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Full text of "Review of the Administration's preferred alternative for the Pacific Northwest Management Plan : hearing before the Subcommittee on Specialty Crops and Natural Resources of the Committee on Agriculture, House of Representatives, One Hundred Third Congress, first session, November 18, 1993"

REVIEW OF THE ADMINISTRATION'S PREFERRED 
ALTERNATIVE FOR THE PACIHC NORTHWEST 
MANAGEMENT PLAN 




Y 4, AG 8/1:103-52 

Revieu of the Adninistration's Pref. . . j 

HEARING 

BEFORE THE 

SUBCOMMITTEE ON SPECIALTY CROPS 
AND NATURAL RESOURCES 

OF THE j 

COMMITTEE ON AGRICULTURE 
HOUSE OF REPRESENTATIVES 

ONE HUNDRED THIRD CONGRESS 

I 

FIRST SESSION 



NOVEMBER 18, 1993 



Serial No. 103-52 










Printed for the use of the Committee on Agrioilture 



■''^ct.>.. 



U.S. GOVERNMENT PRINTING OFFICE 
78-799 WASHINGTON : 1994 

For sale by the U.S. Government Printing Office 
Superintendent of Documents, Congressional Sales Office, Washington, DC 20402 
ISBN 0-16-046301-7 



78-799 0-94-1 



<P1 

|/ REVIEW OF THE ADMINISTRATION'S PREFERRED 
ALTERNATIVE FOR THE PACIHC NORTHWEST 
MANAGEMENT PLAN 



Y 4, AS 8/1:103-52 .. 

Revieu of the ftdninistration's Pref. 



HEARING 

BEFORE THE 

SUBCOMMITTEE ON SPECIALTY CROPS 
AND NATURAL RESOURCES 

OF THE 

COMMITTEE ON AGRICULTURE 
HOUSE OP REPRESENTATIVES 

ONE HUNDRED THIRD CONGRESS 

FIRST SESSION 



NOVEMBER 18, 1993 



Serial No. 103-52 







Printed for the use of the Committee on AgriciJture 



U.S. GOVERNMENT PRINTING OFFICE 
78-799 WASHINGTON : 1994 

For sale by the U.S. Government Printing Office 
Superintendent of Documents, Congressional Sales Office, Washington, DC 20402 
ISBN 0-16-046301-7 



78-799 0-94-1 



COMMITTEE ON AGRICULTURE 



E (KIKA) DE 

GEORGE E. BROWN, Jr., CaUfomia, 

Vice Chairman 
CHARLIE ROSE, North Carolina 
GLENN ENGLISH, Oklahoma 
DAN GLICKMAN, Kansas 
CHARLES W. STENHOLM, Texas 
HAROLD L. VOLKMER, Missouri 
TIMOTHY J. PENNY, Minnesota 
TIM JOHNSON, South Dakota 
BILL SARPALIUS, Texas 
JILL L. LONG, Indiana 
GARY A. CONDIT, CaUfomia 
COLLIN C. PETERSON, Minnesota 
CALVIN M. DOOLEY, California 
EVA M. CLAYTON, North CaroUna 
DAVID MINGE, Minnesota 
EARL F. HILLIARD, Alabama 
JAY INSLEE, Washington 
THOMAS J. BARLOW III, Kentucky 
EARL POMEROY, North Dakota 
TIM HOLDEN, Pennsylvania 
CYNTHIA A. McKINNEY, Georgia 
SCOTTY BAESLER, Kentucky 
KAREN L. THURMAN, Florida 
SANFORD D. BISHOP, JR., Georgia 
BENNIE G. THOMPSON, Mississippi 
SAM FARR, California 
PAT WILLL\MS, MCn'Una 
BLANCHE M. LAMBERT. Ark&nsas 



LA GARZA, Texas, Chairman 

PAT ROBERTS, Kansas, 

Ranking Minority Member 
BILL EMERSON, Missouri 
STEVE GUNDERSON, Wisconsin 
TOM LEWIS, Florida 
ROBERT F. (BOB) SMITH, Oregon 
LARRY COMBEST, Texas 
WAYNE ALLARD, Colorado 
BILL BARRETT, Nebraska 
JIM NUSSLE, Iowa 
JOHN A BOEHNER, Ohio 
THOMAS W. EWING, IlUnois 
JOHN T. DOOLITTLE, CaUfomia 
JACK KINGSTON, Georgia 
BOB GOODLATTE, Virginia 
JAY DICKEY, Arkansas 
RICHARD W. POMBO, CaUfomia 
CHARLES T. CANADY, Florida 
NICK SMITH, Michigan 
TERRY EVERETT, Alabama 



Professional Staff 

DlANNg^EpwELL, Staff Director 

Vernie HubEfflr, CnOf Counsel and Legislative Dir^or 

Gary R. Mitchell, Minority Staff Director 

James A. Davis, Press* Secretary 



Subcommittee on Specialty Crops and Natural Resources 



CHARLIE ROSE, 

SCOTTY BAESLER, Kentucky, 

Vice Chairman 
SANFORD D. BISHOP, Jr., Georgia 
GEORGE E. BROWN, Jr., CaUfomia 
GARY A. CONDIT, CaUfomia 
EVA M. CLAYTON, North Carolina 
KATEN L. THURMAN, Florida 
DAVID MINGE, Minnesota 
JAY INSLEE, Washington 
EARL POMEROY, North Dakota 
GLENN ENGLISH, Oklahoma 
CHARLES W. STENHOLM, Texas 
COLLIN C. PETERSON, Minnesota 
SAM FARR, Califomia 
HAROLD L. VOLKMER, Missouri 



North Carolina, Chairman 

TOM LEWIS, Florida 
BILL EMERSON, Missouri 
JOHN T. DOOLITTLE, CaUfomia 
JACK KINGSTON, Georgia 
BOB GOODLATTE, Virginia 
JAY DICKEY, Arkansas 
RICHARD W. POMBO, CaUfomia 
TERRY EVERETT, Alabama 



(ID 



CONTENTS 



Page 

Rose, Hon. Charlie, a Representative in Congress from the State of North 

Carolina, opening statement 1 

Smith, Hon. Robert F. (Bob), a Representative in Congress from the State 

of Oregon, opening statement 2 

Response to written questions 17 

Witnesses 

Bonnicksen, Thomas M., professor, department of forest science, Texas A&M 

University 5 

Prepared statement 87 

Cullinan, Timothy P., wildlife biologist. National Audubon Society 38 

Prepared statement 261 

Geisinger, James, president. Northwest Forestry Association 3 

Prepared statement 45 

Guse-Noritake, Judy R., director, national river policy. Pacific Rivers Council . 29 

Prepared statement 229 

Hermach, Timothy G., executive director. Native Forest Council 42 

Prepared statement 270 

Kaczynski, Victor W., certified fisheries scientist, St. Helens, OR 7 

Prepared statement 125 

McKillop, William, professor, forest economics, college of natural resources. 

University of California, Berkeley 9 

Prepared statement 178 

Norman, Julie Kay, president, board of directors, Headwaters 37 

Prepared statement 255 

Shaffer, Meirk L., vice president, resource planning and economics. Wilderness 
Society, also on behalf of the National Wildlife Federation and^the National 

Resources Defense Council 27 

Prepared statement 218 

Taylor, Robert J., director, wildlife ecology, California Forestry Association 10 

Prepared statement 203 

Submitted Material 

Belcher, Jennifer M., commissioner, public lands. State of Washington 290 

Carmichael, Richard W., president, American Fisheries Society, Oregon chap- 
ter, letter of November 15, 1993 298 

Letter of October 27, 1993 303 

Helms, John R., registered forester, Columbia, SC, letter of October 26, 1993 . 318 
Herger, Hon. Wally, a Representative in Congress from the State of Califor- 
nia, prepared statement 333 

KeUy, Mary Sauls, ecologist. Western North Carolina Alliance, letter of Octo- 
ber 25, 1993 337 

Sutton, Michael, acting vice president, U.S. land and wildlife program, World 

WUdlife Fund, letter of October 25, 1993 339 

(III) 



REVIEW OF THE ADMINISTRATION'S PRE- 
FERRED ^AJ^TERNATIVE FOR THE PACIFIC 
NORTHWEST MANAGEMENT PLAN 



THURSDAY, NOVEMBER 18, 1993 

House of Representatives, 
Subcommittee on Specialty Crops 

AND Natural Resources, 
Committee on Agriculture, 

Washington, DC. 
The subcommittee met, pursuant to call, at 2:05 p.m., in room 
1300^ Longworth House Office Building, Hon. Charlie Rose (chair- 
maif^f the subcommittee) presiding. 

Plpesent: Representatives Condit, Minge, Pomeroy, Peterson, 
Farr, Volkmer, Lewis, Doolittle, Kingston, and Goodlatte. 
Also present: Representatives Smith of Oregon and DeFazio. 
Staff present: Andy Baker, assistant counsel; William E. 
O'Conner, Jr., minority policy coordinator; Glenda L. Temple, clerk; 
Keith Pitts, Alexandra Buell; James A. Davis, and Stacy Carey. 

OPENING STATEMENT OF HON. CHARLIE ROSE, A REP- 
RESENTATIVE IN CONGRESS FROM THE STATE OF NORTH 
CAROLINA 

Mr. Rose. The Subcommittee on Specialty Crops and Natural Re- 
sources will please come to order. 

Today's hearing will consist of two panels to provide us with a 
review of the administration's preferred alternative for the Pacific 
Northwest Management Plan. 

Will our first panel please come to the table. 

Mr. James Geisinger, president of the Northwest Forestry Asso- 
ciation, Portland, Oregon; Dr. Thomas Bonnicksen, professor, de- 
partment of forestry science, Texas A&M; Dr. Victor Kaczynski, 
fisheries biologist; Dr. William McKillop, forestry department. Uni- 
versity of California; Dr. Robert Taylor, California Forestry Asso- 
ciation. 

Gentlemen, as you all know, your entire statement will be a part 
of the record. What we would like to ask you to do is to give us 
a 5-minute summary of the key points of your testimony. Several 
of our participants have late afternoon flights to catch. 

I want to thank you for attending this meeting. The hearing is 
a follow-up of our joint hearing on August 3, 1993, Serial No. 103- 
32, at which the administration testified about its proposal, and 
when Congress convenes next year the subcommittee will invite 

(1) 



other concerried parties to testify about the Presideht's plan, par- 
ticularly State and local government authorities. 

Mr. Smith of Oregon. Mr. Chairman. 

Mr. Rose. Yes, sir, Mr. Smith, for any opening statement you 
may have. 

OPENING STATEMENT OF HON. ROBERT F. (BOB) SMITH, A 
REPRESENTATIVE IN CONGRESS FROM THE STATE OF 
OREGON 

Mr. Smith of Oregon. I thank the chairman. I thank him for the 
courtesy of allowing me a very short opening statement, recogniz- 
ing that I am not a member of this subcommittee, but of course vi- 
tally interested in this issue. I appreciate that, Mr. Chairman, and 
thank you for holding this hearing. 

The administration, as you had previously stated, had their op- 
portunity to present their side of the story in August. Now, I think 
it is time to hear the real truth. It is sort of ironic that now Jack 
Ward Thomas gets to implement the forest plan that he secretly 
wrote in the Bank Tower in Portland. We are all watching carefully 
to see how Dr. Thomas performs in his new job. After all, he is 
uniquely qualified to manage 29,000 people and 150 forests in 
America after managing the Starkey Elk Station in northern Or- 
egon with four or five employees. 

I have gone back and I have looked at some of the testimony 
from that hearing in August and I was really startled by some of 
the comments, made by Mr. Lyons and Mr. Collier, when they were 
questioned about when are we going to get some timber to our 
mills in the Northwest. 

Let me take a moment to remind my colleagues about some of 
the promises Mr. Collier and Mr. Lyons made on August 3. 

First of all, Mr. Collier said he believed the Forest Service can 
have green sales on the ground early next year. That is next year. 
He even assured me that it would be a "worst-case scenario," if the 
administration wouldn't sell any timber until late 1994 or 1995. 
Well, it has been 108 days since he uttered this nonsense and I 
still haven't seen any timber. 

And what about Mr. Lyons' grand announcement that environ- 
mentalists were going to allow some sales to go forward. Let me 
quote him. "We identified 200 million board feet that we think we 
can move with quickly." 

Mr. Lyons must measure quickness by a sundial. That 200 mil- 
lion board feet turned into 83 million board feet and Judge Dwyer 
hasn't even released these sales, which by the way, amount to only 
a bundle of sticks for a wood-starved industry. This 83 million 
board feet is enough to run one medium sawmill for 1 year. 

And by the way, we hear now that there may be only 1 million 
board feet released, not 83 million board feet. I suppose the only 
truth that came out of that hearing is that the administration was 
covering up the job loss associated with this plan. 

We learned that the President's plan, although suggested it 
would cost 6,000 jobs, now we find out from their own people that 
it will cost 66,000 jobs. 

Mr. Chairman, by the time this administration realizes that op- 
tion 9 will never work, it will be too late for Oregon's timber com- 



35 

munities. It is high time that they swallowed their pride, admit 
this plan is an unmitigated failure, and work with Congress to 
craft a balanced solution. 

I thank my friend for allowing me to make this statement. And 
if he is still on the phone, I will begin to conduct this hearing. That 
ought to shock him. 

I will yield to my friend Mr. Peterson for any comments he would 
like to make. 

Mr. Rose. Mr. Peterson. 

Mr. Peterson. I am just happy to be here, Mr. Chairman, 

Mr. Rose. Our first panelist, Mr. James Geisinger, will you 
please proceed, sir. 

STATEMENT OF JAMES GEISINGER, PRESIDENT, NORTHWEST 

FORESTRY ASSOCIATION 

Mr. Geisinger. My name is James Geisinger. I am president of 
the Northwest Forestry Association. 

Mr. Chairman, I would like to submit for the record, as an at- 
tachment to my prepared statement, our full and complete analysis 
of the President's option 9. It was prepared by 20 experts in the 
field of forest ecology, silviculture, wilderness ecology, biology, fish- 
eries, hydrology, economics, and sociology; 15 of those individuals 
are Ph.D. -level scientists. 

