May 19, 1997

RE:     Comments on and FOIA request for Summit Fire Recovery Project DEIS

Carl Pence
Forest Supervisor
P.O. Box 909
John Day, OR 97845

Dear Carl:

First I would like to thank you, Sharon Sweeney, Joel Waldo, and Hugh Snook for the field tour of the Summit Fire project area.  We now have a better appreciation for the magnitude and intensity of the fire and a better understanding of your proposed action.

After reviewing the Summit Fire Recovery Project DEIS, Blue Mountain Native Forest Alliance, Grande Ronde Resources Council, Kettle Range Conservation Group, Tonia Wolf, and Steve Willer have the following comments.

1.  Riparian Areas.

We are opposed to entry into PACFISH stream buffers.  PACFISH and the proposed alternative for ICBEMP, alternative Four, have specific no cut buffers unless it can be demonstrated that vegetation management inside of the buffers will improve riparian and aquatic health.  The Summit DEIS does not demonstrate this.  Rather, it is our understanding that the buffers will be entered in order to get KV monies, which in turn will be used to replant the riparian areas.
 
First, is it not true that KV funding generated by a salvage project can be spent anywhere within the project area?  If this is not true, please provide us with rules or regulations stating the contrary.  We also understand that regardless of whether salvage logging occurs, fire restoration money is available from other sources.  Please fully address other sources of  monies for reforestation in the FEIS.

Second, if you determine that the buffers must be entered for reasons other than to provide monies for replanting, please clearly explain these reasons in the FEIS.

Third, getting riparian areas quickly revegetated with plants other than trees is a crucial part of maintaining water quality within the project area.   Burned and salvaged areas grow half the vegetative biomass of burned, unsalvaged areas. Anecdotal evidence suggests that fire salvage may permanently reduce site potential.  A recent visual survey of an old fire site on the Colville National Forest where salvage logging was halted halfway up a drainage gives a graphic comparison between salvaged and un-salvaged areas of the same site.
 

About five miles from the Copper Butte Fire, the White Mountain Fire burned some 20,000 acres in the Colville National Forest in 1988.  In the aftermath, the Forest Service planned to salvage most of the burned trees for commercial uses, and some salvage projects were carried out.  In areas treated, grasses were planted to control erosion on the steep slopes and logging roads were built to access the salvage areas.

 
This summer, visitors to the White Mountain Fire found some important differences between burned-over spots that had been salvaged and places that had been left alone.  In one headwater stream area that has not been salvaged, observers noted native fireweed growing six feet tall, Scouler willow and other shrubs stabilizing streambanks and providing shade over the water, downed trees creating pools in the stream, and thick mosses growing at the bases of standing burned trees.  Naturally regenerated tree seedlings are in abundance, and the species mix represents the entire spectrum of conifers to be expected in a high elevation, mixed conifer stand.
 
The salvaged area visited is less than 100 yards downslope from the untouched area.  There, tree regeneration has been out-competed by introduced grasses.  The banks of the same stream are bare, with evidence of erosion and silt deposition in the channel.  There are few large snags to provide bird habitat or shade for mosses, little down material to recharge soils or house beneficial insects and small mammals.  The fireweed is half as tall as in the headwater area, growing through spots where introduced grass seed did not take hold. (From TRANSITIONS July/August 1994)

Please provide us with any information that you have contrary to our contention that burned and salvaged areas grow less vegetative biomass than burned, unsalvaged areas.
 
Fourth,  PACFISH no-cut buffers maintain the microclimate of riparian areas, provide filtration, shade, and large wood.  After the Summit Fire, there is less microclimate, filtration, and shade.  However, the large wood still exists.  The no-cut buffers should be honored unless you can prove that removing large wood is beneficial to the riparian and aquatic habitat.  In the "Broadscale Assessment of Aquatic Species and Habitats" for ICBEMP, the authors explained that any reduction in the amount of large woody debris within the streams, or within the distance equal to one site-potential tree height from the stream, can reduce instream complexity.  Large woody debris increases the quality of pools, provides hiding cover, slow water refuges, shad, and deep water areas.

Fifth, please thoroughly explain in the FEIS the method by which you intend to remove trees within the no-cut buffers.  How will the methods insure degradation of the water quality and fish habitat will not occur?

