho federal lands. Department of Lands to assess the opportunities that exist with this project and adjacent endowment lands to utilize Good Neighbor Authority.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
2-8 Comment • I agree with the mechanical removal of material from the outer Comment noted: Based on shade data collected portion of the RCAs as well as the work to reduce some of the across the project, shade will be maintained fuel loadings in these areas. Leaving excess fuels in these while reducing hazardous fuels near important sensitive areas can be detrimental when fire is re-introduced into riparian habitat the system. Reducing the likelihood of uncharacteristic fire in these areas will help to maintain the necessary shade and water temperatures to maintain the ecosystem.
2-9 Comment • I appreciate that the Forest Service is looking at multiple different Both action alternatives propose more intensive types of prescriptions for the project area. Many times I see large surface fuel treatments within the wildland- projects that have one prescription that is generalized throughout urban interface. the project area, it is important that we maintain the heterogeneity on the landscape through different management tactics. I suggest that the Forest Service look at implementing some of the more aggressive treatments in the WUI to reduce the fire danger for the adjacent private properties.
2-10 Comment • I support reducing the fuel loadings as well as reducing the Thank you for your support. stocking levels to increase habitat for white headed woodpeckers and the animals associated with more open forests.
2-11 Comment • I am pleased with the amount of proposed acres treated in this Thank you for your support. project area. Normally I see projects where less than 10% of the project area is treated. This project appears to be well thought out and the amount of management has the potential to help pay for the other restoration needs in the project area.
2-12 Comment • Overall, I believe this project is a very good project that balances Thank you for your support. the needs of the wildlife, forest resiliency and the economic needs of the local communities. I look forward to seeing the outcomes
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Comment # Identification Summary of Comment Responsible Official’s Disposition
Respondent #3: Aaron Scheff, Idaho Department of Environmental Quality, letter dated 4/21/2016
3-1 Comment Thank you for the opportunity to respond to your request for comment. Thank you for your comment. While DEQ does not review projects on a project-specific basis, we attempt to provide the best review of the information provided. DEQ encourages agencies to review and utilize the Idaho Environmental Guide to assist in addressing project-specific conditions that may apply. This guide can be found at http://www.deq.idaho.gov/ieg/
3-2 Comment 1. Air Quality All rules pertaining to air quality have been reviewed and will be met. • Please review IDAPA 58.01.01 for all rules on Air Quality, especially those regarding fugitive dust (58.01.01.651), trade waste burning (58.01.01.600-617), and odor control plans (58.01.01.776). For questions, contact David Luft, Air Quality Manager, at 373-0550. • IDAPA 58.01.01.201 requires an owner or operator of a facility to obtain an air quality permit to construct prior to the commencement of construction or modification of any facility that will be a source of air pollution in quantities above established levels. DEQ asks that cities and counties require a proposed facility to contact DEQ for an applicability determination on their proposal to ensure they remain in compliance with the rules. For questions, contact the DEQ Air Quality Permitting Hotline at 1-877- 573-7648. IDAPA 58.01.01.614 sets out the rules for prescribed burning in Idaho. Please ensure all prescribed burning is done in compliance with the rules, and in compliance with the Operations Guide of the Montana/Idaho Airshed Group.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
3-3 Comment 2. Wastewater and Recycled Water Wastewater sewage services are not expected to be needed as a result of this project. • DEQ recommends verifying that there is adequate sewer to serve Authorization of sewage and/or wastewater or this project prior to approval. Please contact the sewer provider recycled water handling facilities is not a part of for a capacity statement, declining balance report, and willingness any of the proposed alternatives (EA, Chapter 2). to serve this project. Authorization of sewage and/or wastewater or • IDAPA 58.01.16 and IDAPA 58.01.17 are the sections of Idaho recycled water handling facilities is not a part of rules regarding wastewater and recycled water. Please review the any of the proposed alternatives for the High these rules to determine whether this or future projects will Valley EA (EA, Chapter 2). require DEQ approval. IDAPA 58.01.03 is the section of Idaho rules regarding subsurface disposal of wastewater. Please review this rule to determine whether this or future projects will require permitting by the district health department. • All projects for construction or modification of wastewater systems require preconstruction approval. Recycled water projects and subsurface disposal projects require separate permits as well. • DEQ recommends that projects be served by existing approved wastewater collection systems or a centralized community wastewater system whenever possible. Please contact DEQ to discuss potential for development of a community treatment system along with best management practices for communities to protect ground water. • DEQ recommends that cities and counties develop and use a comprehensive land use management plan, which includes the impacts of present and future wastewater management in this area. Please schedule a meeting with DEQ for further discussion and recommendations for plan development and implementation. For questions, contact Todd Crutcher, Engineering Manager, at 373- 0550.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
3-4 Comment 3. Drinking Water This project does not propose any development that would affect drinking water supplies. • DEQ recommends verifying that there is adequate water to serve this project prior to approval. Please contact the water provider • No residential or commercial for a capacity statement, declining balance report, and willingness development is proposed. to serve this project. • This project would not access any • IDAPA 58.01.08 is the section of Idaho rules regarding public drinking water system. drinking water systems. Please review these rules to determine • This project does not propose the whether this or future projects will require DEQ approval. development, modification, or use of any • All projects for construction or modification of public drinking water drinking water system or private well. systems require preconstruction approval. • DEQ recommends verifying if the current and/or proposed drinking water system is a regulated public drinking water system (refer to the DEQ website at http://www.deq.idaho.gov/water-quality/drinking- water.aspx). For non-regulated systems, DEQ recommends annual testing for total coliform bacteria, nitrate, and nitrite. • If any private wells will be included in this project, we recommend that they be tested for total coliform bacteria, nitrate, and nitrite prior to use and retested annually thereafter. • DEQ recommends using an existing drinking water system whenever possible or construction of a new community drinking water system. Please contact DEQ to discuss this project and to explore options to both best serve the future residents of this development and provide for protection of ground water resources. • DEQ recommends cities and counties develop and use a comprehensive land use management plan which addresses the present and future needs of this area for adequate, safe, and sustainable drinking water. Please schedule a meeting with DEQ for further discussion and recommendations for plan development and implementation. For questions, contact Todd Crutcher, Engineering Manager at 373-0550.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
3-5 Comment 4. Surface Water If dewatering activities are required to implement a portion of the proposed action (such as • A DEQ short-term activity exemption (STAE) from this office is construction of stream crossings a short-term required if the project will involve de-watering of ground water activity exemption will be acquired from DEQ prior during excavation and discharge back into surface water, to construction. A detailed analysis of the effects including a description of the water treatment from this process to of this project on surface water is included in the prevent excessive sediment and turbidity from entering surface Hydrology Technical Report. water. The Forest Service will comply with all applicable • Please contact DEQ to determine whether this project will require NPDES permitting requirements in place at the a National Pollution Discharge Elimination System (NPDES) time implementation is initiated and at all times Permit. If this project disturbs more than one acre, a stormwater during the implementation process. permit from EPA may be required. A detailed analysis of the effects of this project on • If this project is near a source of surface water, DEQ requests surface water will be included in the Hydrology that projects incorporate construction best management practices Technical Report (including relevant BMPs, (BMPs) to assist in the protection of Idaho’s water resources. identified as design features in the EA). The Additionally, please contact DEQ to identify BMP alternatives and proposed activities will incorporate BMPs to to determine whether this project is in an area with Total protect water quality wherever applicable utilizing Maximum Daily Load stormwater permit conditions. the BMPs approved by the State of Idaho as well The Idaho Stream Channel Protection Act requires a permit for as the National Core BMP Technical Guide most stream channel alterations. Please contact the Idaho (USDA Forest Service 2012). The project area Department of Water Resources (IDWR), Western Regional Office, does not include streams with TMDLs or streams at 2735 Airport Way, Boise, or call 208-334-2190 for more with guidance from downstream TMDLs. information. Information is also available on the IDWR website at: Should project related activities include stream http://www.idwr.idaho.gov/WaterManagement/StreamsDams/Strea channel alteration; the Idaho Department of Water ms/AlterationPermit/AlterationPermit.htm Resources would be contacted. Should any project related activities include • The Federal Clean Water Act requires a permit for filling or dredging or filling in waters of the United States, a dredging in waters of the United States. Please contact the US permit would be requested from the U.S. Army Army Corps of Engineers, Boise Field Office, at 10095 Emerald Corps of Engineers as required by Part 404 of the Street, Boise, or call 208-345-2155 for more information Clean Water Act. regarding permits. For questions, contact Lance Holloway, Surface Water Manager, at 373- 0550.
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3-6 Comment 5. Hazardous Waste And Ground Water Contamination The proposed action would not produce hazardous waste. An approved hazardous waste • Hazardous Waste. The types and number of requirements that control plan would be completed as part of the must be complied with under the federal Resource Conservations normal operating procedures for a timber sale on and Recovery Act (RCRA) and the Idaho Rules and Standards for National Forest Lands. Any incident involving Hazardous Waste (IDAPA 58.01.05) are based on the quantity hazardous waste would be cleaned up as and type of waste generated. Every business in Idaho is required required by the rules and regulations governing to track the volume of waste generated, determine whether each hazardous waste disposal. type of waste is hazardous, and ensure that all wastes are Trash or solid waste would not be disposed of by properly disposed of according to federal, state, and local burial or burning with the exception of the normal requirements. and customary practice of burning activity fuels • No trash or other solid waste shall be buried, burned, or and natural fuel loads. otherwise disposed of at the project site. These disposal methods Hazardous material would be stored as required are regulated by various state regulations including Idaho’s Solid by state and federal regulations. An approved Waste Management Regulations and Standards, Rules and plan would be required for the storage and Regulations for Hazardous Waste, and Rules and Regulations for transportation of hazardous materials. No storage the Prevention of Air Pollution. of hazardous materials or refueling of equipment • Water Quality Standards. Site activities must comply with the would occur within the 260-foot riparian Idaho Water Quality Standards (IDAPA 58.01.02) regarding conservation area (RCA) of any waterbody unless hazardous and deleterious-materials storage, disposal, or specifically approved by the Forest Service. Any accumulation adjacent to or in the immediate vicinity of state such storage or refueling within the RCA would waters (IDAPA 58.01.02.800); and the cleanup and reporting of only be approved with adequate spill prevention in oil-filled electrical equipment (IDAPA 58.01.02.849); hazardous place. materials (IDAPA 58.01.02.850); and used-oil and petroleum The activities associated with the proposed action releases (IDAPA 58.01.02.851 and 852). are not expected to result in the release, spilling, • Petroleum releases must be reported to DEQ in accordance with leaking, emission, discharge, escape, leaching, or IDAPA 58.01.02.851.01 and 04. Hazardous material releases to disposal of a contaminant into the environment in state waters, or to land such that there is likelihood that it will a manner that causes a ground water quality enter state waters, must be reported to DEQ in accordance with standard to be exceeded, injures a beneficial use IDAPA 58.01.02.850. of ground water, or is not in accordance with a permit, consent order or applicable best • Ground Water Contamination. DEQ requests that this project management practice, best available method or comply with Idaho’s Ground Water Quality Rules (IDAPA best practical method 58.01.11), which states that “No person shall cause or allow the As designed, this project would not release or release, spilling, leaking, emission, discharge, escape, leaching, dispose of any contaminant into the environment. or disposal of a contaminant into the environment in a manner Should an unintended release or spill occur that causes a ground water quality standard to be exceeded, notifications would be made as required by injures a beneficial use of ground water, or is not in accordance established protocol. with a permit, consent order or applicable best management practice, best available method or best practical method.” For questions, contact Dean Ehlert, Waste & Remediation Manager, at 373-0550.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
3-7 Comment 6. Additional Notes Underground storage tanks would not be approved with the Proposed Action. Above • If an underground storage tank (UST) or an aboveground storage ground storage tanks would incorporate leak tank (AST) is identified at the site, the site should be evaluated to proof containment sufficient to contain 125% of determine whether the UST is regulated by DEQ. EPA regulates the tank’s capacity. All required permits would be ASTs. UST and AST sites should be assessed to determine acquired by the contractor. whether there is potential soil and ground water contamination. Appropriate BMPs as required by the Idaho Please call DEQ at 373-0550, or visit the DEQ website Forest Practices Act approved for the activities (http://www.deq.idaho.gov/waste-mgmt- remediation/storage- proposed in this project would be implemented. tanks.aspx) for assistance. Vehicle cleaning would occur off-site in an • If applicable to this project, DEQ recommends that BMPs be appropriate facility, or a recovery system would implemented for any of the following conditions: wash water from be used. cleaning vehicles, fertilizers and pesticides, animal facilities, composted waste, and ponds. Please contact DEQ for more information on any of these conditions.
3-8 Comment We look forward to working with you in a proactive manner to address Thank you for your comment. potential environmental impacts that may be within our regulatory authority. If you have any questions, please contact me, or any our technical staff at 208-373
Respondent #4: Alan Ward, Roger Jackson, and Laura Baker, Boise County Commissioners, letter dated 4/12/2016
4-1 Comment During our regular meeting on April 5th, 2016 we reviewed a letter and Thank you for your support. invitation to comment from your office dated March 23rd, 2016, which
outlined a proposed High Valley Integrated Restoration Project in the Boise, Gem and Valley Counties. The Boise County Board of Commissioners would like to thank you for the opportunity to voice their concerns when and if there are any to the proposed project. As we understand the proposed area will have some rerouting of roads, some thinning as well as timber activity. The Boise County Board of Commissioners fully supports the proposed High Valley Integrated Restoration Project in the Boise, Gem and Valley Counties. We appreciate the opportunity to submit our comments to you and your agency keeping us informed of these types of activities. This treatment area is located in Boise County and we are hopeful the project moves forward immediately to protect all Boise County forests and surrounding areas.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
Respondent #5: Jeff Cook, Idaho Parks and Recreation (Outdoor Recreation Analyst, Recreation Bureau), email dated 4/12/2016
5-1 Comment The Idaho Department of Parks and Recreation (IDPR) staff reviewed Thank you for your comment. We acknowledge the High Valley Integrated Restoration Project Environmental that snowmobile riding is a popular form of Assessment (EA). The Emmett Ranger District proposes to conduct some recreation on the Boise National Forest. land management activities, including timber harvest in the High Valley Project Area. The project area is popular for snowmobiling. Some of the system roads in the project area serve as groomed snowmobile trails in the winter. We are pleased to see that Design Feature RR1 would be a part of this project. This design feature prohibits plowing and winter logging between December 15th and March 15th. The project would also prohibit log hauling on weekends and holidays according to Design Feature VM- 5. This design feature will lessen the conflict between recreation traffic and logging traffic. The IDPR appreciate the opportunity to review and comment on this EA. If you or your staff have any questions about our comments, please let me know. My contact information is in my signature line.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
Respondent #6: Dick Artley, Individual, letter with attachments dated 4/12/2016
NOTE: The following comments have been paraphrased due to their length. Full text of Mr. Artley’s comments are found in Appendix B of this document
6-1 Comment Please read and consider my comments on the pre-decisional EA for the Comment noted. proposed High Valley timber sale below. Remember these wise words as you read my comments: “God has cared for these trees, saved them from drought, disease, avalanches, and a thousand tempests and floods. But he cannot save them from fools. John Muir You hide the information in your hardcopy Project File at the district that tells the public whether you will be applying an herbicide that is sometimes lethal to mammals (including humans) … Roundup. At page 101 of your pre-decisional EA you say: “Refer to the noxious weeds technical report available in the project record for the detailed supporting analysis, including evaluations of herbicides used to treat noxious weeds as part of the Forest’s Integrated Noxious Weed Program.” This could easily been posted online in an Appendix. I will expect this in the final EA. Roundup is especially toxic to children (see Issue #4) at page 8 below. I cannot believe Supervisor Seesholtz would approve of you planting the cancer seed in babies.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-2 Comment Introduction Comment noted. Ranger Newton, of course you have already selected the alternative you will implement. You did this before you asked for scoping comments. Now you are passing the High Valley timber sale through the NEPA process to make it legal. Your IDT members (who know better) are helping you justify his decision. To the IDT members who are responsible to protect the amenity natural resources so loved by the public who provides the tax money for your salaries I ask you this. I understand why the names of the IDT members aren’t shown in Chapter 4. This EA violates NEPA more times than I have ever seen … and I have reviewed hundreds. This pre-decisional EA smoothes-over and minimizes the “environmental damage from logging” that will be caused by the High Valley timber sale.” A few IDT members know this but their position pays to well to jeopardize it by doing the right thing for future generations of Americans. The complete text of this USDA audit can be read at the following link: http://www.nytimes.com/1999/02/05/us/audit-faults-forest- service-on-logging-damage-in-us-forests.html Here’s the History of NEPA. Why is this new to you and a few of your IDT members?
6-2.1 Literature Agriculture Department's inspector general’s findings based on a 1999 New York Times article refers to 12 specific Cited audit of the USFS timber program. The first sentence of the audit findings timber sales from 1995-1999 and that Federal says this: auditors found logging was poorly done, streams “Federal auditors have found that the Forest Service frequently fails to and wildlife were not being adequately protected, assess, prevent or correct environmental damage from logging on the and mitigation measures were not incorporated. national forests.” The High Valley project will have Harvest http://www.nytimes.com/1999/02/05/us/audit-faults-forest-service- Inspectors and Timber Sale Administrators on the on-logging-damage-in-us-forests.html ground during the entire timber harvest process to ensure compliance. In addition project design features, BMPS, and monitoring are incorporated in the EA and followed up by resource specialists to ensure compliance.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-2.2 Literature Associate Chief Sally Collins describes how the new USFS deals To continue on with her speech after the selected Cited with timber reference Associate Chief Collins goes on to list Forest Service Associate Chief Sally Collins “The Future of Partnering several of the threats: Fire and Fuels, Invasive with the Forest Service” species, Loss of open space, non-managed A speech presented at the Annual Meeting of the National Association of recreation, the backlog in facilities and restoration Conservation Districts Atlanta, GA—February 8, 2005. projects, water quality problems and finally ozone http://www.fs.fed.us/spf/coop/library/NACDspeech.pdf and carbon. The High Valley projects addresses the issues of fire and fuels, restoration, and improving watershed resources through road decommissioning.
6-2.3 Literature Deputy Chief Jim Furnish reflects on his USFS employment Copy of book not provided by the Commenter. Cited http://www.towardanaturalforest.com/ The Forest Service is mandated to manage the NFS lands for multiple uses. The High Valley project was designed with this in mind. There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-3 Suggested Issue #1 ----- Logging road construction causes significant Alternative ecological harm. Please analyze an action alternative in detail that EA, Table 3 on page 26 indicates a total of 9.1 does not construct any new roads (temporary or system). miles. This includes 8.6 miles of temporary road Comment: Table 3 on page 26 indicates you plan to construct 9 miles of and 0.5 miles of new NFS road. The 8.6 miles of new road as part of the Proposed Action. A report authored by Gerald temporary road would be fully obliterated within Coghlan, WO Acting Director of Engineering in 1998 indicates there are three years after project competition see Design 372,956 miles of existing national forest system road (page 5). The Feature RM-5. agency currently constructs 2,000 miles of system road per year. At this The Fact sheet at: rate there are 409,000 miles now. In addition to that, there is at least http://www.fs.fed.us/eng/road_mgt/factsheet.s double this amount in unsurfaced, sediment producing, outsloped, html states that in 1998 the Forest Service temporary roads that have not been totally obliterated and “put to bed” constructed 215 miles of road which is less than where the fill is returned to the cut. The average distance to the moon (it the 2,000 miles stated in the comment. From varies) is 384, 403 miles … and you propose more. Isn’t there enough 1991 to 1997 on average 2,700 miles have been road? Are you clinically obsessed to produce volume at any cost to the decommissioned annually. In addition, the fact public land? sheet references approximately 60,000 miles of See the 1998 report at this link: unclassified roads including temporary roads http://www.fs.fed.us/eng/road_mgt/roadsummary.pdf which is less than the 818,000 miles stated as an Please read Opposing Views Attachment #4. estimate in the comment.
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A “no road construction and reconstruction” alternative will likely reduce There are four purposes identified for this project the sale volume some. However, it stands out among the possible action identified in Chapter 2 of the EA. alternatives that should be analyzed in detail because it reduces the Purpose 1: Manage forest structure and species adverse environmental effects while still meeting the purpose and need composition to accelerate development of large for the project. Ranger Newton, some members of your IDT know this. tree size class stands dominated by early seral Ask yourself why they are afraid to voice their opinions. tree species (e.g., ponderosa pine [Pinus Comment: Please don’t exclude a “no new road” alternative from ponderosa]) that would contribute to achievement analysis in detail by claiming the P&N will not be met. The P&N includes of Forest Plan desired vegetation and associated timber harvest but it does not specify a volume of number of acres. The wildlife source habitat conditions. Increase “no new roads” alternative will reduce the acres treated, but will still meet landscape resiliency to uncharacteristic the P&N since most harvest would still occur. This alternative is very disturbance events and promote fire’s ecological important because it eliminates road-construction related adverse natural role in achieving desired conditions. resource impacts. Purpose 2: Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. Purpose 3: Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. Purpose 4: Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. A no roads alternatives would reduce the effectiveness of meeting Purposes 1, 2 and 4 and their associated needs. In addition, while on the surface it would appear a no roads alternative may address Purpose 3, in this case, it would actually reduce accomplishment of Purpose 3. As disclosed in Chapter 2, Comparison of Alternatives, Table 5 which addresses how will alternative address “Issue 2: Effects of road activities on water quality-Construction and reconstruction of roads may significantly harm water quality and riparian habitat.”, the conclusion summarized is: “The road reconstruction proposed for this project is associated with road realignment where existing roads within RCAs are replaced with roads farther from stream channels. The result of
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road realignment would be reduced sediment delivery to streams and reduced riparian impacts in the short-term to long-term time frames. No new road construction would occur within RCAs Temporary road construction would have a temporary to short-term immeasurable negative effect to water quality riparian habitat at two intermittent stream crossings. After completion of project-related activities, these roads would be recontoured and riparian habitat would be restored in the long-term timeframe.” Thus, the effects from the proposed road reconstruction/ construction are beneficial due to moving roads out of RCAs and the conclusions concerning effects of temporary road construction would be immeasurable. Therefore, there would be no benefit in including a “no road construction and reconstruction” alternative analyzed in detail because it would not result in any measurable difference in effects to natural resources identified as a concern by the commenter, including in the referenced Attachment 4, compared to the alternatives already considered in detail. In fact, the likely outcome is it would not meet all four purposes as well as the two action alternatives already assessed in detail. Compared to no action, a no roads alternative would not result in the “immeasurable” temporary and short- term negative effects associated with construction of the temporary roads, but it would also not result in the beneficial long term benefits of reconstruction existing NFS roads currently located in RCAs. As identified in the Transportation Analysis (TAP 2015), the NFS roads to be reconstructed are considered part of the minimum road system needed to meet long-term management objectives within this project area, thus simply decommissioning segments within the RCA without reconstructing the segments needed to maintain the usability of the road system is not an alternative.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
Comment: Without exception, road construction and reconstruction are As identified in the statements quoted from Chief activities that cause damage to some important natural resources in the Dombeck, roads “often” cause serious ecological forest. New road construction is particularly detrimental to aquatic and impacts. That is not the case for the High Valley wildlife resources. Chief Dombeck’s statement below supports this fact. proposed action. "Roads often cause serious ecological impacts. There are few more As identified in the previous comment response, irreparable marks we can leave on the land than to build a road." the effects from the proposed road reconstruction/ Dr. Mike Dombeck, Chief, US Forest Service construction are beneficial due to moving roads Remarks to Forest Service employees out of RCAs and the conclusions concerning and retirees at the University of Montana effects of temporary road construction would be February 1998 immeasurable. Therefore, there would be no benefit in including a “no road construction and Link to statement: reconstruction” alternative analyzed in detail https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/ because it would not result in any measurable Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20Servi difference in effects to natural resources identified ce%20Employees%20and%20.htm as a concern by the commenter, including in the Opposing Views Attachment #4 contains statements by hundreds of referenced Attachment 4, compared to the Ph.D. scientists describing Chief Dombeck’s observations in greater alternatives already considered in detail. detail. In addition, the Proposed Action would decommission 27.3 miles of NFS road and unauthorized routes within the project area reducing impacts to resources identified as a concern to the commenter.
Comment: Since best science and Dr. Dombeck agree that there are As discussed in responses above, in this situation “few more irreparable marks we can leave on the land than to build a a “no new road” alternative would decommission road”, isn’t this is a valid reason to analyze a “no new road” alternative in less miles within the RCAs of the project area detail? than the Proposed Action. More NFS road miles would be maintained with a “no new road” within the RCAs about 14.8 versus 11.9 miles for the Proposed Action. Therefore, a “no new roads” alternative would fall within the range of effects disclosed for the Proposed Action and the No action alternative. Effects of road construction, reconstruction and decommissioning for each of the alternatives analyzed in detail are disclosed in chapter 3 for vegetation, fire/fuels, wildlife, soil/water/riparian and aquatic resources, fish habitat and noxious weeds.
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Comment: The Administrative Procedures Act directs judges to set aside A court’s inquiry is limited to whether the agency an agency action if the court determines that the action is “arbitrary, “considered the relevant factors and articulated a capricious, an abuse of discretion, or otherwise not in accordance with rational connection between the facts found and law.” 5 U.S.C. § 706(2)(A). A line-officer who ignores best-science and the choice made. (Baltimore Gas&Elec. Co. v. instead makes a Decision on weak, meager evidence provided by people NRDC, 462 U.S. 87, 105 (1983). with financial interest in a sale being sold (i.e. IDT members that Thus the scope of the review under the arbitrary represent timber and engineering) is guilty of violating the APA. You have and capricious standard is narrow and a court is done this. not to substitute its judgment for that of an agency. An agency’s action is arbitrary and capricious if: • The agency fails to consider an important aspect of the problem (overlooked evidence). In the case of the High Valley project, the important aspect of the problem is that the existing road system is contributing effects to biophysical resources that needs to be addressed; e.g. roads important to the minimum road system identified in the TAP that fall within RCAs need to realigned/ reconstructed so that they fall outside RCAs. • The agency offers an explanation for the decision that is contrary to the evidence. (unwarranted facts) The decision not to consider a “no roads” alternative in detail has been fully described in the last 4 responses. • The agency’s decision is so implausible that it could not be ascribed to a difference in view or be the project of agency expertise (Lack logic). The development of the proposed action and the beneficial and/or immeasurable temporary and short term impacts described in previous comments is based analyses completed by resource specialists utilizing best available science to reach their conclusions as to effects disclosed. • If the agency’s decision is contrary to the governing law, or the Agency standards
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Comment # Identification Summary of Comment Responsible Official’s Disposition
are not applied in a consistent manner (A clear error of judgment). As described in Chapter 1 and supported by effects disclosures by resource specialist in Chapter 3, decisions concerning road management in High Valley is consistent with governing law and Agency standards for analysis important to informing decisions made.
Comment: Please don’t claim the No Action alternative satisfies this See comment responses above request to analyze a “no new roads” alternative in detail. The timber sale contains some actions that will benefit the ecosystem of the area. A “no new roads” alternative would include these actions. The P&N will still be met because volume will be available from existing roads. A “no new roads” action alternative is reasonable. It will benefit the forested ecosystem, it produces volume and reduces fuels, and eliminates the ecosystem damage caused by roads that is identified in Opposing Views Attachment #4.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
Request for changes to be made to the final NEPA document: Comment Acknowledged. See comment Analyze a no road construction (including temp roads) action alternative responses above. in detail. This would satisfy the P&N. Just as with No Action, this Detailed responses to Attachment 4 alternative provides the public with the trade-off between the Proposed comments/opposing views relative to the High Action and an alternative with less volume and less environmental impact Valley project have been completed and included . . . especially to aquatic resources. as part of the comment response documentation Failure to analyze a timber sale with no new road construction will violate: for the project. As discussed in previous 40 CFR 1500.2(e) and (f) because the Responsible Official was unable to responses, a “no new roads” alternative would fall avoid or minimize adverse effects of the project upon the quality of the within the range of effects disclosed for the human environment without complete knowledge of all likely adverse Proposed Action and the No action alternative. effects. Most adverse effects of road construction activities described by Effects of road construction, reconstruction and scientists in the Opposing Views Attachment #4 was not mentioned in decommissioning for each of the alternatives the final NEPA document EA. analyzed in detail are disclosed in chapter 3 for vegetation, fire/fuels, wildlife, soil/water/riparian and aquatic resources, fish habitat and noxious weeds. As stated in previous responses, the effects from the proposed road reconstruction/ construction are beneficial due to moving roads out of RCAs and the conclusions concerning effects of temporary road construction would be immeasurable. Therefore, there would be no benefit in including a “no road construction and reconstruction” alternative analyzed in detail because it would not result in any measurable difference in effects to natural resources identified as a concern by the commenter, including in the referenced Attachment 4, compared to the alternatives already considered in detail.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-3.1 Literature http://www.fs.fed.us/eng/road_mgt/roadsummary.pdf This is a Forest Service document from 1998 that Cited describes the National Forest Roads System and Use. This document along with the data, facts, and figures it contains would be 18 years old. The data is not a useful tool to compare the effects of the High Valley Project. The High Valley Project will reduce the total miles of NFS road and unauthorized routes within the project area. The effects to the transportation system is described in chapter 3.
6-3.2 Literature Opposing Views Attachment #4 See Appendix A Cited
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-3.3 Literature Dr. Mike Dombeck, Chief, US Forest Service Remarks to Forest Service Letter from Chief, communication between Cited employees and retirees at the University of Montana February 1998 employees regarding the concern about roads on https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/ the environment. Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20Servi Predicted sediment delivery from either action alternative would be reduced from the existing ce%20Employees%20and%20.htm condition in the long-term time frame (EA, Sedimentation Summary) The concern about effects of roads and logging on sedimentation, stream systems and fisheries motivated the High Valley IDT to recommend, and the Responsible Official to approve Purpose #3 “Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs” and Need #2,” Reduce degradation resulting from road related impacts to improve the quality of soil, water, fish and wildlife habitat. Several roads within riparian conservation areas (RCAs) are producing fine sediment into streams which can impair aquatic function and degrade riparian habitat “. The road package for this project addresses this purpose and need by realigning roads away from stream channels and decommissioning by full obliteration non-system routes. Alternatives B and C would reduce the road density within riparian conservation areas (RCAs), from 7.9 mi/mi2 to 6.0 mi/mi2 and all non-system routes would be fully decommissioned (EA Table 3), For this project , RCAs 130 feet away from intermittent non-fish bearing streams, ponds, lakes, and wetlands, and 260 feet from perennial streams.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-4 Comment Issue #2 ----- If you apply herbicides that contain glyphosate The decision to allow the use of herbicides as part (Roundup etc.) you will wake up each morning wondering how many of the standard operating procedure on the Boise people will die of cancer and how many kids will struggle through National Forest for the treatment of invasive life coping with birth defects and autism … because you didn’t care. species is outside the scope of the High Valley project. Request for changes to be made to the final NEPA document: The decision to allow the use of chemical Include the herbicide information currently in the Project File in an treatment was documented in the Boise National appendix and assure the final EA states “herbicides that contain Forest Noxious Weed and Poisonous Plant glyphosate will not be applied.” The decision document should also say Control Program Decision, 1988. Human health this. and ecological risk assessments for the chemicals used are located in the project record.
6-4.1 Various articles listed These articles were not reviewed. The use of herbicides containing glyphosate is not part of the proposed action. Treatment of weeds is part on an ongoing Forest effort. See response to 6-4
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5 Comment Issue #3 – Some IDT members claim No Action will result in an The High Valley EA does not state that logging increased probability of severe wildfires. This is inconsistent with prevents fire. the “best science” quoted below. Indeed, for decades USFS leaders The report does discuss three alternative and a have promised the public that agency projects will be based on wildfire hazard rating associated with each. The “best science.” Clearly this is not the case with the High Valley alternatives were analyzed to display the changes timber sale. in wildfire hazard ratings over time. The effects disclosures written by the IDT members all indicate selecting The no action alternative would progress the the No Action alternative will be a tragic mistake that will decimate, project area towards a predominantly very high ravage and annihilate the natural resources and recreation opportunities wildfire hazard rating, making it highly susceptible in the sale area as a result of fire. to stand replacing wildfire which is outlined in the They are either clueless about the interaction between fire and logging or High Valley EA on pages 35-36. have no problem writing lies to make the No Action alternative appear to be a tragic choice. Either way they have no business being IDT members. Where were the fire specialists? Either they didn’t read the bungled effects disclosures in Chapter 3 predicting a catastrophic fire if it’s not harvested, or they have not kept up with the latest fire science. I invite you and all IDT members to examine independent science explaining how harvested areas interact with fire in Opposing Views Attachment #3. It contains conclusions written by 66 well respected scientists not affiliated with the USDA. They explain how harvesting an area does not reduce fire starts, fire intensity, or rate of spread. Some demonstrate how logging exacerbates fire behavior. The IDT members base their No Action effects on skewed, untrue so-called fire science authored by USFS employees. Request for changes to be made to the final NEPA document: Provide independent science validating the IDT claims that logging reduces fire effects or remove the IDT’s claims that logging prevents fire from Chapter 3. Failure to do so will violate 40 CFR 1500.2(b) because no evidence is presented for environmental effects conclusions, 40 CFR 1501.2(a) because the environmental effects and values are not identified in detail, and without substantiating evidence for effects conclusions the public cannot determine if they are accurate and based on best science which violates 40 CFR 1500.1(b). The final NEPA document will also violate 40 CFR 1500.1(b) because the Chapter 3 environmental effects section written by IDT members is contrary to the “best science” statements written by hundreds of well- respected, independent scientists in the Opposing Views Attachments. With this being the case, the agency effects disclosures are not “high quality” and an “accurate scientific analysis.”
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5.1 Literature Opposing Views Attachment #3 See Appendix A Cited
6-5.2 Literature Mark Rey’s March 3, 2003 testimony to the United States House of Testimony recapping the 2002 fire season and Cited Representatives Committee on Resources about the Threat of Wildland giving an outlook for 2003. Mr. Rey iterates that Fire and the need to log hazardous fuels can be read at: safety of firefighters and communities is our first http://www.wildlandfire.com/docs/2003_n_before/rey_testimony_200 priority. With the fire adapted ecosystems of North 3.htm America, we have the challenging task of reducing fuels and the vulnerability of our communities to wildfire while restoring the health of our forests and rangelands. This challenge is national and long term in scope. The 10-Year Implementation Plan and the Wildland Fire Leadership Council will continue to foster cooperation and communication among Federal agencies, States, local governments, Tribes, and interested groups and citizens.
6-5.3 Literature Commercial Logging Causes Forest Fires Newspaper article primarily focused on politics of Cited Published in FOREST CONSERVATION NEWS TODAY, July 20, 2002 timber harvest. OVERVIEW & COMMENTARY by Forests.org The High Valley project has been designed to http://forests.org/archived_site/today/recent/2002/grgrurge.htm trend the project area towards a more natural fire return interval through thinning and prescribed burning.
6-5.4 Literature Fight Fire With Logging? Article in Mother Jones website regarding that the Cited Forestry experts have long known that commercial logging National Fire Plan is “becoming a feeding ground increases the risk of forest fire. So why, critics are asking, does the for logging companies” so they can remove the Bush administration's new fire prevention plan ignore that fact? largest diameter trees. By Dan Okoand Ilan Kayatsky The High Valley project is utilizing several Published by Mother Jones magazine, Wed Jul. 31, 2002 methods to achieve the desired goals of creating large diameter open ponderosa pine stands for http://www.motherjones.com/politics/2002/08/fight-fire-logging white-headed woodpecker. These include small diameter thin, thinning from below, brush mastication, and prescribed burning.
6-5.5 Literature A Burning Issue: Helping Loggers, Hurting Forests Opinion piece about the Sierra Nevada Cited By Dr. Chad Hanson Framework. Published on Monday, July 15, 2002 in the Los Angeles Times http://www.commondreams.org/views02/0715-04.htm
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5.6 Literature The wildland fires of 2002 illuminate fundamental questions about Article published in the Oregon Quarterly Cited our relationship to fire regarding the 2002 fire season and it “was but a By Dr. Timothy Ingalsbee harbinger of more frequent severe fire seasons to Published in the Winter 2002 issue of the Oregon Quarterly come’ if we do not make changes between society and fires. This includes the damage done http://www.fire-ecology.org/research/wildfire_paradox.pdf by building firelines, dropping retardant or contaminated water (noxious weeds, disease) in pristine areas, lighting backfires kills more than it saves due to the intensity, leave more large diameter trees- they’re the ones better able to withstand a fire, and follow the community wildfire standards (clear up to 200 feet from a house in the WUI). A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface.
6-5.7 Literature A Report to the President in Response to the Wildfires of 2000, The President asked for a report as well as short- Cited By Lyle Laverty USDA Forest Service and Tim Hartzell U.S. Department term actions towards reducing the wildland urban of the Interior, September 8, 2000 interface hazards and preparing firefighters for http://frames.nacse.org/6000/6269.html extreme conditions in the future. The 2000 Congressional Research Service (CRS) report pertained to plantations, which is dissimilar to this project. CRS also emphasized need to treat activity fuels, which this project does.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5.8 Literature Western National Forests: A Cohesive Strategy is Needed to Report to the Subcommittee on Forest and Forest Cited Address Catastrophic Wildfire Threats Health, Committee on Resources, House of Published by the Government Accounting Office, GAO/RCED-99-65 Representatives on the need for a cohesive http://www.gao.gov/archive/1999/rc99065.pdf strategy on catastrophic wildfire threats. Scientists and agency officials attribute this (on the dry eastside forests) to long periods of fire suppression resulting in denser forests, shifts in tree species composition, and increases in insects and disease. A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface.
6-5.9 Literature Timber Industry Fails to Convince Judges that Logging Levels News article noting that a district Judge ruled in Cited Linked to Wildfires favor of the plaintiffs after having his previous Published by a New Century of Forest Planning, September 29, 2015 decision where he found for the Defense http://forestpolicypub.com/2015/09/29/timber-industry-fails-to- overturned by the DC Circuit court convince-judges-that-logging-levels-linked-to-wildfires/
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5.10 Literature Commercial Logging for Wildfire Prevention: Facts Vs Fantasies Article on how commercial logging does not really Cited By Dr. Timothy Ingalsbee benefit wildfire prevention and how commercial Link: http://www.fire-ecology.org/citizen/logging_and_wildfires.htm logging, road building, grazing etc. can lead to increases in disease, insects and severe fires and now is the time for ‘Congress to heed the facts, not fantasies, and develop forest management policies based on science, not politics.’ There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
6-5.11 Literature Sierra Nevada Ecosystem Project: Final Report to Congress Article about fires in the Sierra Nevada’s, the Cited Prepared by the USFS Pacific Southwest Research Station, 1996 diaries of early explorers detailing the open vs http://pubs.usgs.gov/dds/dds-43/ dense dark forest and the indiscriminate burning done by sheepherders that would burn anything that would burn. One purpose of the High Valley Project is to return the area to a more fire dependent system normally found under historical conditions.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-5.12 Literature More Logging Won’t Stop Wildfires Opinion piece on why the author’s oppose Cited By Dr. Chad Hanson and Dr. Dominick DellaSala pending legislation to allow more post-fire salvage logging. Published in the New York Times on July 23, 2015 http://www.nytimes.com/2015/07/23/opinion/more-logging-wont- stop-wildfires.html?_r=0
6-5.13 Literature Historical and current forest landscapes in eastern Oregon and Stated findings are acknowledged. One purpose Cited Washington. Part II: Linking vegetation characteristics to potential and need for the High Valley project is the need fire behavior and related smoke production for the project is to decrease the density of trees, Mark H. Huff; Roger D. Ottmar; Ernesto Alvarado; Robert E. Vihnanek; providing a variety of stand structures and John F. Lehmkuhl; Paul F. Hessburg; Richard L. Everett, 1995 compositions appropriate to the biophysical https://www.frames.gov/rcs/6000/6691.html environment in order to increase resilience and provide habitat for a variety of species (flora and fauna). The area includes ponderosa pine plant communities which are fire dependent and treatments were designed to move the stands towards more open structural conditions reflective of low intensity, high frequency burning regimes to provide habitat for white-headed woodpeckers and others associated with more open structure conditions.
6-5.14 Literature Fire hazard from precommercial thinning of ponderosa pine. Research paper from 1968 discussing the amount Cited Research Paper (PNW-RP-057) of slash created during pre-commercial thinning By: G.R. Fahnestock, 1968 when the cut stems are left on site and the https://www.frames.gov/rcs/11000/11147.html resulting fire hazard from these fuels.
6-5.15 Literature Testimony to the Agriculture, Nutrition and Forestry Committee Press conference with U.S. Senator Torricelli Cited United State Senate. Hearing to Review Healthy Forests Restoration regarding deforestation is reducing biodiversity Act, HR 1904 June 26, 2003 and clear cutting leads to severe ecosystem By:, Arthur Partridge Ph.D., Professor Emeritus, University of Idaho consequences such as: erosion, damage to streams, and even age stands could lead to http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3- increases in insects and disease. music.shtml High Valley resource specialists are well aware of competing needs within the forest and these are addressed the analysis in Chapter 3 of the EA.
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6-5.16 Literature Study challenges views about Western forest fires, July 23, 2012 News article giving a brief summary of a study of Cited By: Scott Sonner, AP field notes taken teams of government land Published in the Daily World surveyors in the mid-1800s attempting to map the http://www.thedailyworld.com/sections/newswire/northwest/study- nation’s wild lands. The transects covered 250 miles in three states. challenges-views-about-western-forest-fires.html
6-5.17 Literature Objectives and considerations for wildland fuel treatment in forested This document discusses long term fuel planning Cited ecosystems of the interior western United States (page 10) to create conditions in which fire can occur By: Dr. Jack Cohen (a USFS fire physicist) without devastating consequences. It also Published in Forest Ecology and Management, issue 256, 2008 identifies the Federal agency dilemma that the http://www.firewise.org/Information/Research-and-Guidance/WUI- home ignition zone largely occurs on private lands and most land management agencies do not have Home-Ignition- the authority to mitigate the WUI ignition potential Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment. directly, so are forced to take indirect routes. pdf
6-5.18 Literature Researcher Finds Need for more Prescribed Burning Newspaper article on research done by Mark Cited By Tom Kuglin Finney, Ph.D., a research forester with the U.S. Published in the Helena Independent Record newspaper, June 17, 2015 Forest Service Fire Lab in Missoula. Finney found http://helenair.com/news/local/researcher-finds-need-for-more- that fire “ripped through logged areas,” and only units where prescribed fire was introduced prescribed-burning/article_4a58c3c3-a7bb-5905-a505- showed effectiveness in stopping or mitigating 4567e8107600.html wildfire spread. “This isn’t saying that timber harvesting is bad or good, it’s just that it doesn’t substitute for the change in fuel structure under prescribed burning,” he said. The High Valley project plans for prescribed fire to follow the planned thinning.
6-5.19 Literature "Healthy Forests" and Wildfire Control: Accumulating Scientific Evidence An opinion piece on why we need to accept that if Cited By Dr. Thomas Power we are careful where and how we live in forests A Montana Public Radio Commentary, December 11, 2006 and learn to accept fire as a natural part of a healthy forested landscape, both prescribed fire http://forestcouncil.org/so-called-healthy-forests-and-wildfire-control/ and natural fires, we can both protect ourselves and enjoy the benefits of diverse natural forests.
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6-6 Issue #4 ----- The pre-decisional EA fails to describe the effects to air These topics where addressed in Chapter 3 of the quality, heritage resources, recreation and scenery resources in EA (page 30. The full text of the Technical reports Chapter 3. are available upon request. Request for changes to be made to the final NEPA document: Include discussions, information and data in Chapter 3 showing the effects to air quality, heritage resources, recreation and scenery resources that will result from logging, road construction and burning that will occur as part of this project. If you feel these resources will not be affected, please describe why.
6-7 Issue #5 ----- Ranger Newton, please take additional action to The requested changes are outside the scope of further reduce the risk to people’s homes and the lives of family the project. members in the WUI should a wildfire start nearby. Firewise is a County program. The Forest Service The pre-decisional EA at page 6 states: agrees with the concepts of Firewise communities and many members of our staff are actively “Approximately 4,654 acres are delineated as WUI within the involved in these community meetings. 7,736-acre Project Area.” The USFS has no jurisdiction to do fuels Ranger Newton, you don’t want to apply Firewise techniques or quote Dr. reduction on private property. Cohen’s research conclusions because they show how and why fine fuels The High Valley project has been designed to removal close to homes is more effective than fuels logging. Why do you meet four main purposes including reduce the ignore Dr. Cohen’s research conclusions? You do so because it might fuels hazard and risk of crown fire spread, jeopardize your precious volume attainment. Who will die because you focusing more intense surface fuel treatments are obsessed by volume? within the wildland-urban interface. Request for changes to be made to the final NEPA document: Modify the Proposed Action to do the following in addition to hazardous fuels removal: • distribute Firewise handouts to WUI residents describing the fine fuels removal methods (where and how). • contact the people living in the WUI and announce Firewise workshops will be held to answer questions. • offer to remove the fine fuels (with written permission) on private property owned by elderly and disabled homeowners who cannot do the work themselves. • modify the P&N to reflect what should be the prime goal of this timber sale: reduce the chance that homes will burn in the WUI should a wildfire start in the area. Fuels reduction would then be an alternative, but this would open the door to the 3 actions shown above.
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6-7.1 Literature Link to Recommendations from the Firewise Communities Program: These articles are about defensible space around Cited http://www.firewise.org/wildfire-preparedness/be-firewise/home-and- homes; tips and tools to make your home and landscape/defensible-space.aspx?sso=0 neighborhood safer from wildland fire; and ways homeowners can make their homes safer from Link to Firewise principles: http://www.firewise.org/wildfire- wildfire. preparedness/be-firewise/home-and-landscape.aspx?sso=0 These articles do not directly pertain to this Link to the Firewise web site: http://www.nfpa.org/safety- project because the objective of this project is not information/for-consumers/outdoors/wildland-fires to provide structure protection for private residents but to effectively treat National forest lands, specifically reducing the wildfire hazard within the wildland-urban interface.
6-7.2 Literature Reducing the Wildland Fire Threat to Homes: Where and How Much? Finney and Cohen (2003) discussed the success Cited Presented as the Fire Economics Symposium in San Diego, California on of fuel management treatments for the purposes April 12, 1999. of benefiting wildland values in addition to http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf increasing home survivability. Concepts from both papers were used broadly in the fuels report, although neither is cited Finney, M., and J. Cohen. 2003. Expectation and Evaluation of Fuel management Objectives. p. 353-366. In: Omi, P.N., and J.A. Linda, tech. eds. 2003. Fire, fuel treatments, and ecological restoration: Conference proceedings; 2002. 16-18 April; Ft. Collins, CO. Proceedings RMRS-P-29. USDA, Forest Service, RMRS. 475p.
6-7.3 Literature Objectives and considerations for wildland fuel treatment in forested This document discusses long term fuel planning Cited ecosystems of the interior western United States to create conditions in which fire can occur Published in Forest Ecology and Management 256, 2008 without devastating consequences. It also (Pages 4, 10, and 1999-2000 cited) identifies the Federal agency dilemma that the http://www.firewise.org/Information/Research-and-Guidance/WUI- home ignition zone largely occurs on private lands and most land management agencies do not have Home-Ignition- the authority to mitigate the WUI ignition potential Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment. directly, so are forced to take indirect routes. pdf
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6-7.4 Literature Here is a link to all 13 publications authored by Dr. Cohen describing the These documents address the concepts of Cited overwhelming effectiveness of using his fine fuels removal methods near structure protection for landowners. These papers homes to reduce the risk that they might burn. discuss concepts such as: http://firewise.org/wildfire-preparedness/wui-home-ignition- • It is not reasonable to form agency and research/the-jack-cohen-files.aspx?sso=0 public expectations for the non- occurrence of wildland fires, including wildland fires encroaching on communities. • Structure ignition and determining suitable clearing distances around structures to prevent ignition from radiant heat. • Ignitability of structures within the WUI areas and the Structure Ignition Assessment Model (SIAM). It speaks to areas immediately adjacent to homes and residential fire resistance; not the surrounding areas which make up the WUI. • The need to reduce forest fuels if structures do not have adequate fuel breaks around them, which makes them susceptible to firebrand ignition. • Home survivability in the wildland-urban interface. Finney and Cohen (2003) discussed the success of fuel management treatments for the purposes of benefiting wildland values in addition to increasing home survivability. • Suppressing wildfire among numerous highly flammable houses was too much for typical wildland firefighting personal to handle. • Opportunities to regulate house construction or subdivision layout through planning and zoning regulations to improve the home ignition zone around structures. Concepts from both papers were used broadly in the fuels report as it is recognized that public safety and structure protection are highest
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priority. The Forest Service does not have the authority to regulate home construction or conduct fuels reduction on private property. Managing fuels to reduce wildfire hazard in the WUI is one of the objectives of the High Valley project.
6-7.5 Literature Western National Forests: A Cohesive Strategy is Needed to Report to the Subcommittee on Forest and Forest Cited Address Catastrophic Wildfire Threats Health, Committee on Resources, House of Published by the Government Accounting Office, GAO/RCED-99-65 Representatives on the need for a cohesive http://www.gao.gov/archive/1999/rc99065.pdf strategy on catastrophic wildfire threats. Scientists and agency officials attribute this (on the dry eastside forests) to long periods of fire suppression resulting in denser forests, shifts in tree species composition, and increases in insects and disease. A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface
6-7.6 Literature University of California; SNEP Science Team and Special Consultants Article about fires in the Sierra Nevada’s, the Cited “Sierra Nevada Ecosystem Project: Final Report to Congress diaries of early explorers detailing the open vs Volume 1, Chapter 4 – Fire and Fuels. dense dark forest and the indiscriminate burning done by sheepherders that would burn anything http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf that would burn. One purpose of the High Valley Project is to return the area to a more fire dependent system normally found under historical conditions.
6-7.7 Literature Opposing Views Attachment #11 See Appendix A Cited
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6-8 Comment Issue #6 ----- The American people do not want their national forests Consideration of the social aspects related to logged and roaded up. The money for your salary (and the IDT timber harvest in concert with utilizing the best members’ salary) comes from tax dollars supplied by these same available science was accomplished with the High Americans you propose to backhand by ignoring and rejecting their Valley Project, through the design of alternatives, desires and wishes for their precious public land. Do you enjoy different silvicultural treatments, assessment of serving your corporate masters first? effects, and determination of mitigation measures. Request for changes to be made to the final NEPA document: include the above quote in the final NEPA document showing the majority of the people in the area reject logging in the Boise National Forest. The discussion should explain why the recommendations of over 200 Ph.D. scientists represented in Opposing Views Attachments #1 and #4 aren’t applicable to the High Valley sale area and/or why the information provided by several timber IDT members should trump these independent scientists’ research conclusions, thus establishing USFS IDT members’ information as “best available science.”
6-8.1 Literature 2000 USDA Forest Service RPA Assessment. Gen. Tech. Rep. RMRS- The Government Performance and Results Act Cited GTR-95. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, (Public Law 103-63) requires that each Federal Rocky Mountain Research Station. agency submit to Congress a five-year Strategic http://www.fs.fed.us/rm/pubs/rmrs_gtr095.pdf Plan. The Plan is to include long-term goals and (Pages 2, 9, 27-28, and 54 cited) objectives. Identifying the long-term goals and objectives is one of the most critical aspects of Strategic Planning. The Results Act requires an agency to ask for the views and suggestions of anyone “potentially affected by or interested in” it’s Strategic Plan. This GTR is a summary of that public sensing.
6-8.2 Literature MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS The analyses completed in the specialist reports Cited AND AGENCIES THE WHITE HOUSE, Office of the Press Secretary, take into consideration, and make conclusions March 9, 2009 based on, research, science, reports, models, http://www.whitehouse.gov/the-press-office/memorandum-heads- monitoring and site-specific information as it was executive-departments-and-agencies-3-9-09 available, in conjunction with scientific recommendations regarding the management of, and effects of, the project activities on the relevant resource. The High Valley Project documents a full environmental review informed by science.
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6-8.3 Literature Improving Regulation and Regulatory Review Executive Order 13563 See response to 6-8.2 Cited of January 18, 2011 Published in: the Federal Register, Vol. 76, No. 14 Friday, January 21, 2011 http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf
6-8.4 Literature 16 U.S.C. § 1851 : US Code - Section 1851: National standards for See response to 6-8.2 Cited fishery conservation and management. http://codes.lp.findlaw.com/uscode/16/38/IV/1851
6-8.5 Literature Opposing Views Attachments #1, #4, and #15 See Appendix A Cited
6-9 Request for Issue #7 ----- Please post your responses to public comments online The Response to Public Comments is part of the Information as well as maintaining a hardcopy in the Project File. official project record and is available upon Comment: Members of the public who submit comments on a draft request by any interested party. NEPA document make the effort to read the NEPA document closely and take the time to compose comments that reflect their issues. Unless you respond to these comments and allow the public to read your responses they don’t know if their comments were read and “considered.” Plus, such responses show you aren’t ignoring the public. Request for changes to be made to the final NEPA document: Post your responses to ALL public comments online so the 322 million Americans\ national forest owners might read them if they choose.
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6-10 Comment Issue 8 – Competent, professional USFS line-officers don’t All issues raised by the public are evaluated. backhand and insult the public they supposedly serve by declaring For each issue, the cause and effect for the issue their comments to be “not significant” as you have done on page 17. topic as put forth by the respondent is noted. The Request for changes to be made to the final NEPA document: Assure Responsible Official then makes a determination that all (emphasis added) issues identified by the public are listed in the of the status of each issue by evaluating them body of the NEPA document posted online and hardcopy. against the following criteria to determine whether or not the concern would be a major factor in the analysis process: • •Has the concern been addressed in a previous site-specific analysis, such as in a previous environmental impact statement or through legislative action? • •Is the concern relevant to and within the scope of the decision being made and does it pertain directly to the Proposed Action? • •Can the concern be resolved through mitigation (avoiding, minimizing, rectifying, reducing or eliminating, or compensating for the proposed impact) in all alternatives? • •Can the issue be resolved through project design in all alternatives? • Major issues are points of unresolved conflict with the Proposed Action identified during external scoping efforts. .
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6-11 Comment Issue #9 ----- The pre-decisional EA does not contain recent The Idaho Department of Environmental Quality (emphasis added) stream survey data that is essential to determine has determined that all of the streams within the whether the stream conditions were harmed by timber sale Water Resources Analysis Area meet all of their activities. The only way to determine this is before and after beneficial uses. None of these streams are listed measurements which require survey data before the timber sale is under Part 303(d) of the Clean Water Act as implemented. water quality limited (Water and Soils Technical The Proposed Action map shows many cutting units either adjacent to Report). No Total Minimum daily Load (TMDL) perennial streams. Other units have perennial streams running through pollutant allocation has been made for any stream them. The Proposed Action roads map shows proposed locations for in the Water Resources Analysis Area. temporary roads crossing perennial streams. In addition, to address potential impacts to Request for changes to be made to the final NEPA document: treatment within RCAs, data was collected on the Include the measured results of recent stream surveys and display a composition of riparian vegetation, existing stream monitoring schedule to be completed during and immediately stream shading, hillslope and aspect, as well as following sale closure. the width of riparian vegetation along streams. Data was also collected to run the Megahan- Ketcheson Model to predict the potential for sediment delivery to streams from this project. Photo points were also collected upstream and downstream on stream channels across the project area. This data was collected in August and September of 2015. A table including a summary of this data is included as an appendix to the Water and Soils Technical report for this project (Water and Soils Technical Report). GPS data was collected at all these sites so post treatment data could be collected, if necessary.
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6-12 Comment Issue #10 ---- Increases in National forest logging do not stabilize or Timber harvest, fuels reduction, ecological enhance the economy of small communities located near them. restoration, recreation, providing for clean air and One of your needs listed in the P&N at page 7 for this timber sale is: water are all part of the multiple-use mandate of “Provide a predictable and recurring supply of wood products from lands the Forest Service. The High Valley project is identified in the Forest Plan as suitable for timber management.” designed to meet multiple objectives Once again this is a cut & paste get-out the cut P&N statement you will find in the P&Ns for your past timber sale draft EAs and DEISs. Request for changes to be made to the final NEPA document: Either: 1) remove the following statement from the P&N: “Provide a predictable and recurring supply of wood products from lands identified in the Forest Plan as suitable for timber management.” OR 2) include the text or links to the text of the following papers (referenced above) in an Appendix to the NEPA document. Line-officers must not withhold such important information from the public. Congress promulgated laws to prevent zealous federal officials from behaving in such a manner to feather their nest. “The Economic Impact of Trails-Forest Recreation’s Growing Inpact” “Seeing Forests for their Green: Economic Benefits of Forest Protection, Recreation, and Restoration”, “The Economic Impact of Preserving Washington’s Roadless National Forests” A 1998 presentation to the National Trails Training Partnership by U.S. Undersecretary of Agriculture Jim Lyons
6-12.1 Literature “The Economic Impact of Preserving Washington’s Roadless National This study evaluated the likely economic impacts Cited Forests” by Thomas Michael Power, Ph.D., Professor of Economics, of protecting all of the inventoried roadless areas University of Montana, June 13, 2000. in Washington’s National Forests from logging http://www.kettlerange.org/power/ExecSummary.htm and commercial development on rural areas, isolated communities, and small towns with a http://www.kettlerange.org/power/powerreport.htm relatively high dependence on logging or forest products manufacturing for their employment and income. The High Valley project does not include inventoried roadless areas.
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6-12.2 Literature EcoNorthwest, “Seeing Forests for their Green: Economic Benefits Article discusses the benefits of goods and Cited of Forest Protection, Recreation, and Restoration”, August 13, 2000 services derived from national Forests and http://econw.com/our-work/publications/seeing-forests-for-their- advocates that commercial logging must stop. green-economic-benefits-of-forest-protection-recre/ Timber harvest, fuels reduction, ecological restoration, recreation, providing for clean air and water are all part of the multiple-use mandate of the Forest Service. The High Valley project is designed to meet multiple objectives
6-12.3 Literature U.S. Undersecretary of Agriculture Jim Lyons states that recreation Article discusses the economic benefits of Cited revenues from national forests significantly exceed timber revenues. recreation on National Forest. The Forest Service A 1998 presentation to the National Trails Training Partnership by U.S. recognizes recreation as an important part of our Undersecretary of Agriculture Jim Lyons’ statements quoting figures from multiple-use mission. Recreation, timber harvest, the draft RPA (Resources Planning Act) of 1995. fuels reduction, and ecological restoration are not http://www.americantrails.org/resources/economics/EconForestRec.ht incompatible uses if planned strategically. ml
6-12.4 Literature http://illinois.sierraclub.org/piasapalisades/factshee.htm Link takes the reader to main Sierra Club, Piasa Cited Chapter web page. Nothing on the current page references the High Valley project.
6-12.6 Literature Logging expansion won't help rural communities Opinion piece on rural economies in Oregon. Cited Portland Oregonian online, June 29, 2014 Speaks to the need to find solutions that create a http://www.oregonlive.com/opinion/index.ssf/2014/06/logging_expans future where our public forests provide sustainable timber, clean water, abundant fish ion_wont_help_ru.html and wildlife, and lucrative outdoor recreational opportunities
6-12.7 Literature Opposing Views Attachment #1 See Appendix A Cited
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6-13 Issue #11 ----- Noise and Dust caused by Timber Harvest Adversely As identified in Chapter 3 of the EA, pages 30-31, Affects Recreation and Wildlife, thus these Adverse Social and the recreation resource analysis showed that Environmental Impacts must be Analyzed in Chapter 3 with follow- Alternatives B and C would not substantially affect up changes made to the timber sale design to eliminate these recreational resources or users because adverse effects recreational experiences will be maintained within Sadly, the pre-decisional EA fails to mention noise and dust resulting from the Project Area. The potential direct, indirect and logging activities. The noise is clearly evident and disruptive several miles cumulative effects summarized in Chapter 3 and away from the source. discussed in detail in the Recreation Resource Request for final NEPA document modifications: Please disclose that Technical Report discloses that proposed noise and dust may adversely affect recreation experience of human activities will be mitigated by design features, visitors to the forest and some wildlife species that exist near the project largely by keeping recreationists away from area and analyze the effects that may occur to 1) recreation, and 2) proposed activities, thus minimize any impacts, vulnerable wildlife species in Chapter 3, and explain why such impacts including from those related to dust and noise. are a justified tradeoff for the stated project benefits. Design features include: Failure to do so violates 40 CFR 1508.3 because these likely indirect RM-5—Public motorized access shall be adverse effects were not discussed in Chapter 3. The omission of this restricted on all permanent and temporary roads information from Chapter 3 also violates 42 USC section 7641 and Title built for the purpose of supporting of vegetation 42--The Public Health and Welfare, Chapter 65-- NOISE CONTROL, Sec. management during activity implementation. 4901. Temporary roads would be fully obliterated within three years from when the project is completed. RR-1—Prohibit snow plowing on established groomed snow routes within the Project Area, including associated haul routes, from December 15 to March 15 where plowing would conflict with established winter recreation use periods. VM-5—Prohibit log haul on weekends (all day Saturday and Sunday); all major holidays (New Years, Memorial Day, Independence Day, Labor Day, Thanksgiving and the day after, Christmas eve and Christmas day); and the opening day of deer, elk, and turkey general hunting seasons. VM-6—Post warning and/or closure signs on authorized haul routes and adjacent to active logging operations to inform the public of logging operations and truck traffic hazards. Similar to recreation, Chapter 3 of the EA, pages 53-75, the wildlife resource analysis showed that Alternatives B and C would not substantially affect wildlife resources, in fact in the long term several wildlife species will realized habitat benefits from restoration activities to be implemented. The potential direct, indirect and cumulative effects summarized in Chapter 3 and discussed in detail
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in the Wildlife Resource Technical Report, disclose that proposed activities will be mitigated by design features in the temporary and short term, including minimizing any impacts from dust and noise that could disrupt wildlife species during critical life phases. Design features include: WL-3—Include protective measures for Threatened, Endangered, and Regional 4 Sensitive (TES) Species against unforeseen events in the timber sale contracts and other project-related contracts (non-commercial thinning). Mandatory provisions of the timber sale contract (currently contract provision B(T)6.24) provide protective measures for any TES plant or animal species identified in the Project Area during the entire period that the sale is under contract. WL-4—Restrict vegetation treatment within a 650- foot radius of an active goshawk nest tree to retain vegetative structure around the nest site. In addition, no commercial harvest, non-commercial thinning, mechanical fuel abatement, or road construction/reconstruction activities should occur within a 1,500-foot buffer (Jones 1979) around active goshawk nest tree(s) from March 1 to August 15 to avoid disrupting nesting activities. Timing restrictions shall only be required for active nest sites. Timing restrictions shall not restrict planned road use patterns, public access, or log hauling. Because goshawks commonly move to alternate nest sites within a territory, the nest site location must be re-identified annually. WL-5—The following timing restriction shall be implemented in treatment units that have been identified to have occupied flammulated owl habitat in 2013-2015 surveys in order to minimize disruption of reproductive activity. This includes not implementing commercial harvest, non- commercial thinning, fuel abatement, or road construction/reconstruction activities from May 1 to August 15 (WIST02 and WIST03), based on the 2013-2015 flammulated owl occurrence map.
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WL-6—Upon discovery of an active bald eagle nest during project implementation, the following timing and spatial restrictions on proposed activities shall be implemented to minimize or avoid disruption of reproductive activity: 1. No commercial harvest, non-commercial thinning, mechanical fuel abatement, or road construction/reconstruction activities shall occur within 660 feet of the nest tree (USFWS 2007) for the duration of the nesting period (February 1 through August 31) (Kaltenecker 2000); 2. Removal of overstory trees should not occur within 330 feet of the nest tree (USFWS 2007) to retain nesting stand characteristics including perch trees. Thinning of trees in the understory should occur outside of the nesting period or when eagles are otherwise not present as determined by the project wildlife biologist. Nest trees shall not be harvested. WL-7—In occupied flammulated owl medium to large tree size class stands in PVG 6 where, following mechanical treatment, it is estimated that canopy cover would be reduced to the low class (<40 percent), select 1 snag > 20” DBH per 10 acres (where available) to receive an 83-foot no treatment buffer where snag densities permit. This prescription would retain the structurally diverse vegetative condition that currently exists around that snag important to flammulated owl source habitat. WL-8—Existing vegetation would be maintained within one site potential tree height of elk wallows and natural licks (WIGU13) identified in RCAs (Refer to Site Potential Tree Height in Chapter 2). The Wildlife Biologist would be notified as soon as possible if a wallow is discovered by layout and marking personnel. The wildlife biologist or representative would review the site on the ground and determine whether the silvicultural prescription adequately protects the site and provides cover for wildlife use. Prescriptions may be modified to provide adequate cover if needed. This design feature applies to commercial and
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non-commercial vegetation treatments. Exceptions include the location of wallows on established road prisms (authorized or otherwise) required for harvest implementation (WIGU13). As a result of application of these design features, the ID team Wildlife biologist concluded the following for migratory birds: “In general, effects to migratory birds from proposed activities have been minimized by considering the timing of activities to minimize disturbances during the breeding season; retaining snags for nesting structures; and retaining the integrity of breeding sites.” Similar conclusions, where applicable, were reached for other species assessed. As to the comment “Failure to do so violates 40 CFR 1508.3, this reference pertains to the section in the CFR “Terminology and Index”, and specifically 40 CFR 1508.3 defines “affecting” as meaning “will or may have an effect.” This term, consistent with the definition at 40 CFR 1508.3, was used in disclosures of effects in Chapter 3 for the recreation and wildlife resource.
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42 U.S. Code Chapter 65 - NOISE CONTROL As identified below in the Congressional Findings and statement of policy pertaining to 42 U.S. Code Chapter 65 - NOISE CONTROL, this law pertains to establishment of Federal noise emission standards for products distributed in commerce. The High Valley Project is not proposing to distribute any such products. 4901 – Congressional Findings and statement of policy (a) The Congress finds— (1) that inadequately controlled noise presents a growing danger to the health and welfare of the Nation’s population, particularly in urban areas; (2) that the major sources of noise include transportation vehicles and equipment, machinery, appliances, and other products in commerce; and (3) that, while primary responsibility for control of noise rests with State and local governments, Federal action is essential to deal with major noise sources in commerce control of which require national uniformity of treatment. (b) The Congress declares that it is the policy of the United States to promote an environment for all Americans free from noise that jeopardizes their health or welfare. To that end, it is the purpose of this chapter to establish a means for effective coordination of Federal research and activities in noise control, to authorize the establishment of Federal noise emission standards for products distributed in commerce, and to provide information to the public respecting the noise emission and noise reduction characteristics of such products. (Pub. L. 92–574, § 2, Oct. 27, 1972, 86 Stat. 1234.)
