August 8, 1999
Christine Walsh, District Ranger, Becky Parmenter
Paul Mintier, John Oppenlander
Boulder Ranger District, US Forest Service
2995 Baseline Rd., Suite 110
Boulder, CO 80303
Dear Christine, Becky, Paul and John,
With regard to the Winiger Ridge Pilot Vegetation Management Project, after careful thought and discussion at our last meeting, PUMA has decided to support the No Action Alternative. The FS Proposed Action does not come close enough to meeting the fundamental points that were defined in the Memorandum of Understanding made in March 1997 between Puma and the Forest Service.
We very much support the goal of thinning our overcrowded forests, and providing effective fire mitigation. But in spite of the many meetings we have had with the FS, we still do not feel that our main concerns regarding the kind and amount of thinning to be done are adequately addressed in the current proposal, or that good enough provisions for evaluating, monitoring and controlling the cutting are built into the implementation plan.
Our concerns remain largely the same as they were at the beginning, as follows:
1) The Conflict between Logging Contracts and Forest Health
We understand that logging contracts are the only tool available to treat these unhealthy forest conditions on the large scale required, and that commercial logging can achieve a good result for the purpose of fire control. However, there is an inherent conflict between a commercially viable logging contract and the goals of forest health.
Puma questions whether it is possible to design the cutting prescriptions so that they will sell as logging contracts, and at the same time address the unique needs of these already seriously overcut forests for old growth recovery and forest health. We feel that no action at all may be preferable to yet another round of destructive cutting that will remove the few remaining middle sized trees from these areas.
2) Cutting Many or Most of the Middle-sized Trees
There are virtually no "big" trees (over 14 inches dbh) left in these areas. Only stumps remain from that size tree. So the issue here is not big trees, but rather middle size trees, i.e. those that are 8 to 13 inches dbh. The Scoping Document says that only 10% of trees cut would be in that size range, but barely 10% of the trees in these forests are of that size to begin with. The plan thus seems to call for cutting most or all of them, reducing these cutting units to stands of extremely small sized trees, under 6 to 8 inches dbh.
Loggers, for reasons of economy and effort, need to cut "from the top down", i.e. cut the biggest trees down to a minimum smaller size. But what these forests need for forest health is cutting "from the bottom up", i.e. the removal of only the smaller trees, leaving all trees over a certain size.
We see no reason other than their commercial value for removing the last of the middle size trees from these forests. Proper thinning for fire mitigation could be fully achieved by removing the over crowded smaller trees, and leaving the 10% of middle size ones as they stand.
Puma has stated very clearly from the beginning of these discussions four years ago that it does not want to see the logging contracts made commercially viable by the inclusion of these middle size trees. We remain firm and clear on this point. This represents perhaps the most important and difficult to reconcile problem we have with this FS Proposed Action.
Without the middle-size trees, the logging contracts would probably have little value, and the project could not take place. We understand this, and are aware that this means no significant, large scale fire mitigation, and no relief of the forest overcrowding. However, we feel that the loss of this middle size class of trees is too high a price to pay for fire mitigation. This, we feel, would be destroying the forest in order to save it.
3) The Need for Small Pilot Projects
Puma would like to see a few small pilot projects done first, one for each of the different forest types in the area -- ponderosa, aspen, mixed conifer/aspen, lodgepole, etc. We want to evaluate such small cuts with the Forest Service, and then proceed, or not, with the rest of the project area, based on what we learn from them.
To call the whole Winiger Ridge Project Area a "Pilot Project", and treat the whole 2100 acres as one large "experiment" does not show sensitivity for the enormous impact this work will have on the Magnolia area. We need to start with small cuts (40 acres for example), and learn what works and what we want before treating our whole area. Such an approach would take longer than the Proposed Action. We hope this slower paced, small test plot approach can be done within the terms of the grant the Forest Service is working with.
4) 60 - 80 Basal Area is Too Thin
While perhaps desirable for full scale fire control, Puma feels that an average of 70 "Basal Area" is far too thin for an attractive or healthy forest. One acre contains 43,500 sq feet. To leave only 70 sq feet of wood area as seen from above is far thinner than one might think. Particularly when the remaining trees are all under 8 inches dbh, spindly and widely spaced. Such a forest is surprisingly unattractive to look at.