We are fortunate to have four of those individuals with us today. 
They are Dr. Tom Bonnicksen, a professor of forestry at the depart- 
ment of forest science at Texas A&M; Dr. Vic Kaczynski, a consult- 
ing fisheries biologist from Tigard, Oregon; Dr. Robert Taylor, a 
Wildlife Ecologist with the California Forestry Association; and Dr. 
William McKillop, a professor of forest economics at the University 
of California, Berkeley. 

Before we hear from the doctors, however, I would like to make 
a few brief comments on behalf of the patient. The forest products 
industry had very high hopes going into the forest conference proc- 
ess. We were hopeful it would be a procedure that would break the 
gridlock and get back to prudent management program for our for- 
est. 

Unfortunately, we find ourselves today in a worse situation than 
we were in on April 2, when the President convened his conference. 
The President promised on April 2, to break the legal gridlock, to 
get us out of the courtroom and back into the conference room. He 
promised a fair and a balanced solution, one that brought science, 
social concerns, and economics together in a integrated way and a 
plan that would be legally credible. 

He said that it would be a plan with long-term certainty and 
short-term relief. When he said those things, we were almost cer- 
tain that he was referring to a legislative solution because a new 
bill is the only vehicle for delivering on those promises. It is the 
only way to eliminate the court injunction and it is the only way 
to set a long-term strategy for managing our public forest re- 
sources. 

Our hopes were dashed on that very same day when he and the 
Vice President went into the basement of the Portland Convention 
Center and announced that they had no intentions of modifying 
any laws, streamlining any regulations, or offering any new laws. 



What proceeded in the following 90 days was a process whereby 
a handpicked group of scientists, each of whom had established a 
track record as advocates of special interests, met behind closed 
doors with no public input, nor with input from other scientists 
with opposing views. They developed a plan that we believe to be 
illegal, utilizing an illegal process that produced a very skewed 
range of alternatives for the President to consider. 

This process and product violated the Federal Advisory Commit- 
tee Act, the National Environmental Policy Act, the National For- 
est Management Act, the Federal Land Management and Land 
Planning Act, and the O&C Act. The product of these scientists' ef- 
forts is neither balanced nor is it a solution. 

Let me address the issue of balance. What the President has pro- 
posed would reduce regional timber supply in the Northwest by 76 
percent. It would eliminate some 70,000 jobs. It would prohibit any 
programmed timber harvests on 83 percent of the Federal forest 
land base addressed by these scientists. It will result in the closure 
of multimillion dollar facilities that employ people that have the 
highest wages of any industry in our region. 

It is not an ecosystem management plan as characterized by the 
scientists. It is a preservation plan designed to create old-growth 
forests in as rapid a manner as possible on 83 percent of the Fed- 
eral forest lands in the region. Its objective, as stated by the sci- 
entists, is to recreate these forests into their presettlement condi- 
tions and, Mr. Chairman, I can't find any place in our laws that 
identify "presettlement conditions" as a management objective for 
our forest lands. It emphasizes almost entirely late successional 
forests and wildlife that depends on them, with absolutely no men- 
tion of wildlife that depends on early successional forests. 

We are still in court today. The court injunction is still in place. 
The Forest Service is working on yet a fourth environmental im- 
pact statement for a district court judge that has rejected three so 
far. Why we should think the fourth time is going to be the charm, 
is absolutely beyond me. But even if this plan is acceptable, even 
if our industry was willing to swallow hard and accept a 76-percent 
reduction in timber supply, the fact is, as presently constituted, 
this plan will not work. The best scenario is that a record of deci- 
sion will be done by April 1, 1994, midway through the fiscal year 
1994. 

If there are no appeals and there is no litigation, the Forest Serv- 
ice will begin preparing timber sales, which is a very lengthy proc- 
ess. Most of those sales will have to go through section 7 consulta- 
tion under the Endangered Species Act for fish, marbled murrelets, 
or spotted owls, a process in our experience that takes at least 6 
months. So clearly, we are right out of 1994 and into 1995 before 
we even begin. 

I would like to compare briefly where we are today as opposed 
to April 2. On April 2, we had an injunction in place. We had a 
flawed EIS and a date to go before the judge. Today, we have an 
injunction in place and we are working on another EIS and we 
have a date in court with that same judge. 

The net effect of the President's intervention in this process has 
been to delay any decisions by at least a year. Nothing more, noth- 
ing less. 



■M 

Just briefly, I would like to comment on what we know today 
about the process that occurred in the U.S. Bank Tower that Con- 
gressman Smith referred to. The process was well underway before 
April 2. This process and the scientists involved were selected be- 
fore the President ever came to Portland. 

Secretary Babbitt instructed them at least 2 weeks before the 
conference occurred to apply the NFMA viability rule to all alter- 
natives and all lands, whether they be administered by the BLM 
or the Forest Service, an illegal act, I might add. One scientist on 
the panel admitted that this was not a scientific process but in fact 
was a policymaking process and referred to their office as the 
"tower of power" to give you some idea of the self-importance they 
anointed on themselves. 

I would like to conclude by simply saying that these scientists 
were asked to solve a legal dilemma and make a policy decision 
that rightfully belongs in this institution, the U.S. Congress. And 
our message to you, if you hear anjrthing today, is that you must 
come to the table and settle this issue with a long-term solution 
that the people of the Northwest can rely on. This responsibility 
does not belong to a group of scientists. It does not belong exclu- 
sively to the executive branch. It belongs here. 

Thank you. 

[The prepared statement of Mr. Geisinger appears at the conclu- 
sion of the hearing.] 

Mr. Rose. Thank you, sir. 

Next panelist, please identify yourseif. 

STATEMENTT OF THOMAS M. BONNICKSEN, PROFESSOR, 
DEPARTMENT OF FOREST SCIENCE, TEXAS A&M UNIVERSITY 

Mr. BONNICKSEN. My name is Dr. Thomas Bonnicksen. I am a 
forest ecologist and professor or forestry in the department of forest 
science at Texas A&M University. I have conducted research on the 
restoration and management of ancient forests for more than 23 
years. 

I will comment briefly on the FEMAT report that forms the basis 
for the President's plan and then I will answer three questions that 
I was asked to address about maintaining old-growth forests. 

Flawed science and a bias against timber management within 
the FEMAT report deprived the President of information on many 
effective options for managing old growth. The report presented 10 
options that actually constitute variations of one previous rec- 
ommendation, setting aside protected reserves. Consequently, the 
poor advice received by the President led to the adoption of a pres- 
ervation-oriented forestry plan. 

The President's plan includes ,7 million acres of reserves, of 
which only 37 percent contain large, trees. Thus, the reserves are 
composed mostly of cut-over land and young forests instead of old 
growth. Of concern is the lack of a convincing rationale to justify 
the amount of land set aside in reserves and the lack of a plan to 
manage these reserves. 

The first question I was asked to answer: Did the natural or 
presettlement forest include a large amount of old growth? 

A persistent myth about ancient forests is they were composed 
mostly of large old trees. Ancient forests did contain patches of old 



growth, but they also included patches of young trees, shrubs, and 
grasslands. Differences in the amount of old growth in ancient for- 
ests depended primarily on the frequency and intensity of fires. 

The President's plans affects forests under two fire regimes: In- 
frequent and massive fires that killed most of the trees and fre- 
quent and small surface fires that thinned the forest and killed few 
large trees. This distinction was not made in the FEMAT report. 

The natural or presettlement forest produced by these two fire 
regimes share a common attribute; they formed a mosaic of patches 
of different-sized trees. The size of the patches within the mosaic 
were large in the massive fire regime and small in the surface fire 
regime. 

My analysis shows that old growth occupied a small proportion, 
18 to 21 percent of the natural forest in areas dominated by the 
surface fire regime. Old-growth occupied a somewhat larger propor- 
tion — 42 to 60 percent for Douglas-fir forests — of the natural for- 
ests in the areas dominated by the massive fire regime. 

The second question I was asked to answer: Is a series of large 
reserves needed to maintain healthy old-growth forests? 

The short answer is no. Unfortunately, the FEMAT assessment 
relies on reserves because it accepts a typical preservationist bias 
against humans, including American Indians. To admit that Indi- 
ans played a decisive ecological role jeopardizes the idea that old 
growth can only be presei:yed in dehumanized reserves. 

Nevertheless, at the time of European"^ settlement, there were 
about 12 million Indians living in ^forth America who had been 
managing the lapd for over 11,000 years. Anr^erican Indians were 
a natural and dominant force responsible for creating' and main- 
taining ancient forests. 

A series of large reserves is not needed to establish and maintain 
healthy old-growth forests. The removal of Indians and the sup- 
pression of fires has already led to the deterioration of forests with- 
in our national parks and wilderness areas. The reserves in the 
President's plan will compound the problem and produce 
unsustainable artificial forests unlike any that existed in tbe past. 

In the surface fire dominated regime, the plan will allow fire cy- 
cles to shift toward longer intervals and larger, more dangerous 
fires than existed under presettlement conditions. The dominant 
species will also shift from shade intolerant species like ponderosa 
pine to shade tolerant species like white fir. 

In the massive fire dominated region, the President's plan will 
allow small western hemlock trees to gradually replace the huge 
Douglas-fir trees that people associate with old-growth forests. 
Douglas-fir trees cannot regenerate without fire or other disturb- 
ances. 

The reserves proposed in the President's plan represent tiny 
fragments of forest that are isolated from one another. These iso- 
lated fragments can never function as an interconnected and self- 
sustaining forest ecosystems. 

The third question I was asked to answer: Are there options in- 
volving timber harvesting that would maintain healthy old-growth 
forest? 

The short answer is yes. The FEMAT assessment rejects options 
involving timber harvesting as a tool to maintain old growth. The 



assessment team made it clear that they doubt that managers can 
create old growth. That is a philosophical argument, not a scientific 
fact. No scientific evidence exist to support the contention that old 
growth cannot be created. On the contrary, American Indians cre- 
ated and maintained old-growth forests for thousands of years. 

There are at least four timber harvesting options in my written 
statement that could maintain old-growth forests. These four op- 
tions would be more successful than the reserves proposed in the 
plan. 

A limited number of reserves are needed for scientific purposes, 
but reserves will not preserve old growth. Timber harvesting op- 
tions can maintain old growth, generate the revenue needed to pay 
management costs, and protect jobs in local communities. In con- 
trast, the reserves proposed in the President's plan will eliminate 
thousands of jobs and create costly, unnatural old-growth forests 
that cannot be sustained. 

Thank you. 

[The prepared statement of Mr. Bonnicksen appears at the con- 
clusion of the hearing.l 

Mr. Rose. Thank you very much. 

We will have questions of the panel as soon as all of you have 
made your statements. 

Dr. Kaczynski. 

STATEMENT OF VICTOR W. KACZYNSKI, CERTIFIED FISHERIES 

SCIENTIST, ST. HELENS, OR 

Mr. Kaczynski. Yes, sir. 

My name is Dr. Vic Kaczynski. I am a practicing fisheries ecolo- 
gist with 24 years of professional experience with salmonid issues 
in the Pacific Northwest from Alaska to northern California. My 
presentation today summarizes the highlights of testimony submit- 
ted by Dr. John Palmisano. I worked with Dr. Palmisano on the de- 
velopment of this testimony. 

Most Pacific salmon and trout migrate through several distinct 
habitats during their complex life cycles. Think of their needs as 
a triangle with three sides. The three sides being fresh water, the 
estuary, and the ocean. Any one of these major habitat types can 
be a critical limiting factor in their survival and abundance. 

Forest streams are but a small part of the complex of habitats 
needed for the growth and survival of these fish. Most forest 
streams are small, steep, and have low biological productivity. A 
large majority of these streams are not the primary spawning or 
rearing habitat for salmon. However, they are the primary habitat 
for the common resident cutthroat trout. 

No evidence is presented in the FEMAT report that forest stream 
habitat is limiting the abundance of our anadromous Pacific salm- 
on and trout. I want to repeat that. No scientific evidence was pre- 
sented that forest stream habitat is limiting the abundance of 
salmon and trout in the Pacific Northwest. In fact, much scientific 
evidence exists that our forest streams, even though they are sec- 
ondary salmon habitat, are underutilized today. 

Some improvement in survival can be made through the en- 
hancement of forest stream habitat. However, the increase in adult 



8 

abundance will be relatively small. More significant gain can be 
made elsewhere in the critical triangle of salmon life. 

The lower gradient floodplain reaches of our streams and rivers 
are relatively much more productive and, unfortunately, more de- 
graded than are our forest streams. Local flood control projects, 
water withdrawals for our civilization and our economy, point and 
nonpoinf pollution have all taJcen their toll on our streams and riv- 
ers. 

Also, our larger rivers are often developed for multipurpose 
projects such as flood control, storage, irrigation, and hydroelectric. 
We can and should do a much better job of protecting and restoring 
the downstream freshwater habitat. Further gains can be made in 
restoring and mitigating lost estuary habitat. 

Too much critical estuary area has been lost in the Pacific North- 
west. Juvenile salmon are forced to migrate into the ocean when 
estuary food supplies run out. These smaller fish are more vulner- 
able to predators and suffer a higher mortality rate as a whole as 
a result of this. The larger the salmonid upon entry into the ocean, 
the higher the probability of its survival. 

Finally, we need to properly manage our ocean, bay, and river 
fisheries. Significant overharvest of wild stocks has been a serious 
problem which has been aggravated by hatchery production. Hatch- 
ery stocks can sustain high harvest rates while w.ild stocks can 
only sustain low to moderate harvest rates. We have had a mixture 
of hatchery stocks and wild stock in the ocean, and up until 1992, 
last year, we have managed our ocean fisheries to harvest at the 
higher hatchery rate. We must guarantee enough spawners to fully 
seed the freshwater habitat and this simply has not occurred. 

These conclusions are not presented to negate reasonable and 
prudent protection and restoration of forest stream habitat. Rather, 
the conclusions are presented to demorl^trate the need for a more 
balanced and effective salmon restoration plan. The draft plan just 
released for the Snake River recovery team is an example of a more 
comprehensive needed approach. 

I am very critical of the proposed plan because of the absence of 
appropriate mission actions by some agency authors of the plan. 
The plan is glaring in its omission of such actions. And such ac- 
tions would have had a liiuch higher probability of success to re- 
store our depressed fish stocks. In fact, by itself, the proposed 
FEMAT plan has a low probability of restoring depressed fish 
stocks. 