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6-14 Comment Issue #12 ----- Please respond to the opposing views contained in See Appendix A for Responses to the Opposing the Opposing Views Attachments to these comments. View Attachments Request for changes to be made to the final NEPA document: Each opposing viewpoint is different and is related to a unique subject, therefore a single response attempting to deal with all opposing views simultaneously does not respond to opposing views as required by law. Please respond to each opposing view and post the responses online for the public to see. Simply placing a hardcopy of your opposing views responses in the project file located at the district hides the information from the American public. No American should have to drive hundreds or thousands of miles to read a public document. There are also laws that require Federal Agencies to ”make diligent efforts to invole the public and “encourage and facilitate public involvement.”
6-14.1 Literature Opposing Views Attachments See Appendix A Cited
6-14.2 Literature Not responding to responsible opposing views is also inconsistent with The Forest Service has reviewed and considered Cited court precedent: the opposing science viewpoints provided through Center for Biological Diversity v. United States Forest Service, the public involvement on this project. All Argued and Submitted July 15, 2003, In the United States Court of documents referenced in this attachment, unless Appeals, Ninth Circuit, otherwise noted, are contained in the Project Sierra Club v. Eubanks 335 F. Supp. 2d 1070 (ED Cal. 2004 File. Seattle Audubon Society v. Lyons 871 F. Supp. 1291, 1318 (W.D. Wash. 1994), Seattle Audubon Society v. Moseley 798 F. Supp. 1473 (WD Wash. 1992) , Sierra Club v. Bosworth 199 F.Supp.2d 971, 980 (N.D. Cal. 2002),
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6-15 Issue #13 ----- The Proposed Action will clearly cause the resource The Opposing View Attachments along with all degradation and destruction described in the ATTACHMENTS to comment letters received are part of the public these comments. record for the High Valley project. The attachments to these comments present the “responsible” opposing Any part of this record is available upon request. views of between 500 and 600 independent, unbiased Ph.D. biological scientists who describe the resource damage caused by commercial timber sale logging and road construction activities that occur at any location, on any topography, at any elevation, at any time logging takes place. . Request for changes to be made to the final NEPA document: Include the source literature for particularly relevant science quotes contained in the Opposing Viewpoint Attachments in the References section of the final EIS and cite the quotes contained in the attachments in the body of the final EIS. Indeed, it makes sense for a public servant to present the public with the whole story which includes benefits and drawbacks of project implementation.
6-15.1 Literature Opposing View Attachments See Appendix A Cited
6-15.2 Literature Rejecting valid science because it s at odds with USFS timber agenda is The Forest Service has reviewed and considered Cited also inconsistent with court precedent: the opposing science viewpoints provided through Sierra Club v. Eubanks 335 F. Supp. 2d 1070 (ED Cal. 2004) the public involvement on this project. All Seattle Audubon Society v. Lyons 871 F. Supp. 1291, 1318 (W.D. documents referenced in this attachment, unless Wash. 1994) otherwise noted, are contained in the Project Seattle Audubon Society v. Moseley 798 F. Supp. 1473 (WD Wash. File. 1992) Sierra Club v. Bosworth, 199 F.Supp.2d 971, 980 (N.D. Cal. 2002)
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6-16 Issue #14 ----- You have consciously selected literature for the The Opposing View Attachments along with all References section that excludes science describing how logging comment letters received are part of the public will adversely affect non-timber natural resources in the sale area. record for the High Valley project. Your References section does not include ANY (emphasis added) source Any part of this record is available upon request. documents for the scientific quotes contained in the Opposing Views Attachments.
Request for changes to be made to the final NEPA document: Include some source documents from the Opposing Views Attachments in the References section of the final EA. Also, cite some the specific quotes related to the issue that are presented in the source literature in the Opposing Views Attachments.
6-16.1 Literature A WEB search of the words TIMBER ADVERSE EFFECTS LOGGING Noted Cited gets 2,330,000 hits. See for yourself: http://www.bing.com/search?q=timber%20adverse%20effects%20loggi ng&qs=n&form=QBRE&pq=timber%20adverse%20effects%20logging&s c=0-23&sp=-1&sk=&cvid=e4548830f3cf4a34a71c3919ee83fa9c
6-16.2 Literature Federal Register / Vol. 69, No. 188, page 58056 The quoted sentence in context: Cited Wednesday, September 29, 2004 Rules and Regulations For example, while population data have been http://www.fs.fed.us/r1//projects/plan_rule/intrpretative-rule.pdf held to be required for management indicator species under the 1982 rules, other tools often can be useful and more appropriate in predicting the effects of projects that implement a land management plan, such as examining the effect of proposed activities on the habitat of specific species; using information identified, obtained, or developed through a variety of methods, such as assessments, analysis, and monitoring results; or using information obtained from other sources such as State fish and wildlife agencies and organizations such as The Nature Conservancy. The purpose of this interpretative rule is to clarify that, both for projects implementing plans and plan amendments, paragraph (a)’s mandate to use the best available science applies. This applies to the analysis done in the High Valley EA
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-17 Comment Issue #15 ----- The Proposed Action does not respond to of the The concern about effects of roads and logging Purpose & Need goals. Therefore, it must be rejected. on sedimentation, stream systems and fisheries Need #1 shown at page 7 for this timber sale’s draft EA states: motivated the High Valley IDT to recommend, and “Address undesirable impacts to soil and water quality and restore the Responsible Official to approve Purpose #3 hydrologic function and riparian habitat.” “Improve watershed function through restoration This timber sale is called the High Valley Integrated Restoration project. of aquatic resources and road-related impacts to Clearly you intend for the logging and road construction to “restore” the wildlife, fish, soil, and water resources while forest’s natural resources. providing for the transportation system necessary Request for changes to be made to the final NEPA document: to meet short and long-term management needs” Include the qualifications of the IDT members and discuss why they trump and Need #2,” Reduce degradation resulting from the experts in the Opposing Views Attachments or if you feel the experts road related impacts to improve the quality of soil, are more qualified than the IDT members, please select another water, fish and wildlife habitat. Several roads Proposed Action that “best science” says will restore” the forest’s natural within riparian conservation areas (RCAs) are resources. producing fine sediment into streams which can impair aquatic function and degrade riparian habitat “. The road package for this project addresses this purpose and need by realigning roads away from stream channels and decommissioning by full obliteration non-system routes. Alternatives B and C would reduce the road density within riparian conservation areas (RCAs), from 7.9 mi/mi2 to 6.0 mi/mi2 and all non-system routes would be fully decommissioned (EA Table 3), For this project , RCAs 130 feet away from intermittent non-fish bearing streams, ponds, lakes, and wetlands, and 260 feet from perennial streams. Predicted sediment delivery from either action alternative would be reduced from the existing condition in the long-term time frame (EA, Sedimentation Summary)
6-17.1 Literature Pacific Salmonids: Major Threats and Impacts Summary of threats to salmonids including those Cited Published by NOAA fisheries Office of Protect Resources, May 15, 2014 that can be caused by logging. http://www.nmfs.noaa.gov/pr/species/fish/salmon.html There are no anadromous streams in the High Valley project area.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-17.2 Literature Partridge, Arthur Ph.D., professor emeritus, University of Idaho Press conference with U.S. Senator Torricelli Cited Statement at a Press Conference with Senator Robert Torricelli about S. regarding deforestation is reducing biodiversity and clear cutting leads to severe ecosystem 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. consequences such as: erosion, damage to Capitol streams, and even age stands could lead to http://www.saveamericasforests.org/news/ScientistsStatement.htm increases in insects and disease. High Valley resource specialists are well aware of competing needs within the forest and these are addressed the analysis in Chapter 3 of the EA.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-17.3 Literature Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 Article in Native Forest Network to President Bush Cited Scientists Seek Logging Ban on U.S.-Owned Land” calling for an end of commercial logging and New York Times, April 15, 2002 instead focus on restoration and utilizing tree-free http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.ht products. The Forest Service is mandated to manage the m NFS lands for multiple uses. The High Valley project was designed with this in mind. There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-17.4 Literature Long, Richard D., U.S. Department of Agriculture Office of Inspector U.S. Department of Agriculture Office of Inspector Cited General General Western Region Audit Report on the "Western Region Audit Report: Forest Service National Fire Plan National Fore Plan Implementation. This report Implementation" Report No. 08601-26-SF, November 2001. “recommended how best to respond to the http://www.usda.gov/oig/webdocs/08601-26-SF.pdf ongoing fires, reduce the impacts of these fires on rural communities, and ensure sufficient firefighting resources in the future.” It found that the Forest Service did not correctly calculate funds needed to fight fire, it did not exercise control over restoration and rehabilitation NFP funding, ensure all projects met funding criteria, and clarify project criteria to address issues 1-3.
6-18 Comment Issue #16 ----- After reading the attachments I hope you can ignore Ecosystem Restoration Policy Forest Service your need for volume and understand your proposed High Valley Manual (FSM) 2020. May 27, 2016. timber sale is not a restoration project. Ecosystem restoration can be achieved by a Request for changes to be made to the final NEPA document: range of management activities, such as forest Eliminate “Restoration” from the sale name and eliminate the word thinning to reduce tree density, prescribed fire to “restore” from the text. reduce fuel buildup, replacing culverts to better connect streams, or fencing to restrict disturbances. Ecosystem restoration may include manipulating or protecting terrestrial and aquatic ecosystems to assist in their recovery or adaptation to changing environmental conditions
6-18.1 Literature We concluded that commercial timber sales do not meet the criteria for See response to 6-18 Cited forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf
6-18.2 Literature Pacific Salmonids: Major Threats and Impacts Summary of threats to salmonids including those Cited Published by NOAA fisheries Office of Protect Resources, May 15, 2014 that can be caused by logging. http://www.nmfs.noaa.gov/pr/species/fish/salmon.html There are no anadromous streams in the High Valley project area.
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-18.3 Literature Partridge, Arthur Ph.D., professor emeritus, University of Idaho Press conference with U.S. Senator Torricelli Cited Statement at a Press Conference with Senator Robert Torricelli about S. regarding deforestation is reducing biodiversity 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, and clear cutting leads to severe ecosystem U.S. Capitol consequences such as: erosion, damage to http://www.saveamericasforests.org/news/ScientistsStatement.htm streams, and even age stands could lead to increases in insects and disease. High Valley resource specialists are well aware of competing needs within the forest and these are addressed the analysis in Chapter 3 of the EA.
6-18.4 Literature Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 Article in Native Forest Network to President Bush Cited Scientists Seek Logging Ban on U.S.-Owned Land” calling for an end of commercial logging and New York Times, April 15, 2002 instead focus on restoration and utilizing tree-free http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.ht products.
m
6-18.5 Literature Link to full report: http://fseee.org/index.php/stay- Opinion piece stating that restoration is a Cited informed/projects/1004368 misleading term for clearcut
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6-19 Comment Issue #17 ----- Your untrue, pathetic, fabricated Chapter 3 Effects of the No Action alternative are addressed disclosures are clearly intended to convince the public selecting in each resource area Technical report the No Action alternative would be a tragic mistake. The IDT members all know it’s their job to portray No Action as a harrowing, disastrous mistake. Some IDT members copied and pasted the same No Action effects wording they used in prior NEPA documents. The IDT members know that in some cases disclosing accurate, true No Action effects would make it difficult for the Responsible Official to select the Action alternative already selected for implementation prior beginning the NEPA process. The sale area has never been commercially logged. The IDT silviculturist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in a trend towards a high insect and disease rating. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The fuels specialist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in a very high wildfire hazard rating across the Project Area. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT biologist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the extirpation of the white-headed woodpecker in source habitat would be absent in 39 years. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT biologist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the flammulated owl suitable habitat would start to decline in 39 years. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT soils scientist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the risk of wildfire cover could potentially trigger landslides. Do you really expect the American public to believe this? Some natural resource
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Comment # Identification Summary of Comment Responsible Official’s Disposition
specialists will not lie to please the Responsible Official. Why hasn’t this occurred in the last several hundred years: Request for changes to be made to the final NEPA document: Disclose accurate No Action effects to the natural resources in and downstream from the sale area. If the IDT member still feels their resource will be plundered by not logging and roading and maintaining the conditions that have existed for many decades, then quote the science and identify the data that led them to these conclusions. The court will not accept unsubstantiated claims of damage.
6-20 The children born 50 years from today will not appreciate the Comment noted ecological plunder caused by this timber sale. How could anyone ignore children? They won’t appreciate their land being plundered to provide a natural resource extraction corporation with profit.
6-21 By now you may have read the information contained in the Opposing Thank you for your comment. View Attachments. Reasonable people would have doubts about the wisdom of their proposal that is likely to create major adverse impacts to their resources as described by hundreds of Ph.D. scientists in the attachments. Responsible people that contemplate any action intuitively engage the Precautionary Principle. Perhaps you have never heard of it. Here it is in a nutshell: The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking an action. See: http://en.wikipedia.org/wiki/Precautionary_principle Opposing Views Attachment #15 contains quotes by Hilda Diaz-Soltero, Dr. Ann Bartuska, Chief Dale Bosworth, Associate Chief Sally Collins, Chief Dr. Mike Dombeck, Chief F. Dale Robertson, Agriculture Secretary Dan Glickman, and USFS Chief Tom Tidwell, who all tell the public the USFS depends on “best science” as the basis for it’s projects How do you justify not complying?
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-21.1 Literature Opposing Views Attachment #15 See Appendix A Cited
6-21.2 Literature http://en.wikipedia.org/wiki/Precautionary_principle The analyses completed in the specialist reports Cited take into consideration, and make conclusions based on, research, science, reports, models, monitoring and site-specific information as it was available, in conjunction with scientific recommendations regarding the management of, and effects of, the project activities on the relevant resource. The High Valley Project documents a full environmental review informed by science.
6-22 Ranger Newton, as you and your IDT will find out, the Opposing Views Thank you for your comment. Attachments contain the wisdom of several hundreds Ph.D. scientists who all agree that logging and roading the forest will inflict major adverse ecological impacts. They show how the passing of time without human manipulation is the only way to bring these logged areas back to health in spite of the fact you claim this timber sale will create a healthy forest and “restore” the natural resources in the area. Some of your IDT members know this is true and are frightened to speak up. A small sample of the opposing views from the Opposing Views Attachments is included below. When the 44 statements above are combined with the rest of the science conclusions in the Opposing Views Attachments your next move should be clear.
6-22.1 Literature Opposing Views Attachments See Appendix A Cited
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Comment # Identification Summary of Comment Responsible Official’s Disposition
6-23 Comment Ranger Newton, after reading the effects disclosures in Chapter 3, I must Comment noted conclude the other resource specialists on the IDT have been obedient. Their analysis disclosures show they have no problem trading off the health of the resources they are responsible for protecting for your precious volume. They wrote what you wanted to read. Don’t the kids born in 50 years deserve a place to escape the insanity of a United States with 400 million people? Don’t they deserve to experience solitude, quietness and an occasional nature sound? Unless USFS employees start rejecting the USDA notion that a forest is like a wheat field to be “harvested” regularly, these kids will only be able to experience an undeveloped forest on a DVD depicting the “old times.”
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Appendix A – Response to Opposing Views Submitted by Dick Artley The following table summarizes the Forest Service’s consideration of publications that were provided during the comment period and directly referenced in the comments, or determined to either have some relevance to the analysis or indicate there is a difference of opinion within the body of the science. NEPA states that comments on the EA shall be as specific as possible (40 CFR 1503.3 Specificity of Comments). Some of the following documents are considered non-substantive comments that do not warrant further response. In either case, the following table explains the consideration given by the Forest Service.
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Referenced Document Forest Service Consideration/Response Opposing View-Attachment #1 These opposing views include science authored by 268 Ph.D. scientists (see pages 41-50) who are world-class experts in forest ecology. Their statements support the fact that logging directly assaults the recreating public and many natural resources in the forest 1.1 Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and The picture in the Cascadia Wildlands Project publication shows clearcuts and Implications” talks about fragmentation and edge effects which results in crowding of the ark Clearcuts and forest fragmentation, Willamette NF, Oregon. (Meffe et al. 1997) where after logging, species all try to exist in the remaining From: Cascadia Wildland Project, Spring 2003 patches of unlogged forest. http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20 Clear cut prescriptions are not proposed for the High Valley project. During the Effects%20and%20Implication.pdf development phase of the planning project, habitat for multiple species was taken into account. For further discussion on habitat considerations see the Wildlife and Silviculture Reports.
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Referenced Document Forest Service Consideration/Response 1.2 Anderson, P.G. 1996. “Sediment generation from forestry Conference proceedings. The Forest Service recognizes and addresses the operations and associated effects on aquatic ecosystems” points from this opinion regarding sedimentation produced from harvest Proceedings of the Forest-Fish Conference: Land Management activities and its effects on fish resulting from changing stream morphology Practices and habitat conditions. Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta. Predicted sediment delivery from either action alternative would be reduced http://www.alliance- from the existing condition in the long-term time frame (EA, Sedimentation pipeline.com/contentfiles/45____Sediment_generation.pdf Summary) The concern about effects of roads and logging on sedimentation, stream systems and fisheries motivated the High Valley IDT to recommend, and the Responsible Official to approve Purpose #3 “Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs” and Need #2,” Reduce degradation resulting from road related impacts to improve the quality of soil, water, fish and wildlife habitat. Several roads within riparian conservation areas (RCAs) are producing fine sediment into streams which can impair aquatic function and degrade riparian habitat “ . The road package for this project addresses this purpose and need by realigning roads away from stream channels and decommissioning by full obliteration non-system routes. Alternatives B and C would reduce the road density within riparian conservation areas (RCAs), from 7.9 mi/mi2 to 6.0 mi/mi2 and all non-system routes would be fully decommissioned (EA Table 3), For this project , RCAs 130 feet away from intermittent non-fish bearing streams, ponds, lakes, and wetlands, and 260 feet from perennial streams. Anderson 1996 relies heavily on Megahan and Kidd 1972 to describe the effects of roads and logging on stream sedimentation. The co-author of this article, Walter Megahan, along with Gary Ketcheson, developed the Megahan- Ketcheson Model (Ketcheson and Magahan 1996) that predicts sediment delivery distances from various treatments such as road construction and maintenance, timber harvest and fuels treatments. This model was used to display the potential for sediment delivery from proposed treatments in the High Valley Project (Water and Soils Technical Report, Appendix B, pages 94- 98). Based on the Megahan-Ketcheson Model, sediment delivery would be reduced with either action alternative due to reducing the miles of road near stream channels, limiting timber harvest to at least one site potential tree height (130 ft.) from any waterbody, and prohibiting operating heavy equipment such skidders and yarders in the RCA (EA Table 5; Design features SW-7, SW-2 (Alternative B Only), (EA Appendix A, Design Features) For Alternative C, no commercial harvest would occur within the RCA (design feature SW-2 (Alternative C Only), (Appendix A, Design Features)
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Referenced Document Forest Service Consideration/Response 1.3 Aber John, Norman Christensen, Ivan Fernandez, Jerry Franklin, Lori The quotes from commenter could not be located within this cited report. This Hidinger, Malcolm Hunter, James MacMahon, David Mladenoff, John report "outlines key ecological considerations that should underlie sound forest Pastor, David Perry, Ron Slangen, Helga van Miegroet. “Applying management practices." It looks at ecological considerations for forest Ecological Principles to Management of the U.S. National management in five broad categories: 1) soil and nutrient cycles, 2) hydrology, Forests” 3) biodiversity, 4) landscape level issues, and 5) global change. Issues in Ecology Number 6 Spring 2000 The commenter appears to take this paper out of context. All the principles http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf described below apply to the Telegraph Vegetation Project. The authors of this paper state support for active forest management to meet the above goals, and the commenter has taken this research out of context to support his argument. These comments do not have a direct relationship to the proposed action or include supporting reasons for the responsible official to consider. The primary thesis of the paper is captured by the following statements, taken from the paper: “We have identified major ecological considerations that should be incorporated in sound forest management policy and their potential impacts on current practice: • •Maintenance of soil quality and nutrient stocks that hold the key to current and future forest productivity may necessitate adjusting timber harvest rates and leaving more large woody debris on cutover sites. • •Protection of water quality and yield and prevention of flooding and landslides call for greater attention to the negative impacts of logging roads and the value of undisturbed buffer zones along streams and rivers. • •Conservation of forest biodiversity will often require reducing forest fragmentation by clearcuts and roads, avoiding harvest in vulnerable areas such as hardwood or old growth stands and riparian zones, and restoring natural structural complexity to cutover sites. • •Planning at the landscape level is needed to address ecological concerns such as biodiversity, water flows, and forest fragmentation. Repeated overcutting of National Forests lands in the past has been linked to lack of planning at the landscape scale. • •Increasing pressures on forests due to human population growth and global change oblige land managers to be alert for climate- related stresses as well as damage from ground-level ozone, acid rain, and acidification of soils and watersheds. The paper also states, “Proposals to ban all timber harvesting on National Forests would leave managers without a valuable tool that can be used selectively to restore early successional habitat, reduce fuel loads, and contain pest and pathogen outbreaks in some forests”. All of these issues are addressed in the EA and respective Specialist Reports.
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Referenced Document Forest Service Consideration/Response 1.4 Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Article in the Portland Independent Media Center newswire that says the Published by the Portland Independent Media Center, August 2002. recent wildfires in the west are being inappropriately blamed on http://portland.indymedia.org/en/2002/08/17464.shtml environmentalists by the President, timber industry representatives and the Forest Service. It says that old growth logging should be halted and more concern around housing and communities should be undertaken. The article stresses the importance of fuels reductions around communities. The High Valley Project displays that harvest, thinning, and prescribed burn treatments will effectively modify fire behavior within treated areas and reduce the intensity of a potential wildfire under normal summer conditions. Following harvest activities, the slash will be treated to reduce fire hazard. 1.5 Barry, John Byrne. “Stop the Logging, Start the Restoration” Sierra Club article that states timber advocates say commercial logging on from The Planet newsletter federal lands can be sustained, whereas the North Star chapter (Minnesota) June 1999, Volume 6, Number 5 says public data does not support this. Instead they support bill, H.R.1396, http://www.sierraclub.org/planet/199905/ecl1.asp which “would eliminate the money-losing commercial logging” and help logging communities develop alternative means of creating revenue. This is a 17-year old opinion commentary published in a 1999 Sierra Club newsletter, advocating an end to commercial timber harvest on Federal lands. The Sierra Club supported the National Forest Protection and Restoration Act (H.R. 1396) that would eliminate commercial logging on Federal public lands. This bill did not become law. It does not provide specific information related to the High Valley project; nor does the commenter demonstrate a specific connection to this project The High Valley project was designed recover the economic value of forest products in a manner beneficial to local communities and forest management. 1.6 Cushman, John H. Jr. “Audit Faults Forest Service on Logging New York Times article refers to 12 specific timber sales from 1995-1999 and Damage in U.S. Forests” New York Times, February 5, 1999 that Federal auditors found logging was poorly done, streams and wildlife were http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936 not being adequately protected, and mitigation measures were not A35751C0A96F958260&sec=&spon=&pagewanted=print incorporated. http://www.ncpa.org/sub/dpd/index.php?Article_ID=12468 The High Valley project has Harvest Inspectors and Timber Sale Administrators on the ground during the entire timber harvest process to ensure compliance. In addition project design features, BMPS, and monitoring are incorporated in the EA and followed up by resource specialists to ensure compliance. 1.7 Higgins, Margot, “National forest logging is bad business, study says” Summary of a report that claims logging creates more economic harm than Posted on CNN.com-Nature, March 16, 2000 good. http://www.colorado.edu/AmStudies/lewis/west/costlogging.pdf Project economics have been addressed in the analysis of the High Valley project. There are multiple objectives to the High Valley Project In addition to supporting local economies and offsetting the cost of implementation the High Valley project has been designed to trend the area towards desired vegetative and wildlife habitat conditions; reduce fuels hazards and improve watershed function.
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Referenced Document Forest Service Consideration/Response 1.8 Dombeck, Mike Ph.D. Communication letter sent to all USFS employees by then Chief Dombeck a message on "Conservation Leadership” sent to all USFS regarding doing a better job in talking about and managing values like: employees on July 1, 1998 “wilderness and roadless areas, clean water, protection of rare species, old http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98. growth forests, naturalness” as these are what the American people cherish. html By Federal law (NFMA), forest plans provide the framework for the management of National Forest System lands. The High Valley Project is an integrated resource project that addresses the needs of wildlife, aquatics, vegetation, the local economy, soils, invasive species management, and air quality within the project area. The project will not affect wilderness values and will meet all Forest Plan standards and guidelines. 1.9 Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 Article in Native Forest Network to President Bush calling for an end of “Scientists Seek Logging Ban on U.S.-Owned Land” commercial logging and instead focus on restoration and utilizing tree-free New York Times, April 15, 2002 products. http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
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Referenced Document Forest Service Consideration/Response 1.10 Bush Fire Policy: Clearing Forests So They Do Not Burn” Forest Conservation News Today article that President Bush and the Forest FOREST CONSERVATION NEWS TODAY, August 27, 2002 Service are utilizing fear of fire to increase large-scale logging projects. http://forests.org/archived_site/today/recent/2002/tiporefl.htm There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. 1.11 Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David A scientific panel report from National Wildlife Federation emphasizing that as Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified our understanding about forest habitats increases so must our prescriptions Forest Management to Achieve Watershed and Forest Health: A for improving health evolve. It focuses on Simplified Structure-Based Critique." Management (SSBM) which is a set of loosely associated forestry concepts http://www.coastrange.org/documents/forestreport.pdf drawn principally from traditional silvicultural science, and applied to landscape-level forest management. “SSBM relies on traditional silvicultural techniques—harvest, thinning, chemical application (herbicide and pesticide), and pruning—to create salable timber and other forest “products,” including wildlife habitat.” The High Valley Project does not propose what the authors are calling Simplified Structure-Based Management. The High Valley Project proposes active management using a variety of treatments and treatment methods to improve forest stand resilience and reduce forest fuels. Timber harvest is proposed within an area that has been actively managed in the past. The project will not affect old growth stands and individual large, older trees will be retained within treatment areas. Consistent with the recommendations in the article, the High Valley Project will retain coarse woody debris, snags, and other forest structure within vegetation treatment units.
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Referenced Document Forest Service Consideration/Response 1.12 Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. Quotes provided by commenter not in Franklin and Agee (2007) Forging a 2007. “Forging a Science-Based National Forest Fire Policy.” Science-based National Forest Fire Policy. This paper is on the need for a Issues in Science and Technology. A National Wildlife Federation National Forest Fire Policy (NFFP) based on science vice the current system publication sponsored by the Bullitt Foundation where each Federal land management agency has their own established fire http://www.coastrange.org/documents/forestreport.pdf policies. The authors recognize that all forests are not alike and cannot be managed under one 'universal policy' and that recognition of different forest types and regions is an important key that an NFPP must accommodate. The High Valley project fire and fuel specialist considered site specific fuels conditions in their analysis. (Chapter 3 Fire and Fuels). 1.13 Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut A 2002 article in the Environmental News Service an International Daily Down the Trees!” Environmental News Service, 2008. Newswire concerning President Bush wanting to increase logging and road http://www.ens-newswire.com/ens/aug2002/2002-08-23g.asp building activities on Federal lands. Cascadia Forest Alliance agrees that the forests are out of balance due to decades of fire suppression but they say “increasing logging is the exact opposite of what should be done.” There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. 1.14 Government Accounting Office. “Western National Forests: A Report to the Subcommittee on Forest and Forest Health, Committee on Cohesive Strategy is Needed to Address Catastrophic Wildfire Resources, House of Representatives on the need for a cohesive strategy on Threats” GAO/RCED-99-65 catastrophic wildfire threats. Scientists and agency officials attribute this (on http://www.gao.gov/archive/1999/rc99065.pdf the dry eastside forests) to long periods of fire suppression resulting in denser forests, shifts in tree species composition, and increases in insects and disease. A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient ecosystems will reduce the need for and extent of aggressive wildfire suppression strategies, such as retardant drops and fire line construction.
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Referenced Document Forest Service Consideration/Response 1.15 Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and CRS Report for Congress concerning Forest Fire/Wildfire Protection (updated Procedures: Analysis of Alternative Systems.” A Congressional in 2006) especially in regards to two main factors: wildland urban interface Research Service (CRS) report, October 30, 1995. (WUI) and decline in forest and rangeland health. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215 Forest health and WUI areas were discussed in both Silviculture and Fire and Fuels Reports. 1.16 Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent New York Times article regarding the Los Alamos prescribed fire that “went Catastrophic Fires, It Causes Them.” Published in the New York awry”, logging of large trees reduces the older, thick-barked trees that would Times, May 19, 2000 survive a fire of this type and use of timber sales as a tool of fire management http://www.commondreams.org/views/051900-101.htm is not an option as most tress that need to be removed are of the smaller diameter variety that have very little commercial value. The High Valley project is not intended to “prevent catastrophic fires” but to minimize the probability of extreme fire behavior within the treated areas, among other purposes. Individual large, older trees will be retained within treatment areas and the High Valley Project will retain coarse woody debris, snags, and other forest structure within vegetation treatment units. 1.17 Hanson, Chad, Ph.D. “National Forest Protection” Environment The cited picture is of clearcuts on private timberlands. Now (see picture on last page) The High Valley project does not propose clearcutting. http://www.environmentnow.org/forest.html 1.18 Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and The cited article is opinion commentary written in response to previous Forest Fires.” Guest Commentary in New West, July 11, 2008 editorials. The author criticizes unnamed timber industry spokespersons for http://www.newwest.net/topic/article/logging_industry_misleads_on_c making what he claims are false statements regarding wildland fires and limate_and_forest_fires/C41/L41/ climate change. The quote supplied by the commenter is opinion, is unrelated to the High Valley project, and does not provide anything substantive to warrant a response. 1.19 Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of The quote is 'Increased tree utilization potentially reduces the organic parent Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in material (litter and wood residues) available for soil formation processes." This Western Montana” Forest Science, Volume 22, Number 4, 1 study was conducted on a 250-year old mature Douglas-fir forest with December 1976 , pp. 393-398(6) limestone-based soil, thus it is not relevant to the High Valley planning area. http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000 004/art00007;jsessionid=l2sdf2hphia2.alexandra 1.20 Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public." Quote on the Evergreen webpage from Dr. Houston (1997) regarding the lack Evergreen magazine, October 1997. of transparency between the public and the Federal agencies. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with The High Valley project has followed the NEPA process which included public _the_public-v2.html involvement: meetings with the BFC collaborative group, tribal consultation, public field trips, scoping opportunity, and a 30 day comment period on the EA.
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Referenced Document Forest Service Consideration/Response 1.21 H. R. 1494 text. April 4, 2001 House Resolution 1494 was “To save taxpayers money, reduce the deficit, cut http://www.agriculturelaw.com/legis/bills107/hr1494.htm corporate welfare, protect communities from wildfires, and protect and restore America's natural heritage by eliminating the fiscally wasteful and ecologically destructive commercial logging program on Federal public lands, restoring native biodiversity in our Federal public forests, and facilitating the economic recovery and diversification of communities affected by the Federal logging program”. This bill was never passed through Congress. There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
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Referenced Document Forest Service Consideration/Response 1.22 Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Book Review: The Work of Nature regarding ecosystem services, how they Biodiversity Sustains Us”from his book review of The Work of are important to human civilizations, what we have done to disrupt them, and Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, that we should consider each species an “irreplaceable resource that should 1997, Newsletter of Earth Day Southern Tier, February/March 1999, be preserved for future generations unless the costs of doing so prove to be p. 2 intolerably—not just inconveniently—high.” http://www.mikehudak.com/Articles/FromPrairieDogs9902.html There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. 1.23 Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Stated findings are acknowledged by District Fuels Managers and in the High Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Valley EA, and some of the reasons why treatment of activity-generated fuels Everett, Richard L. Ph.D. 1995. “Historical and current forest is proposed in this project. One purpose and need for the High Valley project landscapes in eastern Oregon and Washington. Part II: Linking is the need for the project is to decrease the density of trees, providing a vegetation characteristics to potential fire behavior and related variety of stand structures and compositions appropriate to the biophysical smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest environment in order to increase resilience and provide habitat for a variety of Service, Pacific Northwest Research Station. species (flora and fauna). The area includes ponderosa pine plant https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/P communities which are fire dependent and treatments were designed to move B96155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E the stands towards more open structural conditions reflective of low intensity, 70?sequence=1 high frequency burning regimes to provide habitat for white-headed woodpeckers and others associated with more open structure conditions.
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Referenced Document Forest Service Consideration/Response 1.24 Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Unpublished research paper for the Western Ancient Forest Campaign on Analysis of the Quincy Library Group Fire Protection Plan." Quincy Library Group Bill (H.R.858) which originally called for a Proposal to Unpublished research paper. 1997. increase federally subsidized commercial logging and morphed into a Plan http://www.fire-ecology.org/research/logging-for-firefighting_2.htm “that claims increased timber extraction would both stabilize local economies and protect public forests from wildfires.” A selective reading of SNEP can thus extract specific quotes to support all sides in the debate over resource extraction vs. environmental protection in management of National Forests and other public lands. There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation.
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Referenced Document Forest Service Consideration/Response 1.25 Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Article on how commercial logging does not really benefit wildfire prevention Prevention: Facts Vs Fantasies” and how commercial logging, road building, grazing etc. can lead to increases http://www.fire-ecology.org/citizen/logging_and_wildfires.htm in disease, insects and severe fires and now is the time for ‘Congress to heed the facts, not fantasies, and develop forest management policies based on science, not politics.’ There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long-term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. 1.26 Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution Article published in the Portland Oregonian regarding that Congress is utilizing to Wildfires” published in the Portland Oregonian, August 6, 2002 the severe fire season to try and pass legislation that would bypass the public http://www.klamathforestalliance.org/Documents/loggingwithoutlimits. involvement process in fuels reduction process. html The High Valley project has followed the NEPA process which included public involvement: meeting with the BFC collaborative group, tribal consultation, a public field trip, scoping opportunity, and a 30 day comment period on the EA. 1.27 Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate Article published in the Oregon Quarterly regarding the 2002 fire season and it fundamental questions about our relationship to fire.” The “was but a harbinger of more frequent severe fire seasons to come’ if we do Oregon Quarterly, Winter 2002 not make changes between society and fires. This includes the damage done http://fireecology.org/research/wildfire_paradox.pdf by building firelines, dropping retardant or contaminated water (noxious weeds, disease) in pristine areas, lighting backfires kills more than it saves due to the intensity, leave more large diameter trees- they’re the ones better able to withstand a fire, and follow the community wildfire standards (clear up to 200 feet from a house in the WUI). A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient ecosystems will reduce the need for and extent of aggressive wildfire suppression strategies, such as retardant drops and fire line construction.
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Referenced Document Forest Service Consideration/Response 1.28 Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Article published in the Missoula Independent regarding that the Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Service has become dependent on severe fires (brought on by decades of fire Vol. 14 No. 24, June 2003 suppression) and how the Forest Service is trying to mask timber sales under http://www.fire-ecology.org/research/USFS_fire_dependent.html the guise of "fuels reduction" and "forest restoration" projects. A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient landscapes will allow for less expensive and laborious direct attack wildfire suppression strategies while creating conditions more conducive for fire to naturally regulate tree density. 1.29 Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Article on Common Dreams.org concerning the Firefighters United for Safety, Fire.” Published by the Firefighters United for Safety, Ethics, and Ethic, and Ecology (FUSEE) group, and the over dramatization by newspaper Ecology (FUSE), January 2005 articles on fire. FUSEE offers the public “new perspectives on wildland fires, http://www.commondreams.org/news2005/0111-14.htm and the related issues of public information.” Approximately 4,654 acres are delineated as the wildland-urban interface within the 7,736 acre Project Area. Within the WUI, hazard reduction treatments are needed to reduce the risk of wildfire to values based on their spatial context, relationship to topography, fire and weather patterns, and hazards on adjacent non-National Forest System (NFS) lands. 1.30 Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects This publication is about effects of linear development (roads) on wildlife and of Linear Developments on Wildlife: A Review of Selected the commenter is concerned about wolverine. Scientific Literature.” Prepared for Canadian Association of The project area it is not defined as alpine or subalpine nor does it have talus Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. slopes. Aubrey et al. (2007) reported that virtually all of the wolverine records http://www.capp.ca/getdoc.aspx?DocId=24902&DT=PDF located in the pacific states were within or near alpine areas." 1.31 Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, Guest Viewpoint from The Register Guard (Eugene, OR) newspaper that the Eugene Register Guard January 11, 2009 logging has started many of the recent fires in Lane county. http://www.highbeam.com/doc/1G1-192070397.html The High Valley project prescriptions were developed to reduce fuels and the wildfire hazard. Logging and thinning contracts require the operator to comply with mitigations that reduce the potential for equipment to start a fire (e.g. spark arrestors) and require the operator/contractor to have tools (e.g. fire extinguisher and shovel) available to suppress a fire should one start. 1.32 Keene, Roy Restorative Logging? “More rarity than reality” Guest Guest editorial comment in Eugene weekly newspaper concerning the Viewpoint, the Eugene Register Guard March 10, 2011 increased logging proposed under the guise of “restoration” and the http://eugeneweekly.com/2011/03/03/views3.html detrimental effects on the land. The High Valley project analysis has addressed the effects of the proposed activities by resource in the EA.
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Referenced Document Forest Service Consideration/Response 1.33 Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. This study was done on steep slopes (30-70%), utilizing clear cutting and Cafferata "Effects of Human-Induced Changes on Hydrologic skyline yarding, along a coastal range that receives a large amount of Systems." An American Water Resources Association publication, moisture year round. June 1994 This article is not relevant to the High Valley project. Slope stability and effects http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF to soils was addressed in the Hydrology and Soils Technical Report. Only 1.1% of the project area is identified as moderate to high risk of landslides. Design feature SW-9 requires that site-specific management measures or mitigations shall be required where the proposed activities might initiate landslides (EA, Appendix A). 1.34 Klein, Al 2004. Logging Effects on Amphibian Larvae Populations Although the title of the cited article infers that the effects of logging were in Ottawa National Forest. studied, only ‘pre-logging’ data was collected in seven vernal ponds in http://www.nd.edu/~underc/east/education/documents/AKlein2004Pr Michigan’s Upper Peninsula. No post-logging data was collected; therefore, no e-loggingsurveyofamphibianlarvaeinvernalpools.pdf conclusions regarding the effects of logging on amphibians can be drawn from this article that was written by a college student attending the University of Notre Dame. The second quote provided by the commenter is an unsupported assumption by the author. In his assumptions, the author also fails to define the harvest type and logging method to be used. Silvicultural practices vary depending on the objectives to be achieved. The spotted salamander is found in the eastern United States and Canada; thus the High Valley project area in western Idaho is far outside its range. Resource protection measures for the project include the prohibition of timber harvest activities within stream buffers thus there will be no disturbance to riparian areas or change in stream shade. There are no ponds within or near proposed treatment areas. Timber harvest will have no detrimental effects to water yield. 1.35 Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. The President asked for a report as well as short-term actions towards Department of the Interior “A Report to the President in Response reducing the wildland urban interface hazards and preparing firefighters for to the Wildfires of 2000”, September 8, 2000. extreme conditions in the future. The 2000 Congressional Research Service http://frames.nacse.org/6000/6269.html (CRS) report pertained to plantations, which is dissimilar to this project. CRS also emphasized need to treat activity fuels, which this project does. 1.36 Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the Testimony presented before the U.S. House of Representatives Subcommittee National Forests” Testimony before the U.S. House of on Forests and Forest Health (Committee on Resources) on thinning for fire Representatives Subcommittee on Forests and Forest Health risk reduction and post-fire salvage logging. (Committee on Resources) December 4, 2001. The High Valley project includes project design features (PDFs) to mitigate the http://www.nrdc.org/land/forests/tnl1201.asp spread of invasive species and erosion. The High Valley project does not include a proposal to salvage log. Wildlife habitat was also considered in proposal development.
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Referenced Document Forest Service Consideration/Response 1.37 Leitner, Brian. “Logging Companies are Responsible for the Article in Democratic Underground.com with regards to the fires in California California Wildfires.” the Democratic Underground, October 30, and how the logging companies are actually responsible for them by clear 2003. cutting and thinning. http://www.democraticunderground.com/articles/03/10/30_logging.ht The District Silviculturalist and District Wildlife Biologist worked together to ml ensure that forest health, density reduction, and wildlife requirements were met. Restoration treatments would be designed to reduce the threat for uncharacteristic wildfire disturbances. 1.38 Long, Richard D., U.S. Department of Agriculture Office of Inspector U.S. Department of Agriculture Office of Inspector General Western Region General "Western Region Audit Report: Forest Service National Audit Report on the National Fore Plan Implementation. This report Fire Plan Implementation" Report No. 08601-26-SF, November “recommended how best to respond to the ongoing fires, reduce the impacts 2001. of these fires on rural communities, and ensure sufficient firefighting resources http://maps.wildrockies.org/ecosystem_defense/Resources_Species_ in the future.” It found that the Forest Service did not correctly calculate funds Topics/Fire/Misuse%20of%20Fire%20Plan%20funds.pdf needed to fight fire, it did not exercise control over restoration and rehabilitation NFP funding, ensure all projects met funding criteria, and clarify project criteria to address issues 1-3. 1.39 Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for Article in Science magazine regarding “Ecological sustainability in the planning 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: area, looking at broad factors such as the proportion of old-growth forests, Vol. 283. no. 5410, pp. 1996 – 1998 stream flows, wildfire frequency, and the amount and distribution of large dead http://www.sciencemag.org/content/283/5410/1996.summary trees ” The EA addresses old forest, stream flows, frequency and the amount and distribution of large dead trees. The resource specialists analysis for the High Valley planning area is found in Chapter 3 of the EA. 1.40 Maser, C. Ph.D., and J. M. Trappe Ph.D. “The Seen and Unseen United States Department of Agriculture General Technical Report regarding World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW- down wood. 164 The High Valley project recognizes and manages for down wood and snags http://www.fs.fed.us/pnw/publications/pnw_gtr164/ for wildlife. 1.41 Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin United States Department of Agriculture General Technical Report on downed Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA wood and its effects on the forest floor, streams, estuaries and coastal Forest Service, GTR-PNW-GTR-229 beaches. http://www.fs.fed.us/pnw/publications/pnw_gtr229/ The High Valley project recognizes and manages for down wood and snags for wildlife 1.42 McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, United States Department of Agriculture General Technical Report on how G.H. Reeves, and L.A. Brown “Management history of eastside logging effects small headwater streams. ecosystems: changes in fish habitat over 50 years, 1935-1992.” Effects to small streams are minimized due to the riparian buffers that are part 1994 GTR-321 93-181 of the project design. See the Water and Soils Technical Report for effects to http://www.fs.fed.us/pnw/publications/pnw_gtr321/ streams from the High Valley Project. See response to 1-2. 1.43 Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects Oregon Department of Fish and Wildlife publication. of Logging on the Aquatic Resources of Three Headwater Effects to small streams are minimized due to the riparian buffers that are part Streams of the Alsea River, Oregon – Part III.” Fishery Report of the project design. See the Water and Soils Technical Report for effects to Number 9 Oregon Department of Fish and Wildlife. streams from the High Valley Project. See response to 1-2 http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf
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Referenced Document Forest Service Consideration/Response 1.44 Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Article in Issues in Ecology (English version) regarding how human impacts Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. have effects biological diversity and ecosystem services. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. One focus of the High Valley project is wildlife, specifically the white-headed Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman woodpecker, and how to create the large diameter, open stands for habitat it Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining requires while balancing the need for denser, more closed canopy stands for Natural Life Support Processes." Issues in Ecology No. 4. Fall other wildlife species. 1999. http://www.esa.org/science_resources/issues/TextIssues/issue4.php 1.45 Nappier, Sharon. Lost in the Forest: How the Forest Service's Article in Taxpayers for Common Sense on how the Forest Service Misdirection, Mismanagement, and Mischief Squanders Your Misdirection, Mismanagement and Mischief Squanders your Tax Dollars in Tax Dollars.Taxpayers for Common Sense, 2002. regards to timber sales, road management, and reforming budget priorities. http://www.ourforests.org/fact/lostintheforest.pdf 1.46 Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human- Current management practices on the forest use an interactive approach for Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - ecologically sustainable forestry. 525. 25 July 1997. The Silviculturalist, Wildlife Biologist and Fuel/fire managers worked together http://www.sciencemag.org/content/277/5325/522.abstract?maxtosho to ensure that forest health, density reduction, prescribed burning, and wildlife w=&HITS=10&hits=10&RESULTFORMAT=&fulltext=logging&searchi requirements were met. d=1136659907310_5043&FIRSTINDEX=0&journalcode=sci 1.47 Northup, Jim. 1999. "Public Wants More Wilderness, Less The High Valley planning area has never been identified for inclusion in the Logging on Green Mountain NF". Press Release by Forest Watch, Wilderness System. a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10 1.48 Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Article in Mother Jones website regarding that the National Fire Plan is Jones, August 1, 2002 “becoming a feeding ground for logging companies” so they can remove the http://motherjones.com/politics/2002/08/fight-fire-logging largest diameter trees. The High Valley project is utilizing several methods to achieve the desired goals of creating large diameter open ponderosa pine stands for white-headed woodpecker. These include small diameter thin, thinning from below, brush mastication, and prescribed burning. 1.49 Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary Could not locate full text article. The commenter quoted the abstract that is L. Sherriff “Are Wildfire Mitigation and Restoration of Historic available at website. Abstract discusses ponderosa pine-dominated montane Forest Structure Compatible? A Spatial Modeling Assessment” forest zone in Boulder County, Colorado mostly on private lands “and the need Published Online: by the by Association of American Geographers. for wildfire mitigation and restoration of historic forest structure are potentially Sep. 8, 2006 needed.” http://www.ingentaconnect.com/content/routledg/anna/2006/0000009 The desired condition is landscapes dominated by early-seral species with a 6/00000003/art00001 heterogeneous spatial distribution. 1.50 Powell, Douglas S. Ph.D., Joanne L. Faulkner, David R. Darr, Unites States Department of Agriculture General Technical Report on Forest Zhiliang Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of the United States. This report is more than 20 years old and Resources of the United States." USDA Forest Service. Rocky Mt. more current science and assessments were utilized during the analysis for Forest and Range Experiment Station. Gen. Tech. Rep. RM-234. the High Valley project. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html
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Referenced Document Forest Service Consideration/Response 1.51 NO ENTRY_ARTLEY SKIPPED 1.52 Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Letter addressed to members of Congress that clearcutting, even aged Ph. D. and over 600 other leading biologists, ecologists, foresters, silvicultural practices and timber road construction lead to ecosystem and scientists from other forest specialties. From a 1998 letter to fragmentation and degradation. These 600+ scientists urge Congress to pass congress. the "Act to Save America's Forests." as they feel it may be the last hope for http://www.saveamericasforests.org/resources/Scientists.htm America's forests. The High Valley project does not propose even-aged silvicultural prescriptions and would result in a net reduction of road miles. 1.53 Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Letter on the "Act to Save America's Forests endorsed by over 600 leading Carnahan scientists, this bill provides a concrete blueprint for managing our federal http://www.saveamericasforests.org/Raven.htm forests and proposes to stop logging in roadless areas, ‘special areas and Northwest Ancient Forests. The Act to Save America's Forests was introduced but not passed into law. The High Valley project will not harvest timber or construct roads in “ancient forests, roadless areas, riparian areas, or in special areas that contain outstanding biological values.” Timber harvest activity will occur within and adjacent to areas that have been previously managed. 1.54 Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Letter to Chief Bosworth from the California Native Plant Society (CNPS) Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 regarding poor policy conclusions that failure to log National Forest is causing members of congress wildfires. The CNPS supports “fire and fuels management practices that http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02 minimize danger to lives and property, creates and maintain sustainable, %20letterhead.pdf productive forest ecosystems dominated by viable native species, conserve rare and imperiled species through their natural ranges and protect water quality and supply, soils and other forest ecosystem services and resources.” A comprehensive analysis was completed for the High Valley project and available in Chapter 3 of the EA and the associated technical reports.
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Referenced Document Forest Service Consideration/Response 1.55 Roelofs, Terry D. Ph.D. Testimony for the California State Water Article concerning salmonid in California waterways. Board and Regional Water Quality Control Boards Regarding Dr. Roelofs expressed concern over the effects of past timber management on Waivers of Waste Discharge Requirements on Timber Harvest Plans. coho salmon habitat in Northern California. He identifies impacts from timber August 2003. harvest relating to: 1) increases in sediment input to salmon bearing streams http://webcache.googleusercontent.com/search?q=cache:QNy_aih1R and their tributaries: 2) decreased input of LWD into waterways; 3) altered xEJ:edennapa.org/thp/roelofstestimony.doc+%22timber+harvest%22 streamflow regimes, increased likelihood of scouring flows and flooding; and +ph.d.+adverse&hl=en&ct=clnk&cd=5&gl=us 4) increased water temperatures. All four of these potential impacts are addressed in the Water and Soils technical report for this project (Water and Soils Technical Report). 1. Alternative B and Alternative C would result in a measurable increase in sediment delivery in the temporary time frame, with a measurable decrease in sediment delivery in the short-term to long-term time frames (Water and Soils Technical Report, pages 44-52). 2. Alternative B and Alternative C would preserve LWD by maintaining a no- harvest buffer of one site potential tree height along stream channels (Water and Soils Technical Report pg. 12). 3. All three alternatives would preserve the existing flow regime (Water and Soils Technical Report pg. 55). 4. Alternatives B and C would immeasurably decrease stream shade in the temporary to short-term time frames and immeasurably improve stream shade in the long term time frame when compared to the existing condition or the No Action alternative (Water and Soils Technical Report, pages 37-44). 1.56 Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to Non-technical article in Rural Development Perspectives detailing a study and the Rural West” Rural Development Perspectives, vol. 14, no. 2 results on why people move to western rural areas. The number one reason http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf was amenities related to the social environment, employment and outdoor recreation. There is no private land within the planning area of the High Valley project however, the opportunities for hunting, driving on roads and dispersed camping are plentiful. 1.57 Scott, Mark G. “Forest Clearing in the Gray’s River Watershed Thesis paper. Research area is Gray's River watershed, approximately 20 1905-1996” A research paper submitted in partial fulfillment of the miles from the coast of the Pacific Ocean. The climate, topography, and requirements for the degree of MASTER OF SCIENCE in geology are vastly different than the relatively dry central Idaho forest in the GEOGRAPHY Portland State University, 2001 High Valley Project Area. http://www.markscott.biz/papers/grays/chapter1.htm The Gray’s River Watershed timber management was dominated by clearcut logging, which is not proposed for the High Valley Project. The comparison of the effects of different clearcut rotations described in this article do not apply to the High Valley project. The recommendation put forth in this article, to balance resource values with commodity values, are designed into the High Valley Project.
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Referenced Document Forest Service Consideration/Response 1.58 Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. Article in the Electronic Green Journal that looks at the public demand for "Physicians of the Forest": A Rhetorical Critique of the Bush accountability on fires and the shift in ideology resulted in the Healthy Forest Healthy Forest Initiative” Electronic Green Journal, Issue #19, Initiative. December 2003 The desired condition is landscapes dominated by early-seral species http://escholarship.org/uc/item/4288f8j5 arranged in a heterogeneous spatial distribution. The High Valley project utilizes a combination of vegetation treatments and prescribed fire to create vegetative conditions that are more resilient to future disturbance events. 1.59 Sierra Club. 2005 “Ending Commercial Logging on Public Lands” Short article calling for the end of commercial logging on federal lands and to http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html stop tax payer subsidizing of these activities. More money and effort should be put into preservation. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker, and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. Analysis of the High Valley Action Alternatives indicate the utilization of wood products would result in a net financial gain, which could be used to offset the costs of other restoration treatments. 1.60 Slaymaker, Olav Ph.D. “Assessment of the Geomorphic Impacts Commenter quoted abstract from research article. Study area is British of Forestry in British Columbia” AMBIO: A Journal of the Human Columbia, Canada where the topography, geology, and climate is Environment 29(7):381-387. 2000 vastly different from the forest of the High Valley planning area. http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381 See response to 1-2 1.61 Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to Testimony before the House Resources Committee stating that fires should be Central Oregon Communities and the Surrounding allowed to burn under appropriate conditions as 100 years of fire suppression Environment.” Testimony before the House Committee on has altered the fire regime, houses and property should use fire resistant Resources, August 25, 2003 materials, and returning fire to fire-dependent landscapes is important. http://www.propertyrightsresearch.org/2004/articles6/testimony_of_an The desired condition is landscapes dominated by early-seral species dy_stahl.htm arranged in a heterogeneous spatial distribution. The High Valley project utilizes a combination of vegetation treatments and prescribed fire to create vegetative conditions that are more resilient to future disturbance events. 1.62 Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Article in CommonDreams.org that President Bush and timber industry are Fire: Why Forest Management Exacerbates Loss of Lives and capitalizing on people’s fear of fire to increase commercial logging in back Property” Published by CommonDreams.org, October 31, 2003 county old growth forests instead of thinning around communities for wildfire http://www.commondreams.org/scriptfiles/views03/1031-10.htm protection. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker, and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. In addition High Valley utilizes a combination of vegetation treatment and prescribed fire to help reset the fire regime in the area towards what is a normal cycle for them (every 5-15 years vice the decades that resulted from previous fire suppression policies).
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Referenced Document Forest Service Consideration/Response 1.63 Taxpayers for Common Sense. “From the Ashes: Reducing the An article regarding the mismanagement of tax payer money on ineffective or Harmful Effects and Rising Costs of Western Wildfires” low priority effects. In addition Congress has granted a “blank check” approach Washington DC , Dec. 2000 to firefighting and the Forest Service has not followed through on reforming its http://www.ourforests.org/fact/ashes.pdf wildfire program. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. 1.64 Thomas, Craig. “Living with risk: Homeowners face the Article in the Sacramento Bee newspaper regarding the Angora fire and responsibility and challenge of developing defenses against instead of pointing fingers to focus on the real problem, which is surface fuels, wildfires.” Sacramento Bee newspaper, July 1, 2007. brush and trees smaller than 16 inches in diameter and that home owners are http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07- responsible for defensible spaces around their homes. There is broad 01_SacramentoBee.php consensus on this point from various jurisdictions with the Tahoe Basin. The High Valley fire/fuels managers will work with the District Silviculturalist for vegetation treatments prior to prescribe burning to reduce the understory and ladder fuels as needed, while balancing the need for course woody debris and a multi-storied condition within the mixed1 fire regime. 1.65 University of California; SNEP Science Team and Special Article about fires in the Sierra Nevada’s, the diaries of early explorers Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report detailing the open vs dense dark forest and the indiscriminate burning done by to Congress” Volume 1, Chapter 4 – Fire and Fuels. sheepherders that would burn anything that would burn. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. 1.66 NO ENTRY_ARTLEY SKIPPED 1.67 Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle Forest Service supported document. The Multiple -Use Sustained Yield Act of Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public 1960 recognizes not only the cost and benefits but goods and services that Forestlands: A Survey of the Literature.A study conducted on may or may not have a monetary value attached. behalf of the U.S. Forest Service. The High Valley EA recognizes this and they are included in the analysis. http://www.icbemp.gov/science/vincent.pdf 1.68 Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Article in the Baltimore Chronicle regarding high levels of undergrowth can Chronicle cause severe fire and some hazardous fuels reduction is warranted. However, http://www.baltimorechronicle.com/firelies_jul02.shtml the environmentalists are at odds with the Forest Service saying they are using the guise of fuels reduction to log old growth mature forests. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species.by utilizing various vegetation treatments in combination with prescribed fire.
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Referenced Document Forest Service Consideration/Response 1.69 Wuerthner, George. “Logging, thinning would not curtail Guest viewpoint in the Eugene Register in which the author refutes a previous wildfires” The Eugene Register-Guard, December 26, 2008 article regarding the “unhealthy forest” require more logging. He says that http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not- large fires are driven by climatic conditions high winds, high temperatures, low curtail.html humidity and severe drought, you have the right ingredients for large fires. The fire/fuels managers are well aware of these effects on prescribed fire and consideration has been given in the analysis 1.70 Wuerthner, George “Who Will Speak For the Forests?” NewWest, Blog article on New West.Net detailing his view, “that the role of environmental January 27, 2009 organizations is to continuously challenge the assumption that we “need” to http://www.newwest.net/topic/article/who_will_speak_for_the_forests/ log the forest” and advocate responsible behavior and promote recycling to C564/L564/ reduce the “need” for wood products. High Valley resource specialists are well aware of competing needs within the forest and these are addressed in Chapter 3 of the EA 1.71 Ziemer, Robert R. Ph.D., "Effect of logging on subsurface Paper study area is 4.3 miles from the Pacific Ocean in California where three pipeflow and erosion: coastal northern California, USA." swales were constructed to measure pipeflow (an engineering term used to Proceedings of the Chengdu Symposium, July 1992. IAHS describe concentrated subsurface erosion). Publication. No. 209, 1992 This is not applicable to the High Valley planning area due to topography, http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF geology, and climate, which is vastly different from coastal California. Subsurface pipeflow is uncommon in the well-drained coarse grained sandy loam soils that dominate the High Valley Project Area. 1.72 From an April 16, 2002 letter to President Bush asking him to stop all Letter to President Bush on Native Forest Network asking him to stop logging in the national forests. commercial logging on federal lands and instead invest in “scientifically http://www.wvhighlands.org/Voice%20PDFs/VoiceAug02.pdf supported forest restoration projects.” Commercial logging destroys wildlife habitat, degrades streams, increases fragmentation and reduces ecosystem health. High Valley resource specialists are well aware of competing needs within the forest and these are addressed the analysis in Chapter 3 of the EA. 1.73 Partridge, Arthur Ph.D., Statement at a Press Conference with Press conference with U.S. Senator Torricelli regarding deforestation is Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save reducing biodiversity and clear cutting leads to severe ecosystem America’s Forests April 28, 1998, U.S. Capitol consequences such as: erosion, damage to streams, and even age stands http://www.saveamericasforests.org/news/ScientistsStatement.htm could lead to increases in insects and disease. High Valley resource specialists are well aware of competing needs within the forest and these are addressed the analysis in Chapter 3 of the EA. In addition clear-cut logging is not proposed in the High Valley project. 1.74 Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects Article on disturbance and the effects on soil erosion and surface water and of forest management on erosion and soil productivity. Proceedings how they affect soil productivity in regards to roads, timber management, of the Symposium on Soil Quality and Erosion Interaction harvesting effects, nutrient impacts, and fire effects. . Keystone, CO, July 7, 1996. Ankeney, IA: Soil and water The High Valley project would improve soil productivity by reducing total soil Conservation Society. 16 p. resource commitment by ripping of landings and skid trails as required by http://forest.moscowfsl.wsu.edu/smp/docs/docs/Elliot_1-57444-100- design features SW-7 and VM-8, as well as decommissioning 27.3 miles of 0.html road.
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Referenced Document Forest Service Consideration/Response 1.75 Forests Monitor, Environmental Impacts of Logging, 2006 (with Environmental impact assessments of logging operations in a number of photos) different countries (Papua New Guinea, Solomon Islands and Cameroon) http://www.forestsmonitor.org/en/reports/550066/550083 demonstrating destructive logging practices using heavy machinery seriously reduce the forest's ability to carry out vital environmental and ecological functions. This article documents effects of logging in tropical forests which have vastly different environmental conditions than the Northern Rocky Mountains. The High Valley project has Harvest Inspectors and Timber Sale Administrators on the ground during the entire timber harvest process to ensure compliance. In addition project design features, BMPS, and monitoring are incorporated in the EA and followed up by resource specialists to ensure compliance. 1.76 Hansen, Chad, Ending Timber Sales on National Forests: THE Economic costs of timber sales on Forest Service Lands FACTS (FY ’97) Published in the Earth Island Journal, 1999 http://www.johnmuirproject.org/pdf/Fy-1997-Economic-Report- Ending-Timber-Sales.pdf 1.77 WUERTHNER, GEORGE, “Why are Conservation Groups Opinion piece Advocating Logging Public Forests?” Published by Counterpunch, September 27, 2012 http://www.counterpunch.org/2012/09/27/why-are-conservation- groups-advocating-logging-public-forests/ 1.78 “Stop Drilling and Logging on Federal Lands While the Public is Kept Petition asking that mining, drilling, and logging not occur on federal lands Out” A petition targeted for Secretary of the Interior Sally Jewel and during the government shutdown. Secretary of Agriculture Tom Vilsack. Posted at FORCECHANGE.COM, 2013 http://forcechange.com/86223/stop-drilling-and-logging-on-federal- lands-while-the-public-is-kept-out/ 1.79 Conservation Groups Look to Hold Forest Service Accountable New article stating that a lawsuit was filed against the Bitterroot National for Middle East Fork Logging Plan Published by Lowbagger, April Forest's Middle East Fork Hazardous Fuel Reduction project. 25, 2006 http://www.lowbagger.org/mideast.html
1.80 Trees Are Our Climate Saviors - So Stop Logging on Public Land Opinion piece stating that President Obama could combine his aspirations for 02/12/2014 climate protection and land protection by stopping commercial logging on The Huffington Post federal lands so forests can capture more carbon dioxide from the http://www.huffingtonpost.com/ellen-moyer-phd/trees-are-our-climate- atmosphere. logging_b_4775894.html
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Referenced Document Forest Service Consideration/Response 1.81 Logging Impacts Summary article on some of the negative impacts that logging operations can Published by Sierra Forest Legacy, 2012 have on the forests of the Sierra Nevada. http://www.sierraforestlegacy.org/FC_FireForestEcology/FFE_Loggin Analysis on the effects of the High Valley Project on streams, aquatic gImpacts.php resources, and soils are located in the High Valley Water Resources Technical Report. 1.82 Pacific Salmonids: Major Threats and Impacts Summary of threats to salmonids including those that can be caused by Published by NOAA fisheries Office of Protecte Resources, May 15, logging. 2014 There are no anadromous streams in the High Valley project area. http://www.nmfs.noaa.gov/pr/species/fish/salmon.htm 1.83 Global Deforestation Deforestation: The conversion of forest to another land use or the long-term Published by the University of Michigan, 01/04/2010 reduction of the tree canopy cover below a 10 percent threshold. Deforestation http://www.globalchange.umich.edu/globalchange2/current/lectures/d implies the long-term or permanent loss of forest cover and its transformation eforest/deforest.html into another land use. All stands currently forested within the High Valley area will remain forested. 1.84 Groups Challenge Industrial Logging of Pristine Wildlife Habitat New article stating that a lawsuit was filed against the Spotted Bear logging Along South Fork Flathead River project in Montana. A Western Environmental Law Center Press Release, 2/28/2012 http://www.westernlaw.org/article/groups-challenge-industrial-logging- pristine-wildlife-habitat-along-south-fork-flathead-rive 1.85 Judge Halts Glacier Loon Timber Sale in Swan Valley New article stating that the judge ruled to enjoin the Glacier Loon Timber sale Published in the Flathead Beacon, Sep 26, 2014 for incomplete ESA analysis. http://flatheadbeacon.com/2014/09/26/judge-halts-glacier-loon- timber-sale-swan-valley/ 1.86 Judge stops 3 Montana logging projects over lynx New article stating that the judge ruled to enjoin the Cabin Gulch on the By Matt Volz, Associated Press June 26, 2013 Helena National Forest and a two others on the Gallatin National Forest in http://news.yahoo.com/judge-stops-3-montana-logging- southwestern Montana for incomplete ESA analysis (lynx). 141919567.html 1.87 Judge blocks Klamath logging plan New article stating that the judge ruled to enjoin a timber sale on the Klamath By Don Thompson,Associated Press National Forest in California. October 16, 2004 http://www.wildcalifornia.org/media/epic-in-the-news/judge-blocks- klamath-logging-plan/ 1.88 Hansen, Chad Ph.D., The Big Lie: Logging and Forest Fires Opinion piece Published by the Earth Island Journal, spring 2000 issue http://yeoldeconsciousnessshoppe.com/art6.html
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Referenced Document Forest Service Consideration/Response Opposing View-Attachment #3 Best Science shows Commercial Logging to Reduce Fuels is not only Ineffective at Reducing Fire Intensity and Rate of Spread, but sometimes Exacerbates Fire Behavior. Since Fuels Reduction is a Favorite USFS Excuse to Log Public Land its Employees are Taught to Ignore and Deny this Information 3.1 Agee, James K. Ph.D. “The Severe Weather Wildfire-Too Hot to This document is applicable and consistent with literature used in the Handle? analysis. Large severe wildfires are more weather-dependent than fuel- Northwest Science, Vol. 71, No. 1, 1997 dependent. The paper does not consider the significance of the fuel http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf complex and the direct correlation to fire severity/intensity. Fuel condition also affects the intensity/severity and is the only function that can be manipulated in order to reduce future intensities. 3.2 Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Article in the Portland Independent Media Center newswire that says the Published by the Portland Independent Media Center, August 2002. recent wildfires in the west are being inappropriately blamed on http://portland.indymedia.org/en/2002/08/17464.shtml environmentalists by the President, timber industry representatives and the Forest Service. It says that old growth logging should be halted and more concern around housing and communities should be undertaken. The article stresses the importance of fuels reductions around communities. The High Valley EA displays that harvest, thinning, and prescribed burn treatments will effectively modify fire behavior within treated areas and reduce the intensity of a potential wildfire under normal summer conditions. Following harvest activities, the slash will be treated to reduce the wildfire hazard. 3.3 Berry, Alison Ph.D., 2007. “Forest Policy Up in Smoke: Fire This paper talks about the history of fire suppression in the U.S. and how Suppression in the United States.” A PERC publication. it has created the current fuels situation. The fire and fuels report http://www.law.northwestern.edu/searlecenter/papers/Berry_forest addresses this same issue. The paper also speaks to how the Forest _policy.pdf Service should manage wildfire and what the federal fire policy should be, and that is not a project level decision. 3.4 Bessie, W. C. Ph.D. and E. A. Johnson Ph.D. “The Relative This article is about subalpine forests in Canada. Weather is Importance of Fuels and Weather on Fire Behavior in Subalpine important to fire and is discussed in the fire and fuels report. Forests” Ecology, Vol. 76, No. 3 (Apr., 1995) pp. 747-762. Published by: Ecological Society of America http://www.jstor.org/pss/1939341 3.5 Bird, Bryan “Fires Normal Part of Ecology - Fear of fires This is an article responding to another article. It discusses the effects of ungrounded” climate and does not consider the correlation to the fuels complex. Mountain View Telegraph, December 20, 2007 http://www.wildearthguardians.org/library/paper.asp?nMode=1&nL ibraryID=567 3.6 “Bush Fire Policy: Clearing Forests So They Do Not Burn” The cited article is opinion commentary written in 2002 criticizing then FOREST CONSERVATION NEWS TODAY, August 27, 2002 President Bush and his administration’s support for fuels reduction (Healthy http://forests.org/archived_site/today/recent/2002/tiporefl.htm Forests Initiative). This is dated opinion not applicable to the current administration nor the High Valley project.
