Mr. F. Carl Pence

Forest Supervisor

Malheur National Forest

431 Patterson Bridge Road

P.O.B. 909

John Day, OR 97845

Dear Mr. Pence

This letter reflects the comments of the Cascadia Fire Ecology Education Project (CFEEP) on the Summit Fire Recovery Project. Our careful reading of the Draft Environmental Impact Statement (DEIS) has led us to the firm conclusion that the official documentation is seriously flawed: the range of alternatives is too narrow, the effects analysis is inadequate, the disclosure of impacts is incomplete, and the alleged purpose and need for the Project is ill-conceived. In our educated opinion, we believe the agency should start over with a recovery plan that presents genuine alternatives to the kind of “past” management actions which continue in the present: cut, burn, plant, spray, poison, fight fires, and call it “reforestation.” Below are specific statements for the IDT to consider, and questions for more information that we believe is necessary to disclose in the Final EIS.

ITEM: LACK OF SCIENTIFIC DATA TO SUPPORT CLAIM THAT RECENT WILDFIRES ARE BURNING ABOVE HISTORIC LEVEL OF INTENSITY

The claim that the Summit Fire---or any other wildfire this century--burned above the historic level of intensity is completely without any foundation in science. Where is your data on previous fires to support this claim? Where is your data on the Summit Fire to support this claim? What is your definition or ÒmeasureÓ of fire intensity? These questions need to be answered and disclosed in the FEIS in order to support the driving assumption underlying this Project.

The voluminous Sierra Nevada Ecosystem Project (SNEP) brought together some of the agencyÕs top fire scientists. These scientists performed an exhaustive review of the literature, and informed the public of a critical truth: there is no direct data to support the assertion that fires today are more intense than either presettlement fires, or fires in the early 20th century. (SNEP, 2:1035) The agency must disclose its research data on alleged changes in fire intensity and explain how the fire managers of the Malheur National Forest know more than the team of experts who wrote the SNEP report.

Certainly, there have been some big fires in the last ten years, and these have caused significant mortality of big old trees. But the mere amount of acres or trees within a burn perimeter has nothing to do with quantitatively assessing the level of fire intensity. Nowhere in the DEIS is the concept of fire intensity defined or explained---not even in the glossary. Without a definition of fire intensity or data on historic and recent fire intensities, the public cannot assess the tradeoffs in environmental effects from salvage logging vs. no action.

Moreover, the DEIS states that “historically, the biophysical environments within the project area had been shaped by low to high intensity fires.” (p.1-10) Since high intensity fires are inclusive in the historic range of variability, how can the agency claim that stands which burned with high intensity during the Summit Fire are ÒoutsideÓ this range? The agency has failed to justify the purpose and need of the Project.

ITEM: LACK OF DATA TO SUPPORT CLAIM THAT CURRENT CONDITIONS EXIST BEYOND THE HISTORIC RANGE OF VARIABILITY

The purpose and need for the Project depend on the assertion that current stand structure conditions exist beyond the historic range of variability. This assertion is not supported by the data presented in tables 3-2, 3-3, and 3-4. First of all, the agency fails to disclose the methodology for its guestimates on the various percentages of historic stand structures. Indeed, the numbers are introduced with the words “believed to have extisted before the 20th century.” (pg. 3-7) What is the basis for these beliefs? The FEIS needs to disclose how the agency came up with its beliefs about the various percentages of historic stand structures.

Secondly, using the year 1850 as the benchmark for the historic range of variability seems arbitrary and capricious. Why is the history of Native American inhabitation of the land excluded from the historic range? If Euro-Americans began radically altering the environment since 1850, then it would be foolish for the agency to base a desired future condition on the past 150 years. There is no way the agency can restore stability to the ecosystem if their vision is framed by instability.

Thirdly, in order to support the claim that current conditions are “beyond the historic range of variability,” this would involve analyzing the two successional extremes: the very early and late/old stages. If the agency’s claim was true, this would mean that currently there is less early successional forest than existed in the past, and alternately, that there is more late/old successional forest than existed in the past. In fact, there is more (not less) early successional forest as a result of the Summit Fire. Only the Hot-Dry zone of the LEEK Ecological Analysis Unit shows an amount of early successional forest less than the historic range, and this is by a mere two percent! The rest of the biophysical zones are well within the range of variability for early successional forest.

On the other end of the successional scale, none of the biophysical zones have more than the amount of late/old successional forest expected for the historic range of variability. Between these two extremes which define the range of variability, the percentages of each structural category are still well within the range of variability. Hence, the agency has failed to prove any need at all for the “recovery” of the burned area in order to bring it within the historic range of stand variability.

The ultimate point of agency confusion is the sentence that states: “The proposed activities would only salvage dead trees; therefore, historic range of variability is displayed for informational purposes only.” (pg. 3-6) What does this mean in plain language? In our interpretation, it means that the whole issue of Òrestoring the area to its historic range of stand structure variabilityÓ (pg. 1-10) is the agencyÕs intentional obfuscation of the real issue: this is a timber sale, not a restoration or recovery project.

ITEM: CONTRADICTION BETWEEN MANAGING FOR THE NATURAL VERSUS HISTORIC RANGE OF VARIABILITY

There seems to be confusion and contradictions among members of the Inter-Disciplinary Team as to whether the Project is based on analysis of the natural or historic range of variability. The fire/fuels management member makes statements pertaining to managing Òwithin the natural range of variability.Ó (pg. 3-20) The two different concepts relate to immensely different time scales. Whereas the historic range has been arbitrarily selected as 1850 a.d. to the present, the time scale for the natural range has not been defined. This issue is fundamental to the purpose and need, and the desired future condition of the landscape. The FEIS needs to clarify and be consistent the time scale the Project is using to analyze stand conditions and fire history.

ITEM: INAPPROPRIATE MEASURES USED TO ANALYZE FIRE SEVERITY

Fire intensity and fire severity are two related but different concepts. Fire intensity refers more to fire behavior and its effects on above-ground vegetation. Fire severity, however, relates to fire effects on soil and below-ground resources. The use of flame length as a definition of fire severity in table 3-5 and figures 3-2 and 3-3 is thus an inappropriate measure for analyzing fire severity. New analytical measures and real quantitative data on the intensity of historic fires and the Summit Fire must be presented in the FEIS in order for the agency to justify its claims that the Summit Fire burned with greater intensity (or “severity”) than historic fires.

To sum up, this assumption of increased fire intensity is arguably the Project’s most critical issue that is driving the proposal to commit wholesale salvage logging across the landscape. Yet, without this research data on historic and current levels of fire intensity, the DEIS is offering a data-free analysis to the public and the Decisionmaker. The lack of analysis and disclosure on this issue greatly affects the rationale for the Proposed Action, and imperils the legality of the EIS. In our opinion, the agency fails to make a convincing argument in support of its alleged purpose and need.