Forest stream measur^es alone simply have too low a potential to 
significantly restore our depleted fish stocks. The biological produc- 
tivity potential simply isn't there. The same relatively low level of 
success could be gained by much less severe levels of land manage- 
ment activities and restrictiorts in our Federal forests. ' 

Thank you. 

[The prepared statement of Mr. Kaczynski appears at the conclu- 
sion of the hearing.! 

Mr. Rose. Thank you very much. 

Next, Mr. McKillop. 



STATEMENT OF WILLIAM McKILLOP, PROFESSOR, FOREST EC- 
ONOMICS, COLLEGE OF NATURAL RESOURCES, UNIVERSITY 
OF CALIFORNIA, BERKELEY 

Mr. McKiLLOP. Thank you, Mr. Chairman. 

My name is William McKillop, professor of forest economics at 
the University of California, Berkeley. 

I will comment on some of the defects of the FEMAT report and 
highlight the severe economic impacts of adopting the forest plan, 
that is FEMAT option 9. 

A major defect of FEMAT is that it did not compare its options 
to a proper baseline alternative. As a result, the severe economic 
impacts of the options were not properly exposed. It should have 
used some period such as 1980 to 1989 as a baseline period for 
making this assessment. 

The annual Federal timber harvest over that period averaged 4.5 
billion board feet per year and that, Mr. Chairman,. was a level of 
timber harvest that was clearly sustainable. I'he plan calls for a 
3.4 billion board feet reduction, that is a 76 percent reduction from 
that level. This will lead to a loss of 34,000 jobs in the timber in- 
dustry and 38,000 other jobs in the economy at large, for a total 
loss of 72,000 jobs. 

My estimate is very ; close ' to the estimate made by Professor 
Greber in front of this committee some time ago. He estimated a 
loss of 66,000 jobs, but unlike myself, he did not include losses in 
the pulp and paper industry. 

There would be a loss in payrolls and other regional' income of 
$1.7 billion a year. In addition, there would be major losses to all 
levels of government. Net receipts to the U.S. Treasury from timber 
sales will drop by $300 million a year. Revenue to county and 
school districts will drop by $200 million a year. There will be a 
loss in State income tax receipts of about $60 million a. year and 
a loss in Federal income tax receipts of approximately $120 million 
a year. That is a total revenue loss per year of some $680 million 
to government. 

In addition, Government must find $750, million which will be 
needed to provide unemployment compensation for the laid-off 
workers for the first 12 months of their unemployment. 

The plan will also have major adverse impacts on consumers of 
wood products throughout the United States. It will cost them ap- 
proximately $3 billion a year because of increased lumber and ply- 
wood prices. That means that the aggregate national loss from 
adoption of this plan will be something like $4.7 billion a year. 

Now, the FEMAT report attempts to gloss over the severe em- 
ployment impacts of the plan by pretending there will be increased 
activity in recreation, tourism, special forest products and service 
forestry, and its analysis of this issue is totally false. The most at- 
tractive areas, from a tourist or recreational point of view, are al- 
ready in reserves. Some 8.6 million acres, that is 36 percent of the 
Federal land base in this region, is already in parks, reserves, and 
wilderness areas. 

Furthermore, the vast majority of users of the national forests 
require access by roads to pursue their recreational and other ac- 
tivities. And these are roads that have been built with timber har- 
vest receipts. Without timber harvesting, those roads would not 



10 

have been built and the national forests would not have been acces- 
sible to the vast majority of the people of Oregon, Washington, and 
other regions. 

The same thing goes for the gathering of special forest products 
which the FEMAT report emphasizes. We are talking about folks 
that gather wild mushrooms and foliage. They need roads to bring 
their products to market, and furthermore, most of their products 
are found in young-growth forests not in old-growth forests. 

None of the options will result in increases in fisheries stocks, as 
Dr. Kaczynski explained. That means that there will be no increase 
in employment in the commercial fishery industry. And the same 
goes for service forestry. Tree planting and forest improvement 
work activity in that area will significantly decline because most of 
that work follows the harvesting of timber to replant areas and to 
tend young forest stands. 

So, Mr. Chairman, this plan is, from an economic point of view, 
a disaster for the people of Washington, Oregon and northwestern 
California. And in addition, it is ironic that from an environmental 
point of view, it is counterproductive, when one looks at the global 
environment and the national environment as well. 

We have some of the most productive forests in the world, as I 
know from my worldwide experience, here on the Pacific coast. If 
we don't produce a reasonable part of our needs for raw materials 
from this area, then we are going to have to get it from Canada. 
As a result, the Canadians are going to ship less to Japan and 
other parts of Asia, like Taiwan and Korea, who are going to have 
to turn around and get it from the tropical forests of Malaysia and 
Indonesia or from the fragile ecosystems of Siberia. In Siberia, for 
example, you must log 15 times the acreage to get the same 
amount of wood that you can get from 1 acre here on the Pacific 
coast. 

Furthermore, the higher lumber and plywood prices are going to 
drive consumers to substitute materials such as steel and concrete. 
Those materials require much greater levels of energy, at least 10 
times the energy to manufacture and, in addition, cause much 
greater levels of pollution in their manufacture and use. 

Therefore, Mr. Chairman, not only is this an economic disaster, 
it is counterproductive from an environmental point of view. 

Thank you. 

[The prepared statement of Mr. McKillop appears at the conclu- 
sion of the hearing.] 

Mr. Rose. Thank you. Dr. McKillop. 

Next, Dr. Taylor. 

STATEMENT OF ROBERT J. TAYLOR, DIRECTOR, WILDLIFE 
ECOLOGY, CALIFORNIA FORESTRY ASSOCIATION 

Mr. Taylor. By way of introduction, my name is Robert Taylor. 
I have a Ph.D. in biology from the University of California, Santa 
Barbara. For 18 years, I taught biology, ecology, and wildlife biol- 
ogy at the University of Minnesota, Clemson University, and Utah 
State University. I have published in the fields of animal popu- 
lation biology, predator-prey relationships, biodiversity, and land- 
scape ecology. I am director of wildlife ecology for the California 



11 

Forestry Association, where I do research and policy work on 
threatened and endangered species. 

I am here to voice the concern I share with other wildlife biolo- 
gists in the forest products industry and elsewhere over the report 
of the Forest Ecosystem Management Assessment Team, FEMAT, 
and the resultant option 9, the administration's plan for managing 
the Federal forests of the Pacific Northwest and northern Califor- 
nia 

In preparing this testimony, I was frustrated with the extent 
with which this document is being portrayed as science. I want to 
state in the strongest possible terms that the FEMAT report is not 
a scientific document. 

It has three major flaws: From the wildlife standpoint, the first, 
and most obvious, is a distorted view of the application of scientific 
methods to natural resources decisionmaking. My written testi- 
mony contains examples of this. The list is long and I cannot ad- 
dress it in a few minutes. 

A second and more fundamental problem is that FEMAT chose 
to accept the administration's charge to plan for the viability and 
distribution of species known or reasonably expected to be associ- 
ated with old-growth forest conditions. Quite apart from the legal 
aspect of whether this is right or not, it is an impossible task sci- 
entifically. 

Viability, as the FEMAT team interpreted that word, is the prob- 
ability that a species will be present and well-distributed 100 years 
from now. The hard fact is that the ecological sciences cannot with 
confidence predict the abundance and distribution of any animal 
species more than 10 years into the future, much less 100. To come 
up, as this team did, with numerical assessments of viability is to 
do little more than quantify wild guesses. Ignorance expressed in 
numbers is still ignorance. 

The third major flaw is the FEMAT's refusal to incorporate the 
latest data readily available to them. An example of this is the re- 
cent information on the occurrence of and habitat use by the north- 
ern spotted owl. The information on which the FEMAT team based 
its report flies in the face of increasingly strong evidence that the 
owl is not old-growth dependent and is in fact not threatened. 

The only responsible options should be either to refuse the 
charge or to issue a report in which the dominant output from the 
Nation's forests would not be logs or birds or water, but scientific 
information. Why did the team not do this? 

The administration has stated that the scientists were merely 
following the orders of their decisionmakers. The charter under 
which they worked bears this out. At the same time, I am forced 
to conclude that the team was overwhelmingly dominated by below- 
average scientists and nonscientists. Let me defend that assertion. 

Working scientists publish in the peer-reviewed literature and 
any publication worthy of the paper it is printed on is cited. I tab- 
ulated the scientific citations for the year 1992 for all members of 
the team and also all members of the species expert viability pan- 
els. 

This is a standard method for evaluating the quality of scientific 
work. To provide a perspective, I examined the citation records of 
ecologists in several university departments and compared those 



12 

records to my subjective assessment of the individual scientific rep- 
utation. 

"Nonscientists" and "poor" scientists are not cited at all. "Below- 
average" scientists are usually cited 10 or fewer times per year. 
"Average" ecological scientists are cited 11 to 30 times per year and 
"above-average" scientists are cited more than 30 times per year. 
By this yardstick, I am an average scientist, I was cited 17 times 
last year. 

Of the 44 biologists on the FEMAT team, 7 percent were above 
average, 14 percent were average, 34 percent were below average 
and fully 45 percent were poor scientists or nonscientists. Of the 
74 biologists who comprised the species expert viability panels, and 
this surprised me, 9 percent were above average, 7 percent were 
average, 49 percent were below average and 35 percent were poor 
scientists or nonscientists. 

In other words, only 12 out of 74 were average to good scientists. 
What we have here, I submit, is a collection of policymakers, bio- 
logical bureaucrats, and below-average scientists cloaked in a false 
mantle of science certainty they have not earned the right to wear. 

I suggest it would be a mistake to consider the FEMAT report 
and option 9 as anything other than a work of political advocacy 
masquerading as a scientific document. 

[The prepared statement of Mr. Taylor appears at the conclusion 
of the hearing.] 

Mr. Rose. Strong letter to follow, right? 

Would all the others comment on Dr. Taylor's — I am not famil- 
iar — in Congress again we are very used to rating. We call them 
votes. Whether you win by 10 percent or 20 percent or you lose. 

But now you are keeping score another way here and you are 
saying about how many times you are cited in what? 

Mr. Taylor. In peer reviewed publications in the scientific lit- 
erature, any peer reviewed publication. 

Mr. Rose. All right. 

Is that a valid — Dr. Geisinger, is that a way of rating scientists? 

Mr. Geisinger. Unfortunately, I am not a doctor, but I would en- 
courage my colleagues to respond to that question. 

Mr. Rose. All right. 

Mr. BONNICKSEN. It is one of many criteria that is used for ad- 
vancement in university professorial positions, but it is equally im- 
portant to point out that regardless of the credibility of the sci- 
entists, there was a systematic effort to exclude members of the sci- 
entific community from FEMAT who had opposing points of view. 

Mr. McKlLLOP. My conclusion would be that Dr. Taylor's assess- 
ment of the scientific quality is appropriate. I did not look at the 
qualifications of the ecologists, and certainly from an economic 
point of view. Professor Greber is credible, but the whole tone of 
the writing of FEMAT relating to employment, I believe, had a 
great deal of political spin on it and was not really a scientific doc- 
ument. 

Mr. Rose. Thank you. 

I yield to Mr. Lewis for his questioning. 

Mr. Lewis. Thank you, Mr. Chairman. The statements just made 
seriously undermine the credibility of the report and the course of 



13 

action being pursued by the administration; what are the options 
at this point? Where do we go from here? 

Mr. Geisinger. I will take a shot at that, Congressman. I think 
this plan is doomed to failure; failure on its own weight and merit. 
It will not work and I am sure we can come back here a year from 
now and the story will be that little if any timber has been pro- 
duced by this plan. 

Rather than waiting 1 year or 2 years to find that out, I think 
we need to admit it today and pursue another course for resolving 
this issue. And I think that course belongs here in Congress. Con- 
gress is responsible for setting forest policy, not a team of sci- 
entists. 

I think it is time to sit down and try to embrace the concerns 
of our industry and the communities of people that depend on it 
in the Northwest, the concerns of the environmental community, 
and get on with legislating a solution. I can assure you that the 
next panel is going to be just as strident in their criticisms of this 
plan as I have been. 

But as you listen to them, I would hope that you would reflect 
on the debates of last year when a bill that was introduced on the 
environmental community's behalf by Chairman George Miller of 
the Interior Committee at that time, and Bruce Vento, a chairman 
of a subcommittee, a bill that would actually produce more timber 
than this bill will, was deemed to be so radical and so detrimental 
and destructive to the economy of the Northwest that the chairman 
couldn't get the bill out of his own committee. And a year later, we 
have a President advocating a plan that will produce less timber 
than that one would and the environmental community is still 
criticizing it, and I would hope that you would ask them why. 

Mr. Lewis. Anyone else wish to comment? 

Mr. BONNICKSEN. I will make one comment about it. First and 
foremost, it is tragic that a plan that is costing thousands of jobs 
is simultaneously not achieving its goal of preserving old-growth 
forests. Old-growth forests are not museum exhibits that simply 
can be managed by dusting them off. They are living things that 
are bom, grow old, and die. Without a management plan designed 
to continually reproduce old growth, the old-growth forests, particu- 
larly the large old Douglas-fir trees that we associate with these 
ancient forests, will simply disappear. 

So in answer to your question, since we cannot bring the Indians 
back and we cannot allow hundreds of thousands of acres to go up 
in large catastrophic fires as happened in presettlement times, I 
think we are going to have to rely on timber management as a tool 
not only to sustain the old growth but to use the revenue to pay 
the costs and simultaneously generate the wood that we need. I am 
absolutely convinced that we can use timber management success- 
fully to do that. 

Mr. Lewis. Thank you. 

Mr. Kaczynski. Mr. Lewis, in terms of the fish plan, the authors 
there tried to jam in the productivity to restore these stocks within 
the forest streams and the potential for doing that just isn't there. 
These higher gradient streams, just as in agriculture with high 
gradient hillsides, are low in productivity. Your real basic fresh- 



14 

water productivity is down in your lower gradients or floodplains, 
so ecologically you can't do it. 