2.  Snag, green tree replacement, and down log levels.

First, we are absolutely opposed to the timber companies determining which trees will be left as snags.  On the field tour, you said that you will give pictures of the type of trees to be left as snags to the timber companies and then it is up to the companies to determine which trees to leave.  THE FOREST SERVICE WILL NOT MARK ANY OF THE TREES TO BE LEFT AS SNAGS!!!  This is outrageous.  The Forest Service is responsible for marking leave trees.  It is not the duty of timber companies to determine which trees are necessary for wildlife.  It would be a direct conflict with their desire to get out as much timber volume as possible.  The duty to insure the viability of wildlife is the Forest Service's.  You will surely be violating the National Forest Management Act is you allow persons with interests in conflict with wildlife needs to determine what trees should be left for wildlife.  This is especially true considering the size of this project (15,000 acres of harvest and 110 mmbf).  If the Summit Fire Recovery Project is too big for the Forest Service to properly execute, then you must reduce the project area to a manageable acreage.

All the DEIS says is that "where available, four snags per acre over 21 inches dbh will remain."  The number of snags left for wildlife should be based on the most recent science.  Alternative Four of the ICBEMP DEIS recommends two trees per acre greater than 21 inches dbh and eight trees per acre greater than 12 inches dbh for dry forests.  For moist forests, alternative Four recommends six trees greater than 21 inches dbh per acre and twelve trees greater than 12 inches dbh per acre.  Finally, for cold forests, eighteen trees greater than 12 inches dbh per acre are recommended.  If you decide not to implement these standards, the FEIS must thoroughly explain why.

Further, the ICBEMP's proposed alternative, alternative Four, states that big down logs, 33 logs fifteen inches dbh or greater per acre, are necessary to insure the viability of old-growth associated species.  This finding was based on the most recent science.  You must consider this science and if you decide not to implement the standards, thoroughly explain why in the FEIS.  As with snags, the Forest Service must mark the down logs that will remain for wildlife.   Also, please provide us with the information upon which you relied to determine that leaving dead woody material significantly increases the probability of reburn.

That the Forest Service designate and mark the trees to be left as snags, green tree replacements and down logs, is especially important in the roadless areas where it is likely that many large trees still exist.

The Summit Fire Salvage DEIS acknowledges the importance of large snags and large down logs for nutrient cycling and insect predator habitat yet proposes to reduce the potential for recruitment of these vital structural components both inside and outside of riparian areas.  One of the most important findings of the ICBEMP in regard to forest health is that large snags and down wood play a vital role in protecting the forest from defoliating insects.

In a section titled "What is required to maintain long-term productivity" (page 164) the authors of the Integrated Scientific Assessment (ISA) say "[s]pecial emphasis can be placed on the cycling of the dead component of vegetation.  Management practices can include provisions to maintain dead standing and down vegetation material and litter."  Unfortunately these components of a healthy forest are the very components that are in shortest supply.  On page 180 of the ISA, the authors continue, "[w]e had not anticipated the data indicating the extensive loss of large trees in the landscape over much of the Basin.  The harvest legacy has been more extensive than we thought."

The ISA specifically mentions problems that can result from logging these large trees:
 

 Harvest of the large live or dead residual trees from these types results in the loss of important habitats as well as components in long-term nutrient cycles.  Management practices can promote the maintenance of these large residual trees where they exist and where they have been harvested or otherwise lost, management can focus on rapid growth of selected young trees with similar characteristics  (ISA at 169).

As currently defined (in Public Law 104-19), salvage emphasizes the extraction of specified volumes of dead and green trees at risk of dying.  As such, harvest will emphasize larger trees, both green and recent dead, of desirable species (ponderosa pine, Douglas fir).  Our findings suggest that this type of harvesting is not compatible with contemporary ecosystem-based management.

Please consider and analyze in the FEIS the following scientific research supporting retention of large snags.

Twenty inch ponderosa pine snags are expected to remain standing for an average of ten years. This means that some ponderosa snags will remain standing longer and some will remain standing for a shorter period of time. Snags that are larger than 20 inches also are expected to remain standing for a longer period of time.