ITEM: FAILURE TO GIVE MEANINGFUL DESCRIPTION TO THE CONCEPT OF FUELS PROFILE

The use of “tons per acre” to define the concept of fuels profile is spurious and unsatisfactory. Whereas tons-per-acre is a quantitative measure for such a concept as fuels load, the concept of fuels profile requires a qualitative descriptor. It is the spatial arrangement of fuels, both horizontally and vertically, that is key for describing fuels profile, not volume by weight as is offered in the DEIS (pg. 1-10). The agency needs to offer a more accurate definition and meaningul description of the concept of fuels profile in order to properly analyze the effects of proposed actions and convey these to the public.

Additionally, the agency needs to disclose whether or not leaving four snags per acre averaged across a 100 acre area will yield the desired ÒprofilesÓ of 10-40 tons per acre (varying according to specific biophysical environment) of fuels larger than 3 inches DBH. Are these measures also averaged across a 100 acre area? How many site-potential snags will need to be retained in order to maintain 30 or 40 tons per acre of this material? The agency must consider that if one of the objectives is to restore fire to its natural role in the ecosystem, then it needs to retain enough snags and logs not only for the needs of wildlife, but also the needs of wildfires.

ITEM: FAILURE TO DISCLOSE THE RELATIONSHIP OF THE PROJECT TO THE NEW FEDERAL WILDLAND FIRE MANAGEMENT POLICIES

The agency is fond of tiering proposed activities to more “global” planning documents found in the Regional Office; yet, nowhere in the DEIS is there an explanation of the relationship of this Project to the new Federal Wildland Fire Management Policies. Arguably, this entire Project should be tiered to this most global of all planning documents (the policies apply not only to the Forest Service, but to all federal land management agencies). Indeed, the Project’s stated purpose and need clearly pertain to fire management planning. Furthermore, the DEIS states that Òfire management planning becomes a significant issue in the subwatersheds contained within the Summit Fire Recovery Project area.Ó (3-14) Given this admission, what are the Fire Management Action Plans for the subwatersheds and special management areas within the Project area? Were these plans revised in order to comply with the new federal policies? If not, then more planning and analysis is needed in order to deal with this admittedly significant issue.

The DEIS briefly mentions that “Fire management planning entails activities such as wildfire suppression, wildfire hazard/risk reduction, and prescribed fire applications.” (pg. 3-14) However, the DEIS fails to disclose the relationship of proposed actions to wildfire suppression activities. What will be the indirect, and cumulative effects of proposed “recovery” actions on future wildfire suppression activities? How does wildfire suppression relate to the alleged purpose and need to “restore fire to its natural role within the Project area.Ó (pg. 1-10) What will be the indirect and cumulative environmental effects on native flora and fauna from proposed salvage logging-related actions coupled with wildfire suppression actions? What are the effects of wholesale removal of large fuels on the wildfire hazards of those sites? How will conversion of salvaged stands to even-aged ÒreprodÓ units affect the risk and hazard of future wildfires? What are the agencyÕs plans for wildfire risk reduction in terms of prescribed burning, especially slash burning, broadcast understory burning, and prescribed natural fires? The DEIS fails to disclose information on these significant issues, as well as fails to explain how the proposed actions are tiered to the new Federal Wildland Fire Management Policies. The FEIS must answer these questions and disclose this information related to the significant issue of fire management planning.

ITEM: FAILURE TO DISCLOSE AUTHORIZING NEPA DOCUMENTS ON FIRE MANAGEMENT PLANS

The agency makes the claim on page 2-3 that fire suppression is authorized under existing NEPA documents. The new revised Federal Wildland Fire Management Policies mandate that new fire management plans must be developed for all federal lands containing burnable vegetation; however, he DEIS fails to disclose whether or not the Malheur is complying with the new federal policies and has developed new fire management plans for the subwatersheds contained within the Project area.

If the Malheur did develop new fire management plans for the Summit Fire area, then how did public participation occur? As you should know, the new federal policies require public participation in the development of these new plans. How did (if at all) the agency comply with NEPA in developing its current fire management action plans, be these of the old or new policies? Existing NEPA documents on the old fire management policies are insufficient for analysis and disclosure of the foreseeable future environmental and economic effects of the MalheurÕs new fire management plans.

The FEIS needs to disclose the relationship between the proposed actions, the new federal fire management policies, and the Malheur’s new fire management plans. If the Malheur has not developed new plans for the subwatersheds within the Project area, then it is failing to comply with the new policies. If it has developed new plans that conform to the new policies, then the agency must show how it complied with NEPA in this endeavor. Without this necessary information, the public cannot assess whether or not future fire suppression activities is authorized under NEPA.

ITEM: FAILURE TO FULLY DISCLOSE EFFECTS OF SUMMIT FIRE SUPPRESSION ACTIVITIES

The DEIS states that 122 mapped miles of stream were affected by the Summit Fire and by fire suppression activities.” (pg. 3-27) What were these fire suppression activities, and how did they affect fish habitat? Did the agency draw water from streams in order to feed hoselays or spray on gravel roads? What were the direct and indirect effects on fish habitat and other aquatic species and wildlife from these activities? Will these same suppression activities occur in the future? If so, then the FEIS needs to fully disclose the cumulative environmental effects of past, present, and future wildfire suppression activities. If not, then the FEIS needs to explain the effects on future wildfire suppression from prohibitions against drawing water from fish-bearing rivers and streams.

ITEM: FAILURE TO DISCLOSE THAT FIRE SUPPRESSION CANNOT CONTAIN AND CONTROL WILDFIRE DURING EXTREME FIRE WEATHER EVENTS

From the very brief sketch of the wildfire incident on page 1-1, it is clear that the Summit Fire was the outcome of an extreme weather event that was beyond human ability to prevent, and beyond human ability contain or control wildfire until the weather changed. The ability of wildfire to spread across 30,000 acres in two days is an awesome reminder of NatureÕs power. This big blow-up was the product of several factors, not simply a matter of the fuel load. The FEIS needs to disclose to the public the conclusions of the Federal Wildland Fire Management Program and Policy Review on the efficacy of contain and control suppression tactics and strategies during extreme fire weather events.

ITEM: FAILURE OF PROJECT TO ACHIEVE OBJECTIVE OF RESTORING FIRE TO ITS NATURAL ROLE IN THE ECOSYSTEM

The scale and kind of proposed “recovery” actions---logging, burning, road-building, spraying, poisoning wildlife, and ongoing fire suppression---will result in cumulative effects that will continue to alter the landscape. How can the agency claim to be initiating a project that will help restore fire to its natural role if its “recovery” actions will continue to manufacture an unnatural landscape? What scientific data or research documents the use of the above proposed “recovery” actions as a means of restoring fire ecology processes? This information should be disclosed in the FEIS in order for the public to assess if proposed actions are going to meet the ProjectÕs purpose and needs for restoration of natural fire ecology processes.