If they are going to make the fish plan work to restore these 
stocks, they have to include these other options. They have to make 
it more comprehensive. Then they would have a much higher prob- 
ability of success and they have to bring in actions in the estuaries 
and the ocean. 

I didn't name the agency, but the National Marine Fishery Serv- 
ice, it was an author. So was the Environmental Protection Agency 
and so was the U.S. Fish and Wildlife Service. If they had an act 
in their mission responsibilities as part of the more comprehensive 
goal, we would have a higher probability of success. 

Mr. Lewis. Thank you. 

Mr. VOLKMER [assuming chair]. I have a few questions. 

How much timber, Jim, are we going — let's put it in, since I 
haven't been involved in this too much lately. We got here 1993 
coming to a close. How much timber did we cut out of region 6 in 
northern California and region 5 public lands? 

Mr. Geisinger. Off of public lands, I believe 

Mr. VOLKMER. U.S. public lands, BLM and Forest Service. 

Mr. Geisinger. I would estimate that they sold about 500 million 
board feet. 

Mr. VoLKMER. And how much do you anticipate or has been sold 
that will be cut next year? 

Mr. Geisinger. Well, right now with the court injunction in 
place, the only timber that is going to be sold is on the east side 
of region 6 in the area that you just defined. They had planned on 
selling 600 million board feet of timber off the east side, that was 
up until the time that the new Assistant Secretary of Agriculture 
decided to impose some screens on that 600 million feet, three of 
them. One was for preserving old growth and restoring the lands 
to their presettlement conditional. The second was to expand ripar- 
ian protection. The third was to provide wildlife habitat for other 
species. 

They are now saying, out of that 600 million feet, they might sell 
272 million board feet, and much of that still has to go through sec- 
tion 7 consultation with the Fish and Wildlife Service about the 
salmon, grizzly bear, and gray wolf. So how much of that is going 
to be sold is not known, but the optimistic assessment is 272 mil- 
lion board feet in an area that was selling around 5 billion. 

Mr. Volkmer. Well, the plan that this administration has pro- 
posed wasn't a great deal different, a little different, a little bit 
more comprehensive than what this committee reported out last 
year. 

Mr. Geisinger. I would submit that it is very different, Mr. 
Chairman. You are referring to Congressman Kopetski's bill which 
would have produced something in excess 

Mr. Volkmer. No, I am not talking about Congressman 
Kopetski's bill. I am talking about the bill that was reported out 
of the Agriculture Committee that used eight, not nine but used 
eight. 

Mr. Geisinger. You are talking about the "Gang of Four" option 
8? 

Mr. Volkmer. Yes. That is what we used. 



Mr. Geisinger. I thought that was the bill that was sponsored 
by Congressman Kopetski. At any rate, it would have produced in 
excess of 2 billion feet just from this region alone, not to mention 
northern California. It had considerably more acreage available for 
managing timber than this bill. This bill effectively places 83 per- 
cent of the 24 million acres addressed by the FEMAT team off lim- 
its for any sustained programmed harvest of the timber. We are 
left with 17 percent of the land base which would be managed 
under a much lower intensity of timber management than any plan 
tKe Forest'^ Service has ever developed. 

Mr. VOLKMER. Then you want to whisk this off to the Congress? 

Mr. Geisinger. The only way it is going to work, Mr. Chairman, 
in all candor, is if the President asks for your help, and what we 
are hope|ul of is that we won't^^ait until this time in 1994 or 1995 
to realize that the plan won't work. Secretary of Interior Lujan was 
routinely criticized up hjere on the Hiir''during his tenure as Sec- 
retary of Interior, but at least he had the foresight and understand- 
ing that he needed yQjUr help to solve this pfobl^m. And I am hope- 
ful that this administration will come to that i^alization sooner, 
rather than later, because time, frankly, is not on our side. 

Mr. VOLIQVIER. No. As one who has been through this war, and 
I know the gentleman from Oregon over there keeps smiling, as 
one who has been through this war, as you know, more than once, 
it will be very difficult, in my opiniSn, to get an3^hing passed 
through this House and the Senate because of the divergent views 
that the principals have involved. When I talk about the principals, 
I am talking about those that are affected adversely by the lack of 
timber harvest and those that feel that the land out there and the 
trees all have to be preserved. 

So I, for one, don't know what the chairman plans to do, the 
chaintfan of this subcommittee plans to do, but I do know that 
maybe the administration's plan won't work. Maybe it won't do all 
that it is supposed to do. But it is sure better than a three-page 
press release and you can remember a thf^e-page press release; 
can you not? 

Mr. Geisinger. Yes, I do, and I don't disagree with that. 

However, I would say that the "something is better than nothing" 
approach does not really take care of the problem out in the Pacific 
Northwest. 

Probably, as I mentioned in my testimony, even if you could ac- 
cept option 9 and the outputs prescribed in it, we don't believe that 
even 1.2 billion feet can be produced and in the process of imple- 
menting this plan prematurely and illegally, this administration is 
breaking all the same procedural environmental statutes that they 
have accused previous administrations of breaking. 

The east side screens that I just mentioned, were an arbitrary 
decision by the Assistant Secretary of Agriculture to reduce 
planned timber sales, sales that were funded by Congress by 60 
percent. And he did it with a memo. 

I have to believe that if another administration or any adminis- 
tration tried to increase timber sales by 60 percent with a memo 
over and above what Congress had authorized, they would get 
hauled into court. 



16 

Unfortunately, that is the position that we have been placed in 
regarding this decision. 

Mr. VOLKMER. Do you have a proposal? 

Mr. Geisinger. At this time, we don't have one that is very spe- 
cific. We certainly have some ideas that we have been discussing 
amongst ourselves in the industry, and come next year, we will be 
prepared to advance a proposal, unless you think we can get one 
passed by next Tuesday. 

Mr. VoLKMER. Well, you know as well as I do about that. 

Well, as far as this gentleman is concerned, I am always willing 
to look at anything that somebody is willing to propose. I haven't 
had time to be here through the full testimony and I personally 
haven't had time because of working on other things, things called 
floods for the people affected by those out in my district, in my 
State and I haven't taken the time to — really I haven't reviewed 
the administration's proposals that well but because of testimony 
here today, we will do that. Mr. Smith. 

Mr. Smith of Oregon. I thank the chairman very much. 

Well, you thoroughly thrashed option 9. It doesn't protect the 
fish. Its economic impacts were not correctly determined. A $4.5 
billion hit is a huge amount. And the scientists weren't qualified 
to do this or at least underqUalified. I hope you all have tenure, 
do you? Good. Well, that eases my mind. 

First, I would like to ask any of the four of you, I have a letter 
before me written on April 23, which I would like to submit for the 
record from the Fish and Wildlife Service in Portland, Oregon, 
signed by Marvin Pleriert, and the letter was in a response to a 
question that I had with respect to where and when you could har- 
vest timber in owl habitat. 

He is talking about the removal of selective . tree harvest. And 
they harvested, by the way, this timber in owl habitat in the. most 
environmental-sensitive place in the whole world, a watershed over 
in Ashland, Oregon, where we have the Shakespeare festival. They 
harvested some 10 million board feet in the watershed and the 
water source of Ashland Oregon. 

"The result was that owls seemed to cope with the light touch of 
activity very easily, even while on the nest, while nearly 10 million 
board feet of timber was removed. We do not believe that this ac- 
tivity has created any threat to the survival or recovery of the owl; 
we believe the forest habitat has been improved by creating a 
multistoried canopy with the remaining debris for forage habitat." 

Question: As I understand it, FEMAT has a principle of saying 
you cannot harvest timber in owl habitat. Here is a Forest Service 
biologist who says if you do it at the proper time while they are 
not nesting or while they are not breeding, you don't impact spot- 
ted owl. 

Question: Do you agree with this analysis? 

[The letter follows:] 




17 



TAKE" 
PRIDE INS 



United Slates Department of the Interior america| 



FISH AND WILDLIFE SERMCE 

911 N E. llih Avenue 
Portland, Oregon 97232m81 



AKK Z'^W3 



Honorable Robert F. Smith 
U.S. House of Representatives 
Washington, D.C. 20515 

Dear Mr. Smith: 

We were pleased to receive your letter of April 8, regarding alternative 
forest practices In n9rthern spotted owl habitat. We, too, are excited about 
the possibility of h^vipg logging proceed in a manner consist4nt with 
conservation of listed species , "and the Ashland/Applegate projects are 
examples of how this can occur. 

We will attempt to answer your questions with a note towards positive actions 
that can be taken to loosen the gridlock now before us. 

1) What were the conditions or constraints that enabled logging to occur in 
spotted owl habitat in the Ashland watershed and does that logging present any 
threat to the survival or perpetuation of the northern spotted owl. In your 
opinion? 

Response - The conditions of the Ashland watershed were exemplary of over- 
stocking of for, St species and a dangerous level of "fuel" on the ground for 
the encouragement of fires. The Ashland watershed is primarily managed for 
the water supply of the City of Ashland, but also is used extensively for 
recreational nature observation. The major management tools used in deciding 
the amount of harvest were: a) what would the forest have looked like without 
timber harvest and without fire abatement, and b) what are the objectives for 
a healthy ecosystem, Including listed species (e.g. spotted owl)? The 
Forest's fire management specialist was deeply Involved in the planning of the 
timber harvest, as well as the controlled burns to reduce fuel levels. The 
other major factor was the avoidance of clear cuts as the harvest 
prescription. Helicopter removal of selected tree harvest was accomplished 
throughout the Forest, Including areas near owl nests. "The" result was that 
owls seemed to cope with the "light touch". of activity very easily, even while 
on the nest, while nearly 10 million board feet of timber was removed. We do 
not believe that this activity has .created any threat to the survival or 
recovery of the owl; Indeed, we believe the Forest habitat has b een _ Im p roved 
by creating a multl-storled canopy -with thereiaalnlng debris for forage 
habitat. - 

2) If logging can indeed be conducted on an ecologically sound basis- - 
without threatening the spotted owl- -on that scale, would It be possible to 
conduct similar logging on a larger experimental area, such as the Rogue River 
National Forest? 



18 



Honorable Robert F. Smith 



Response - In our view, the larger the landscape under consideration, the more 
options for management to occur. It should be understood, however, that 
single ownership management often creates situations of conflicting practices. 
As such, it is extremely important to have the cooperation of all landowners 
In the landscape in order to cooperatively ensure that all forested areas 
receive equal opportunity for harvest and equal responsibility for 
conservation. In larger management units, such as the Rogue River, timber 
harvest could be managed to ensure that areas harvested In one area of the 
landscape are supported by habitat in another area of the landscape. Through 
this approach over time, the whole landscape could receive selective harvest 
treatments while new trees come on line to replace their function as older 
habitat. This is precisely the approach under planning for the Applegate 
watershed adjacent to the Ashland watershed. Following the example of the 
Ashland project, the Applegate project has brought in Federal, State, and 
private landowners to plan the ecologically sensitive manner in which logging 
can continue without degrading the quality of the environment. We believe 
this is an attainable goal and have supported this effort. Ue would also 
support a large scale effort on the Rogue River National Forest and, 
hopefully, adjacent landowners. 

3) If Pacific Northwest forests were to be managed on an ecosystem basis, 
rather than the species-by- species struggles of late, would it be possible 
and/or necessary to prescribe similar management within other land use 
designations where timber harvest is currently prohibited? 

Response - We interpret your question to revolve around wilderness. National 
Parks, and Habitat Conservation Areas under the Interagency Scientific 
Committee (ISC)," or their Designated Conservation Area replacement under the 
draft Recovery Plan for the northern spotted owl. Since wilderness and 
National Park areas are guided by specific legislation, we will focus on the 
need for "set-asides" for the northern spotted owl. Many of these areas have 
been identified to protect the remnants of old growth forests and to provide 
for new habitat to be created within the units. We agree that species-by- 
species management will not bring about holistic solutions and also believe 
the primary obstacle to progressing to landscape management is a lack of 
trust. Many in the public interested in maintaining the ecological integrity 
of the northwest forests do not believe the forests have been managed properly 
and do not have trust in the Federal agencies to ensure ecosystem diversity. 
Conversely, many others (including private landowners) do not believe that 
they will be able to see their investments in the forest industry mature for 
their children. As a result, some harvests are occurring at a rotational 
cycle as young as 35 years to avoid the possibility of creating habitat that 
might be regulated. 

If these problems in trust could be overcome, there would only be the need for 
"set asides" as the anchor areas from which to manage the landscape, and then 
only until the surrounding landscape becomes healthy. W»<i«i4»»Wstic 
• manageraent-l? done IpJc^pp£t^j;^^|ieM-is^»0-iT««t-ii«d'%or-^ 
iireas could receive both"con"servation arid harvest .with the overall ecosy.Steni 



19 



Honorable Robert F. Smith 



In mind. In addition, this approach could eliminate the need to list species 
under the Endangered Species Act because the threats of extinction from 
habitat degradation will have been significantly eliminated. 

We have always taken the position that good forest management is also good 
wildlife management. When the habitat reflects natural, or near natural, 
conditions, the species should be provided for. This is the goal of the Fish 
and Wildlife Service in the northwest forest issue. 

We appreciate your continued interest in resolving these conflicts and moving 
toward healthy ecosystems and sustained timber harvest. If we can be of 
further assistance, please do not hesitate to contact me. 

^_ Sincerely, 



^iU^/(jJuu.J~- 



.'....;. .1,, t. Ft_ ...T 
Regional Director 



20 

Mr. Taylor. Congressman, I would like to counter with another 
letter that I would like to enter into the record. That is a letter of 
June 29, 1993, to President Clinton, from four Forest Service biolo- 
gists, two of whom were members of the interagency scientific team 
chaired by Jack Ward Thomas that generated the system of owl re- 
serves. These four biologists repudiate the notion of owl reserves in 
California and southern Oregon as a dangerous way of dealing with 
the fire situation and think that we ought to stop and rethink the 
situation for spotted owls in this area. 

