Grand Mesa, Uncompahgre, Gunnison National Forest

February 4, 2015

Scott Armentrout Forest Supervisor Grand Mesa, Uncompahgre, Gunnison National Forest 2250 Highway 50 Delta, CO 81416

RE: SBEADMR Project – Pre Draft EIS

Dear Scott,

First we applaud your staff for your proactive approach to the effects of the spruce beetle epidemic and the aspen issues. This approach is challenging but has raised public awareness about forestry issues and allayed fears rising from urban myths and misunderstandings about the extensive safeguards built into timber management standards and guidelines and the numerous timber sale ‘C’ clauses that mitigate and manage the effects of timber management.

I am an active participant in the SBEADMR working group and would like to add some insights as this project progresses. I represent numerous independent, family businesses that provide processing, logging, hauling and other contractual timber services.

1) We support the continuation of the scope of the project (acreage to be managed) and believe that it is realistic in light of the scope of the bark beetle activity and the drought induced effects on aspen. The adaptive management component should allow the public to understand the objectives for each treatment on an annual basis over the next 10 years. Industry is fully in support of a 50,000 to 60,000 ccf program on the GMUG in order to maintain our highly adaptable, small but efficient timber infrastructure. SBEADMR is destined to fill much of this timber target by logging in dead timber.

The Regional office could provide the list of Colorado projects that are 10 year, landscape scale projects, and each of these has received the support of their communities. This may help provide context for the SBEADMR approach.

2) We urge that the draft EIS clearly state that the date of forest mortality will be a driver in identifying annual projects. Objectively, the public receives the greatest benefits when tree removal occurs when the trees have little deterioration and the highest monetary value. The highest value, equates to the lowest management costs, and thus more acres treated. As we have stated often, the longer a dead tree remains in the forest, the greater the checking, rot, and other defects in the sawtimber. Similarly, at the outset of the mountain pine beetle epidemic, the bark beetle forests had 250 projects through NEPA and ready for action between 2005 & 2007.

3) We suggest a robust examination of the future forest dynamics while the new forest regenerates within a sea of standing and falling dead trees. Salvage is beneficial by supplying wood to our industry, while also having the added benefit of removing many tons- but not every ton- of biomass. Excess biomass creates long term issues for wildlife and wildlife corridors, hunting, grazing, wildland fires and fire fighting, and even safety for those recreating while fishing, hiking and 4- wheeling.

The following graphic was often used in discussions on the mountain pine beetle forests and it was used to display the hazard of added fuels that would be involved in future fires for years to come. What is the GMUG view of this issue specifically?

Fuel Profile Hazard Associated with MPB Mortality

Greatest

Tree Crown in “Red and Dead” Stage Surface Fuel Loadings Increase with Tree Fall

Needle Fall Leading to Hazard Snag Condition

Snag Stage Lowest

3 - 4 4 - 6 6 – 20 50+ Years Since Beetle Attack (Approximate)

4) The socio-economic dimensions have been vaguely presented to- date and we look forward to reviewing this portion of the Draft EIS. The Colorado mountain bark beetle forests presented an exhaustive list of the costs and effects that were anticipated when communities co-exist in and near forests undergoing beetle epidemics. The SBEADMR project provides one tool for managing these myriad effects to roads, campgrounds, fencelines, dispersed camp sites, and urban infrastructure such as powerlines, private inholdings, emergency transmission sites, and very importantly water supplies (reservoirs and diversions).

5) The discussions at work group meetings have attempted to exhaustively list the values and GIS layers of all the various important components of the forest ecosystem and of all the different users of the forests. At the point of choosing and designing a project, obviously not every value can be prioritized for every acre of the forest. Defining the process of balancing all of the sometimes competing values will be an important concept in the adaptive management discussion of the EIS.

We know that this project will receive intensive analysis by you and your staff. We believe that Alternative 2 can best accommodate the diverse management needs that the GMUG will face in the near future. We believe that timber projects have been successfully managed by this forest for many years. Interestingly, the past timbering mistakes highlighted in occasional comment letters occurred some 30 years ago. We believe that this project can play a valuable and legitimate role of managing a small portion- less than 2%- of the GMUG forest. As Gifford Pinchot envisioned, this ‘land of many uses’ can surely accommodate this project to the benefit of communities and jobs for the surrounding area.

Thank you for your leadership and the professional, hard work by your dedicated staff. Thank you also for the multiple opportunities for giving input!

Sincerely,

Nancy Fishering