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Referenced Document Forest Service Consideration/Response 3.7 Coe, Nathan J. “Forestry shouldn’t be an ‘industry’ “ The cited article is opinion commentary published in a Colorado newspaper Durango Herald, February 12, 2011 criticizing what appears to be ongoing timber harvest near Durango, http://www.durangoherald.com/article/20110213/OPINION03/70213 Colorado for the purpose of fuels reduction. 9987/Forestry-shouldn%E2%80%99t-be-an- A combination of prescribed burning and mechanical treatments are %E2%80%98industry%E2%80%99 prescribed in the High Valley project area to restore stand structures and compositions more likely to support low and mixed severity wildfire. 3.8 Forest Policy Research paper 2008 “Montana: Blackfoot Clearwater The cited article is unsupported opinion commentary that questions the Stewardship Proposal is all about selling out to Pyramid lumber” effectiveness of thinning to reduce fire hazard. http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwater- Fuel modeling suggests the reduction of surface and ladder fuels along with stewardship-proposal-is-all-selling-out-to-pyramid-lumber/ the separation of tree crowns prescribed in the High Valley vegetation treatments will decrease the risk of high severity crown fire. 3.9 Forest Policy Research paper 2008 “California: Too often thinning This article cites a study that suggests that mechanical thinning followed by treatments tend to increase fire hazards” prescribed fire to reduce surface fuels is effective in creating stands that are http://forestpolicyresearch.org/2008/12/19/california-too-often- more resistant to severe fire effects. The article emphasizes the importance thinning-treatments-tend-to-increase-fire-hazards/ of treating surface fuels with prescribed fire following thinning activities to reduce future fire severity and spread. The Forest Service agrees. 3.10 Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” David Frey is writing about another report authored by Noon, Black and NewWest.net, 3-03-10 DellaSalla which states that climate is the leading driver of fire not beetle kill http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_re and that thinning should be focused on Wildland Urban Interface. A quote port_says/C41/L41/ by Frey is that cutting roads into current roadless areas could bring harm to wildlife, soils and fisheries. The original report was not referenced or linked so could not review the original article. There are no inventoried roadless areas within the High Valley Project area. Both action alternatives would result in a net reduction in the miles of road. Vegetative treatments would be designed to improve ecosystem resiliency in the face of uncertain future climatic conditions. 3.11 Gable, Eryn “Battling beetles may not reduce fore risks – report” Land The commenter has quoted Barry Noon. This opinion piece is on tree Letter, March 4, 2010 thinning and logging across millions of acres of Western lodgepole pine and http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire- spruce-fir, and suggests that it is unlikely to reduce fire risk or alleviate risks-report/ future large-scale epidemics of bark beetles and that limited funds should be used for WUIs. The Vegetation Technical Report in the project record addresses the insect and disease hazard. Vegetative conditions within the High Valley project are dissimilar from homogenous lodgepole pine and spruce fir forests. 3.12 Gorte, Ross W. Ph.D. from a CRS report for Congress, January 18, This document is a congressional research service report to Congress 2006 discussing forest fires and wildfire protection. The cited text occurs in a part http://www.ncseonline.org/nle/crsreports/06Feb/RL30755.pdf of the document that describes the evolution of a federal fire policy. The High Valley Project does not dispute this statement. This part of the document discusses the benefits of fire to regeneration, wildlife habitat, and reducing the spread of noxious weeds. The effects of the High Valley Project analyzed these topics.
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Referenced Document Forest Service Consideration/Response 3.13 Government Accounting Office. “Western National Forests: A Report to the Subcommittee on Forest and Forest Health, Committee on Cohesive Strategy is Needed to Address Catastrophic Wildfire Resources, House of Representatives on the need for a cohesive strategy Threats” GAO/RCED-99-65 on catastrophic wildfire threats. Scientists and agency officials attribute this http://www.gao.gov/archive/1999/rc99065.pdf (on the dry eastside forests) to long periods of fire suppression resulting in denser forests, shifts in tree species composition, and increases in insects and disease. A need of the High Valley project is to reduce the fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient ecosystems will reduce the need for and extent of aggressive wildfire suppression strategies, such as retardant drops and fire line construction. 3.14 Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent New York Times article regarding the Los Alamos prescribed fire that “went Catastrophic Fires, It Causes Them.” Published in the New York awry”, logging of large trees reduces the older, thick-barked trees that would Times, May 19, 2000 survive a fire of this type and use of timber sales as a tool of fire http://www.commondreams.org/views/051900-101.htm management is not an option as most tress that need to be removed are of the smaller diameter variety that have very little commercial value. The High Valley project is not intended to “prevent catastrophic fires” but to minimize the probability of extreme fire behavior within the treated areas, among other purposes. Individual large, older trees will be retained within treatment areas and the High Valley Project will retain coarse woody debris, snags, and other forest structure within vegetation treatment units. 3.15 Hermach, Tim. “The Skinny on Thinning, Should we save the forest The cited article is unsupported opinion commentary written by the from itself?” executive director of the Native Forest Council in opposition to fuels Published by the Eugene Weekly Viewpoint, 11/1/07 reduction treatments that involve commercial tree removal. http://www.forestcouncil.org/tims_picks/view.php?id=1211 3.16 Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Stated findings are acknowledged by District Fuels Managers and in the Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. High Valley EA, and some of the reasons why treatment of activity- Everett, Richard L. Ph.D. 1995. “Historical and current forest generated fuels is proposed in this project. One purpose and need for the landscapes in eastern Oregon and Washington. Part II: Linking High Valley project is the need for the project is to decrease the density of vegetation characteristics to potential fire behavior and related trees, providing a variety of stand structures and compositions appropriate smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest to the biophysical environment in order to increase resilience and provide Service, Pacific Northwest Research Station. habitat for a variety of species (flora and fauna). The area includes https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB9 ponderosa pine plant communities which are fire dependent and treatments 6155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E70?s were designed to move the stands towards more open structural conditions equence=1 reflective of low intensity, high frequency burning regimes to provide habitat for white-headed woodpeckers and others associated with more open structure conditions.
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Referenced Document Forest Service Consideration/Response 3.17 Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Article on how commercial logging does not really benefit wildfire prevention Prevention: Facts Vs Fantasies” and how commercial logging, road building, grazing etc. can lead to http://www.fire-ecology.org/citizen/logging_and_wildfires.htm increases in disease, insects and severe fires and now is the time for ‘Congress to heed the facts, not fantasies, and develop forest management policies based on science, not politics.’ There are multiple objectives to the High Valley Project which go beyond logging alone. The project has been designed to meet four main purposes. Manage forest structure and species composition to accelerate development of large tree size class stands dominated by early seral tree species (e.g. ponderosa pine [Pinus ponderosa]) that would contribute to achievement of Forest Plan desired vegetation and associated wildlife source habitat conditions. Increase landscape resiliency to uncharacteristic disturbance events and promote fire’s ecological role in achieving desired conditions. (2) Reduce the fuels hazard and risk of crown fire spread, focusing more intense surface fuel treatments within the wildland-urban interface. (3) Improve watershed function through restoration of aquatic resources and road-related impacts to wildlife, fish, soil, and water resources while providing for the transportation system necessary to meet short and long- term management needs. (4) Utilize wood products resulting from restoration and fuel reduction treatments to support local and regional economies and offset the cost of project implementation. 3.18 Ingalsbee, Timothy Ph.D. 2000. “Money to Burn: The Economics of The paper addresses the national fuels program policies and suggested Fire and Fuels reforms. Management, Part One: Fire Suppression. “An American Lands Alliance publication. www.fire-ecology.org/research/money_to_burn.html 3.19 Ingalsbee, Timothy Ph.D., “National Fire Plan Implementation: This is an opinion piece on the National Fire Plan Forest Service Failing to Protect Forests and Communities” American Lands Alliance, March 2002 http://www.fire-ecology.org/policy/ALA_fire_policy_2002.html
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Referenced Document Forest Service Consideration/Response 3.20 Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate Article published in the Oregon Quarterly regarding the 2002 fire season fundamental questions about our relationship to fire.” The Oregon and it “was but a harbinger of more frequent severe fire seasons to come’ if Quarterly, Winter 2002 we do not make changes between society and fires. This includes the http://fireecology.org/research/wildfire_paradox.pdf damage done by building firelines, dropping retardant or contaminated water (noxious weeds, disease) in pristine areas, lighting backfires kills more than it saves due to the intensity, leave more large diameter trees- they’re the ones better able to withstand a fire, and follow the community wildfire standards (clear up to 200 feet from a house in the WUI). A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient ecosystems will reduce the need for and extent of aggressive wildfire suppression strategies, such as retardant drops and fire line construction. 3.21 Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Article published in the Missoula Independent regarding that the Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Service has become dependent on severe fires (brought on by decades of Vol. 14 No. 24, June 2003 fire suppression) and how the Forest Service is trying to mask timber sales http://www.fire-ecology.org/research/USFS_fire_dependent.html under the guise of "fuels reduction" and "forest restoration" projects. A need of the High Valley project is to reduce fuels hazard and risk of crown fire spread to minimize the danger and difficulty of suppressing future wildfires, and enhance future forest resiliency. More intense surface fuel treatments would be focused within the wildland-urban interface. Creating more resilient ecosystems will reduce the need for and extent of aggressive wildfire suppression strategies, such as retardant drops and fire line construction. 3.22 Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Article on Common Dreams.org concerning the Firefighters United for Fire.” Published by the Firefighters United for Safety, Ethics, and Safety, Ethic, and Ecology (FUSEE) group, and the over dramatization by Ecology (FUSE), January 2005 newspaper articles on fire. FUSEE offers the public “new perspectives on http://www.commondreams.org/news2005/0111-14.htm wildland fires, and the related issues of public information.” Approximately 4,654 acres are delineated as the wildland-urban interface within the 7,736 acre Project Area. Within the WUI, hazard reduction treatments are needed to reduce the risk of wildfire to values based on their spatial context, relationship to topography, fire and weather patterns, and hazards on adjacent non-National Forest System (NFS) lands.
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Referenced Document Forest Service Consideration/Response 3.23 Ingalsbee, Timothy Ph.D. and Joseph Fox, Ph.D. “Firefighters Article on Common Dreams.org concerning the Firefighters United for United for Safety, Ethics, and Ecology (FUSEE): Torchbearers Safety, Ethic, and Ecology (FUSEE) group, and the over dramatization by for a New Fire Management Paradigm” newspaper articles on fire. FUSEE offers the public “new perspectives on A poster presentation at the Third International Fire Ecology and wildland fires, and the related issues of public information.” Management Congress, Association for Fire Ecology Approximately 4,654 acres are delineated as the wildland-urban interface November 13-17, 2006 within the 7,736 acre Project Area. Within the WUI, hazard reduction treatments are needed to reduce the risk of wildfire to values based on http://fusee.org/docs/AFE_FUSEE_display_abstract.pdf their spatial context, relationship to topography, fire and weather patterns, and hazards on adjacent non-National Forest System (NFS) lands. 3.24 Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, Guest Viewpoint from The Register Guard (Eugene, OR) newspaper that the Eugene Register Guard January 11, 2009 logging has started many of the recent fires in Lane county. http://www.highbeam.com/doc/1G1-192070397.html The High Valley project prescriptions were developed to reduce fuels and the wildfire hazard. Logging and thinning contracts require the operator to comply with mitigations that reduce the potential for equipment to start a fire (e.g. spark arrestors) and require the operator/contractor to have tools (e.g. fire extinguisher and shovel) available to suppress a fire should one start. 3.25 Keene, Roy Restorative Logging? “More rarity than reality” Guest Guest editorial comment in Eugene weekly newspaper concerning the Viewpoint, the Eugene Register Guard March 10, 2011 increased logging proposed under the guise of “restoration” and the http://eugeneweekly.com/2011/03/03/views3.html detrimental effects on the land. The High Valley project analysis has addressed the effects of the proposed activities by resource in the EA. 3.26 Kelly, Steve Ph.D. 2007. “Cheap Chips, Counterfeit Wilderness: This is an opinion piece about the Beaverhead-Deerlodge Forest in Greenwashing Montana Logging on Montana's Biggest National Forest.” Published by the World Prout Assembly http://www.worldproutassembly.org/archives/2007/12/cheap_chips _cou.html 3.27 Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department The President asked for a report as well as short-term actions towards of the Interior “A Report to the President in Response to the reducing the wildland urban interface hazards and preparing firefighters for Wildfires of 2000”, September 8, 2000. extreme conditions in the future. The 2000 Congressional Research Service http://frames.nacse.org/6000/6269.html (CRS) report pertained to plantations, which is dissimilar to this project. CRS also emphasized need to treat activity fuels, which this project does. 3.28 Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Testimony presented before the U.S. House of Representatives Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) on Subcommittee on Forests and Forest Health (Committee on thinning for fire risk reduction and post-fire salvage logging. Resources) December 4, 2001. The High Valley project includes IDFs to mitigate the spread of invasive http://www.nrdc.org/land/forests/tnl1201.asp species and erosion, both concerns of salvage logging in the testimony. Wildlife habitat was also considered in proposal development.
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Referenced Document Forest Service Consideration/Response 3.29 Leitner, Brian. “Logging Companies are Responsible for the Article in Democratic Underground.com with regards to the fires in California California Wildfires.” the Democratic Underground, October 30, 2003. and how the logging companies are actually responsible for them by clear http://www.democraticunderground.com/articles/03/10/30_logging.html cutting and thinning. The High Valley project focus is on wildlife and how to balance the need for large diameter open stands of ponderosa pine for one species versus a closed canopy, stand that other species prefer. The District Silviculturalist and District Wildlife Biologist worked together to ensure that forest health, density reduction, and wildlife requirements were met. 3.30 “More Large Forest Fires Linked To Climate Change” This 2006 article discusses the relationship of climate and large, severe Adapted from materials provided by the University of Arizona wildfires and fire exclusion. This project would modify the effects of ScienceDaily, July 10, 2006 wildfire through fuels manipulation. Fuel is the only manageable piece of the fire environment, we cannot change climate or topography. http://www.sciencedaily.com/releases/2006/07/060710084004.htm 3.31 Morgan, Penelope Ph.D., Emily K. Heyerdahl Ph.D., and Carly E. Paper discusses climate effects as related to large, severe wildfires in Gibson the Northern Rockies. 2008 "Multi-season climate synchronized forest fires throughout Although not referenced it supports the analysis. the 20th century, Northern Rockies", Ecology, 89, 3: 717-728. http://www.firelab.org/index.php?option=com_jombib&task=show bib&id=343 3.32 Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, Article in Mother Jones website regarding that the National Fire Plan is August 1, 2002 “becoming a feeding ground for logging companies” so they can remove the http://motherjones.com/politics/2002/08/fight-fire-logging largest diameter trees. The High Valley project is utilizing several methods to achieve the desired goals of creating large diameter open ponderosa pine stands for white- headed woodpecker. These include small diameter thin, thinning from below, brush mastication, and prescribed burning.
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Referenced Document Forest Service Consideration/Response 3.33 Oregon State University Research The cited article is a review of a published study entitled ”Forest Fuel Science Centric, July 9, 2009 Reduction Alters Fire Severity and Long-term Carbon Storage in Three http://www.sciencecentric.com/news/article.php?q=09070918- Pacific Northwest Ecosystems” written by Stephen Mitchel, Mark Harmon forest-fire-prevention-efforts-will-lessen-carbon-sequestration- and Kari O’Connell. The authors of the study used a forest ecosystem add-greenhouse-warming simulation model to examine the effects of fuel reduction on fire severity and the resulting long-term carbon storage among three Pacific Northwest ecosystems: the east Cascades ponderosa pine forests, the west Cascades western hemlock-Douglas-fir forests, and the Coast range western hemlock- Sitka spruce forests. Their results suggest that if fuel reduction treatments are effective in reducing fire severities in the western hemlock-Douglas-fir forest of the west Cascades and western hemlock-Sitka spruce forests of the Coast Range, it will come at the cost of long-term carbon storage even if harvested materials are utilized as biofuels. The conclusions of this paper are not applicable to the High Valley project as the forest types that were studied in the Pacific Northwest are vastly different from those found in the project area. The responses to fuel reduction treatments and carbon storage cannot be correlated from the study to the treatments in the Selected Alternative. 3.34 O'Toole Randal. “Incentives, Not Fuels, Are the Problem” The cited article is opinion commentary that claims that the Forest Service Published by the Thoreau Institute exaggerates wildfire and forest fuels concerns to leverage Congress for a http://www.ti.org/fireshort.html bigger budget. The author also claims the reason for increased fire suppression and fuel reduction costs is due to Congress providing the Forest Service a ‘blank check,’ which he suggests offers no incentive to control costs. How Congress funds the Forest Service is outside the scope of the High Valley project. In the sentence following the provided quotation, the author writes, “I am not saying there is no buildup of fuels, just that the buildup isn’t as important as the popular story has led us to believe.” It is well established that potential fire behavior (intensity) and severity (effect) are dependent on the interaction between fuel, weather, and physical setting (Jain and Graham 2004; Graham et al. 2004). Of those three factors, the only thing humans can alter through management is fuel. 3.35 O’Toole, Randal. 2002. “Reforming the Fire Service: An The cited article is opinion commentary that is a longer version of the article Analysis of Federal Fire Budgets and Incentives.” The Thoreau cited in 3-34 above. Please see response to 3-34. Institute. www.ti.org/firesvc.pdf
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Referenced Document Forest Service Consideration/Response 3.36 O’Toole, Randal. “Money to Burn?” The cited article is opinion commentary that is essentially the same as what Regulation, Winter 2002 - 2003 is contained in the articles of 3-34 and 3-35 above. This discusses the http://www.cato.org/pubs/regulation/regv25n4/v25n4-6.pdf history of the Forest Service in relation to spending on fuels treatments. It concludes that decentralized planning should be allowed and a pilot forest charter idea should be used and favor spending tax payers’ money on fuels treatment projects. Please see response to 3-34 3.37 Partridge, Arthur Dean Ph.D. This is the same citation as Montgomery, David Ph.D. This article contains Testimony to the Agriculture, Nutrition and Forestry Committee statements by scientists that support S. 977, HR 1376, an Act to Save United State Senate. Hearing to Review Healthy Forests Restoration America’s Forests. Act, HR 1904 The High Valley project follows all applicable laws and regulations June 26, 2003 http://www.univision.co.za/offer-day- oA2A392Cr1N3B2x_2F2du3g3-music.shtml 3.38 Peters, Robert L. Ph.D, Evan Frost, and Felice Pace. 1996 “Managing This opinion paper is general and not specific to the High Valley project for Forest Ecosystem Health: A Reassessment of the ‘Forest The link did not work. However, based on the quote provided, this paper is Health Crisis” based on using salvage activities as a tool to reduce fire hazard and/or http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.h insect and disease epidemics to improve forest health. There is confusion tm as to which document “USFS 1993” is since no bibliography was included with this reference and there are many references available that could fit this citation. Current direction for National Forest Resource Management is in the Forest Service Manual (FSM) Chapter 2020.2: “The aim is to reestablish and retain ecological resilience of National Forest System lands and associated resources to achieve sustainable management and provide a broad range of ecosystem services. Healthy, resilient landscapes will have greater capacity to survive natural disturbances and large scale threats to sustainability, especially under changing and uncertain future environmental conditions, such as those driven by climate change and increasing human uses.” Clarification on this point was not provided by the commentor, thus this review is based solely on the excerpt provided in the comment and does not take into account the reference “USFS 1993.” 3.39 Peterson, Mike The cited testimony is opinion commentary opposing the Healthy Forests testimony to the Senate Agriculture, Nutrition, and Restoration Act as written for various reasons. Forestry Committee concerning the Healthy Forests Restoration Act, The High Valley project is not designed to prevent loss of structures on HR 1904. June 26 2003 private land because this project does not propose treatment on privately http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_i owned property. In addition to protecting life, property, and resources within d=2258 and adjacent to the WUI, one purpose and need of the project is to trend the project area landscape toward a more fire resilient condition. Following treatment on NFS lands within the WUI, future wildfires in the project area following a severe crown fire would be less intense, less resistant to control, and would provide more of a safety margin for firefighters and residents.
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Referenced Document Forest Service Consideration/Response 3.40 Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Could not locate full text article. The commenter quoted the abstract that is Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest available at website. Abstract discusses ponderosa pine-dominated Structure Compatible? A Spatial Modeling Assessment” Published montane forest zone in Boulder County, Colorado mostly on private lands Online: by the by Association of American Geographers. Sep. 8, 2006 “and the need for wildfire mitigation and restoration of historic forest http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/ structure are potentially needed.” 00000003/art00001 The desired condition is landscapes dominated by early-seral species arranged in a heterogeneous spatial distribution. 3.41 Power, Thomas Ph.D. “The Politics of Forest Fires -- The Abuse of This opinion piece advocates that commercial logging is one of the major Other People's Hard Times.” 8/15/2000. Thomas Michael Power is causs of unhealthy forest. Until the forest products industry stops trying to the Professor and Chairman of the Economics Department, University insist that clearcutting our public lands is necessary for the health of those of Montana lands, we will make no progress in restoring those lands. http://www.forwolves.org/ralph/tompower.htm The High Valley fire is not proposing clearcutting 3.42 Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant These statements are generalizations, which, although they may be valid in Society some settings, do not apply to the High Valley Project because of project Excerpt from a letter to Chief Dale Bosworth and 5 members of design features. Moreover, this is court testimony by a third party, which congress, 2002 although it is the speakers considered opinion, it is not peer reviewed http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.0 material 2%20letterhead.pdf 3.43 Schoennagel, Tania Ph.D., Thomas T. Veblen Ph.D., and William H. This paper discusses the relationship of climate and large, severe wildfires Rommie Ph.D. “The Interaction of Fire, Fuels, and Climate across with fuel treatments. This project would modify the effects of wildfire through Rocky Mountain Forests” fuels manipulation, using mechanical treatments and prescribed fire. Fuel is Bioscience, July 2004 / Vol. 54 No. 7 the only element of the fire environment that can be managed as http://www.montana.edu/phiguera/GEOG430/PurdyFireFieldTrip/Sc topography and climate are beyond our control. hoennagel_et_al_2004_Bioscience.pdf 3.44 Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Article in CommonDreams.org that President Bush and timber industry are Why Forest Management Exacerbates Loss of Lives and Property” capitalizing on people’s fear of fire to increase commercial logging in back Published by CommonDreams.org, October 31, 2003 county old growth forests instead of thinning around communities for wildfire http://www.commondreams.org/scriptfiles/views03/1031-10.htm protection. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. In addition High Valley utilizes a combination of vegetation treatment and prescribed fire to help reset the fire regime in the area towards what is a normal cycle for them (every 5-15 years vice the decades that resulted from previous fire suppression policies).
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Referenced Document Forest Service Consideration/Response 3.45 Taxpayers for Common Sense. “From the Ashes: Reducing the An article regarding the mismanagement of tax payer money on ineffective Harmful Effects and Rising Costs of Western Wildfires” Washington or low priority effects. In addition Congress has granted a “blank check” DC , Dec. 2000 approach to firefighting and the Forest Service has not followed through on http://www.ourforests.org/fact/ashes.pdf reforming its wildfire program. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species. 3.46 Thomas, Craig. “Living with risk: Homeowners face the Article in the Sacramento Bee newspaper regarding the Angora fire and responsibility and challenge of developing defenses against instead of pointing fingers to focus on the real problem, which is surface wildfires.” Sacramento Bee newspaper, July 1, 2007. fuels, brush and trees smaller than 16 inches in diameter and that home http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07- owners are responsible for defensible spaces around their homes. There is 01_SacramentoBee.php broad consensus on this point from various jurisdictions with the Tahoe Basin. The High Valley fire/fuels manager works with the District Silviculturalist for vegetation treatments prior to prescribe burning to reduce the understory and ladder fuels as needed to address desired conditions for vegetation and wildfire hazard. 3.47 University of California; SNEP Science Team and Special Consultants Article about fires in the Sierra Nevada’s, the diaries of early explorers 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” detailing the open vs dense dark forest and the indiscriminate burning done Volume 1, Chapter 4 – Fire and Fuels. by sheepherders that would burn anything that would burn. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species by utilizing various vegetation treatments in combination with prescribed fire. 3.48 USDA Forest Service This citation accompanies a quote that weather not fuels is the main driver BALD ANGEL VEGETATION MANAGEMENT PROJECT of fire behavior. We agree and the fire and fuels analysis addresses this. ENVIRONMENTAL Fuel is the only element of the fire environment that can be managed as ASSESSMENT. La Grande Ranger District, Wallowa-Whitman National topography and climate are beyond our control. Forest December 2006 https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/660 8/Wallowa_Whitman_Bald_Angel_Vegetation_Management_EA.pdf ?sequence=1
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Referenced Document Forest Service Consideration/Response 3.49 Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Article in the Baltimore Chronicle regarding high levels of undergrowth can Chronicle cause severe fire and some hazardous fuels reduction is warranted. http://www.baltimorechronicle.com/firelies_jul02.shtml However, the environmentalists are at odds with the Forest Service saying they are using the guise of fuel s reduction to log old growth mature forests. One focus of the High Valley project is wildlife, specifically the white-headed woodpecker and how to create the large diameter, open stands for habitat it requires while balancing the need for denser, more closed canopy stands for other wildlife species by utilizing various vegetation treatments in combination with prescribed fire. 3.50 Walsh, Jeremy “Scientist: Money to fight beetles as fire mitigation The Forest Service could not access this article thus this response is only to not productive” the quotation provided. The concepts of the interaction between fuels and Durango Herald, April 23, 2010 weather have already been addressed in the responses to opposing views http://durangoherald.com/sections/News/2010/04/23/Scientist_Mon #1, #3, and #4. The quotation does not appear to be applicable to the High ey_to_fight_beetles_as_fire_mitigation_not_productive/ Valley project because there are no current beetle infestations to be mitigated within the project area. 3.51 Westerling, Anthony Ph.D., “Does Global Warming Increase Forest NPR interview with Anthony Westerling regarding global warming and Fires?” increases in large fire acres. Creating more resilient landscapes will allow NPR, Talk of the Nation, July 7, 2006 for more safe and effective management of wildfires. http://www.npr.org/templates/story/story.php?storyId=5541423 3.52 Wuerthner, George Opinion piece in Eugene Weekly that discusses concerns with climate and “The Climate Factor - Forest thinning won't deter the coming large fuels treatments fires” Eugene Weekly, December 6, 2007 http://www.eugeneweekly.com/2007/12/06/views3.html 3.53 Wuerthner, George. “Logging, thinning would not curtail wildfires” The This is an opinion article in response to a guest viewpoint presented in The Register - Guard (Eugene Ore.), December 26, 2008 Register-Guard, the daily newspaper for Eugene, Oregon. The guest http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not- viewpoint discusses wildfires and why a stronger agency role is needed in curtail.html assisting communities to develop, implement, and monitor local efforts to reduce hazardous fuels on public and private land. The selected text states that fire is a natural part of many forested ecosystems and can increase biodiversity. It further goes on to suggest that wildfire is underrepresented on the landscape and will likely continue to increase with global warming. The High Valley Project does not dispute these statements. 3.54 Wuerthner, George “Forest Service misses education opportunity” The cited article is unsupported opinion commentary criticizing a fuels Published in NewWest, June 2010 reduction project on the Helena National Forest. The article is irrelevant to http://www.newwest.net/topic/article/elliston_face_is_yet_another_ the High Valley project because the opposing view only addresses the example_of_forest_service_malfeasance/C564/L564/ particular conditions found on the HNF project area and the HNF’s analysis of those conditions. There can be no comparisons made between the HNF’s project and the Griffin Creek II project as that information is not provided by the commenter.
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Referenced Document Forest Service Consideration/Response 3.55 Wuerthner, George “Pine Beetle Fears Misplaced” The cited article is unsupported opinion commentary stating that bark Helena Independent Record, March 25, 2010 beetle-induced tree mortality creates new ecological opportunities, http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d- increases biodiversity, improves ecosystem health, and reduces fire risk. 001cc4c002e0.html This article is irrelevant to the High Valley project because salvage of dead and dying trees is not proposed. 3.56 Wuerthner, George, “WHY THINNING FORESTS IS POOR WILDFIRE Article discussing thinning effectiveness and wildfire control. There is a STRATEGY” consistent theme to these fires. They all burned under extreme fire weather Published in the Wildlife News, January 27, 2014 conditions—and often burned through thinned forests, clearcuts, overgrazed http://www.thewildlifenews.com/2014/01/27/why-thinning-forests-is- rangelands and previously burned acreage. In other words, fuel reductions poor-wildfire-strategy/ did not appear to appreciably change the course of these blazes. It goes on to explain why thinning is ineffective , “There are good reasons to believe that thinning cannot and will not effectively halt such blazes. First, most thinning projects are not done properly. A properly performed fuels reduction project would include not only mechanical removal of smaller trees and reduction of canopy density, but also broadcast prescribed burning to reduce ground fuels. In fact, mechanical thinning alone often INCREASES fire spread by putting more fine fuels on the ground.” The High Valley Project displays that harvest, thinning, and prescribed burn treatments will effectively modify fire behavior within treated areas and reduce the intensity of a potential wildfire under normal summer conditions. Following harvest activities, the slash will be treated to reduce fire hazard. 3.57 Egan, Timothy, “Fires Not Caused by Reduced Logging, Article discussing the Clinton administration plans to release its CongressionalReport Finds” recommendations on how to manage more than 40 million acres that are Published in the New York Times: September 1, 2000 considered to be at extreme risk of wildfires. A report by a bipartisan http://www.nytimes.com/2000/09/01/us/fires-not-caused-by-reduced- research group for Congress has found There appears to be no link logging-congressional-report-finds.html between reduced logging on national forests over the last decade and the wildfires now raging through much of the West. If anything, heavy logging from earlier years may have contributed more to the conditions that have made Western forests ripe for big fires, because more flammable small trees and heavy brush are often left in the forest after the larger stands of timber have been taken out. The High Valley Project displays that harvest, thinning, and prescribed burn treatments will effectively modify fire behavior within treated areas and reduce the intensity of a potential wildfire under normal summer conditions. Following harvest activities, the slash will be treated to reduce fire hazard. 3.58 Hanson, Chad, “The Big Lie: Logging and Forest Fires” Opinion piece Published in the Earth Island Journal, Spring 2000 http://yeoldeconsciousnessshoppe.com/art6.html
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Referenced Document Forest Service Consideration/Response 3.59 “Logging can 'greatly increase' fire severity for 50 years, Article discussing the effects of clear felling areas adjacent to towns and researchers say” increased fire risk. Broadcast on ABC News Australia, August 3, 2014 Clear cut prescriptions are not proposed for the High Valley project. http://www.abc.net.au/news/2014-08-04/logging-greatly-increases-fire- Restoration treatments would be designed to reduce the threat for risk-black-saturday-study/5646220 uncharacteristic wildfire disturbances. 3.60 Campbell, James, “Study finds logging increased intensity of Black Article discussing an Australian study that concluded, that clear fell logging Saturday fires” increased the danger from bushfire. Published in the Herald Sun, August 03, 2014 Clear cut prescriptions are not proposed for the High Valley project. http://www.heraldsun.com.au/news/victoria/study-finds-logging- Restoration treatments would be designed to reduce the threat for increased-intensity-of-black-saturday-fires/story-fni0fit3- uncharacteristic wildfire disturbances. 1227012027799 3.61 Sonner, Scott AP, Study challenges views about Western forest fires News article giving a brief summary of a study of field notes taken teams of Published in the Daily World, July 23, 2012 government land surveyors in the mid-1800s attempting to map the nation’s Link: http://www.thedailyworld.com/sections/newswire/northwest/study- wild lands. The transects covered 250 miles in three states. challenges-views-about-western-forest-fires.html 3.62 More Logging Won’t Stop Wildfires Opinion piece on why the author’s oppose pending legislation to allow more By Drs. CHAD T. HANSON and DOMINICK A. DELLASALA post-fire salvage logging. The New York Times, Jul 28, 2015 http://www.oregonwild.org/about/press/more-logging- won%E2%80%99t-stop-wildfires
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Referenced Document Forest Service Consideration/Response Opposing View-Attachment #4 These opposing views include science authored by 268 Ph.D. scientists (see pages 41-50) who are world-class experts in forest ecology. Their statements support the fact that logging directly assaults the recreating public and many natural resources in the forest 4.1 Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and The cited reference is primarily a general overview of fragmentation as it Implications” pertains to wildlife habitat. Fire history studies on the Boise National Forest http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Eff indicate that the forest experienced fires ranging from frequent, low severity ects%20and%20Implication.pdf under burns to large stand-replacing fires. These fires produced a variety of habitats and naturally fragmented the forest cover. Proposed timber harvests within the High Valley project area watersheds will not alter the landscape outside the range of conditions that would likely occur naturally over time in this area. The wildlife effects analysis adequately addresses the issue of fragmentation by assessing habitat connectivity impacts. The EA demonstrates habitat connectivity will be maintained. Past regeneration harvest units within this drainage are 15 or more years old and have sufficient regrowth to provide adequate cover for wildlife species. The High Valley Project does not propose any new clearcuts. Another of the proposals set forth in this article is the inclusion of buffers. The High Valley Project proposes buffers along stream courses. 4.2 Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr and R. This study was of debris slides in the Klamath Mountains in which 3/4 of the R. Ziemer Ph.D. "Logging and forest roads related to increased slides were found on steep slopes (over 70 percent) and half on the lower debris slides in southwestern Oregon." Journal of Forestry Vol. 83, third of slopes. The Klamath Mountains topography, geology, and climate is No. 4. 1985. vastly different from the High Valley planning area. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF Only 1.1% of the project area is identified as moderate to high risk of landslides. Design feature SW-9 requires that site-specific management measures or mitigations shall be required where the proposed activities might initiate landslides (EA, Appendix A). 4.3 “Applying Ecological Principles to Management of the U.S. This report outlines key ecological considerations that should underlie sound National Forests” Issues in Ecology Number 6 Spring 2000 forest management as listed by the panel. The quote from the commenter re: http://cfpub.epa.gov/watertrain/pdf/issue6.pdf Road Construction Opposing View 3 could not be located in this report. 4.4 Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi “Evaluating the Abstract only. Commenter has quoted “Plot-level studies have demonstrated Effects of Forest Roads on Shallow Landsliding” Geophysical the ability of forest roads to intercept and route both subsurface and surface Research Abstracts, Vol. 5, 13312, 2003 overland flow more efficiently to the stream network.” http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf This study is very difficult to apply to Idaho as there is very little relevance of this reference to the proposed project area. The landscape, climate, soils, and geology of Italy are so different that almost no correlation could be reached. However, the general concepts of subsurface “throughflow” are discussed in the Hydrology report. Only 1.1% of the High Valley project area is identified as moderate to high risk of landslides. Design feature SW-9 requires that site-specific management measures or mitigations shall be required where the proposed activities might initiate landslides (EA, Appendix A).
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Referenced Document Forest Service Consideration/Response 4.5 Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins This article describes a hydrologic model designed in the boreal forests of “Predicting the Effects of Forest Roads on Streamflow using a central Saskatchewan and Manitoba, Canada. This model was studied in an Distributed Hydrological Model” area with vastly different rainfall/snowmelt, temperature, soils, and vegetation from a poster presented at the fall meeting of the American Geophysica conditions than in the High Valley Project Area. The Megahan-Ketcheson Union, San Francisco, CA, December 1996. Model used in the sediment analysis for the High Valley Project was developed approximately 21 miles northeast of the High Valley project area in http://www.ce.washington.edu/~lxb/poster.html similar soils, climate and geology to the project area. 4.6 Reice, Seth, Ph.D. from a press conference with Senator Robert This document is Dr. Reice’s statement in support of the Act to Save Torricelli, April 28, 1998, America’s Forests. He highlights that disturbances such as fire are natural http://www.saveamericasforests.org/news/ScientistsStatement.htm and can be good for the forest. The High Valley Project does not dispute this statement. Dr. Reice specifically speaks about how fire suppression can lead to a disturbance of natural succession. Fire suppression is outside the scope of the High Valley Project. 4.7 Brister, Daniel. "A Review and Comment on: Forest Service Roads: Opinion on USFS report. The focus is on the relationships between roads A Synthesis of Scientific Information, 2nd Draft, USDA Forest and sedimentation in streams. Service." December 1998. The cited paper is commentary on a national report on scientific information http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific- regarding the state of National Forest roads. The opposing views are beyond information-socio-economic-impacts the scope of the High Valley project, as they are general in nature and contain no specific information related to the High Valley project; nor does the commenter demonstrate a specific connection to this project. Negative effects from road construction activities are not anticipated, primarily due to the location and design of the roads and the use of appropriate erosion control measures, including well-established Best Management Practices. 4.8 Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 This paper is on salvage logging in Canada to recover potential revenue that "Evaluating effects of large-scale salvage logging for mountain is lost as trees (mostly lodgepole) die and may slow the spread of beetles to pine beetle on terrestrial and aquatic vertebrates." Mountain Pine other areas and the effects of salvage logging on vertebrates. Beetle Initiative Working Paper 1. Canadian Forest Service. The high Valley project is not a salvage project. https://www.for.gov.bc.ca/hfd/library/documents/bib92944.pdf
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Referenced Document Forest Service Consideration/Response 4.9 Burns, James W., "Some Effects of Logging and Associated Road In the project referenced, 66 km of road were constructed, including four Construction on Northern California Streams." Transactions of the crossings, within 76 meters of the stream. The entire area between the road American Fisheries Society, Volume 1, Number 1, January 1972. and stream was logged and dozers disturbed over 41 percent of the stream http://www.fs.fed.us/psw/publications/4351/Burns72.pdf length in the stream to remove slash and skid trees. Total biomass of invertebrates did not decrease. Recolonization occurred within 2 years and total biomass increased over the control stream (N. Fk Caspar). Salmonid populations recovered to within 20 percent of preconstruction level within 2 years. Author stated that most damage was caused by dozers operating in the stream. The relevance of this article to the Griffin Creek II project is something of a "lessons learned" tale about the importance of minimizing ground disturbance in and near streams. The practices described in the paper from 1972 are avoided during modern forest management activities. The High Valley project has riparian habitat conservation areas between all harvest units and streams. 4.10 Brown, George W. Ph.D., The Impact of Timber Harvest on Soil and This article warns against using broad generalizations in addressing the Water Resources effects of logging on the environment. Specific issues addressed are water Dr. BROWN is the Forest Hydrologist, School of Forestry, Oregon State temperature, sedimentation, soil impacts, mass failures (landslides), and flow University regimes. All these issues are addressed in a project-specific manner in the http://andrewsforest.oregonstate.edu/pubs/pdf/pub1695.pdf High Valley Water Resources Technical Report. 4.11 From Forest Roads and Sediment Project This project is in process and conclusions are forthcoming. The authors are PROJECT DURATION:1 January 2011 to 30 November 2019 testing sediment delivery from forest roads in Virginia using the WEPP Published by Virginia Tech University Model. Precipitation, climate, vegetation, and soils in Virginia are different By W. Mike Aust,Ph.D., Kevin McGuire, Ph.D., M. Chad Bolding, Ph.D. than in the High Valley project area. It is acknowledged that roads can impact and Scott Barrett, Ph.D. sediment delivery to streams. Sedimentation from roads is analyzed in the http://hydro.vwrrc.vt.edu/research/projects/forest-roads-and-sediment- High Valley Water Resources Technical Report, with an increase in sediment project/ delivery in the temporary time frame and a reduction (improvement) in sediment delivery in the long-term tie frame due to reduced road miles near stream channels (Water Resources technical Report, pages 44-52). 4.12 Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks Letter from Chief, communication between employees regarding the concern made to Forest Service employees and retirees at the University of about roads on the environment. Montana. February 1998. This speech advocated, in part, for a more carefully managed National Forest https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/ transportation system. Specifically: 1) More carefully considered decisions to Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20S build new roads, 2) Eliminate old unneeded roads, 3) Upgrade and maintain ervice%20Employees%20and%20.htm the roads important to public access, and 4) Develop new and dependable funding for forest road management. Concepts discussed in the speech were used in the analysis for the High Valley project as they addressed items 1 through 3. Item 4 is outside the scope of this project.
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Referenced Document Forest Service Consideration/Response 4.13 EPA entry into the Federal Register: March 3, 2000 (Volume 65, This entry into the Federal Register was entered by the US Forest Service, Number 43) Page 11675, "National Forest System Road not the EPA. This entry was to inform the public of their opportunity to Management." comment on what was at that time a proposed rule change that would http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day- provide for a new travel analysis process (TAP). This process is currently in 03/g5002.htm effect and was used to develop the roads proposal identified in Alternative B and Alternative C (Project record, Forest Wide Travel Analysis Process, Addendum 1 to the Final Report, High Valley Integrated Restoration Project). 4.14 “Forest Fragmentation and Roads” Eastern Forest Environmental The provided reference is a webpage from a Forest Health Monitoring Threat Assessment Center U.S. Forest Service - Southern Research National Technical Report from the Southern Research Station of the USDA Station Forest Service. This document discusses the effects of roads related to http://www.forestthreats.org/publications/su-srs-018/fragmentation habitat fragmentation across the U.S. It is general in nature. The paper provided neither site-specific nor species-specific information relative to High Valley project nor the management of Boise National Forest management indicator species or designated threatened, endangered, or sensitive species 4.15 Forman, Richard T. and Lauren E. Alexander “Roads and their Major Quote is abstract from paper. This paper is a comparison of The Netherlands, Ecological Effects” Annual Review of Ecology and Systematics, Vol. Australia, and the United States on roads and their effects. 29: 207-231, November 1998 The High Valley Project would reduce the miles of road in the project area, http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29 including non-system routes by 24.6 miles (EA, table 3) .1.207?cookieSet=1&journalCode=ecolsys.1 4.16 Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Paper. Commenter reiterates two of the many questions that the panel Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified specified under "III. Considerations for Ecosystem-based Management Forest Management to Achieve Watershed and Forest Health: A Approaches" suggests as a checklist of important considerations that should Critique." A National Wildlife Federation publication sponsored by the be included in fashioning and/or evaluating an ecosystem-based Bullitt Foundation management plan. http://www.coastrange.org/documents/forestreport.pdf This article identifies a number of concerns related to logging. These include, among others, increased risk of mass failure, changes in flow regime, and the effects of roads. The effects of the High Valley Project to each of these resources are described in the Water Resource Technical Report 4.17 Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” David Frey is writing about another report authored by Noon, Black and NewWest.net, 3-03-10 DellaSalla which states that climate is the leading driver of fire not beetle kill http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_re and that thinning should be focused on Wildland Urban Interface. A quote by port_says/C41/L41/ Frey is that cutting roads into current roadless areas could bring harm to wildlife, soils and fisheries. The original report was not referenced or linked so could not review the original article. There are no inventoried roadless areas within the High Valley Project area. Both action alternatives would result in a net reduction in the miles of road. Vegetative treatments would be designed to improve ecosystem resiliency in the face of uncertain future climatic conditions. 4.18 Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan Commenter quoted the Introduction of this paper in regards to stream "Diversion Potential at Road-Stream Crossings." USDA Forest crossings of roads. Service. 9777 1814—SDTDC. December 1997. The High Valley Project would remove 23 stream crossings on non-system http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf routes (Water Resources Technical Report, pg. 47).
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Referenced Document Forest Service Consideration/Response 4.19 Gable, Eryn “Battling beetles may not reduce fore risks – report” Land The commenter has quoted Barry Noon. This opinion piece is on tree Letter, March 4, 2010 thinning and logging across millions of acres of Western lodgepole pine and http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire- spruce-fir, and suggests that it is unlikely to reduce fire risk or alleviate future risks-report/ large-scale epidemics of bark beetles and that limited funds should be used for WUIs. The Vegetation Technical Report in the project record addresses the insect and disease hazard. Vegetative conditions within the High Valley project are dissimilar from homogenous lodgepole pine and spruce fir forests. 4.20 Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the This study is by the USDA Forest Service Southern Research Station on four forest road system." In: Proceedings of the conference 34 different alternatives for filtering sediment laden road run-off before it reaches international erosion control association; ISSN 1092-2806. [Place of the forest floor in Alabama. It studied vegetation, riprap, sediment fence, and publication unknown]: International Erosion Control Association: 301- settling basins. 310. This study occurred in Georgia. The soil description indicates that the study http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf area has a soil texture similar to that found in the High Valley project area. However, the peak 10 yr. 24-hr rainfall event would be far more intense than that of the project area. The results of this study found that vegetation, sediment fence, and settling basins were effective treatments for reducing sediment movement from the road prism. The High Valley Project requires sediment treatments to reduce sediment from roads. These include seeding (vegetation), and straw wattles or slash filter windrow (similar to silt fences, but more effective in a snow dominated climate such as the High Valley project area), (Design Features RM-3 and SW-5, EA Appendix A) 4.21 Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. This synthesis goes through a wide variety of beneficial and detrimental and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of effects of roads on social-economic, wildlife, aquatics, landscape scale and a Scientific Information." USDA Forest Service, General Technical general consideration of road networks. From the paper: "Roads are a vital Report PNW-GTR-509. component of civilization. They provide access for people to study, enjoy, and http://www.fs.fed.us/pnw/pubs/gtr509.pdf commune with forested wildlands and to extract an array of resources from natural and modified ecosystems." The High Valley Project would reduce the miles of road in the project area, including non-system routes by 24.6 miles (EA, table 3), while maintaining the rodd system needed to meet management and recreational needs (Project record, Forest Wide Travel Analysis Process, Addendum 1 to the Final Report, High Valley Project).
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Referenced Document Forest Service Consideration/Response 4.22 Hann, W.J. et al. 1997. Landscape dynamics of the Basin. Pp. 337- Not the full document. (Abstract only, preface, Science team members, 1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of volume contents and acknowledgements). A quote from the abstract states Ecosystem Components in the Interior Columbia Basin and Portions of “As compared to historic conditions, the terrestrial, aquatic, forest, and the Klamath and Great Basins: Volume II. USDA Forest Service, PNW- rangeland systems have undergone dramatic changes. Forested landscapes GTR-405 are more susceptible to fire, insect, and disease than under historic http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf conditions.” The High Valley Project endorses this type of management and the purpose and need strives to return the area to a more fire dependent system normally found under historical conditions. 4.23 Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Commenter quote is summary from paper. This paper is the study of whether Macroinvertebrate Soil Fauna of the Southern Appalachian roads affect the abundance and richness of macroinvertebrate fauna in the Mountains” soil leaf litter in the Southern Appalachian Mountains. The Southern http://www.jstor.org/stable/2641904 Appalachian Mountains topography, geology, and climate is vastly different from the High Valley planning area, thus this paper is not applicable to the High Valley project area. 4.24 Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D., Murray K. Clayton Commenter quote is the beginning of the papers summary. This paper Ph.D., Roger B. Hammer Ph.D., and Charlotte E. Gonzalez-Abraham mapped roads in northern Wisconsin from aerial photographs between 1937 Ph.D. “Road Development, Housing Growth, and Landscape to 1999 to improve the understanding of the dynamics of road networks over Fragmentation In Northern Wisconsin: 1937–1999” Ecological time and their effects on landscape patterns, and to identify significant Applications: Vol. 16, No. 3, pp. 1222-1237. relationships between road changes and other land-use changes. http://www.esajournals.org/doi/abs/10.1890/1051- This article indicates that increased road density leads to greater 0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journ environmental impacts, particularly to increased fragmentation and reduced alCode=ecap patch size. The High Valley Project would reduce road density from 7.9 mi/mi2 to 6.0 mi/mi2. 4.25 Ivins, Molly Creators Syndicate, August 3 1997 08 03 Article with the viewpoint that the Forest Service is logging in inappropriate http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997- steeper slopes with landslides occurring as a result of logging and road 08-03.html building. Slope stability and effects to soils was addressed in the Hydrology Technical Report. Only 1.1% of the project area is identified as moderate to high risk of landslides. Design feature SW-9 requires that site-specific management measures or mitigations shall be required where the proposed activities might initiate landslides (EA, Appendix A). 4.26 Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple This paper looks at the effects of road networks on stream and riparian Ph.D., and Kai U. Snyder. "Effects of roads on hydrology, networks in steep mountain watersheds, with high precipitation, forest cover, geomorphology, and disturbance patches in stream networks." and road networks, principally the H. J. Andrews Experimental Forest on the Conservation Biology 14, No. 1. 2000. western slopes of the Oregon Cascades. http://www.jstor.org/stable/2641906 Topography, geology, and climate in the High Valley project area is vastly different from westside Oregon. The High Valley Project would reduce road density from 7.9 mi/mi2 to 6.0 mi/mi2.
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Referenced Document Forest Service Consideration/Response 4.27 Kahklen, Keith. "A Method for Measuring Sediment Production from This objective of this paper is to provide a method of measuring sediment Forest Roads." Pacific Northwest Research Station, USDA Forest production from roads and sediment transportation from roads to small Service. Research note PNW-RN-529, April 2001. streams. http://www.fs.fed.us/pnw/pubs/rn529.pdf This article describes a methodology useful for experimental design and would be too intensive to be practical for project analysis. In addition, the study was completed in southeast Alaska where rainfall events are far more intense than in the Northern Rocky Mountains. The Megahan-Ketcheson Model used in the High Valley Project sediment analysis was developed in Silver Creek approximately 21 miles northeast of the High Valley Project Area. The methodology used to develop the model included flumes to measure flow and catch basins to measure sediment, as well as portable rainfall collection devices similar to the design used in the Alaska study. 4.28 Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Letter about the Beschta report (not peer-reviewed science) and why the Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt Subcommittee on Forests and Forest Health should abide by it anyway. The from a letter to the Subcommittee on Forests & Forest Health U.S. Beschta report focuses on the impacts to the environment from road House of Representatives. 3 July, 2002. construction and timber harvest associated with salvage harvest. http://www.westerntrout.org/trout/Reports/bosworth_response_to_Salva The High Valley Project is not in a wildfire area and is not proposing any ge_report.pdf salvage. 4.29 Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament Article on decline of songbirds in Connecticut and along the eastern as experts ponder the decline of dozens of forest species” National seaboard due to forest fragmentation. Wildlife The effects of the High Valley Project on migratory birds has been addressed http://www.nwf.org/News-and-Magazines/National- in the Wildlife Technical Report. Wildlife/Birds/Archives/1992/Singing-the-Blues-for-Songbirds.aspx 4.30 Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona Publication that discusses the restoration of roads and different methods to University Ecological Restoration Institute publication Working Paper restore a road. 12. June, 2005. The High Valley Project proposes to restore a net total of 24.6 miles of roads http://library.eri.nau.edu/gsdl/collect/erilibra/import/Lowe.2005.Working and non-system routes in excess of road construction (EA, Table 3) Paper12RestoringForest.pdf 4.31 Luce, Charles H. Ph.D., 2002. "Hydrological processes and This paper addresses cutslope surfaces and road hydrology and the need for pathways affected by forest roads: what do we still need to learn?" more research. The researcher says that a great deal of literature on forest Hydrologic Processes: 16, 2901–2904. roads focuses on road tread and the impervious nature of it and we should http://www.treesearch.fs.fed.us/pubs/23954 look at better ways to decompact them after use. The High Valley Project would reduce the miles of road in the project area, including non-system routes by 24.6 miles (EA, table 3) 4.32 Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Although not referenced, this document supports the watershed analysis for Road Effects on Stream Channel Networks in an Eastern Sierra water and sediment yield and road densities. The High Valley project Nevada Watershed." Journal of the Nevada Water Resources proposes road improvements to minimize effects to water and sediment yield Association, Volume 2, Number 2, Fall 2005. to streams and reduces road impacts to streams. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_ The High Valley Project would reduce the miles of road in the project area, article4.pdf including non-system routes by 24.6 miles (EA, table 3)
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Referenced Document Forest Service Consideration/Response 4.33 Malecki, Ron W. “A New Way to Look at Forest Roads: the Road Article from a gentleman who developed a Road Hydrologic Impact Rating Hydrologic Impact Rating System (RHIR)” The Road-RIPorter, System (RHIR) to assess the impacts of roads in an area. The model also Autumn Equinox, 2006 can be used to identify roads that are contributing to impacts in the http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf watershed and should be targeted for rehabilitation or decommissioning. The roads analysis for the High Valley Project used a different model, the GRAIP LITe model, to identify roads that would impact water resources. This model was used to identify road segments that could need treatment. Five miles of roads determined to be needed for long-term management would be realigned (relocated) farther from stream channels. Twenty-one miles of non- system routes would be decommissioned (EA, Table 3). 4.34 McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging Comment is the abstract. This is an old paper on roads where type of road roads in northwestern California: How much is avoidable?" Journal and road location play a large part in road-related erosion. Best Management of Forestry 8(1): 23-26. Practices and updated technology are utilized today to help locate roads in a http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf suitable and sustainable location where needed. The High Valley Project includes road realignment that relocates roads away from stream channels. Best Management Practices used to reduce sediment from roads includes, erosion control seeding, straw wattles, straw bales, or slash filter windrows (Design Features RM-3, and SW-5, EA Appendix A). 4.35 McFero III, Grace, J. "Sediment Plume Development from Presentation written for 2004 ASAE/CSAE Annual International Meeting in Forest Roads: How are they related to Filter Strip Canada. It is about utilizing turn-outs, and turnout spacing along the road Recommendations?" An ASAE/CSAE Meeting Presentation, Paper length, and Best Management Practices (BMPs) to help control sediment Number: 045015, August 1-4, 2004. movement and resulting sediment plumes from the road system. http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf This article recommends minimum streamside management zones (SMZs) based on sediment delivery distances from roads. For the High Valley Project, sediment plume distances are predicted using the Megahan- Ketcheson Model (Ketcheson and Megahan 1996). These distances were used to predict where and to what extent sediment would be delivered to streams. For the Boise National Forest, SMZs are named riparian conservation areas (RCAs). For the High Valley Project, RCA widths range from 130 feet to 260 feet, far more than the 30 meters recommended in McFero 2004.
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Referenced Document Forest Service Consideration/Response 4.36 McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist This study was conducted to determine to what extent logging activities and Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and road building have changed the overall landscape structure, especially patch logging on landscape structure in the San Juan Mountains, structure in mature forests at elevations over 7,874 feet. If the analysis was Colorado (USA)” Landscape Ecology, Volume 16, Number 4 / May, done in suitable timberlands then the number of patches increased but the 2001 overall size decreased as the result from timber harvest and road building http://www.springerlink.com/content/w12557624742tv77/ activities than the landscape as a whole. If all the study area land was included then only small changes in landscape structure was noted. This paper also states: “We investigated the magnitude of change in landscape structure resulting from roads and logging since the onset of timber harvest activities in 1950. We found limited evidence for significant impacts in our study area when all lands within the landscape were considered.” The paper makes a distinction between the impacts of roads and timber harvest at different scales and at areas of different management emphasis. This reference also includes a discussion about how not all sediment sources from roads can be avoidable. Road maintenance and application of BMPs prior to project implementation will decrease the effects the existing roads have on the stream network. The Water Resources section of Chapter 3 of the EA acknowledges the effects roads can have on sediment production and includes design criteria to reduce sediment in the project area. 4.37 McLellan, Bruce N. “Relationships between Human Industrial This paper is about grizzly bears and the relationship between roads, their Activity and Grizzly Bears” Bears: Their Biology and Management, use of habitat close to roads, and how timber harvest may alter their habitat, Vol. 8 International Conference on Bear Research and Management especially in remote areas. February 1989 (1990), pp. 57-64 There are no known grizzly bears, nor is there any grizzly bear habitat in the http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/Mc High Valley project area. Clellan_8.pdf 4.38 Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from Article for the 2003 Seattle Geological Society of America discussing the Forest Roads in Washington State” from a presentation presented at Washington Road Surface Erosion Model and its associated database. The the 2003 Geological Society of America meeting. emphasis is on the relationship between roads as a source of sediment in the http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm area. Washington State prescribes a road surface erosion model for use on state and private lands within Washington State. For the High Valley Project, the Megahan-Ketcheson Model (Ketcheson and Megahan 1996) was used. This was a more appropriate model to use because it was developed in the Northern Rockies 21 miles from the High Valley Project Area. This model was developed for granitic soils and the climate found in Southwest Idaho.
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Referenced Document Forest Service Consideration/Response 4.39 Montgomery, David Ph.D., Statement at a Press Conference with This opposing view is beyond the scope of project level planning such as Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save High Valley as the view more directed at national level budgetary priority America’s Forests April 28, 1998, U.S. Capitol setting. http://www.saveamericasforests.org/news/ScientistsStatement.htm Forest Service policy at the national level concerning road management is in part found in the Code of Federal Regulations and Forest Service Manual (FSM) direction Project level planning regarding transportation management was conducted using this travel analysis process. The Travel Analysis for High valley is found the project file. 4.40 Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the The cited reference is an opinion piece that discusses the effects of all roads Road to Destruction” Wildlands CPR in general and potential mitigation measures to reduce the effects. Many of http://www.wildlandscpr.org/ecological-effects-roads the effects discussed in this paper are those associated with paved, well- maintained, high-speed roads. However, it is recognized that lower-standard, unpaved Forest roads can have effects as well. Specifically, the article addresses the following potential road-related impacts: road kill, road aversion, isolation of populations, barriers, negative edge effects, invasive weeds, loss of forest interior habitats, brown-headed cowbird parasitism, human access, poaching, collisions, snag removal, and increases in fire ignitions. In a section titled Impacts on Terrestrial Habitat, the article states that “A narrow logging road with no maintained verge would not be expected to generate substantial edge effects, particularly if surrounded by a tall forest canopy. In this sense, the road would not differ much from a hiking trail (even trails create some edge effects, however, such as invasion of weedy plants caused by pant- legs dispersal). As forest roads are ‘improved,’ road clearance increases and allows more penetration of sunlight and wind. Edge species are then attracted to these openings. Two-lane roads with maintained rights-of-way and all interstate highways are lined by edge habitat. A forest criss-crossed by improved roads may be largely edge habitat, and its value for conservation of native flora and fauna diminished accordingly.” This rationale acknowledges that small forest roads typically have much less of an impact on wildlife than larger, higher-volume road systems. The ID Team wildlife biologist is well aware of the effects of forest roads on wildlife habitat. The analysis of the impact of forest roads on wildlife and their habitat at the project level is thoroughly presented in the Wildlife Technical report. In response to the third paragraph of this opposing view regarding national level transportation policy, please see the response to comment 4.39.
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Referenced Document Forest Service Consideration/Response 4.41 Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on Commenter quoted the abstract. The Ovenbird is a Neotropical migrant that habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): prefers deciduous/conifer (maple, basswood, pine forests) closed canopy 937-946. forests in the east and is a rare vagrant west of the Rockies (NatureServe http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html 2012). 4.42 Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution Paper on how roads and logging contribute to fragmentation by dissecting of Roads to Forest Fragmentation in the Rocky Mountains." large patches into smaller ones creating more edge effects. Conservation Biology 10: 1098-1106. See response to 4-1 http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm The Wildlife section in the EA discusses the existing condition and habitat effectiveness of the area considering the current density of roads. 4.43 Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Commenter quoted the abstract. This paper is on road surface erosion and Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. how much is actually from the roadbed itself, how much is from other http://www.fs.fed.us/psw/publications/reid/psw_1984_reid001.pdf sources, and how important is this road surface source in comparison/relation to those other sources in western Washington. Topography, climate, and geology are different in western WA than the High Valley project area The Megahan -Ketcheson Model (Ketcheson and Megahan 1996) used for predicting sediment delivery distances for the High Valley Project estimates sediment derived from the entire road prism. 4.44 Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss Paper on roads being the 'backbone' of society, the problems associated with 1994. "What do we know about Roads?" USDA Forest Service. roads and options for roads (restricted use, closing). The paper discusses the http://www.fs.fed.us/psw/publications/reid/4Roads.htm relationship between roads and sedimentation. We agree that roads are likely to deliver sediment to streams, especially if the roads are near stream channels. For this reason, the High Valley Project proposes to realign roads away from stream channels and to decommission all non-system routes in the project area. 4.45 Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. This paper is on the effects of roads and logging in a pair of watersheds- one 1979. "Watershed's Response to Logging and Roads: South Fork was logged and one was left alone as a control. Streamflow and of Caspar Creek, California, 1967-1976." USDA Forest Service, sedimentation was measured over several years and analyzed separately. Research Paper PSW-146. This study addresses suspended sediment in streams from road building and http://www.fs.fed.us/psw/publications/rice/Rice79.pdf timber harvest. The High Valley Project would reduce sediment compared to the existing condition or the no action alternative (Alternative A) by realigning roads away from streams (Water Resources Technical Report pages 44 to 52) and incorporating a non-harvest buffer of at least 130 feet, with no heavy equipment such as log skidders within 260 feet of a waterbody (High Valley Project design features SW-2 (Alterantive B) and SW-2 (Alternative C) (EA Table 3)
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Referenced Document Forest Service Consideration/Response 4.46 Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road This paper's study area is in southern Tennessee and northern Georgia Erosion, Sediment Transport and Model Validation in the Southern looking at a major river (supplies drinking water, being considered for Wild Appalachians." Presented at the Second Federal Interagency and Scenic status) where the researchers are working with an erosion model Hydrologic Modeling Conference, July 28 – August 1, 2002. (Sediment Tool) to help prioritize road improvement projects by looking at http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf severity of sediment erosion and transport, sediment impacts on water quality, road usage, and potential effectiveness of restoration. The tool studied in this article was developed for use in the southern Appalachian Mountains of Georgia and Tennessee. They were developed for sedimentary and metamorphic rocks of this area and a mild marine influence climate. In contrast, the High Valley Project include primarily granitic parent material and a climate with both maritime and continental influences, with snowfall-dominated precipitation. The sediment delivery model used for the High Valley Project was developed 21 miles from the High Valley Project at Silver Creek, ID in the same granitic geology, and climate. 4.47 Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger This article discusses the relationship between roads and habitat 2005. “Effects of Roads on Elk: Implications for Management in effectiveness for wildlife species. Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical The effects of roads on elk from the High Valley project are disclosed the editor, The Starkey Project: a synthesis of long-term studies of elk and Wildlife Technical Report. mule deer. Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf 4.48 Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads” The portion of this article cited discusses the negative effects of roads on The Interagency Forest Ecology Study Team (INFEST) newsletter wildlife such as habitat fragmentation, increased access, disturbance and http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm vehicle collision mortality. It also cites a decline in habitat use near open roads by grizzly bears. The effects of roads on elk from the High Valley project are disclosed the Wildlife Technical Report. 4.49 Shanley, James B. and Beverley Wemple Ph.D. “Water Quantity and This research is on mountain stream hydrology and the Quality in the Mountain Environment” Vermont Law Review, Vol. importance/vulnerability to mountain development (ski areas, resorts) due to 26:717, 2002 harsh environment for vegetation, thin soils, and high snowfall. This article is http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf concerned with effects of ski areas and resorts in Vermont. The climactic conditions in Vermont vary greatly from the Northern Rocky Mountains. The northeastern United States has regular precipitation throughout the year while the arid west has a prolonged annual summer drought. As a consequence, a larger percent of precipitation falls as snow (usually over 60% of annual precipitation) than in Vermont (about 30% according to the article. Also, this article is concerned with ski area and resort development, which is different than road construction and obliteration and timber harvest in that the ski resorts produce greater disturbance, often over a smaller area than timber harvest.
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Referenced Document Forest Service Consideration/Response 4.50 Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in This paper looks at location of the road, road width, cutslope, and number of the Southern Appalachian Mountains." Southern Journal of Applied vehicle trips on the road in relation to soil loss. It also examines whether Forestry 8: 209-216. 1984. grass along the slopes or a light layer of gravel in the roadbed gravel would http://cwt33.ecology.uga.edu/publications/403.pdf affect soil loss. This article addresses soil loss (erosion) from roads in the southern Appalachian Mountains. That area has a different climate than that in the High Valley project area. Rain falls through much of the year. Snow melts after several days in the study while in the High Valley area snow persists from three to five months of the year. The study did, however make some general conclusions that may apply to High Valley. One is that seeding grass on fill slopes reduces erosion. The High valley Project proposes to seed disturbed soils (Design Feature SW-5, EA Appendix A). Another is that gravel properly placed on the travel surface reduces erosion. The High Valley Project proposes to gravel an additional 5.3 miles of road and replace gravel on an additional 9.0 miles (EA, Proposed Action Description, Chapter 1) 4.51 Switalski, Adam “Where Have All the Songbirds Gone? The paper provided neither site-specific nor species-specific information Roads, Fragmentation, and the Decline of Neotropical Migratory relative to the Lower Priest project or the management of IPNF management Songbirds” indicator species or threatened endangered or sensitive species. Samson Wildlands CPR, September 8, 2003 1997 states, “Recent experimental evidence suggests habitat fragmentation http://www.wildlandscpr.org/node/213 in ecosystems with a high natural disturbance has little effect on species survival rates owing to the adaptation of natural disturbance regimes." Estill (1996) and Samson recommend not addressing the issue of fragmentation at the project level. 4.52 Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. Commenter quoted the abstract. This paper is on road construction during “Review of Ecological Effects of Roads on Terrestrial and Aquatic the past century and how it is the most widespread form of natural landscape Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, modification. This, in turn, modifies animal behavior, increases mortality from February 2000 road kill and alters habitat and how road maintenance contributes to an http://www.transwildalliance.org/resources/200922144524.pdf increase in chemicals being added to the environment. The effects of roads on elk from the High Valley project are disclosed the Wildlife Technical Report. 4.53 Watson, Mark L. "Habitat Fragmentation and the Effects of Roads Literature review on habitat fragmentation and road construction. on Wildlife and Habitats." Background and Literature Review 2005. The effects of roads on elk from the High Valley project are disclosed the http://www.safepassagecoalition.org/resources/Habitat%20Fragmentati Wildlife Technical Report. on.pdf
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Referenced Document Forest Service Consideration/Response 4.54 Wisdom, Michael J., Richard S. Holthausen Ph.D., Barbara C. Wales Roads/road density and wildlife are discussed in the Wildlife Technical report Ph.D., Christina D. Hargis Ph.D., Victoria A. Saab Ph.D., Danny C. Lee Ph.D., Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames. "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications .Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000. http://www.treesearch.fs.fed.us/pubs/3081 4.55 Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council Letter to Rogue River-Siskiyou National Forest re: Motorized Vehicle Use Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou Draft Environmental Impact Statement concerning the amount of open roads National Forest Travel Management Team and the effects of those roads on that Forest. http://www.pacificrivers.org/protection-defense/comment- This is specific to the Deschutes National Forest. letters/Rogue%20River%20Siskiyou%20TMP%20DEA.pdf 4.56 Wuerthner, George 2008 “Ecological Differences between Logging Comments on a blog website. The commenter suggests a relationship and Wildfire” between roads and fragmented habitat. Additionally, roads can be a vector http://wuerthner.blogspot.com/2008/12/ecological-differences-between- for invasive species spread. logging.html The High Valley Project discloses the impacts of the project on wildlife habitat, including fragmentation in the Wildlife section of the EA. The project also includes invasive plant prevention practices to keep invasive species from being introduced into the project area. Currently the project area only has a few populations of invasive species even though the area has been previously logged and roaded. 4.57 Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Article regarding the impacts of forest fragmentation and the impacts to Land Trust newsletter, 2004 wildlife species. http://www.ourbetternature.org/forestfrag.htm The Wildlife section in the EA discusses the existing condition and habitat effectiveness of the area considering the current density of roads.