F. P. Keen, a Forest Service Entomologist at the California Forest and Range Experiment Station, wrote  "The Rate of Natural Falling of Beetle-Killed Ponderosa Pine Snags" which was published in the October 1955 Journal of Forestry.  This study was based on a snag census conducted between 1919 and 1949 on the 640 acre Crowder Flat section of the Modoc National Forest in California.  In this study, Keen concluded that after 25 years, 10 percent of the original snags were still standing, and of these, some remain for at least another 15 years.

Keen also noted that "the rate [of fall] also depends upon the size or diameter of the snags, the proportion of heartwood, and many other variables."  Based on his thirty year study he developed the following chart to depict the rate of fall for snags in different size classes:

After 0-14 years

After 17-30 years

D.b.h. (inches)

No. of original snags

(1932 cruise)

(1949 cruise)

10-18

1,886

62

21

20-28

1,599

65

10

30-38

931

72

21

40-48

179

82

28

50 and over

39

72

12

Total

4,634

The Crowder Flat area originally had only 7.24 snags per acre. After thirty years only 1.26 of the original snags per acre remained. The Crowder Flat area had approximately 35% mortality. If the area had 100 percent mortality like some areas of the Summit analysis area there would have been several times as many snags left after thirty years.

Some studies suggest that fire "hardened" snags can survive for twice as long as snags that were not killed by fire.  In Dahms, Walter G. Research Note No. 57, Pacific Northwest Forest and Range Experiment Station, Portland, Oregon. 1949, the author noted that, "the 'fire' snags have tended to stand longer than the 'insect' snags. At the end of 9 years 75 percent of the 'insect' snags were down, but it took 18 years for the same proportion of 'fire' snags to fall. It is not known whether this difference is the result of the way the two groups were killed, the tendency of insects to select certain types of trees, the differences in soil, or a combination of these factors."

No  research studies have been done on the long term (>30 years) persistence of snags but it seems reasonable that some fire "hardened" snags may persist for 60 to 80 years.  In order for a few snags to persist for the period of time necessary to grow trees 15-20 inches dbh, the Forest Service must retain as many large snags as possible.

Dahms also notes that:
 

Comparison of the results of this study with those obtained by McArdle in studying Douglas-fir snags indicates that pine snags tend to stand a shorter period of time, perhaps by several decades, than do fir snags.

Please consider leaving all trees greater than 20 inches dbh.  There is no question of their beneficial value to wildlife.

3.  Roadless areas.

We oppose any entry into the two roadless areas.  The Summit Fire project area includes 8,700 acres of the Greenhorn Mountain Roadless Area and 2,800 acres of the Jumpoff Joe Roadless Area.  In a letter from Regional Forester Robert Williams to the region six forest supervisors, Williams stated:
 

[R]iparian, old-growth, and roadless areas are vitally important to the character, productivity, and values for which so many treasure the National Forests.  In restoring their health and reducing the danger of their catastrophic loss, we must expend extra effort to work with a broad spectrum of the public in gaining their understanding and support when we have compelling reasons to consider activities in these areas.

4.  Roads.

We oppose the building of any new roads, especially in big game winter range and wildlife emphasis areas.  Roads are incompatible with the maintenance of quality wildlife habitat, and they impact big game distribution and vulnerability.  At the most, only the 43 miles of primary use roads should be evaluated for reconstruction.  The FEIS must fully disclose the type of "reconstruction" planned for the 160 miles of existing roads.  The Forest Service must explain fully when and how it will obliterate and close roads.  Roads are the leading source of sediment that ends up in streams.  The prevention of soil erosion and stream sedimentation is critical to fish bearing streams and must take precedent over any need to build or reconstruct roads.

5.  Livestock grazing.

We oppose of any livestock grazing in the project area for a minimum of two full years.  Non-use may well extend beyond that time, especially if the area is exposed to unusually droughty conditions in the next few years.  Grazing use must not be resumed at all until all management fences have been restored to usable condition and until all springs and other watering facilities are usable within the grazing allotment areas.

The Forest Service must state in the FEIS what forest conditions must exist before it will allow further grazing.  The public cannot write educated comments for this project unless these conditions are known to us.  Cumulative impacts cannot be properly considered and addressed.  We agree that the permittees should not be left in doubt about when they can again graze their livestock.  Therefore, determine the forest conditions after which grazing may occur and let the permittees and us know in the FEIS.