Apparently, the agency intends to “wipe the slate clean” and start over from scratch in order to implement its new attitude toward fire. It looks like the agency is trying to mimick a stand-replacing fire with stand-replacing logging. However, the agencyÕs conception of a stand-replacement fire is qualitatively different than the actual process of forest regeneration. Looking only at the dynamics of wildfire, even an extreme wildfire event does not vaporize all of the biomass; in fact, the fire leaves behind most of the large-diameter snags and logs. These remnants of the biological legacy remain in the ecosystem for decades, offering many benefits to the next forest---and the next fire. Indeed, successful regeneration of old-growth may require a series of reburns in order to create the right soil and hydrological conditions. By extracting all of these snags and logs at once, however, the agency will effectively abort this natural recovery process, impairing the soil fertility and hydrological characteristics, and changing the site to one that cannot sustain old-growth trees. The effects of proposed actions on future reburns, and the ecological benefits of reburns to the ecosystem must be disclosed in the FEIS.

Contrary to the agency’s stated objective, the proposed actions will likely prevent future wildfires from burning with either natural behavior or natural effects, thus, contradicting the stated objective to restore fire to its natural role within the ecosystem. In this likely scenario, how can the agency claim its actions to be any kind of ÒrecoveryÓ or ÒrestorationÓ strategy when in fact they constitute a qualitative alteration of the landscape and fire ecology processes? The DEIS is insufficient in explaining how proposed actions will help restore fire to its natural role or stands to their fire-effected structural diversity in the Project area.

ITEM: FAILURE TO DISCLOSE THE FIRE RISK THRESHOLD LEVELS, AND DISCLOSE AREAS WHERE SLASH TREATMENT WILL NOT OCCUR

The DEIS states that unmerchantable trees, limbs, and snags will be left on site; moreover, logging slash will only be treated if it exceeds the fire risk threshold levels. (pg. 4-3) Nevertheless, the document does not disclose what these threshold levels are, or what salvage area will not treat the slash. Logging slash is one of the most extreme fuel hazards for wildfires, and puts planted units at risk of catastrophic loss when even moderate intensity fires burn threw slash-laden units. Furthermore, the DEIS fails to explain how the many thousands of tons of logging slash dumped on thousands of acres in an extremely short time span will help return the Project area to its historic range of fire or stand variability. Logging slash alters the natural fuels profile, and feeds more extreme fire behavior, especially when it underlies dense even-aged stands of young “reprod.” The FEIS needs to address these issues of logging slash, fire risk, and fire hazard in order to explain how slash accumulations serve the alleged purpose and need of the Project.

ITEM: FAILURE TO DISCLOSE EFFECTS OF SALVAGE LOGGING ON LOCAL FIRE WEATHER IN COOL-MOIST AND COOL-DRY BIOPHYSICAL ZONES

The DEIS discloses that the natural fire history of the cool-moist and cool-dry biophysical environments is highly complex, and includes the range of fire behavior and effects from low to moderate and high severity fires. (pg. 3-16) Accordingly, the DEIS fails to justify the purpose and need for the Project since the stands within these biophysical environments that burned with high severity were normal, natural events. Indeed, the DEIS states that within these areas, “stand replacement fires are the rule rather than the exception.” (pg. 3-17) How and why is salvage logging necessary to “restore fire to its natural role” or return the stand structure to a desired condition for the reintroduction of natural fire in these areas? The DEIS fails to make a case justifying the alleged need to ÒrecoverÓ in order to ÒrestoreÓ stand conditions to allow natural fires.

The DEIS states that the fire history of these biophysical environments is “largely the influence of weather” (pg. 3-16) rather than fuel profiles. Indeed, it is clear that the large acreage of the Summit Fire was the result of an extreme fire weather event (strong East winds) not fuel conditions. If weather is the predominant factor influencing fire behavior in the cool-moist and cool-dry environments, why is the agency altering the fuel bed of stands within these zones? What will be the indirect and cumulative effects on local weather and microclimates from salvage logging? It is likely that salvage logging will have effects on local weather, particulary winds and temperatures patterns. These effects need to be analyzed and disclosed in the FEIS.

Once again, if high severity fires are normal, natural events within the cool-moist and cool-dry biophysical zones, then why is there a need to do any managed recovery actions at all? The agency has failed to justify its self-proclaimed “need” to manage or recover anything, particularly the Roadless Areas, Scenic Area, and Riparian Habitat Conservation Areas where no programmed timber extraction was supposed to occur. The FEIS needs to analyze the effects of salvage logging on local weather, and justify its alleged need to do any recovery actions at all in order to restore natural fire patterns in the cool-moist and cool-dry biophysical zones.

ITEM: FAILURE TO DISCLOSE HOW PROPOSED TIMBER EXTRACTION AND FIRE SUPPRESSION WILL DEVELOP STANDS MORE RESILIENT TO FUTURE FIRES

The DEIS states that the results of “past” fire suppression and timber extraction resulted in the development of a more homogeneous (or less heterogeneous) landscape pattern. (pg. 3-18) The DEIS fails to disclose how the proposed actions (specifically salvage logging, artificial planting, herbicide spraying, and future fire suppression) will result in the development of a heterogenous landscape more resilient to future severe wildfires. The DEIS also fails to disclose how proposed timber extraction activities and future wildfire suppression actions differ from these activities in the past. Considering that the agency claims that these “past” management activities have changed the forest structure to make it more vulnerable to severe wildfires, why is the agency going to continue these practices? When and how will the proposed actions get the agency off the treadmill of fire suppression and salvage logging? The cumulative effects of past logging and firefighting with proposed future logging and firefighting needs to be analyzed and disclosed in the FEIS.

Finally, the DEIS fails to explain how the proposed actions will make the forest more ÒresilientÓ to wildfire. On the contrary, the creation of even-aged stands devoid of large snags and logs and structural diversity will make these units more vulverable to catastrophic reburns. Considering the relatively high fire frequency, particularly in the hot-dry and warm-dry biophysical environments, it should be expected that some of these units will experience a reburn within the next 25 years. The agency needs to analyze the ecological and economic effects of worst-case scenario reburns of this young, even-aged “reprod” that will necessitate repeated firefighting and repeated planting.

ITEM: FAILURE TO DISCLOSE THE EFFECTS OF CATTLE GRAZING ON ALTERATIONS OF THE NATURAL FIRE REGIME AND DESIRED FUTURE CONDITION FOR NATURAL FIRE RESTORATION

It is disclosed in a photo caption on page 3-50 that “Cattle grazing helps reduce vegetation, limiting some fine fuels.” (3-50) What are the implications of this statement in terms of fire ecology processes? What are the environmental effects of limiting some fine fuels that would help spread low intensity ground fires? The DEIS fails to adequately disclose the effects of ÒpastÓ grazing policies and practices on the dynamics of the Summit Fire and the alterations of stand structure. The FEIS needs to disclose whether or not cattle grazing complies or conflicts with the Project’s alleged purpose and need to restore fire to its natural role in the landscape.