The people of this area should be fully informed what a forest like this looks like. In addition, the forest floor becomes over exposed, it gets hot and dried out, runoff increases, the watershed is depleted, the exposed soils are subject to erosion, wildlife loses shelter, and windthrow is a problem. The only real advantage to such extreme thinning is fire mitigation. Here again, we feel the price is too high, the conflict between fire control and forest health too great.
5) Need for a "Circuit Breaker", or Control Method
Puma has long asked for some method of controlling or even stopping the logging projects if their effect on the forests is not desirable. If too many middle-size trees are being cut, or the thinning level of 70 basal area is too thin, or undesirable side effects of logging occur, such as weed proliferation, erosion, or stimulation of pine beetle outbreak, then how is the project to be modified or controlled? This issue needs to be addressed very specifically to avoid conflict in the future. Puma wants very much to maintain the friendly and cooperative relationship it has always had with the Forest Service.
6) Cutting Aspen Groves From the Top Down to 3 to 4 Inches
The plan calls for cutting aspen stands from the top down, i.e. taking out all trees over 3 or 4 inches. This may be necessary to create a logging contract for work on aspen, because there is no value whatever in small diameter aspen. It may be a method of encouraging aspen recovery over the long term. But such an approach means the destruction of a age diversity in our aspen stands, and a severe negative impact on the wildlife, from elk to birds, that depend on this rich and sheltering habitat. Puma does not support this approach to treating aspen.
7) Stimulating Further Mountain Pine Beetle Outbreaks
The cutting of ponderosa, and perhaps even lodgepole, if done between June 1 and Sept 15, is known to stimulate pine beetle outbreaks directly. Beetles are attracted by the smell of sap, on a large scale, as well as to stressed or injured trees.
If pine beetles move into the thinned out stands, they could cause severe additional damage. This occurred recently in Jamestown, following a Forest Service cutting project. Puma feels this shows a further need for caution, for establishing monitoring and control methods, and undertaking small initial pilot projects rather than approving the whole 2100 acre project at once – particularly in light of the pine beetle infestation we are experiencing in the Winiger Ridge/Twin Sisters area.
8) Many Logging Mitigation Measures Missing From the Proposal
In spite of the highly detailed list of mitigation measures in the Memorandum of Understanding, virtually no mention of them was made in the Proposed Action. It is difficult to ask logging contractors to perform a lot of non revenue producing, costly and time consuming mitigation work, in the context of logging contracts which are already barely viable financially for these operators.
However, Puma feels that without assuring adequate mitigation of the effects of logging, these contracts would cause as much or more harm than good. We want to see specific and detailed assurances made in the following areas:
- weed control
- road closure and recovery
- erosion control
- avoiding the stimulation of pine beetle outbreaks
- control of unplanned recreation access in the opened up areas
- piling and burning of slash
- retention of specific numbers of down and standing wildlife snags per acre
- retention of tree clusters & irregular spacing, avoidance of uniform trunk & crown spacing
9) Avoiding "High-grading" the Logging Contracts
In the rest of this Southern Rockies region, from New Mexico to Wyoming, wherever the forests have become over harvested like ours, there has been a pattern to Forest Service logging contracts, which we hope to avoid here. First the cutting prescription is designed with environmental and ecological goals incorporated. The prescription thus wins acceptance by the public, and contracts are prepared and presented to the logging operators. They say they can't make money on such contracts, and turn them down, as they may well do here, in spite of the large percentage of bigger trees that are being offered for sale. So then the Forest Service revises, or "high grades" the contracts, providing more of the bigger trees, and reducing the requirements for mitigation and land recovery. By this time the contracts are no longer under public scrutiny, and the high grading passes largely unnoticed. Puma would like some specific assurance that this pattern cannot occur here.
We understand the great difficulty the agencies face in trying to deal with the fire prone, overcut, unhealthy forests in this area. It is unfortunate that our society has not taken better care of its forests, and that the only tool available today to treat them is that of commercial logging contracts. However, we also feel that it is important to safeguard the remaining stands of recovering forest, and not subject them to yet another round of treatment, compromised by the demands of the wood products market, that like so many other such projects, we may come to regret.
We are still very much hoping that a way can be found to treat our forests, to meet the bottomline needs of logging operators, and at the same time to promote greater forest and ecosystem health. We are trusting still that this Forest Service Proposed Action can be revised in the course of this scoping and decision process so that it becomes something we can enthusiastically support. We look forward to working on this project further with you, to discover ways to resolve the difficulties we have with the present plan.
Sincerely,
The residents and members of Preserve Unique Magnolia Association (PUMA)
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