6.  Monitoring and mitigation.

Water quality monitoring is not specified in the DEIS.  We believe that such monitoring is crucial to evaluate whether the activities proposed result in the desired outcome.  Please explain fully in the FEIS what water quality monitoring will occur and if none will occur, why not.

Please address in the FEIS how you will be monitoring the ongoing timber sales to ensure that the sales are being implemented on the ground properly.  Because this project is of such magnitude, detrimental environmental impacts may be devastating. If this project results in spreading your sales administrators too thin so that no sales are properly monitored, you must reduce the scale of the project.

We commend the concept of taking photos at "photo points" to monitor the effects of harvest activities on the scenic resources.  We do not believe "4 photo points" for each management unit is adequate.  Please make those photo points in both traditional media and digital media.

The draft DEIS does not deal with independent news media monitoring and monitoring by private individuals.  The attempt to exclude both independent news writers and the media by the Siskiyou National Forest were unconstitutional as determined by a recent court case.  We wish to know how you plan to handle ours and other monitoring efforts by the public and news media.  We believe this should be addressed in your monitoring plan.

For mitigation, we recommend the "flush cutting" and "removal" of stumps in sensitive areas.  If the Forest Service will not do this, please address this in the FEIS.

7.  Analysis file and requested extension of comment period.

Blue Mountain Native Forest Alliance requested an extension for the DEIS commenting period because the analysis reports for this project were not complete one week before comments were due, except the vegetative and one other report.   Although the DEIS states that there is a comprehensive project file documenting the EIS development process,  the Forest Service assured us that all of the information in these analysis reports are in the DEIS.  Apparently the only information in the project file is scoping letters.  After looking at the completed analysis reports, if they do provide addition insight into this project, we may request a revised DEIS for the portions for which we were not fully informed.

8.  Economics.

The Forest Service discusses only the local economy and its relationship to timber harvest as a significant economic issue.  We believe the Forest Service must recognize the following significant economic issues as relevant to this salvage sale:

        A.  The Forest Service must recognize that we now live in a global economy.  For instance, the 1986 Chernobyl nuclear accident that spewed clouds of radiation over several European nations, changed the world mushroom market and as a result, thrust Eastern Oregon into the global mushroom market.  Now National Forests in Eastern Oregon provide a significant share of the worlds mushrooms--millions of dollars worth of mushrooms are exported from Eastern Oregon's National Forests every year.  The mushroom economy is a very important economy to Oregonians.  Any action taken by this salvage sale that would impact the viability of mushroom production need to be taken into account.  For example, cattle grazing could have a major impact on mushroom production.  It appears that the economic value per acre of mushroom sales far exceeds that of cattle production per acre.  An alternative that protects the mushroom crop must be developed.

        B.  The Forest Service must recognize that recreation and other visitor related economies are significant.  After this salvage sale is completed, the local, regional, state, and national tourism business will go back to relying heavily on recreation resources generated by the National Forest System.   For example, in 1991, nearly $3 billion was generated state-wide by visitor expenditures in Oregon.  Hunting and fishing in Eastern Oregon alone generate millions of dollars annually.  Leaving out these important economic issues would certainly deny this EIS of real professional credibility.

The report should not rely on Forest Service economic values assigned to recreation if such data is outdated.  EIS preparers should contact State Economists for updated information!

        C.  The DEIS indicates a strong desire to facilitate the access to dead timber for local timber companies.  Will the bidding process be limited only to local timber companies or will companies from other communities within the region have an opportunity to bid on this sale?  Please show data indicating where and how "1,300 annual jobs" will be made available.

        D.  Please show whether or not this will be a deficit sale and show the dollar amount that will be deficit.

9.  Wildlife

The DEIS does not adequately discuss the impact on wildlife that the removal of 110 mmbf will have, including the displacement of many wildlife species.  Big game uses the Summit Fire area currently.  However, with the projected disturbance due to the removal of 110 mmbf and large scale road building and reconstruction, big game may be forced to leave the area.  These impacts must be discussed, including the positive impacts if no roads are built.  The roads will increase public access to these areas, and the big game will be forced to move out.  Please provide us with evidence that by not harvesting the Summit Fire project area, wildlife movement could be impeded.