ITEM: INADEQUATE DISCLOSURE OF THE CURRENT CONDITION AND INDIRECT EFFECTS OF PREVIOUSLY LOGGED AREAS WITHIN THE BURN

On page 3-8 it is stated that “In some portions of the area, past harvest areas seemed to have greater tree survival than areas not harvested.” What age and species of trees survived and why? What about the other portions of the area that were not disclosed in the DEIS---did previously logged areas burn with moderate or high intensity? Did a greater proportion of young planted trees burn with high mortality than not? What were the indirect and cumulative effects of previously cutover lands on the mortality of adjacent native old-growth trees? The answer to these questions are critical for the public to assess the likely outcome of management actions.

It is our informed opinion that even-aged management derived from salvage logging and artificial planting actually increase the fire hazard of these managed sites in both the short and long-term. Accordingly, agency actions will not enable humans to “restoreÓ natural fire to the ecosystem, but on the contrary, will set the fuel and microclimatic conditions to more intense, severe wildfires in the future. This will not only continue to imperial public forests, but make society forever dependent upon massive, costly “inputs” of fire suppression and artificial planting.

To repeat, the agency needs to analyze the indirect and cumulative effects of even-aged silvicultural systems (as proposed in this Project) of future risk and hazard of large-scale wildfires and fire-caused mortality of artificial young-growth and native old-growth trees. The FEIS should disclose the effects of cutover and planted areas on the fire behavior and fire effects of the Summit Fire, particularly the silvicultural systems based on even-aged management (e.g. clearcutting and shelterwood). Then the FEIS should analyze these past management silvicultural activities/units in relation to current high mortality stands and proposed salvage units. This will help answer the question, really the “burning issue” of so-called “recovery” projects: do plantations inhibit or promote large-scale fires? The FEIS should focus on this issue and answer this question before proceeding with any of the proposed actions.

QUESTION: HOW DID THE AGENCY “RECOVER” THE 1994 REED AND INDIAN ROCK FIRES?

It is not disclosed on page 3-5 the current condition of the 1994 Indian Rock and Reed Fires. Were these fire “recovered” by salvage logging? If so, what were the effects of salvage logging on the fire behavior of the Summit Fire? Also, what will be the cumulative effects on soil and site productivity from a third ÒcatastrophicÓ disturbance (i.e. salvage logging following two wildfires) in less than four years?

ITEM: FAILURE TO DISCLOSE THAT HERBICIDE SPRAYING WILL INCREASE FIRE HAZARD

The agency has known for over twenty years that herbicide spraying increases the fire hazard of “treated” stands. The Pacific Southwest Forest and Range Experimental Research Station revealed in the document PSW-241 that ÒDessication of woody vegetation with herbicides markedly influences fire behavior---more than can be attributed to changes in fuel moisture content alone.Ó (Bentley, et al., 1971) The Pacific Northwest Forest and Range Experimental Research Station revealed in the document PNW-317 that “Fires in sprayed brush build up and spread over an area more rapidly and uniformly than do fires in unsprayed brush.” (Stewart, 1978) For several seasons following an herbicide spray operation, dead leaves may remain on their branches. The effect not only continues to shade the confers and thus fails to “release” them, but worse, this standing dead dried brush resists decay and remains available to fuel a hot burn. The agency needs to disclose that the use of chemical herbicides for brush control will significantly increase the fire hazard, thereby affecting fire control and the effectiveness of reforestation.

ITEM: FAILURE TO DISCLOSE THAT HERBICIDE SPRAYING WILL INCREASE TOXIC EXPOSURE TO FIREFIGHTERS

The DEIS failed to disclose the indirect effects of toxic smoke on firefighters from brush that is sprayed and then burned. The chemicals on the brush are not instantly and completely volatized during a fire, especially along the edge of the flame front. In advance of the flames, the heated vegetation will release chemical residues into the atmosphere, thereby exposing firefighters (and wildlife) to increased exposure from chemical toxins. The agency needs to disclose the indirect effects of chemical herbicide spraying that will put firefighters at increased risk of toxic exposure in the event of a wildfire.

ITEM: FAILURE TO COMPARE THE ECOLOGICAL AND ECONOMIC COSTS AND BENEFITS OF CHEMICAL HERBICIDES VERSUS MANUAL RELEASE

If the agency was truly concerned with the mission of caring for the land and serving people, then it would drop from further consideration the use of chemical herbicides. A manual release program would put many people to work earning good wages while doing good things for the land. Manual release targets the undesirable species (especially noxious weeds and exotics) rather than uniformly attacks all species. Manual release avoids the toxic effects of chemicals which affects both humans and wildlife. Manual release can prune overstocked trees at the same time as it puts the cut brush directly on the ground, speeding up the decay process, and reducing fire hazard. Manual release can use the cut brush to add shading for seedlings and thwart brousing by deer, thereby saving the economic expenses and environmental effects of the unsightly shade screens and deer tubes. Additionally, when laid directly on the ground, the cut brush helps retain soil moisture, resists rainsplash and sheetwash erosion, and adds nutrients to the soil. These are longterm economic benefits measurable in terms of reforestation success and spared expenses from more intensive management inputs. There is really no valid justification for the use of toxic chemical herbicides when compared with the ecological and economic benefits of manual release techniques that accomplish several objectives at the same time. The agency needs to disclose the comparative costs and benefits of chemical herbicides versus manual release techniques.

ITEM: FAILURE TO DISCLOSE EFFECTS OF MANAGING SALVAGE UNITS AS EVEN-AGED STANDS

The alleged purpose and need for the Project is “to initiate projects that will move toward restoring the area to its historic range of stand structure variability by biophysical environment.Ó (p.1-10) The document fails to define or explain what the agency considers to be ÒvariabilityÓ in stand structure. Description of the Proposed Action indicates that the agency intends to manage salvage-logged units as even-aged stands. Retaining a mere four snags per acre (averaged across 100 acres in some biophysical environments) is a de facto clearcut in the eyes of the public and most non-agency scientists. The resulting stand structure of salvage units will have the same “variability” as a plantation. From a perspective that values biological and structural diversity, even-aged plantations are vastly inferior to a naturally recovering forest that has abundant large snags and logs. Indeed, managed “recovery” actions will greatly simplify salvage units and the ecosystem at large. This reduction of variability through the wholesale extraction of the biological legacy within managed units will result in the exact opposite outcome of the agency’s alleged purpose and need---salvage logging will not reduce wildfire hazard or make these stands more resilient to fire, but will actually increase the risk and hazard of catastrophic loss from wildfire and the same time it impoverishes the ecosystem of biological diversity. This outcome of the Proposed Action thus violates the stated purpose and need for the Project.

The biological legacy of snags and logs serve a number of vital ecological and habitat functions that are not reducible to their classification as Òfuels.Ó Indeed, these structures can also act as natural fire suppressants by providing shade from high surface winds and temperatures, providing moisture to retard fire spread, providing refugia for wildlife to escape the flame front, returning nutrients to the soil, and preventing erosion and siltation. In contrast, even-aged stands without abundant snags or logs are prone to hot temperatures and low humidities, and high surface winds that feed intense flame fronts and rapid fire spread. Furthermore, the lack of structure denies the wildlife refugia from the flames or nutrients for post-fire recovery.