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Referenced Document Forest Service Consideration/Response Opposing View-Attachment #11 Caring USFS Officials will Always Take the Most Effective Action Available to Reduce the Risk Of Homes Burning and Loss of Life should a Wildfire Start Near Neighborhoods Located in the Woods Not Analyzing an Alternative in Detail that Applies Dr. Cohen’s Fine Fuels Removal Methods Discussed below Indicates the Responsible USFS Official Believes Timber Removal resulting from Hazardous Fuels Reduction Logging is more Important than Preventing Homes from Burning 11.1 Fact Sheet: Understanding Fire and Fire Behavior Summary paper of basic fire principles: Ontario Aviation and Forest Fire Management Fire follows the laws of physics. It is predictable that if there is fuel, oxygen, http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf heat, and a source of ignition, something will burn. In wildlands, the amount of fuel is the only element we can control to reduce the risk of wildfire. • Homeowners are their own first line of defense. Saving a home from wildfire depends primarily on two factors: roofing material and the quality of the “defensible space” surrounding it. • Aggressive creation of defensible space around homes, combined with hazardous fuels reduction to explicitly protect communities, will go a long way to reduce the risk of wildfire to communities. • There are two principal reasons for restoring greater forest ecosystems to improve forest ecosystem health and reduce hazardous fuels. 1. The first is that plume-dominated fire and extreme fire behavior can overtake wildland-urban interface treatments and ignite fire in a community. This may be in the form of surface fire, crown fire, or embers moving in front of a fire. 2. The second relates to the unequivocal and critical relationship of forested communities to their greater ecosystems. “Removing biomass and fuels only in the wildland-urban interface can help protect homes and businesses. However, protecting resource values such as water quality, forest health and productivity, wildlife habitat, and recreation values requires vegetation and fuel management at a landscape scale. Fuel treatments carried out over large landscapes can reduce both the size and severity of wildfires and their effects on communities and the environment.” Fire behavior models developed by Mark Finney indicate that by locating fuel breaks in strategic locations it is possible to treat only 20% of the landscape and modify fire behavior. This approach is an effective first step to maximize protection and buy time while ecological restoration proceeds at the landscape level. Ecological restoration will be a necessary prerequisite for the reintroduction of natural fire on a large scale.
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Referenced Document Forest Service Consideration/Response 11.2 Source: Wildland-Urban Fire—A different approach Document supports that it is not reasonable to form agency and public http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf expectations for the non-occurrence of wildland fires, including wildland fires encroaching on communities. 11.3 Reducing the Wildland Fire Threat to Homes: Where and How Much? This paper was read for background information regarding home Presented as the Fire Economics Symposium in San Diego, California survivability in the wildland-urban interface. Finney and Cohen (2003) on April 12, 1999. [See pages 1-6] discussed the success of fuel management treatments for the purposes of http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf benefiting wildland values in addition to increasing home survivability. Concepts from both papers were used broadly. 11.4 Structure Ignition Assessment can Help Reduce Fire Damages in the This article focuses on structure home loss in the instance of wildland fire. WUI [See pages 4-5] The objective of the High Valley project is not to protect human built Published in Fire Management Notes, Volume 57 No. 4, 1997 structures. http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf 11.5 Examination of the Home Destruction in Los Alamos Associated with Discusses how suppressing wildfire among numerous highly flammable the Cerro Grande Fire July 10, 2000 houses was too much for typical wildland firefighter personal to handle. Source: USDA Forest Service, Rocky Mountain Research Station, Missoula, Montana, 2000. [See page 4] http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20co py.pdf 11.6 The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Discusses change in fire management policy and the relationships between Exclusion Paradigm [See pages 24-25] wildfires and the causal linkage to WUI fire disasters. Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf 11.7 Thoughts on the Wildland-Urban Interface Fire Problem, June 2003 . Discusses the dilemma of suppressing all fires. Fire suppression direction is [See page 2] not a project level decision. http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf 11.8 Saving Homes from Wildfires: Regulating the Home Ignition Zone This article focuses on structure home loss in the instance of wildland fire. Published in Zoning News, May 2001 [See page 1] The objective of the High Valley project is not to protect human built http://www.battle-creek.net/docs/fire/Zoning.pdf structures. 11.9 What is the Wildland Fire Threat to Homes? [See pages 4-11] Document supports the project in that fire brands are a threat to structure Presented as the Thompson Memorial Lecture, April 10, 2000 ignition when they ignite flammable material near the structure. Fire brands http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf traveled 1 kilometer in this study. 11.10 Modeling Potential Structure Ignitions from Flame Radiation Exposure The opposing views associated to Cohen and Butler is of the same nature with Implications for Wildland/Urban Interface Fire Management and scope as the previous opposing views found above. Please see the Presented at the 13th Fire and Forest Meteorology Conference. Lorne, responses to all the opposing views above. Australia, 1996 [See pages 81, 86-end] http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialigniti ons.pdf
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Referenced Document Forest Service Consideration/Response 11.11 Preventing Disaster Home ignitability in the Wildland-Urban Interface This article focuses on structure home loss in the instance of wildland fire. Published in the Journal of Forestry 98(3): 15-21, 2000 The objective of the High Valley project is not to protect human built [See pages 15-21] structures. http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf 11.12 Objectives and considerations for wildland fuel treatment in forested This document was not used in the project analysis. It discusses long term ecosystems of the interior western United States fuel planning to create conditions in which fire can occur without devastating Published in Forest Ecology and Management 256, 2008 consequences. It also identifies the Federal agency dilemma that the home [See pages 1998-2000] ignition zone largely occurs on private lands and most land management http://www.firewise.org/Information/Research-and-Guidance/WUI- agencies do not have the authority to mitigate the WUI ignition potential Home-Ignition- directly, so are forced to take indirect routes. Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment. pdf
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Referenced Document Forest Service Consideration/Response Opposing View-Attachment #15 These opposing views include science authored by 268 Ph.D. scientists (see pages 41-50) who are world-class experts in forest ecology. Their statements support the fact that logging directly assaults the recreating public and many natural resources in the forest 15.1 Excerpts from an interview with Hilda Diaz-Soltero Associate Chief for Interview, not a scientific publication. Associate chief discusses the Natural Resources, USDA Forest Service Women in Natural importance of integration of science and management sides of the Forest Resources, Vol. 21, No. 3, August-00 Service. Below is the quoted sentence in context: http://www.fs.fed.us/publications/2000/00nov02-Hilda-Diaz-Soltero- “I work with forest inventories, like the Forest Inventory and Interview.pdf Assessment, or the Natural Resources Inventory System. I am very much involved in trying to integrate the science and the management sides of the Forest Service. It’s very, very important that we conduct that integration, because our management decisions are scientifically based, and there is an ever-increasing need for more scientific information. Additionally, I get involved in selecting, mentoring, and training the next generation of leaders. It’s succession planning.” The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring. 15.2 Dr. Ann Bartuska, Deputy Chief for Research and Development, USDA Testimony, not a scientific publication. Discusses the use of best science Forest Service, Excerpt from testimony before the House Resources available. Below is the quoted sentence in context: Forest and Forest Health Subcommittee July 15, 2004 “Mr. Chairman, post-catastrophic forest restoration is a complex http://www.fs.fed.us/congress/108/house/oversight/bartuska/07150 process which begins almost immediately following a destructive 4.html event. Forest Service research works with managers to develop tools and information that these managers need to do their jobs better. Forest Service managers strive to use the best science available in their decision making. We realize there are questions still to be answered about the effects of our restoration activities, and we are working to find these answers. We also know that we would not be responsible stewards if we waited to satisfy all uncertainties before proceeding with our work. ”The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring.
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Referenced Document Forest Service Consideration/Response 15.3 Dale Bosworth Chief, USDA Forest Service Excerpt from a statement Statement, not published paper. Chief Bosworth indicated that in 2005 the before the Committee on Energy and Natural Resources United States Forest Service would work to accomplish watershed restoration efforts Senate March 3, 2004 under the Healthy Forests Restoration Act and that the Research Stations http://www.ourforests.org/fact/bosworthtestimony0304.pdf are committed to utilizing the best science available. Below is the quoted sentence in context: “We must also realize that it is not only the hazardous fuel reduction program that will improve overall forest and rangeland health. The integrated approach of multiple management activities in the agency’s wildlife, grazing, vegetative management, and timber programs will improve the condition of the land, or in the Forest Service vernacular ‘improve condition class.’ This emphasis encompasses one of the ‘four threats’ I refer to in managing this agency. We are committed to accomplishing the aggressive treatments planned in the President’s Budget for FY 2005 using new authorities in the Healthy Forests Restoration Act that improve the condition class of the nation’s watersheds and thus protect communities and resources for future generations – and our Research Station directors are committed to providing the Forest Service with the best science available.” The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring.
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Referenced Document Forest Service Consideration/Response 15.4 Sally Collins Associate Chief USDA Forest Service Excerpt from Statement, not published paper. Sally Collins is quoted that the use of best testimony before the Committee on Energy and Natural Resources, available science is needed. United States Senate July 11, 2006 The following is a quote pertaining to use of best available science in the http://www.fs.fed.us/congress/109/senate/oversight/collins/071106.html speech cited: “Our guidance also differs from the BLM due to continuing advances in wind energy technology, as well as new information on its affects on wildlife and civilian and military radar. Our direction will address these emerging issues to ensure it is based on the available best science. The Forest Service expects to publish the wind energy policy and handbook direction in the Federal Register this fall. The policy will call for the evaluation of wind energy proposals to be done at the Forest level using public comment processes due to the differing landscapes, habitats, wildlife populations, and public concerns unique to each site.” The impacts of wind energy are outside of the scope of the High Valley Project. No wind energy technology activities are proposed with this project. The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring.
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Referenced Document Forest Service Consideration/Response 15.5 Dale N. Bosworth Chief USDA Forest Service Excerpt from a speech Statement, not published paper. Chief Bosworth focused his statement on on Sustainable Management of the National Forests, at the Andrus the use of best science. The following is a quote pertaining to use of best Center for Public Policy, Boise State University December 12, 2001 available science in the speech cited: http://www.andruscenter.org/images/transcripts/Sustainable_transcript. “The system is broken. Analysis paralysis means really that we pdf can’t manage the land in the ways that the American people have come to expect. They expect us to use the best science, and we ought to use the best science. But we’re required to incorporate into the process every bit of new information that comes along. If the folks on the forest have been working away, and they are finally getting close to making a decision, some new information becomes available. They’re back to the drawing board to incorporate that new information. During the time that they’re incorporating that new information, another bit of new information comes in. Now they have to go back to the drawing board again and consider that new information. You can get yourself into just a vicious circle and end up never making a decision that you can sustain. People expect us to make timely decisions, and they expect us to act on them. They expect us to take care of the land while we’re doing it, but we’ll have to make some changes in the process.” The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring. 15.6 Sally Collins Associate Chief USDA Forest Service Excerpt from a Statement, not published paper. Sally Collins is quoted and implies that the speech to the Land Trust Alliance Rally “Protecting Open Spaces: use of best available science is needed to assure special areas are Partners in a Common Cause” October 31, 2004 managed in the long-term and that researchers and managers should work http://www.fs.fed.us/news/2004/speeches/10/open-spaces.shtml together to understand the consequences of our decisions. The following is a quote pertaining to use of best available science in the speech cited: “Third, always use the best science. Science can’t decide for us, but it can help us understand the consequences of our decisions. Forest Service Research and others in academia can deliver some of the best science and technical resources to help inform how these special areas should be managed for the long term.” The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring.
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Referenced Document Forest Service Consideration/Response 15.7 Statement by Heidi Valetkevitch, National Media Officer USDA Forest Statement, not published paper. The following is a quote pertaining to use of Service to Joe Bauman, reporter for the Deseret Morning News best available science in the statement cited: December 24, 2004 "’The new rule directs forest managers to use the best http://www.deseretnews.com/article/600100084/New-forest-rules-focus- science available to protect species at a landscape level,’ on-holistic-approach.html she said. The emphasis is to preserve ecosystems as a whole. The present rule requires attention on a species level, she said, while the new approach will be ‘much more holistic,’ examining the forest ‘from a landscape level.’" The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring. 15.8 Brown, Joel “Power to the People!” SRM Rangeland News, November Newsletter/opinion. The commenter included a quote from Forest Service 2007 Chief Abigail Kimball where she stated that management approaches http://www.rangelands.org/RN/Nov.RN07.pdf should be based on the best available science. On June 29, 2007, Chief of the Forest Service, Gail Kimbell expressed her support of employees participating in professional societies. In her letter she states: “As stewards of forests and rangelands, we must respond to the many challenges of managing a wide variety of resources and values. To meet these various challenges, a diverse and highly qualified cadre of natural resource and other professionals is critical to assure that management approaches are based on the best science. More than ever, it is important for each of us to continue to learn, enhance our resource knowledge, and develop innovative approaches to cooperatively conserve this Nation’s natural resources.” The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring.
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Referenced Document Forest Service Consideration/Response 15.9 Statement by Chief Dr. Mike Dombeck “Forest Chief Shifts focus to Statement, not published paper. Shifts focus of management to use best clean water” April 1998 TRANSITIONS available science. http://www.waterplanet.ws/transitions/tr9804/ Our jobs are not easy jobs, but conservation has moved from a 'special interest' to a national priority. The Forest Service must be a leader in using the best science and the best managers to accomplish "what I think is one of the noblest, most important callings of our generation bringing people together and helping them find ways to live within the limits of the land. That also is a marked shift for an agency more known for an attitude of limitless resource production from national forests. The High Valley project utilized the best available science in the development of the proposed action and alternatives, including treatment prescriptions, analysis of effects, and development of mitigation measures and monitoring. 15.10 Chief F. Dale Robertson From a June 4, 1992 direction letter to This links to a 1993 document from the Lolo National Forest pertaining to a Regional Foresters and Station Directors, Appendix B Chief F. Dale Five year review of their forest plan. It is not relevant to the High Valley Fire. Robertson From FIVE YEAFt REVIEW - B-3 # # The use of the “new perspectives” back in the 1990s was an effort to http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_053856.p consider more ecosystem based management in national forests and to use df science in the development of management actions. New perspectives had been replaced with an ecosystem approach to management actions and the use of best available science. The High Valley project utilized the best available science.
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Referenced Document Forest Service Consideration/Response 15.11 Smith, Ted “Chief's Ecosystem Stewardship Conference Workshop Conference transcripts, not scientific document. Emphasis is on using the Review” Eco-Watch, February 26, 1996 best available science to guide management. http://www.fs.fed.us/eco/eco-watch/ew960226.htm The following is a quote pertaining to use of best available science in the statement cited: In 1994 Chief Jack Ward Thomas of the U.S. Forest Service invited private foundations to join the USFS and other federal resource management agencies in co- funding a national workshop designed to bring the best science, broadly defined, to an 11-day workshop of agency natural resource managers. Having a science background himself, Thomas wanted to capture the scientific underpinnings of ecosystem dynamics in order to establish a more solid basis for sustainable resource management. Private foundations, invited for the first time to join the Forest Service in this way, would, Thomas felt, add legitimacy and assist in bringing in scientific talent from outside the government. The 11 days allocated to the Workshop, unusual by most standards, accommodated a vast range of scientific information—biological and socio-economic— which bears on resource management. But it also meant that scientists and resource managers would convene every afternoon in break-out sessions to wrestle with the "how to" issues. Chief Thomas committed himself to being present for two full weeks. He came. He stayed. And he (wisely) did not seek to conquer. When resource managers and scientists are thrown together, it appears that the managers work hardest in trying to understand the relevance of available science to their mandated responsibilities. Scientists, normally rewarded for producing good science, do not work quite so hard to understand what level of science the managers must command in order to do their jobs. The incentives are unequal—and this showed up in the plenary sessions where several of the scientists spoke to what they knew—not to what their audience needed to know. The High Valley project utilized the best available science, through the design of alternatives, different silvicultural treatments, assessment of effects, and determination of mitigation measures.
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Referenced Document Forest Service Consideration/Response 15.12 Agriculture Secretary Dan Glickman, From an Announcement of Interim This excerpt is from a speech in reference to an 18 month moratorium on Ban on Forest Road Construction, Washington, D.C., February 11, forest road construction in certain unroaded areas that went into effect so 1999 the Forest Service could revise its national road management policy. The http://www.usda.gov/news/releases/1999/02/0056 moratorium ended in 2000 and a new management policy was adopted in 2001. The High Valley Project does not propose construction of roads into roadless areas. The analyses completed in the specialist reports take into consideration, and make conclusions based on, research, science, reports, models, monitoring and site-specific information as it was available, in conjunction with scientific recommendations regarding the management of, and effects of, the project activities on the relevant resource. The High Valley Project documents a full environmental review informed by science. 15.13 Statement by USFS Chief Tom Tidwell From an interview with Rob Statement made by Chief Tidwell regarding the use of the best available Chaney of the Missoulian, June 19, 2009 science. http://westinstenv.org/sosf/2009/06/19/tidwell-interviewed-by-the- Chief Tidwell: I’m going to have a transition with Chief (Gail) missoulian/ Kimball [sic, Missoulian error]. The thing we see as our focus is implementing the economic recovery projects, the opportunity we had there to not only get a lot of essential work done but to provide jobs, especially in counties across the country where there’s high unemployment. We continue to move forward with our focus on climate change, to use the science that we have and apply that science so that natural systems are able to adapt to the various stressors that are occurring in the changing climate. Tidwell: We do have a leadership role. Part of it comes from the extensive research that our research-and-development branch of the agency has been doing for the last few decades. We have some of the best science, and we need to make sure we’re applying that, using that and sharing that as we move forward. I think we have a key leadership role, not only in the application of science but to help inform and educate our community and the folks we work, so they can understand the changes that are occurring, how it’s affecting the landscape and help us find solutions about how we need to change our management so these natural systems are able to adapt to various climate change stressors. The High Valley project utilized the best available science, through the design of alternatives, different silvicultural treatments, assessment of effects, and determination of mitigation measures.
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Referenced Document Forest Service Consideration/Response 15.14 Potyondy, John P. 2007 “The Evolution of Channel Maintenance The following is a quote pertaining to use of best available science in the Science in the Forest Service” Mr. Potyondy is the WO Watershed, document cited: Fish, Wildlife, Air, and Rare Plants Staff The USDA Forest Service Stream Systems Technology Center http://www.stream.fs.fed.us/afsc/pdfs/Potyondy.pdf was established in 1992, in part, to improve the scientific understanding of channel maintenance flows. Since that time, they have consulted with a wide array of scientists in the Forest Service, other agencies, universities, and consultants, with the aim of arriving at a consensus on the best science available to address this issue. Two specific areas need further research with respect to current channel maintenance science: First, much remains to be learned about sediment transport science in coarse- grained gravel bed channels typically found in the mountainous watersheds of the national forests; Second, much remains to be learned about streamside vegetation and species specific linkages between streamside vegetation and streamflows in mountain streams. As work in these areas continues, we can be certain that the science of channel maintenance will once again evolve in response to this new knowledge and the approach employed today may again need to be refined to reflect the new science. This article describes the dynamics of streamflows necessary to maintain stream channels. This is of particular concern when the government asserts a water right for instream flows. The High Valley Project would not measurably affect instream flows.
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Referenced Document Forest Service Consideration/Response 15.15 Melle, Ann R. “The U.S. Forest Service Approach to Forest Law This paper has discusses in a very broad way the many integrated aspects Enforcement” A presentation to the East Asia Ministerial Conference, of the U.S. Forest Service forest management and enforcement program. September 12, 2001 Ms. Melle is the Asst. Director of Law Enforcement The National Forest System consists of around 195 different and Investigations, USDS Forest Service administrative units totaling over seventy seven million hectares http://www.for.gov.bc.ca/hfd/library/documents/bib49682.pdf of land spread throughout the United States and its territories. These units represent a tremendous variety of ecosystems from the tropical forests of Puerto Rico to the mangroves of Florida to the high elevation boreal and bristlecone pine forests of our mountain west and Alaska. Many hundreds of types of forest products are harvested every year from Forest Service lands for personal and commercial use, including foods and flavorings, medicinal herbs and pharmaceuticals, decoratives, floral greenery and dyes, specialty wood items, landscaping plants, fuelwood, wood pulp and sawtimber products and by-products. The public demand for forest products changes rapidly, reflecting changes in the market place, shifts in technology, consumerism and social climate, new ways forest resources are valued, and shifts in the economy. The Forest Service manages the National Forest System's natural resources with a commitment to long term ecosystem sustainability, multiple use, local community involvement and economic stability, interaction of social and cultural values with forest resource management, and the use of management practices based on the best science available. This paper will focus on the management of sawtimber products, however, we apply similar concepts and programs to other forest resources. The High Valley project proposes vegetation management to achieve goals related to providing habitat for species reliant on more open habitat conditions. It does not concern law enforcement or investigations related to illegal activities.
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Referenced Document Forest Service Consideration/Response 15.16 Statements by retired Chief Dr. Mike Dombeck “Politics vs. Science,” The following is a quote pertaining to use of best available science in the October 19, 2006 Published by the University of Wisconsin, Board of statements cited: Regents. We asked Michael Dombeck, former head of the U.S. Forest http://whyfiles.org/247sci_politics/index.php?g=5.txt Service, why government should fund research when the results might not accord with its political interests. "That is the head-in- the-sand approach," says Dombeck, now a professor of global environmental management at University of Wisconsin-Stevens Point. "Not wanting to hear it doesn't mean it's not true, or that it doesn't represent the best science of the day. The responsible policy maker ought to seek out the best science, because ultimately that will yield the best result." “To put things in perspective, Dombeck says, "Science should not be the only driver of policy; there are economic, social and political concerns, but ... scientists can provide information that informs policymaking; 'If we adopt this policy, this will be the outcome,' and that certainly does not appear to be happening." “We can't leave the mishmash of political science without enjoying one irony: The U.S. government remains the world's biggest funder of science -- which is even probably true of climate science. As Greenberg says, "Most science goes on untouched. The scientists are given the money, and do their work without any political interference." Consideration of the social aspects related to timber harvest in concert with utilizing the best available science was accomplished with the High Valley Project, through the design of alternatives, different silvicultural treatments, assessment of effects, and determination of mitigation measures.
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Referenced Document Forest Service Consideration/Response 15.17 Kaufmann, Merrill R. 2005 “Good Fire, Bad Fire” Mr. Kaufmann is the USDA publication about the role of fire in forest ecosystems. The quote from Rocky Mountain Research Station's team leader for ecosystem the commenter is taken out of context, as the premise of the section of the management, Fort Collins, CO, USDA Forest Service paper that the comment comes out of is that the current condition on the http://csfs.colostate.edu/pdfs/Good_Fire_Bad_Fire.pdf ground (which is a result of decades of fire suppression) can be at least partially remedied through reintroduction of fire. Science and history tell us that much of the western landscape we grew up knowing and loving is an artifact of human management from the late 19th century. With fire removed from ecosystem processes, and nothing to limit shrub invasions in prairies or millions of seedlings in forests, our landscape has become unnatural and unsustainable. When fire strikes now, it’s a different problem because the land has been too long without. The first step in redressing this situation may be the most difficult—that of changing our collective perception of what a healthy and sustainable forest or prairie looks like. We have to learn to understand what we see, for we have grown up accepting our experience, believing the forests we see today are natural. To deliberately alter them seems contrary to the very ethic of good environmental stewardship. But good stewardship, and good ecology, often means realizing that many of today’s forests are not natural at all. Here the scientific community can help. Carefully done science can provide common ground for agreement among different stakeholders, enabling communities to unify. As a general rule, no. In many cases our forests, due to our tinkering, have become too vulnerable to runaway crown fires. Even the most carefully planned “controlled” burns may constitute unacceptable risk to the many people who live in or near the forest, at the wildland-urban interface. The best science available tells us that at some point we must reinstall this missing ecosystem process so the natural machinery functions properly again. We have to do it cautiously until our forests are restored to a more natural condition, and we may need treatments other than fire to reduce the risks of reintroducing fire. In many other places, such as some prairies and shrublands, it is only our perception of the role of fire that we must overcome to restore normal ecosystem processes. Fire can threaten ranch structures, but lack of fire can be a greater threat to long-term ranching livelihood. The High Valley project proposes to do exactly that - work towards returning the project area to more of a natural fire return interval.
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Referenced Document Forest Service Consideration/Response 15.18 Bravo, Aguirre Celedonio and Carlos Rodriguez Franco, compilers USDA publication from a symposium on future inventory and monitoring 1999. North American Science Symposium: Toward a Unified programs to hydrological responses to disturbance processes on a Framework for Inventorying and Monitoring Forest Ecosystem watershed scale. Resources. Guadalajara, Mexico (November 2-6, 1998). Proceedings The following is a quote pertaining to use of best available science in the RMRS-P-12. U.S. Department of Agriculture, Forest Service, Rocky testimony cited: Mountain Research Station The general objective of this Symposium was to build on the http://cwt33.ecology.uga.edu/publications/pubs_martha_new_0128200 best science and technology available to assure that the 3/Batch_2_@300dpi/PDF/1389.pdf data and information produced in future inventory and monitoring programs are comparable, quality assured, available, and adequate for their intended purposes, thereby providing a reliable framework for characterization, assessment, and management of forest ecosystems in North America. Central to the syntheses delivered in this Symposium was the conclusion that a fundamental improvement in the approaches used for inventorying and monitoring ecosystem resources is required to meet current and future environmental uncertainties. Specific actions were proposed to address these challenges. These strategic actions are described in the last chapter of these proceedings. The High Valley project utilizes the best available science combined with site specific data collection to make informed decisions regarding land management.
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Referenced Document Forest Service Consideration/Response 15.19 McDaniel, Josh 2007 “The Zaca Fire: Bridging Fire Science and Not peer reviewed/published document. The paper is regarding the use of a Management” Widland Fire Lessons Learned, predictive wildfire behavior model which was used on the Zaca Fire in http://www.wildfirelessons.net/Additional.aspx California in 2007 in order to facilitate fire suppression efforts during a wildfire. The following is a quote pertaining to use of best available science in the article: “The experience of the Zaca Fire demonstrates a window of opportunity to improve the link between science and management. A major concern often expressed in both fire research and fire management circles is that there is a lot of science being produced, but very little that can or is being incorporated (depending on your perspective) into fire management. There may be a current opening to change that state of affairs.” “This fire season has shown that fire management is changing at a more rapid pace than ever before. Point protection, AMR, and other non-traditional suppression techniques and strategies have become the norm. Much of this change is driven by necessity, as fire managers have struggled to fight larger and more intense fires over longer fire seasons with fewer resources. But, it is change nonetheless. And in this dynamic environment there is potential to build new more substantial links between science and the field. “ The Forest Vegetation Simulator was used to model wildfire hazard, incorporating site specific data with the best available science. 15.20 CENTER FOR BIOLOGICAL DIVERSITY v. UNITED STATES The referenced document is an opinion from the 9th circuit court regarding a FOREST SERVICE Argued and Submitted July 15, 2003. -- November lack of consideration of opposing viewpoints that goshawks are not 18, 2003 Before: KLEINFELD, WARDLAW, Circuit Judges, and generalists. POGUE, Judge. In the United States Court of Appeals, Ninth Circuit The Forest Service has reviewed and considered the opposing science http://caselaw.findlaw.com/us-9th-circuit/1173711.html viewpoints provided through the public involvement on this project. All documents referenced in this attachment, unless otherwise noted, are contained in the Project File.
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Appendix B – Full Text of Comments Submitted by Dick Artley, April 12, 2015 Dear Ranger Newton, Please read and consider my comments on the pre-decisional EA for the proposed High Valley timber sale below. Remember these wise words as you read my comments: “God has cared for these trees, saved them from drought, disease, avalanches, and a thousand tempests and floods. But he cannot save them from fools. John Muir You hide the information in your hardcopy Project File at the district that tells the public whether you will be applying an herbicide that is sometimes lethal to mammals (including humans) … Roundup. At page 101 of your pre-decisional EA you say: “Refer to the noxious weeds technical report available in the project record for the detailed supporting analysis, including evaluations of herbicides used to treat noxious weeds as part of the Forest’s Integrated Noxious Weed Program.” This could easily been posted online in an Appendix. I will expect this in the final EA. Roundup is especially toxic to children (see Issue #4) at page 8 below. I cannot believe Supervisor Seesholtz would approve of you planting the cancer seed in babies. ------Introduction Ranger Newton, of course you have already selected the alternative you will implement. You did this before you asked for scoping comments. Now you are passing the High Valley timber sale through the NEPA process to make it legal. Your IDT members (who know better) are helping you justify his decision. To the IDT members who are responsible to protect the amenity natural resources so loved by the public who provides the tax money for your salaries I ask you this. I understand why the names of the IDT members aren’t shown in Chapter 4. This EA violates NEPA more times than I have ever seen … and I have reviewed hundreds. Comment: It’s clear that the line-officers on the Boise National Forest did not learn from the Agriculture Department's inspector general’s findings based on a 1999 audit of the USFS timber program. The first sentence of the audit findings says this: “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.” This pre-decisional EA smoothes-over and minimizes the “environmental damage from logging” that will be caused by the High Valley timber sale.” A few IDT members know this but their position pays to well to jeopardize it by doing the right thing for future generations of Americans. The complete text of this USDA audit can be read at the following link:
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http://www.nytimes.com/1999/02/05/us/audit-faults-forest-service-on-logging-damage-in-us- forests.html Here’s the History of NEPA. Why is this new to you and a few of your IDT members? Congress promulgated and President Nixon signed the bill establishing the National Environmental Protection Act in 1969. NEPA is referred to as the “environmental Magna Carta.” The law was enacted on January 1, 1970. NEPA grew out of the increased appreciation and concern for the environment that resulted from the 1969 Santa Barbara oil spill. During this time, National interest in preserving the environment was bolstered by Rachel Carson's book, Silent Spring. Congress responded by passing the Wilderness, Clean Air, and Clean Water Acts. The preamble to NEPA reads: "To declare national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality.” NEPA describes a process that when followed will ensure that environmental factors are weighted equally when compared to other factors in the decision making process undertaken by federal agencies. NEPA was intended to help the decision-maker select the alternative that would benefit the public the most. NEPA is not a time-consuming, expensive, meaningless task as you believe it is Ranger Newton. Associate Chief Sally Collins describes how the new USFS deals with timber You all know your proposed timber sale is inconsistent with Ms. Collins’ observations below. “Post-World War II, we entered a new period characterized by timber production. From the 1960s to the 1980s, every administration, with strong congressional support, called for more timber harvest from the national forests, with the goal of replacing the depleted stocks of private and state timber as a result of the war effort. We measured success largely in terms of producing timber and providing multiple uses, including outdoor recreation and fish and wildlife. In the early 1990s, that changed again. Today, we’re in a new period focused primarily on ecological restoration and recreation. Maybe more than ever before, we are focusing on delivering values and services like clean air and water, scenic beauty, habitat for wildlife, and opportunities for outdoor recreation. Not only do Americans want these things from their national forests, but this shift is also essential to cope with some huge threats to the sustainability of these forests.” (pp 8-9) Forest Service Associate Chief Sally Collins “The Future of Partnering with the Forest Service” A speech presented at the Annual Meeting of the National Association of Conservation Districts Atlanta, GA—February 8, 2005. http://www.fs.fed.us/spf/coop/library/NACDspeech.pdf
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Deputy Chief Jim Furnish reflects on his USFS employment Please consider retired Deputy Chief Furnish’s observations in light of the proposed High Valley timber sale. Indeed, Mr. Furnish knows the USFS well. He was: 1968-1976 – forester on the Black Hills NF 1977-1984 – District Ranger on the Bighorn NF 1984-1989 – planning staff on the San Juan NF 1989-1991 – appeals coordinator in the WO 1991-1999 – forest Supervisor on the Siuslaw NF 1999-2002 -- Deputy Chief of the USFS in the WO Here are several quotes from his book. “What saddens me is that the head of a once-trusted agency implicitly admitted that its leaders lied and broke the law.” (page 11) “He (Jim Hagemeier) wanted these forests to retain their natural character, not become yet another forest landscape of cookie cutter homogeneity. For any forester schooled in agency dogma, this meant war. Bureaucratic war anyway. Foresters worked at maximizing timber production, minimizing cost, designing the best logging practices, ensuring a fair price for the sale, and overseeing logging operations toughly but fairly. You log it right, and people will like what they see --- or at least you explain to them that they should like it even if they don't." (pages 28 and 29) “In large part, forest plans held to the agency’s timber-first priority. Environmental groups waged war.” (page 59) “Fewer and fewer people accepted sweeping vistas dominated by clear-cuts and new roads. Instead, they valued naturalness, clean water, abundant fish and wildlife , and a deep sense of connection with the land. They were anguished at what the Forest Service was taking from the forest at the expense of future generations.” (pages 113 and 114) “A different set of societal values emerged, inviting the agency to change. The failure to respond to this value shift had profound consequences for the Forest Service. How many polls that show 90 of the people hate clear-cuts does one have to read before concluding that it’s time to do something different?” (pages 134 and 135) “Similarly, roadless areas had long been regarded by the Forest Service as merely the next place one goes to log more trees.” (page 151) “The timber industry, as well as many people in Forest Service leadership, continued to view roadless area protection antithetical of multiple use mandates.” (page 151) “Next, the agency leaders need to explicitly embrace the mandate of ecosystem management, which I would describe as value-driven resource management with a goal of maintaining or achieving naturalness. Primary values should be clean water and air, abundant fish and wildlife, quality recreation opportunities, and sustaining landscape function.” (page 198)
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Here is Mr. Furnish’s conclusion: “How much are public forests worth? They are priceless.” Comment: Ask yourself if Mr. Furnish would consider your High Valley timber sale one that: • uses agency dogma to further the “agency’s timber-first priority” • will create a “landscape of cookie cutter homogeneity” • will “take from the forest at the expense of future generations” • ignores emerging “societal values inviting the agency to change” • “explicitly embraces the mandate of ecosystem management” I suggest all USFS employees who wish to learn the truth buy Mr. Furnish’s book at: http://www.towardanaturalforest.com/ Please have the courage to read the book. Finally, ask yourself if you should be assisting to prepare the High Valley pre-decisional EA. Does the Boise National Forest ignore emerging “societal values” that scream out for the “agency to change”? You won’t regret taking this giant step forward. It’s not to late to reexamine the Purpose & Need. Based on your education and experience will logging 9 square miles and building 9 miles of road really improve the resources the P&N claims will be improved by logging? If your answer is “no” you aren’t committed yet. Please exit your denial mode and accept the truth. Comment: I saw it myself during my 31 years with the USFS. Here are the facts. The agency routinely and repeatedly showers its employees with information intended to teach them that satisfying the agency’s timber agenda transcends all other actions … including amenity resource protection. Agency foresters are taught timber is king and it’s their job to create private industrial tree farm conditions in the national forests. Their rewards system is based on timber outputs and acres “mechanically treated” (a.k.a. logged). Ask yourself why they describe logging using euphemisms. ------Issue #1 ----- Logging road construction causes significant ecological harm. Please analyze an action alternative in detail that does not construct any new roads(temporary or system). Comment: Table 3 on page 26 indicates you plan to construct 9 miles of new road as part of the Proposed Action. A report authored by Gerald Coghlan, WO Acting Director of Engineering in 1998 indicates there are 372,956 miles of existing national forest system road (page 5). The agency currently constructs 2,000 miles of system road per year. At this rate there are 409,000 miles now. In addition to that, there is at least double this amount in unsurfaced, sediment producing, outsloped, temporary roads that have not been totally obliterated and “put to bed” where the fill is returned to the cut. The average distance to the moon (it varies) is 384, 403 miles … and you propose more. Isn’t there enough road? Are you clinically obsessed to produce volume at any cost to the public land? See the 1998 report at this link: http://www.fs.fed.us/eng/road_mgt/roadsummary.pdf Please read Opposing Views Attachment #4.
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A “no road construction and reconstruction” alternative will likely reduce the sale volume some. However, it stands out among the possible action alternatives that should be analyzed in detail because it reduces the adverse environmental effects while still meeting the purpose and need for the project. Ranger Newton, some members of your IDT know this. Ask yourself why they are afraid to voice their opinions. Comment: Please don’t exclude a “no new road” alternative from analysis in detail by claiming the P&N will not be met. The P&N includes timber harvest but it does not specify a volume of number of acres. The “no new roads” alternative will reduce the acres treated, but will still meet the P&N since most harvest would still occur. This alternative is very important because it eliminates road-construction related adverse natural resource impacts. Comment: Without exception, road construction and reconstruction are activities that cause damage to some important natural resources in the forest. New road construction is particularly detrimental to aquatic and wildlife resources. Chief Dombeck’s statement below supports this fact. "Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road." Dr. Mike Dombeck, Chief, US Forest Service Remarks to Forest Service employees and retirees at the University of Montana February 1998 Link to statement: https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dom beck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm Opposing Views Attachment #4 contains statements by hundreds of Ph.D. scientists describing Chief Dombeck’s observations in greater detail. Comment: Since best science and Dr. Dombeck agree that there are “few more irreparable marks we can leave on the land than to build a road”, isn’t this is a valid reason to analyze a “no new road” alternative in detail? Comment: The Administrative Procedures Act directs judges to set aside an agency action if the court determines that the action is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). A line- officer who ignores best-science and instead makes a Decision on weak, meager evidence provided by people with financial interest in a sale being sold (i.e. IDT members that represent timber and engineering) is guilty of violating the APA. You have done this. Comment: Please don’t claim the No Action alternative satisfies this request to analyze a “no new roads” alternative in detail. The timber sale contains some actions that will benefit the ecosystem of the area. A “no new roads” alternative would include these actions. The P&N will still be met because volume will be available from existing roads. A “no new roads” action alternative is reasonable. It will benefit the forested ecosystem, it produces volume and reduces fuels, and eliminates the ecosystem damage caused by roads that is identified in Opposing Views Attachment #4.
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Request for changes to be made to the final NEPA document: Analyze a no road construction (including temp roads) action alternative in detail. This would satisfy the P&N. Just as with No Action, this alternative provides the public with the trade-off between the Proposed Action and an alternative with less volume and less environmental impact . . . especially to aquatic resources. Failure to analyze a timber sale with no new road construction will violate: • 40 CFR 1500.2(e) and (f) because the Responsible Official was unable to avoid or minimize adverse effects of the project upon the quality of the human environment without complete knowledge of all likely adverse effects. Most adverse effects of road construction activities described by scientists in the Opposing Views Attachment #4 was not mentioned in the final NEPA document EA. ------Issue #2 ----- If you apply herbicides that contain glyphosate (Roundup etc.) you will wake up each morning wondering how many people will die of cancer and how many kids will struggle through life coping with birth defects and autism … because you didn’t care. Page 101 of your scoping letter you say: “Refer to the noxious weeds technical report available in the project record for the detailed supporting analysis, including evaluations of herbicides used to treat noxious weeds as part of the Forest’s Integrated Noxious Weed Program.” I am saddened that you still believe all herbicides are similar and don’t bother to tell the public the herbicide brand name and formulation that will be sprayed. All (emphasis added) herbicides are toxic to mammals (including humans), birds and fish. A few can be lethal. Why isn’t there an herbicide specialist on the Boise NF that knows this? As I will show below, hundreds of independent Ph.D. chemists have written literature showing why glyphosate should never be applied anywhere at any time for any reason. Is it worth the risk when there are other ways to kill noxious weeds without killing people? You won’t be popular when your employees ……… and the judge, when the local public finds out you ignored this warning. Please do not apply herbicides that contain the chemical glyphosate. I present my reasons below. Ranger Newton, if you would not spray a chemical that might cause cancer on your property where children and pets might be, you should not decide to contaminate public land with the same chemical. Why would the FDA start testing food for glyphosate if it was safe? See: FDA to Start Testing Monsanto's Glyphosate in Food, February 19, 2016 http://readersupportednews.org/news-section2/318-66/35283-fda-to-start-testing-monsantos- glyphosate-in-food Do you really want to do business with Monsanto? Do you trust them to put more importance on public safety than profits? Please open and read this link posted by Global Research: http://www.globalresearch.ca/the-complete-history-of-monsanto-the-worlds-most-evil- corporation/5387964
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MONSANTO'S PESTICIDE IS TOP SUSPECT BEHIND MYSTERIOUS KIDNEY DISEASE Link: http://www.truth-out.org/news/item/34899-monsanto-s-pesticide-is-top-suspect-behind- mysterious-kidney-disease A ‘Lively’ Day at Monsanto Headquarters Link: https://www.organicconsumers.org/blog/%E2%80%98lively%E2%80%99-day-monsanto- headquarters MONSANTO'S ROUNDUP KILLS AND DAMAGES MORE THAN WEEDS Link: http://www.truth-out.org/speakout/item/34689-monsanto-s-roundup-kills-and-damages- more-than-weeds Ranger Newton, please change your draft NEPA document before it goes final. I don’t think you want to spew a known carcinogen on land enjoyed by families and children. Multiple scientific studies conclude even casual exposure to glyphosate causes terrible, health problems in mammals (including humans). This research shows Glyphosate exposure might cause cancer later in life. Glyphosate was first registered for use in the U.S. in 1974. In the last 40 years about 25 billion pounds of this poison has been sprayed in the United States. Please ask yourself if this might be a reason why there is currently a cancer epidemic in America. Please consider the following online information: “The public's appreciation of the toxicity of glyphosate—the active ingredient in Monsanto's broad-spectrum herbicide Roundup—is still limited, despite highly damning research being published. The fact that Monsanto marketed Roundup as "environmentally friendly" and "biodegradable" probably has a lot to do with this general lack of insight. More people are apt to remember the Roundup commercial than recall the fact that Monsanto was twice found guilty of false advertising of this herbicide. In 2009, a French court again upheld these earlier convictions. Mounting evidence shows that glyphosate is FAR more toxic than anyone previously suspected, both alone and in combination with other additives (as in the case of Roundup), or in combination with other agricultural chemicals and/or heavy metals. Dr. Donald Huber, one of the premier plant pathologists in the US, views it far more toxic than DDT. They are spraying nearly ONE BILLION pounds every year on our food crops. That is enough glyphosate to fill 4,000 Olympic sized swimming pools. Most recently, what's being referred to as "an epidemic" of chronic kidney disease—a mysterious form of toxic nephropathy—striking down farmers in Sri Lanka, India, and Central America's Pacific coastline (El Salvador, Nicaragua, and Costa Rica), has now been traced back to Roundup in combination with contaminated fertilizer.” “ Link: http://www.honeycolony.com/article/toxic-combo-roundup-fertilizers-blamed- tens-thousands-deaths/
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Herbicides that contain glyphosate are banned in Denmark, England, Italy, El Salvador, Sri Lanka, France, Holland, Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan, Chile, South Africa, Luxembourg, Madeira, New Zealand, Peru, South Australia, Russia, France, Switzerland, Columbia, and Costa Rica Please consider opening the links displayed in this WEB search http://www.bing.com/search?q=Roundup+Banned+in+What+Countries&first=1&FORM=PERE In September of 2015 the California Environmental Protection Agency announced its intention to label glyphosate as carcinogenic These links provide more information: http://guardianlv.com/2015/09/california-epa-to-label-glyphosate-as-carcinogenic/ http://www.fooddive.com/news/california-epa-pushing-to-label-glyphosate-as- carcinogenic/405238/ Monsanto Is Suing California for Trying to Inform People That Roundup Causes Cancer By Rebecca Spector, Center for Food Safety March 2, 2016 Link: http://www.alternet.org/environment/monsanto-suing-california-trying-inform-people- roundup-causes-cancer?akid=14027.303761.V7snL_&rd=1&src=newsletter1051814&t=19 The EPA has been in Bed with the Manmade Chemical Corporations for Decades. They will Finally be brought to Justice. Please read this article: “Lawsuit Targets EPA's Failure to Release Public Records on Toxic Herbicide” Excerpt: “The EPA has yet to fully comply with a Freedom of Information Act request filed by the Center two years ago seeking information about the EPA’s decision to register the pesticide cocktail. Today’s lawsuit seeks full public disclosure of those documents.” Link to full article: http://www.biologicaldiversity.org/news/press_releases/2016/enlist-duo-02- 03-2016.html Worldwide research on glyphosate safety indicates exposure to the toxic chemical causes the following human health complications: birth defects, miscarriages, premature births, cancer - non-Hodgkin’s lymphoma and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning disabilities, ADHD and other neurological disorders (especially in children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, decrease in the sperm count and chromosomal damage. Here’s the abstract discussing Roundup from the April 2013 science periodical Entropy: “Glyphosate, the active ingredient in Roundup®, is the most popular herbicide used worldwide. The industry asserts it is minimally toxic to humans, but here we argue otherwise. Residues are found in the main foods of the Western diet, comprised primarily of sugar, corn, soy and wheat. Glyphosate's inhibition of cytochrome P450 (CYP) enzymes is an overlooked component of its toxicity to mammals. CYP enzymes play crucial roles in biology, one of which is to detoxify xenobiotics. Thus, glyphosate enhances the damaging effects of other food borne chemical residues and environmental
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toxins. Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body. Here, we show how interference with CYP enzymes acts synergistically with disruption of the biosynthesis of aromatic amino acids by gut bacteria, as well as impairment in serum sulfate transport. Consequences are most of the diseases and conditions associated with a Western diet, which include gastrointestinal disorders, obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease. We explain the documented effects of glyphosate and its ability to induce disease, and we show that glyphosate is the “textbook example” of exogenous semiotic entropy: the disruption of homeostasis by environmental toxins.” Link: http://www.mdpi.com/1099-4300/15/4/1416 Here are the results of WEB searches on the 11 diseases and afflictions shown above that are missing from the SERA Report: “glyphosate” “autism” 354,000 hits. Here they are: http://www.bing.com/search?q=%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Cautis m%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D%20%E2%8 0%9Cautism%E2%80%9D&sc=6-21&sp=- 1&sk=&cvid=3BE172C360804C6CA5FCED95F44D6C65 “glyphosate” “dementia” 73,500 hits. Here they are: http://www.bing.com/search?q=%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Cdeme ntia%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D%20%E2% 80%9Cdementia%E2%80%9D&sc=0-0&sp=- 1&sk=&cvid=6F6D55E7534547E4B8AC483241265F5D “glyphosate” “infertility” 56,800 hits. Here they are: http://www.bing.com/search?q=%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Cinferti lity%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D%20%E2% 80%9Cinfertility%E2%80%9D&sc=2-26&sp=- 1&sk=&cvid=AEC0E7FF60614005BF62C2EAEFEC4FD5 “glyphosate” “diabetes” 975,000 hits. Here they are: http://www.bing.com/search?q=%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Cdiabet es%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D%20%E2%8 0%9Cdiabetes%E2%80%9D&sc=2-23&sp=- 1&sk=&cvid=C9456FBAC7414D76A3292BC5351401FF “glyphosate” “premature births” 32,600 hits. Here they are: http://www.bing.com/search?q=%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Cprema ture%20births%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D %20%E2%80%9Cpremature%20births%E2%80%9D&sc=0-0&sp=- 1&sk=&cvid=0243581D827147C9A67667B4F3880366
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“glyphosate” “asphyxia” 16,700 hits. Here they are: http://www.bing.com/search?q=%20%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Ca sphyxia%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E2%80%9D%20% E2%80%9Casphyxia%E2%80%9D&sc=0-0&sp=- 1&sk=&cvid=E4238949DBC54EEEAFB9A7F843385DC0 “glyphosate” “hairy cell leukemia” 61,800 hits. Here they are: http://www.bing.com/search?q=%20%E2%80%9Cglyphosate%E2%80%9D%20%E2%80%9Ch airy%20cell%20leukemia%E2%80%9D&qs=n&form=QBRE&pq=%E2%80%9Cglyphosate%E 2%80%9D%20%E2%80%9Chairy%20cell%20leukemia%E2%80%9D&sc=0-0&sp=- 1&sk=&cvid=6150F9120F7A4A3D8D3CB03652486A88 People that contemplate any risky action intuitively engage the Precautionary Principle. Please take this opportunity yourself. “The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking an action.” See: http://en.wikipedia.org/wiki/Precautionary_principle Important Concluding Statement: You and I both know that in the vast majority of cases, your Deputy Regional Forester will support your decision regardless of the allegations of violation of law IF they believe the objector does not have the resources or motivation to follow-up with court action. You know you can spray Roundup with impunity. What your Regional Forester cannot do is manipulate your conscience. He/she cannot prevent you from watching videos depicting: An autistic child trying to do things other kids do. How a family deals with a loved one with premature dementia. The look on a mothers face when she is yold her baby has birth defects. The last painful minutes of a person dying of cancer. The look on a person’s face when their doctor tells them they have diabetes. The stress and depression of a person told they have fatal kidney disease the day before. The sorrow of a woman who has just had a miscarriage People can be bribed and billion dollar corporations know how to do it. See; http://www.alternet.org/food/true-inside-story-how-college-professor-sells-out- monsanto?akid=13934.303761.P-FhZW&rd=1&src=newsletter1049885&t=11 The USDA has been in bed with Monsanto for decades Read “USDA Forces Whole Foods to Accept Monsanto”, February 3, 2016 Excerpts:
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“In a cleverly worded, but profoundly misleading email sent to its customers last week, Whole Foods Market, while proclaiming their support for organics and "seed purity," gave the green light to USDA bureaucrats to approve the "conditional deregulation" of Monsanto's genetically engineered, herbicide-resistant alfalfa. Beyond the regulatory euphemism of "conditional deregulation," this means that WFM and their colleagues are willing to go along with the massive planting of a chemical and energy-intensive GE perennial crop, alfalfa; guaranteed to spread its mutant genes and seeds across the nation; guaranteed to contaminate the alfalfa fed to organic animals; guaranteed to lead to massive poisoning of farm workers and destruction of the essential soil food web by the toxic herbicide, Roundup; and guaranteed to produce Roundup-resistant superweeds that will require even more deadly herbicides such as 2,4 D to be sprayed on millions of acres of alfalfa across the U.S.” Entire article at: http://readersupportednews.org/opinion2/265-34/34968-usda-forces- whole-foods-to-accept-monsanto There are alternatives to using Roundup or other herbicides that contain glyphosate. The choice is yours. Is it worth the risk? Please remember Theodore Roosevelt’s sage words: “No man may poison the people for his private profit.” Here, please read “Monsanto's Sealed Documents Reveal the Truth Behind Roundup's Toxicological Dangers” Excerpt: “Over the years a large body of independent research has accumulated and now collectively provides a sound scientific rationale to confirm that glyphosate is far more toxic and poses more serious health risks to animals and humans than Monsanto and the US government admit. Among the many diseases and health conditions non-industry studies identified Alzheimer’s, Parkinson’s and autism since Roundup has been shown to instigate aluminum accumulation in the brain. The herbicide has been responsible for reproductive problems such as infertility, miscarriages, and neural tube and birth defects. It is a causal agent for a variety of cancers: brain, breast, prostate, lung and non-Hodgkin lymphoma. Other disorders include chronic kidney and liver diseases, diabetes, heart disease, hypothyroidism, and leaky gut syndrome. In addition to lung cancer, glyphosate may be responsible for today’s growing epidemics of chronic respiratory illnesses among farm workers and their families.[6] However, these findings derive from outside the Big Agriculture industry. Private industries routinely defend themselves by positing their own research to refute independent reports. Consequently, for several decades it has been a he-said-she-said stalemate. Monsanto is content with this. It can conduct business as usual, Roundup sales increase, and the debates and media wars continue without government interference. Then who is protecting the public?” Link to entire article: https://www.organicconsumers.org/news/monsantos-sealed-documents- reveal-truth-behind-roundups-toxicological-dangers
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Here’s more Recent Evidence. The take-home message? Given the information above, anyone who knowingly applies this poison to land owned by other people could be tried for involuntary manslaughter. Article Title: Concerns over use of glyphosate-based herbicides and risks associated with exposures: a consensus statement. Excerpt: “In killing weeds and indeed almost all growing plants, the primary mode of glyphosate herbicidal activity is the inhibition of a key plant enzyme, namely 5- enolpyruvylshikimate-3-phosphate synthase (EPSPS). This enzyme is part of the shikimic acid pathway and is essential for the synthesis of aromatic amino acids that govern multiple, essential metabolic processes in plants, fungi, and some bacteria. Since this EPSPS-driven pathway does not exist in vertebrate cells, some scientists and most regulators assumed that glyphosate would pose minimal risks to mammals. However, several studies, some described below, now show that GBHs can adversely affect mammalian biology via multiple mechanisms.” Published by BioMed Central, February 17, 2016 Link to full article: http://ehjournal.biomedcentral.com/articles/10.1186/s12940-016-0117-0 Article Title: Science Used to Regulate Monsanto's Roundup Is Outdated, Says New Study Excerpt: “Despite the extensive and increasing use of glyphosate, we know little about how much of the chemical people are actually being exposed to. Here in the US, glyphosate is not among the pesticide residues for which the US Department of Agriculture (USDA) routinely tests food. It is also not included among the 200-plus chemicals on the US Centers for Disease Control and Prevention's (CDC) human biomonitoring program.” Published by TRUTHOUT, February 24, 2016 Link to full article: http://www.truth-out.org/news/item/34918-science-used-to-regulate-roundup- is-outdated-says-new-study My Concluding Comments: Ranger Newton you can believe one dubious glyphosate safety study, or you can depend on hundreds of independent scientists’ research conclusions. Most people would make a life or death decision based on best science. It’s your choice. Request for changes to be made to the final NEPA document: Include the herbicide information currently in the Project File in an appendix and assure the final EA states “herbicides that contain glyphosate will not be applied.” The decision document should also say this. Failure to tell the public this chemical will not be used leaves the door open for glyphosate application. This violates: 40 CFR 1501.2 (b), 40 CFR 1502.16(a) and (b), and 40 CFR 1508.8(b) because Chapter 3 omits important environmental effect disclosures (i.e. glyphosate exposure sometimes causes cancer) The Apr. 21, 1997 Executive Order No. 13045 because the Responsible Official does not ensure that this project will not disproportionately expose children to environmental health risks and safety risks. 40 CFR §1508.27(b)(2) because the FOIA intensity discussion fails to discuss the degree to which the proposed action affects public health or safety. ------
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Issue #3 – Some IDT members claim No Action will result in an increased probability of severe wildfires. This is inconsistent with the “best science” quoted below. Indeed, for decades USFS leaders have promised the public that agency projects will be based on “best science.” Clearly this is not the case with the High Valley timber sale. The effects disclosures written by the IDT members all indicate selecting the No Action alternative will be a tragic mistake that will decimate, ravage and annihilate the natural resources and recreation opportunities in the sale area as a result of fire. They are either clueless about the interaction between fire and logging or have no problem writing lies to make the No Action alternative appear to be a tragic choice. Either way they have no business being IDT members. Where were the fire specialists? Either they didn’t read the bungled effects disclosures in Chapter 3 predicting a catastrophic fire if it’s not harvested, or they have not kept up with the latest fire science. I invite you and all IDT members to examine independent science explaining how harvested areas interact with fire in Opposing Views Attachment #3. It contains conclusions written by 66 well respected scientists not affiliated with the USDA. They explain how harvesting an area does not reduce fire starts, fire intensity, or rate of spread. Some demonstrate how logging exacerbates fire behavior. The IDT members base their No Action effects on skewed, untrue so-called fire science authored by USFS employees. Here’s an explanation of how fuels logging came about. Comment: Bush appointed timber industry lobbyist Mark Rey to Under Secretary of Agriculture. This put him in charge of the USFS. Rey was sworn in by Agriculture Secretary Ann Veneman on October 2, 2001. Rey’s appointment was a calculated move. Rey knew his job was to invent more excuses to commercially log our national forests. Surprise! Rey did his job well. He played on the public’s fear of fire after the 2000 and 2002 fires. He knew they would accept anything … even ineffective fuels logging. Now the USFS routinely offers timber sales to reduce hazardous fuels. Prior to 2003 the USFS had no timber sales with hazardous fuels removal in the P&N. I invite you to check this out. Mark Rey’s March 3, 2003 testimony to the United States House of Representatives Committee on Resources about the Threat of Wildland Fire and the need to log hazardous fuels can be read at: http://www.wildlandfire.com/docs/2003_n_before/rey_testimony_2003.htm The following documents authored by independent scientists not connected to the USDA debunk Rey’s fuels logging policy. The IDT members are either unaware of this science or refuse to accept it. Please direct them to incorporate it in their No Action effects disclosures in the final EA. Commercial Logging Causes Forest Fires Published in FOREST CONSERVATION NEWS TODAY, July 20, 2002 OVERVIEW & COMMENTARY by Forests.org Link: http://forests.org/archived_site/today/recent/2002/grgrurge.htm
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Excerpts: “It is well known scientifically that “commercial logging actually increases fire severity by removing large, fire- resistant trees and leaving behind very small trees and flammable "slash debris"--branches, twigs and needles from felled trees. The removal of mature trees also decreases the forest canopy, creating hotter, drier conditions on the ground. The additional sun exposure encourages the growth of flammable brush and weeds. Reduction of flammable underbrush can reduce fire severity, and environmental groups have encouraged such projects. However, the Bush administration has grossly misused the funds that Congress appropriated for brush reduction near homes. In Sierra Nevada national forests last year, more than 90% of these funds were instead earmarked for preparation of large timber sales focused on the removal of mature and old-growth trees miles from the nearest town.” "The Forest Service, Bush administration and anti-environmental members of Congress are spreading a great deal of misinformation about wildfire, hoping to capitalize on public fire hysteria and minimize public opposition to increased logging and roadbuilding in our national forests," said Jake Kreilick of the National Forest Protection Alliance based in Missoula, Montana. "With virtually all new timber sales couched in terms of 'reducing fuels' or 'restoring forest health,' fire hysteria has emerged as the driving force behind the Forest Service's logging program and the administration's efforts to 'streamline' our nation's environmental laws," Kreilick said.” Fight Fire With Logging? Forestry experts have long known that commercial logging increases the risk of forest fire. So why, critics are asking, does the Bush administration's new fire prevention plan ignore that fact? By Dan Okoand Ilan Kayatsky Published by Mother Jones magazine, Wed Jul. 31, 2002 Link: http://www.motherjones.com/politics/2002/08/fight-fire-logging Excerpts: “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk." Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires. "The plan consists mostly of complaining about forest fires and ginning up more money for logging," Lawrence says.”
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A Burning Issue: Helping Loggers, Hurting Forests By Dr. Chad Hanson Published on Monday, July 15, 2002 in the Los Angeles Times Link: http://www.commondreams.org/views02/0715-04.htm Excerpts: “Scores of scientists and the federal government's own national fire plan have concluded that the removal of mature trees from forests increases the severity of forest fires. Why then would the Bush administration use the threat of fires to try to increase logging of mature and old-growth trees in our national forests? That is clearly the administration's intention, as outlined in two recent memos on revising the Northwest Forest Plan and the "Sierra Nevada Framework" plan to allow logging companies increased access to ancient forests on public lands. The move is being led by Mark Rey, a former timber industry lobbyist and a President Bush appointee who oversees the Forest Service.” “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) The wildland fires of 2002 illuminate fundamental questions about our relationship to fire By Dr. Timothy Ingalsbee Published in the Winter 2002 issue of the The Oregon Quarterly Link: http://www.fire-ecology.org/research/wildfire_paradox.pdf Excerpts: “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.” A Report to the President in Response to the Wildfires of 2000, By Lyle Laverty USDA Forest Service and Tim Hartzell U.S. Department of the Interior, September 8, 2000
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Link: http://frames.nacse.org/6000/6269.html Excerpts: "Most of the trees that should be removed to reduce accumulated fuels are small in diameter and have little or no commercial value." "Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities (including reducing fuels) it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats Published by the Government Accounting Office, GAO/RCED-99-65 Link: http://www.gao.gov/archive/1999/rc99065.pdf Excerpts: “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” Timber Industry Fails to Convince Judges that Logging Levels Linked to Wildfires Published by a New Century of Forest Planning, September 29, 2015 Link: http://forestpolicypub.com/2015/09/29/timber-industry-fails-to-convince-judges-that- logging-levels-linked-to-wildfires/ Excerpts: “In a decision dismissing three lawsuits intended to compel more federal land logging in western Oregon, DC federal district court judge Richard Leon found that the timber industry failed to show that less logging means more wildfires (see page 7’s footnote).” Judge Leon’s ruling likely ends a two-decades long legal skirmish by the timber industry to compel federal agencies to increase logging levels from Northwest Forest Plan lands. The campaign has been led by the Portland-based American Forest Resource Council. For 20 years AFRC chose primarily the courts as its strategy to
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increase logging. Today’s decision suggests that AFRC may change its focus from the courts to Congress Commercial Logging for Wildfire Prevention: Facts Vs Fantasies By Dr. Timothy Ingalsbee Link: http://www.fire-ecology.org/citizen/logging_and_wildfires.htm Excerpt: "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity." Sierra Nevada Ecosystem Project: Final Report to Congress Prepared by the USFS Pacific Southwest Research Station, 1996 Link: http://pubs.usgs.gov/dds/dds-43/ Excerpts: "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity" "Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes. In general, rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds." "As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high.” More Logging Won’t Stop Wildfires By Dr. Chad Hanson and Dr. Dominick DellaSala Published in the New York Times on July 23, 2015 Link: http://www.nytimes.com/2015/07/23/opinion/more-logging-wont-stop-wildfires.html?_r=0 Excerpt: “In the case of the Rim Fire, our research found that protected forest areas with no history of logging burned least intensely. There was a similar pattern in other large fires in recent years. Logging removes the mature, thick-barked, fire-resistant trees. The small trees planted in their place and the debris left behind by loggers act as kindling; in effect, the logged areas become combustible tree plantations that are poor wildlife habitat.” Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production By: Mark H. Huff; Roger D. Ottmar; Ernesto Alvarado; Robert E. Vihnanek; John F. Lehmkuhl; Paul F. Hessburg; Richard L. Everett, 1995 Link: https://www.frames.gov/rcs/6000/6691.html
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Excerpts: "As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon." "Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes…In general, rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds." Fire hazard from precommercial thinning of ponderosa pine. Research Paper (PNW-RP- 057) By: G.R. Fahnestock, 1968 Link: https://www.frames.gov/rcs/11000/11147.html Excerpt: "It appears significant that many large fires in the western United States have burned almost exclusively in slash. Some of these fires have stopped when they reached uncut timber; none has come to attention that started in green timber and stopped when it reached a slash area." Testimony to the Agriculture, Nutrition and Forestry Committee United State Senate. Hearing to Review Healthy Forests Restoration Act, HR 1904 June 26, 2003 By:, Arthur Partridge Ph.D., Professor Emeritus, University of Idaho Link: http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml Excerpt: “The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.” Study challenges views about Western forest fires, July 23, 2012 By: Scott Sonner, AP Published in the Daily World Link: http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views- about-western-forest-fires.html Excerpts: “More highly intense fire is not occurring now than historically in dry forests,” said William Baker, who teaches fire ecology and landscape ecology in Laramie, Wyo.,
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where he’s been doing research more than 20 years. “These forests were much more diverse and experienced a much wider mixture of fire than we thought in the past, including substantial amounts of high-severity fire.” “ “If he’s right, he and others say it means fuel-reduction programs aimed at removing trees and shrubs in the name of easing fire threats are creating artificial conditions that likely make dry forests less resilient.” “Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes.” “We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.” Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States (page 10) By: Dr. Jack Cohen (a USFS fire physicist) Published in Forest Ecology and Management, issue 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf Excerpts: “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999) “Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000) Researcher Finds Need for more Prescribed Burning By Tom Kuglin Published in the Helena Independent Record newspaper, June 17, 2015 http://helenair.com/news/local/researcher-finds-need-for-more-prescribed- burning/article_4a58c3c3-a7bb-5905-a505-4567e8107600.html Excerpts: “Finney presented his research on fire behavior in landscapes of varying levels of logging and prescribed burning at last week’s “Fire on the Landscape” lecture series in Helena. While logging or thinning is often touted as a means to mitigate fire, he has found it does little to stop a wildfire.” “There’s a confusion that if you do timber management you’re doing fuel management -- you’re not,” Finney said. “We’re not going to cut our way out of the problem, but there are ways to do this strategically, get the benefits and have a sustainable fire management approach.”