10.  Research Natural Area

We believe this should also be a significant issue.  It would seem odd that the timber harvested from this project will be open to a regional bidding process for timber companies throughout Eastern Oregon and yet a solid evaluation of this area for RNA status is dropped from consideration because it is of "regional scope."  Your draft report gives ample evidence that the combination of management and fire history that has occurred within this area presents an excellent opportunity for study and deserves equal evaluation as an alternative.  Please see Linda Driskill's detailed comments on this issue.

11.  Animal damage control.

Please discuss alternatives to poisoning and trapping ground squirrels (gophers?) that will protect newly planted trees.  What is the success rate of buying plastic cones for the trees instead, of watering the trees, of preparing the soil and buying mats that retard competing vegetation?
 
12. Other comments

        A.  Under the Fire/Fuels Management section of the Affected Environment on page 3-15, three fire regimes are identified: 1) low severity; 2) moderate severity; and 3) high severity.  Yet, there is no map showing where these regimes occur in reference to planned harvest activities.

The maps, graphics, and narrative parts of this draft EIS do not disclose the actual boundaries of the fire in comparison to the planned harvest and other treatment activities.  Furthermore, this draft document does not disclose the location of the unburned areas within the fire perimeter nor does it show areas outside the burned area that may be impacted by this recovery project.  It also does not give any indication of the relative degree of fire impact upon the forest ecosystem.  In summary, the Draft EIS does not meet NEPA disclosure standards. Reviewers do not have sufficient information to evaluate the effects of alternatives upon the existing environment.

According to one of the affected environment authors (page 3-18), "Management activities such as fire suppression and timber harvest have had significant effects on vegetation and fire regimes within the project area (Agee, 1994; Johnson et al, 1994; Hessburg et al, 1994; Agee, 1993)."  There are no maps showing the reviewer the location and extent of these previous fires.

        B. The intent of the recovery project is a little confusing.  The Abstract statement states that the project will occur within the "Summit Fire Area."  Yet at the top of page 1-11, under Purpose & Need, the report shows an intent to "[r]eforest salvaged areas and other areas identified as a reforestation need."  Does this mean that the project area as identified is not the only area in which harvest will occur?  We would appreciate clarification of the "other areas."

        C.  Please show data indicating that natural regeneration is less responsive than past reforestation activities in this particular area.  We believe that the reforestation success on the Malheur National Forest has been very poor - as little as 5% success rate - and do not believe that natural regeneration could be less successful.

        D.  Please explain why that "[w]ithin riparian areas ...mountain alder, red-osier dogwood, and quaking aspen...may be planted" rather than will be planted (page 2-13, paragraph 4)!  We note that some species "would" be planted and some species "may" be planted. If this is truly a "Recovery Project," we  believe that species that are native and critical to recovery "shall" be planted!

        E.  Please provide us with copies of the peer reviewed scientific documents which support your contention that logging large trees and leaving small trees and slash will reduce fire hazard within the next several decades.  The final pre-publication draft of Landscape Dynamics of the Basin from the ICBEMP Scientific Assessment states that:

Harvest regimes generally produce substantially higher fuel loads than the non-harvest regime. In the short term (< 40 to 50 years), post-harvest treatments increase fuel loading. Typical harvest treatments leave of the dead fuel on the ground rather than still standing as in non-harvest (with fire and with no fire) or native disturbance regimes. Many harvest treatments do not include broadcast burning, but rather leave all fuels either spread on the ground or in piles. Even when they are broadcast burned, large-diameter fuels remain intact for long periods of time. Non-harvested stands can also contain high fuel loadings. For example, epidemic outbreaks of disease or insects, wind storms, or stands transitioning from stem exclusion to understory reinitiation often have high fuel loading.
 
        F.  Finally, we incorporate the Summit Fire Recovery Project DEIS comments of Linda Driskill and Inland Empire Public Lands Council into these comments.

Thank you very much for considering our comments.  Please send the FEIS and all other information requested to Jennifer Schemm, Blue Mountain Native Forest Alliance, 506 M Avenue, La Grande, OR 97850;  Dave Robinson, Kettle Range Conservation Group, P.O. Box 151, Curlew, WA 99118-0151;  Tonia Wolf, Eastside Conservation Ontology, 63715 OB Riley Road, Bend, OR 97701; and Steve Willer, Friends of Neotropical Migratory Birds, 353 NE 7th Street, Bend, OR 97701.

Sincerely,
 

Jennifer Schemm