Abundant large snags and logs are also essential for maintaining biological diversity. Indeed, many threatened and endangered species and their prey directly utilize these structures for food or shelter. Additionally, many invertebrates and fungi are found only in or around large snags and logs. Although they are typically considered to be Òdead,Ó large snags and logs often contain more species of wildlife than living green trees. For this reason, not to mention their values to soil fertility and watershed stability, snags and logs are arguably the most valuable trees in the forest. Even-aged stands devoid of abundant snags and logs lack this diversity of native species.

As the new Forest Service Chief, Mike Dombeck, has stated publicly, it is time that the agency stop minimizing wildlife and watershed protection in order to maximize timber extraction. The agency must explain how salvage logging (and herbicide spraying and wildlife poisoning) will Òbegin to restore stand structure and vegetative species diversityÓ (p. 1-10), and what the effects of eliminating the biological legacy of large snags and logs will do to long-term ecosystem functions, habitat quality, and fire hazard in managed units.

ITEM: INCONSISTENCY BETWEEN MANAGING FOR TIMBER EXTRACTION AT A STAND LEVEL VERSUS MANAGING FOR SNAG RETENTION AT A LANDSCAPE LEVEL

The DEIS discloses that snags and green replacement trees will be managed at the landscape level (pg. 1-11) However, the effects of proposed salvage logging are analyzed at a stand level. Managing at a stand level is a retrograde strategy that defies the concept of Ecosystem Management, however, the agency cannot use the presence of snags in the landscape found outside of units slated for “recovery” actions in order to “mitigate” the effects of timber extraction inside managed units. Indeed, the purpose of an EIS is to analyze the effects of management actions on the environment. The agency cannot include analysis of a larger unmanaged area as a means of reducing the significance of effects of management actions in managed sites. The agency must either analyze effects at the stand level (in which case, the amount and kind of snag retention will likely be insufficient for wildlife habitat and watershed functions), or analyze at the landscape level (in which case, the cumulative effects of new timber extraction added to past timber extraction will put the landscape outside the historic range of variability and dispute the rationality of further additional timber extraction). The agency needs to be consistent with its use of scale in analyzing effects, and disclose more fully the effects and effectiveness (or lack thereof) of a recovery strategy based on even-aged stands.

ITEM: INADEQUATE ANALYSIS OF THE ECOLOGICAL BENEFITS OF BIOLOGICAL AND STRUCTURAL DIVERSITY DERIVED FROM NO ACTION

The No Action alternative is required by NEPA to be fully developed and properly analyzed because this is the baseline from which the agency can assess the environmental effects of its proposed actions. The section on regeneration under the No Action alternative improperly focusses on the negative effects of uneven distribution of natural regeneration. The fact that the distribution of natural tree regeneration will be uneven, ranging from clumps to open areas with no trees at all, is not a negative impact but rather is a positive ecological asset in terms of creating biological and structural diversity.

Additionally, the Timber First! paradigm that pits nitrogen-fixing species of “brush” (e.g. ceanothus) as “competitors” with artificially planted trees is outdated, short-sighted, narrow-minded thinking. It is wholly inadequate for analyzing the natural regeneration processes that will unfold under the No Action alternative. Given sufficient time (something that the agency refuses to allow Nature) it is likely that these sites will be superior in soil fertility and soil structure compared to the simplified managed sites. Plantations often require massive inputs of money and technology to adequately restock the unit with trees.

The DEIS states that post-fire dynamics on fungi and mycorrhizal populations are not well understood, and that possibly viable populations may be present for 1-2 years after a severe fire event. (pg. 3-40) On the other hand, the DEIS states that “Salvage logging of dead trees is not expected to have any additional effect in the surface mycorrhyzae.” (pg. 4-4) The IDT would be wise to analyze the effects of post-fire salvage logging on soils and site productivity by citing the research of Dr. David Perry of the School of Forestry at Oregon State University. In his research in the Siskiyous, including some salvage logged units from the 1987 Silver Fire, Dr. Perry discovered that mycorrhyzal fungi can survive on the roots of ceanothus following a fire disturbance. The impacts of fire salvage logging, however, changed the microclimatic conditions by removing shade from the snags and disturbing the soil by yarding operations. This made the sites hot and droughty and effectively killed all of the subsurface fungi. As the fungal filaments decomposed, it destroyed the soil peds that previously held pores spaces for air and water. These changes in soil structure occurred very rapidly---within a few years after salvage logging. This altered the soil structure from one that previously supported a forest to one that resembled infertile sand. Multiple attempts to replant these sites have failed, and they are now appear to be permanently deforested. The FEIS should disclose to the public the significant and irreversible effects on mycrorhizal fungi, soil fertility, and soil structure that will occur from the cumulative impacts of salvage logging and brush eradication.

ITEM: FAILURE TO DISCLOSE SCIENTIFIC BASIS FOR MINIMUM LARGE WOODY MATERIAL REQUIREMENTS

What is the scientific or research basis for establishing the MLWM requirements? What biologists or soil scientist has determined that only three ponderosa pine logs six feet long and twelve inches wide are needed per acre? Has this MLWM been validated in the literature or by a non-agency scientists? The MLWM seem arbitrary and capricious without further disclosure of the biological reasons for such paltry amounts of the biological legacy being retained following salvage logging.

ITEM: INAPPROPRIATE PRESENTATION OF HERBICIDE SPRAYING AS “MITIGATIONÓ MEASURES, AND FAILURE TO FULLY DISCLOSE EFFECTS OF THESE ACTIONS

The presentation of herbicide spraying and wildlife poisoning as “mitigation” measures for other management actions is totally inappropriate. These so-called mitigation measures are actions which cause significant direct, indirect, and cumulative environmental effects that need to be disclosed. The DEIS does not satisfy NEPA by simply tiering its use of herbicides to a regional FEIS and ROD; on the contrary, site-specific data and analysis must be presented for these site-specific actions. The Regional FEIS does not specifically discuss the application of herbicides following a severe wildfire. The effects of such poisons on this scale of disturbance is different than the normal impacts of a ÒgreenÓ timber sale. The analysis of these toxins should include effects from release into the ecosystem via airborne drift, runoff ,and burning (in the event of a wildfire). Also, the analysis should go beyond looking at the effects on humans, but also include the whole array of flora and fauna which may be affected. Indeed, the DEIS for the Summit Project is completely inadequate in disclosing analysis of the likely toxic effects on non-human species. Herbicide spraying is not appropriately analyzed or conceptualized as a “mitigation” measure; it is a management action all its own. Viewed as such, what are the mitigation measures for the use of toxic herbicide sprays?