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“Finney found that fire “ripped through logged areas,” and only units where prescribed fire was introduced showed effectiveness in stopping or mitigating wildfire spread.” "Healthy Forests" and Wildfire Control: Accumulating Scientific Evidence By Dr. Thomas Power A Montana Public Radio Commentary, December 11, 2006 http://forestcouncil.org/so-called-healthy-forests-and-wildfire-control/ Excerpts: “But the Bush Administration and some of the leadership of the Forest Service want to use logging techniques in places far removed from homes and communities to reduce the threat of wildfire. The basic idea is that most of our forests are far too dense. There are way too many trees per acre. This, we are told, not only makes them "unhealthy" but also reduces their productivity for wood production and makes them prone to frequent and severe wildfires that damage the forests even further. Cutting down many or most of those trees is the proposed solution.” “Most of the dense forests that the Bush Administration and some in the Forest Service want to thin to return them to "health" are not unhealthy at all. Forest scientists have been studying the fire histories of our forested landscapes in more and more detail to try to understand their densities and fire behaviors in the centuries before we began grazing cows, harvesting trees, and suppressing fires in them. What they are finding is that a significant part of the forest landscape regularly had very dense stands of trees that every few centuries burned in large natural conflagrations. It was only the lower elevation forests that featured park-like mixes of large, almost inflammable, trees and open grasslands.” “This is not a pessimistic story. It means that we need to focus our forest fire protection where our homes, communities, and lives are threatened. We do not have to spend tens of billions of dollars trying to save our forests from themselves. The forests do not need it, thank you, and those billion dollar efforts would not work anyway. If we are careful where and how we live in forests and learn to accept fire as a natural part of a healthy forested landscape, both prescribed fire and natural fires, we can both protect ourselves and enjoy the benefits of diverse natural forests.” Study challenges views about Western forest fires By Scott Sonner AP Published in the Daily World, July 23, 2012 http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views-about- western-forest-fires.html Excerpts: “Researchers at the University of Wyoming studied historical fire patterns across millions of acres of dry Western forests. Their findings challenge the current operating
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protocol of the U.S. Forest Service and other agencies that today’s fires are burning hotter and more frequently than in the past. “It means we need to rethink our management of Western dry forests,” said Baker, a member of a U.S. Fish and Wildlife Service working group that is developing plans to help bolster northern spotted owl populations in dry forests. Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes. “We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.” The 60 science quotes contained in Opposing Views Attachment #3 clearly and unambiguously indicate the USFS’s claim that timber sales create conditions that reduce fire intensity and rate of spread is an untrue fabrication to justify fuels logging. True to form, some IDT members involved in the preparation of this pre-decisional EA have chosen to play fast and loose with the truth as they portray the effects of the No Action alternative as ghastly, disgusting, and frightful (see below). They know they will be punished if they don’t give the Responsible Official reason to select the Proposed Action. How do they do it? They claim doing noting will surely be catastrophic. The American people pay USFS experts in biology, soils, recreation, heritage etc. to conduct themselves in a professional manner. Unfortunately, most IDT members for this project opted to repeat USFS-approved text intended to promote the agency’s timber agenda. This is sad behavior by those paid by the American public to protect their beloved amenity resources from harm. I guess this is what happens when the effect disclosures are copied & pasted from previous EAs and EISs. Here are the deplorable logging/fire No Action effects disclosures authored by some IDT members: Comment: Dr. Jack Cohen (a USFS employee) and the 11 independent scientists quoted above all indicate logging does not affect fire starts or intensity, yet someone wrote this No Action effect: Vegetation Effects to Wildfire Hazard Rating “Alternative A would result in a very high wildfire hazard rating.” (pg 35) Effects to Riparian Conservation Areas Restoration “Alternative A would result in a very high wildfire hazard rating within RCAs.” (pg 44) In the final NEPA document please tell the public why you reject the research conclusions of well respected Ph.D. fire ecologists shown above and instead accept the effects written by someone that contradict the scientists’ findings. Comment: Dr. Jack Cohen (a USFS employee) and the 11 independent scientists quoted above all indicate logging does not affect fire starts or intensity, yet someone wrote this No Action effect:
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Fire & Fuels Effects to Wildfire Hazard Rating in the Wildland Urban Interface and Non-Wildland- Urban Interface “Alternative A would result in a very high wildfire hazard rating across the Project Area.” (pg 48) Wildfire Hazard Rating Across the Project Area “Under Alternative A, wildfire hazard within and outside the WUI would trend towards very high with an increased portion of areas classified as having an extreme wildfire hazard rating by 2055.” (pg 49) Wildfire Hazard Rating within the Wildland-Urban Interface “Based on the assessment of wildfire hazard rating for Alternative A, if a wildfire were to occur and a surface fire transitioned to the crowns, stand replacement fire behavior would likely result for all modeled years.” (pg 51) “The wildfire hazard rating would be reduced substantially for all years within the WUI under Alternatives B and C compared to Alternative A, lowering the risk of sustained crown fire and reducing the potential for erratic fire behavior; undesirable fire effects (size, intensity, and severity); and the threat to structures consistent with Forest Plan Objective 1655 (Figure 12).” (pg 51) In the final NEPA document please tell the public why you reject the research conclusions of well respected Ph.D. fire ecologists shown above and instead accept the effects written by someone that contradict the scientists’ findings. Comment: Dr. Jack Cohen (a USFS employee) and the 11 independent scientists quoted above all indicate logging does not affect fire starts or intensity, yet someone wrote this No Action effect: Soil Water etc Effects to Sensitive Riparian Soils “Alternative A would not affect riparian soils because no activities which would change the current condition are proposed. However, if a wildfire were to occur within these riparian areas, soils could be impacted by burning of riparian vegetation; consumption of the surface organic layer; and, in the case of high-severity fire, by changing the chemical composition of the upper layers of the soil.” (pg 86) Effects to Slope Stability “Under Alternative A, no activities are proposed which could affect landslide risk. However, the risk of wildfire and resultant surface erosion and lack of vegetative cover could potentially trigger landslides.” (pg 88) This is pathetic In the final NEPA document please tell the public why you reject the research conclusions of well respected Ph.D. fire ecologists shown above and instead accept the effects written by someone that contradict the scientists’ findings.
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Comment: Dr. Jack Cohen (a USFS employee) and the 11 independent scientists quoted above all indicate logging does not affect fire starts or intensity, yet someone wrote this No Action effect: Noxious Weeds There are no effects of No Action displayed. This is because the No Action alternative will not increase the potential for the introduction of new noxious weed species or spread of known noxious weed species. In the final NEPA document please tell the public why you reject the research conclusions of well respected Ph.D. fire ecologists shown above and instead accept the effects written by someone that contradict the scientists’ findings. Also include the No Action effects . Concluding statements about the tragic, untrue natural resources effects analysis disclosures cooked-up by most IDT members. After reading chapter3, I don’t know whether to laugh or cry. I know the IDT members were all striving to be “team players” by portraying the No Action alternative as a dreadful, ill-advised, appalling, ghastly action. They didn’t anticipate there would be members of the public reading Chapter 3 who have a basic understanding of fire ecology and the intelligence to compare the IDT effects disclosures above with the research conclusions if independent scientists not connected with the USDA. Each IDT member has been obedient. Your pathetic, untrue No Action effects guarantee that Ranger Newton will reject the No Action alternative. Without exception the IDT members fabricated untrue (sometimes pathetic) negative effects of No Action for ALL (emphasis added) resources analyzed. Each IDT member actually believes USFS mythology about how logging and fire interact. It’s sad that no IDT members had the initiative and curiosity to examine real science conclusions resulting from the research done by independent scientists with no connection to the USDA. There is no reason to trust the accuracy and truthfulness of this pre-decisional EA. Each IDT member should hang their head in shame while simultaneously genuflecting to their corporate masters. Supervisor Seeholtz, I expected a better product from you. I taught 1900-1 beginning NEPA to USFS employees. My students could have picked this pre-decisional EA apart before the instruction had started. Never before have I read a NEPA document written by IDT members with such little knowledge about how logging and fire interact. Of course, if the USFS didn’t teach that logging reduces fire the agency would loose one of the most frequently used excuses to further the USFS timber agenda. Request for changes to be made to the final NEPA document: Provide independent science validating the IDT claims that logging reduces fire effects or remove the IDT’s claims that logging prevents fire from Chapter 3. Failure to do so will violate 40 CFR 1500.2(b) because no evidence is presented for environmental effects conclusions, 40 CFR 1501.2(a) because the environmental effects and
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values are not identified in detail, and without substantiating evidence for effects conclusions the public cannot determine if they are accurate and based on best science which violates 40 CFR 1500.1(b). The final NEPA document will also violate 40 CFR 1500.1(b) because the Chapter 3 environmental effects section written by IDT members is contrary to the “best science” statements written by hundreds of well-respected, independent scientists in the Opposing Views Attachments. With this being the case, the agency effects disclosures are not “high quality” and an “accurate scientific analysis.” ------Issue #4 ----- The pre-decisional EA fails to describe the effects to air quality, heritage resources, recreation and scenery resources in Chapter 3. Without exception, EAs and EISs for timber sales written on other national forests contain effects write-ups in Chapter 3 addressing how or whether the timber sale will affect air quality, heritage resources, recreation and scenery resources. In spite of the fact this timber sale “could” or “may” affect these resources, the predicted effects are not disclosed (a.k.a. hidden). Request for changes to be made to the final NEPA document: Include discussions, information and data in Chapter 3 showing the effects to air quality, heritage resources, recreation and scenery resources that will result from logging, road construction and burning that will occur as part of this project. If you feel these resources will not be affected, please describe why. Failure to do so will violate 40 CFR 1500.1(b) and 1508.8 which state: ““Effects and impacts as used in these regulations are synonymous. Effects includes ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative.” Also you will be in violation of 40 CFR 1501.2(b), 40 CFR 1501.5(c-3), 40 CFR 1502.15, 40 CFR 1502.16 (a, b, and d), and 40 CFR 1504.1. ------Issue #5 ----- Ranger Newton, please take additional action to further reduce the risk to people’s homes and the lives of family members in the WUI should a wildfire start nearby. The pre-decisional EA at page 6 states: “Approximately 4,654 acres are delineated as WUI within the 7,736-acre Project Area.” Ranger Newton, you don’t want to apply Firewise techniques or quote Dr. Cohen’s research conclusions because they show how and why fine fuels removal close to homes is more effective than fuels logging. Why do you ignore Dr. Cohen’s research conclusions? You do so because it might jeopardize your precious volume attainment. Who will die because you are obsessed by volume? Before Dr. Jack Cohen retired, he was a fire physicist who worked for the USFS doing research to determine the best action to reduce damage to homes in the WUI if a wildfire starts nearby.
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His research was done at the Forest Service's Missoula Fire Sciences Laboratory at the Rocky Mountain Research Station. His fine fuels removal methods are implemented in foreign countries. They are the most effective fire damage risk reduction methods available. For more than 15 years, the National Fire Protection Association’s (NFPA) wildfire safety recommendations have been shaped by Dr. Cohens fire science. The resulting Firewise Communities Program provides guidance for homeowners on the WUI to help them prepare their homes to resist wildfire. Some homeowners in the WUI might already be familiar with Firewise and applied its methods to their property. Other homeowners may not know about Firewise and/or are unable to physically treat their property. Some homeowners in the WUI may have already removed fine fuels within several hundred feet of their homes using the Firewise instructions. Some homeowners have not because they are either unaware of Firewise or they are physically unable to do the work. This is where the USFS should enter the picture. Here is the Firewise information: Link to Recommendations from the Firewise Communities Program: http://www.firewise.org/wildfire-preparedness/be-firewise/home-and- landscape/defensible-space.aspx?sso=0 Link to Firewise principles: http://www.firewise.org/wildfire-preparedness/be- firewise/home-and-landscape.aspx?sso=0 Link to the Firewise web site: http://www.nfpa.org/safety-information/for- consumers/outdoors/wildland-fires Dr. Cohen wrote several books and made presentations to people involved in fire protection describing the methods for reducing fire damage risk. Dr. Cohen states: “As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5) Source for quote above: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf Dr. Cohen states: “Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands.” (Pg. 4) Source for quote above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008
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http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf Dr. Cohen states: “Effective landscape fuel reduction does not necessarily prevent W- UI home fire destruction.” (Pg. 10) “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999) “Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000) Source for quotes above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf Here is a link to all 13 publications authored by Dr. Cohen describing the overwhelming effectiveness of using his fine fuels removal methods near homes to reduce the risk that they might burn. Link: http://firewise.org/wildfire-preparedness/wui-home-ignition-research/the-jack- cohen-files.aspx?sso=0 As Dr. Cohen states, fuels reduction logging removed from the immediate vicinity of the WUI is not a waste of time, but it certainly should not be the only action (emphasis added) that should be taken if saving the home is a primary goal. Dr. Cohen provides compelling evidence that fuels reduction is not the only way to reduce the risk of fire damage. When the homeowners are exposed to Dr. Cohen’s research conclusions quoted above the homeowners will be even more enthusiastic about applying Firewise techniques. I quote Government Accounting Office, GAO/RCED-99-65 below. The Government Accountability Office (GAO) is a government agency that provides auditing, evaluation, and investigative services for the United States Congress. “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.”
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Source for quote above: Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats Published by the Government Accounting Office, GAO/RCED-99-65 Link: http://www.gao.gov/archive/1999/rc99065.pdf Clearly, both fuels removal and applying the Firewise methods gives the homeowners more protection that just applying one of the methods without the other. The Purpose & Need for this project does not reflect the goal to save lives and homes in the WUI using all available methods. The current P&N describes an action (fuels removal) rather than a goal to reduce or eliminate fire damage risk. Broadening the P&N would open the door to use other fire damage risk reduction methods in addition to fuels logging. Fuels logging is an alternative … not a primary purpose and goal. Indeed, the homeowners living close to the national forests where a fire might start should be given all the protection possible by the USFS. This member of the public is surprised that a USFS line-officer isn’t aware of the research conclusions of Lyle Laverty who is another fire expert also employed by the USFS. Also, there is a vast amount of peer reviewed independent scientific research that reveals logging does not mitigate fire behavior. Several of the scientists quoted below conclude that logging exacerbates fire severity and rate of spread. I am interested in how you respond to the comments below. Please be thoughtful. Human lives depend on it. Here is a quote from the 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress. Please consider this information as you formulate the final Proposed Action. "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62) "Logged areas generally showed a strong association with increased rate of spread and flame length, thereby suggesting that tree harvesting could affect the potential fire behavior within landscapes. In general, rate of spread and flame length were positively correlated with the proportion of area logged in the sample watersheds." "As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high.” Source for quote above: University of California; SNEP Science Team and Special Consultants “Sierra Nevada Ecosystem Project: Final Report to Congress Volume 1, Chapter 4 – Fire and Fuels. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf Here is a quote from the April 1999 GAO Report to the Subcommittee on Forests and Forest Health, Committee on Resources, House of Representatives regarding fuels reduction. Please consider this information as you formulate the final Proposed Action.
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"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." Source for quote above: Government Accounting Office, Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats GAO/RCED-99- 65 http://www.gao.gov/archive/1999/rc99065.pdf Request for changes to be made to the final NEPA document: Modify the Proposed Action to do the following in addition to hazardous fuels removal: • distribute Firewise handouts to WUI residents describing the fine fuels removal methods (where and how). • contact the people living in the WUI and announce Firewise workshops will be held to answer questions. • offer to remove the fine fuels (with written permission) on private property owned by elderly and disabled homeowners who cannot do the work themselves. • modify the P&N to reflect what should be the prime goal of this timber sale: reduce the chance that homes will burn in the WUI should a wildfire start in the area. Fuels reduction would then be an alternative, but this would open the door to the 3 actions shown above. If this does not occur, you will violate:
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• 40 CFR 1500.2(e) because the Responsible Official was unable to avoid or minimize adverse effects of the project upon the quality of the human environment without complete knowledge of all likely adverse effects. Most adverse effects of project activities described by scientists in the Opposing Views Attachment #11 was not mentioned in the final NEPA document EA. • 40 CFR 1500.2(f) because the Responsible Official was unable to avoid or minimize any possible adverse effects upon the quality of the human environment without knowledge of the adverse effects. Had the Responsible Official known about these effects he would have acknowledged the existence of some adverse effects described in the Opposing Views Attachment #11 in the final NEPA document EA. • NEPA Sec. 101(b)(2) because the Responsible Official does not “assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings;” • NEPA Sec. 101(c) because “The Congress recognizes that each person should enjoy a healthful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment.” • Ex. Ord. No. 13045, Apr. 21, 1997 [section 1-101(a)] because the Responsible Official does not “make it a high priority to identify and assess environmental health risks and safety risks that may disproportionately affect children.” For EAs only • The draft FONSI violates 40 CFR §1508.27(b)(2) because the intensity discussion fails to discuss the degree to which the proposed action affects public health or safety. ------Issue #6 ----- The American people do not want their national forests logged and roaded up. The money for your salary (and the IDT members’ salary) comes from tax dollars supplied by these same Americans you propose to backhand by ignoring and rejecting their desires and wishes for their precious public land. Do you enjoy serving your corporate masters first? The American citizens are your supervisors. In America, when an employee consciously and willfully disobeys his/her supervisor on a regular basis they are terminated. Here are the statistics you ignore. In 2002, 7,069 Americans were randomly selected in the lower 48 states to respond to the statistically significant Values, Objectives and Beliefs survey sanctioned by Chief Thomas. Chief Thomas spent the American public’s money on the survey because he believed it would guide future agency management decisions. Chief Thomas didn’t anticipate future USFS line-officers would be clinically obsessed by volume accumulation as is the case here. Page 1 briefly describes the survey: “The items in the survey have been extensively pre-tested and applied in various other studies. The values scale was designed to focus on values that people hold for public lands (called the Public Lands Values). It was tested using both students and adults around the United States. The objectives scale items were developed using input from 80
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focus groups around the country. The beliefs and attitudes scales tier down from the objectives items.” This survey was intended to measure what the public wants from their national forests. They were asked about their values with respect to public lands, objectives for the management of public lands, beliefs about the role the agency should play in fulfilling those objectives, and attitudes about the job the agency has been doing. Why was the survey done? The results were needed to support the 2000 USDA Forest Service RPA Assessment. Gen. Tech. Rep. RMRS-GTR-95. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. Here are a few quotes from the final report: “People see the provision of less consumptive services as more important than those that are more consumptive.” (page 2) “Overall, the protection of ecosystems and wildlife habitat is seen as an important objective for public land management.” (page 9) “It is interesting to note that the public feels that the conservation and protection of watersheds is an important objective, consistent with the USDA Forest Service Organic Act. Also, important objectives for the public are the preservation of natural resources through policies that restrict commodity uses, protection of ecosystems and wildlife habitat, and preservation of the ability to enjoy a “wilderness” experience. A somewhat important objective is the preservation of local cultural uses.” (page 27) “The public sees the restriction of mineral development and of timber harvest and grazing as being more important than the provision of natural resources to dependent communities (although this is still seen as somewhat important).” (page 28) Link to survey: http://www.fs.fed.us/rm/pubs/rmrs_gtr095.pdf Comment: Of the 7,069 Americans surveyed in Chief Thomas’s values survey in 2002, 88.4% supported elimination of timber harvest and mining, and instead prefer the agency employees to spend their tax dollars on protecting watersheds from harm and less consumptive services. They wanted national forest management to be based on science rather than money. This percentage has increased in the 13 years since the survey. What’s so special about the High Valley timber sale that would make these 88.4% of Americans embrace the logging? Comment: Why do accept the recommendations supplied by a handful of timber IDT members financially motivated to enable and facilitate timber sales regardless of resource impacts, when it is the antithesis of best science described in the Opposing Views Attachments? An executive order requires federal agencies to use best available science: “Science and the scientific process must inform and guide decisions of my Administration on a wide range of issues, including improvement of public health, protection of the environment, increased efficiency in the use of energy and other resources, mitigation of the threat of climate change, and protection of national security.
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The public must be able to trust the science and scientific process informing public policy decisions. Political officials should not suppress or alter scientific or technological findings and conclusions. If scientific and technological information is developed and used by the Federal Government, it should ordinarily be made available to the public. To the extent permitted by law, there should be transparency in the preparation, identification, and use of scientific and technological information in policymaking. The selection of scientists and technology professionals for positions in the executive branch should be based on their scientific and technological knowledge, credentials, experience, and integrity.” Source: MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES THE WHITE HOUSE, Office of the Press Secretary, March 9, 2009 http://www.whitehouse.gov/the-press-office/memorandum-heads-executive- departments-and-agencies-3-9-09 “General Principles of Regulation. (a) Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation. It must be based on the best available science.” “Sec. 5. Science. Consistent with the President’s Memorandum for the Heads of Executive Departments and Agencies, ‘‘Scientific Integrity’’ (March 9, 2009), and its implementing guidance, each agency shall ensure the objectivity of any scientific and technological information and processes used to support the agency’s regulatory actions.” Source: Improving Regulation and Regulatory Review Executive Order 13563 of January 18, 2011 Published in: the Federal Register, Vol. 76, No. 14 Friday, January 21, 2011 http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf The High Valley timber sale area contains streams that have year round resident fish. Federal agencies are required by law to use best available science as a basis for their decisions: “(2) Conservation and management measures shall be based upon the best scientific information available.” Source: 16 U.S.C. § 1851 : US Code - Section 1851: National standards for fishery conservation and management. http://codes.lp.findlaw.com/uscode/16/38/IV/1851 Comment: Even the USFS acknowledges that the public does not want their public lands logged. Please read about Chief Thomas’ survey below: In 2002, 5,064 Americans were randomly selected in the lower 48 states. This statistically significant survey was intended to measure what the public wants from their national forests. They were asked about their values with respect to public lands, objectives for the management of public lands, beliefs about the role the agency should
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play in fulfilling those objectives, and attitudes about the job the agency has been doing. The survey was contracted by Chief Thomas. Why was the survey done? The results were needed to support the 2000 USDA Forest Service RPA Assessment. Gen. Tech. Rep. RMRS-GTR-95. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. Here are a few quotes from the final report: “The public sees the restriction of mineral development and of timber harvest and grazing as being more important than the provision of natural resources to dependent communities (although this is still seen as somewhat important).” (page 28) “Highly familiar members of the public are less likely to support policies that eliminate timber harvest and mining in order to preserve natural resources. These same respondents are also less likely to see the protection of ecosystems and watershed and the preservation of a wilderness experience as appropriate roles for the USDA Forest Service.” (page 54) Link to survey: http://www.fs.fed.us/rm/pubs/rmrs_gtr095.pdf Of the 5,064 Americans surveyed, 589 indicated they were “highly familiar” with the USDA Forest Service. This means 88.4% of those surveyed with moderate or low familiarity support elimination of timber harvest and mining, and instead prefer the agency employees to spend their tax dollars on protecting watersheds from harm and less consumptive services. What will the judge conclude when the plaintiff’s attorney introduces this information? Comment: You know there is no “timber famine” as the USFS has been so fond of predicting for many decades. There is no shortage of raw materials for paper and wood products in the United States. Therefore, there is no reason to have commercial timber sales in the national forests. Only 4.8 % of the raw materials for domestically used wood products and paper come from national forest land. The USFS could stop logging today and the market would never react. The volume would be replaced from private- industrial tree farms and private sources without blinking an eye. Comment: Over 200 Ph.D. scientists are quoted in Opposing Views Attachments #1 and #4. They describe how and why logging and roading at any location at any time inflict heavy, unacceptable damage to the amenity natural resources in the national forests so loved by 322 million Americans. Since you defy their recommendations you must believe your High Valley timber sale is different or special. Why do the independent scientists’ clear descriptions of the massive resource damage caused by timber sales such as yours not apply to the High Valley sale? Comment: For decades the USFS has been telling the public that their projects are all based on “best science.” Opposing Views Attachment #15 contains quotes of the following USFS officials who stress “best science” drives agency actions: Hilda Diaz- Soltero, Dr. Ann Bartuska, Chief Dale Bosworth, Associate Chief Sally Collins, Heidi Valetkevitch, Chief Mike Dombeck, Chief F. Dale Robertson, Agriculture Secretary Dan Glickman, Chief Tom Tidwell, John Potyondy, Ann Melle, and Merrill Kaufmann. The Opposing Views Attachments contain the quoted statements of hundreds of Ph.D. scientists who describe how logging and road construction should be avoided in the
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forest to assure all natural resources will function properly. In spite of this best science, you choose to take the advice of your IDT members to sell the High Valley timber sale. The timber members of the IDT are all financially motivated to sell national forest trees. Why do you reject best science? Request for changes to be made to the final NEPA document: include the above quote in the final NEPA document showing the the majority of the people in the area reject logging in the Boise National Forest. The discussion should explain why the recommendations of over 200 Ph.D. scientists represented in Opposing Views Attachments #1 and #4 aren’t applicable to the High Valley sale area and/or why the information provided by several timber IDT members should trump these independent scientists’ research conclusions, thus establishing USFS IDT members’ information as “best available science.” Failure to provide justification showing why the USFS can take actions that the vast majority of the American public do not want to occur violates 40 CFR 1500.2(e) and (f) because the Responsible Official does not use all practicable means to “avoid or minimize any possible adverse effects of their actions upon the quality of the human environment” and does not “avoid or minimize adverse effects of these actions upon the quality of the human environment”, Executive Order 13563 of January 18, 2011, and 16 U.S.C. § 1851 : US Code - Section 1851. ------Issue #7 ----- Please post your responses to public comments online as well as maintaining a hardcopy in the Project File. Comment: Members of the public who submit comments on a draft NEPA document make the effort to read the NEPA document closely and take the time to compose comments that reflect their issues. Unless you respond to these comments and allow the public to read your responses they don’t know if their comments were read and “considered.” Plus, such responses show you aren’t ignoring the public. Request for changes to be made to the final NEPA document: Post your responses to ALL public comments online so the 322 million Americans\ national forest owners might read them if they choose. Hiding your responses to comments in the Project File clearly violates United States’ law. This is abuse. Will you pay the bills if a person has an accident driving to the district? Its insane to keep the responses off the net. You clearly have something to hide. Failure to post your responses to ALL public comments online will violate 36 CFR 215.6(d) because the Responsible Official did not “address comments received from the public during the comment period in an appendix to the environmental assessment.” Ignoring public comments also violates: 40 CFR 1503.4(a) because the objector does not know how the Responsible Official responded to the objector’s comments, and 40 CFR 1502.9(b) because the Final environmental impact statement does not respond to comments.
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------Issue 8 – Competent, professional USFS line-officers don’t backhand and insult the public they supposedly serve by declaring their comments to be “not significant” as you have done on page 17. Rejecting public input is not trivial. Who do you think you are Mr. Newton? You backhand the members of the public who dare to suggest you modify your timber sale so the logging won’t damage the natural resources in the area. Some members of your IDT don’t like what you are doing and they are afraid to speak up. They know they will be punished for even inferring a timber sale needs to be modified to protect natural resources. Describing some issues submitted by American citizen owners of the Boise National Forest as “non significant issues” as is the case here indicates your unprofessional arrogance and disdain for the public. It shows your willingness to backhand members of the public who even suggest that your sacred timber sale might not be a wise thing to pursue. Tomorrow when you and your IDT members genuflect to corporate America as you enter your office please think about this. How would a real public servant behave? When the public expresses their concern about natural resource harm as part of their comments, they expect the other resource specialists on the IDT who are responsible to protect the natural resources that will likely be harmed to respond with actions to assure the harm does not occur. Guess what? The American public does not want any amenity natural resources damaged or impaired … even if its “short term.” This isn’t such a difficult concept is it? Telling some members of the public their comments are worthless, unimportant and insignificant is bad enough. Failing to tell them why is worse. Request for changes to be made to the final NEPA document: Assure that all (emphasis added) issues identified by the public are listed in the body of the NEPA document posted online and hardcopy. If you feel this is impossible and still want to abuse the public, then tell them why their issue is “not significant.” How would this be done? You would identify their s0-called “not significant” issue. Finally you will explain how and why the issue is “outside the scope,” irrelevant,” or “conjectural.” If you believe the is already decided by law, regulation, Forest Plan, or other higher-level decision, identify the specific section of the law, regulation, Forest Plan, or other higher-level decision. Rejecting public input that they submitted in good faith impolitely excludes these members of the public from further involvement in an EA EIS violates 40 CFR 1506.6(a) because The Responsible Official did not make “diligent” efforts to involve the public and 40 CFR 1500.2(d) by failing to “encourage and facilitate public involvement in decisions which affect the quality of the human environment.” Rejecting some public will only be sanctioned by the court if the public is notified of the types of input that will be rejected in the comment solicitation cover letter. ------
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Issue #9 ----- The pre-decisional EA does not contain recent (emphasis added) stream survey data that is essential to determine whether the stream conditions were harmed by timber sale activities. The only way to determine this is before and after measurements which require survey data before the timber sale is implemented. The Proposed Action map shows many cutting units either adjacent to perennial streams. Other units have perennial streams running through them. The Proposed Action roads map shows proposed locations for temporary roads crossing perennial streams. Any competent fisheries biologist would insist that stream surveys must be taken before logging and road construction occurs to at least measure stream temperature and turbidity. These data would then be compared with measurements at the same locations taken during and after logging and road construction. Comment: Clearly you aren’t concerned about how your precious volume removal “treatments” (a.k.a. logging) will adversely affect the aquatic resources in and downstream from the sale area. Why? The pre-decisional EA fails to describe the process of comparing measurable stream data (i.e. temperature, turbidity etc.) taken during monitoring field trips while logging is occurring with the same data taken before logging. You know what such before and after stream data comparisons will show. A competent hydrologist and/or fisheries biologist would have insisted on this. Request for changes to be made to the final NEPA document: Include the measured results of recent stream surveys and display a stream monitoring schedule to be completed during and immediately following sale closure. Failure to disclose recent stream survey data violates 40 CFR 1500.1(b) because environmental information (stream survey data) is not available to public officials and citizens before decisions are made and before actions are taken. Also without stream survey data it will not be possible to accurately analyze the environmental damage that occurs because of the timber sale’s effects to streams because the Responsible Official will not know if or the magnitude of the effect without before data. ------Issue #10 ---- Increases in National forest logging do not stabilize or enhance the economy of small communities located near them. One of your needs listed in the P&N at page 7 for this timber sale is: “Provide a predictable and recurring supply of wood products from lands identified in the Forest Plan as suitable for timber management.” Once again this is a cut & paste get-out the cut P&N statement you will find in the P&Ns for your past timber sale draft EAs and DEISs. Consider the following excerpts from a research paper that examined community stability vs. increased logging. The study was done on small communities near national forests in Washington State: "The relationship between timber harvest and the overall economic health of Washington communities assumed to be most dependent on logging and forest products runs counter to commonly held assumptions."
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"Despite a 93 percent decline in National Forest timber harvests and the loss of 7,300 forest products jobs statewide between 1988 and 1998, the number of people employed outside of forest products expanded by 726,000 (total employment increased 33 percent), total real income expanded by almost 50 percent, and population rose by 23 percent." "Economic vitality was especially evident in the largely non-metropolitan counties adjacent to National Forest lands in eastern and southwestern Washington. Although 3,000 forest products jobs were lost, more than 170,000 jobs were added outside that sector. The counties adjacent to the National Forests were not driven into economic depression as a result of 70 to 90 percent declines in federal harvests. Instead, average real income, employment, and population expanded significantly." "Even within relatively isolated areas, such as the northeastern tier of counties, there was considerable economic vitality despite the declines in federal timber harvests. In general, all areas gained population at rates above the national average. Some areas, such as Okanogan County, did almost as well as the state’s metropolitan areas despite the decline in federal harvests." "The relatively high unemployment rates in many of the eastern Washington counties adjacent to National Forests cannot be attributed to the decline in federal harvests. Those counties had even higher unemployment rates at the time of peak harvests in the late 1980s. The unemployment rates in excess of the state average did not rise as federal harvests fell dramatically from these peak levels." "While its true that average real pay is low in the eastern and southwest Washington counties adjacent to National Forests, this low pay is not the result of the decline in federal harvests. Average real pay plunged during the 1980s while federal harvests were rising to peak levels. In fact, while federal harvests fell in the 1990s, average pay stabilized or increased." "Federal payments to local governments from revenue generated by local National Forest lands declined with federal harvests during the 1990s. This, however, did not cause an overall decline in the revenues available to local governments. Local and state economic vitality allowed local government revenues to double in the 1990s despite the reduction of the National Forest contributions." From “The Economic Impact of Preserving Washington’s Roadless National Forests” by Thomas Michael Power, Ph.D., Professor of Economics, University of Montana, June 13, 2000. Links to complete article: http://www.kettlerange.org/power/ExecSummary.htm http://www.kettlerange.org/power/powerreport.htm Comment: Dr Power makes the following conclusions from his research findings: “Even within relatively isolated areas, such as the northeastern tier of counties, there was considerable economic vitality despite the declines in federal timber harvests.” “The relatively high unemployment rates in many of the eastern Washington counties adjacent to National Forests cannot be attributed to the decline in federal harvests.
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Those counties had even higher unemployment rates at the time of peak harvests in the late 1980s.” Please describe why Dr. Power’s research does not apply to the Boise National Forest. ECONorthwest reached conclusions similar to those of Dr. Power quoted above: “(1) Despite years of rhetoric and misinformation, national and regional economies are not dependent on logging National Forests. The most often cited misconception is that the regional economy of the Pacific Northwest declined after a court injunction and related events reduced National Forest logging. In fact, instead of collapsing, the region's economy expanded and the Pacific Northwest weathered virtually unscathed the national economic recession that occurred at the same time as the court injunction. (2) National Forests now produce goods and services that are much more significant than the value of logging. (3) The Forest Service logging program has caused devastating impacts in the ability of the National Forests to provide economically valuable goods and services. Reversing the damage caused by logging will be costly but ignoring the need to restore damaged forests will cost even more.” From: EcoNorthwest, “Seeing Forests for their Green: Economic Benefits of Forest Protection, Recreation, and Restoration”, August 13, 2000 http://econw.com/our-work/publications/seeing-forests-for-their-green-economic- benefits-of-forest-protection-recre/ Comment: Mr. Niemi and Ms. Fifield (the authors of this paper) conclude: “Despite years of rhetoric and misinformation, national and regional economies are not dependent on logging National Forests.” Please describe why their research findings do not apply to the Boise National Forest. U.S. Undersecretary of Agriculture Jim Lyons states that recreation revenues from national forests significantly exceed timber revenues. See: A 1998 presentation to the National Trails Training Partnership by U.S. Undersecretary of Agriculture Jim Lyons’ statements quoting figures from the draft RPA (Resources Planning Act) of 1995. http://www.americantrails.org/resources/economics/EconForestRec.html Also see this compelling information: http://illinois.sierraclub.org/piasapalisades/factshee.htm Here’s more from the Portland Oregonian: “Increased logging on federal lands will not fix these problems. Instead, it will diminish jobs in one of Oregon's fastest growing industries, outdoor recreation. The outdoor recreation industry employs about 140,000 workers in Oregon (logging and wood-products manufacturing employ fewer than 30,000). Nationally, jobs in outdoor recreation are growing 5 percent annually. High-quality recreation attracts middle- and high-income families to settle in rural counties, too, boosting local economic activity.
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There is abundant research and data showing that our federal forests would do far more for workers, families and local businesses if managed for ecosystem and human health rather than as tree farms.” From: Logging expansion won't help rural communities Portland Oregonian online, June 29, 2014 http://www.oregonlive.com/opinion/index.ssf/2014/06/logging_expansion_wont_help_r u.html Comment: Why do you reject the findings and conclusions of Undersecretary of Agriculture Jim Lyons who states “recreation revenues from national forests significantly exceed timber revenues.” Elsewhere in these comments are the results of public survey information indicating the public is less likely to recreate near areas that have been logged, thus logging diminishes recreation revenue. Since recreationists avoid areas that have been logged the many “ma and pa” businesses that depend on recreation are harmed. How do you justify harming the revenues of motels, gas stations, restaurants etc. to increase the profits of a very large corporation? Please describe why Undersecretary Lyons’ conclusions about community stability do not apply to the Boise National Forest. Comment: You reject the research conclusions of 241 Ph.D. scientists quoted in Opposing Views Attachment #1 who demonstrate how logging-related harm (and in a few cases destruction) is inflicted on multiple natural resources in and near the sale area. Incredibly, you rely on the advice of 3 or 4 timber employees financially motivated to sell timber. You know the log for community stability P&N statement appears in at least 80% of all timber sale NEPA documents. This has become the commonly used excuse by USFS line-officers to sell unneeded timber sales and you use it here. Comment: If you were really concerned about local community stability and local job creation you would offer this sale as an SBA sale to prevent a large timber corporation from logging it using their own labor. This would prevent the logs from being hauled many miles to be processed at a mill far removed from the small communities you claim need economic help. Of course your motivation to sell this timber sale has nothing to do with community stability. We both know “local community stability” and “local job creation” is part of the USFS dishonest script to trick the public into accepting tragic timber sales. Request for changes to be made to the final NEPA document: Either: 1) remove the following statement from the P&N: “Provide a predictable and recurring supply of wood products from lands identified in the Forest Plan as suitable for timber management.” OR 2) include the text or links to the text of the following papers (referenced above) in an Appendix to the NEPA document. Line-officers must not withhold such important information from the
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public. Congress promulgated laws to prevent zealous federal officials from behaving in such a manner to feather their nest. “The Economic Impact of Trails-Forest Recreation’s Growing Inpact” “Seeing Forests for their Green: Economic Benefits of Forest Protection, Recreation, and Restoration”, “The Economic Impact of Preserving Washington’s Roadless National Forests” A 1998 presentation to the National Trails Training Partnership by U.S. Undersecretary of Agriculture Jim Lyons Failure to do so will violate 40 CFR 1500.1(b) because environmental information is not available to citizens before decisions are made. ------Issue #11 ----- Noise and Dust caused by Timber Harvest Adversely Affects Recreation and Wildlife, thus these Adverse Social and Environmental Impacts must be Analyzed in Chapter 3 with follow-up changes made to the timber sale design to eliminate these adverse effects Sadly, the pre-decisional EA fails to mention noise and dust resulting from logging activities. The noise is clearly evident and disruptive several miles away from the source. Comment #7: Ranger Newton, anyone responsible for protecting the land owned and loved by 307 million Americans as you are must understand that their job under NEPA entails more than simply describing how their proposed project will harm the recreational experiences and natural resources in the forest. They must modify (or drop) their proposed project so the chances of damage and harm no longer exist. Clearly, the public believes their recreation and natural resources in national forests must never be considered acceptable collateral damage of timber volume accumulation. This includes industrial noise and dust degradation. Request for final NEPA document modifications: Please disclose that noise and dust may adversely affect recreation experience of human visitors to the forest and some wildlife species that exist near the project area and analyze the effects that may occur to 1) recreation, and 2) vulnerable wildlife species in Chapter 3, and explain why such impacts are a justified tradeoff for the stated project benefits. Failure to do so violates 40 CFR 1508.3 because these likely indirect adverse effects were not discussed in Chapter 3. The omission of this information from Chapter 3 also violates 42 USC section 7641 and Title 42--The Public Health and Welfare, Chapter 65-- NOISE CONTROL, Sec. 4901. ------Issue #12 ----- Please respond to the opposing views contained in the Opposing Views Attachments to these comments. Request for changes to be made to the final NEPA document: Each opposing viewpoint is different and is related to a unique subject, therefore a single response attempting to deal with all opposing views simultaneously does not respond to opposing views as required by law. Please respond to each opposing view and post the responses online for the public to see. Simply
170 High Valley Integrated Restoration Project Comment Analysis placing a hardcopy of your opposing views responses in the project file located at the district hides the information from the American public. No American should have to drive hundreds or thousands of miles to read a public document. There are also laws that require Federal Agencies to ”make diligent efforts to invole the public and “encourage and facilitate public involvement.” Comment: Please don’t omit meaningful responses because the opposing views are opinions. Why? A viewpoint is a synonym of opinion. As the law states below, there is only 1 way the Responsible Official may decline to respond. He or she must describe why an opposing viewpoint is irresponsible. 40 CFR 1502.9(b) “Final environmental impact statements shall respond to comments as required in part 1503 of this chapter. The agency shall discuss at appropriate points in the final statement any responsible opposing view which was not adequately discussed in the draft statement and shall indicate the agency’s response to the issues raised.” This means the Responsible Official must not decline to respond because the commenter 1) does not supply the source document for the opposing view, 2) the opposing view is not site specific, 3) the opposing view is not peer reviewed etc. Note the law states the final NEPA document must contain the responses. Comment: This commenter is including online source documents for each opposing view for the convenience of the Responsible Official. A few of the links to the source documents are broken. This does not make the Opposing View irresponsible. Failure to provide meaningful responses to opposing views regardless of their source will violate 40 C.F.R. § 1502.9(a) and 1502.9(b) and. 42 USC § 4372(d)(4) because “Final environmental impact statements shall respond to comments as required in part 1503 of this chapter. The agency shall discuss at appropriate points in the final statement any responsible opposing view which was not adequately discussed in the draft statement and shall indicate the agency’s response to the issues raised.” Failure to respond to responsible opposing views (from any source) also is inconsistent with court precedent: Not responding to responsible opposing views is also inconsistent with court precedent: In Center for Biological Diversity v. United States Forest Service, Argued and Submitted July 15, 2003, In the United States Court of Appeals, Ninth Circuit, the court stated: “Accordingly, we find that the Final EIS fails to disclose and discuss responsible opposing scientific viewpoints in the final statement itself in violation of NEPA and the implementing regulations. We therefore reverse the district court's grant of summary judgment and remand to the district court with directions that it remand the final statement to the Forest Service for further proceedings consistent with this opinion.” In Sierra Club v. Eubanks 335 F. Supp. 2d 1070 (ED Cal. 2004), the court stated: "credible scientific evidence that [contradicts] a proposed action must also be evaluated and considered." In Seattle Audubon Society v. Lyons 871 F. Supp. 1291, 1318 (W.D. Wash. 1994), the court stated:
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"[the EIS] must also disclose responsible scientific opinion in opposition to the proposed action, and make a good faith, reasoned response to it." In Seattle Audubon Society v. Moseley 798 F. Supp. 1473 (WD Wash. 1992) , the court stated: "[t]he agency's explanation is insufficient under NEPA … not because experts disagree, but because the FEIS lacks reasoned discussion of major scientific objections." In Sierra Club v. Bosworth 199 F.Supp.2d 971, 980 (N.D. Cal. 2002), the Court held that the Forest Service violated NEPA when it failed to: "disclose and analyze scientific opinion in support of and in opposition to the conclusion that the…project will reduce the intensity of future wildfires in the project area." ------Issue #13 ----- The Proposed Action will clearly cause the resource degradation and destruction described in the ATTACHMENTS to these comments. The attachments to these comments present the “responsible” opposing views of between 500 and 600 independent, unbiased Ph.D. biological scientists who describe the resource damage caused by commercial timber sale logging and road construction activities that occur at any location, on any topography, at any elevation, at any time logging takes place. Comment: The High Valley timber sale will cause major damage to non-vegetative natural resources described by experts in the Opposing Viewpoint Attachments. Forging ahead with the timber sale with full knowledge of the likely resource damage that the sale will cause indicates 1) weighing the relative value of the natural resources in the area against timber outputs has not been done, and 2) they have not been “harmoniously coordinated.” Also, since outdoor recreation, watershed, wildlife and fish are adversely affected by the sale, you obviously consider timber more important that these 4 other resources. Request for changes to be made to the final NEPA document: Include the source literature for particularly relevant science quotes contained in the Opposing Viewpoint Attachments in the References section of the final EIS and cite the quotes contained in the attachments in the body of the final EIS. Indeed, it makes sense for a public servant to present the public with the whole story which includes benefits and drawbacks of project implementation. Failure to do this will violate:
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• 40 CFR 1500.2(b) because the USFS could not complete the necessary environmental analyses without all the effects evidence, • 40 CFR 1501.2(a) because the USFS did not identify environmental effects in adequate detail to complete a technical analyses of the project. • 40 CFR 1500.2(e) because the Responsible Official was unable to avoid or minimize adverse effects of the project upon the quality of the human environment without complete knowledge of all likely adverse effects. Some adverse effects of project activities described by scientists in the Attachments was not mentioned in the final NEPA document EA. • 40 CFR 1500.2(f) because the Responsible Official was unable to avoid or minimize any possible adverse effects upon the quality of the human environment without knowledge of the adverse effects. Had the Responsible Official known about these effects he would have acknowledged the existence of some adverse effects described in the Attachments in the final NEPA document EA. Rejecting valid science because it s at odds with USFS timber agenda is also inconsistent with court precedent: Sierra Club v. Eubanks 335 F. Supp. 2d 1070 (ED Cal. 2004) Opinion excerpt: "credible scientific evidence that [contradicts] a proposed action must also be evaluated and considered." Seattle Audubon Society v. Lyons 871 F. Supp. 1291, 1318 (W.D. Wash. 1994) Opinion excerpt: "[the EIS] must also disclose responsible scientific opinion in opposition to the proposed action, and make a good faith, reasoned response to it." Seattle Audubon Society v. Moseley 798 F. Supp. 1473 (WD Wash. 1992) Opinion excerpt: "[ t ] h e a gency's explanation is insufficient under NEPA … not because experts disagree, but because the FEIS lacks reasoned discussion of major scientific objections." Sierra Club v. Bosworth, 199 F.Supp.2d 971, 980 (N.D. Cal. 2002) Opinion excerpt: The forest service failed to "disclose and analyze scientific opinion in support of and in opposition to the conclusion that the…project will reduce the intensity of future wildfires in the project area." ------
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Issue #14 ----- You have consciously selected literature for the References section that excludes science describing how logging will adversely affect non-timber natural resources in the sale area. Comment: The vast majority of available literature written by independent scientists unaffiliated with the USDA that discusses logging and forest road construction describes the natural resource destruction and adverse effects of these 2 actions. You exclude this science from your References section that describes how logging activities harm (and sometimes destroy) proper natural resource functioning. You select references that support logging and roading because including a representative sample of available logging-related effects science would clearly explain why logging the Stoney timber sale is a mistake. Why am I not surprised that you exclude this independently prepared science and instead include and cite biased documents authored by USFS employees that support logging and road construction? How will the District Court judge rule when the plaintiff’s attorneys present these facts? How will you defend your actions? Comment: The 4 page Literature cited section includes many documents. Incredibly, 26% of these were authored by USFS employees. A word search of the draft EA reveals some of the references not written by USFS employees were not cited in the draft EA. They were included in the Literature Cited section for looks. Since this unprofessional behavior occurs here, why should the public believe what is contained in the draft EA? Real professionals who author NEPA documents do not selectively choose literature to cite in their References section that supports their proposed project and systematically exclude documents those that don’t. Comments: There are no documents listed in your References section that describe the likely or potential natural resource harm, damage and impairment that might occur by constructing 9 miles of road and logging 9 square miles that are part of the Proposed Action. A WEB search of the words TIMBER ADVERSE EFFECTS LOGGING gets 2,330,000 hits. See for yourself: http://www.bing.com/search?q=timber%20adverse%20effects%20logging&qs=n&form =QBRE&pq=timber%20adverse%20effects%20logging&sc=0-23&sp=- 1&sk=&cvid=e4548830f3cf4a34a71c3919ee83fa9c Clearly, you hoodwink and deceive the public by presenting only part of the story. Your References section does not include ANY (emphasis added) source documents for the scientific quotes contained in the Opposing Views Attachments. Your proposal to offer the High Valley timber sale in spite of the scientist’s conclusion ignores best science, therefore you 1) violate the law, and 2) reject your responsibility to serve the recreating public. See below. “This uncertainty has affected the ability of the Forest Service to utilize fully the provisions of § 219.35 paragraph (a) to consider the best science available in plan amendments and project decision making. For example, while population data have been held to be required for management indicator species under the 1982 rules, other
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tools often can be useful and more appropriate in predicting the effects of projects that implement a land management plan, such as examining the effect of proposed activities on the habitat of specific species; using information identified, obtained, or developed through a variety of methods, such as assessments, analysis, and monitoring results; or using information obtained from other sources such as State fish and wildlife agencies and organizations such as The Nature Conservancy. The purpose of this interpretative rule is to clarify that, both for projects implementing plans and plan amendments, paragraph (a)’s mandate to use the best available science applies.” “The transition provisions as originally enacted, and now twice amended, explicitly refer to the 1982 planning rule as the rule ‘‘in effect prior to November 9, 2000.’’ At the same time, given the extension of the effective date of paragraph (d), within which site specific decisions must comply with the 2000 planning rule (68 FR 53294), it is clear that site-specific decisions entered into during the transition period are not to comply with the substantive provisions of the 2000 planning rule. This interpretative rule clarifies that until a new final rule is promulgated, the transition provisions of the 2000 planning rule, as amended by the May 2002 interim final rule remain in effect, including the requirement of § 219.35 paragraph (a) of the transition provisions that responsible officials consider the best available science in implementing national forest land management plans and, as appropriate, plan amendments. Pursuant to paragraph (b), the provisions of the 1982 planning rule may continue to be used only for plan amendments and revisions upon election of the responsible official. Appropriate plan amendments and projects proposed during the transition period should be developed considering the best available science in accordance with § 219.35 paragraph (a).” Federal Register / Vol. 69, No. 188, page 58056 Wednesday, September 29, 2004 Rules and Regulations http://www.fs.fed.us/r1//projects/plan_rule/intrpretative-rule.pdf Request for changes to be made to the final NEPA document: Include some source documents from the Opposing Views Attachments in the References section of the final EA. Also, cite some the specific quotes related to the issue that are presented in the source literature in the Opposing Views Attachments. The public deserves to be informed of this information so they can make an informed decision to support or oppose the timber sale based on complete data. Failure to do so will violate:
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• 40 CFR 1500.1(b) because important environmental information was not made available to citizens before the decision was made. • 40 CFR 1500.1(c) because the public was denied the opportunity to understand the adverse environmental consequences of the logging treatment. • 40 CFR 1500.2(e) because the Responsible Official was unable to avoid or minimize adverse effects of the project upon the quality of the human environment without complete knowledge of all likely adverse effects. Some adverse effects of project activities described by scientists in the Attachments was not mentioned in the final EA. • 40 CFR 1500.2(f) because the Responsible Official was unable to avoid or minimize any possible adverse effects upon the quality of the human environment without knowledge of the adverse effects. Had the Responsible Official known about these effects he she would have acknowledged the existence of some adverse effects described in the Attachments in the final EA. ------Issue #15 ----- The Proposed Action does not respond to of the Purpose & Need goals. Therefore, it must be rejected. Need #1 shown at page 7 for this timber sale’s draft EA states: “Address undesirable impacts to soil and water quality and restore hydrologic function and riparian habitat.” This timber sale is called the High Valley Integrated Restoration project. Clearly you intend for the logging and road construction to “restore” the forest’s natural resources. Comment: Eminent scientists the USDA Office of Inspector General and the NOAA fisheries Office all conclude commercial logging will significantly damage and even destroy natural resources in the forest. These conclusions are based on research. Ranger Newton, here is a small sample of the science you ignored and/or rejected as you planned the High Valley timber sale: “Land use activities associated with logging, road construction, urban development, mining, agriculture, and recreation have significantly altered fish habitat quantity and quality. Associated impacts of these activities include: alteration of streambanks and channel morphology; alteration of ambient stream water temperatures; degradation of water quality; reduction in available food supply; elimination of spawning and rearing habitat; fragmentation of available habitats; elimination of downstream recruitment of spawning gravels and large woody debris; removal of riparian vegetation resulting in increased stream bank erosion; and increased sedimentation input into spawning and rearing areas resulting in the loss of channel complexity, pool habitat, suitable gravel substrate, and large woody debris.” Pacific Salmonids: Major Threats and Impacts Published by NOAA fisheries Office of Protecte Resources, May 15, 2014 http://www.nmfs.noaa.gov/pr/species/fish/salmon.html
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“Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.” Partridge, Arthur Ph.D., professor emeritus, University of Idaho Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.” “The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.” Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Scientists Seek Logging Ban on U.S.-Owned Land” New York Times, April 15, 2002 http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf Request for changes to be made to the final NEPA document: Include the qualifications of the IDT members and discuss why they trump the experts in the Opposing Views Attachments or if you feel the experts are more qualified than the IDT members, please select another Proposed Action that “best science” says will restore” the forest’s natural resources.
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Failure to do so will violate NFMA at Section 6 (g)(3)(E)(iii), 40 CFR 1500.1(c) and 40 CFR 1500.2(e) and (f). ------Issue #16 ----- After reading the attachments I hope you can ignore your need for volume and understand your proposed High Valley timber sale is not a restoration project. I cannot believe there are still USFS employees who really believe commercial timber sales restore anything but the purchaser’s bottom line. Here’s a little history. The public’s opposition to timber sales had been steadily increasing. In the fall of 2008 Chief Kimbell took action hoping to regain agency credibility. She issued verbal direction to the Regional Foresters to phase out the use of the terms “timber sale” and “logging” in documents that might be read by the public. “Timber sale” was to be replaced with “restoration project” and “logging” was to be replaced by “treatment.” Comment: The USDA Office of Inspector General concludes that commercial timber sales are not restoration projects. "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf Why do you disagree with the OIG by referring to your Middle Fk Weiser timber sale as a restoration project? Comment: The following eminent Ph.D. biological scientists, the USDA Office of Inspector General and NOAA fisheries employees conclude commercial logging will significantly damage and even destroy natural resources in the forest. These conclusions are based on research. Ranger Newton, here is a small sample of the science you ignored and/or rejected as you planned the High Valley timber sale: “Land use activities associated with logging, road construction, urban development, mining, agriculture, and recreation have significantly altered fish habitat quantity and quality. Associated impacts of these activities include: alteration of streambanks and channel morphology; alteration of ambient stream water temperatures; degradation of water quality; reduction in available food supply; elimination of spawning and rearing habitat; fragmentation of available habitats; elimination of downstream recruitment of spawning gravels and large woody debris; removal of riparian vegetation resulting in increased stream bank erosion; and increased sedimentation input into spawning and rearing areas resulting in the loss of channel complexity, pool habitat, suitable gravel substrate, and large woody debris.” Pacific Salmonids: Major Threats and Impacts Published by NOAA fisheries Office of Protecte Resources, May 15, 2014 http://www.nmfs.noaa.gov/pr/species/fish/salmon.html
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“Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.” Partridge, Arthur Ph.D., professor emeritus, University of Idaho Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.” “The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.” Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Scientists Seek Logging Ban on U.S.-Owned Land” New York Times, April 15, 2002 http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf Who are these IDT members who so cavalierly reject “best science”? Comment: Ranger Newton, your insincere, disingenuous, trickery desperately trying to convince the public that your logging and roading “restores” anything but corporate profit is now a Forest Service Employees for Environmental Ethics focus issue. You
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destroy your professional integrity by pushing this “restoration” lie. Here’s what the Forest Service Employees for Environmental Ethics group has to say: “Two decades ago, it wasn’t uncommon to hear Forest Service managers brag about “getting out the cut.” Career advancement often depended on how much timber volume could be produced. The word clearcut was not yet taboo. Those days are gone, thank goodness. Once again, though, the Forest Service is laying plans to cut down wide swaths of our National Forests. And those would-be timber beasts have learned an important lesson—language matters. They’ve ditched the terms they learned in forestry school, replacing them with feel- good jargon like “restoration,” “forest health,” “wildfire resilience” and “collaboration.” “ “Countering these damaging, falsely advertised restoration projects takes time and resources. It requires close reading of lengthy, complicated environmental review documents. It requires careful strategizing. It requires forming alliances with residents and elected officials. Often, it requires litigation. FSEEE is uniquely positioned to lead the charge against these damaging and misleading restoration logging projects. We know the laws and we know how the Forest Service works.” “This is the sad reality being proposed for hundreds of thousands of acres of public lands around the nation. The Forest Service is waging a cynical public-relations campaign designed to fool the public into supporting more logging of our National Forests under the guise of restoration, when in reality, it’s just cover for more clearcuts.” Link to full report: http://fseee.org/index.php/stay-informed/projects/1004368 Are you aware that some of your employees are secret dues-paying FSEEE members? Comment: You are obedient Ranger Newton. You title your timber sale The High Valley Integrated Restoration project. Like any good USFS team player. You use “restore” 27 times in the draft EA. You know the USFS deception language well. It would bother most people to fool and lie to their supervisors (322 million Americans) who provide the money for their salary. You don’t care do you? Why? Your job pays well and you know dealing with timber sales in the public arena honestly will eliminate your future promotion opportunities. I have included many quotes by independent Ph.D. biological scientists in the Opposing Views Attachments describing how logging and road construction destroy the ability of many natural resources in the forest to function properly. Only a lunatic would believe the statements by several USFS IDT members with massive incentive to say nothing that might jeopardize a proposed timber sale should trump the experts. Accumulating volume and spending all your NFTM allocation this FY simply isn’t worth the natural resource damage you will inflict. Request for changes to be made to the final NEPA document: Eliminate “Restoration” from the sale name and eliminate the word “restore” from the text. Failure to do so violates:
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18 USC § 1519 and the public trust. 40 CFR § 1500.1(b) because actions were not taken to protect, restore, and enhance the environment, and 40 CFR 1500.2(f) because actions were not taken to avoid or minimize any possible adverse effects of their actions on the quality of the human environment. Lying about the effects will give the Responsible Official an excuse to take no action to eliminate the damage, thus 18 U.S.C. § 1001 has been violated. ------Issue #17 ----- Your untrue, pathetic, fabricated Chapter 3 disclosures are clearly intended to convince the public selecting the No Action alternative would be a tragic mistake. The IDT members all know it’s their job to portray No Action as a harrowing, disastrous mistake. Some IDT members copied and pasted the same No Action effects wording they used in prior NEPA documents. The IDT members know that in some cases disclosing accurate, true No Action effects would make it difficult for the Responsible Official to select the Action alternative already selected for implementation prior beginning the NEPA process. The sale area has never been commercially logged. The IDT silviculturist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in a trend towards a high insect and disease rating. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The fuels specialist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in a very high wildfire hazard rating across the Project Area. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT biologist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the extirpation of the white- headed woodpecker in source habitat would be absent in 39 years. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT biologist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the flammulated owl suitable habitat would start to decline in 39 years. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. The IDT soils scientist claims maintaining the status-quo, unlogged state in the sale area that has existed for hundreds of years will suddenly result in the risk of wildfire cover could potentially trigger landslides. Do you really expect the American public to believe this? Some natural resource specialists will not lie to please the Responsible Official. Why hasn’t this occurred in the last several hundred years:
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Request for changes to be made to the final NEPA document: Disclose accurate No Action effects to the natural resources in and downstream from the sale area. If the IDT member still feels their resource will be plundered by not logging and roading and maintaining the conditions that have existed for many decades, then quote the science and identify the data that led them to these conclusions. The court will not accept unsubstantiated claims of damage. Failure to do so will violate 18 USC 1519 and 40 CFR 1500.1(b) because the analysis is not “accurate” and is inconsistent with best science. 40 CFR 1500.1(e) because without an accurate effects analysis the Responsible Official will not select No Action “avoid or minimize adverse effects” because he/she will be unaware that No Action will cause no resource damage when compared with the effects of logging and roading. 40 CFR § 1500.1(b) and 40 CFR 1500.2(f) because the pessimistic No Action effects disclosures would not motivate the Responsible Official to 1 take action to select No Action to avoid or minimize any possible adverse effects on the quality of the human environment. ------The children born 50 years from today will not appreciate the ecological plunder caused by this timber sale. How could anyone ignore children? They won’t appreciate their land being plundered to provide a natural resource extraction corporation with profit. Most Americans want future generations of kids to have the opportunity to experience the quietness and solitude in a real, undeveloped forest. This will become more important in 2070 when the predicted population of the United States will be 418 million people. The wild UNDEVELOPED national forests will provide one of the only escapes from the insanity of a world driven even more by money than it is now. Comment: The High Valley sale will take away more undeveloped national forest acres from the legacy the unborn kids of the future. Which is most important: the future kids of America or another summer home for the CEO of a timber extraction corporation? In 2015 the total area commercially logged in all USFS regions was 205,000 acres. The 10-year average is 220,000 acres. At this rate, future generations will loose 11,880,000 acres of undeveloped forestland. You contribute to this sad statistic with this timber sale. I wonder if all your IDT members are proud to assist you in your plunder. Do they know the USFS logged 903,000 acres in 1990? ------By now you may have read the information contained in the Opposing View Attachments. Reasonable people would have doubts about the wisdom of their proposal that is likely to create major adverse impacts to their resources as described by hundreds of Ph.D. scientists in the attachments. Responsible people that contemplate any action intuitively engage the Precautionary Principle. Perhaps you have never heard of it. Here it is in a nutshell: The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking an action.
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See: http://en.wikipedia.org/wiki/Precautionary_principle Opposing Views Attachment #15 contains quotes by Hilda Diaz-Soltero, Dr. Ann Bartuska, Chief Dale Bosworth, Associate Chief Sally Collins, Chief Dr. Mike Dombeck, Chief F. Dale Robertson, Agriculture Secretary Dan Glickman, and USFS Chief Tom Tidwell, who all tell the public the USFS depends on “best science” as the basis for it’s projects How do you justify not complying? ------Ranger Newton, as you and your IDT will find out, the Opposing Views Attachments contain the wisdom of several hundreds Ph.D. scientists who all agree that logging and roading the forest will inflict major adverse ecological impacts. They show how the passing of time without human manipulation is the only way to bring these logged areas back to health in spite of the fact you claim this timber sale will create a healthy forest and “restore” the natural resources in the area. Some of your IDT members know this is true and are frightened to speak up. A small sample of the opposing views from the Opposing Views Attachments is included below. I’m sure some members of the IDT are familiar with the work these scientists have produced: E.O. Wilson, Chris Maser, Jerry Franklin … and Aldo Leopold. Please read each of the 44 science statements carefully and compare it with what the USFS teaches you to do. Ask yourself why the USFS pushes timber harvest and road construction and each of these scientists collectively agree that few human actions in the forest ecosystem harm the natural resources more than logging and roading. Now ask yourself what motivates the USFS to harm the amenity resources so loved by the public and simultaneously claim to be a public service agency. Finally, ask yourself if you will be comfortable after you retire knowing you sold yourself to please the natural resource extraction corporations. Do you really want to live the best years of your life looking the other way knowing you are allowing yourself to be manipulated on a daily basis? Most people won’t allow themselves to be used for purposes that violate their deeply held values and ethics. There are ways to stay employed and still significantly delay or in rare cases stop tragic projects. I know. I did it for 14 years. 1) "Human beings and the natural world are on a collision course. Human activities inflict harsh and often irreversible damage on the environment and on critical resources. If not checked, many of our current practices put at serious risk the future that we wish for human society and the plant and animal kingdoms, and may so alter the living world that it will be unable to sustain life in the manner that we know. Fundamental changes are urgent if we are to avoid the collision our present course will bring about." Union of Concerned Scientists 2) "The primary goal of resource management (sustained yield) evolved from the utilitarian values of the Progressive Era. Intuitively, sustained yield is a logical and laudable goal: no more is taken than can be replenished. As it has come to be implemented, however, the concept of sustained yield has been modified to mean taking
183 High Valley Integrated Restoration Project Comment Analysis the maximum supply a system can withstand (i.e., the furthest point to which production can be pushed without impairment of the resource’s ability to reproduce). One of our colleagues calls this 'management at the edge of harm'." Hanna Cortner and Margaret A. Moote in The Politics of Ecosystem Management 3) "Nature designed forests to live 100 to 5000 years. We are designing a forest to live between 60 and 120 years. Nature continually regenerates diverse forests of single and multiple tree species (usually between one and 10 tree species) including plants, animals, micro-organisms and fungi. We design forests of single and multiple tree species (often planting two or more tree species on the same site) leaving regeneration of other components of the ecosystem to nature. Nature designed some forests to be connected, and others to be disconnected, "in space and time over vast landscapes." We are designing fragmented forests disconnected in space and time on clearcut patches. Nature designed a forest to be self-sustaining, self-repairing. We are designing a forest to require external expenditures and subsidies, watershed restoration, brushing, spacing and fertilizers." Anthony Britneff, RPForum, Oct 97 4) "The one process now going on that will take millions of years to correct is the loss of genetic and species diversity by the destruction of natural habitats. This is the folly our descendants are least likely to forgive us." E.O. Wilson 5) "Evidence points to a common cause behind past failures of investments in sustainable development. Historically, the management of forest, rangelands, fisheries, and wildlife resources was dominated by theories of carrying capacity and goals of sustainable yield. Human behavior was ignored. The application of these theories led to the expectation that target variables such as employment could be stabilized and created a demand for a constant flow of product. These policies were successful initially, and profit and employment were, in fact, stabilized. But their very success resulted in slow changes in key ecological, social, and cultural components not captured in the management models: changes that typically led to the collapse of the entire system. The "economic extinction" of cod along the coast of eastern North America is a prime example. From a review of a wide range of failed sustainable development initiatives, a common pathology emerges. At the extreme, the ecological system loses resilience, the industries become dependent and inflexible, the management agencies become rigid and myopic, and the public loses trust in governance." C.S. Holling, Dec 2000 6) "The instrument, the knife, that carved out the new, rudimentary forest was the razor- sharp interest in the production of a single commodity. Everything that interfered with the efficient production of the key commodity was implacably eliminated. Everything that seemed unrelated to efficient production was ignored. Having come to see the forest
184 High Valley Integrated Restoration Project Comment Analysis as a commodity, scientific forestry set about refashioning it as a commodity machine. Utilitarian simplification in the forest was an effective way of maximizing wood production in the short and intermediate term. Ultimately, however, its emphasis on yield and paper profits, its relatively short time horizon, and, above all, the vast array of consequences it had resolutely bracketed came back to haunt it." James C. Scott in Seeing Like a State 7) "Ecological forestry that maintains an effective coarse filter differs markedly from the ‘engineering’ approach common under sustained-yield timber management. Under that model, foresters try to define precise objectives for specific ecosystem components (e.g., trees, water, habitat for a particular endangered species) and use sophisticated quantitative methods to determine optimal management strategies. Though it can be considered appropriate for certain narrowly defined problems, we believe that there is a certain arrogance to such an approach to managing forests for biodiversity. It assumes a near- perfect understanding of the ecosystems under management." Robert Seymour and M.L. Hunter in their book Maintaining Biodiversity in Forest Ecosystems 8) "Two broad schools of thought exist regarding landscape planning. In one, future landscape patterns are described in specific desired products (e.g., wood fiber, habitat) and known ecosystem processes. The theme can be summarized as ‘we know what we want and we know how to get it’. In the other approach, future patterns are based upon historic patterns to the degree feasible. This point of view reflects the fact that we cannot even name all the species in the landscape, much less rationally plan for their habitat needs and ecosystem functions. A premise of this approach is that native species have adapted to the disturbance events and resulting range of habitat patterns of the past thousands of years. The probability of their survival is reduced if their environment deviates substantially from the range of historic conditions." Cissel, Swanson, McKee and Burditt Journal of Forestry 9) "Current standards represent the protection of environmental and cultural values as constraints on managing the timber resource. Current standards do not effectively integrate ecosystem and cultural values. Nor do they adequately address requirements for ecosystem sustainability, harmonious stewardship of all resources, and the needs of future generations. Historical approaches to forest management have focused largely on products rather than on the biological systems from which these products derive. In Clayoquot Sound, as elsewhere in British Columbia, sustaining timber production has historically taken precedence over maintaining forest ecosystems. The Panel believes that forests should be managed as ecosystems, rather than as potential products, and that forest practices should not put at risk the long-term health of forest ecosystems. 'Sustainable ecosystem management' is characterized by resource management practices that are scientifically based, ecologically sound, and socially responsible.