[The letter follows:] 



United States 
Department of 
Agriculture 



Forest 
Service 



21 



Pacific Southwest 
Research Station 



P.O. Box 2k5 
Berkeley. CA 9^701 



Reply to: 4000 

Date: June 29. 1993 



Honorable Bill Clinton 
President of the United States 
The White House 
Washington, D.C. 20500 



Dear President Clinton: 

The Forest Ecosystem Management Assessment Team, assembled at your direction 
following the Forest Conference in Portland in early April, has been 
developing a set of options and recommendations for your use in crafting an 
integrated approach to managing Pacific Northwest forests. We support the 
efforts of the highly qualified people who have been working on the Ecosystem 
Team. We also support your premise underlying the Forest Conference — that a 
healthy environment and a healthy economy can be compatible. The purpose of 
this letter is to urge you to select a course of action for certain Pacific 
Northwest forest ecosystems that we think is critical to their health and 
integrity, and that may at the same time enhance opportunities for 
en:plcyme.".t. The ecosystems in question, and the reasons we believe that 
special provisions are needed for them, are described briefly below. 

The geographic scope of the work of the Ecosystem Team is the range of the 
northern spotted owl. Forested ecosystems throughout this range have been 
strongly influenced by fire and other disturbance factors such as insects, 
diseases, and wind. However, the characteristic fire regimes--for example, 
how often and how severely fires burned in the centuries before European 
settlers begar. to exert ir.ejor influences on the forests — differ widely among 
subregions of the ranee, rri"srily in response to clinstic differences. The 
Sicist "ores--£ west of the Cascade crest ir. Washington and Oregon and north of 
the Klamath Mountains (for simplicity, hereinafter referred to as "moist" 
forests) bur.ned relatively infrequently, in some places only once every 
several hundred years. When they burned, however, fires tended to be severe 
and to kill most large trees over wide areas. The drier forests east of the 
Cascades in Washington and Oregon, in the Cascades of northern California, and 
in the Klamath Mountains of southwestern Oregon and northwestern California 
(hereinafter referred to as "dry" forests) had quite different fire regimes. 
In these areas fires burned much more frequently (on the order of once every 5 
to 30 years), and because less fuel accumulated between fires, they also 
burned less severely. Typically, medium- to large-sized trees survived o\'er 
most of the burned area. 

Forests with these very different fire regimes also differ substantially in 
terms of impact of past management activities and risk of catastrophic loss or 
ecosystem deterioration. Fire suppression policies begun in the early 1900s 
have affected the moist forest ecosystems relati\'ely little. These same 

function of the dry forests. As frequent fires of low to moderate severity 
have ceased being a dominaint ecological force, trees of fire-sensitive and 



22 



President Clinton ' Page 2 

shade-tolerant species have increased dramatically in abundance, particularly 
in small to medium size classes. Unnaturally dense stands have led to drought 
stress and insect outbreaks, resulting in widespread mortality of trees in 
many areas and the potential for extensive mortality in many other places. 
Along with fuels on the forest floor that have accumulated far beyond their 
normal levels, these stand conditions have substantially increased the 
probability (and actual occurrence) of large-scale, catastrophic wildfires. 
Such adverse changes certainly are not consistent with the goal of sustaining 
healthy, productive, biologically diverse forest ecosystems. 

The necessity and difficulty of restoring and sustaining these dry forest 
ecosystems is emerging as a major challenge confronting the Forest Service and 
other forest management organizations. Several recent reports have stressed 
the importance of this issue and have recommended approaches to the problem. 
Three excellent examples, all released in 1993. are "Fire related 
considerations and strategies in support of ecosystem management" (a staffing 
paper prepared in the Forest Service's Washington Office), "Eastside forest 
ecosystem health assessment" (a report prepared at the request of Speaker 
Foley and Senator Hatfield, and published jointly by the National Forest 
System and Forest Service Research), and "Forest health in the Blue Mountains: 
a management strategy- for fire-adapted ecosystems" (a publication of the 
Pacific Northwest Research Station of the Forest Service). In addition, two 
cf the Appendices (F and G) to the "Recovery plan for the northern spotted 
owl" recognize major differences between moist and dry forest ecosystems and 
recommend management approaches that differ accordingly. For example, 
management activities designed to reduce the risk of catastrophic fire tend 
not to be very cost-effective in moist forests. In contrast, fuel management 
strategies, including development of fuelbreak systems and initiation of 
extensive prescribed burning, may be very important investments in the future 
of dry forests. Thinning of overly-dense stands anywhere in the Pacific 
Northwest can, among other things, speed the development of desirable 
cld-crowth-type characteristics. The need for thinning aid other 
silvicuitural methods may be more critical in many portions of the dry forest 
types, however: without them, the risk of catastrophic loss to wildfire, 
insects, and disease will continue to escalate. 

• r 

The appropriateness of a more active form of management in the dry forests is 
reinforced, we believe, by another recently-released report — "The California 
spotted owl: a technical assessment of its current status" (a publication of 
the Pacific Southwest Research Station of the Forest Service). Three of us 
(McKelvey, Noon, and Verner) were members of the core team of wildlife 
biologists responsible for preparing the report (Verner was team leader) , and 
a'Jthored most of the chapters in the report. The fourth (Weatherspoon) served 
as a consultEint/ advisor to the core team, and authored two chapters dealing 
with fire ecology and fuels management, and (with McKelvey) long-term 
management strategies. The team's principal recommendations for management 
dealt with forests of the Sierra Nevada, which for the most part have 
short-interval fire regimes similar to those of the dry forests within the 
range of the northern spotted owl. The team decided not _t_o recommend 
establishment of a Isrge-scale reserve systen: for the California spotted o>-.l. 
Risk of loss of habitat to wildfire, along with limited opportunities in a 
reserve system to eiineliorate that risk, played a major role in the decision. 



23 



President Clinton Page 3 

The report states (pp. 18-19), "Sierran mixed-conifer forests, where most 
California spotted owls occur, are drier and. given the effects of fire 
exclusion, much more prone to stand-destroying fires than are most forests in 
western Washington and Oregon." This report contains recommendations for fuel 
management and silviculture that may be relevant also to the dry forests 
within the range of the northern spotted owl. 

On May 6-7 one of us (Keatherspoon) participated in a panel in Portland 
convened to help the Ecosystem Team assess ecosystem viability for the various 
optior.s that had been developed up to that point. Each of the options 
included a unique mix of one or more of several tj^pes of conservation areas, 
which permitted a range of management intensity from no management to limited 
management . The options also varied in terms of the degree to which they made 
provisions for subregional differences related to climate and fire regime. 
There were some indications at that time that concerns related to forests of 
northern California and other dry forests of Oregon and Washington were not 
being addressed as fully as those related to the moist forests. Recognition 
of important subregional differences, particularly with regard to fire ecology 
and related management of conservation areas, did not seem to be well 
developed at that time (in large part understandable because of the short time 
available for the assessment). Recent conversations with colleagues who are 
members of the Ecosystem Teajn indicated that they agreed with these 
observations, based on current versions of the options. Our intent certainly 
is not to criticize the Ecosystem Team's report, especially since we have not 
seen the final version of it. Nor do we see our recommendations here as 
contrary to the strategies proposed for the northern spotted owl by the ISC 
(Thomasy Tean: or the Recovery Team of the U.S. Fish and Wildlife Service. 
Both of those teams recommended a separate management plan for each 
conservation area , which could develop fuel -treatment programs specific to the 
conditions in each area. We simply want to urge that appropriate attention be 
given tc this issue, and the possibility of its not being addressed fully in 
the Ecos\'£teiE Team's final report pro\'ided the impetus for us to write this 
letter to you. V,e felt it was important to write now, ratner than wait until 
we had had time to review the final report, in order that these concerns might 
have a better chance of being incorporated into your announced management 
strategi' for Pacific Northwest forests. 

In short, Mr. President, we think it is essential that the management strategy 
developed by your administration take into account the distinctive nature and 
special needs of the short-interval fire-adapted ecosystems east of the 
Cascades and in southwestern Oregon and northern California. As we indicated 
earlier, several excellent reports substantiate this need and provide useful 
recomcendations . We do not argue against conservation areas. We simply 
suggest that, for whatever system of conservation areas may be adopted, 
flexibility be incorporated into it to meet the needs of these dry forest 
ecosystems. A "hands-off" approach in conservation areas might be appropriate 
elsewhere in the Pacific Northwest, at least in the short term. But in these 
dry forests, abandoning all management activities, including fuel management, 
will simply exacerbate existing problems and could be a recipe for disaster. 
This recor-.Tien^ ?. ti OP 1? r.ct s ^l^^' *"r ''c^^t o"jt the "ut" e." "ll ci~*'S* ciu'"' ^ 
the needed work will produce little or no timber volume. The question is one 
cf eccsystea health Zuid sustainability . The measures needed to restore and 



24 



President Clinton Page 't 

maintain these ecosystems, however, will require a lot of rather intensive 
work. Jobs, therefore, would be a substantial and valuable byproduct. 

We hope these comments are helpful. 

Respectfully, 

I si Kevin S. McKelvey 

KEVIN S. MCKELVEY 

Wildlife Biologist 

Pacific Southwest Research Station- 

I si Barry R. Noon 

BARRY R. NOON 

Research Wildlife Biologist and Project Leader 

Pacific Southwest Research Station 

/s/ Jared Verner 

JARED VERNER 

Research Wildlife Biologist and Project Leader 

Pacific Southwest Research Station 

» » 

I si C. Phillip Weatherspoon 

C. PHILLIP WEATHERSPOON . 

Research Forester and Project Leader 

Pacific Southwest Research Station 



25 

Mr. Smith of Oregon. Anybody else wish to comment? 

Mr. McKiLLOP. Mr. Congressman, I am an economist with a cer- 
tain degree of biological training, but my observation from action 
in the field in California is that there seems to be many more owls 
on private lands than on adjacent national forests that have much 
less harvests. Frankly, owls in California seem to do very well in 
stands that were formerly harvested or partially cut. 

Mr. Taylor. Perhaps, I could add, the California Forestry Asso- 
ciation submitted a petition to remove the spotted owl from the 
threatened species list in California. We did this on the basis of ex- 
tensive research on owl habitat requirements, modeling of owl pop- 
ulation dynamics, and we believe owls do very well indeed in sec- 
ond-growth-managed forests. 

Mr. Smith of Oregon. You see, gentlemen, the point is that if in- 
deed you can holistically manage the forest, then, and you agree 
with this fish and wildlife biologist in Portland, Oregon, who has 
been there for 25 years, then you can't at thje same time defend set- 
ting aside 8 million acres to protect the spotted owl, can you? Does 
that follow for you? 

Mr. Geisinger. I agree and I think the key is to practice that 
kind of selective mariagemient and holistic management, as you de- 
scribed it — we would call it ecosystem management— across broad 
landscapes escapes and. not effectively lock up 83 percent of the 
lands and just apply those practices to 17 percent. 

Mr. Smith of Oregon. So do you believe finally that by proper 
management over a broad area that you could harvest timber, pro- 
tect fish, protect owls, protect the marbled murrelet and harvest 
timber without setting aside huge blocks of land for the protection 
of one species and one species only, which may not be in the best 
interests of the forest plan for the long term? 

Mr. BONNICKSEN. If I can add to what my colleagues have said, 
if we set aside reserves, we, in essence, have tried to freeze the for- 
est in time forever and it will actually grow into less and less via- 
ble owl habitat as a result. The reason we have owls now is be- 
cause for the last 12,000 years the forest was subjected to massive 
disturbances, such as windthrows and fires, and it created a diver- 
sity of conditions that supported and sustained the spotted owl. 
Timber hai^vesting produces the same result in the future that fires 
did in the past. So I am not the least bit surprised that spotted 
owls thrive within a managed environment. 

Mr. Smith of Oregon. I thank the chairman. 

Mr. Volkmer. Does the gentleman from North Dakota have any 
questions? 

[No response.] 

Mr. Volkmer. The gentleman from Virginia has left. 

The gentleman from California. 

Mr. DOOLITTLE. Yes, sir; Mr. Chairman. 

Dr. Taylor, you testified that — well, maybe I heard it differently, 
but either this reserve approach which is fundamental to managing 
the northern spotted owl, which is key to all the FEMAT reports 
here — ^you indicate in your testimony that two members of this 
interagency scientific team that crafted that approach have pub- 
licly repudiated that. But I thought I heard you say that there 
were four of them? 



26 

Mr. Taylor. The letter is signed by four Forest Service sci- 
entists: Kevin McKelvey, Barry Noon, Jared Verner and Phillip 
Weatherspoon. Barry Noon and Jared Verner were members of 
that team. 

Mr. DOOLITTLE. From which this whole idea of setting aside for- 
est reserves came in all the FEMAT reports. Wouldn't that render 
invalid the whole approach that was taken? 

Mr. Taylor. Yes, and the reason is these areas are too risky 
from a fire standpoint to be managed as reserves without being 
touched by humans. 

Mr. DOOLITTLE. So it seems incredible, Mr. Chairman, that here 
this train is moving along and the fundamental premise of it turns 
out to be false and yet it is still called science. And I think you gen- 
tlemen made some very good points. I am sorry I didn't get here 
for the very beginning of your testimony, but as I read through the 
testimony I have in front of me, the discussion of the abuse of 
science I think is very critical, because this seems to me to be not 
only the future but increasingly it is the present. 

We are going to have a scientific panel that reaches conclusions 
that would — in fact, maybe you gentlemen could explain how this 
happened. It was that Jack Ward Thomas committee that rec- 
ommended it, wasn't it, that northern California go through the re- 
serve on the northern spotted owl and now he is coming around 
and saying that never should have happened. Can you explain the 
reasoning history of that? 

Mr. McKlLLOP. Congressman, I can give you some insight. Jack 
Ward Thomas was an honorary lecturer at the University of Cali- 
fornia in the Albright lecture series. In response to a question from 
me saying look. Jack, I have been out in the redwood region and 
noted the abundance of owls in managed forests; how do you ac- 
count for that? He said, "Well, we recommended to the Fish and 
Wildlife Service it not be listed in northern California." So we must 
ask the Fish and Wildlife Service why did they go ahead and list 
it in northern California and cause so much economic damage that 
need not have occurred. 

Mr. DOOLITTLE. OK. 

Mr. Taylor. Congressman, if I could add to that? I think it 
should be noted that the administration has basically empowered 
only one school of thought within the scientific community and that 
school of thought, reserve-oriented school of thought has effectively 
suppressed the opinions of other scientists. I think if you go out 
and look at the scientific community and sample it in an unbiased 
fashion, you will find a variety of viewpoints not just the one that 
is presented in the FEMAT report. 