ITEM: FAILURE TO FULLY DISCLOSE EFFECTS OF WILDLIFE POISONING

The DEIS is also grossly inadequate in analyzing the effects of poison bait for wildlife. What will be the effects of strychnine and aluminum phosphide on non-target species, particularly raptors, vultures, and other scavengers? The assumption that wolverines will develop an aversion to poisoned gophers is without any foundation in scientific research, as is the assumption that poisoned wolverines will only become sick and not suffer increased mortality from ingestion of strychnine-laced rodents. The FEIS needs to analyze with much more depth and detail the indirect and cumulative effects of poison on non-target species of wildlife.

ITEM: FAILURE TO ANALYZE EFFECTS OF DUST ABATEMENT

Another “mitigation” measure that the agency failed to analyze the environmental effects were dust-abatement measures to reduce airborne sediments from entering waterways. What will be the effects from lignin sulfate running off and entering streams? Will the agency also be spraying water on the roads to reduce airborne dust? If so, what will be the effects on aquatic species from withdrawing water from streams during the summer? The above questions need to be answered in a FEIS that analyzes the environmental effects of mitigation measures as well as the primary management actions.

ITEM: FAILURE TO DISCLOSE LOCATIONS OF “REPLACEMENT OLD-GROWTH STANDS”

It is unclear from the DEIS what an “old-growth replacement stands” is or means, and where they might be located. Are these stands currently old-growth? Are they of the same size, habitat suitability, and ecological value as the stands they are replacing? From the DEIS, it seems that these replacement stands are old-growth in name only, like the so-called ÒLate-Successional ReservesÓ of Option Nine forests (these LSRs are comprised of an average 40% of clearcuts and plantations, and contain very little ancient forest). This concept of “replacement” old-growth stands sounds similar to the concept of the Earned Harvest Effect which enabled the agency to overcut old-growth under the assumption that intensive management techniques would regrow trees faster in the future. Through these managerial fictions, many “phantom forests” now exist on the agency’s maps, but not on the landscape. The FEIS needs to disclose whether or not these replacement stands are currently actual old-growth, or are merely lines on a map indicating a forest that might someday in the future become old-growth. Also, the proposed locations and existing conditions of these replacement old-growth stands need to be disclosed so that the public can assess whether or not this ÒmitigationÓ measure is a fact or fantasy.

ITEM: FAILURE TO ANALYZE INDIRECT EFFECTS OF SALVAGE LOGGING ON REGENERATION DELAYS

One of the main objectives of the Project is to “reforest” burned areas. The DEIS makes the claim that, “Reforestation will restore live trees to burned areas sooner than would occur naturally.” (p. 1-11) This statement is not supported by any data or evidence. What is the current status of the natural regeneration of the full range of native species that make up a natural forest (as opposed to a post-salvage plantation)? How are natural seedlings doing in burned old-growth stands compared to burned logged stands? What is the average number of regeneration failures and length of regeneration delays on intensively managed units in the Long Creek District? What will be the costs of two or three attempts to plant a salvage unit in order to meet stocking levels should earlier attempts fail? How does this period of delay compare to estimates of the time needed for natural regeneration to become established? The agency needs to disclose this data for the public to assess the veracity and viability of the stated objective to ÒreforestÓ salvage logged areas faster than Nature can do without logging and planting.

The agency assumes that a speedy planting following the impacts of salvage logging will result in successful reforestation; yet, it needs to disclose data on the actual foreseeable time period of artifical reforestation to succeed. Even if one narrows the definition of a forest to mean only trees (or timber) while excluding all of the other flora, the agencyÕs allegation is still not defensible---indeed, the objective itself is not defensible. The point of authentic forest recovery is not to restore live trees to burned areas “sooner,” but rather, restore them longer (meaning that they live long enough to become old-growth). The agency needs to disclose why it values speed over the efficiency, quality, and lower costs of natural regeneration.

The agency assumes that through the use of technology (e.g. shade screens, shade cloths, and chemical fertilizers) it can successfully reforest a stand that has suffered through the impacts of wildfire, logging, slash-burning, and spraying. The proposed vast reduction in the number of snags and logs from salvage units will cause indirect effects on the regeneration success (or lack thereof) of the artificially planted tree seedlings by changing the microclimatic conditions of the site. By removing all but four snags per acre, this will expose the seedlings to direct sunlight and drying winds. Recognizing that there is a need to control sunlight damage, this should mean that the agency should not deliberately expose sites to more sunlight than is already occurring. How will sunlight damage be ÒcontrolledÓ by removing existing natural shade structures (i.e. snags and logs) via salvage logging? How much will the tiny shade screens mitigate the creation of units with 0% shade cover?

Large-diameter snags and logs provide vital shade from the sun and wind. Research on the Willamette National Forest’s Warner Fire Recovery Project revealed that the stems of trees 150 feet tall with a 24 inch DBH accounts for 15-24% of the shade on a slope. Again, how much shade is offered by the shade screens? What is the longevity of these screens, and what percentage of saplings that grow slightly taller and/or wider than the screens will not survive? From our field observations, it appears that those pathetic little shade screens only provide shade for a season or two of a sapling’s growth, and cannot compare with the kind of long-term shade that snags and logs provide for the first critical decade of a treeÕs growth.

Finally, these shade screens are a visual blight: littering the landscape with thousands of shade screens is grossly unsightly---it is enough to make Woodsy Owl screech in his grave! After the artificially planted seedlings fry and die in the hot, dry conditions of a de facto clearcut, the stems often rot away leaving behind the shade screens and their non-biodegradable stakes. The agency needs to analyze the effects of shade screens and other plastic devices on scenic values.

ITEM: FAILURE TO HONESTLY DISCLOSE PRIORITY OF TIMBER RECOVERY OVER ECOSYSTEM RECOVERY

The above words were the management directive established by former Chief Jack Ward Thomas. The agency failed to live up to these ideals during his tenure, and although Forest Service employees have no legal obligations to continue to give lip-service to this directive, the lack of the ability of the agency to live up to this then or now remains a great moral failure of the Forest Service, and a disservice to the public and their forests. This Project reveals an appalling reaction against the last fifteen years of the agency’s public relations efforts, and an almost antagonistic rebuke to the environmental attitudes of the majority of the American people. The ecologically aware public is left wondering what sand dune the Malheur’s managers have their heads stuck inside.

The sentence on pg. 1-12 describing the Proposed Action is highly revealing of the agency’s priorities with this so-called “recovery” project: “In order to salvage fire-killed timber and accelerate the recovery of the project area...” As stated, the first goal of this Project is to salvage-log timber; the secondary goal is allegedly to accelerate recovery. This outdated “timber first!” policy flies in the face of the agency’s Ecosystem Management philosophy and the management direction being offered by Forest Service Chief, Mike Dombeck. This is particularly irksome in Management Areas which normally would restrict timber extraction. It is further revealing of the backwards mentality of the MalheurÕs managers that Forest Health/Ecosystem Management is considered an ÒOther Issue,Ó not a Significant Issue or guiding vision for this Project.