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The Scientific Panel’s recommendations are among the first efforts taken to shift forestry from its historical focus on sustaining output levels for specific forest products, to a focus on sustaining forest ecosystems." Clayoquot Sound Scientific Panel 10) "If we choose to continue our current patterns of use, we face almost certain declines in the ability of ecosystems to yield their broad spectrum of benefits … from clean water to stable climate, fuelwood to food crops, timber to wildlife habitat. We can choose another option, however. It requires reorienting how we see ecosystems, so that we learn to view their sustainability as essential to our own. Adopting this "ecosystem approach" means we evaluate our decisions on land and resource use in terms of how they affect the capacity of ecosystems to sustain life, not only human well-being but also the health and productive potential of plants, animals, and natural systems. Maintaining this capacity becomes our passkey to human and national development, our hope to end poverty, our safeguard for biodiversity, our passage to a sustainable future." in People and Ecosystems: The Fraying Web of Life by the World Resources Institute 11) "Nature designed a forest as an experiment in unpredictability. We are trying to design a regulated forest. Nature designed a forest of long-term trends. We are trying to design a forest of short-term absolutes. Nature designed a forest with diversity. We are designing a forest with simplistic uniformity. Nature designed a forest with interrelated processes. We are trying to design a forest based on isolated products." Chris Maser in The Redesigned Forest 12) "One of the most fundamental lessons of the last several decades of ecological research is that the biological diversity of North American forests is far greater than previously thought. At the same time, much more is at risk through traditional forestry programs then ever imagined. Perhaps nowhere has this been more pronounced that in the debate over the fate of the remaining old forests of the Pacific North-West." Bruce Marcot in Creating a Forestry for the 21st Century 13) "Limiting the periodic harvest of a renewable resource to its periodic growth is the fundamental dictum of sustained yield, but it can take at least two forms. The benign and conservative form sets the harvest level according to the spontaneous (some might say 'natural') periodic increment of the resource. A bolder, more vigorous approach applies capital to the resource, to stimulate production 'artificially'. This approach holds an immense appeal to resource managers with exaggerated anxieties about scarcity, and it appeals immensely to those of the Type A, cabbage-patch, persuasion. Maximum sustained yield would be limited only by the biological capacity of the land to absorb productive capital inputs. "As the second half of the twentieth century got underway, the bold form of sustained yield was pursued enthusiastically by the federal resource agencies. After WW11, the budget floodgates of public capital opened, and the maximizers of sustained yield went on a binge of dam construction, rangeland 'improvement', recreational facilities
186 High Valley Integrated Restoration Project Comment Analysis development, road building, and clear-cutting. Single-resource agencies, cheered on by their single-resource clientele groups undertook Type A management activities with unprecedented capability. "Labeled 'intensive management' in the Forest Service, the enthusiasm led to 'a conspiracy of optimism' as historian Paul Hirt described the period. What timber management meant, in the post-war years, was the conversion of complex biological systems, the old growth forests of the West, into simplified timber plantations." Richard W. Behan in Plundered Promise 14) "The primary goal of resource management (sustained yield) evolved from the utilitarian values of the Progressive Era. Intuitively, sustained yield is a logical and laudable goal: no more is taken than can be replenished. As it has come to be implemented, however, the concept of sustained yield has been modified to mean taking the maximum supply a system can withstand (i.e., the furthest point to which production can be pushed without impairment of the resource’s ability to reproduce). One of our colleagues calls this ‘management at the edge of harm’." Hanna Cortner and Margaret A. Moote in The Politics Of Ecosystem Management 15) "If 20th century forestry was about simplifying systems, producing wood, and managing at the stand level, 21st century forestry will be defined by understanding and managing complexity, providing a wide range of ecological goods and services, and managing across broad landscapes…managing for wholeness rather than for the efficiency of individual components." Kohm and Franklin in Creating A Forestry For the 21th Century 16) "Sustainable forestry will not result from lengthening rotations on tree farms and preserving a few small areas for display of other forest qualities. The evolution to sustainable forestry requires, at a minimum, a recognition of the limitations of present knowledge and of the risk that human intervention will do irreversible harm before enough knowledge accumulates to identify the practices of sustainable forestry. This recognition leads to a double strategy: 1) intensify research on how forest systems work and 2) preserve options for the future. Preserving options implies stopping policies that are doing harm by destroying watersheds, biological diversity, scenic beauty and other forest values. It means developing new forest management techniques that give far less weight to the present and more to the future and less weight to wood production and more to other values." Alice Rivlin in Defining Sustainable Forestry 17) "The concept of conservation ecology is often limited to a protectionist agenda: buy, fence, and lock up as much as possible of the natural world. But fences rot and
187 High Valley Integrated Restoration Project Comment Analysis locks rust. Arbitrary lines drawn on a map have always faded in time; just ask a Cherokee. The critical challenge for science, and our species, demands that we abolish intellectual barriers, crush limited paradigms, and take the broadest possible view of the problem." O’Neill, Kahn, and Russell 18) "In a sense, the need for integration is also the lesson of the old paradigm's failure. The paradigm failed because it oversimplified a complex reality. It is still not clearly understood that the oversimplification took two forms. First, the sustained yield paradigm failed to understand the complexity of forest ecosystems, systematically downgrading the mounting evidence of soil erosion, biodiversity loss, and disappearing habitat as so many anomalies to be handled by doing better in future. Second, it failed to come to terms with the fact that sustainability is as much a social as an ecological problem. Sustained yield forestry is only a problem to the extent that it fails to provide us with what we want from our forests. It continues to be defended precisely because it is providing some people with exactly what they want." Jeremy Rayner, Implementing Sustainability in West Coast Forests in the Journal of Canadian Studies 19) "EM (ecosystem management) technology will probably emerge as more important to people than either the technology of the communications revolution or biotechnology, because of its potential usefulness in guaranteeing a livable environment." John Gordon, Yale University 20) "Decisions made when the sustained yield paradigm was established after the Second World War set British Columbia on a path that has been and will continue to be extremely costly and disruptive to reverse." Cashore et al., Change and Stability in BC Forest Policy from In Search of Sustainability 21) "To illustrate how inadequate existing knowledge has been, consider the important discoveries of the last 25 years with regard to: 1) the extraordinary dynamics of the below-ground subsystem and its high energy requirements; 2) the importance of the dead tree and its derivatives in the long-term functioning and habitat diversity of forests, streams, and rivers; 3) the scale and complexity of edge influences that can be created through forest harvest practices; and 4) the importance of biological legacies, living and dead, in ecosystem recovery following catastrophic disturbances, and the poor match in conditions and processes between most natural disturbances and clearcutting. This is just a small sample of recent scientific insights into forest ecosystems. In fundamental ways, each of these findings alters our view of these forests and how they work. We simply did not understand some very basic aspects of forest structure and function. Consequently, traditional forestry approaches, based on a very simple view of
188 High Valley Integrated Restoration Project Comment Analysis a forest, have proven very inadequate. Resource managers thought that they could grossly simplify forests without consequence. They have done so on a grand scale, and often react energetically against adoption of alternative models of how forest ecosystems work. There is no question that recognizing the potential ecological value of a dead tree makes life much more difficult (or, put another way, more interesting) for the silviculturalist. Perhaps as important, it challenges the basic value set for foresters, many of whom share a strongly utilitarian view of the forest." Jerry Franklin in Conservation Ecology 22) "Sustained yield is not the same thing as sustainability. You could produce a sustained yield of timber (for several rotations anyway) without practicing sustainable forestry. Managing for a consistent and sustained supply of one commodity does not ensure that all other commodities and values will be maintained. Nor is the concept of sustained yield particularly appropriate for forests as ecosystems. Even if one includes all known non-timber forest products and all aspects of ‘wildcrafting’, most components of forest biodiversity are not harvestable resources. Nevertheless, natural resources have continued to be managed (or mismanaged) under the rubric of sustained yield in one form or another, and the histories of forestry, fisheries, and wildlife management show similar patterns [of resource depletion]." Pojar et al. in Silvicultural Options on the Central Coast draft BC MoF, 1999 23) "When systems are pushed outside the bounds of natural variability, there is a substantial risk that biological diversity and ecological function will be jeopardized and therefore, ecological systems will not be naturally maintained." Ayn Shlisky Journal of Forestry 24) "Forestry has been largely concerned with silviculture, defined as "that branch of forestry which deals with the establishment, development, care, and reproduction of stands of timber" (Toumey 1947). The aim of silviculture, according to Toumey, is the "continuous production of wood". But forests comprise much more than wood and other products for human consumption, much more even then the "public service" functions of climate regulation, water supply, pest control, gene banks, or recreational opportunities. What future generations can afford to lose is not the only consideration. Forests are valuable and must be sustained for their own sake. Until we acquire such an attitude, the sustainability concept may just be a smoke screen, behind which we continue to chip away at our biotic heritage." Dr. Reed Noss in Defining Sustainable Forestry 25) "The agricultural paradigm of forestry adopted in this century (simplification and uniformity in structure, pattern, and product) and the regulated landscape (fully occupied by an ordered age sequence of managed stands) no longer suffices. The simplistic notion that four regeneration harvest practices, designed with the knowledge and objectives of the 19th century, can meet the objectives of the 21st century must be given up."
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Kohm and Franklin in Creating a Forestry for the 21st Century 26) "Sustained yield and sustainable development are unquestionably in conflict. Attitudes, policies, and management strategies that evolved to serve the sustained yield ideal are, in many respects, outmoded. Sustainable development demands that timber primacy be replaced by a concern for a forests' contribution to human welfare in the broadest sense. The emphasis must shift from maintaining timber supplies over the long run to maintaining a multitude of resource values that are dependent upon site productivity, ecosystem, ecosystem health, integrity, and diversity." David Haley and Martin Luckert in Managing Natural Resources in BC 27) "Sustaining the yield of a single resource is based on the concept of equilibrium. That is, balance between growth and harvest can be sustained in perpetuity. However the sustained yield idea simply does not fit contemporary circumstances. A different paradigm of forest management is required in a society: • where change is ubiquitous, • where change is rapid and encouraged, • where a scarcity of wood products has failed to materialize, and • where the forest is appreciated for an array of commodity and amenity values." R.W. Behan Journal of Forestry 28) "On a net basis, the forest-planning adventure has been disastrous. Achievements have been grossly outweighed by the environmental, social, managerial, and political damages and costs. Indicting the Forest Service for this travesty of professional management and public administration is indeed inescapable … but it is also insufficient. Also at fault is the obsolete paradigm of professional forestry based on producing a maximum sustained yield of timber. Maximum sustained yield of timber might well be called the forestry of the 20th century - and it differs little from the 19th or 18th." R.W. Behan in Creating A Forestry For The 21st Century 29) "The major change in forestry thinking wrought by Ecosystem Management has been the abandonment of the concept of a stable flow of wood from the land as a universally dominant management objective. As an environmental paradigm replaces utilitarian, conservation, and preservation paradigms in land managers’ and the public’s view of the landscape, the management of whole systems for a variety of purposes rather than commodity flows or single resources (including "wilderness") will become increasingly overt and explicit. Ecosystem Management will differ from multiple-use management in focusing on inputs, interactions, and processes, as well as uses and outputs." Dr. John C. Gordon, Yale University
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30) "A student of forestry in the 1950’s or 1960’s would have found information on converting old-growth stands into even-aged regulated forests, preventing and suppressing fire, creating habitat for game species, or calculating optimum rotations. Little mention was made of institutional or social issues. The forester of the 20th century could go to his post in the woods, plan for a sustained flow of timber, mitigate the negative effects of harvesting, provide for other values where possible, and feel secure in the knowledge that he had carried out his professional duties. Of course, the 21st century will not be such a time." Katherine Kohm and Jerry Franklin in Creating a Forestry for the 21st Century 31) "The growing demand for forest products led the government to quickly take measures to manipulate the forest cover to obtain more wood or to justify larger harvests. To attain increased productivity, forest policy tried to change to make industry more responsible in exploiting the forest in a manner that redistributes the stock of trees on its areas. Under the mechanical interpretation, harvesting the forest is to be structured in such a way that after a transition period, average annual growth is maximized. This is what is meant by ‘normalizing the forest.’ The policy has two objectives. One is always to try and support industry. The second, however, is to ensure that the commercial forest has the maximum quantity of available wood for harvesting. The forest becomes a variable factor of production. The ‘normal’ forest, where each age class of tree occupies the same space over time, is the desired goal because it represents a condition of social stability and maximizes all the functions of the forest. This model of a normal forest raises a number of questions. The idea that an even flow of wood could stabilize human communities betrays, once more, a lack of understanding of economics. Normalization does not take into account the profit motive of mills, where the wood is transformed, although the pursuit of profit is a basic rule of business. We find rhetorical and mysterious the assertion that the normal forest would eventually lead to a situation in which all the functions of the ecosystem are optimized. It does have the trappings of an ecosystem approach. Nevertheless, in our view, the objective of the normal forest, or the normalization of the forest, is merely an elegant way to justify an increase in allowable cuts without increasing the responsibilities of industry." Luc Boutillier in Howlett, ed CANADIAN FOREST POLICY 32) "Principle 1: Sustain healthy, diverse, and productive ecosystems in the long term. A key lesson of the 1980’s was that a national forest or grassland is much greater than the sum of its multiple uses. People demanded that management goals and objectives go beyond the yields of board feet of timber, user days of recreation, animal-unit-months of grazing, and other "multiple use outputs" projected in the endless tables and graphs within forest plans. For too long, federal land use managers had been treating natural resources "as discreet entities, focusing on their economic value and paying little attention to underlying natural systems and processes"(Keiter 1990). This first principle suggests an important corollary for multiple-use management: the key to sustaining all benefits is in managing for ecosystem health. Earlier, it was assumed that land would be taken care of as long as management succeeded in
191 High Valley Integrated Restoration Project Comment Analysis sustaining yields of the various multiple uses. It is now recognized that ecosystem health must be a conscious and deliberate goal as well as the over all context for multiple use management." Dr. Winnifred Kessler and Dr. Hal Salwasser in A New Century for Natural Resources Management 33) "Tensions over ecosystem management are at their starkest in cases where environmentalists and their allies contend that harvesting plans endorsed by the industry and other parts of the development coalition involve a rate of logging too high to allow protection of ecosystem characteristics. Anxious to maintain harvest levels, the industry and its supporters usually adopt as their first line of defense a set of responses based upon the sustained yield … multiple use (integrated management) discourse that was employed to legitimate operations through out the 1970s and 1980s. Industry spokespersons argue that their harvesting practices are designed to sustain the timber supply and protect other important forest values such as wildlife, viewscapes, and riparian zones. Where this response fails to neutralize pressure for ecosystem management, industry interests usually begin to explore what might be referred to as ‘old wine in new bottles’ strategies. Typically these combine symbolic maneuvering with limited substantive concessions. Elements of the ecosystem management discourse are incorporated into rejigged defenses of the practices, and if necessary, these practices are adjusted with an eye to convincing at least the undecided portions of the attentive public that these constructions are credible. Throughout this exercise, industry interests try to create and capitalize on the ambiguity surrounding ecosystem management concepts, hoping to maintain a set of meanings loose enough to allow limited modifications of the practice to be sold as a genuine response to new ideas. Ultimately, the development coalition aims to neutralize pressures for policy change by winning support for the claim that it has brought practices into line with the standards embodied in the ascendant discourse." Jeremy Wilson in Howlett, ed CANADIAN FOREST POLICY 34) "As conceived in the Multiple Use and Sustained Yield Act, within the limits set by ecological sustainability, land and resource planning was to seek the achievement and maintenance in perpetuity of high levels or regular periodic outputs of the various renewable resources of the national forests. Two realities make this approach problematic. First, the dynamics of ecosystems means that scheduling a regular, predictable output of a single product probably will fail because productivity varies through time. For example, experience has shown the difficulty of achieving even flow when management focuses upon maintenance of a high level of production of a short list of outputs (such as wood fiber and forage). Second, an even flow can be sustained under variability, but it often comes by over-exploiting the system's productivity (e.g., by harvesting more than is produced annually) or by impairing other ecosystem elements (e.g., grazing under conditions that cause erosion). When managed this way, National Forests appear to promise a stability of commodity flow that they can not deliver, and public expectations are raised about the long-term capability of the land and likely resource flows. At the extreme, forests managed this way become subject to catastrophic surprises when unusual, but natural, events occur
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(e.g., greatly increased flooding and landslides during heavy rains). Communities that grow dependent on artificially high or constant commodity flows can eventually suffer the same catastrophic surprises … losing all semblance of sustainability." Committee of Scientists Third Draft Preliminary Report, July 98 35) "From the inception of American forestry in the late nineteenth century, foresters saw old growth as an obstacle in the way of the ultimate goal of forestry: to achieve a fully regulated forest producing desired goods and services efficiently and without waste. Foresters hoped to convert old growth as quickly as possible to thrifty, young, growing forests. This remarkably enduring perspective remained largely unchallenged within the forestry profession until the 1980’s, even though for decades many non- timber-oriented resource management professionals defended the positive values of old growth. Greatly outnumbered in the forestry schools, the timber industry and government agencies, these dissenters remained on the margins of policy debates until the 1980’s." Paul Hirt in Institutional Failure in the U.S. Forest Service 36) "There are currently many plans for sustainable use or sustainable development that are founded upon scientific information and consensus. Such ideas reflect ignorance of the history of resource exploitation and misunderstanding of the possibility of achieving scientific consensus concerning resources and the environment. Although there is considerable variation in detail, there is remarkable consistency in the history of resource exploitation: resources are inevitably overexploited, often to the point of collapse or extinction." Dr. Carl Walters, Donald Ludwig, and Dr. Ray Hilbor 37) "A good example of a policy that might be portrayed as precautionary, but is not and should be reformed, is the traditional approach of taking the maximum sustainable yield (MSY) from a fishery. The MSY approach to managing fisheries involves creating a bell-shaped curve to determine the total advisable catch of a targeted stock. In theory, as long as the catch remains on the ascending side of the curve, increased fishing will yield a larger sustainable take. But once the catch moves to the downside of the curve, more fishing will mean less catch because of undue thinning of the population's ability to replenish itself. Managers thus strive to remain at the peak of the curve, known as the MSY plateau. Yet it has been shown time and again that MSY is very difficult to predict and that damage is done by overfishing. Commercial fish populations fluctuate considerably, and often unpredictably, because of ever-changing ocean conditions. Meanwhile, industry attempts to stay at the peak of a historically determined MSY curve have led to dramatic collapses. Rather than give due regard to conservation for the long term, MSY management practices seek to maximize short-term exploitation of the sea." Wilder, Tegner and Dayton
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38) "Those advancing anthropocentric (or softer, less biocentric) definitions (of ecosystem management ) are criticized for offering a naïve, ‘we can have our cake and eat it too’ position that dilutes ecosystem management into something closely resembling discredited concepts such as multiple use and integrated resource management. It is easy, critics say, to ‘cheery pick’ a few elements from the list of ecosystem management goals and principles. Full and genuine adoption of this list, however, would require and/or entail a comprehensive package of changes, a ‘seismic shift’ in mindset that would overturn assumptions and practices based upon utilitarianism and the ‘commodity forest’ and replace them with ones based on a Leopoldian land ethic and the ‘environmental forest’. Out would go the tacit assumptions underlying traditional resource management practices including earth as a resource for humans, competition over cooperation, control in place of adaptation, viewing all problems as soluble, and viewing nature as stable or balanced. In would come contextual thinking, management premised on complex conceptions of ecological and organizational systems, and new approaches ‘based upon the science of surprise, complexity and non-linearity." Jeremy Wilson in Howlett, ed CANADIAN FOREST POLICY 39) "In my own field, forestry, group A is quite content to grow trees like cabbages, with cellulose as the basic forest commodity. It feels no inhibition against violence … its ideology is agronomic. Group B, on the other hand, sees forestry as fundamentally different from agronomy because it employs natural species, and manages a natural environment rather than creating an artificial one. Group B prefers natural reproduction on principle. It worries on biotic as well as economic grounds about the loss of species like chestnut, and the threatened loss of the white pines. It worries about a whole series of secondary forest functions: wildlife, recreation, watersheds, wilderness areas. To my mind, Group B feels the stirrings of an ecological conscience." Aldo Leopold in A Sand County Almanac 40) "Preservation of future stewardship options is rarely possible when current rates of resource exploitation are high. Preserving options assumes an acceptable "decision space" will be available to address the environmental problems confronting future human generations. However, many forest and range ecosystems have experienced intensive resource management and utilization by Euro-Americans with adverse effects on their productive potential. The most significant changes in these systems have occurred over the last 200 years. For example, in forested systems most of the old-growth has been converted to younger stands, extensive road systems have been built with outdated technologies based on unsustainable levels of resource use. In rangeland areas, alterations to riparian systems and stream channels has been extensive, a consequence of historical watershed and riparian management practices. In either of these situations, future stewardship options have been reduced or, in some cases, essentially eliminated. While current stewardship activities can potentially reduce (sometimes increase) future options, if these practices significantly and adversely affect other resources or values, then they are also likely to significantly limit future options. If current practices result in
194 High Valley Integrated Restoration Project Comment Analysis species becoming threatened or endangered, water quality standards being exceeded, or public values and trust violated, then dramatic readjustments to current stewardship activities are clearly needed. Preserving options is also a way of explicitly acknowledging our incomplete knowledge of complex ecosystems – that is, our ignorance of how they function and their interactions with natural and human influenced disturbance regimes and our responsibilities to future human generations. This philosophy is perhaps best encapsulated by focusing more on what we leave behind in exploited ecosystems than on what is taken from them." Committee of Scientists Third draft Preliminary report, July 98 41) "Increasingly, after World War II, the assumptions foresters adopted regarding these myriad considerations shifted first toward the ever-optimistic and finally to the improbable. Those altered assumptions produced a watershed change in forest management an aggressive approach appropriately labeled "intensive management" and advocated in an important document produced by the Forest Service in 1969 titled the Douglas-fir Supply Study. The philosophy of intensive management lent a façade of rationality to a timber program that was, in fact, driven by markets and unsustainable over the long haul. Intensive management ideology also deflected, to an extent, criticisms of the Forest Service by non-timber resource users. Intensive management promised more of everything: more commercial resource extraction and more recreation, more logging and more wildlife. Intensive management also promised to mitigate any resource damage due to development. Unfortunately, these hopeful visions often failed to pan out for lack of funding or because of irresolvable conflicts between uses or simple environmental limitations. Still, as long as the agency promised more and better management, it could elicit a certain amount of patience from critics and deference from policy-makers. But this would not last indefinitely. The proliferation of timber roads and rapid liquidation of old growth eventually made a mockery of sustained yield and multiple use policies on Northwest national forests, and this, in turn, spelled disaster for the Forest Service’s public image." Paul Hirt in Institutional Failure in the U.S. Forest Service 42) "In the past, Registered Professional Foresters emerging from forestry schools across Canada were narrowly trained to maximize fibre production on a given area of land. Safeguarding the health and integrity of ecosystems did not constitute an important dimension of their education or of their work. In the 1990s, significant and long-needed changes are taking place in the forestry curricula in many Canadian schools. However, the new approach is still framed within the sustained yield forest management paradigm, and on prioritizing fibre production over ecosystem health and integrity. Only fundamental reform of the forestry profession can create the New Forester to practice the New Forestry." Fred Gale in The Wealth of Forests
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43) "Through government regulation, "sustained-yield" forestry has become the norm for forest management in North America. As the name implies, sustained-yield forest management focuses on the net productivity of surface resources in the forest. Economic considerations are paramount, and to achieve commercially viable levels of timber in perpetuity, sustained-yield forest management requires frequent intrusions into the woods and aggressive reforestation after harvest. This results in more evenly-aged, less diverse tracts of forestland. In essence, sustained-yield forest management is lowest- common-denominator forestry, producing wood of only average quality and engineering a forest ecosystem that lacks the depth and richness of the natural order." David Ford Certified Forest Products Council in Wrong Focus of Resource Management 44) "The government’s forest policy proposal was released in June 1985 in a document entitled To Build a Forest for the Future. The hypothesis underlying the ministry’s study was an idea dear to professional foresters in Quebec. They took for granted that maintaining a tree cover sufficient to meet the needs of the wood industry would preserve all of the functions of the forest. This hypothesis brings us back to the classic interpretation of the concept of sustained yield. Focussing on the trees, this concept reduced the function of the forest to wood. This reasoning sacrifices the complexity of the forest to bolster a reductionist and technical approach. The merit of the report, however, was that it simplified the aims of the emerging forest policy and consequently enhanced its short-term chances of success." Luc Bouthillier in Howlett, ed CANADIAN FOREST POLICY Based on the evidence, several IDT members can and should take action to stop the High Valley timber sale. You know what to do. When the 44 statements above are combined with the rest of the science conclusions in the Opposing Views Attachments your next move should be clear. These statements clearly represent “best science.” Allowing Mr. Riling (who is financially motivated to produce volume) to trump the best science is folly. ------Ranger Newton, after reading the effects disclosures in Chapter 3, I must conclude theother resource specialists on the IDT have been obedient. Their analysis disclosures show they have no problem trading off the health of the resources they are responsible for protecting for your precious volume. They wrote what you wanted to read. Don’t the kids born in 50 years deserve a place to escape the insanity of a United States with 400 million people? Don’t they deserve to experience solitude, quietness and an occasional nature sound? Unless USFS employees start rejecting the USDA notion that a forest is like a wheat field to be “harvested” regularly, these kids will only be able to experience an undeveloped forest on a DVD depicting the “old times.” ------Sincerely, Dick Artley’s scanned signature is contained in the “signature” attachment.
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Dick Artley [retired USFS forest planner and a person who believes the availability of undeveloped public land for his grandchildren to enjoy is orders of magnitude more important than short-term corporate profit) 415 NE 2nd Street Grangeville, Idaho 83530 208-983-0181 [email protected]
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Appendix C – Full text of Opposing View Attachments submitted by Dick Artley
Opposing Views Attachment #1 These opposing views include science authored by 268 Ph.D. scientists (see pages 41-50) who are world-class experts in forest ecology. Their statements support the fact that logging directly assaults the recreating public and many natural resources in the forest Why would a caring other resource specialist on the IDT choose to assist in this national forest plunder? ------Timber Harvest Opposing View #1 - The following document contains pertinent color pictures showing logging damage, thus the article text is not shown here. Please use the link below to access the article. Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and Implications” Clearcuts and forest fragmentation, Willamette NF, Oregon. From: Cascadia Wildland Project, Spring 2003 http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implica tion.pdf ------Timber Harvest Opposing View #2 - “Timber harvest operations have been shown to have many effects on adjacent watercourses and on the aquatic ecosystems they support. This may occur from introductions or loss of woody debris, loss of riparian vegetation, accelerated stream bank and bed erosion, the alteration of natural channel form and process, and the reduction of stream habitat diversity. However, the existing literature indicates one of the most insidious effects of logging is the elevation of sediment loads and increased sedimentation within the drainage basin. Sediment generation from various forestry practices has been studied extensively in the past. Forestry practices which generate suspended sediments include all operations that disturb soil surfaces such as site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road construction and maintenance.” Anderson, P.G. 1996. “Sediment generation from forestry operations and associated effects on aquatic ecosystems” Proceedings of the Forest-Fish Conference: Land Management Practices Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta.
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http://www.alliance-pipeline.com/contentfiles/45____Sediment_generation.pdf ------Timber Harvest Opposing View #3 - “Timber harvest will remove dead and dying material from the site and inhibit the recruitment of downed woody material as time progresses. Timber harvest and associated reduced structural complexity and reduced age and size class diversity are all known to reduce population abundance and diversity of ants and a number of birds. For instance, ants are documented to require downed woody material in a variety of sizes and in all stages of decomposition (Torgersen and Bull, 1995). This is an attribute that is negatively correlated with harvest of the dead and dying trees and positively correlated with natural succession, especially after disturbance. Ants and birds are known to predate on insect species which cause mortality to trees, serving as a potentially important population control in the case of epidemics or before they occur (Campbell, Torgersen and Srivastava, 1983). Structural and functional characteristics associated with unlogged forests are also important for canopy arthropods, which play an important role in regulating pest outbreaks (Schowalter, 1989). Structural complexity, functional diversity, diversity of ecological process and diversity of structure in roadless areas are all expected to be less susceptible to the outbreak of pests and regulate insect activity in surrounding homogenized forests (Schowalter and Means, 1989; Franklin, Perry, Schowalter, Harmon, McKee and Spies, 1989). A large body of scientific evidence also indicates that increased edge effect and increased sunlight into stands, resulting from reduced canopy cover associated with timber harvest, can directly promote the population abundance, productivity and persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989).” “Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf ------Timber Harvest Opposing View #4 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.” Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml ------Timber Harvest Opposing View #5 - “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.”
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“Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ " “But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.” Barry, John Byrne. “Stop the Logging, Start the Restoration” from The Planet newsletter June 1999, Volume 6, Number 5 http://www.sierraclub.org/planet/199905/ecl1.asp ------Timber Harvest Opposing View #6 - “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests. After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that ’immediate corrective action is needed.’ A new report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out. The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.” Cushman, John H. Jr. “Audit Faults Forest Service on Logging Damage in U.S. Forests” New York Times, February 5, 1999 http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A35751C0A96F958260&s ec=&spon=&pagewanted=print http://www.ncpa.org/sub/dpd/index.php?Article_ID=12468 ------Timber Harvest Opposing View #7 – “Logging on national forest land creates more economic harm than good, according to a recent study by the National Forest Protection Alliance and the Forest Conservation Council. The 75-page report, three years in the making, notes there are dramatic economic and social losses when forests are logged under the U.S. Forest Service's timber-sale program.
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The report, "The Economic Case Against Logging National Forests," states that national forest lands are far more valuable to rural communities when trees are left standing, and that the federal logging program creates billions of dollars in unaccounted costs for communities, businesses, and individuals. This expense comes in addition to timber industry subsidies, which cost American taxpayers approximately $1.2 billion a year.” “Talberth said both reports lend support to current efforts in Congress to end the federal timber- sale program. Introduced by Rep. Cynthia McKinney (D-Georgia) in April 1999, the National Forest Protection and Restoration Act (H.R. 1396) would put an end the federal timber-sale program.” Higgins, Margot, “National forest logging is bad business, study says” Posted on CNN.com-Nature, March 16, 2000 http://www.colorado.edu/AmStudies/lewis/west/costlogging.pdf ------Timber Harvest Opposing View #8 - “I recently read a letter from a line officer who chided local managers for being behind schedule relative to meeting the region’s ‘timber targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.” “We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.” "Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations." Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to all USFS employees on July 1, 1998 http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.html ------Timber Harvest Opposing View #9 - “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.” “The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the
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commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.” Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Scientists Seek Logging Ban on U.S.-Owned Land” New York Times, April 15, 2002 http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm ------Timber Harvest Opposing View #10 - “The Bush administration has announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large- diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.” “Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm ------Timber Harvest Opposing View #11 - "The proposition that forest values are protected with more, rather than less logging, and that forest reserves are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base. (page 2)" "On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they reduce traditional sources of timber income. (page 2)" Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." http://www.coastrange.org/documents/forestreport.pdf ------Timber Harvest Opposing View #12 - “Consequently, we specifically criticize the “simplified structure-based management” approaches derived from simple structural models and traditional
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silvicultural systems such as clearcutting. In our view, the assumptions underpinning simplified structure-based management (SSBM) are not supported by the published scientific literature on structural development of natural forests, disturbance ecology, landscape ecology and conservation biology, or by the relationships between ecosystem structures and processes. In this report, we review scientific findings associated with each of these areas with particular attention to the over-simplified structural models associated with SSBM and the importance and viability of forest reserves to achieve various ecological goals. (page 2) “We do not believe, however, that scientific literature or forestry experience supports the notions that intensively managed forests can duplicate the role of natural forests, or that sufficient knowledge and ability exist to create even an approximation of a natural old-growth forest stand.” (page 3) Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 2007. “Forging a Science-Based National Forest Fire Policy.” Issues in Science and Technology. A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf ------Timber Harvest Opposing View #13 - “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.” “According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’” Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut Down the Trees!” Environmental News Service, 2008. www.ens-newswire.com/ens/aug2002/2002-08-23g.asp ------Timber Harvest Opposing View #14 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value." "Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."
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Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf ------Timber Harvest Opposing View #15 - “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs, logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred during the decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partially created by past timber sales.” “A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)” “One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed. (10)” Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems.” A Congressional Research Service (CRS) report, October 30, 1995. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215 ------Timber Harvest Opposing View #16 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “
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“As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high- value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).” “The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.” “After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire- resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.” Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://yeoldeconsciousnessshoppe.com/art6.html ------Timber Harvest Opposing View #17 - "But all of these benefits are harmed by one activity— commercial logging on national forests through the Forest Service’s timber sale program, in which private timber companies pay the Forest Service to be allowed to cut down trees on public land.” “In other words, the timber sales program functions as a particularly destructive form of government subsidy to private logging companies. This subsidy is so large that if the government ended the Forest Service timber sales program, a portion of the money saved could be used employ every timber worker that is currently involved in cutting down national forests to instead work on ecological restoration, repairing the damage that has been done to our forests, and there would still be millions of dollars remaining in taxpayers savings.” Hanson, Chad, Ph.D. “National Forest Protection” Environment Now (see picture on last page) http://www.environmentnow.org/forest.html ------Timber Harvest Opposing View #18 - “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing wildland fires …” Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and Forest Fires.” Guest Commentary in New West, July 11, 2008
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http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest_fires/C 41/L41/ ------Timber Harvest Opposing View #19 - "Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes." Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in Western Montana” Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-398(6) http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsessionid=l2 sdf2hphia2.alexandra ------Timber Harvest Opposing View #20 - "For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do." Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public." Evergreen magazine, October 1997. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public-v2.html ------Timber Harvest Opposing View #21 - "SEC. 3. FINDINGS. Congress finds the following: Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries." H. R. 1494 text. April 4, 2001 http://www.gpo.gov/fdsys/pkg/BILLS-107hr1494ih/content-detail.html ------
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Timber Harvest Opposing View #22 - "Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences." Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Biodiversity Sustains Us” from his book review of The Work of Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997 Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 http://www.mikehudak.com/Articles/FromPrairieDogs9902.html ------Timber Harvest Opposing View #23 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9) “As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.” Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessionid= C8DDB611DB29D3716BBF313AADBA2E70?sequence=1 ------
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Timber Harvest Opposing View #24 - "The Quincy Library Group's (QLG's) fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review." "The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management expertise." "In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects." "Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires." "And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution." "The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of 'cut and run' logging, many of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets … a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs." Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan." Unpublished research paper. 1997. http://www.fire-ecology.org/research/logging-for-firefighting_2.htm ------Timber Harvest Opposing View #25 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to
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heed the facts, not fantasies, and develop forest management policies based on science, not politics.” Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm ------Timber Harvest Opposing View #26 - "Since the 'New Perspectives' program of the early 1990s, the agency has tried to dodge public opposition to commercial logging by using various euphemisms, such as this gem from the Siskiyou National Forest: Clearcuts are called 'minimum green tree retention units.' Accordingly, Forest Service managers have believed that if they simply refer to logging as 'thinning,' or add the phrases 'fuels reduction' or 'forest restoration' to the title of their timber sale plans, then the public will accept these projects at face value, and business-as-usual commercial logging can proceed. In the face of multiple scandals and widespread public skepticism of the Forest Service's credibility, it seems that only Congress is buying the agency's labeling scheme." Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to Wildfires” published in the Portland Oregonian, August 6, 2002 http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.html ------Timber Harvest Opposing View #27 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://www.fire-ecology.org/research/wildfire_paradox.pdf ------Timber Harvest Opposing View #28 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards." "Decades of encouraging private logging companies to take the biggest, oldest, most fire- resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands." "In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick-diameter fire-resistant overstory trees instead
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of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks." Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html ------Timber Harvest Opposing View #29 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire- resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.” “Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.” Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm ------Timber Harvest Opposing View #30 - “Linear developments may result in habitat avoidance for grizzly bears. Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non- hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.” “The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.” Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of Linear Developments on Wildlife: A Review of Selected Scientific Literature.” Prepared for
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Canadian Association of Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. http://www.arlis.org/docs/vol1/A/65937142.pdf ------Timber Harvest Opposing View #31 - “History, not science, refutes the claim that logging helps to prevent forest fires. The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests. Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot. More logging will not fix this.” Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.thefreelibrary.com/Logging+does+not+prevent+wildfires.-a0192070397 ------Timber Harvest Opposing View #32 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds. Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?” Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html ------Timber Harvest Opposing View #33 - "Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low-ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest." Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata
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"Effects of Human-Induced Changes on Hydrologic Systems." An American Water Resources Association publication, June 1994 http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF ------Timber Harvest Opposing View #34 - "Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)." "Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain." "Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources less than four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools." Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest. http://www.nd.edu/~underc/east/education/documents/AKlein2004Pre- loggingsurveyofamphibianlarvaeinvernalpools.pdf ------Timber Harvest Opposing View #35 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.” Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. https://www.frames.gov/rcs/6000/6269.html ------
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Timber Harvest Opposing View #36 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.” “How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.” Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp ------Timber Harvest Opposing View #37 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non- commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground. Leitner, Brian. “Logging Companies are Responsible for the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html ------Timber Harvest Opposing View #38 - "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11) Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf ------Timber Harvest Opposing View #39 - “In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become
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the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.” Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998 http://www.sciencemag.org/content/283/5410/1996.summary ------Timber Harvest Opposing View #40 - "Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system." Maser, C. Ph.D., and J. M. Trappe Ph.D. “The Seen and Unseen World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW-164 http://www.fs.fed.us/pnw/publications/pnw_gtr164/ ------Timber Harvest Opposing View #41 - "Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5) "Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44) Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA Forest Service, GTR-PNW-GTR-229 http://www.fs.fed.us/pnw/publications/pnw_gtr229/ ------Timber Harvest Opposing View #42 - "In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by: a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.” McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of eastside ecosystems: changes in fish habitat over 50 years, 1935-1992.” 1994 GTR-321 93-181 http://www.fs.fed.us/pnw/publications/pnw_gtr321/
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------Timber Harvest Opposing View #43 - “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams. The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution of fishes, reduction in fish numbers, and reduction in total biomass.” Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of Logging on the Aquatic Resources of Three Headwater Streams of the Alsea River, Oregon – Part III.” Fishery Report Number 9 Oregon Department of Fish and Wildlife. http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf ------Timber Harvest Opposing View #44 - "Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling." "All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in functioning can be particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations." "Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levels typical of managed ecosystems." Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining Natural Life Support Processes." Issues in Ecology No. 4. Fall 1999. http://cfpub.epa.gov/watertrain/pdf/issue4.pdf ------Timber Harvest Opposing View #45 - "As a result of the Forest Service's well-documented mismanagement over many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry."
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Nappier, Sharon. Lost in the Forest: How the Forest Service's Misdirection, Mismanagement, and Mischief Squanders Your Tax Dollars. Taxpayers for Common Sense, 2002. http://www.ourforests.org/fact/lostintheforest.pdf ------Timber Harvest Opposing View #46 - "Agroforestry does reduce biodiversity. In forests used for logging, whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and catchment purposes. Management strategies for sustainable forestry are being developed, but there is a need for further interaction among foresters, ecologists, community representatives, social scientists, and economists." Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human-Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997. http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow=&HITS=10&hits=10&R ESULTFORMAT=&fulltext=logging&searchid=1136659907310_5043&FIRSTINDEX=0&jour nalcode=sci ------Timber Harvest Opposing View #47 - "The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees." "The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non-material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning." "The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed." "For example: • 82 percent wanted to ban clearcutting, • 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining undisturbed forest; and • 72 percent urged prohibition of logging if bear or other wildlife habitat would be harmed." "Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more important than protection of endangered species."
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"'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'." Northup, Jim. 1999. "Public Wants More Wilderness, Less Logging on Green Mountain NF". Press Release by Forest Watch, a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10 ------Timber Harvest Opposing View #48 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk." “Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.” Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://motherjones.com/politics/2002/08/fight-fire-logging ------Timber Harvest Opposing View #49 - “In response to catastrophic wildfires, wide-reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore historic forest structure in those forest types that are outside of their historic range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then aggregated by land management classes. Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations. Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce
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the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.” Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001 ------Timber Harvest Opposing View #50 - "Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands." Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of the United States." USDA Forest Service. Rocky Mt. Forest and Range Experiment Station. Gen. Tech. Rep. RM-234. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html ------Timber Harvest Opposing View #52 - “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades. We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems. The Act to Save America's Forests will: • Make the preservation and restoration of native biodiversity the central mission of Federal forest management agencies. • Ban extractive logging in core areas of biodiversity and the last remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value. • Protect sensitive riparian areas and watershed values by banning extractive logging in streamside buffer zones. • End clearcutting and other even age logging practices on federal land. • Establish a panel of scientists to provide guidance to federal forest management. We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to
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Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery into the 21st century and beyond.” Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Ph. D. and over 600 other leading biologists, ecologists, foresters, and scientists from other forest specialties. From a 1998 letter to congress. http://www.saveamericasforests.org/resources/Scientists.htm ------Timber Harvest Opposing View #53 - “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologically-sound plan for protecting and restoring the entire federal forest system. If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.” Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Carnahan http://www.saveamericasforests.org/Raven.htm ------Timber Harvest Opposing View #54 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).” Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf
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------Timber Harvest Opposing View #55 - “I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect this threatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.” “Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In my experience the most pervasive and severe impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasive changes due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.” Roelofs, Terry D. Ph.D. Testimony for the California State Water Board and Regional Water Quality Control Boards Regarding Waivers of Waste Discharge Requirements on Timber Harvest Plans. August 2003. http://www.docstoc.com/docs/20957789/EXPERT-WITNESS-REPORT-OF-TERRY-D ------Timber Harvest Opposing View #56 - “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, protective strategies made up 76 percent of the preferred management strategies and commodity-based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.” Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural Development Perspectives, vol. 14, no. 2 http://www.colorado.edu/AmStudies/lewis/west/amenities.pdf ------
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Timber Harvest Opposing View #57 - “Once clear-cutting has occurred, regulation and human silvicultural practices become responsible for the revegetation that follows. The creation of new forest succession patterns are the result of human control over the growing environment. Rather than proceeding at a natural pace, humans attempt to speed up the forest succession process to quickly return to a situation where harvesting is again possible. Reforestation of the disturbed area after clear-cutting also emphasizes maintaining control over the distribution and quality of forest species. Simplification is a state that results from the forest being harvested before it reaches maturity. Logging simplifies forest ecosystems (Dudley et al 1995) by narrowing the age range of the stand and suppressing diversification through repeated harvesting, burning to remove slash, and replanting with hybrid seedlings. Simplification affects the health and productivity of the forest because simplified forests lack the variety found in older stands, including species diversity, vertical structure, and microhabitat. From an ecological standpoint, a simplified forest of a particular age has less overall bio-mass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of merchantable timber. Scott, Mark G. “Forest Clearing in the Gray’s River Watershed 1905-1996” A research paper submitted in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE in GEOGRAPHY Portland State University, 2001 http://www.markscott.biz/papers/grays/chapter1.htm ------Timber Harvest Opposing View #58 - “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.” Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. "Physicians of the Forest": A Rhetorical Critique of the Bush Healthy Forest Initiative” Electronic Green Journal, Issue #19, December 2003 http://escholarship.org/uc/item/4288f8j5 ------Timber Harvest Opposing View #59 - “Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact,
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the justification for the Weeks Act in 1911 which established national forests in the east, was watershed protection. (A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.) “Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, as well as homes for a myriad of plants and wildlife that can live nowhere else.” Sierra Club. 2005 “Ending Commercial Logging on Public Lands” http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html ------Timber Harvest Opposing View #60 - “Timber harvesting in British Columbia influences (a) forest hydrology; (b) fluvial geomorphology; (c) terrain stability; and (d) integrated watershed behavior. Impacts on forest hydrology are well understood and include increased average runoff, total water yield, increased storm runoff and advances in timing of floods. Stream channels and valley floors are impacted differently by fine sediment, coarse sediment and large woody debris transport. Terrain stability is influenced through gully and mass movement processes that are accelerated by timber harvesting. Impacts on integrated watershed behavior are assessed through disturbed sediment budgets and lake sediments.” Slaymaker, Olav Ph.D. “Assessment of the Geomorphic Impacts of Forestry in British Columbia” AMBIO: A Journal of the Human Environment 29(7):381-387. 2000 http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381 ------Timber Harvest Opposing View #61 - “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and communities.” “Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.” Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to Central Oregon Communities and the Surrounding Environment.” Testimony before the House Committee on Resources, August 25, 2003
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http://www.propertyrightsresearch.org/2004/articles6/testimony_of_andy_stahl.htm ------Timber Harvest Opposing View #62 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles. The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity. Logging, especially clear cutting, can change the fire climate so that fires start more easily, spread faster, further, and burn hotter causing much more devastation than a fire ignited and burned under natural conditions. If we stop the logging and stop building fire prone developments, we minimize the loss of lives and property suffered by people in fires. As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make more money from our losses. Just like big tobacco.” Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm ------Timber Harvest Opposing View #63 - “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotes nearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1) “Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9) “Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19) “Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20) “Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20) Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires”
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Washington DC , Dec. 2000 http://www.taxpayer.net/library/article/from-the-ashes ------Timber Harvest Opposing View #64 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.” Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php ------Timber Harvest Opposing View #65 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62) University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://www.alibris.com/Sierra-Nevada-Ecosystem-Project-Final-Report-to-Congress-Status-of- the-Sierra-Nevada-University-of-California/book/9814335 ------Timber Harvest Opposing View #67 - "The development of sound forest-management policies requires that consideration be given to the economic benefits associated with competing uses of forest resources. The benefits that may be provided under different management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasi-option value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices and costs." Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public Forestlands: A Survey of the Literature. A study conducted on behalf of the U.S. Forest Service, January 31, 1995 http://icbemp.gov/science/vincent.pdf ------Timber Harvest Opposing View #68 - “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalists at odds with
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the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees. Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires. In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “ Voss, René, Ph.D. “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml ------Timber Harvest Opposing View #69 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.” Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html ------Timber Harvest Opposing View #70 - “Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitive wildlife. Logging typically requires roads and skid trails which create chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who suggests that logging is a benefit or benign is not doing a full accounting of costs.” Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.” Wuerthner, George “Who Will Speak For the Forests?” NewWest, January 27, 2009 http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/
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------Timber Harvest Opposing View #71 - "After logging, peak pipeflow was about 3.7 times greater than before logging." "The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)." Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow and erosion: coastal northern California, USA." Proceedings of the Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992 http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF ------Timber Harvest Opposing View #72 - “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, but also numerous other services such as recreation and clean water.” “Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat.” “It is now widely recognized that commercial logging has damaged ecosystem health, clean water, and recreational opportunities-- values that are highly appreciated by the American public. The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service and independent economists have estimated that timber accounts for only 2.7 percent of the total values of goods and services derived from the National Forests, while recreation and fish and wildlife produce 84.6 percent.” From an April 16, 2002 letter to President Bush asking him to stop all logging in the national forests. http://www.wvhighlands.org/Voice%20PDFs/VoiceAug02.pdf
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The names of the 221 Ph.D. level scientists that signed the letter are listed below: Dr. E.O. Wilson, Ph.D. University of the Pacific, Tulane University, Department of Biological Museum of Natural Harvard University, Sciences, Professor History, Director and Department of Biology, Emeritus Curator of Fishes Professor ------Dr. William D. Anderson, Dr. Fakhri Bazzaz, Ph.D. Dr. Anne Ehrlich, Ph.D. Jr., Ph.D. Harvard University, Stanford University, Grice Marine Biological Department of Biology, Department of Biological Laboratory Mallinckrodt Professor of Sciences, Sr. Research Biology Associate, Center for ------Conservation Biology Dr. Robert Angus, Ph.D. Dr. Donald L. Beaver, ------University of Alabama- Ph.D. Dr. Peter Raven, Ph.D. Birmingham, Department of Biology, Professor Michigan State University, Missouri Botanical Department of Garden, Director, 2000 ------Zoology/The Michigan National Medal of Science Dr. Jonathan W. State University Museum, winner Armbruster, Ph.D. Professor Emeritus ------Auburn University, ------Dr. David R. Foster, Ph.D. Department of Biology, Dr. David L. Bechler, Assistant Professor of Harvard University, Ph.D. Biology, Curator of Fishes Director Harvard Forest Valdosta State University, ------Department of Biology, Dr. David R. Atkinson, Dr. Kenneth P. Able, Ph.D. Department Head Ph.D. University at Albany, ------Cornell University, SUNY Department of Dr. Chris Benkman, Ph.D. Professor of Ecology & Biological Sciences, Evolutionary Biology New Mexico State Professor University, Department of ------Biology, Associate Michelle A. Baker, Ph.D. Dr. Kraig Adler, Ph.D. Professor Utah State University, Cornell University, Vice ------Department of Biology, Provost for Life Sciences, Dr. Brad Bergstrom, Ph.D. Assistant Professor Professor of Biology Valdosta State University, ------Department of Biology, Dr. Henry L. Bart, Jr., Dr. Steven C. Anderson, Professor Ph.D Ph.D. ------
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Dr. Tim M. Berra, Ph.D. Alaska Pacific University, Appalachian Ecological Department of Consultants, Botanist Ohio State University, Environmental Science, Evolution, Ecology & ------Associate Professor Organismal Biology, Dr. Todd Campbell, Ph.D. Professor Emeritus ------University of Tennessee, ------Dr. David M. Bryant , Ph.D. Department of Ecology Dr. Benjamin Blount, and Evolutionary Biology, Ph.D. Harvard University, Post-Doctoral Research Department of Earth and University of Georgia, Associate The Institute for Planetary Science, Department of Biological Invasions Member, Zi Sigma Pi, the Anthropology, Professor Honorary Fraternity of ------Foresters Kai Chan, Ph.D. Dr. Dee Boersma, Ph.D. ------Princeton University, University of Washington, Dr. Deborah Buitron, Department of Ecology Department of Zoology, Ph.D. and Evolutionary Biology Professor North Dakota State ------University, Department of Dr. Jiquan Chen, Ph.D. Dr. Eric Bolen, Ph.D. Biological Sciences, Adjunct Professor Michigan Tech University, University of North School of Forestry and Carolina- Wilmington, Dr. Rabel J. Burdge, Ph.D. Wood Products, Associate Department of Biology, Western Washington Professor, Landscape Professor of Wildlife University, Department of Ecology & Ecosystem Ecology Sociology, and Science ------Environmental Studies, ------Professor Emeritus, Dr. Herb Boschung, Ph.D. Dr. Joel E. Cohen, Ph.D. ------University of Alabama- Rockefeller University, Tuscaloosa, Department of Dr. Nancy M. Butler, Ph.D. Professor of Populations Biological Sciences, Gustavus Adolphus ------Professor Emeritus College, Department of Cormac Collier, Ph.D. ------Biology, Assistant Professor Cape Cod National Dr. Richard Bradley, Ph.D. ------Seashore, Biological Ohio State University, Technician Dr. William Calder, Ph.D. Department of Evolution, ------Ecology, and Organismal University of Arizona, Biology, Professor Professor of Ecology and Dr. Jeff Connor, Ph.D. ------Evolutionary Biology Michigan State University, ------Department of Botany and Dr. Greg Brown, Ph.D. Plant Pathology, Associate Kevin Caldwell, Ph.D Professor, Kellogg
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Biological Station, Southeastern Louisiana University of California- Associate Editor Evolution University, Department of Davis, Biology, Associate ------Department of Professor Anthropology Carol Conway, Ph.D. ------University of California- Dr. Thomas W. Culliney, Davis, Department of Dr. Calvin B. DeWitt, Ph.D. Ecology Ph.D. Hawaii Department of ------University of Wisconsin- Agriculture, population Madison Professor of Dr. Joseph Cook, Ph.D. ecologist Environmental Studies University of Alaska, ------Director, Au Sable Institute Curator of Mammals and of Environmental Studies Dr. Gretchen C. Daily, Professor of Biology Ph.D. ------Stanford University, Dr. Janis L. Dickinson, Dr. Jeffery D. Corbin, Department of Biological Ph.D. Ph.D. Sciences, Bing University of California- University of California- Interdisciplinary Research Berkeley Museum of Berkeley, Department of Scientist, Editor, Nature's Vertebrate Zoology, Integrative Biology, Post- Services: Societal Assistant Research Doctoral Fellow/ Lecturer Dependence on Natural Zoologist Hastings Natural Ecosystems ------History Reservation ------Dr. Richard G. Coss, Ph.D. ------Dr. James Danoff-Burg, Dr. C. Kenneth Dodd, Jr., University of California- Ph.D. Davis, Graduate Groups in Ph.D. Psychology, Ecology, and Columbia University, University of Florida Animal Behavior Professor Center for Environmental Department of Wildlife Research and ------Ecology and Conservation, Conservation, Associate Courtesy Associate Dr. Tom Cottrell, Ph.D. Research Scientist Professor, President, The Central Washington ------Herpetologists' League University, Department of Dr. Margaret B. Davis, ------Biology, Plant Ecologist Ph.D. Dr. David Edds, Ph.D. ------University of Minnesota, Emporia State University, Dr. Tom Cottrell, Ph.D. Department of Ecology, Department of Biological Evolution and Behavior, Sciences, Professor Central Washington Regents Professor of University, Department of Ecology, retired ------Biology, Plant Ecologist ------Dr. Joan Edwards, Ph.D. ------Dr. Larry Dew, Ph.D. Williams University, Dr. Brian I. Crother, Ph.D. Department of Biology, Professor of Biology
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------Iowa State University, Dr. Douglas S. Glazier, Department of Physiology, Ph.D. Dr. Timothy J. Ehlinger, Professor of Ph.D Juniata College, Environmental Physiology Department of Biology, University of Wisconsin------Professor of Biology Milwaukee, Department of Biological Sciences, Dr. Johannes Foufopoulos, ------Assistant Professor Ph.D. Dr. Robert H. Gray , Ph.D. ------Princeton University, Umatilla Chemical Agent Department of Ecology Dr. Paul Ehrlich, Ph.D. Disposal Facility, Principal and Evolutionary Biology, Investigator Stanford University, Visiting Assistant Department of Biological Professor ------Sciences, Professor of ------Dr. Jay Greenberg, Ph.D. Biological Sciences Dr. ElizaBeth A. Fox, University of Rochester ------Ph.D. Medical Center, Dr. W. Hardy Eshbaugh, Department of Princeton University, Ph.D. Biochemistry and Department of Ecology Biophysics Miami University, and Evolutionary Biology, Department of Botany, Lecturer ------Professor Emeritus ------Dr. Correigh Greene, Ph.D. ------Patricia Gensel, Ph.D. University of California- Dr. William J. Etges, Ph.D. Davis, Section of University of North Evolution and Ecology University of Arkansas, Carolina, Professor of Department of Biological Biology, President ------Sciences Botanical Society of Dr. Ed Grumbine, Ph.D. America ------University of California- Dr. Joseph E. Faber, Ph.D. ------Santa Cruz, Extension Sierra Institute West Virginia University- Dr. Cameron Ghalambor, Parkersburg, Division of Ph.D. ------Natural Sciences, Assistant University of California- Dr. David G. Hankin, Professor Riverside, Department of Ph.D. Biology ------Humboldt State University, Elizabeth Fensin, Ph.D. ------Telonicher Marine Lab Professor of Fisheries N.C. Division of Water Dr. Barrie K. Gilbert, Biology Quality, Environmental Ph.D. Biologist Utah State University, ------Department of Fisheries Dr. Robert B. Hastings, and Wildlife-- Ecology Ph.D. Dr. G. Edgar Folk, Ph.D. Center, Senior Scientist ------
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Southeastern Louisiana ------Dr. Dan Janzen, Ph.D University, Department of Dr. Mark Hixon, Ph.D. University of Biology, Professor of Pennsylvania, Biological Sciences Oregon State University, Department of Zoology Professor ------Dr. Dean A. Hendrickson, Ph.D Dr. Karen Holl, Ph.D. Dr. Robert L. Jeanne, Ph.D. University of Texas- University of California- Austin, Texas Natural Santa Cruz, Department of University of Wisconsin- History Collections, Texas Environmental Studies Madison, Department of Entomology, Professor of Museum of Science and ------History, Curator of Entomology and Zoology Dr. Robert W Howarth, Ichthyology ------Ph.D. ------Dr. Paul A. Johnsgard, Environmental Defense Dr. Andrew Hendry , Ph.D. Ph.D. Oceans Program, Senior University of Nebraska- University of Scientist and Program Lincoln, Department of Massachusetts- Amherst, Manager Organismic and Biological Sciences, Evolutionary Biology ------Foundation Professor of Program Dr. Bruce Hungate, Ph.D. Biological Sciences ------Northern Arizona ------Dr. James D. Hengeveld, University, Department of Dr. Erik S. Jules, Ph.D. Biological Sciences, Ph.D. Humboldt State University, Assistant Professor Indiana University, Department of Biological Department of Biology, ------Sciences, Assistant Assistant Professor & Lab Dr. Alan Hutchcroft, Ph.D. Professor Coordinator Rockford College, Bartels ------Professor of Chemistry Dr. James R. Karr, Ph.D. Dr. Frank H. Heppner, ------University of Washington, Ph.D. Dr. David W. Inouye, Department of University of Rhode Ph.D. Environmental Health, Island, Department of Professor of Aquatic Biological Sciences, University of Maryland, Sciences and Zoology, Professor of biological Professor & Director, Adjunct Professor of Civil sciences Graduate Program in Engineering Sustainable Development ------and Conservation Biology ------Dr. David M. Hillis, Ph.D. ------Dr. Sylvan R. Kaufman, Ph.D. University of Texas- Dr. Charles Jackson, Ph.D. Austin, Director, School of Biological Sciences ------
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Harvard University, Society for Integrative and ------Biological Labs, Comparative Biology Dr. Robert O. Lawton, Postdoctoral Fellow ------Ph.D. ------Dr. Arthur H. Kopelman, University of Alabama- Dr. Sterling Keeley, Ph.D. Ph.D. Huntsville, Department of Biological Sciences University of Hawaii- State University of New Manoa, Department of York, Department of Estella Leopold, Ph.D. Botany, Professor and Science and Mathematics, University of Washington, Chair Professor of Science, Department of Botany, President Coastal Research ------Professor and Education Society of Dr. Melody J. Kemp, Ph.D. Long Island ------University of Notre Dame, ------Dr. John J. Lepri, Ph.D. Department of Biological Dr. Don Kroodsma, Ph.D. University of North Sciences, Postdoctoral Carolina, Department of Research Associate University of Biology, Associate Massachusetts, Department ------Professor of Biology of Biology, Professor Dr. Keith T. Killingbeck, ------Ph.D. Dr. Malcolm P. Levin, Dr. Kenneth Krysko, Ph.D. Univeristy of Rhode Ph.D. Island, Department of University of Florida, University of Illinois at Biological Sciences Florida Museum of Natural Springfield, Department of History, Collections ------Environmental Studies, Manager, Division of Department Chair Dr. David R. Klein, Ph.D. Herpetology ------University of Alaska------Fairbanks, Institute of Dr. John Lichter, Ph.D. Bernard Kuhajda, Ph.D. Arctic Biology, Professor Bowdoin College, Biology Emeritus University of Alabama- Department and Tuscaloosa, Department of ------Environmental Studies Biological Sciences Program, Assistant Dr. Walter Koenig, Ph.D ------Professor University of California- Stephen P. Kunz , Ph.D. ------Berkeley, Museum of Vertebrate Zoology Certified Senior Dr. William Z. Lidicker, Ecologist,Certified Ph.D. ------Wetland Scientist University of California, Dr. Alan Kohn, Ph.D. ------Berkeley, Professor of University of Washington, Integrative Biology, Dr. Doug LaFollette, Ph.D. Department of Zoology, Emeritus Professor Emeritus, Wisconsin Secretary of ------Formerly President of State
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Dr. David R. Lighthall, University of San Diego, Dr. Bruce Means, Ph.D. Ph.D. Assistant Professor of Florida State University, Biology California Institute for Department of Biological Rural Studies, Executive ------Sciences, Adjunct Professor of Biological Director Dr. James B. McGraw, Science, Executive ------Ph.D. Director Coastal Plains Dr. John T. Lill, Ph.D. West Virginia University, Institute Department of Biology, University of Missouri------Eberly Professor of St.Louis Biology & Aldo Leopold Dr. Robert J. Meese, Ph.D. ------Leadership Program University of California, Dr. Randy Linder, Ph.D. Fellow Department of University of Texas------Environmental Science and Policy Austin, School of Biology Don McKenzie, Ph.D. Sciences/Section of ------University of Washington, Integrative Biology College of Forest Dr. Gary K. Meffe, Ph.D. ------Resources, Research University of Florida, Dr. Robin A. Matthews, Ecologist Department of Wildlife Ph.D. ------Ecology and Conservation, Adjunct Professor, Editor, Western Washington Dr. John McLaughlin, Conservation Biology University, Huxley College Ph.D. of Environmental Studies, ------Western Washington Professor, Director, University, Huxley College Dr. DeForest Mellon, Institute for Watershed of Environmental Studies,- Ph.D. Studies Department of University of Virginia, ------Environmental Sciences, Department of Biology, Dr. Thomas P. Maxwell, Assistant Professor Professor of Biology Ph.D. ------University of Maryland, Dr. David McNeely, Ph.D Dr. John Miles, Ph.D. Institute for Ecological Langston University, Economics, Professor Western Washington Department of Biology, University, Huxley College ------Professor of Environmental Studies, Dr. Audrey Mayer, Ph.D. ------Professor, Director Center for Geography and University of Cincinnati, Dr. Geoff Meaden, Ph.D. Department of Biological Environmental Social Canterbury Christ Church Sciences Sciences University College, ------Department of Dr. Terrence P. McGlynn, GeographyMarine Dr. Arlee M. Montalvo, Ph.D. Fisheries GIS Unit Ph.D. ------
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University of California- Ecology, Professor Biological Sciences, Riverside, Department of Emeritus Professor Botany and Plant Sciences, ------Asst. Res. Plant Population Biologist & Lecturer Dr. Steven Mullin, Ph.D. Dr. Philip Nyhus, Ph.D. ------Eastern Illinois University, Franklin & Marshall Department of Biological College, Department of Dr. Harold Mooney , Ph.D. Sciences, Professor Geosciences, Assistant Professor Stanford University, ------Department of Biological ------Sciences, Paul S. Achilles Dave Neely, Ph.D. Dr. Dennis Ojima, Ph.D. Professor of University of Alabama, Environmental Biology Biodiversity and Natural Resource Ecology ------Systematics Laboratory, Colorado State University, Senior ------Dr. Cliff Morden, Ph.D. Research Scientist, Aldo University of Hawaii- Dr. Richard Niesenbaum, Leopold Leadership Manoa, Department of Ph.D. Fellow Botany, ProfessorCenter Muhlenberg College, ------for Conservation Research Department of Dr. Gordon H. Orians, and Training BiologyAssociate Ph.D. ------Professor of Biology, Donald and Anne Shire University of Washington, Dr. Timothy C. Morton, Distinguished Teaching Professor Emeritus of Ph.D. Professor Zoology University of Chicago, ------Department of Biology, visiting Assistant Dr. Elliott A. Norse, Ph.D. Dr. Michael Ort, Ph.D. Professor, Ecological President, Marine University of Northern Society of America Conservation Biology Arizona, Department of ------Institute, Author: Ancient Geology, Associate Forests of the Pacific ProfessorCenter for Dr. Peter B. Moyle, Ph.D. Northwest Environmental Sciences and Education University of California------Davis, Department of ------Wildlife, Fish, and Dr. M. Philip Nott, Ph.D. Dr. Richard S. Ostfeld, Conservation Biology, The Institute for Bird Ph.D. Professor of Fish Biology Populations Institute of Ecosystem ------Studies Dr. Helmut C. Mueller, Dr. Gary Nuechterlein, ------Ph.D. Ph.D. Dr. Ken Parejko, Ph.D. University of North North Dakota State Carolina, Department of University, Department of Biology & Curriculum in
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University of Wisconsin, University of Idaho- University of Wisconsin- Department of Biology, Moscow, Department of Madison, Department of Associate Professor Fish and Wildlife Botany ------Dr. Dennis Paulson, Ph.D. Dr. Stuart Reichler, Ph.D. Dr. Barry Rosenbaum, Ph.D. University of Puget Sound, University of Texas- Slater Museum of Natural Austin, School of Biology University of Colorado, History, Director Sciences Research Associate, Institute of Arctic and ------Alpine Research Dr. Ann Phillippi, Ph.D. Dr. Janita Rice, Ph.D. ------California State University Dr. Scott D. Russell, Ph.D. Dr. Stuart Pimm, Ph.D. ------University of Oklahoma, Columbia University, Dr. Carol Riley, Ph.D. George Lynn Cross Center for Environmental ------Research Professor of Research and Botany, Director, Samuel Conservation, Professor of Dr. Caroljane B. Roberts Noble Electron Conservation Biology Robertson, Ph.D. Microscopy Laboratory ------Dr. Mary V. Price, Ph.D. Dr. George Robinson, Dr. John M. Rybczyk, Ph.D. University of California- Ph.D. Riverside, Department of State University of New Western Washington Biology, Professor of York at Albany, University, Huxley College Biology Department of Biological of Environmental Studies, Sciences, Associate Assistant Professor ------Professor ------Dr. Mark Pyron, Ph.D. ------Dr. Karin Sable, Ph.D. Ball State University, Joe Rocchio, Ph.D. Department of Biology, University of Puget Sound, Assistant Professor Colorado Natural Heritage Department of Economics Program, Wetland ------Ecologist ------Dr. Peter A. Quinby , Ph.D. ------Dr. Edward Saiff, Ph.D. Paul Smith's College, Dr. Charles Romesburg, Ramapo College of New Natural Resources, Science Ph.D. Jersey, Department of and Liberal Arts, Assistant Biology, Professor of Dean and Associate Utah State University, Biology, Fellow, American Professor Department of Forest Association for the Resources, Professor ------Advancement of Science ------Dr. John T. Ratti, Ph.D. ------Dr. Thomas Rooney, Ph.D.