Mr. DOOLITTLE. I appreciate that. I think this needs to be ex- 
plored further and we are going to have to take this information 
and develop it. I think you have really performed a service for us 
by giving us that. 

Let me ask you this: We hear a lot about sustainable yield. That 
is kind of the new buzzword. Were the national forests on a sus- 
tained yield basis prior to the listing of the northern spotted owl? 

Mr. McKiLLOP. May I respond to that, Mr. Congressman? For- 
esters have had the concept of sustained yield for over 100 years. 
The national forest plans that were in existence prior to Judge 



27 

Dwyer's decision and prior to the listing of the owl, provided for 
sustained yield. The harvest levels that they prescribed were sus- 
tainable indefinitely as required by the National Forest Manage- 
ment Act. So it is totally untrue to say that we need to have these 
reserves because the Forest Service was not on a sustained yield 
basis. 

It genuinely was on a sustained yield basis and if it is not able 
to do that anymore, it is because of the withdrawals under the 
FEMAT and related court decisions. 

Mr. DOOLITTLE. Thank you. 

Mr. VOLKMER. Does the gentleman from Minnesota have any 
questions? 

[No response.] 

Mr. VoLKMER. Does the gentleman from Florida have any addi- 
tional questions? 

If not, I want to thank the members of this panel for their testi- 
mony here today. 

We have a vote, we will recess the subcommittee at this time 
with this panel. And when we return, we will start with the next 
panel. 

Thank you very much for your testimony. 

[Recess taken.] 

Mr. Rose [resuming chair]. The subcommittee will resume, its sit- 
ting. And our second panel will please take their seats. 

Dr. Mark Shaffer; Ms. Judy Noritake; Mr. Tim Cullinan; Ms. 
Julie Norman; and Mr. Tim Hemjach. 

We will put your full titles in vvhen you begin your testimony. 

We than^ the second panel for being here. Members will' be com- 
ing back from the vote. 

Dr. Shaffer is vice president of the Wilderness Society and we ap- 
preciate very much your being here; and would ask that you begin 
with your testimony. 

As usual, your entire statement will be a part of the record. Give 
us about a 5-minute overview and then we will get into questions. 

STATEMENT OF MARK L. SHAFFER, VICE PRESffiENT, RE- 
SOURCE PLANNING AND ECONOMICS, WILDERNESS SOCI- 
ETY, ALSO ON BEHALF OF THE NATIONAL WILDLIFE FED- 
ERATION AND THE NATIONAL RESOURCES DEFENSE COUN- 
CIL 

Mr. Suffer. Thank you, Mr. Chairman. 

My name is Mark Shaffer. I am vice president for resource plan- 
ning and economics with the Wilderness Society. 

I thank you and the other mejjibers of the subcommittee for the 
opportunity to be here today and I would lil^e to say that the state- 
ments I am making represent the views of the Wilderness Society, 
the National Wildlife Federation, and the Natural Resources De- 
fense Council. 

First, I would like to say that we have been extremely gratified 
by the Clinton administration's willingness to tackle this issue and 
not sidestep it. From the forest conference they held in the spring 
to the incredible amount of work done under very short time-lines 
by the FEMAT, this administration has signaled it is serious about 
solving this problem. 



28 

The other thing that I would like to underscore is that some of 
the exchange in the preceding panel troubles me a little bit, par- 
ticularly when people seem to be focusing on the late successional 
reserves that have been proposed as owl reserves. I think it has 
been clear to the courts and clear to scientists for quite some time 
that this issue is not an issue of just owls. It is the issue of an en- 
tire ecosystem and over 1,300 species that depend on that eco- 
system. So I think we have seen in the FEMAT report finally a rec- 
ognition by the administrative end of Government that this is a 
broad-scaled ecosystem problem that involves many species, not 
just a single bird. 

It troubles me somewhat to have to say that despite all these 
good efforts and the very good view that we have about the admin- 
istration's willingness to tackle this problem, we don't think their 
proposed alternative, option 9, is an adequate solution to the an- 
cient forest issue. We think that there are a number of reasons 
why it will not provide a scientifically sound, ecologically credible, 
or legally responsible solution as the President promised. 

We have detailed our criticisms in an official critique of the plan 
that was submitted during the public comment period, and I have 
attached a copy of that detailed statement to my testimony today 
for the record. 

What I would like to do, since time is limited, is basically sum- 
marize for the subcommittee the three or four broad areas in which 
we think option 9 currently fails and to underscore that we think 
this plan can work if these key issues are addressed in the right 
way. 

The first great weakness of option 9 is that it is not going to save 
enough of what we are running out of, which is old trees. That is 
why we have a problem. We have cut too many old trees in that 
region and option 9 basically splits the baby of those trees left that 
aren't already protected, and that is simply not scientifically, eco- 
logically, or legally acceptable in our mind. The consequences of 
that go far beyond the potential loss of one bird, the spotted owl. 

By the Government scientists' own assessment, some 840 species, 
78 percent of the 1,200 to 1,300 species that depend on old trees, 
old forests, are likely not to be viable at the end of another century 
if option 9 is implemented. We hardly think that this meets the let- 
ter of the law or the intent of NFMA or the Endangered Species 
Act. 

Second, in addition to cutting too many old trees, the plan would 
also provide inadequate protection to aquatic resources, particu- 
larly salmon stocks, many of which in this region are already show- 
ing severe signs of decline, some of which are either listed or have 
been petitioned for listing. And what concerns us most is that in 
this process where a number of resource managers and scientists 
made recommendations on the amount of watershed protection that 
had to be in this plan to prevent these kinds of listings in the fu- 
ture, somehow in the course of the development of this plan, their 
recommendations were overlooked. 

I believe there is some terminology here which it is going to take 
a long time to explain, but let's put it this way: The scientists rec- 
ommended what was called "full-SAT" protection for watersheds 
across the landscape of public ownership in the Pacific Northwest. 



29 

Somewhere along the Hne the managers and the policymakers de- 
cided that outside of key watershed areas, half of that would do. 

We have seen this situation before. This kind of situation has 
been litigated before when the managers ignore the advice of their 
own scientists. So from the watershed protection standpoint alone, 
we think this plan fails. 

Finally, option 9 does not provide the sorts of long-term manage- 
ment protection as prescriptions for the so-called matrix areas that 
are going to solve this problem over the long term. And the solution 
of this problem over the long term is to return these public lands 
to a more natural system that is dominated by old trees. That is 
not going to happen under option 9 with the matrix prescriptions 
as they currently exist. 

What I would like to underscore for the subcommittee is I have 
a very different view from the first panel. I share their view, but 
I also differ. I share the view that this plan is currently not ade- 
quate but I hold the view that there are some ways that we can 
change it, and we are very close to a solution. I would hate to see 
us abandon this at this point and go back to ground zero and start 
over. 

Mr. Chairman, I brought some maps that I wanted to use to il- 
lustrate these points, but I notice I am already going through the 
yellow light. 

[The prepared statement of Mr. Shaffer appears at the conclusion 
of the hearing.] 

Mr. Rose. Let me get the panel through and then we will come 
back because I want to ask you some questions. 

Our next panelist is Ms. Judy R. Guse-Noritake. 

STATEMENT OF JUDY R. GUSE-NORITAKE, DIRECTOR, 
NATIONAL RIVER POLICY, PACIFIC RIVERS COUNCIL 

Ms. GUSE-NORITAKE. Thank you, Mr. Chairman. 

I am Judy Noritake. I am the national river policy director for 
the Pacific Rivers Council. 

Over the course of last few years, a series of reputable studies 
have examined the plight of species that depend on the old-growth 
watersheds of the Pacific Northwest. All these studies have come 
to the same conclusion, namely, that the protection of key water- 
shed refuges, protection of riparian areas, and a regional program 
of watershed restoration are essential to the survival of species 
that depend on healthy rivers and watersheds. The species in ques- 
tion include hundreds of stocks of Pacific salmon, trout and 
steelhead, and a long list of other animals and plants. 

The scientific studies are unified as well in their conclusion that 
current public land management of rivers and watersheds is inad- 
equate. Without substantial change in land management, water- 
shed ecosystems and habitat for river-related species cannot be 
maintained. Without substantial change in land management, the 
Pacific Northwest will face a continuing and rising tide of 
extinctions. 

Salmon are not the only aquatic species at risk, many of the 
nearly 200 lesser-known species that depend on old-growth forest 
and watershed ecosystems are in as much trouble as the salmon. 
The plight of these other species cannot be blamed on agriculture, 



78-799 0-94-2 



30 

commercial fishing, variable ocean conditions, or on seals and sea 
lions. The loss of most river and riparian species, including salmon, 
is directly and unequivocally associated with the degradation of 
their habitats, and on Federal land that degradation is overwhelm- 
ingly caused by logging, grazing and roadbuilding. Every reputable 
study agrees on this point. 

Paid apologists for the timber industry have gone to great 
lengths to point out that, historically speaking, salmon habitat was 
lost to agriculture, streamside development, cannelization, diking, 
and the like. This is certainly correct, historically speaking. The 
post-European development of Northwest cities and agriculture de- 
stroyed much salmon habitat, so much so that today most remain- 
ing high quality habitat is high up in the forested watersheds on 
Federal lands. 

Most private land salmon habitat was compromised long ago. But 
this is not the 1890's, and we must remember that it is to the fu- 
ture that we must look not the past. Today the last best salmon 
habitat is on public land in the national forests, where it is not 
threatened by urban development, but it is threatened by logging. 
The Oregon chapter of the American Fisheries Society Critical Wa- 
tersheds Database, as well as the "Gang of Four" report, the SAT 
report, the Eastside Forests Scientific Society report, the PACfish 
and the FEMAT report that we are discussing here today are in 
deep and broad agreement: To protect salmon and the other species 
that depend on river and watershed ecosystems, we must protect 
key watersheds; eliminate logging, roadbuilding and grazing in ri- 
parian areas; and begin a regionwide program of watershed res- 
toration. 

In a word, the aquatic conservation principles in the President's 
plan are based on sound science. The plan details a four part strat- 
egy of key watersheds, riparian protection, watershed analysis, and 
watershed restoration. While we believe each of these four parts 
could and should be strengthened as discussed below, we fully sup- 
port the approach. Our analysis is that if the aquatic strategy is 
strengthened, and if it is fully and faithfully implemented, it will 
have a high probability of maintaining the habitat for river and 
watershed related species on the Northwest national forests. 

However, the plan must be strengthened to provide a high prob- 
ability of preserving species and ecosystems. We support strength- 
ening that plan exactly as the FEMAT team themselves rec- 
ommended in this report: First, key watersheds must be completely 
protected from logging, including salvage and thinning, and road- 
building until they are no longer needed as refuges; and second, ri- 
parian protection must be uniformly improved across the Federal 
landscape. 

In addition, we also recommend that as in the key watersheds, 
no new roads be built in roadless areas outside the key watersheds. 
Implementation of the aquatic strategy will present two serious 
challenges: First, the embryonic techniques of watershed analysis 
must be synthesized into a workable tool. We believe that the ad- 
ministration will need to bring in the best and the brightest to aid 
in the detailed development of this new approach. 

Current drafts of watershed analysis procedures do not inspire 
confidence. We believe therefore that these developing techniques 



31 

should be tested first outside of key watersheds, in the areas where 
the watershed's integrity has already been compromised. 

Second, skilled personnel must be trained and empowered in the 
watershed approach. We would like to underscore the critical need 
for part of the moneys appropriated for fiscal year 1994 watershed 
restoration to be applied to this training immediately. 

Those who are unwilling or unable to adapt to a truly new per- 
spective will need to step aside. Since the passage of the National 
Forest Management Act in the 1970's, the agencies have provided 
continuous assurances that timber sales have been consistent with 
maintaining fish habitat. Even though those assurances have 
proved to be dramatically false, there remain a significant number 
of officers within the agencies who defend them. 

It is difficult to see how such defenders can faithfully implement 
an approach that contradicts their earlier work. Substantial 
changes in staffing and lines of authority may be required if the 
President's plan is to hit the ground intact. 

While none of the changes needed in the President's plan are 
trivial, neither are they insurmountable, nor do they require new 
study. The steps required to strengthen the plan are already 
spelled out in the plan. The steps required for implementation de- 
pend on leadership from the administration. And I would add that 
the Oregon Chapter of the American Fisheries Society in their for- 
mal written comments on FEMAT suggest exactly the same meas- 
ures that we suggest. 

Mr. Chairman, the President's plan, if strengthened in ways that 
are well understood and if faithfully implemented, would bring the 
management of aquatic ecosystems on public lands within the 
range of the spotted owl into line with the reputable science con- 
cerning watershed ecosystems. We commend the President's team 
for that achievement, and we stand ready to assist this committee 
in the further examination of these issues. 

I have a copy of our detailed comments on the President's plan 
and I would like to ask that you enter them into the record. 

[The prepared statement of Ms. Guse-Noritake appears at the 
conclusion of the hearing.] 

Mr. Rose. Certainly, that will be done. 

How many of you have early afternoon or later afternoon flights? 

Mr. ShafTer. 

I believe we probably need to let you go ahead and talk about 
the maps, but can you give us about 10 more minutes. 

Mr. Shaffer. Sure. 

Mr. Rose. Let me ask you this: If we had the wisdom of Solomon 
at our disposal here, suppose we could put a panel together in a 
room, make it pieces of panel 1 and panel 2, maybe not totally all 
of you. I am going to ask the people who are here from panel 1 and 
those who will be here from panel 2, to drop me a note to suggest 
how we might and where you might have a small informal discus- 
sion about trying to resolve these vast conflicts. That may not be 
possible. I think it certainly should be. And see if we can have the 
Northwest Management Plan revisited in the Forestry Subcommit- 
tee. We can find some more common grounds. 

I am going to ask Mr. Shaff'er to talk about his maps. 



32 

Ms. Noritake, I appreciate your comments. I read about you in 
the magazine called "National Fisherman" that I subscribe to and 
they have articles about these situations from time to time. 

Mr. Shaffer. , 

Mr. Shaffer. Thank you, Mr. Chairman. 