For your information, in a speech to Regional Foresters and Research Station Directors on April 8, 1997, Chief Dombeck said many things which reveal that the priorities of this “recovery” project are retrograde to the new perspectives and management directions of the agency as a whole. Chief Dombeck said, ÒToday, society's priorities are shifting. Our management priorities must keep pace with our scientific knowledge of ecological systems and society's values...My challenge to you is to help make watershed health, ecosystem health, the health of the land -- whatever you wish to call it -- the driving force... We cannot allow (timber) production to diminish the land's productive capacity...All of the goods and services that we provide to the American people are dependent on healthy lands and waters. The health of the land must be our overriding priority!Ó

If the Malheur’s employees were to take the Chief’s words to heart, the Inter-Disciplinary Team would state that the essential priority of the Project is to ensure recovery of the ecosystem, and secondarily, when and where it conforms to this first priority, to get some timber cut out. The agency needs to disclose how (if at all) this so-called ÒrecoveryÓ project conforms to the principles of Ecosystem Management and the directives coming from the office of the Chief. Further, the FEIS needs to be honest with the public and disclose on the cover of the document that this is a timber recovery project, not a “fire” recovery or ecosystem recovery project.

QUESTION: WHY ARE SALVAGE SALES EXEMPT FROM THE REVISED INTERIM ECOSYSTEM STANDARDS?

The DEIS informs the public in a brief sentence on page 3-7 that salvage sales are exempt from the revised interim ecosystem standards. Why are salvage sales exempt? The amount and kind of timber extraction in this Project is qualitatively different---on a vastly increased scale---than the other kinds of sales exempted (e.g. firewood sales). It is not appropriate to use the exemption in this case in order to get the cut out. Besides, the DEIS states that this is a “Fire Recovery Project,” not a salvage timber sale. Are fire recovery projects specifically exempt from the revised interim ecosystem standards?

Unless explicitly stated that fire recovery projects are exempt, the Summit Project should fully comply with the most conservative interpretation of the standards in order to best meet riparian, wildlife, and ecosystem needs, as well as preserve future planning options until the Record of Decision for the Interior Columbia Basin Ecosystem Management Project is completed.

ITEM: FAILURE TO JUSTIFY CLAIM THAT THE SALVAGE LOGGING WOULD “RESTORE OR ACCELERATE FISHERIES HABITAT RECOVERY” OR MEET RIPARIAN MANAGEMENT OBJECTIVES

There is little explanation in the DEIS to help the public understand what the agency is thinking when it states that salvage logging will restore or acclerate fisheries habitat recovery or meet riparian management objectives (RMOs). There is not even a definition or explanation of RMOs in the document. In the Biological Evaluation in Appendix D, it is very revealing how the District biologist crafts the following sentence: “With the proposed action, desired conditions and RMOs would be achieved earlier due to fisheries/watershed improvement projects implemented in conjunction with the salvage activities.” From this wording, it appears that the improvement projects will have the desired positive effects, but salvage logging will have neutral (or more likely, detrimental) effects on fisheries/watersheds. The FEIS must clarify the distinction between restoration and extraction activities for the public to be better able to assess the net effects of the proposed actions.

Again, the question is asked, why is the agency willing to do ecological restoration from “past” management mistakes only if it can offer new timber sales? What precisely will the be ecological benefits---that is, the benefits to the ecosystem---from salvage logging activities? This is the essential question that must be answered in the FEIS. Adding ecological restoration actions onto resource extraction actions and then making the claim that the positive effects of restoration outweigh the negative effects of extraction has no basis in scientific research. The agency must disclose its analytical methods for claiming that salvage logging will “improve” or “restore” or “acclerate recovery” of riparian habitat, watersheds and fisheries.

ITEM: FAILURE TO FULLY ANALYZE EFFECTS OF TIMBER EXTRACTION FROM RIPARIAN HABITAT CONSERVATION AREAS

Although the Malheur does not need to comply with the Northwest Forest Plan, there is a reason why the Riparian Reserve widths established by the NWF Plan are determined by the average site-specific tree that may fall into any fish-bearing, non-fish-bearing, perennial, or ephemeral stream. Every part of a site-specific tree is important to the riparian zone. Indeed, in the short-term, it is the upper-most section of a tree furthest away from the stream that has the greatest probability of falling directly into a deeply-incised channel. The trees nearest the channel are normally suspended above the stream until, over the long-term, they have rotted enough to break up and fall into the water. Thus, the claim that salvage logging inside RHCAs will be ÒmitigatedÓ by taking 90% of the trees beyond 15-25 feet from the stream channel is utterly ridiculous! Indeed, it is a scandalous subversion of the PACFISH and INFISH conservation strategies. The FEIS needs to fully analyze and disclose the short-term and long-term effects of salvage logging within RHCAs, and not falsely claim that the agencyÕs logging prescriptions serve as “mitigation” measures.

Finally, the agency has completely failed to explain how salvage logging in and adjacent to RHCAs will begin to “restore” or “improve” water quality, as stated on pg. 1-10. This statement is especially problematic for water quality limited streams. How will salvage logging reduce further impacts to water quality? The DEIS fails to address this very important issue and needs to be disclosed in the FEIS.

ITEM: FAULTY PRESENTATION OF ECONOMIC DATA

Data on employment in Grant and Harney counties is misreported in table 3-9. Whereas the paragraph above explains that lumber and wood manufacturing accounts for 11% and sole-proprietorships contribute approximately 12% of the total employment in these counties, these number are apparently transposed in table 3-9. This error needs to be corrected, as is significant for informing the public that the huge, long-term negative environmental impacts on their/our public lands will occur in order to subsidize the private profits and short-term jobs of the lowest employment sector in these counties. Indeed, the ecological impacts of salvage logging, road-building, herbicide spraying, wildlife poisoning, and other destructive management actions will cause significant effects on the short-term and long-term economics of the remaining 89% of the counties’ workforce. For these reasons, this petty error in table 3-9 needs to be corrected in the FEIS for the public to fully grasp the economic implications of this Project.

ITEM: FAILURE TO CALCULATE ROAD CONSTRUCTION/RECONSTRUCTION INTO THE TOTAL COSTS OF LOGGING

The Forest Service has been manipulating its economic analyses of logging costs for years by excluding the costs of road construction. Perhaps timber managers may fool themselves that these logging roads offer Òmultiple usesÓ such as recreation and fire control, but research shows otherwise. The only recreational users of these logging roads are hunters, who are fast turning our National Forests into a giant drive-by shooting gallery. Moreover, the benefits of roads to fire suppression are far outweighed by fact that roadways are the prime location of human-caused ignitions. Indeed, logging roads are constructed for one main, primary, exclusive purpose: to publicly subsidize the private profits of timber corporations.

The DEIS states clearly the primary reason for reconstructing 160 miles of logging roads: “Reconstructing existing roads is an important way of preparing them for hauling salvaged material to mills.” (2-18) If this is their primary purpose, then road construction and reconstruction must be calculated in the economic analyses of the costs of logging. The FEIS must disclose to the pubic these economic data, or explain with some rationale why the costs of logging roads are excluded from the costs of logging.