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Dr. Alan H. Savitzky, University of Denver, Environmental Systems, Ph.D. Department of Biology, Assistant Professor Professor Old Dominion University, ------Associate Professor of ------Dr. John Soluri, Ph.D. Biological Sciences Dr. Fraser Shilling, Ph.D. Carnegie Mellon Dr. John O. Sawyer, Ph.D. University of California- University, Department of Humboldt State University, Davis, Section of History, Assistant Emeritus Professor of Microbial and Cellular Professor of History and Botany Biology, Chair Committee Policy on Conservation, Society ------for Integrative Dr. William H. andComparative Biology Dr. Stefan Sommer, Ph.D. Schlesinger, Ph.D. ------Idaho State University, Duke University, Dean, Erin A. Shope, Ph.D. Department of Biological Nicholas School of the Sciences, Research Environment and Earth Brevard University, Assistant, Professor, Sciences, James B. Duke Environmental Educator Director Natural Heritage Professor of ------Center Biogeochemistry Dr. Clifford Slayman, ------Ph.D. Dr. Lisa G. Sorenson, Dr. Stephen H. Schneider, Yale School of Medicine Ph.D. Ph.D Cellular and Molecular Union of Concerned Stanford University, Physiology, Professor of Scientists, Global Department of Biological Physiology Environment Program, Sciences ------Adjunct Research Assistant Professor- Biology ------Dr. Christoper C. Smith, Department, Dr. Peter Schulze, Ph.D. Ph.D. BostonUniversity Austin College, Associate Kansas State University, ------Professor of Biology, Division of Biology Dr. Michael Soule, Ph.D. Director, Center for ------Environmental Studies Wildlands Project Dr. Bradley F. Smith, ------Ph.D. ------Burton Shank, Ph.D. Western Washington Dr. Larry T. Spencer, Ph.D. Florida Fish and Wildlife University, Huxley College Plymouth State College, Conservation, of Environmental Studies, Professor of Biology AssociationResearch Dean ------Biologist ------Dr. Timothy P. Spira, Ph.D. ------Dr. Youngsinn Sohn, Ph.D. Dr. Sharron K. Sherrod, Clemson University, University of Maryland- Department of Biological Ph.D. Baltimore, Geography &
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Sciences, Associate Biological Sciences, Dr. Harry M. Tiebout, Professor Associate Professor Ph.D. ------West Chester University, Department of Biology Dr. Alan Springer, Ph.D. Dr. Boyd R. Strain, Ph.D. ------University of Alaska- Duke University, Fairbanks, Institute of Department of Biological Dr. Gordon Ultsch, Ph.D. Marine Science, Professor Sciences, Professor University of Alabama- Emeritus ------Tuscaloosa, Department of ------Biological Sciences Dr. Robert D. Stevenson, Ph.D. Dr. Michael C. Swift, ------Ph.D. University of Dr. Loraine Utter Kohorn, Massachusetts- Boston, St. Olaf College, Ph.D. Department of Biology, Department of Biology, Duke University, Associate Professor of Department of Biology- Department of Biology University of Virginia, Biology/Nicholas School sabbatical ------of the Environment, ------Visiting Assistant Dr. Glen R. Stewart, Ph.D. Professor Dr. Douglas W. Tallamy, California State Ph.D. ------Polytechnic University- Pomona, Department of University of Delaware, Dr. Daniel M Vernon, Biological Sciences, Department of Entomology Ph.D. Professor of Zoology and Applied Ecology, Whitman University, Professor ------Department of Biology ------Dr. Craig Stockwell, Ph.D. ------Dr. Eric J. Taylor, Ph.D North Dakota State Dr. Richard A. Wahle, University, Department of Fish and Wildlife Biologist Ph.D. Zoology, Assistant ------Bigelow Laboratory for Professor Ocean Sciences, Research Dr. John Terborgh, Ph.D. ------Scientist Duke University, Center ------Dr. Phillip K. Stoddard, for Tropical Conservation, Ph.D. James B Duke Professor Dr. David B. Wake, Ph.D. Florida International ------University of California, University, Department of Professor of Integrative Dr. Andrea S. Thorpe, Biological Sciences Biology, Curator, Museum Ph.D. ------of Vertebrate Zoology University of Montana, ------Dr. Philip C. Stouffer, Division of Biological Ph.D. Sciences Dr. Skip Walker, Ph.D. Southeastern Louisiana ------University, Department of
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University of Alaska- Dr. Nickolas M. Waser, Department of Biology, Fairbanks, Institute of Ph.D. Professor, Director North Carolina Botanical Garden Arctic Biology University of California------Riverside, Department of ------Biology, Professor of Dr. Lawernce R. Walker, Dr. Bill Willers, Ph.D. Biology, President, Rocky Ph.D. Mountain Biological University of Wisconsin- University of Nevada- Las Laboratory Oshkosh, Department of Vegas, Department of Biology, Emeritus ------Biology, Professor of Professor of Biology Biology Dr. Judith S. Weis, Ph.D. ------Rutgers University, Dr. Joe Williams, Ph.D. Dr. Diana H. Wall, Ph.D. Department of Biological Colorado State University, Sciences, Professor of Colorado State University, Department of EPO Biology, Past President College of natural Biology American Institute of Resources, Professor, Biological Sciences ------Director, Natural Resources Ecological ------Dr. Ernest J. Willoughby, Ph.D. Laboratory Dr. John F. Weishampel, ------Ph.D. St. Mary's College of Maryland, Department of Dr. Donald M. Waller, University of Central Biology, Professor of Ph.D. Florida, Department of Biology Biology University of Wisconsin------Madison, Department of ------Botany, Editor, Evolution Dr. Michael Windelspecht, Dr. Gregory Welch, Ph.D. Ph.D. ------University of Maine, Appalachian State Dr. David O. Wallin, Ph.D. Professor Darling Marine University, Department of Center Western Washington Biology, Assistant University, Huxley College ------Professor of Biology of Environmental Studies- Dr. Robert G. Wetzel, ------Department of Ph.D. Environmental Sciences, Dr. Marti Witter, Ph.D. Associate Professor University of Alabama------Tuscaloosa, Department of ------Biological Sciences, Dr. Helen Young, Ph.D. Dr. Glen Walsberg, Ph.D. Bishop Professor of Middlebury College, Biology Arizona State University Department of Biology ------Professor Professor of Biology Dr. Peter S. White, Ph.D. ------President, Cooper Ornithological Society University of North Dr. Joy B. Zedler, Ph.D. Carolina- Chapel Hill,
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University of Wisconsin- Madison, Department of Botany and Arboretum, Aldo Leopold Professor of Restoration Ecology ------Dr. Marion Klaus, Ph.D. Sheridan College
239 High Valley Integrated Restoration Project Comment Analysis ------Timber Harvest Opposing View #73 - “Recently, so called "salvage" logging has increased on national forests in response to a timber industry invented "forest health crisis" which points the finger at normal forest processes of fire, fungi, bacteria, insects and other diseases. In fact the crisis in the national forests is habitat destruction caused by too much clearcutting. My long-term studies of forest diseases in Idaho show the loss by disease and insect activity in all age classes of forests to be less than or slightly more than 1 percent per year over the past thirty-eight years. These findings are consistent with Forest Service national level data. Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.” Partridge, Arthur Ph.D., professor emeritus, University of Idaho Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm ------Timber Harvest Opposing View #74 – “In our overview of the impacts of forest management activities on soil erosion and productivity, we show that erosion alone is seldom the cause of greatly reduced site productivity. However, erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term site productivity and may lead to sustained periods of extended erosion that could exacerbate degradation. Managers should be concerned with harvesting impacts, site preparation disturbances, amount of tree that is removed, and the accumulation of fuel from fire suppression. On erosion-sensitive sites, we need to carefully evaluate such management factors.” Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on erosion and soil productivity. Proceedings of the Symposium on Soil Quality and Erosion Interaction, Keystone, CO, July 7, 1996. Ankeney, IA: Soil and Water Conservation Society. 16 p. http://forest.moscowfsl.wsu.edu/cgi-bin/engr/library/searchpub.pl?pub=1999c ------Timber Harvest Opposing View #75 - “Logging often destroys natural habitats, resulting in the loss of biodiversity and sometimes leading to the local, and possibly global, extinction of species. Although estimates of the rates of loss vary, few deny the reality of the current losses of both flora and fauna.177 “
240 High Valley Integrated Restoration Project Comment Analysis According to a joint report by the Worldwide Fund for Nature and the Sarawak Forest Department, "Logging causes immediate forest disturbances, long-term habitat changes (e.g. damage to food trees and salt-licks), increased hunting by timber company workers and availability of logging roads as hunting routes. The destruction of wildlife from habitat loss must be recognised to be on an enormous scale".178 In Central Africa, the opening-up of the forest by logging facilitates the illegal hunting of wildlife, including protected species such as primates, and is leading to a decline in wildlife populations.179 Deterioration in water quality has caused a decline in fish stocks and has affected aquatic biological diversity because indigenous animals and plant life are highly vulnerable to oxygen depletion, suspended particulate matter and a lack of light.180 Even so called selective logging severely affects the complex and rich biodiversity of forests through excessive damage to residual stands, destruction of other plant and tree species and the creaming-off of species which are the most valuable for timber. An FAO study in Malaysia has shown that as much as 50% of the standing forest may be damaged and the surface soil destroyed when up to 30% of the ground surface is exposed. During silvicultural treatment in logging operations in Sarawak, so-called uneconomic forest species are deliberately poisoned. This reduces the complexity and species diversity of the tropical forests to only 10% of the original condition, resulting in the systematic elimination of tree genetic resources and contamination of the environment.181 According to the IUCN the most frequently recorded of all threats to globally endangered tree species is 'felling'.182 “ Forests Monitor, Environmental Impacts of Logging, 2006 (with photos) http://www.forestsmonitor.org/en/reports/550066/550083 ------Timber Harvest Opposing View #76 - Major report findings: 1) If we ended the timber sales program on national forests and redirected the logging subsidies we could provide over $30,000 for each public lands timber worker for retraining or ecological restoration work - - and still have over $800 million left over for taxpayer savings in the first year alone. 2) We don’t need to log national forests for our timber supply, given the fact that the timber cut annually from national forests nationwide now comprises only 3.3% of this nation’s total annual wood consumption, and less than 4% of the sawtimber used for construction. 3) Logging on national forests INCREASES the risk of forest fires more than any other human activity. 4) A bipartisan nationwide poll conducted in 1998 found that 69% of Americans now oppose allowing timber companies to log our national forests. Hansen, Chad, Ph.D., Ending Timber Sales on National Forests: THE FACTS (FY ’97) Published in the Earth Island Journal, 1999 http://www.johnmuirproject.org/pdf/Fy-1997-Economic-Report-Ending-Timber-Sales.pdf ------Timber Harvest Opposing View #77 – “However, I believe that their support for logging represents a failure to challenge many of the flawed assumptions that are guiding federal logging
241 High Valley Integrated Restoration Project Comment Analysis programs and in some cases even repeating many of the same pejorative language helps to undermine in the long term conservation efforts. After all if the public believes our forests are sick and unhealthy; that logging will cure them; that logging will preclude wildfires and eliminate beetle kill, and that rural economies are dependent on public lands logging to survive, than they are, in my view, contributing to the wrong message.” “There may be legitimate rationales for logging, but it’s not the one usually given for logging public forests today. Indeed, the major justifications given for logging public lands is typically some social or ecological benefit—to reduce fires, clean up bug killed trees, fix watersheds, restore forest health or provide for “economic stability” to rural communities. In far too many cases, all of these are just cover to hide the main reason for logging—to maintain the local timber industry at the expense of our forest’s ecological integrity and taxpayer dollars.” WUERTHNER, GEORGE, “Why are Conservation Groups Advocating Logging Public Forests?” Published by Counterpunch, September 27, 2012 http://www.counterpunch.org/2012/09/27/why-are-conservation-groups-advocating-logging- public-forests/ ------Timber Harvest Opposing View #78 – “Because of the current government shutdown, the public is being kept out of all National Parks and many other federal lands. But ironically, oil, mineral, and timber companies are still allowed to drill, mine, and log on federal lands while the shutdown is going on. Officials in the US Department of Interior and Department of Agriculture, which oversee National Park and National Forest lands respectively, have given us an unusually clear glimpse of where their priorities lie. Federal lands are supposed to be managed for the benefit of the American people, and resource extraction shouldn’t be going on while the public is barred from our National Parks. During the shutdown, which was caused because Congress has been unable to pass a budget, almost all “nonessential” federal government services are temporarily unavailable. The fact that the Departments of Interior and Agriculture have apparently found the resources to keep public lands open to drilling and logging, but can’t keep National Parks and other recreational areas open, shows resource extraction in being prioritized over public access to our lands. It’s time for this to change.” “Stop Drilling and Logging on Federal Lands While the Public is Kept Out” A petition targeted for Secretary of the Interior Sally Jewel and Secretary of Agriculture Tom Vilsack Posted at FORCECHANGE.COM, 2013 http://forcechange.com/86223/stop-drilling-and-logging-on-federal-lands-while-the-public-is- kept-out/ ------Timber Harvest Opposing View #79 – “"We tried for the past 18-months to work with Supervisor Bull to implement an effective community fuel reduction project up the East Fork. Our proposal - which was favored by 98% of the 13,000 public comments received on this project would have reduced fuels on 1,600 acres of national forest land, pumped $1 million into the local economy
242 High Valley Integrated Restoration Project Comment Analysis and provided 45 local jobs. Unfortunately, this common sense plan was rejected by Supervisor Bull," stated Koehler.” “ "The attempt by Supervisor Bull to cover-up public knowledge of excessive soil damage in the project area by altering the best-available scientific data and by purging project file documents related to soils is a blatant attempt to white-wash this damaging proposal and cannot go unchallenged," explained Campbell.” “The East Fork project area is still recovering from historic Forest Service mismanagement including clearcutting, terracing and excessive roadbuilding. 33% of the entire analysis area has already been logged. The analysis area averages 5.2 miles of road per square mile, not including jammer roads. These roads contribute 151.2 tons of sediment per year to streams within the project area. The East Fork, running through the middle of the project area, is officially classified as an impaired stream because its excessive sediment load has compromised its ecological integrity. Several watersheds already exceed established thresholds for clearcutting, which threatens stream channel stability with increased runoff.” Conservation Groups Look to Hold Forest Service Accountable for Middle East Fork Logging Plan Published by Lowbagger, April 25, 2006 http://www.lowbagger.org/mideast.html Note: In April of 2009, the Forest Service's Northern Region rewarded Supervisor Bull for his mismanagement of public land with a promotion to the Director of Recreation. ------Timber Harvest Opposing View #80 –“Photosynthesis is one of only two significant mechanisms for removing carbon dioxide from the atmosphere (the other being dissolution into water, leading to destructive ocean acidification). Carbon dioxide is released when trees are cut down, and deforestation accounts for at least 15 percent of global carbon emissions. Thus, cutting down trees is a double-whammy because we not only lose carbon capture capacity, but we release more carbon, too. An erroneous conventional view holds that young trees capture more dioxide than mature trees; therefore, we should cut down mature trees. However, for most species -- 97 percent of 403 tropical and temperate species -- the biggest trees increase their growth rates and sequester more carbon as they age. This conclusion is based on repeated measurements of 673,046 individual trees, some going back more than 80 years, on six continents We need all levels of government to start preserving forests -- and fast. In addition to switching from dirty to clean energy, President Obama should halt commercial logging on federal lands, eliminate biomass power plant subsidies that drive forest destruction, and permanently protect forests for carbon capture (in addition to forests' many other public benefits).” Trees Are Our Climate Saviors - So Stop Logging on Public Land 02/12/2014 The Huffington Post http://www.huffingtonpost.com/ellen-moyer-phd/trees-are-our-climate-logging_b_4775894.html ------
243 High Valley Integrated Restoration Project Comment Analysis Timber Harvest Opposing View #81 –“Logging activities have numerous impacts on aquatic systems in the Sierra Nevada. The end result of logged landscapes is a highly altered forest system which creates significant problems related to erosion, sedimentation and altered stream flow patterns. Logging removes large trees that normally fall into streams and provide shelter and thermal cover, raises water temperatures and pH, and degrades the chemical and ecological conditions and food webs that fish need to survive. Logging and the roads created to facilitate logging also significantly degrade stream ecosystems by introducing high volumes of sediment into streams, changing natural streamflow patterns, and altering stream channel morphology. Areas that have been logged are far more likely to suffer from major landslides and erosion events which deposit abnormally high levels of sediment into area streams. Roads, ditches, and newly created gullies form new, large networks of flow paths across the landscape. These logged areas therefore, sustain much higher discharge volumes after a storm event than they ever did when the forest was intact. The changes in stream habitat caused by this increase in sediment loads greatly affects the health of aquatic organisms. The survival rates of many fish species are known to significantly decrease as fine sediment levels and temperatures in the water increase. The deposition of fine sediment on the stream bed degrades spawning areas, reduces pool refuge habitat, decreases winter refuge areas for juveniles, and impedes feeding visibility. Likewise, sensitive amphibian and invertebrate species are also adversely affected by increased sediment loads, decreasing in abundance and diversity as sediment levels rise. The drastic changes in the health of aquatic species brought on by logging has far reaching impacts for general forest ecology as well. Invertebrates, amphibians, and fish are important prey species for many mammals, birds and bats that are vital to the biological integrity of the forest.” Logging Impacts Published by Sierra Forest Legacy, 2012 http://www.sierraforestlegacy.org/FC_FireForestEcology/FFE_LoggingImpacts.php ------Timber Harvest Opposing View #82 – “Natural resource use and extraction leading to habitat modification can have significant direct and indirect impacts to salmon populations. Land use activities associated with logging, road construction, urban development, mining, agriculture, and recreation have significantly altered fish habitat quantity and quality. Associated impacts of these activities include: alteration of streambanks and channel morphology; alteration of ambient stream water temperatures; degradation of water quality; reduction in available food supply; elimination of spawning and rearing Figure 1. Forestry Photo: NOAA habitat; fragmentation of available habitats; elimination of downstream recruitment of spawning gravels and large woody debris; removal of riparian vegetation resulting in increased stream bank erosion; and increased sedimentation input into spawning and rearing areas resulting in the loss of channel complexity, pool habitat, suitable gravel substrate, and large woody debris. Studies indicate that in most western states, about 80 to 90 percent of the historic riparian habitat has been eliminated. Further, it has been estimated that during the last 200 years, the lower 48 United States have lost approximately 53 percent of all wetlands. Washington and
244 High Valley Integrated Restoration Project Comment Analysis Oregon's wetlands have been estimated to have been diminished by one third, while it is estimated that California has experienced a 91 percent loss of its wetland habitat. Pacific Salmonids: Major Threats and Impacts Published by NOAA fisheries Office of Protecte Resources, May 15, 2014 http://www.nmfs.noaa.gov/pr/species/fish/salmon.htm ------Timber Harvest Opposing View #83 – “It is impossible to overstate the importance of humankind's clearing of the forests. The transformation of forested lands by human actions represents one of the great forces in global environmental change and one of the great drivers of biodiversity loss. The impact of people has been and continues to be profound. Forests are cleared, degraded and fragmented by timber harvest, conversion to agriculture, road-building, human-caused fire, and in myriad other ways. The effort to use and subdue the forest has been a constant theme in the transformation of the earth, in many societies, in many lands, and at most times. Deforestation has important implications for life on this planet. Just think, originally, almost half of the United States, three-quarters of Canada, almost all of Europe, the plains of the Levant, and much of the rest of the world were forested. The forests have been mostly removed for fuel, building materials and to clear land for farming. The clearing of the forests has been one of the most historic and prodigious feats of humanity.” “Since 1600, 90% of the virgin forests that once covered much of the lower 48 states have been cleared away. Most of the remaining old-growth forests in the lower 48 states and Alaska are on public lands. In the Pacific Northwest about 80% of this forestland is slated for logging.” Global Deforestation Published by the University of Michigan, 01/04/2010 http://www.globalchange.umich.edu/globalchange2/current/lectures/deforest/deforest.html ------Timber Harvest Opposing View #84 –“The Forest Service’s proposed Spotted Bear logging project would jeopardize the area’s wildife, which are already teetering on the edge of survival. The project would use helicopters, ground-based equipment, and skylines to remove approximately 11 million board foot of timber across 1,853 acres of pristine wildlife habitat adjacent to the Great Bear and Bob Marshall Wilderness areas. An additional 1,347 acres would be burned. Most of the units slated to be logged are mature, 75-140 year old stands of Doug-fir, western larch, spruce, and lodgepole pine that have never been logged (this area burned in the late 1800s and early 1900s). The project would require 2,200 log truckloads traveling back and forth on a narrow dirt road over 55 miles from the nearest town. To access the remote area, the Forest Service is proposing to open 9.7 miles of roads that were closed to provide security for elk and grizzly bears and build 6.6 miles of new “temporary” roads that will be used over the next 6 years. The Forest Service also proposes to increase motorized access to the project area by extending the season of use by an additional five weeks. Motorized users will now be allowed to access the area in early June causing added trauma to the grizzlies who will have just recently emerged from their dens and will be nutrionally stressed.
245 High Valley Integrated Restoration Project Comment Analysis “The Spotted Bear area is a critical wildlife connector”, said Keith Hammer, Chair of Swan View Coalition. “Calving elk and nutritionally stressed bears need more springtime and early summer security, not more motor vehicle traffic.” “ Groups Challenge Industrial Logging of Pristine Wildlife Habitat Along South Fork Flathead River A Western Environmental Law Center Press Release, 2/28/2012 http://www.westernlaw.org/article/groups-challenge-industrial-logging-pristine-wildlife-habitat- along-south-fork-flathead-rive ------Timber Harvest Opposing View #85 –“Four conservation groups — Alliance for the Wild Rockies, Swan View Coalition, Friends of the Wild Swan and Native Ecosystems Council — sued to halt the sale in June 2013. The groups claimed the project would harm grizzly bear, lynx, wolverine and other species and plants while damaging the forest’s remaining old growth.” “The project area is within the designated “grizzly recovery zone” of the Northern Continental Divide Ecosystem. It is also considered critical habitat for other species listed under the ESA, including bull trout.” “The Forest Service published its Environmental Assessment in August 2012 and concluded that the Glacier-Loon Timber Sale would have no effect on grizzly bears, Canada lynx, bull trout, bull trout critical habitat and water howellia, a threatened plant species under the ESA.” “The judge ordered the project be stopped and said these Forest Service lands have to be managed under federal environmental laws to protect native species just like all other national forests, Garrity said. “It’s unfortunate that we had to once again take the federal government to court to force them to follow the law,” Garrity said. “We had no other choice if we want to conserve the last remaining habitat for bull trout, grizzly bears, lynx and other old growth dependent wildlife since the Forest Service insists on being serial law breakers.” “ Judge Halts Glacier Loon Timber Sale in Swan Valley Published in the Flathead Beacon, Sep 26, 2014 http://flatheadbeacon.com/2014/09/26/judge-halts-glacier-loon-timber-sale-swan-valley/ ------Timber Harvest Opposing View #86 –“That makes four timber projects since May in which U.S. District Judge Dana Christensen found fault with the U.S. Forest Service and the U.S. Fish and Wildlife Services' conclusion that cutting and burning in those areas would not significantly harm the big cats' territory.” “Christensen ruled the Endangered Species Act requires the agencies to determine whether lynx "may be present" there, which is a lesser standard than what the agencies used in concluding lynx don't "occupy" the area.” “The judge said the government approved those projects based on an unreliable conclusion they would not harm the lynx's critical habitat.” Judge stops 3 Montana logging projects over lynx By Matt Volz, Associated Press June 26, 2013
246 High Valley Integrated Restoration Project Comment Analysis http://news.yahoo.com/judge-stops-3-montana-logging-141919567.html ------Timber Harvest Opposing View #87 –“A federal judge has blocked logging proposed for the Klamath National Forest in Siskiyou County, chiding the U.S. Forest Service for its review of the environmental damage that would result.” “The service should have done a full environmental review and done a better job projecting the impact on wildlife and forest conditions, ruled U.S. District Judge Frank C. Damrell Jr.” Judge blocks Klamath logging plan By Don Thompson,Associated Press October 16, 2004 http://www.wildcalifornia.org/media/epic-in-the-news/judge-blocks-klamath-logging-plan/ ------Timber Harvest Opposing View #88 –“The fact is, commercial logging doesn't prevent catastrophic fires; it causes them. In the latter part of the 19th century, this was common knowledge. Relentless clearing of forests in the Great Lakes region left huge areas largely devoid of the cooling shade of trees, replacing moist natural forest microclimates with the hotter, drier conditions characterized by stump fields. Flammable logging "slash debris" covered the landscape.” It was in this setting that a massive, cataclysmic fire started near Peshtigo, Wisconsin in 1871. More than 1,200 people were killed. Similar blazes erupted in subsequent years.” One of the primary reasons that the national forest system was established in 1891 was to prevent the destructive fires caused by logging. It was not until 1897 that, under industry pressure, our national forests were first opened up to timber sales by an appropriations rider. The first timber sale was offered in 1899--100 years ago. “Like the timber industry, the Forest Service also recognized an emerging public relations dilemma several years ago. It knew that it would no longer be able to justify its timber sales program on economic grounds. Instead of dropping the program, it simply gave it a sexy new name--"Forest Stewardship." The Forest Stewardship program was born in 1993 and was marketed fraudulently as a series of management activities supposedly conducted primarily for the health of the forests. The USFS attempted to distinguish this new program from its Timber Commodity program, which clearly was concerned with nothing more than commercial resource extraction.” “In April 1999, the US General Accounting Office (GAG) released a report on the Forest Service's approach to fire management that called into serious question the use of the timber sales to address fire issues. The GAO noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value." The report also found that Forest Service managers "tend to (1) focus on areas with high-value commercial timber rather than on areas with high fire hazards or (2) include more large, commercially valuable trees in a timber sale than are necessary to reduce the accumulated fuels." The "low value materials," observed the GAG, "are unattractive to timber purchasers." “
247 High Valley Integrated Restoration Project Comment Analysis Hansen, Chad Ph.D., The Big Lie: Logging and Forest Fires Published by the Earth Island Journal, spring 2000 issue http://yeoldeconsciousnessshoppe.com/art6.html
248 High Valley Integrated Restoration Project Comment Analysis Opposing Views Attachment #3 Best Science shows Commercial Logging to Reduce Fuels is not only Ineffective at Reducing Fire Intensity and Rate of Spread, but sometimes Exacerbates Fire Behavior. Since Fuels Reduction is a Favorite USFS Excuse to Log Public Land its Employees are Taught to Ignore and Deny this Information. Fuels reduction Opposing View #1 - “large, severe wildfires are more weather-dependent than fuel-dependent,” Agee, James K. Ph.D. “The Severe Weather Wildfire-Too Hot to Handle? Northwest Science, Vol. 71, No. 1, 1997 http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf ------Fuels reduction Opposing View #2 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.” Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml ------Fuels reduction Opposing View #3 - “One reason that fuels reduction treatments should be limited is that they may not address the important effects of climate and weather on fire behavior. Some studies suggest that it is drought and warmer temperatures—not fuels accumulations—that are the major explanatory factors for large fires (O’Toole 2002-2003, Pierce et al. 2004). It is an unrealistic goal to return all forests to historical states, in light of the fact that agencies have no control over drought or temperature.” (pgs. 15 – 16) Berry, Alison Ph.D., 2007. “Forest Policy Up in Smoke: Fire Suppression in the United States.” A PERC publication. http://www.law.northwestern.edu/searlecenter/papers/Berry_forest_policy.pdf ------Fuels reduction Opposing View #4 - “Fire intensity was correlated to annual area burned; large area burned years had higher fire intensity predictions than smaller area burned years. The reason for this difference was attributed directly to the weather variable frequency distribution, which was shifted towards more extreme values in years in which large areas burned. During extreme weather conditions, the relative importance of fuels diminishes since all stands achieve the threshold required to permit crown fire development. This is important since most of the area
249 High Valley Integrated Restoration Project Comment Analysis burned in subalpine forests has historically occurred during very extreme weather (i.e., drought coupled to high winds). The fire behavior relationships predicted in the models support the concept that forest fire behavior is determined primarily by weather variation among years rather than fuel variation associated with stand age.” Bessie, W. C. Ph.D. and E. A. Johnson Ph.D. “The Relative Importance of Fuels and Weather on Fire Behavior in Subalpine Forests” Ecology, Vol. 76, No. 3 (Apr., 1995) pp. 747-762. Published by: Ecological Society of America http://www.jstor.org/pss/1939341 ------Fuels reduction Opposing View #5 - “Climatic conditions drive all big fires— not fuels. All substantial fires occur only if there is extended drought, low humidity, high temperatures and, most importantly, high winds. When conditions are "ripe" for a large blaze, fires will burn through all kinds of fuel loads. For this reason, most fires go out without burning more than a few acres; approximately 1 percent of all fires are responsible for about 95 percent to 99 percent of the acreage burned.” “Under severe conditions, fires burn through all kinds of fuel loads including thinned/logged forests. Contrary to what the U.S. Forest Service has stated about the Ojo Peak Fire, local witnesses have said the fire blew right through the hotter, drier thinned forests where the cooling effect of forest canopy had been removed.” Bird, Bryan “Fires Normal Part of Ecology - Fear of fires ungrounded” Mountain View Telegraph, December 20, 2007 http://www.wildearthguardians.org/library/paper.asp?nMode=1&nLibraryID=567 ------Fuels reduction Opposing View #6 - “The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.” “Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm ------Fuels reduction Opposing View #7 - “As someone with first-hand experience in fire hazard reduction and first-hand knowledge of the forest management field, as well as someone with lifelong roots in the Durango community, I am abhorred by the destruction, nearly amounting to clear cutting, that is taking place around our community under the guise of “fire hazard reduction.” “ Coe, Nathan J. “Forestry shouldn’t be an ‘industry’ “
250 High Valley Integrated Restoration Project Comment Analysis Durango Herald, February 12, 2011 http://www.durangoherald.com/article/20110213/OPINION03/702139987/Forestry- shouldn%E2%80%99t-be-an-%E2%80%98industry%E2%80%99 ------Fuels reduction Opposing View #8 - “First, most large fires are climatic/weather driven events, not fuels driven. Extended drought, high winds, high temperatures and low humidity enable fires to burn through all fuel loadings. Many of the large Western fires in recent years were in forests that had been previously logged and/or thinned, with little apparent effect on fire spread or severity.” Forest Policy Research paper 2008 “Montana: Blackfoot Clearwater Stewardship Proposal is all about selling out to Pyramid lumber” http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwater-stewardship-proposal-is- all-selling-out-to-pyramid-lumber/ ------Fuels reduction Opposing View #9 - “most large fires are climatic/weather driven events, not fuels driven. Extended drought, high winds, high temperatures and low humidity enable fires to burn through all fuel loadings.” Forest Policy Research paper 2008 “California: Too often thinning treatments tend to increase fire hazards” http://forestpolicyresearch.org/2008/12/19/california-too-often-thinning-treatments-tend-to- increase-fire-hazards/ ------Fuels reduction Opposing View #10 - “The primary driver of fire is not beetle kill. It’s climate,” said Barry Noon, a wildlife ecology professor at Colorado State University and an author of the report. “It’s drought and temperature.” “The report was authored by Noon; Clark University professor Dominik Kulakowski ; Scott Black, executive director of the Xerces Center for Invertebrate Conservation and Dominick DellaSala, president and chief scientist for the National Center for Conservation Science and Policy.” Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/ ------Fuels reduction Opposing View #11 - “ “Extensive areas of dead trees have understandably led to widespread concern about the increased risk for forest fires,” said Dominik Kulakowski, one of the report’s authors and a professor of geography and biology at Clark University in Worcester, Mass. “This is a logical concern, but the best available science indicates that the occurrence of large fires in lodgepole pine and spruce-fir forests is mainly influenced by climatic conditions, particularly drought.” “
251 High Valley Integrated Restoration Project Comment Analysis Gable, Eryn “Battling beetles may not reduce fire risks – report” The Xerces Society Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/ ------Fuels reduction Opposing View #12 - “Reducing burnable biomass, however, does not eliminate wildfires, because fuel reduction does not directly alter the dryness of the biomass or the probability of an ignition.” Gorte, Ross W. Ph.D. “Wildfire Damages to Homes and Resources: Understanding Causes and Reducing Losses” A CRS report for Congress, June 2, 2008 http://www.nationalaglawcenter.org/assets/crs/RL34517.pdf ------Fuels reduction Opposing View #13 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value." "Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards." Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf ------Fuels reduction Opposing View #14 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “ “As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high- value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).” “The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’
252 High Valley Integrated Restoration Project Comment Analysis The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.” “After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire- resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.” Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://www.commondreams.org/views/051900-101.htm ------Fuels reduction Opposing View #15 - “Emerging science demonstrates that the real culprit for creating more wildfires — including southern California's blazes — is not "fuels" but climate and weather. Climate change simply means we must learn to live with more wildfires. Humankind can be pretty smart (we made it to the Moon), but we can also be pretty stupid (we're destroying the lungs of the planet for profit). One thing, however, is certain: Mother Nature knows best. So let's be responsible and stop logging the publicly owned forests, let them recover and let God and nature back in.” Hermach, Tim. “The Skinny on Thinning, Should we save the forest from itself?” Published by the Eugene Weekly Viewpoint, 11/1/07 http://www.forestcouncil.org/tims_picks/view.php?id=1211 ------Fuels reduction Opposing View #16 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9) “As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.” Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest 253 High Valley Integrated Restoration Project Comment Analysis landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessio nid=C8DDB611DB29D3716BBF313AADBA2E70?sequence=1 ------Fuels reduction Opposing View #17 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.” “How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.” Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm ------Fuels reduction Opposing View #18 - "Problems exist with over-generalizing the effects of fire exclusion, and misapplying data derived from short-interval forest ecosystems (e.g. ponderosa pine stands) to long-interval forest ecosystems that have not missed their fire cycles yet and are still within their historic range of variability for stand-replacing fire events (e.g. high elevation lodgepole pine or fir stands)." Ingalsbee, Timothy Ph.D. 2000. “Money to Burn: The Economics of Fire and Fuels Management, Part One: Fire Suppression. “An American Lands Alliance publication. www.fire-ecology.org/research/money_to_burn.html ------Fuels reduction Opposing View #19 - “Congress should prohibit the use of commercial timber sales and stewardship contracts for hazardous fuels reduction projects. Commercial logging removes the most ecologically valuable, most fire- resistant trees, while leaving behind highly flammable small trees, brush, and logging debris. The use of "goods for services" stewardship contracts also encourages logging larger, more fire-resistant trees in order to make such projects attractive to timber purchasers. The results of such logging are to increase fire risks and fuel hazards, not to reduce them. The financial incentives for abusive logging under the guise of "thinning" must be eliminated.” Ingalsbee, Timothy Ph.D., “National Fire Plan Implementation:
254 High Valley Integrated Restoration Project Comment Analysis Forest Service Failing to Protect Forests and Communities” American Lands Alliance, March 2002 http://www.fire-ecology.org/policy/ALA_fire_policy_2002.html ------Fuels reduction Opposing View #20 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5) Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://fireecology.org/research/wildfire_paradox.pdf ------Fuels reduction Opposing View #21 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards." "Decades of encouraging private logging companies to take the biggest, oldest, most fire- resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands." "In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks." Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html ------Fuels reduction Opposing View #22 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire- resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.”
255 High Valley Integrated Restoration Project Comment Analysis “Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.” Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm ------Fuels reduction Opposing View #23 - “For example, use of taxpayer dollars and resources on deficit timber sales that remove fire-resilient old-growth trees and leave behind untreated logging slash, violate federal environmental laws in planning or implementation, or are deceptively labeled as “fuels reduction” or “forest restoration” projects when they actually increase fuel hazards or degrade ecological integrity, is an ethical as well as an ecological issue. These kind of anti-ecological, unethical forest management projects also adversely affect firefighter and community safety by diverting limited federal dollars away from genuine hazardous fuels reduction activities, and by degrading ecological conditions in ways that increase wildfire rate of spread, intensity, or severity.” Ingalsbee, Timothy Ph.D. and Joseph Fox, Ph.D. “Firefighters United for Safety, Ethics, and Ecology (FUSEE): Torchbearers for a New Fire Management Paradigm” A poster presentation at the Third International Fire Ecology and Management Congress, Association for Fire Ecology November 13-17, 2006 http://fusee.org/docs/AFE_FUSEE_display_abstract.pdf ------Fuels reduction Opposing View #24 - “History, not science, refutes the claim that logging helps to prevent forest fires. The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests. Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot. More logging will not fix this.” Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.highbeam.com/doc/1G1-192070397.html
256 High Valley Integrated Restoration Project Comment Analysis ------Fuels reduction Opposing View #25 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds. Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?” Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html ------Fuels reduction Opposing View #26 - “There is a gathering body of evidence that large wildfires are not determined by “unnatural” fuel loading. Lodgepole pine, subalpine fir, and aspen depend on infrequent, stand-replacing, high intensity fires. Most of the B-D NF is well within the natural range of variability. In fact, dense forest stands may not be caused by fire exclusion, but by a series of consecutive wet years that boosted seedling survival and expanded the local range. Drought, wind, and low humidity, not fuels loads, drive large wildifires. Weather and climatic conditions are also the driving force behind expanding insect populations.” Kelly, Steve Ph.D. 2007. “Cheap Chips, Counterfeit Wilderness: Greenwashing Logging on Montana's Biggest National Forest.” Published by the World Prout Assembly http://www.worldproutassembly.org/archives/2007/12/cheap_chips_cou.html ------Fuels reduction Opposing View #27 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.” “Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.”
257 High Valley Integrated Restoration Project Comment Analysis Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. http://www.fs.fed.us/emc/hfi/president.pdf ------Fuels reduction Opposing View #28 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.” “How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.” Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp ------Fuels reduction Opposing View #29 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non- commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground. Leitner, Brian. “Logging Companies are Responsible for the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html ------Fuels reduction Opposing View #30 - “Almost seven times more forested federal land burned during the 1987-2003 period than during the prior 17 years. In addition, large fires occurred about four times more often during the latter period.” “The increases in fire extent and frequency are strongly linked to higher March-through-August temperatures and are most pronounced for mid-elevation forests in the northern Rocky Mountains.
258 High Valley Integrated Restoration Project Comment Analysis The new finding points to climate change, not fire suppression policies and forest fuel accumulation, as the primary driver of recent increases in large forest fires.” “More Large Forest Fires Linked To Climate Change” Adapted from materials provided by the University of Arizona ScienceDaily, July 10, 2006 http://www.sciencedaily.com/releases/2006/07/060710084004.htm ------Fuels reduction Opposing View #31 - “We inferred climate drivers of 20th-century years with regionally synchronous forest fires in the U.S. northern Rockies. We derived annual fire extent from an existing fire atlas that includes 5038 fire polygons recorded from 12070086 ha, or 71% of the forested land in Idaho and Montana west of the Continental Divide. The 11 regional-fire years, those exceeding the 90th percentile in annual fire extent from 1900 to 2003 (>102314 ha or ~1% of the fire atlas recording area), were concentrated early and late in the century (six from 1900 to 1934 and five from 1988 to 2003). During both periods, regional-fire years were ones when warm springs were followed by warm, dry summers and also when the Pacific Decadal Oscillation (PDO) was positive. Spring snowpack was likely reduced during warm springs and when PDO was positive, resulting in longer fire seasons. Regional-fire years did not vary with El Nino-Southern Oscillation (ENSO) or with climate in antecedent years. The long mid-20th century period lacking regional-fire years (1935-1987) had generally cool springs, generally negative PDO, and a lack of extremely dry summers; also, this was a period of active fire suppression. The climate drivers of regionally synchronous fire that we inferred are congruent with those of previous centuries in this region, suggesting a strong influence of spring and summer climate on fire activity throughout the 20th century despite major land-use change and fire suppression efforts. The relatively cool, moist climate during the mid-century gap in regional-fire years likely contributed to the success of fire suppression during that period. In every regional-fire year, fires burned across a range of vegetation types. Given our results and the projections for warmer springs and continued warm, dry summers, forests of the U.S. northern Rockies are likely to experience synchronous, large fires in the future.” Morgan, Penelope Ph.D., Emily K. Heyerdahl Ph.D., and Carly E. Gibson 2008 "Multi-season climate synchronized forest fires throughout the 20th century, Northern Rockies", Ecology, 89, 3: 717-728. http://www.firelab.org/index.php?option=com_jombib&task=showbib&id=343 ------Fuels reduction Opposing View #32 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk." “Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from
259 High Valley Integrated Restoration Project Comment Analysis protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.” Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://www.motherjones.com/news/feature/2002/08/fireplan.html ------Fuels reduction Opposing View #33 - “Fuel reduction treatments should be forgone if forest ecosystems are to provide maximal amelioration of atmospheric carbon dioxide over the next 100 years,' the study authors wrote in their conclusion. 'If fuel reduction treatments are effective in reducing fire severities in the western hemlock, Douglas-fir forests of the west Cascades and the western hemlock, Sitka spruce forests of the Coast Range, it will come at the cost of long- term carbon storage, even if harvested materials are used as biofuels.’ ” Oregon State University Research Science Centric, July 9, 2009 http://www.sciencecentric.com/news/article.php?q=09070918-forest-fire-prevention-efforts- will-lessen-carbon-sequestration-add-greenhouse-warming ------Fuels reduction Opposing View #34 - “While top officials blame recent fires on fuels, all the on-the-ground reports I've read focus on the weather.” O'Toole Randal. “Incentives, Not Fuels, Are the Problem” Published by the Thoreau Institute http://www.ti.org/fireshort.html ------Fuels reduction Opposing View #35 - “This paper will show that built-up fuels are not the main reason, or even a major reason, for recent severe fires or high fire suppression costs. The weather is the prime reason for widespread fires this year as well as in 2000, 1999, and other recent years. But the major reason for increased costs is institutional: The federal land agencies, and especially the Forest Service, have a blank check to put out fires and thus have no reason to control their costs. If fuels are not the problem, then it isn’t necessary to spend $400 million a year treating them.” O’Toole, Randal. 2002. “Reforming the Fire Service: An Analysis of Federal Fire Budgets and Incentives.” The Thoreau Institute. www.ti.org/firesvc.pdf ------Fuels reduction Opposing View #36 - “Post-fire reports on individual fires make little or no mention of excess fuels. Instead, fire scientists agree that drought is the cause of the severe fires in recent years. This year’s Rodeo- Chedisky Fire, the largest fire in Arizona history, was on heavily managed and thinned federal lands, not an untouched wilderness brimming with excess fuels.”
260 High Valley Integrated Restoration Project Comment Analysis O’Toole, Randal. “Money to Burn?” Regulation, Winter 2002 - 2003 http://www.cato.org/pubs/regulation/regv25n4/v25n4-6.pdf ------Fuels reduction Opposing View #37 - “The current focus on ‘fuels’ is, in itself, misguided because almost anything in a forest will burn, given the right conditions. Any fire specialist will tell you that the principal factors affecting fire are temperature and moisture, not fuels. No legislation will prevent or even reduce fires in the vast areas of the national forests and to pretend so is fraudulent.” Partridge, Arthur Dean Ph.D. Testimony to the Agriculture, Nutrition and Forestry Committee United State Senate. Hearing to Review Healthy Forests Restoration Act, HR 1904 June 26, 2003 http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-music.shtml ------Fuels reduction Opposing View #38 - “A number of studies have shown that for some ecosystems, the major factor determining fire intensity and size is weather and not the amount of fuel (Baker 1989, Flannigan and Harrington 1988, Haines and Sando 1969, Rothermel 1995). For example, Bessie and Johnson (1995) found that fire spread and intensity were strongly related to weather conditions and only weakly related to fuel loads in the southern Canadian Rockies. Similarly, many hundreds of the thousands of acres of forests that were intensely burned in the 1994 Tyee Fire on the Wenatchee National Forest had very low fuel loads. The Forest Service and Fish and Wildlife Service concluded that weather patterns and terrain -- not fuels -- were the major reasons why this large fire burned the way it did (U.S. Forest Service 1995, U.S. Fish & Wildlife Service 1994). Such case studies provide little evidence that salvage logging of dead and dying trees will significantly reduce wildfires.” Peters, R.L., E. Frost, and F. Pace. “Managing for forest ecosystem health: A reassessment of the forest health crisis.” Defenders of Wildlife. April 1996. http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.htm ------Fuels reduction Opposing View #39 - “H.R 1904 does not include any specific measures to protect homes or communities. It is also inconsistent with the Western Governors' Association 10-Year Comprehensive Strategy, which does not call for any changes in existing laws. The only proven method to protect homes and communities is to reduce flammable materials in the immediate vicinity of structures, yet the definitions in H.R. 1904 would not require any activities to be near homes. Instead, the bill seeks to further subsidize the timber industry and eliminate obstacles to logging large, fire-resistant trees miles away from the nearest home. The country's top forest scientists, including the Forest Service's own scientists, have found that this kind of logging can actually increase fire risk and make fires larger and more intense.” Peterson, Mike testimony to the Senate Agriculture, Nutrition, and
261 High Valley Integrated Restoration Project Comment Analysis Forestry Committee concerning the Healthy Forests Restoration Act, HR 1904. June 26 2003 http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_id=2258 ------Fuels reduction Opposing View #40 - “We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.” Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001 ------Fuels reduction Opposing View #41 - “While most of us have suffered with the unavoidable fire-related anxieties, we have also been impressed by the hard work and heroism of both neighbors and anonymous firefighters. But others have tried to profit from the fires and the primordial fears they evoke. The forest products industry has been in the lead in this exploitation of other people's hardtimes. The forest products industry wants access as cheaply as it can get it to as much wood fiber as possible. It once had privileged access to forested public lands. As the frontier economy has faded and government give-aways have fallen out of political favor, the forest products industry's privileged grip on public resources has begun to slip. The current forest fires offer them an opportunity to try to regain some of their lost clout. The fires, timber industry spokespersons claim, are the result of restrictions on commercial logging on public lands. If all of these lands had been logged, they assert, the fires would not be burning. It is the federal government and the environmentalists they are in cahoots with who have caused the fires that now threaten us. As one timber industry advocate baldly said, "I never saw a clearcut burn." Nothing could be further from the truth. Of course clearcuts burn. When long, hot summers dry out the grasses, brush, and logging wastes, they can flare explosively. When they grow thick with closely packed young trees, they present exactly the fire danger we are wrestling with now. The logging roads provide human access that is the source of the vast majority of forest fires. If roading and logging eliminated the threat of wildfire, most of the fires that threaten us now would not be burning. Look at where these fires are: They are largely burning on the forest-urban interface in areas adjacent to intense human activity. In Western Montana, for instance, the fires are burning in the forests adjacent to some of the rapidly growing residential areas in the nation, the Bitterroot, Helena, and Clark Fork Valleys. These are not roadless areas that have never been logged. Quite the contrary, they are areas that were roaded and logged in the past. Those roads often have then provided access for the human activity that now dominates these areas, including the home building, residential settlement of the last two decades, and recreational activity. The trees now burning are usually second growth that followed past logging.”
262 High Valley Integrated Restoration Project Comment Analysis Power, Thomas Ph.D. ”Thee Politics of Forest Fires -- The Abuse of Other People's Hard Times.” 8/15/2000 Thomas Michael Power is the Professor and Chairman of the Economics Department, University of Montana http://www.forwolves.org/ralph/tompower.htm ------Fuels reduction Opposing View #42 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).” Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress, 2002 http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf ------Fuels reduction Opposing View #43 - “No evidence suggests that spruce–fir or lodgepole pine forests have experienced substantial shifts in stand structure over recent decades as a result of fire suppression. Overall, variation in climate rather than in fuels appears to exert the largest influence on the size, timing, and severity of fires in subalpine forests (Romme and Despain 1989, Bessie and Johnson 1995, Nash and Johnson 1996, Rollins et al. 2002). We conclude that large, infrequent standreplacing fires are “business as usual” in this forest type, not an artifact of fire suppression.” (Pg. 666) “Variation in daily area burned was highly correlated with the moisture content of 100-hour (2.5- to 7.6- cm diameter) and 1000-hour dead fuels (Turner et al. 1994). Once fuels reached critical moisture levels later in the season, the spatial pattern of the large, severe stand-replacing fires was controlled by weather (wind direction and velocity), not by fuels, stand age, or firefighting activities (Minshall et al. 1989,Wakimoto 1989, Turner et al. 1994).” (Pg. 666) Schoennagel, Tania Ph.D., Thomas T. Veblen Ph.D., and William H. Rommie Ph.D. “The Interaction of Fire, Fuels, and Climate across Rocky Mountain Forests” Bioscience, July 2004 / Vol. 54 No. 7 http://www.montana.edu/phiguera/GEOG430/PurdyFireFieldTrip/Schoennagel_et_al_2004_Bios cience.pdf
263 High Valley Integrated Restoration Project Comment Analysis ------Fuels reduction Opposing View #44 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.” Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm ------Fuels reduction Opposing View #45 - “Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20) “Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20) Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000 http://www.ourforests.org/fact/ashes.pdf ------Fuels reduction Opposing View #46 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.” Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php ------Fuels reduction Opposing View #47 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62)
264 High Valley Integrated Restoration Project Comment Analysis University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf ------Fuels reduction Opposing View #48 - “Why is the natural fire regime in most Rocky Mountain ponderosa pine–Douglas fir forests variable in severity? Extended droughts and high winds can lead to exceptional fire spread across a broad spectrum of fuel loads and forest structures. For example, almost 25,000 ha of ponderosa pine– Douglas fir forest burned on a single day (9 June 2002), driven by strong winds (Finney et al., 2003). Yet, brief episodes when the winds declined and fuel moisture rose, led to low-severity fire in the same landscape (Finney et al., 2003), suggesting that extreme weather, not fuels, was the chief cause of high-severity fire under those conditions. Even during summer, ponderosa pine–Douglas fir landscapes in the Rocky Mountains are subject to rapid increases in wind speed and changes in direction from jet streams or cold fronts (Baker, 2003).” (pg. 5) USDA Forest Service BALD ANGEL VEGETATION MANAGEMENT PROJECT ENVIRONMENTAL ASSESSMENT. La Grande Ranger District, Wallowa-Whitman National Forest December 2006 https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/6608/Wallowa_Whitman_B ald_Angel_Vegetation_Management_EA.pdf?sequence=1 ------Fuels reduction Opposing View #49 - “Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires. In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “ Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml ------Fuels reduction Opposing View #50 - “The federal assistance could include funding to help state and local governments mitigate the beetle infestations, the presence of which increases the risk of forest wildfires that endanger surrounding communities and infrastructure, said supporters of the bill.” “Kulakowski, a former research scientist at the University of Colorado at Boulder and current professor at Clark University in Massachusetts, discounted this notion during his testimony. He said climate, not insects, plays the most important role in forest fires, as wildfires are more likely to occur during droughts.”
265 High Valley Integrated Restoration Project Comment Analysis Walsh, Jeremy “Scientist: Money to fight beetles as fire mitigation not productive” Durango Herald, April 23, 2010 http://durangoherald.com/sections/News/2010/04/23/Scientist_Money_to_fight_beetles_as_fire_ mitigation_not_productive/ ------Fuels reduction Opposing View #51 - “New research published this week in the journal Science says that global warming may be causing more intense wildfires in the western United States. The researchers found that increases in large wildfire activity in the western United States over the past 25 years is ‘strongly associated with increased spring and summer temperatures and an earlier spring snowmelt.’ " Westerling, Anthony Ph.D., “Does Global Warming Increase Forest Fires?” NPR, Talk of the Nation, July 7, 2006 http://www.npr.org/templates/story/story.php?storyId=5541423 ------Fuels reduction Opposing View #52 - “Indeed, climatic conditions drive all big fires — not fuels. All substantial fires occur only if there is extended drought, low humidity, high temperatures and, most importantly, high winds. Wind, in particular, is critical. Wind increases fire spread exponentially. When conditions are "ripe" for a large blaze, fires will burn through all kinds of fuel loads. By contrast if the forest is wet like Oregon's coastal forests, you can have all the fuel in the world, and it won't burn. For this reason, most fires go out without burning more than a few acres. By contrast, when you have drought, low humidity, high temperatures and wind, a few blazes will grow into huge fires. For this reason, approximately 1 percent of all fires are responsible for about 95 to 99 percent of the acreage burned.” Wuerthner, George “The Climate Factor - Forest thinning won't deter the coming large fires” Eugene Weekly, December 6, 2007 http://www.eugeneweekly.com/2007/12/06/views3.html ------Fuels reduction Opposing View #53 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.” Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html ------
266 High Valley Integrated Restoration Project Comment Analysis Fuels reduction Opposing View #54 - “For example, the Forest Service justifies the Elliston Face timber sale on the basis of reducing what they call “hazardous” fuels (which as an ecologist I call woody biomass). To quote the FS, “This project would reduce wildland fire risk and help protect lives, communities, and ecosystems from the potential consequences of a high-intensity wildland fire within treatment areas.” “ “The Forest Service makes these assertions even though the statement is full of falsehoods, misleading and/or unproven assumptions.” “even the Forest Service’s own analysis concludes that logging of the Elliston Face will have some adverse impacts on soils, watersheds, wildlife, scenery and recreation. So we need to ask whether the potential effects of a fire that may not occur for a century or more is worth the negative impacts created by the logging process now?” “The Forest Service’s own analysis has six indicator species— including pileated woodpecker, hairy woodpecker, martin, northern goshawk. These species depend on dead snags and down wood that pine beetles and wildfire create. But the FS treats beetles and wildfire as unwelcome events.” “the FS exploits the fears of misinformed citizens. One can only conclude the agency is still the handmaiden to the timber industry rather than a public servant working on behalf of all citizens of the country.” Wuerthner, George “Forest Service misses education opportunity” Published in NewWest, June 2010 http://www.newwest.net/topic/article/elliston_face_is_yet_another_example_of_forest_service_ malfeasance/C564/L564/ ------Fuels reduction Opposing View #55 - “Ultimately, fuels do not control fires. If the climate/weather isn’t conducive for fire spread, it doesn’t much matter how much dead wood you have piled up, you won’t get a large fire. As an extreme example, think of all the dead wood lying around on the ground in old-growth West Coast rainforests — tons of fuel, but few fires — because it’s too wet to burn. Large blazes are driven by a combination of extreme drought, low humidity, high temperatures and, most importantly, wind. These conditions do not occur in the same place at the same time very frequently — which is why there are often decades to centuries between major blazes and most fires go out without burning more than a few acres.” Wuerthner, George “Pine Beetle Fears Misplaced” Helena Independent Record, March 25, 2010 http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d-001cc4c002e0.html ------Fuels reduction Opposing View #56 - “In the last analysis, the politics of forest thinning promotes more logging. The timber industry has successfully sold the idea that fuel reductions work and it has great influence with politicians who buy into to its assurance that logging reduces large fires.” “So is there any place for forest thinning/fuel reductions? There is. But it should be limited to the areas immediately surrounding homes and communities. Since one can’t predict where a fire will
267 High Valley Integrated Restoration Project Comment Analysis start and burn, thinning forest willy-nilly is a waste of effort. Not only are most thinning projects done improperly, most are done for the wrong reasons and lose taxpayer money to boot.” “Thinning trees/shrubs near homes, combined with a reduction in home flammability by installation of metal roofs, removal of flammable materials adjacent to homes, and other measures can virtually guarantee a home will survive even a severe high intensity forest fire.” Wuerthner, George, “WHY THINNING FORESTS IS POOR WILDFIRE STRATEGY” Published in the Wildlife News, January 27, 2014 http://www.thewildlifenews.com/2014/01/27/why-thinning-forests-is-poor-wildfire-strategy/ ------Fuels reduction Opposing View #57 - “If anything, heavy logging from earlier years may have contributed more to the conditions that have made Western forests ripe for big fires, because more flammable small trees and heavy brush are often left in the forest after the larger stands of timber have been taken out, said the report, by the Congressional Research Service, which analyzes policy for Congress.” Egan, Timothy, “Fires Not Caused by Reduced Logging, Congressional Report Finds” Published in the New York Times: September 1, 2000 http://www.nytimes.com/2000/09/01/us/fires-not-caused-by-reduced-logging-congressional- report-finds.html ------Fuels reduction Opposing View #58 - “The fact is, commercial logging doesn't prevent catastrophic fires; it causes them. In the latter part of the 19th century, this was common knowledge. Relentless clearing of forests in the Great Lakes region left huge areas largely devoid of the cooling shade of trees, replacing moist natural forest microclimates with the hotter, drier conditions characterized by stump fields. Flammable logging "slash debris" covered the landscape.” “Not long ago, Congress commissioned a study of California's forests that came to be known as the Sierra Nevada Ecosystem Project (SNEP) report. Produced jointly with the US Forest Service in 1996, the report confirmed what people have known for over a century: "timber harvest, through its effects on forest structure, local microclimate, and fuel accumulation, has increased fire severity more than any other recent human activity" “ Hanson, Chad, “The Big Lie: Logging and Forest Fires” Published in the Earth Island Journal, Spring 2000 http://yeoldeconsciousnessshoppe.com/art6.html ------Fuels reduction Opposing View #59 - “Researchers from the Australian National University (ANU) and Melbourne University examined hundreds of thousands of trees burnt in the 2009 bushfires in Victoria, which claimed the lives of 173 people on a day of extreme temperatures and high winds. They found that the increased fire risk began about seven years after an area had been logged and lasted for another 50 years.
268 High Valley Integrated Restoration Project Comment Analysis Professor David Lindenmayer, from the ANU, said the results showed the fires around Kinglake and Marysville were about 25 per cent more severe due to the clear-felling of forest in the area.” “Logging can 'greatly increase' fire severity for 50 years, researchers say” Broadcast on ABC News Australia, August 3, 2014 http://www.abc.net.au/news/2014-08-04/logging-greatly-increases-fire-risk-black-saturday- study/5646220 ------Fuels reduction Opposing View #60 - “The scientists say the study showed conclusively that logging in the decades prior to Black Saturday made the deadly blaze much more extreme. They also warn that increased fire danger in forests lasts for up to 70 years after an area is logged, with the risk peaking between 10 and 50 years.” Campbell, James, “Study finds logging increased intensity of Black Saturday fires” Published in the Herald Sun, August 03, 2014 http://www.heraldsun.com.au/news/victoria/study-finds-logging-increased-intensity-of-black- saturday-fires/story-fni0fit3-1227012027799 ------Fuels reduction Opposing View #61 - “ “More highly intense fire is not occurring now than historically in dry forests,” said William Baker, who teaches fire ecology and landscape ecology in Laramie, Wyo., where he’s been doing research more than 20 years. “These forests were much more diverse and experienced a much wider mixture of fire than we thought in the past, including substantial amounts of high-severity fire.” “ “If he’s right, he and others say it means fuel-reduction programs aimed at removing trees and shrubs in the name of easing fire threats are creating artificial conditions that likely make dry forests less resilient.” “ “It means we need to rethink our management of Western dry forests,” said Baker, a member of a U.S. Fish and Wildlife Service working group that is developing plans to help bolster northern spotted owl populations in dry forests.” “Jennifer Marlon, a Yale University paleoecologist, said a study she recently led on the impact of climate change on forests over thousands of years appeared to be largely consistent “with Baker’s idea that there were large, severe fires even in dry forests historically.” “ “ “The general trend from high fire in the 1800s to very low fire in the 1900s is strong and clear from three independent datasets,” she said. “Open park-like conditions may have indeed occurred after the ‘peak’ in burning during the mid-1800s.” “ “The new studies provide the first “real, direct data’” showing that more forests burned historically, creating more post-fire forest habitat, said Chad Hanson, a forest ecologist and director of the John Muir Project who is helping lead the listing effort and suing the Forest Service to block post-fire logging in woodpecker habitat near Lake Tahoe.” “Now, he believes thinning and post-fire salvage operations should be re-examined and emphasis placed on maintaining high-density stands in certain circumstances that would not threaten people or homes.”
269 High Valley Integrated Restoration Project Comment Analysis “We shouldn’t be managing just for low-density forests,” he said. “We should not be unhappy with — or perhaps even manage for — higher severity fires in the forests.” Sonner, Scott AP, Study challenges views about Western forest fires Published in the Daily World, July 23, 2012 Link: http://www.thedailyworld.com/sections/newswire/northwest/study-challenges-views- about-western-forest-fires.html ------Fuels reduction Opposing View #62- "In the case of the Rim Fire, our research found that protected forest areas with no history of logging burned least intensely. There was a similar pattern in other large fires in recent years. Logging removes the mature, thick-barked, fire- resistant trees. The small trees planted in their place and the debris left behind by loggers act as kindling; in effect, the logged areas become combustible tree plantations that are poor wildlife habitat. More Logging Won’t Stop Wildfires By Drs. CHAD T. HANSON and DOMINICK A. DELLASALA The New York Times, Jul 28, 2015 http://www.oregonwild.org/about/press/more-logging-won%E2%80%99t-stop-wildfires
270 High Valley Integrated Restoration Project Comment Analysis Opposing Views Attachment #4 Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest Road Construction Opposing View #1 - “Fragmentation has been considered as one of the most major factors that lead to the decline of many wildlife species (Brittingham and Temple 1983, Yahner 1988, Winslow et al. 2000) because fragmentation tends to decrease population productivity (Robinson et al. 1995). Therefore, Meffe states that “fragmentation has become a major subject of research and debate in conservation biology” (Meffe et al. 1997, p. 272). Forest fragmentation usually occurs when large and continuous forests are divided into smaller patches as a result of road establishment, clearing for agriculture, and human development (Robinson et al. 1995, Meffe et al. 1997).” (Pg. 1) “Generally, habitat fragmentation is an ecological process in which a large patch of habitat is divided into smaller patches of habitats. Usually, this process is caused by human activities (roads, agriculture, and logging). It also reduces the value of the landscape as habitat for many species (plants and animals). Fragmentation alters natural habitat in many ways, including reduction of patches’ sizes, increment of distances between similar patches, and increment of edges and predation (Brittingham and Temple 1983, Robinson et al. 1995).” (Pp. 2 and 3) Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and Implications” http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implica tion.pdf ------Road Construction Opposing View #2 - "Debris slides over a 20-year period were inventoried on 137,500 acres of forested land in the Klamath Mountains of southwest Oregon. Frequency during the study period was about one slide every 4.3 years on each 1,000 acres-an erosion rate of about 1/2 yd3 per acre per year. Erosion rates on roads and landings were 100 times those on undisturbed areas, while erosion on harvested areas was seven times that of undisturbed areas. Three-quarters of the slides were found on slopes steeper than 70 percent and half were on the lower third of slopes." "Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests." Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr and R. R. Ziemer Ph.D. "Logging and forest roads related to increased debris slides in southwestern Oregon." Journal of Forestry Vol. 83, No. 4. 1985. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF ------Road Construction Opposing View #3 - " ‘Roads may have unavoidable effects on streams, no matter how well they are located, designed or maintained. The sediment contribution to streams
271 High Valley Integrated Restoration Project Comment Analysis from roads is often much greater than that from all other land management activities combined, including log skidding and yarding.’ (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.” “Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.watertalk.org/wawa/ecosci.html ------Road Construction Opposing View #4 - “Plot-level studies have demonstrated the ability of forest roads to intercept and route both subsurface and surface overland flow more efficiently to the stream network. Significant amount of subsurface throughflow can be intercepted by the road, as a function of the road cut depth and the current saturation deficit, and then redirected, concentrating the flow in particular areas below the road. Road drainage concentration increases the effective length of the channel network and strongly influences the distribution of erosional processes. The concept of wetness index has been used in the study as a surrogate for subsurface throughflow, and the effect of forest roads on subsurface throghflow rerouting has been assessed by evaluating the changes in terms of draining upslope areas. A threshold model for shallow slope instability has been used to analyse erosional impacts of drainage modifications. In the model, the occurrence of shallow landsliding is evaluated in terms of drainage areas, ground slope and soil properties (i.e., hydraulic conductivity, bulk density, and friction angle). The model has been used to generate hypotheses about the broader geomorphic effect of roads. Modelling results have been compared with available field data collected in north-eastern Italy.” Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi “Evaluating the Effects of Forest Roads on Shallow Landsliding” Geophysical Research Abstracts, Vol. 5, 13312, 2003 http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf ------Road Construction Opposing View #5 - “A large scale land use experiment has taken place over the last 40 years in the mountainous areas of the northwestern U.S. through timber harvesting. This land use change effects the hydrology of an area through two mechanisms: • Clear-cut logging which causes changes in the dynamics of Rain-On-Snow (ROS) events due to changes in the accumulation and ablation of snow caused by vegetation effects on snow interception and melt; and • Construction and maintenance of forest roads which channel intercepted subsurface flow and infiltration excess runoff to the stream network more quickly.” Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins “Predicting the Effects of Forest Roads on Streamflow using a Distributed Hydrological Model” from a poster presented at the fall meeting of the American Geophysica Union, San Francisco, CA, December 1996.
272 High Valley Integrated Restoration Project Comment Analysis http://www.ce.washington.edu/~lxb/poster.html ------Road Construction Opposing View #6 - "American rivers and streams face destruction by sedimentation. Clearcutting, along with the vast network of logging roads, result in sedimentation and soil erosion into our national forest’s rivers and streams. Sedimentation degrades the water quality, impairs the habitat for fish and macroinvertebrates, and limits the ecosystem functions and services of streams. By Dr. Seth Reice is Associate Professor of Biology in the Department of Biology and Curriculum in Ecology, University of North Carolina. From Press Conference with Senator Robert Torricelli, April 28, 1998, U.S. Capitol regarding the proposed Act to Save America’s Forests (S. 977, HR 1376) ------Road Construction Opposing View #7 - "The present road system constitutes a legacy of current and potential sources of damage to aquatic and riparian habitats, mostly through sedimentation, and to terrestrial habitats through fragmentation and increased access" (Amaranthus et all 1985)." "The failure of the Report to properly address mitigation costs associated with the ecological effects is a serious problem that needs to be addressed in future drafts. Similarly, passive-use values need to be taken seriously and considered throughout the Roads Report. In order to rectify these problems, most of the Socio-Economic Effects subsections will have to be reworked. Failing to do so, the Roads Report will paint an incomplete picture of the costs and benefits associated with the Forest Service's road program." Brister, Daniel. "A Review and Comment on: Forest Service Roads: A Synthesis of Scientific Information, 2nd Draft, USDA Forest Service." December 1998. http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio- economic-impacts ------Road Construction Opposing View #8 - "Sediment input to freshwater is due to either the slower, large-scale process of soil erosion, or to rapid, localized “mass movements,” such as landslides. Forest practices can increase the rate at which both processes occur. Most sediment from forestry arises from landslides from roads and clearcuts on steep slopes, stream bank collapse after riparian harvesting, and soil erosion from logging roads and harvested areas. Roads, particularly those that are active for long periods of time, are likely the largest contributor of forestry-induced sediment (Furniss et al. 1991)." "Sediment can increase even when roads comprise just 3% of a basin (Cederholm et al. 1981)." "More than half the species present in the study area will likely be negatively impacted by sedimentation from logging roads." "In areas made highly turbid (cloudy) from sedimentation, the foraging ability of adults and juveniles may be inhibited through decreased algal production and subsequent declines in insect abundance, or, for visual-feeding taxa dependent on good light, through their inability to find and
273 High Valley Integrated Restoration Project Comment Analysis capture food. Highly silted water may damage gill tissue and cause mortality or physiological stress of adults and juveniles." Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 "Evaluating effects of large-scale salvage logging for mountain pine beetle on terrestrial and aquatic vertebrates." Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest Service. http://warehouse.pfc.forestry.ca/pfc/25154.pdf ------Road Construction Opposing View #9 - "The road construction and right-of-way logging were immediately detrimental to most aquatic invertebrates in South Fork Caspar Creek" "Salmonid populations decreased immediately after the road construction." "Sustained logging and associated road construction over a period of many years do not afford either the stream or the 'fish population a chance to recover." Burns, James W., "Some Effects of Logging and Associated Road Construction on Northern California Streams." Transactions of the American Fisheries Society, Volume 1, Number 1, January 1972. http://www.fs.fed.us/psw/publications/4351/Burns72.pdf ------Road Construction Opposing View #10 – “Road construction in the steep, often unstable terrain of Oregon's mountains is both, difficult and hazardous. It is also costly, both in terms of direct construction and damage to the aquatic environment. We know that in Oregon, forest roads are our greatest source of problems with mass soil movement ( Brown and, Krygier, 1971;Fredriksen, 1970; Dyrness, 1967 ). Yet we do not understand the processes well enough to be able to predict with reasonable certainty where road failures will occur or how alternative road designs will affect mass movements except in the most obvious places.” Brown, George W. Ph.D., The Impact of Timber Harvest on Soil and Water Resources Dr. BROWN is the Forest Hydrologist, School of Forestry, Oregon State University http://andrewsforest.oregonstate.edu/pubs/pdf/pub1695.pdf ------Road Construction Opposing View #11 - “Forested watersheds typically release clean water, yet forest roads and trails can drastically impact water quality. Increased stream sedimentation from road and skid trail crossings represent the most significant water quality threat associated with forestry operations.” From Forest Roads and Sediment Project PROJECT DURATION:1 January 2011 to 30 November 2019 Published by Virginia Tech University By W. Mike Aust,Ph.D., Kevin McGuire, Ph.D., M. Chad Bolding, Ph.D. and Scott Barrett, Ph.D.