I am going to speak without the mike, but I hope you can hear 
me. I would also like to invite you and other members of the com- 
mittee, if you want to step down, you would get a better view of 
the maps. 

What we have brought today, on the basis that a picture is worth 
1,000 words, are some maps that we have prepared based on two 
sets of data. One is the GIS data from the FEMAT team itself, 
which are those different land management designations that are 
being proposed under option 9. 

And that is the different colors that you see. I will tell you what 
they are real quickly. 

Green are congressionally withdrawn forest areas, wilderness 
areas, currently designated; blue are administratively withdrawn 
areas. The forest plan says they are not going to plan timber man- 
agement activities because they are research areas or camping 
areas or whatever. 

The lavender colors are proposed old-growth reserves that would 
be established under option 9. The yellow is matrix areas where 
there would be timber management, and also the orange are adapt- 
ive management zones in which there would be timber manage- 
ment, but ostensibly under some different set of rules than the ma- 
trix, although that is not very clear, and that is one area where we 
have some problems. That is the data that we got from the Govern- 
ment. 

The dark gray stippling that you see overlaid is the ancient for- 
est inventory that the Wilderness Society conducted using remote 
sensing data. It is about 4 years old, so it is a little bit out of date, 
but not too much. This is our assessment of where the ancient for- 
est is, and the definition that we used to develop this data layer 
was the same definition of old growth that the Forest Service used 
to use. It is basically areas that are more than 50 percent trees 200 
years old or older. 

Now, the resolution of these maps is that you can see that these 
are kind of tiny little squares, they are called pixels. The resolution 
is that each of those pixels is 150 meters on a side; and the rule 
is that that 150 by 150 had to be more than 50 percent old trees 
before it would turn gray. 

What I want to draw your attention to is that in existing wilder- 
ness areas, you have quite a dispersion of concentration of the real- 
ly old forest. Some wilderness areas — many wilderness areas are 
high latitude rocks and ice, so they don't contain a lot of endan- 
gered forest. Some wilderness areas do. 

The other thing I want to draw your attention to is just how 
fragmented the forest is across this landscape. We can say one 
thing for the Forest Service for sure, they did a real good job of dis- 
bursing the cut, because most of this map probably would have 
been — 100, 200 years ago, most of this map would have been gray. 

The other thing we want to point out is that if the problem in 
this landscape is that we have cut 90 percent of the old trees when 



33 

the landscape was probably 70 percent old trees, and that means 
that we are running a lot of species like the spotted owl out of 
room, then this gray is the limiting resource, and we ought to focus 
our protection areas on capturing as much of that gray in reserve 
status as possible. 

But you can see by looking at this map that in some cases there 
is almost as much of that ancient forest out in the matrix area that 
is scheduled for cutting as there are in the proposed reserves. We 
did some statistical analysis on this, which we haven't fully com- 
pleted. 

The map I am showing you is the Gifford Pinchott National For- 
est in southwest Washington. In the Six Rivers National Forest in 
California, the percentage of the yellow that is ancient forest is ac- 
tually higher than the percentage of the purple that is ancient for- 
est. 

In other words, the late-succession reserves in some areas con- 
tain a lower concentration of ancient forests than the matrix areas 
that would be subject to cutting. 

The other major concern is that when we overlay major streams 
onto this landscape and look at the potential of the different zones 
to affect riparian management, and therefore, the protection of 
aquatic resources like salmon, we have some additional concerns. 

FEMAT designated what they call key watersheds and these are 
designated here in dark green. For the reasons they enumerate in 
their report, their fisheries scientist said these areas are critical to 
the future health of salmon stocks and other aquatic resources, 
they deserve the highest level of protection. 

I would like to draw your attention to this key watershed in the 
center where you can see that a fair amount of that area is in a 
late-succession natural old-growth reserve, but a very substantial 
proportion of the actual ancient forests are out in the matrix where 
they will be subject to cutting. You can't cut these forests without 
increasing soil erosion, doing some damage to streams. So we have 
a concern in that regard. 

The other concern we have is that in some very important head- 
water areas for major streams and rivers in the area, you see sig- 
nificant concentrations of old growth along these riparian corridors, 
and it is out in the matrix where it is going to get cut. Now, one 
of the panelists on the previous panel pointed out that these high 
altitude, high gradient streams are not the most productive part of 
the system, that is true. 

What wasn't pointed out is that they are a high hazard area. If 
you muck around in steep slopes that are very erodible, you start 
putting a sediment load in the stream that is going to start to af- 
fect the streams not just on the national forest, but far down- 
stream. So those areas are still critical to salmon resources. Even 
if they aren't breeding there, what happens up there can affect the 
water quality where they do breed. 

So our concern is let's make sure that we solve this problem. And 
we are close to solving this problem. But we have to do three 
things to get there. 

One, we have to redraw these lines. I would challenge you, Mr. 
Chairman, and the other members down here, to look at this and 
pretend the colors weren't there, and knowing the background on 



34 

this problem, of what is at stake, where would you draw the lines? 
I have a feeling we would have a different set of lines than we have 
right now. 

So we have to fix that. We have to redraw these lines to capture 
a more significant portion of the ancient forest. 

The other thing we have to do is that we have to take our knowl- 
edge on the salmon, watershed relationships and apply the right ri- 
parian protections. There are parts of key watersheds that aren't 
in late successional reserves that we think ought to be in them. 
More importantly, or equally importantly, we think even outside of 
key watersheds, we need to have full SAT protection along these 
streams to be able to prevent listing of salmon stocks and to pre- 
vent those that may be in bad shape. 

Finally, I kind of agree with panel 1 in the sense that these re- 
serves are not the long-term solution to this problem. They are a 
bridge for 100 years or 150 years until we can really solve this 
problem, and what that is going to take is to return this landscape 
to an average age of about 200, 250-year-old trees, and the current 
prescription for management in the matrix won't get us there. 

So we have to change those prescriptions so that we begin to re- 
grow old ancient forests out here, because we are going to lose 
some of the reserves. So those are our recommendations. I brought 
along other sets of maps and we would be happy at any time to 
brief any other members or your staff and share this information. 

Mr. Rose. Thank you. Dr. Shaffer. I am doing this sort of infor- 
mally right now. I do hope that someone will suggest to me or my 
staff a logical grouping of the parties that should be represented 
in an informal discussion to relook at some of these matters, and 
that you all begin, what subgroups are out there that we should 
get together, and who are logical representatives or combinations 
of logical representatives for each of those groups, so that we might 
sit down and maybe say, all right, this obviously didn't come off of 
Mt. Sinai in stone; let's see if we can run up the hill just one more 
time and look at some other things. I yield to my colleague from 
California, Congressman Farr. 

Mr. Farr. Thank you very much, Mr. Chairman. 

I am curious as to whether you used a methodology such as the 
timber harvesting plans that are required in California and ap- 
proach the resource management issues, the riparian protections, 
protecting old-growth redwoods, whether you could come to the 
same conclusion that you were trying to show us on the map where 
you would protect both the streambeds and the old-growth red- 
woods. 

Is there a different method of resource management that could 
be used that would solve the interests of the parties? I am brand- 
new to this issue, being the newest Member in the House, and I 
am curious, because one thing in common is all of the real estate 
is Federal real estate. 

So do you approach it from a standpoint that you are going to 
allow for a resource recovery for timber harvesting, and at the 
same time meet all of the goals that I think the panelists are talk- 
ing about and allow a win/win rather than a 



35 

Mr. Shaffer. You really want an answer? That is an incredibly 
complicated question. It is a good question. Let me give you my 
personal opinion, or my professional view. 

We are starting to understand just how complicated ecosystems 
are and how many values they represent to society. One index of 
that is the number of species that they contain. And landownership 
patterns in this country don't at all correspond to ecosystem pat- 
terns. 

That is a whole set of problems we are going to have to come to 
terms with. Let's set that aside for the moment and ask if there 
is a style of management that could maintain the system. 

The Wilderness Society doesn't have any problem with resource 
utilization at the right level and in the right way, as long as it 
maintains the full spectrum of forest values. And I think if we had 
started out 100 years ago managing these forests in a different way 
with some different techniques, we might not be sitting here today 
with a problem. 

The point is that we didn't, and the point is that 90 percent of 
the old forest is gone. We are down to 10 percent. I heard a state- 
ment from the first panel that just shocked me, and that was that 
the levels of 4 billion to 5 billion board feet as being sustainable; 
that is preposterous. 

They might be sustainable from a narrow focus on fiber produc- 
tion, but forests are so much more than fiber. They are not sustain- 
able ecologically. 

What we have done, particularly during the decades of the 
1980's, is we have mortgaged the resource development on these 
forests. We are in debt, we have gone too far; and the way we are 
going to maintain the full spectrum of forest values now is to dras- 
tically curtail resource development. 

Not because we have anything against it, but we managed the 
wrong way, and now other resources that are just as valuable are 
at risk of being lost. And what concerns me is that we bring up the 
fact that well, there may be other methods that we could use that 
would do this. 

Well, there may be, if they had been applied to the original land- 
scape that was 70 percent ancient forest. We can't afford to do that 
now without risking losing a whole lot of the other forest values. 
And I am all in favor of experimentation and looking for other 
ways, but let's be clear that we have to have a system of lands that 
are left alone in ancient forest for a while until we figure out these 
other questions, or we are going to lose significant resources. 

Mr. Farr. I am not sure you answered the question. I think 
there is two parts to it. One is what you don't cut and what you 
cut; and then the second part of it is the rate of cut. 

One of the methods we have worked out in California on Califor- 
nia State forest lands is pursuant to California law, and we built 
in — and I am not as familiar with the Federal law — ^built in a lot 
of riparian vegetation protection and protection not solid enough, 
but a discussion about how to protect low-growth redwoods. 

If you used that type of an approach, would you come to the 
same type of conclusion that you are doing, or is that law faulty? 

Mr. Shaffer. I am not famihar with the California law. 

Mr. Farr. Is anyone on the panel? 



36 

Mr. Shaffer. I would hate to speculate, but I would be happy 
to defer. 

Mr. CULLINAN. Let me introduce myself. I am Tim Cullinan, biol- 
ogist for the National Audubon Society, Washington State office in 
Olympia, Washington. I live on the Olympic Peninsula of Washing- 
ton State. 

First, the laws you are referring to in California are those, as I 
understand it, that apply specifically to private timberlands. The 
objectives for private timberland are much different than they are 
for national forests. 

So you are not necessarily comparing apples and apples here, in 
that something that is appropriate for meeting the objectives of a 
private timber producer are not necessarily appropriate for meeting 
all of the different resource objectives for national forests. 

The second half of your question about — I think what you are 
talking about is some creative silviculture that has been applied in 
redwoods that results in maintaining some of those other 
nontimber resources in the forest. That has been tried in the red- 
wood region. I don't think the level of success that you have had 
there necessarily could be extrapolated to areas like where I live, 
much colder climate, much harsher conditions, an entirely different 
forest ecology. 

Those things have not been shown to work; they haven't even 
been tested in that part of the country yet. 

Mr. Farr. What is the solution to this problem as the Chair 
talked about it? We get all in a room, we are going to — is there a 
management solution that can solve everyone's interest? 

Mr. Hermach. I am Tim Hermach with the Native Forest Coun- 
cil in Eugene, Oregon and absolutely we believe that solutions are 
available. Solutions first have to be sought, not necessarily the un- 
Solomon like cutting the baby in half political decisions that many 
of us have been forced into in the past. When we seek win/win so- 
lutions, how to make the most people the most happy, we first 
must answer what is right and what is wrong. I would submit that 
if you took both panel 1 and panel 2, stuck them in a room, every- 
body would die before you would ever see a solution. 

Mr. Rose. Well, unless you had adults present. 

Mr. Hermach. I don't know that they exist sometimes. 

There is an example, however, I think it was under President 
Bush, he put together a National Wetlands Preservation Forum; 
200 people chaired by New Jersey Grovemor Tom Kean at the time. 
Not one idealogue was in that 200 people. They were respected 
opinion leaders, people from much of the spectrum of American life, 
from politics, local, State, national; and from business, local. State, 
national, and from academics, but not one idealogue. 

And they were asked the questions: What is a wetland? What is 
its value in our lives? What are the conditions and what are the 
solutions and what must we do about it and how do we get there? 
That opportunity I think exists, and I think the solutions would 
quickly become apparent. 

But if I recommend them, somebody from panel 1 is going to be 
angry, et cetera, et cetera. 

Mr. Rose. I understand. If the gentleman will yield for just a 
minute, I still think we have a lot of work to do here, and maybe 



37 

some of you can come up with some wisdom that you can share 
with me about who the players ought to be. I come from a part of 
the country where there is, in my district, I don't believe there is 
much, if any, Forest Service property. But a lot of privately man- 
aged land by timber companies, paper companies. And so I come 
at this from a little different perspective, just like Mr. Farr comes 
to it. 

So let's go back, if we could. I didn't get the chance to explain 
this to Mr. Farr. Mr. Shaffer and Ms. Noritake are the only two 
who had the chance to give their testimony. Mr. Shaffer had to 
catch a plane, so we let him testify and then show his maps. 

Ms. Norman, I apologize for keeping you waiting so long. 

STATEMENT OF JULIE KAY NORMAN, PRESIDENT, BOARD OF 

DIRECTORS, HEADWATERS 

Ms. Norman. My name is Julie Norman, I am the president of 
the board of directors of a grassroots group called Headwaters. We 
are based in southwest Oregon, and I am very thankful for this op- 
portunity to testify today. 

The forest plan that is trying to evolve with the Clinton adminis- 
tration working with the public, is a crucial decision that has been 
delayed for many years, and I hope that we can succeed in finding 
a resolution. 

I am going to submit to your staff a full set of our comments that 
we submitted to the Forest Service and BLM, and it has discus- 
sions of various parts of option 9, which we feel need improvement, 
such as the problems with the continued use of even-aged manage- 
ment, that is, the continued use of something very close to 
clearcutting in the commercial lands that fall outside the reserves. 

Another critique we have is the fact that the Forest Service and 
the BLM seem willing to have very low viability ratings for a great 
number of species, and that those low viability ratings may very 
well indicate that species would go extinct or more species would 
come under the Endangered Species Act, which is what we are all 
trying to avoid. 