Finally, if the agency was truly interested in ecosystem recovery instead of timber recovery, it would propose an alternative that would decommission and obliterate those 160 miles of degrading roads. Why does it always take a new timber sale to motivate the agency to do restoration on its ÒpastÓ management mistakes?

ITEM: INCORRECT ANALYSIS OF THE THE ISSUE OF JOBS LOSS UNDER THE NO ACTION ALTERNATIVE

On page 2-2 of the DEIS is the statement that Òexisting jobs may be lostÓ if the No Action alternative is selected. Unless the timber industry and Forest Service have a crystal ball in which they could predict the occurrence of the Summit Fire, calculate opportunities to get the cut out of areas with no programmed timber extraction, and thus hired extra workers to be ready to process this salvaged timber, then no existing job would be lost if the No Action alternative was selected. This erroneous statement must be deleted from the FEIS. If timber industry jobs (or more accurately, timber industry profits) are dependent upon a “sustained yield of salvage” then the agency must disclose to the public that its current crisis management scheme is in fact managing for future crisis, and not trying to avert them.

ITEM: DECISION TO EXCLUDE A NATURAL RECOVERY RESEARCH PROPOSAL FROM THE SCOPE OF THE PROJECT WAS ARBITRARY AND CAPRICIOUS

Mr. Pence, we believe that your decision to exclude consideration of an alternative that would manage portions of the Summit fire area for later designation as a Research Natural Area was wrong, and your reason for declaring an RNA alternative outside the scope of the Project was mistaken. Certainly, establishment of RNAs are done at a Regional level, but the Region depends on the initiative of local citizens and agency employees to propose candidates for RNA designation. Moreover, you should know that anyone can propose areas as candidates for RNA status, and no one has more clout over these nominations or holds more sway over the entire process of establishing RNAs than a Forest Supervisor. Your mind may be closed, Mr. Pence, but your hands are not tied in this matter. On the contrary, your proposed recovery actions essentially constitutes a decision to foreclose future management options by yourself or your predecessors to establish an RNA in the Summit Fire area.

There is a huge gap in the range of alternatives between No Action and the other Action Alternatives. This gap would be filled by adding another alternative that proposes to manage a large portion of the burn for natural recovery research and watershed restoration without salvage logging, herbicide spraying, or wildlife poisoning. This ÒNatural Recovery Research and Restoration” alternative should be unlike the No Action alternative because it should propose a variety of management actions focused on ecological research and watershed restoration. Such an alternative would fulfill the purpose and need based on the assumption that natural fire recovery processes are the only known methods for regenerating biologically and structurally diverse forests capable of surviving future large-scale wildfires.

The agency’s own Regional Ecologist and the Pacific Northwest Forest and Range Experimental Research Station have expressed much interest in establishing fire ecology-oriented Research Natural Areas. The portion of the Summit Fire area containing the Vinegar Hill-Indian Rock Scenic Area and parts of the Greenhorn Mountain and Jumpoff Joe Roadless Areas make logical candidates for this kind of RNA. Additional acreage outside of these special management zones would be desirable in order to conduct landscape-sized longitudinal studies. Remaining lands outside of this research area could be the site of various alternative restoration projects intended to restore the ecosystem and protect the integrity of the RNA.

Part of a longterm strategy to allow fire to play its natural role requires an understanding of the role of natural fire recovery processes. All of the action alternatives propose activities oriented toward commodity resource extraction and contain nothing for the agency or non-agency research community to learn from this burn. Your proposed model of managed fire recovery---salvage logging, road building, artificial planting, herbicide spraying, animal poisoning, and firefighting---is really no “alternative” at all to the so-called “past” management mistakes you allegedly seek to rectify. Rather, it constitutes a further grand experiment on the landscape without any control area from which to measure the effects or effectiveness of managed recovery activities. This greatly impugns the scientific credibility of the recovery project, and violates the spirit of ecosystem management and adaptive management philosophies.

We urge you in the strongest possible terms to reconsider your earlier decision to exclude a Natural Recovery Research alternative from the scope of this project. Allow your Inter-Disciplinary Team to fully develop a new natural fire recovery research/restoration alternative. The planning, analysis, and documentation of the Summit Fire Recovery Project would be greatly enhanced by inclusion of an alternative devoted to natural fire recovery research and watershed restoration activities. At the very least, you should include a natural recovery research zone within Alternative 2 that includes both Roadless Areas and the Scenic Area. The best plan, though, would be to develop another alternative to analyze and compare alongside the current action plans. This would salvage some scientific credibility from this Project and provide benefits to the research community, the ecologically informed public, and forest-dependent communities.

In closing, perhaps the most critical, essential question for the Interdisciplinary Team is this: what actual ecological benefits to the ecosystem, watershed, wildlife, roadless areas, and scenic values will result from the proposed actions? The FEIS needs to specify how the proposed actions will recover the ecosystem, the watershed, native vegetation and wildlife (including S, T, E species), and the non-commodity values of the forest. The document fails to convince the members and staff of the Cascadia Fire Ecology Education Project that this recovery project is anything other than a timber sale, despite the rhetoric of Òrecovery and restoration.Ó

The official documentation is seriously flawed and fails to fully comply with NEPA. The range of alternatives is too narrow, the effects analysis is inadequate, the disclosure of impacts is incomplete, and the agency fails to assure the public that its proposed actions will meet the alleged purpose and needs for the Project. In our sincere opinion, we believe that the agency should start over with a recovery plan that presents genuine alternatives to the kind of “past” management actions which continue to cause problems in the present: the silvicultural methods of cut, burn, plant, spray, poison, and fight fires. It is far past time that the agency learn from its “past” mistakes by not repeating these failed methods of “reforestation” over and over again, spinning ever faster on a treadmill of deforestation. We strongly urge the Decisionmaker to start over with this Project and do not carry forth any of the action alternatives into the Record of Decision.

As a final note, reading the DEIS was a bit of a shock at how crude and crass the Malheur appears to be in its lust to serve the corporate timber industry at any and all costs to its reputation. As presented in the DEIS, this Project appears to be almost a spiteful attack against the environmental values of the majority of the American people and those of the new Chief of the Forest Service, Mike Dombeck. Must we remind you that the Malheur is a National Forest and must be managed with the best interests of the whole citizenry, including future generations of all species, foremost in mind. The Malheur should not be managed as the private fiefdom of the local timber oligarchy.

The Cascadia Fire Ecology Education Project is ready, willing, and able to form a partnership with the Forest Service if and when the Malheur is ready, willing, and able to do forest service and begin genuine ecological restoration of our over-managed lands. Sadly, as presently conceived, this is not the time, place, or project for this joint effort. Please do put us on your mailing list to receive all news and documents on this project, especially the FEIS and ROD.

Sincerely For the Forest,

Timothy Ingalsbee, Ph.D.

Program Director, CFEEP