274 High Valley Integrated Restoration Project Comment Analysis http://hydro.vwrrc.vt.edu/research/projects/forest-roads-and-sediment-project/ ------Road Construction Opposing View #12 - "Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road." Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks made to Forest Service employees and retirees at the University of Montana. February 1998. https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Dom beck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm ------Road Construction Opposing View #13 - "Few marks on the land are more lasting than roads." "The negative effects on the landscape of constructing new roads, deferring maintenance, and decommissioning old roads are well documented. Unwanted or non-native plant species can be transported on vehicles and clothing by users of roads, ultimately displacing native species. Roads may fragment and degrade habitat for wildlife species and eliminate travel corridors of other species. Poorly designed or maintained roads promote erosion and landslides, degrading riparian and wetland habitat through sedimentation and changes in streamflow and water temperature, with associated reductions in fish habitat and productivity. Also, roads allow people to travel into previously difficult or impossible to access areas, resulting in indirect impacts such as ground and habitat disturbance, increased pressure on wildlife species, increased litter, sanitation needs and vandalism, and increased frequency of human-caused fires." EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, "National Forest System Road Management." http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day-03/g5002.htm ------Road Construction Opposing View #14 - “Fragmentation caused by roads is of special interest because the effects of roads extend tens to hundreds of yards from the roads themselves, altering habitats and water drainage patterns, disrupting wildlife movement, introducing exotic plant species, and increasing noise levels. The land development that follows roads out into rural areas usually leads to more roads, an expansion process that only ends at natural or legislated barriers.” “Forest Fragmentation and Roads” Eastern Forest Environmental Threat Assessment Center U.S. Forest Service - Southern Research Station http://www.forestthreats.org/publications/su-srs-018/fragmentation ------Road Construction Opposing View #15 - “A huge road network with vehicles ramifies across the land, representing a surprising frontier of ecology. Species-rich roadsides are conduits for few species. Roadkills are a premier mortality source, yet except for local spots, rates rarely limit population size. Road avoidance, especially due to traffic noise, has a greater ecological impact. The still-more-important barrier effect subdivides populations, with demographic and probably
275 High Valley Integrated Restoration Project Comment Analysis genetic consequences. Road networks crossing landscapes cause local hydrologic and erosion effects, whereas stream networks and distant valleys receive major peak-flow and sediment impacts. Chemical effects mainly occur near roads. Road networks interrupt horizontal ecological flows, alter landscape spatial pattern, and therefore inhibit important interior species. Thus, road density and network structure are informative landscape ecology assays. Australia has huge road-reserve networks of native vegetation, whereas the Dutch have tunnels and overpasses perforating road barriers to enhance ecological flows. Based on road-effect zones, an estimated 15–20% of the United States is ecologically impacted by roads.” Forman, Richard T. and Lauren E. Alexander “Roads and their Major Ecological Effects” Annual Review of Ecology and Systematics, Vol. 29: 207-231, November 1998 http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&jour nalCode=ecolsys.1 ------Road Construction Opposing View #16 - “Questions to consider: Roads dramatically alter forest ecosystems 1. Does the management prescription account for the ecological effects of the road construction and maintenance activities associated with carrying out such activities? 2. Have alternatives to road building been considered? How does the plan attempt to address the effects of roads?” (page 37) Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf ------Road Construction Opposing View #17 - “The authors warned that cutting roads into current roadless areas could bring much more harm to wildlife, soil and fisheries than the beetle-killed trees pose to the forest.” Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/ ------Road Construction Opposing View #18 - "Rarely can roads be designed and built that have no negative impacts on streams. Roads modify natural drainage patterns and can increase hillslope erosion and downstream sedimentation. Sediments from road failures at stream crossings are deposited directly into stream habitats and can have both on-site and off-site effects. These include alterations of the channel pattern or morphology, increased bank erosion and changes in channel width, substrate composition, and stability of slopes adjacent to the channels."
276 High Valley Integrated Restoration Project Comment Analysis "All of these changes result in important biological consequences that can affect the entire stream ecosystem. One specific example involves anadromous salmonids, such as salmon and steelhead, that have complex life histories and require suitable stream habitat to support both juvenile and adult life stages." "A healthy fishery requires access to suitable habitat that provides food, shelter, spawning gravel, suitable water quality, and access for upstream and downstream migration. Road-stream crossing failures have direct impacts on all of these components." Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan "Diversion Potential at Road-Stream Crossings." USDA Forest Service. 9777 1814—SDTDC. December 1997. http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf ------Road Construction Opposing View #19 - “Barry Noon, a professor of wildlife ecology at Colorado State University, noted that scientific research has consistently shown the adverse effects of roads on hydrologic processes and fish and wildlife populations. “ “One of the key things to recognize is the effects of the roads extend far beyond their immediate footprint,” Noon said. For example, “in terms of hydrology, the roads are leading to faster runoff of water, often with great increases in sedimentation, particularly following storm events, and roads in watersheds often lead to increases in the intensity of floods.” “ These changes degrade fish habitat because of the increased sedimentation that leads to decreases in water quality, Noon said. And roads fragment wildlife habitat and create areas that animals avoid, often as result of increased hunting, he said.” Gable, Eryn “Battling beetles may not reduce fore risks – report” Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/ ------Road Construction Opposing View #20 - "Roads and skid trails have been identified as a major contributor to increased turbidity of water draining logging areas resulting in increases from 4 to 93 parts per million (Hoover, 1952). Forest roads have been found to have erosion rates from one to three orders of magnitude greater than similar undisturbed areas (Megahan, 1974) and perhaps account for as much as 90 percent of all forest erosion (Megahan, 1972). Forest roads can also cause soil erosion and stream sedimentation, which adversely impact on the nation’s water quality (Authur et al., 1998). Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the forest road system." In: Proceedings of the conference 34 international erosion control association; ISSN 1092-2806. [Place of publication unknown]: International Erosion Control Association: 301-310. http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf ------
277 High Valley Integrated Restoration Project Comment Analysis Road Construction Opposing View #21 - "Roads have well-documented, short- and long-term effects on the environment that have become highly controversial, because of the value society now places on unroaded wildlands and because of wilderness conflicts with resource extraction." "(Road) consequences include adverse effects on hydrology and geomorphic features (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, use conflicts, destructive human actions (for example, trash dumping, illegal hunting, fires), lost solitude, depressed local economies, loss of soil productivity, and decline in biodiversity." Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of Scientific Information." USDA Forest Service, General Technical Report PNW-GTR-509. http://www.fs.fed.us/pnw/pubs/gtr509.pdf ------Road Construction Opposing View #22 - "Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands." Hann, W.J. et al. 1997 Landscape dynamics of the Basin. Pp. 337-1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405 http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf ------Road Construction Opposing View #23 - “Many forested landscapes are fragmented by roads, but our understanding of the effects of these roads on the function and diversity of the surrounding forest is in its infancy. I investigated the effect of roads in otherwise continuous forests on the macroinvertebrate fauna of the soil. I took soil samples along transects leading away from the edges of unpaved roads in the Cherokee National Forest in the Southern Appalachian mountains of the United States. Roads significantly depressed both the abundance and the richness of the macroinvertebrate soil fauna. Roads also significantly reduced the depth of the leaf-litter layer. These effects persisted up to 100 m into the forest. Wider roads and roads with more open canopies tended to produce steeper declines in abundance, richness, and leaf- litter depth, but these effects were significant only for canopy cover and litter depth. The macroinvertebrate fauna of the leaf litter plays a pivotal role in the ability of the soil to process energy and nutrients. These macroinvertebrates also provide prey for vertebrate species such as salamanders and ground-foraging birds. The effect of roads on the surrounding forest is compounded by the sprawling nature of the road system in this and many other forests. My data suggest that even relatively narrow roads through forests can produce marked edge effects that may have negative consequences for the function and diversity of the forest ecosystem.”
278 High Valley Integrated Restoration Project Comment Analysis Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Macroinvertebrate Soil Fauna of the Southern Appalachian Mountains” http://www.jstor.org/stable/2641904 ------Road Construction Opposing View #24 - “Roads remove habitat, alter adjacent areas, and interrupt and redirect ecological flows. They subdivide wildlife populations, foster invasive species spread, change the hydrologic network, and increase human use of adjacent areas. At broad scales, these impacts cumulate and define landscape patterns.” Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D., Murray K. Clayton Ph.D., Roger B. Hammer Ph.D., and Charlotte E. Gonzalez-Abraham Ph.D. “Road Development, Housing Growth, and Landscape Fragmentation In Northern Wisconsin: 1937–1999” Ecological Applications: Vol. 16, No. 3, pp. 1222-1237. http://www.esajournals.org/doi/abs/10.1890/1051- 0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journalCode=ecap ------Road Construction Opposing View #25 - “Last winter was unusually wet in the Pacific Northwest. The result was landslides all over caused by logging roads; five people died, spawning streams were ruined, water supplies were contaminated and the flooding was tremendously aggravated. According to David Bayles, conservation director of the Pacific Rivers Council, aerial surveys documented more than 650 landslides in February in Washington and Oregon alone. The stupidest and most dangerous practice is allowing logging roads on steep slopes — that's really asking for it. You may ask yourself why the taxpayers are expected to pony up to build roads for profitable logging companies. Build roads for the timber companies in order to stimulate the U.S. logging, paper and building industries. There's just one problem. A lot of U.S. logs get shipped overseas, mostly to Japan. We're actually subsidizing Japanese companies while doing terrible damage to our environment and not helping the U.S. job scene much except when it comes to cutting Start with the assumption that the U.S. Forest Service a component of the Department of Agriculture, is simply an auxiliary branch of the timber industry and you'll pretty much have the picture of what's going on. Last winter, the Forest Service refused a bid at a timber auction from an environmentalist who wanted to save, not harvest, a stand of evergreens in the Okanogan National Forest in Washington. Instead, the Forest Service accepted a bid of $15,000 from a logging company that cut 3.5 million board-feet of lumber in that stand. Try to find a price like that at Home Depot.” Ivins, Molly Creators Syndicate, August 3 1997 08 03 http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html ------
279 High Valley Integrated Restoration Project Comment Analysis Road Construction Opposing View #26 - "Although disturbance patches are created by peak flow and debris flow disturbances in mountain landscapes without roads, roads can alter the landscape distributions of the starting and stopping points of debris flows, and they can alter the balance between the intensity of flood peaks and the stream network's resistance to change." Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of roads on hydrology, geomorphology, and disturbance patches in stream networks." Conservation Biology 14, No. 1. 2000. http://www.jstor.org/stable/2641906 ------Road Construction Opposing View #27 - "In the Pacific Northwest, the two main processes that contribute to sediment production are mass failure and surface erosion from forest roads (Fredriksen 1970, Reid and Dunne 1984). In the Clearwater River basin in the State of Washington, as much as 40 percent of the sediment produced in the watershed was attributed to logging roads (Reid 1980)." Kahklen, Keith. "A Method for Measuring Sediment Production from Forest Roads." Pacific Northwest Research Station, USDA Forest Service. Research note PNW-RN-529, April 2001. http://www.fs.fed.us/pnw/pubs/rn529.pdf ------Road Construction Opposing View #28 - "It is indisputable that roads are one of the greatest threats to the ecological integrity of forested systems and associated river, wetland, lake, and coastal ecosystems. Yet, the USFS has failed to adopt a policy that mandates reversing the worst ecological effects of roads, or that precludes incursion of roads into roadless areas. Despite widespread recognition of these facts, the USFS diverts staff and money to extraordinarily costly salvage logging projects at the expense of reducing the extent of the road network or undertaking needed fine-fuels reductions in unburned forests." Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt from a letter to the Subcommittee on Forests & Forest Health U.S. House of Representatives. 3 July, 2002. http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from_beschta.htm ------Road Construction Opposing View #29 - “Forest fragmentation, as scientists call the intentional felling of woodland, is actually two processes. In populated areas such as the Atlantic seaboard, it means reduction in the size of forest tracts, usually due to suburbanization and development. In less inhabited areas--northern New England, for example--forest fragmentation refers to isolation of one patch of forest from another by logging, or by the building of roads or power lines.”
280 High Valley Integrated Restoration Project Comment Analysis Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament as experts ponder the decline of dozens of forest species” National Wildlife http://www.nwf.org/News-and-Magazines/National-Wildlife/Birds/Archives/1992/Singing-the- Blues-for-Songbirds.aspx ------Road Construction Opposing View #30 - "The compaction of forest road soils is known to reduce aeration, porosity, infiltration rates, water movement, and biological activity in soils. Research indicates that soil bulk density, organic matter, moisture, and litter depths are much lower on roads than on nearby forest lands. Macropores, which provide soil drainage and infiltration, have been shown to significantly decrease in size as a result of road construction and use. Reduced infiltration and increased compaction promote soil erosion, especially during the seasonal southwestern monsoon rains (Elseroad 2001)." "Physical disturbances caused by road construction and vehicle use create ideal conditions for colonization by invasive exotic plant species. The use of roads by vehicles, machinery, or humans often aids the spread of exotic plant seeds. Once established, they can have long-term impacts on surrounding ecosystems and can be difficult to remove." "Roads are known to cause habitat fragmentation. Many create ecological 'edges' with different plant species, light levels, and hiding cover, all of which may alter animal survival, reproductive success, and movement patterns. The introduction of exotic plants can disrupt the availability of native vegetation used by wildlife for food and shelter (Trombulak and Frissell 1999)." "Forest roads often develop a water-repellent soil layer caused by lack of vegetative cover and changes in soil composition. This can substantially influence how runoff is processed. Erosion, the formation of water channels beside the road, and increased sediment loads in nearby streams are common results of this process (Baker 2003)." "Because they provide easier access to many forest tracts, forest roads often allow more human- caused fires to be ignited." Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona University Ecological Restoration Institute publication Working Paper 12. June, 2005. http://www.eri.nau.edu/en/information-for-practitioners/restoring-forest-roads ------Road Construction Opposing View #31 - "Almost everywhere people live and work they build and use unimproved roads, and wherever the roads go, a range of environmental issues follows." "Among the environmental effects of unimproved roads, those on water quality and aquatic ecology are some of the most critical. Increased chronic sedimentation, in particular, can dramatically change the food web in affected streams and lakes." "The nearly impervious nature of road surfaces (or treads) makes them unique within forested environments and causes runoff generation even in mild rainfall events, leading to chronic fine sediment contributions."
281 High Valley Integrated Restoration Project Comment Analysis "If we look at the issue of what we need to learn or the research priorities for forest road hydrology, I would argue that the areas of cutslope hydrology and effectiveness of restoration efforts are perhaps most critical." "At a few sites in the mountains of Idaho and Oregon a substantial portion of the road runoff (80–95%) came from subsurface flow intercepted by the cutslope (Burroughs et al., 1972; Megahan, 1972; Wemple, 1998)." Luce, Charles H. Ph.D., 2002. "Hydrological processes and pathways affected by forest roads: what do we still need to learn?" Hydrologic Processes: 16, 2901–2904. http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%20HP.pdf ------Road Construction Opposing View #32 - "Roads in the watershed contribute to sediment production by concentrating runoff, thereby increasing sediment load to the stream network. Most unimproved (dirt) roads connect either directly or indirectly with streams and, therefore, act as extensions of stream networks by effectively increasing watershed drainage density and subsequently sediment loads to streams. In the South Fork subwatershed of Squaw Creek, road connectivity has resulted in an increase in effective drainage density of approximately 250%. Throughout the Squaw Creek watershed, it is estimated that dirt roads potentially contribute as much as 7,793 metric tons/year to the watershed sediment budget." Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Road Effects on Stream Channel Networks in an Eastern Sierra Nevada Watershed." Journal of the Nevada Water Resources Association, Volume 2, Number 2, Fall 2005. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_article4.pdf ------Road Construction Opposing View #33 - “One of the greatest impacts of roads and (especially motorized) trails is their effect on the hydrology of natural landscapes, including the flow of surface and ground water and nutrients. These hydrologic effects are responsible for changes to geomorphic processes and sediment loads in roaded areas (Luce and Wemple 2001).” (pg. 12) Malecki, Ron W. “A New Way to Look at Forest Roads: the Road Hydrologic Impact Rating System (RHIR)” The Road-RIPorter, Autumn Equinox, 2006 http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf ------Road Construction Opposing View #34 - "A study was made on 344 miles of logging roads in northwestern California to assess sources of erosion and the extent to which road-related erosion is avoidable. At most, about 24 percent of the erosion measured on the logging roads could have been prevented by conventional engineering methods. The remaining 76 percent was caused by site conditions and choice of alignment. On 30,300 acres of commercial timberland, an estimated
282 High Valley Integrated Restoration Project Comment Analysis 40 percent of the total erosion associated with management of the area was found to have been derived from the road system." McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging roads in northwestern California: How much is avoidable?" Journal of Forestry 8(1): 23-26. http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf ------Road Construction Opposing View #35 - "Research has shown that roads can have adverse impacts on the water quality on the forest landscape (Authur et al. 1998; Binkley and Brown 1993; Megahan et al. 1991). The forest road system has been identified by previous research as the major source of soil erosion on forestlands (Anderson et. al 1976; Patric 1976; Swift 1984; Van Lear et al. 1997). Furthermore, roads are cited as the dominant source of sediment that reaches stream channels (Packer 1967; Trimble and Sartz 1957; Haupt 1959)." McFero III, Grace, J. "Sediment Plume Development from Forest Roads: How are they related to Filter Strip Recommendations?" An ASAE/CSAE Meeting Presentation, Paper Number: 045015, August 1-4, 2004. http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf ------Road Construction Opposing View #36 - “Overall, roads had a greater impact on landscape structure than logging in our study area. Indeed, the 3-fold increase in road density between 1950–1993 accounted for most of the changes in landscape configuration associated with mean patch size, edge density, and core area.” McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and logging on landscape structure in the San Juan Mountains, Colorado (USA)” Landscape Ecology, Volume 16, Number 4 / May, 2001 http://www.springerlink.com/content/w12557624742tv77/ ------Road Construction Opposing View #37 - “Road construction in remote areas appears to be the major long term impact of resource extraction industries and the most significant problem facing grizzly bears in most locations. Open roads are an influence in all 5 ways that people affect bears. Vehicles on roads can harass bears, displace them from quality habitats, and cause reduced bear use of altered habitats, such as cutting units. Bears that are displaced from roads may cause social disruption in areas away from roads. Finally, roads permit access for many people and some of these will shoot bears.” (Pg. 62) McLellan, Bruce N. “Relationships between Human Industrial Activity and Grizzly Bears” Bears: Their Biology and Management, Vol. 8
283 High Valley Integrated Restoration Project Comment Analysis International Conference on Bear Research and Management February 1989 (1990), pp. 57-64 http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/McClellan_8.pdf ------Road Construction Opposing View #38 - “Erosion from forest roads can be a large source of sediment in watersheds managed for timber production.” Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from Forest Roads in Washington State” from a presentation presented at the 2003 Geological Society of America meeting. http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm ------Road Construction Opposing View #39 - “Today, addressing the adverse impacts of forest roads is consistently identified as one of the highest watershed restoration priorities in U.S. forests—in many forested watersheds in the western United States there is a greater road density than stream density. It is simply irrational to spend millions of dollars subsidizing further forest road construction when we are simultaneously spending millions of dollars to offset detrimental effects associated with similar actions in the past.” Montgomery, David Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm ------Road Construction Opposing View #40 - “Nothing is worse for sensitive wildlife than a road. Over the last few decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity - habitat destruction and fragmentation, edge effects, exotic species invasions, pollution, and overhunting - are aggravated by roads. Roads have been implicated as mortality sinks for animals ranging from snakes to wolves; as displacement factors affecting animal distribution and movement patterns; as population fragmenting factors; as sources of sediments that clog streams and destroy fisheries; as sources of deleterious edge effects; and as access corridors that encourage development, logging and poaching of rare plants and animals.” "Most public agencies disregard the ecological impacts of roads, and attempt to justify timber roads as benefiting recreation and wildlife management. Even when a land manager recognizes the desirability of closing roads, he or she usually contends that such closures would be unacceptable to the public." “The Forest Service and other public agencies will claim that road closures, revegetation, and other restorative measures are too expensive to be implemented on a broad scale. But much of the approximately $400 million of taxpayers' money squandered annually by the Forest Service on below-cost timber sales goes to road-building. Road maintenance is also expensive. Virtually all of this money could be channeled into road closures and associated habitat restoration. This
284 High Valley Integrated Restoration Project Comment Analysis work would be labor-intensive, and providing income to the many laid off loggers, timber sale planners, and road engineers -- for noble jobs, rather than jobs of destruction!” Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the Road to Destruction” Wildlands CPR http://www.wildlandscpr.org/ecological-effects-roads ------Road Construction Opposing View #41 - “Numerous studies have reported lower densities of breeding Ovenbirds (Seiurus aurocapillus) adjacent to forest edges. However, none of these studies has considered habitat use and reproductive success to address mechanisms underlying the observed pattern, and most were conducted in fragmented landscapes and ignored juxtapositions of forest with narrow openings such as roads. We studied the influence of forest roads on Ovenbird density in an extensively forested region of Vermont, evaluating habitat use and reproductive success relative to mechanisms proposed to explain the density-edge relationship. Territory densities on seven study plots were 40% lower within edge areas (0 to 150 m from unpaved roads) than within interior areas (150 to 300 m from roads). We simulated the distribution of Ovenbird territories and concluded that passive displacement, where birds perceive habitat interfaces as boundaries and limit their territories entirely to forest habitat, did not account for the observed density-edge pattern. Territory size was inversely related to distance from roads, providing an alternative explanation for reduced densities near edges and suggesting that habitat quality was higher away from roads. Pairing success was lower within edge areas than within interior zones, but the difference was not statistically significant. The proportion of males that produced fledglings did not differ between edge and interior areas. We conclude that habitat quality for Ovenbirds may be lower within 150 m of unpaved roads in extensive forested landscapes, affecting territory density and possibly reproductive success.” Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): 937-946. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html ------Road Construction Opposing View #42 - “Increasingly, previously extensive, continuous tracts of forest are being reduced to widely dispersed patches of remnant forest vegetation by logging and road-building, but few measures of the effects of roads on forest fragmentation are available. Fragmentation affects animal populations in a variety of ways, including decreased species diversity and lower densities of some animal species in the resulting smaller patches. This study seeks to quantify the effects of roads and logging activities on forest habitat.” “Roads precipitate fragmentation by dissecting previously large patches into smaller ones, and in so doing they create edge habitat in patches along both sides of the road, potentially at the expense of interior habitat. As the density of roads in landscapes increases, these effects increase as well. McGurk and Fong (1995) considered the additive effects of clearcuts and roads, but did not measure the amount of associated edge habitat. Thus a more direct measurement of the impacts of roads on landscapes is needed.” Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution
285 High Valley Integrated Restoration Project Comment Analysis of Roads to Forest Fragmentation in the Rocky Mountains." Conservation Biology 10: 1098-1106. http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm ------Road Construction Opposing View #43 - “Erosion on roads is an important source of fine- grained sediment in streams draining logged basins of the Pacific Northwest. Runoff rates and sediment concentrations from 10 road segments subject to a variety of traffic levels were monitored to produce sediment rating curves and unit hydrographs for different use levels and types of surfaces. These relationships are combined with a continuous rainfall record to calculate mean annual sediment yields from road segments of each use level. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface.” Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml ------Road Construction Opposing View #44 - "Roads are associated with high sediment inputs and altered hydrology, both of which can strongly influence downstream channel habitats. Roads are also important as a source of indirect human impacts and as an agent of vegetation change and wildlife disturbance." "Any ground disturbance increases the potential for erosion and hydrologic change, and roads are a major source of ground disturbance in wildlands. Compacted road surfaces generate overland flow, and much of this flow often enters the channel system, locally increasing peak flows. Localized peak flows are also increased where roads divert flow from one swale into another, and where roadcuts intercept subsurface flows." "Overland flow from the road surface is a very effective transport medium for the abundant fine sediments that usually are generated on road surfaces. Road drainage also can excavate gullies and cause landslides downslope in swales. Cut and fill slopes are often susceptible to landsliding, and road-related landsliding is the most visible forestry-related erosional impact in many areas." Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss 1994. "What do we know about Roads?" USDA Forest Service. http://www.fs.fed.us/psw/publications/reid/4Roads.htm ------Road Construction Opposing View #45 - "Disturbances from roadbuilding and logging changed the sediment/discharge relationship of the South Fork from one which was supply dependent to one which was stream power dependent, resulting in substantial increases in suspended sediment discharges." "Road construction and logging appear to have resulted in increases in average turbidity levels (as inferred from suspended sediment increases) above those permitted by Regional Water Quality Regulations."
286 High Valley Integrated Restoration Project Comment Analysis Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. 1979. "Watershed's Response to Logging and Roads: South Fork of Caspar Creek, California, 1967-1976." USDA Forest Service, Research Paper PSW-146. http://www.fs.fed.us/psw/publications/rice/Rice79.pdf ------Road Construction Opposing View #46 - "Sediment eroded from gravel roads can be a major component of the sediment budget in streams in this region (Van Lear, et al, 1995)." Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road Erosion, Sediment Transport and Model Validation in the Southern Appalachians." Presented at the Second Federal Interagency Hydrologic Modeling Conference, July 28 – August 1, 2002. http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf ------Road Construction Opposing View #47 - “Early studies of elk were among the first to address effects of roads on wildlife, establishing a precedent for subsequent research on a wide range of terrestrial and aquatic species. These early elk-roads studies included those reported in a symposium on the topic in 1975 (Hieb 1976), the seminal studies of Jack Lyon in Montana and northern Idaho (Lyon 1979, 1983, 1984), the Montana Cooperative Elk-Logging Study (Lyon et al. 1985), and work by Perry and Overly (1977) in Washington and Rost and Bailey (1979) in Colorado. As research and analysis techniques have become more sophisticated, particularly with the advent of geographic information systems (GIS) and high-resolution remote imagery, the study of effects of roads on terrestrial and aquatic communities has evolved into a unique discipline of “road ecology” (Forman et al. 2003). Road effects are far more pervasive than originally believed and include such disparate consequences as population and habitat fragmentation, accelerated rates of soil erosion, and invasion of exotic plants along roadways. Indeed, “in public wildlands management, road systems are the largest human investment and the feature most damaging to the environment” (Gucinski et al. 2001:7). Summaries of the effects of roads on wildlife habitats and biological systems in general have been compiled by Forman and Alexander (1998), Trombulak and Frissell (2000), Gucinski et al. (2001), Forman et al. (2003) and Gaines et al. (2003).” Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger 2005. “Effects of Roads on Elk: Implications for Management in Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor, The Starkey Project: a synthesis of long-term studies of elk and mule deer Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf
287 High Valley Integrated Restoration Project Comment Analysis ------Road Construction Opposing View #48 - “The consequences of road construction to wildlife are generally negative. Roads result in increased human access, habitat fragmentation, disturbance, and in some cases direct mortality due to vehicle collisions.” “Research has documented an 80% decline in grizzly bear habitat use within 1 km of open roads used by motorized vehicles in Montana9. This has been ascribed either to bears avoiding humans or to the selective over-harvest of bears habituated to humans that would otherwise more fully use areas heavily influenced by people.” Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads” The Interagency Forest Ecology Study Team (INFEST) newsletter http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm ------Road Construction Opposing View #49 - “The effects of forest roads on hydrology are related to the effects of forest clearing. Most logging requires road access, and the roads often remain after the logging, so there are both short and long-term effects.94 Forest road surfaces are relatively impermeable. Water readily runs over the road surface and associated roadside ditches, often directly to a stream channel, with the net effect of extending channel networks and increasing drainage density.95 In addition to providing conduits for overland flow, forest roads involve slope-cuts and ditching that may intersect the water table and interrupt natural subsurface water movement.96 This diversion of subsurface water may be quantitatively more important than the overland flow of storm water in some watersheds.97 The importance of roads in altering basin hydrology has been underscored in paired-watershed studies and recent modeling studies.98 “ (Pgs. 730 and 731) Shanley, James B. and BeverleyWemple Ph.D. “Water Quantity and Quality in the Mountain Environment” Vermont Law Review, Vol. 26:717, 2002 http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf ------Road Construction Opposing View #50 - "Roads are often the major source of soil erosion from forested lands (Patric 1976)." "Generally, soil loss is greatest during and immediately after construction." Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in the Southern Appalachian Mountains." Southern Journal of Applied Forestry 8: 209-216. 1984. http://cwt33.ecology.uga.edu/publications/403.pdf ------Road Construction Opposing View #51 - “More subtle causes of habitat loss include the construction of roads and power lines. These linear barriers also have been correlated with a decline in neotropical migrant songbirds (Berkey 1993; Boren et al. 1999; Ortega and Capen 2002). Whether by forest conversion or the construction of roads and power lines, fragmentation
288 High Valley Integrated Restoration Project Comment Analysis subdivides habitat into smaller and smaller parcels. The result is an increase of edge habitat, or the boundary between intact forest and surrounding impacted areas. Small forests with large amounts of edge habitat are a hostile landscape for nesting neotropical migratory songbirds. In these areas, songbirds face two great threats: 1) the loss of eggs and nestlings to predators and, 2) parasitism by cowbirds.” Switalski, Adam “Where Have All the Songbirds Gone? Roads, Fragmentation, and the Decline of Neotropical Migratory Songbirds” Wildlands CPR, September 8, 2003 http://www.wildlandscpr.org/node/213 ------Road Construction Opposing View #52 - “Roads are a widespread and increasing feature of most landscapes. We reviewed the scientific literature on the ecological effects of roads and found support for the general conclusion that they are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads of all kinds have seven general effects: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans. Road construction kills sessile and slow- moving organisms, injures organisms adjacent to a road, and alters physical conditions beneath a road. Vehicle collisions affect the demography of many species, both vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly successful. Roads alter animal behavior by causing changes in home ranges, movement, reproductive success, escape response, and physiological state. Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all species and ecosystems are equally affected by roads, but overall the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems. More experimental research is needed to complement post-hoc correlative studies. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic biota.” Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. “Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, February 2000 http://www.transwildalliance.org/resources/200922144524.pdf ------Road Construction Opposing View #53 - "Roads are a major contributor to habitat fragmentation because they divide large landscapes into smaller patches and convert interior habitat into edge habitat. As additional road construction and timber harvest activities increase habitat fragmentation across large areas, the populations of some species may become isolated, increasing the risk of local extirpations or extinctions (Noss and Cooperrider 1994)."
289 High Valley Integrated Restoration Project Comment Analysis "Habitat fragmentation creates landscapes made of altered habitats or developed areas fundamentally different from those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994 in Meffe et al. 1997). Adverse effects of habitat fragmentation to both wildlife populations and species include: "Increased isolation of populations or species, which leads to: • Adverse genetic effects; i.e. inbreeding depression (depressed fertility and fecundity, increased natal mortality) and decreased genetic diversity from genetic drift and bottlenecks, • Increased potential for extirpation of localized populations or extinction of narrowly distributed species from catastrophic events such as hurricanes, wildfires or disease outbreaks, • Changes in habitat vegetative composition, often to weedy and invasive species, • Changes in the type and quality of the food base, • Changes in microclimates by altering temperature and moisture regimes, • Changes in flows of energy and nutrients, • Changes in the availability of cover and increases edge effect, bringing together species that might otherwise not interact, potentially increasing rates of predation, competition and nest parasitism, and • Increased opportunities for exploitation by humans, such as poaching or illegal collection for the pet trade." Watson, Mark L. "Habitat Fragmentation and the Effects of Roads on Wildlife and Habitats." Background and Literature Review 2005. http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/2004EffectsofRoadso nWil dlifeandHabitats.pdf ------Road Construction Opposing View #54 - "Our analysis also indicated that >70 percent of the 91 species are affected negatively by one or more factors associated with roads." "Roads in forested areas increase trapping pressures for martens and fishers, resulting in significantly higher captures in roaded versus unroaded areas (Hodgman and others 1994) and in logged versus unlogged areas, in which the difference was again attributed to higher road densities in logged stands (Thompson 1994). Secondary roads also might increase the likelihood that snags and logs will be removed for fuel wood. This could impact fishers, martens and flammulated owls, and also could have a negative effect on the prey base for goshawks (Reynolds and others 1992)." "An additional, indirect effect of roads is that road avoidance leads to underutilization of habitats that are otherwise high quality." Wisdom, Michael J., Richard S. Holthausen Ph.D. Barbara C. Wales Ph.D., Christina D. Hargis Ph.D. Victoria A. Saab Ph.D., Danny C. Lee Ph.D.
290 High Valley Integrated Restoration Project Comment Analysis Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications Vo l ume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000. http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wisdom_et_al_2000/Vol_2 a.pdf ------Road Construction Opposing View #55 - “According to the DEIS, the Forest now manages a total of 5,914 miles of roads across the Forest. Scientific literature has established that roads have numerous widespread, pervasive and, if left untreated, long-lasting biological and physical impacts on aquatic ecosystems that continue long after completion of construction. (Angermeier et al. 2004). Roads increase surface water flow, alter runoff patterns, alter streamflow patterns and hydrology, and increase sedimentation and turbidity. Roads are the main source of sediment to water bodies from forestry operations in the United States. (US EPA 2002). Road construction can lead to slope failures, mass wasting and gully erosion. Road crossings can act as barriers to movement for fish and other aquatic organisms, disrupting migration and reducing population viability. (Schlosser and Angermeier 1995). Chemical pollutants that enter streams via runoff, such as salt and lead from road use and management, compound these impacts. Most of these adverse effects are persistent and will not recover or reverse without human intervention. The techniques for road remediation are well established, agreed upon and readily available. (Weaver et al. 2006).” (Pg. 2) Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou National Forest Travel Management Team http://www.pacificrivers.org/protection-defense/comment- letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf ------Road Construction Opposing View #56 - “Fires do not leave a large road network in place (assuming the blaze was not suppressed otherwise there may be dozer lines, etc.). Logging creates roads that fragment habitat and generally increase human access, both of which affect the use of the land by wildlife. Moreover, roads and logging equipment can become vectors for the dispersal of weeds.” Wuerthner, George 2008 “Ecological Differences between Logging and Wildfire” http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html ------Road Construction Opposing View #57 - “Forest fragmentation occurs when large, contiguous blocks of forest are broken up into isolated islands by development, roads, or clearing for agriculture. Just as inbreeding among the royal families of Europe spread hemophilia, forest
291 High Valley Integrated Restoration Project Comment Analysis fragmentation negatively impacts the long term sustainability of both plant and animal communities. Geographic isolation results in inbreeding and diminishes biodiversity.” Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Land Trust newsletter, 2004 http://www.ourbetternature.org/forestfrag.htm
292 High Valley Integrated Restoration Project Comment Analysis Opposing Views Attachment #11 Caring USFS Officials will Always Take the Most Effective Action Available to Reduce the Risk Of Homes Burning and Loss of Life should a Wildfire Start Near Neighborhoods Located in the Woods Not Analyzing an Alternative in Detail that Applies Dr. Cohen’s Fine Fuels Removal Methods Discussed below Indicates the Responsible USFS Official Believes Timber Removal resulting from Hazardous Fuels Reduction Logging is more Important than Preventing Homes from Burning Dr. Cohen’s background Dr. Jack Cohen is a research fire physicist who does his research in the Forest Service's Missoula Fire Sciences Laboratory at the Rocky Mountain Research Station. Dr. Cohen is a Forest Service employee. His research findings clearly show that commercial logging to reduce fuels will not protect homes from wildfire damage in the Wildland Urban Interface (WUI). Dr. Cohen’s Research Findings Represent Best Science and Empirical Evidence Shows his Fire Damage Risk Reduction Methods that remove the Fine Fuels Near the Home are Far Superior to Hazardous Fuel Removal Dr. Cohen Is likely the only Ph.D. fire physicist in America who specializes in determining the best actions to reduce the risk of wildfire damage to homes. Dr. Cohen is a well published scientist-author. He has published 12 peer-reviewed scientific papers summarizing his research findings. ------Independent Sources Emphasize the Effectiveness of Dr. Cohen’s Fire Damage Risk Reduction Methods “Homeowners are their own first line of defense. Saving a home from wildfire depends primarily 8 on two factors: roofing material and the quality of the “defensible space” surrounding it. Research Physical Scientist Jack Cohen noted after visiting homes that survived the Rodeo- Chediski Fire and those that were consumed, that had homeowners followed guidelines for creating defensible space—described as creating an area around a structure where fuels and vegetation are treated, cleared, or reduced to slow the spread of fire—more homes would have survived.” Fact Sheet: Understanding Fire and Fire Behavior Ontario Aviation and Forest Fire Management http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf ------Dr. Cohen’s opposing view #1 - “Research results indicate that the home and its immediate surroundings within 100-200 feet (30-60 meters) principally determines the home ignition potential during severe wildland-urban fires. Research has also established that fire is an intrinsic ecological process of nearly all North American ecosystems. Together, this understanding forms
293 High Valley Integrated Restoration Project Comment Analysis the basis for a compelling argument for a different approach to addressing the wildland-urban fire problem.” (Pg. 1 – abstract) Source: Wildland-Urban Fire—A different approach http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf ------Dr. Cohen’s opposing view #2 - “A senior physicist at the Stanford Research Institute, C.P. Butler (1974), coined the term "urban-wildland interface" and described this fire problem as follows: "In its simplest terms, the fire interface is any point where the fuel feeding a wildfire changes from natural (wildland) fuel to man-made (urban) fuel.” (Pg. 1) Dr. Cohen’s opposing view #3 - “The results of the diverse analytical methods are congruent and consistently indicate that ignitions from flames occur over relatively short distances--tens of meters not hundreds of meters. The severe-case estimate of SIAM indicates distances of 40 meters or less. Experimental wood walls did not ignite at 10 meters when exposed to experimental crown fires. And, case studies found that vegetation clearance of at least 10 meters was associated with a high occurrence of home survival.” (Pg. 4) Dr. Cohen’s opposing view #4 - “Analyses of southern California home losses done by the Stanford Research Institute for the 1961 Belair-Brentwood Fire (Howard and others 1973) and by the University of California, Berkeley, for the 1990 Painted Cave Fire (Foote and Gilless 1996) are consistent with SIAM estimates and the experimental crown fire data. Given nonflammable roofs, Stanford Research Institute (Howard and others 1973) found a 95 percent survival with a clearance of 10 to 18 meters and Foote and Gilless (1996) at Berkeley, found 86 percent home survival with a clearance of 10 meters or more.” (Pgs. 3 and 4) Dr. Cohen’s opposing view #5 - “Extensive wildland vegetation management does not effectively change home ignitability.” (Pg. 5) Dr. Cohen’s opposing view #6 - “Home ignitability also dictates that effective mitigating actions focus on the home and its immediate surroundings rather than on extensive wildland fuel management. Because homeowners typically assert their authority for the home and its immediate surroundings, the responsibility for effectively reducing home ignitability can only reside with the property owner rather than wildland agencies.” (Pg. 5) Dr. Cohen’s opposing view #7 - “As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5) Dr. Cohen’s opposing view #8 - “Home ignitability implies that homeowners have the ultimate responsibility for WUI home fire loss potential. As shown, the ignition and flammability characteristics of a structure and its immediate surroundings determine the home fire loss potential. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for WUI home fire loss, is the homeowner's choice and responsibility.” (Pg. 5) Dr. Cohen’s opposing view #9 - “However, public and management perceptions may impede homeowners from taking principal responsibility. For example, the Federal Wildland Fire Management, Policy and Program Review (1995) observes, ‘There is a widespread
294 High Valley Integrated Restoration Project Comment Analysis misconception by elected officials, agency managers, and the public that wildland/urban interface protection is solely a fire service concern.’ In a Journal of Forestry article, Beebe and Omi (1993) concur, stating that, ‘Public reaction to wildfire suggests that many Americans want competent professionals to manage fire flawlessly, reducing the risks to life, property, and public lands to nil.’ These statements agree with Bradshaw's (1988) description of the societal roles in the WUI problem. He observes that homeowners expect that fire protection will be provided by others. Contrary to these expectations for fire protection, the fire services have neither the resources for effectively protecting highly ignitable homes during severe WUI fires, nor the authority to reduce home ignitability.” (Pg. 6) Source for quotes #2 to #9 above: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf ------Dr. Cohen’s opposing view #10 - “Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands.” (Pg. 4) Dr. Cohen’s opposing view #11 - “Past reports and recommendations as well as experimental research and modeling suggest that W-UI fire-loss mitigation should concentrate on the residence and its immediate surroundings. Any strategy for effectively reducing the W-UI fire problem must initially focus on residential fire resistance.” (Pg. 5 – Conclusion) Dr. Cohen’s opposing view #12 - “Instead of all fire protection responsibilities residing with fire agencies, homeowners take responsibility for assuring firewise conditions and the initial fire defense of their residences during wildland fires. The fire agencies become a community partner that provides information, coordinates and assists in meeting firewise requirements, and provides fire suppression assistance.” (Pg. 5) Source for quotes #10 to #12 above: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf ------Dr. Cohen’s opposing view #13 - “My examination suggests that the abundance and ubiquity of pine needles, dead leaves, cured vegetation, flammable shrubs, wood piles, etc. adjacent to, touching and or covering the homes principally contributed to the residential losses.” (Pg. 4) Source: Examination of the Home Destruction in Los Alamos Associated with the Cerro Grande Fire July 10, 2000 Source: USDA Forest Service, Rocky Mountain Research Station, Missoula, Montana, 2000. http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20copy.pdf ------
295 High Valley Integrated Restoration Project Comment Analysis Dr. Cohen’s opposing view #14 - "The wildland fire management approach for preventing WUI fire disasters largely addresses the wildfire outside the home ignition zone rather than a home's ignition potential as determined by the conditions within the home ignition zone. Since 2000, agency fire management policy initiatives have emphasized fire suppression." (Pg. 24) Dr. Cohen’s opposing view #15 - "Preventing WUI fire disasters requires that the problem be framed in terms of home ignition potential. Because this principally involves the home ignition zone, and the home ignition zone primarily falls within private ownership, the responsibility for preventing home ignitions largely falls within the authority of the property owner. Preventing wildfire disasters thus means fire agencies helping property owners mitigate the vulnerability of their structures. The continued fire management focus on fire suppression suggests the WUI fire problem persists largely as a consequence of framing the WUI fire problem primarily in terms of the fire exclusion paradigm." (Pg. 25) Dr. Cohen’s opposing view #16 - "The continued focus on fire suppression largely to the exclusion of alternatives that address home ignition potential suggests a persistent inappropriate framing of the WUI fire problem in terms of the fire exclusion paradigm." (Pg. 25) Source for quotes #14 to #16 above: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf ------Dr. Cohen’s opposing view #17 - “For the same reason, mitigating home ignition potential during extreme wildland fires must focus activities within and immediate to the residential area, i.e. the home ignition zone. But the home ignition zone largely corresponds to private property. Thus, with minor exception, the authority for effectively reducing the home ignition potential belongs to homeowners. Public land management agencies can facilitate homeowner mitigations and these agencies may be able to reduce fire intensities and the extent of burning around communities. But these agencies cannot accomplish the necessary and sufficient actions necessary to prevent residential fire disasters during extreme fire conditions by treating beyond the home ignition zone.” (Pg. 2) Source: Thoughts on the Wildland-Urban Interface Fire Problem, June 2003 http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf ------Dr. Cohen’s opposing view #18 - “A home with its immediate surroundings (about 100-150 feet from the structure) is called the Home Ignition Zone. Many factors about the HIZ determine the potential for ignition during a wildland fire, such as flammable wood roofs and materials like trees, grass, decks, or adjacent structures leading up to a home.” (Pg. 1) Source: Saving Homes from Wildfires: Regulating the Home Ignition Zone Published in Zoning News, May 2001 http://www.battle-creek.net/docs/fire/Zoning.pdf ------Dr. Cohen’s opposing view #19 - “SIAM calculations indicate that large wildland flame fronts (e.g., forest crown fires) will not result in piloted wood ignitions (e.g., the typical variety of exterior wood walls) at distances greater than 40 meters (Cohen and Butler [In press]).” (Pg. 4)
296 High Valley Integrated Restoration Project Comment Analysis Dr. Cohen’s opposing view #20 - “Field studies conducted during the International Crown Fire Modeling Experiment (Alexander et al. 1998) provided measured data for comparisons with SIAM model estimates. Total heat transfer (radiation and convection) and ignition data were obtained from heat flux sensors placed in wooden wall sections. The instrumented walls were located on flat, cleared terrain at 10, 20, and 30 meters downwind from the edge of the forested plots. The forest was variably composed of an overstory of jack pine (Pinus banksiana) about 13 meters high with an understory of black spruce (Picea mariana). The spreading crown fire produced flames approximately 20 meters high.” (Pg. 5) Dr. Cohen’s opposing view #21 - “Five burns were conducted where wall sections were exposed to a spreading crown fire. As the crown fires reached the downwind edge of the plot, turbulent flames extended into the clearing beyond the forest edge. In two of the five burns, flames extended beyond 10 meters to make contact with the wall section placed at 10 meters from the forest edge. When flame contact occurred, the walls ignited; however, without flame contact, only scorch occurred. The wooden panels at 20 and 30 meters never ignited and the panel at 30 meters never scorched.” (Pg. 6) Dr. Cohen’s opposing view #22 - “Case studies of actual W-UI fires provide an independent comparison with SIAM and the crown fire experiments. The actual fires incorporate a wide range of fire exposures. The case studies chosen examine significant factors related to home survival for two fires that destroyed hundreds of homes. The Bel Air fire resulted in 484 homes destroyed (Howard et al. 1973) and the Painted Cave fire destroyed 479 homes (Foote 1994). Analyses of both fires indicate that home ignitions depend on the characteristics of a home and its immediate surroundings. Howard et al. (1973) observed 95 percent survival for homes with nonflammable roofs and a vegetation clearance of 10 to 18 meters. Foote (1994) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 7) Dr. Cohen’s opposing view #23 - “The high survival rate for homes with nonflammable roofs and 10-20 meter vegetation clearances included firebrands as an ignition factor, thus indicating that firebrand ignitions also depend on the ignition characteristics of the home and the adjacent flammable materials.” (Pg. 8) Dr. Cohen’s opposing view #24 - “Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-UI fire loss problem.” (Pg. 9) Dr. Cohen’s opposing view #25 - “Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction.” (Pg. 10) Dr. Cohen’s opposing view #26 - “Fire losses depend on home ignitions and home ignitions depend on home ignitability. Thus, home ignitability, being limited to a home and its immediate surroundings, offers us the opportunity to separate the W-UI structure fire loss problem from other landscape-scale fire management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as identifying and mapping the potential for W-UI residential fire destruction, identifying appropriate and effective mitigating actions, and determining who should take responsibility for home ignitability.” (Pg. 10) Dr. Cohen’s opposing view #27 - “Thus, wildland fuel reduction that is effective for reducing the wildland fire intensity might be insufficient for reducing the destruction of highly ignitable homes. In contrast, a low home ignition potential reduces the chances of fire destruction without
297 High Valley Integrated Restoration Project Comment Analysis extensive wildland fuel reduction. These findings indicate that the W-UI home fire loss problem is a home ignitability issue largely independent of landscape fuel reduction issues.” (Pg. 10) Dr. Cohen’s opposing view #28 - “The extent of the home ignition zone corresponds more to specific home and community ownership than to the landscapes of federal, state and local land management agencies. This suggests a corresponding responsibility for W-UI home fire loss potential residing with homeowners and communities. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for W-UI home fire loss, is a homeowner and community choice and responsibility.” (Pg. 11) Source for quotes #19 to #28 above: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf ------Dr. Cohen’s opposing view #29 - “Model results indicate that ignitions from flame radiation are unlikely to occur from burning vegetation beyond 40 meters of a structure. Thinning vegetation within 40 meters has a significant ignition mitigation effect.” (Pg. 81) Dr. Cohen’s opposing view #30 - “Vegetation management to prevent ignitions from radiation does not require extensive vegetation removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for a 20 meter flame height.” (Pg. 86 – Conclusions) Source for quotes #29 and #30 above: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management Presented at the 13th Fire and Forest Meteorology Conference. Lorne, Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf ------Dr. Cohen’s opposing view #31 - “Miracles aside, the characteristics of the surviving home and its immediate surroundings greatly influenced its survival.” (Pg. 15) Dr. Cohen’s opposing view #32 - “Based on severe-case assumptions of flame radiation and exposure time, SIAM calculations indicate that wild-land flame fronts comparable to crowning and torching trees (flames 20 meters high and 50 meters wide) will not ignite wood surfaces at distances greater than 40 meters (Cohen and Butler, in press). Figure 2 shows the radiant heat a wall would receive from flames depending on its distance from the fire. The incident radiant heat flux, defined as the rate of radiant energy per unit area received at an exposed surface, decreases as the distance increases.” (Pg. 17) Dr. Cohen’s opposing view #33 - “Analyses of both fires indicate that home ignitions depend on the characteristics of a structure and its immediate surroundings. Howard et al. (1973) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 19) Dr. Cohen’s opposing view #34 - “Using the model results as guidance with the concurrence of experiments and case studies, we can conclude that home ignitions are not likely unless flames and firebrand ignitions occur within 40 meters of the structure. This finding indicates that the spatial scale determining home ignitions corresponds more to specific home and community sites
298 High Valley Integrated Restoration Project Comment Analysis than to the landscape scales of wildland fire management. Thus, the W-UI fire loss problem primarily depends on the home and its immediate site.” (Pg.20) Dr. Cohen’s opposing view #35 - “Thus, the W-UI fire loss problem can be defined as a home ignitability issue largely independent of wildland fuel management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as defining and locating potential W-UI fire problems (for example, hazard assessment and mapping), identifying appropriate mitigating actions, and determining who must take responsibility for home ignitability.” (Pg.20) Dr. Cohen’s opposing view #36 - “The W-UI fire case studies indicated approximately 90 percent survival with a vegetation clearance on the order of 10 to 20 meters for homes with nonflammable roofs. Thus, the case studies support the general flame-to-structure distance range of 10 to 40 meters as found through modeling and experiments.” (Pg.20) Dr. Cohen’s opposing view #37 - “A change needs to take place in the relationship between homeowners and the fire services. Instead of home-related presuppression and fire protection responsibilities residing solely with fire agencies, homeowners must take the principal responsibility for ensuring adequately low home ignitability.” (Pg.21) Source for quotes #31 to #37 above: Preventing Disaster Home ignitability in the Wildland- Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf ------Dr. Cohen’s opposing view #38 - “Many scientists and natural resource agencies suggest extensive fuel treatments to reduce the possibility of severe and intense wildfires that could damage ecosystems, destroy property, and take human life (USDA Forest Service, 2000; GAO, 2003a,b). However, there are a number of misconceptions and misunderstandings about fuel treatments and their use as a panacea for fire hazard reduction across the United States (Finney and Cohen, 2003; Franklin and Agee, 2003).” (Pg.1998) Dr. Cohen’s opposing view #39 - “Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ‘‘fire-proof’’ important areas. It would be virtually impossible to exclude fire from most temperate terrestrial ecosystems because ignition sources are prevalent and fuels cannot be eliminated. Ignition is rarely affected by fuel treatment.” (Pg.1998) Dr. Cohen’s opposing view #40 - “Treating fuels to facilitate suppression is an example in circular logic. If fuel treatment makes suppression more successful in general, then less area will be burned in the short run and more acreage will tend to burn under extreme conditions, when suppression is ineffective. The inevitable result is that more area is burned in fewer, more unmanageable events with greater consequences. In addition, fire suppression leads to continued fuel accumulation and, in turn, more difficult conditions for suppression. This phenomenon has been described as ‘‘the wildland fire paradox’’ (Brown and Arno, 1991). Rather than creating conditions where fire is easier to suppress, fuel treatments should strive to create conditions where fire can occur without the need for suppression.” (Pg.1998) Dr. Cohen’s opposing view #41 - “Bessie and Johnson (1995) show weather (fuel moisture and wind) is far more important than fuels in determining fire behavior; reducing fuels may have a limited impact on fire occurrence.” (Pg.1999)
299 High Valley Integrated Restoration Project Comment Analysis Dr. Cohen’s opposing view #42 - “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999) Dr. Cohen’s opposing view #43 - “Since the home ignition zone largely occurs on private lands, most land management agencies do not have the authority to mitigate the WUI ignition potential directly (Cohen, 2000b). However, the opportunity exists to explicitly define responsibilities for the WUI fire potential (i.e. the home ignition zone) consistent with areas of jurisdiction and separately from ecological wildfire issues.” (Pg.1999) Dr. Cohen’s opposing view #44 - “It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, and the degree to which the residential structures themselves can ignite that determine if the residences are vulnerable.” (Pg.1999) Dr. Cohen’s opposing view #45 - “WUI fuel treatments can be designed such that an extreme wildfire can occur in the WUI without having a residential fire disaster. Although general wildfire control efforts may not benefit from fuel treatments during extreme fire behavior, fuel modifications can significantly change outcome of a wildfire within a treatment area. Research has shown that a home’s characteristics and its immediate surroundings principally determine the WUI ignition potential during extreme wildfire behavior (Cohen, 2000a,c, 2003, 2004). The area that primarily determines WUI ignition potential is called the home ignition zone (Cohen, 2001). WUI fuel treatments can address the home ignition zone by removing flammable materials immediately adjacent to residences.” )Pg. 1999) Dr. Cohen’s opposing view #46 - “Treating fuels may not reduce suppression expenditures. It is a natural mistake to assume that a successful fuel treatment program will result in reduced suppression expenditures. Suppression expenditures rarely depend directly on fuel conditions, but rather on fire location and on what resources are allocated to suppression. The only certain way to reduce suppression expenditures is to make a decision to spend less money suppressing fires.” (Pg. 2000) Dr. Cohen’s opposing view #47 - “Thinning to reduce crown fire potential requires careful evaluation of the tradeoffs in treatment effects on potential surface fire behavior and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result in increased potential surface fire behavior, for several reasons. First, thinning reduces the moderating effects of the canopy on windspeed, so surface windspeed will increase (Graham et al., 2004). It also results in increased solar radiation on the forest floor, causing drier surface fuels. It may also cause an increase in flammable grassy and shrub fuels over time, due to the reduced tree competition.” (Pg.2000) Dr. Cohen’s opposing view #48 - “Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000) Dr. Cohen’s opposing view #49 - “Treating fuels may not improve ecosystem health. Ecosystem restoration treatment and fuel treatment are not synonymous. Some ecosystem restoration treatments reduce fuel hazard, but not all fuel treatments restore ecosystems. Ecosystem restoration treatments are often designed to recreate presettlement fire regimes, stand structures and species compositions while fuel treatment objectives are primarily to reduce fuels to lessen fire behavior or severity—this is known as ‘’hazard Reduction.’’ Achieving fuel hazard reduction goals in the absence of ecosystem restoration is insufficient (Dombeck et al., 2004; Kauffman, 2004).” (Pg.2000) 300 High Valley Integrated Restoration Project Comment Analysis Dr. Cohen’s opposing view #50 - “Conversely, some fuel treatments can reduce fuels but create stands that are quite dissimilar from their historical analogs. Examples include mastication treatments that break, chip, or grind canopy and surface woody material into a compressed fuelbed and thinning treatments that remove the fire adapted species and leave shade-tolerant, late successional species.” (Pg.2000) Source for quotes #38 to #50 above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf ------Concluding Comments Nearly all Forest Service projects that claim to lessen the risks to homeowners living in the WUI propose to reduce hazardous fuels. The NEPA documents that analyze these fuels reduction treatments conveniently do not mention Dr. Cohen’s methods because the Purpose & Need is to reduce fuels … not (emphasis added) to protect homeowners as it should be. Reducing hazardous fuels is an alternative way to lessen the risks to homeowners living in the WUI. It is definitely not a goal or objective unto itself and should never appear in the Purpose & Need. However there is a reason most USFS line-officers deal with WUI risks this way. They know hazardous fuels reduction treatments include the logging of merchantable trees which produces volume and helps them meet their supervisor’s volume expectations and spends the allocated “timer” money each FY. Line-Officers who propose hazardous fuels reduction projects are clearly more interested in accumulating volume than they are protecting the public in the WUI. There are laws that prohibit such actions by a public servant whose salary is partially paid by the families living in the WUI.
301 High Valley Integrated Restoration Project Comment Analysis Attachment #15 Forest Service Leaders Stress that the USFS Bases it’s Projects on Best Science USFS leader statement on best science #1 - "The agency has been able to face changing and challenging times and incorporate new information based on science." "I am very much involved in trying to integrate the science and the management sides of the Forest Service. It’s very, very important that we conduct that integration, because our management decisions are scientifically based, and there is an ever increasing need for more scientific information." Excerpts from an interview with Hilda Diaz-Soltero Associate Chief for Natural Resources, USDA Forest Service Women in Natural Resources, Vol. 21, No. 3 August 2000 http://www.fs.fed.us/publications/2000/00nov02-Hilda-Diaz-Soltero-Interview.pdf ------USFS leader statement on best science #2 - "Forest Service managers strive to use the best science available in their decision making." Dr. Ann Bartuska, Deputy Chief for Research and Development, USDA Forest Service Excerpt from testimony before the House Resources Forest and Forest Health Subcommittee July 15, 2004 http://www.fs.fed.us/congress/108/house/oversight/bartuska/071504.html ------USFS leader statement on best science #3 - "We are committed to accomplishing the aggressive treatments planned in the President’s Budget for FY 2005 using new authorities in the Healthy Forests Restoration Act that improve the condition class of the nation’s watersheds and thus protect communities and resources for future generations, and our Research Station directors are committed to providing the Forest Service with the best science available." Dale Bosworth Chief, USDA Forest Service Excerpt from a statement before the Committee on Energy and Natural Resources United States Senate March 3, 2004 http://www.pirate4x4.com/forum/land-use-issues/232684-statement-dale-n-bosworth-chief-usda- forest-service.html ------USFS leader statement on best science #4 - “Our direction will address these emerging issues to ensure it is based on the available best science.” Sally Collins Associate Chief USDA Forest Service
302 High Valley Integrated Restoration Project Comment Analysis Excerpt from testimony before the Committee on Energy and Natural Resources, United States Senate July 11, 2006 http://www.fs.fed.us/congress/109/senate/oversight/collins/071106.html ------USFS leader statement on best science #5 - "The American people have come to expect us to use the best science, and we ought to use the best science." (pg.4) Dale N. Bosworth Chief USDA Forest Service Excerpt from a speech on Sustainable Management of the National Forests, at the Andrus Center for Public Policy, Boise State University December 12, 2001 http://www.andruscenter.org/images/transcripts/Sustainable_transcript.pdf ------USFS leader statement on best science #6 - "Always use the best science. Science can’t decide for us, but it can help us understand the consequences of our decisions. Forest Service Research and others in academia can deliver some of the best science and technical resources to help inform how these special areas should be managed for the long term." Sally Collins Associate Chief USDA Forest Service Excerpt from a speech to the Land Trust Alliance Rally “Protecting Open Spaces: Partners in a Common Cause” October 31, 2004 http://www.fs.fed.us/news/2004/speeches/10/open-spaces.shtml ------USFS leader statement on best science #7 - "The new rule directs forest managers to use the best science available to protect species at a landscape level. The emphasis is to preserve ecosystems as a whole." Statement by Heidi Valetkevitch National Media Officer USDA Forest Service to Joe Bauman, reporter for the Deseret Morning News December 24, 2004 http://www.deseretnews.com/article/600100084/New-forest-rules-focus-on-holistic- approach.html ------USFS leader statement on best science #8 - On June 29, 2007, Chief of the Forest Service, Gail Kimbell expressed her support of employees participating in professional societies. The following is an excerpt from her support letter: “As stewards of forests and rangelands, we must respond to the many challenges of managing a wide variety of resources and values. To meet these various challenges, a diverse and highly
303 High Valley Integrated Restoration Project Comment Analysis qualified cadre of natural resource and other professionals is critical to assure that management approaches are based on the best science. More than ever, it is important for each of us to continue to learn, enhance our resource knowledge, and develop innovative approaches to cooperatively conserve this Nation’s natural resources.” (pg. 5) Brown, Joel “Power to the People!” SRM Rangeland News, November 2007 http://www.rangelands.org/RN/Nov.RN07.pdf ------USFS leader statement on best science #9 - “The Forest Service must be a leader in using the best science and the best managers to accomplish what I think is one of the noblest, most important callings of our generation bringing people together and helping them find ways to live within the limits of the land." (Pg. 30) Statement by Chief Dr. Mike Dombeck “Forest Chief Shifts focus to clean water” April 1998 TRANSITIONS http://www.waterplanet.ws/transitions/tr9804/ ------USFS leader statement on best science #10 - “We have made great progress under New Perspectives to get land managers and scientists working together as a team in doing the best job possible. Let’s keep it up and make sure our decisions reflect the best science and close the gap between the level of scientific knowledge and its application in our day-to-day management.” Chief F. Dale Robertson From FIVE YEAFt REVIEW - B-3 # # http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_053856.pdf ------USFS leader statement on best science #11 - “In 1994 Chief Jack Ward Thomas of the U.S. Forest Service invited private foundations to join the USFS and other federal resource management agencies in co-funding a national workshop designed to bring the best science, broadly defined, to an 11-day workshop of agency natural resource managers.1 Having a science background himself, Thomas wanted to capture the scientific underpinnings of ecosystem dynamics in order to establish a more solid basis for sustainable resource management. Private foundations, invited for the first time to join the Forest Service in this way, would, Thomas felt, add legitimacy and assist in bringing in scientific talent from outside the government.” Smith, Ted “Chief's Ecosystem Stewardship Conference Workshop Review” Eco-Watch, February 26, 1996 http://www.fs.fed.us/eco/eco-watch/ew960226.htm ------USFS leader statement on best science #12 - "Our challenge is to protect all the different uses of our forests which well-kept roads undoubtedly serve while protecting these remaining
304 High Valley Integrated Restoration Project Comment Analysis untouched places. This is a long and delicate process. It will not happen overnight. We must rely on the best science and broad-based public participation. But in the interim, I am prepared to authorize an 18-month moratorium on the construction of new roads in the last pristine areas of our national forests.” Agriculture Secretary Dan Glickman From an Announcement of Interim Ban on Forest Road Construction Washington, D.C., February 11, 1999 http://www.ibiblio.org/london/permaculture/permaculture-list-archives-1999- 2002/msg04621.html ------USFS leader statement on best science #13 - “We have some of the best science, and we need to make sure we’re applying that, using that and sharing that as we move forward. I think we have a key leadership role, not only in the application of science but to help inform and educate our community and the folks we work with.” Statement by USFS Chief Tom Tidwell From an interview with Rob Chaney of the Missoulian, June 19, 2009 http://westinstenv.org/sosf/2009/06/19/tidwell-interviewed-by-the-missoulian/ ------USFS leader statement on best science #14 - “Since that time, they have consulted with a wide array of scientists in the Forest Service, other agencies, universities, and consultants, with the aim of arriving at a consensus on the best science available to address this issue.” Potyondy, John P. 2007 “The Evolution of Channel Maintenance Science in the Forest Service” Mr. Potyondy is the WO Watershed, Fish, Wildlife, Air, and Rare Plants Staff http://www.stream.fs.fed.us/afsc/pdfs/Potyondy.pdf ------USFS leader statement on best science #15 - “The FS manages the National Forest System's natural resources with a commitment to long term ecosystem sustainability, multiple use, local community involvement and economic stability, interaction of social and cultural values with forest resource management, and the use of management practices based on the best science available.” Melle, Ann R. “The U.S. Forest Service Approach to Forest Law Enforcement” A presentation to the East Asia Ministerial Conference, September 12, 2001 Ms. Melle is the Asst. Director of Law Enforcement and Investigations, USDS Forest Service http://www.for.gov.bc.ca/hfd/library/documents/bib49682.pdf ------USFS leader statement on best science #16 - “ “The responsible policy maker ought to seek out the best science, because ultimately that will yield the best result.". “
305 High Valley Integrated Restoration Project Comment Analysis “To put things in perspective, Dombeck says, "Science should not be the only driver of policy; there are economic, social and political concerns, but ... scientists can provide information that informs policymaking; 'If we adopt this policy, this will be the outcome,' and that certainly does not appear to be happening." “ Statements by retired Chief Dr. Mike Dombeck “Politics vs. Science,” October 19, 2006 Published by the University of Wisconsin, Board of Regents. http://whyfiles.org/247sci_politics/index.php?g=5.txt ------USFS leader statement on best science #17 - “Carefully done science can provide common ground for agreement among different stakeholders, enabling communities to unify.” “The best science available tells us that at some point we must reinstall this missing ecosystem process so the natural machinery functions properly again.” (pg. 9) Kaufmann, Merrill R. 2005 “Good Fire,Bad Fire” Mr. Kaufmann is the Rocky Mountain Research Station's team leader for ecosystem management Fort Collins, CO, USDA Forest Service http://csfs.colostate.edu/pdfs/Good_Fire_Bad_Fire.pdf ------USFS leader statement on best science #18 - “The general objective of this Symposium was to build on the best science and technology available to assure that the data and information produced in future inventory and monitoring programs are comparable, quality assured, available, and adequate for their intended purposes, thereby providing a reliable framework for characterization, assessment, and management of forest ecosystems in North America.” Bravo, Aguirre Celedonio and Carlos Rodriguez Franco, compilers 1999. North American Science Symposium: Toward a Unified Framework for Inventorying and Monitoring Forest Ecosystem Resources. Guadalajara, Mexico (November 2-6,1998). Proceedings RMRS-P-12. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station http://cwt33.ecology.uga.edu/publications/pubs_martha_new_01282003/Batch_2_@300dpi/PDF /1389.pdf ------USFS leader statement on best science #19 - “The experience of the Zaca Fire demonstrates a window of opportunity to improve the link between science and management. A major concern often expressed in both fire research and fire management circles is that there is a lot of science being produced, but very little that can or is being incorporated (depending on your perspective) into fire management. There may be a current opening to change that state of affairs.” McDaniel, Josh 2007 “The Zaca Fire: Bridging Fire Science and Management” Widland Fire Lessons Learned,
306 High Valley Integrated Restoration Project Comment Analysis http://www.wildfirelessons.net/Additional.aspx ------USFS leader statement on best science #20 - “Accordingly, we find that the Final EIS fails to disclose and discuss responsible opposing scientific viewpoints in the final statement itself in violation of NEPA and the implementing regulations. We therefore reverse the district court's grant of summary judgment and remand to the district court with directions that it remand the final statement to the Forest Service for further proceedings consistent with this opinion. See Vitarelli v. Seaton, 359 U.S. 535, 545, 79 S.Ct. 968, 3 L.Ed.2d 1012 (1959) (standing for the well-established principle that an agency is generally required to follow its regulations); see also Cal. v. Block, 690 F.2d at 769 (“Agencies are ․ obliged to adhere to the procedures mandated by NEPA.”) (citing Vt. Yankee Nuclear Power Corp. v. Natural Res. Def. Council, Inc., 435 U.S. 519, 549 n. 21, 98 S.Ct. 1197, 55 L.Ed.2d 460 (1978)). REVERSED AND REMANDED.” CENTER FOR BIOLOGICAL DIVERSITY v. UNITED STATES FOREST SERVICE Argued and Submitted July 15, 2003. -- November 18, 2003 Before: KLEINFELD, WARDLAW, Circuit Judges, and POGUE, Judge. In the United States Court of Appeals,Ninth Circuit http://caselaw.findlaw.com/us-9th-circuit/1173711.html
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