Today, what I want to speak about is one particular issue that 
I addressed in my testimony and that is the inadequate protection 
of the roadless areas. As you can see by this aerial photo over here, 
what we have is a very fragmented landscape due to the Forest 
Service policies of spreading the clearcuts around in an even fash- 
ion. 

During the 1970's and the 1980's, there was an immense amount 
of roadbuilding that went on, and their goal was to spread the 
clearcuts evenly across the landscape with the idea that that would 
minimize the impact to the fisheries. Well, as we found, the frag- 
mentation of the forest with this method of cutting resulted in 
great problems with other species, and the salmon data now is very 
compelling about the declines. 

So the roadless areas are the places where the forest is not frag- 
mented. And in the Clinton's option 9, only approximately 43 per- 
cent of the roadless areas fall inside the reserves. 

So what we would recommend is that the efficiency of the reserve 
system would be greatly enhanced if the rest of those roadless 
areas were included. And the good news is that these areas are 



38 

really the least productive in terms of timber. The reason they are 
still roadless is because they weren't the best ground for tree farm- 
ing. 

A lot of steep slopes are in there. They have sensitive soils; a lot 
of them are at the higher elevations. So according to the scientific 
process and the data in the DSEIS, including all of the remaining 
roadless areas in the reserve, would only reduce the cut by 6 per- 
cent. Even though that would represent reserving 18 percent more 
acres, the amount of timber that is on that land is only 6 percent. 

In fact, we discovered through looking at the data that only 1 in 
4 acres in the roadless areas are suitable for commercial logging. 
They have already been pulled off of the commercial timber base 
for other reasons, such as steep ground and unstable soils. 

So what we call this is a biodiversity bargain. We feel that the 
roadless areas have very special values because they are not frag- 
mented and that the fisheries biologists have clearly identified 
these areas as the best remaining salmon habitat, and also the fact 
that the cut would not be decreased as much if these areas were 
protected. 

Another factor is that these roadless areas have been determined 
by the court as very significant, and so each roadless area entry 
would require a full environmental impact statement. As you know, 
those are very expensive. In the FEMAT report, it requires that 
every roadless area entry would have to have a special watershed 
analysis. So the costs of entering these roadless areas are very 
high. 

Then you add to that the fact that the roadbuilding in those 
areas is more expensive than normal, and the cutting systems and 
the expensive logging equipment that is needed to access steep can- 
yons, such as I find in the Siskiyou roadless areas, that would be 
expensive, too. 

I would like to quote Professor Norm Johnson who was on the 
President's team. He says, "It is going to be a major investment in 
resources to enter those roadless areas. They are going to have an 
environmental impact statement and they are going to be more ex- 
pensive to log. We really do have to ask the question of each one: 
Is it worth it?" 

As an activist who has been involved in this for 10 years and 
participating in forest planning processes very diligently all these 
years, I can say that the roadless areas are regarded as a very spe- 
cial resource to the people who have been fighting for these forests, 
and their inclusion in the reserve system would be regarded as 
very significant. 

Thank you. 

[The prepared statement of Ms. Norman appears at the conclu- 
sion of the hearing.] 

Mr. Rose. Thank you. 

Next, Mr. Tim Cullinan, National Audubon Society. 

STATEMENT OF TIMOTHY P. CULLINAN, WILDLIFE BIOLOGIST, 
NATIONAL AUDUBON SOCIETY 

Mr. Cullinan. Thank you, Mr. Chairman. 

Dr. Shaffer gave you an overview. I want to focus on two specific 
components of the President's proposal, and they address the two 



39 

questions that you and Mr. Farr have asked. One is — this concept 
of adaptive management, which is, in a sense, seeking new ways 
of managing forests so we don't have the detrimental impacts on 
the environment. The second is the topic of consensus-based col- 
laborative planning for resources — like you said, getting people in 
a room and having them work something out. I want to talk about 
those two topics as they relate to the adaptive management areas. 

Mr. Rose. Let me interrupt you and ask you a question. If we 
do get these people in a room and have a discussion, where do we 
find the science base that we can agree on? I think, you know, isn't 
that one of the tremendous problems here, is that 

Mr. CULLINAN. That has been a problem ever since I have been 
alive. 

Mr. Rose. Yes, OK. 

Mr. CULLINAN. And you know 

Mr. Rose. I mean agreeing on- 



Mr. CULLINAN. Scientists are human. Just like everybody else, 
they can disagree with each other. And at some point, though, you 
have to say OK, we have a picture of what the best available 
knowledge is, and we have to move on based on what we have. And 
I think that is what the President tried to do with this particular 
plan. I can explain this a little bit later as I move on. 

Mr. Rose. All right. 

Mr. CULLINAN. Presumably these adaptive management areas 
would be used to test some of these hypotheses that Professor 
Bonnicksen was talking about, that you might be able to manage 
forests in such a way that they would have less impact on the envi- 
ronment than conventional methods of forestry. However, there are 
some technical problems with the way this is proposed in the cur- 
rent plan. 

One, the high timber production goals and the lack of advanced 
planning jeopardize the ability to practice adaptive management. 
Some of these adaptive management zones are located in areas 
where it is just too risky to do that kind of work. 

I think the plan makes some overoptimistic assumptions about 
the potential for successful conflict resolution at the local level, and 
it promises too much decisionmaking authority to local interests. 

Just to elaborate briefly, this option 9 leaves open the possibility 
that timber harvest levels on adaptive management areas will be 
as high as they are on the matrix lands, that is, near full capacity 
for timber output. In the past 4 years I have worked on two 
projects as a scientist, two projects designed to practice adaptive 
management on a scale similar to what is being proposed in the 
President's plan. 

What I have learned is that it is extremely diflicult, if not impos- 
sible, to accommodate research projects on lands that are managed 
near maximum timber capacity. When you do that, you simply 
don't allow the forest managers enough latitude to explore new log- 
ging techniques and scheduling strategies. So the first thing we 
have to do is back down on the expectations of timber output on 
those areas. 

Second, even if you reduce those timber output levels, this plan 
may fail to deliver scientifically sound results. The reason is be- 
cause you need well-coordinated experimental designs for research 



40 

before you implement your plan. And unfortunately, this plan 
pushes the logging ahead on an accelerated schedule before an in- 
tegrated experimental design can be developed to guide the on-the- 
ground research. 

The third thing is — well, I mentioned that some of these are in 
areas where resources are at risk, and I can explain that a little 
bit later if we have time. 

I want to address this proposal to share forest management plan- 
ning authority with local interests. As I interpret the way this is 
written, the Federal agencies would seek negotiated resolutions to 
management conflicts at the local level, and then depend heavily 
on the results of those negotiated agreements to guide management 
decisions on the adaptive management areas. 

Well, there are two aspects of this proposal that I would like to 
see the administration reconsider. One, I think the administration 
makes some overly optimistic assumptions that negotiated agree- 
ments at the local level are possible, or that you can even get peo- 
ple to sit in a room and talk to each other like you suggested. 

Now, I have quite a bit of experience with conflict resolution in 
Washington State, and one thing I know is that good faith negotia- 
tions cannot proceed if the timing or the conditions aren't right. In 
northern California and southern Oregon there are some places 
where those conditions are right. I would suggest that in places 
like where I live on the Olympic Peninsula, they are not. 

In some of these areas, tensions are running extremely high and 
I think the administration needs to reconsider its decision to initi- 
ate these efforts before it proceeds. 

Finally, the last thing is this concept of local influence over deci- 
sionmaking. This plan makes repeated references to involvement of 
local communities and local expertise and local control. Frankly, 
most conservationists in the Northwest regard local control of man- 
agement decisions as a problem, not a solution. 

Historically, the most serious abuses of the forest ecosystem have 
occurred in those ranger districts near isolated, timber-dominated 
communities, far away from the watchful eyes of other resource 
users. In those areas, management decisions in the past have been 
unduly influenced by timber interests. 

So I would like to see that the administration does not lose sight 
of the fact that this plan applies to lands of national interest, and 
that all Americans are entitled to an equal voice in influencing 
both policy and management, and that the public employees that 
implement this plan are responsible for managing the public lands 
for the benefit of all citizens, regardless of whether those citizens 
live in Washington or North Carolina. We cannot allow the Federal 
agencies to abdicate the ultimate responsibility for management 
decisions to these undefined local interests. 

[The prepared statement of Mr. CuUinan appears at the conclu- 
sion of the hearing.] 

Mr. Rose. Thank you. Mr. Farr. 

Mr. Farr. From what I have heard today, what this whole goal 
is about is resource management. And you are telling us that you 
can't allow this sort of local process of resource management to 
exist, and yet we are doing that because we don't have all the for- 
est in our jurisdiction. 



41 

We have private ownership forests; we have State ownership for- 
ests. Why wouldn't a management plan that is good for the goals 
of resource protection that are good under one jurisdiction 
shouldn't be appropriate for another jurisdiction? 

Shouldn't we try to unify the approach to resource management 
rather than have a Federal approach on one hand and a State ap- 
proach on another, and a private approach on a third? 

Mr. CULLINAN. First, I think you would have a hard time con- 
vincing private timber owners that they should manage their lands 
to meet the standards and guidelines that we require for Federal 
lands. The Federal law requires that national forest lands be man- 
aged not just for timber, but for wildlife, fish, water quality, and 
recreation. 

Mr. Farr. We do that in California. Our laws are tougher than 
the Federal laws, and they apply to private lands. 

Mr. CULLINAN. I can't speak to that; I am not familiar with Cali- 
fornia law. 

Mr. Rose. Ms. Norman, give us a quick comment. We will try to 
wrap this up in about 10 minutes if we can. 

Ms. Norman. It is my assumption that the Forest Practices Act 
in California does have some good progressive language in it, but 
in reality, the amount of cutting that a private landowner is al- 
lowed to do, although it does have to stay within some limits, is 
much more intense than the Federal Government allows. 

Mr. Rose. Well, do you agree with Mr. Farr's — would you argue 
with his statement about on public lands? Isn't California pretty 
tough? 

Ms. Norman. On the Federal lands in California they abide by 
the National Forest Management Act, which applies to the entire 
National Forest System. 

Mr. Rose. How about State lands in Cahfornia? 

Ms. Norman. State lands have yet another set of rules written 
by the State of California. 

Mr. Farr. I think that is the issue that we are talking about. 

If the goal here is mutual resource protection, and the statement 
is made that the boundary lines never fit the desire to manage re- 
sources, why don't we really, if we want to really try to solve this, 
why don't we try to bring the goal of good resource management 
in as the goal that we are trying to resolve regardless of where the 
boundary lines fall? 

Ms. Norman. We would agree that ecosystem management re- 
quires a cooperation between the private landowners and the State 
managers and the Federal managers. But the reality is that we 
have private property rights that are held very dear in this coun- 
try, and they conflict with the language of the law that was passed 
by the U.S. Congress in the 1970's. 

Mr. Farr. Well, my understanding is that the power over zoning 
and roadbuilding and resource harvesting, mining on your land is 
still under the power of government. 

Mr. Hermach. It is, but the laws that were passed by the Fed- 
eral Government are stricter than those laws passed by the States, 
including Oregon, Washington, and California. 

Mr. Farr. Thank you. 



42 

Ms. GUSE-NORITAKE. In fact, if I may, I would actually love to 
see, as proposed in FEMAT, a 300-foot buffer on each side of fish- 
bearing streams on private lands in the coastal areas of the three 
States. That is going to be a problem as we start to list more spe- 
cies, what happens on those private lands. 

Those guys don't have to do that now. I would like to see the 
local jurisdictions take that problem on. There would be a lot of 
talk if that happened. 

Mr. Rose. All right. Next, Mr. Hermach. 

STATEMENT OF TIMOTHY G. HERMACH, EXECUTIVE 
DIRECTOR, NATIVE FOREST COUNCIL 

Mr. Hermach. My name is Tim Hermach, and I am from Eu- 
gene, Oregon. 

Mr. Chairman, I thank you for the opportunity to be present 
today. 

Our point of view basically has been business. We ask that public 
property be protected and our laws be respected. As an American, 
I look to the U.S. Congress to protect the public interest, the public 
health and well-being, to set the laws and to see to it that they get 
enforced, to see to it that that is protected. 

Unfortunately, Federal agencies, for which the U.S. Congress is 
in charge, have been breaking the laws, as court decisions would 
amply demonstrate, for over 30 years. They clearcut illegally. Court 
decisions came down accordingly, and then they passed new laws 
that said they could clearcut when it was in the best use of the 
land. Even though it never was, they claimed that it was and they 
continued clearcutting at an accelerated rate. 

That is what caused the problems. Nobody has a problem with 
resource utilization. The Native Forest Council has a major dif- 
ficulty and problem with resource exploitation, extraction, con- 
sumption, and destruction. We don't have sustainable forests in 
this country; we have liquidated forests in this country. We are 
continuing to do that. Resource management means public asset 
liquidations. That has to stop. 

When the U.S. Forest Service sells timber on an acre of public 
land worth $100,000, they make no accounting for a natural re- 
source asset capital account depletion. They say the cost of that in- 
ventory or the value that was liquidated was zero. They claim that 
it has a zero cost basis, a free good. 

That is utter nonsense. There are very few things that panel 1 
and panel 2 would agree with, but I think one is that these 
timberlands have value. 

We must ask the questions, what are the problems, what is caus- 
ing it, what is driving the conflicts and how do we solve them? Not 
alter, modify, delay, defer, move from one place to another, but in- 
stead solve these problems. It is my belief that win/win solutions 
are available. 

In the United States we cut nearly 130 billion board feet of wood 
products every year, much of it wasted in the extraction, wasted in 
the manufacturing, wasted in the construction, wasted in the use, 
and then wasted by nonrecycling. 



43 

Waste reduction alone can reduce the cut requirements by 50 
percent, if we thought that was appropriate. The U.S. public lands 
supply 14 percent of the domestic timber. 

At the same time, we are exporting far in excess of that amount 
unfinished, minimally processed, every single year. We are talking 
about a 5 billion board foot reduction in the cut if we eliminated 
logging of Federal lands altogether in region 6, the Pacific North- 
west. That is an insignificant drop in the domestic timber economy. 

That much timber, however, in some States it may be 50 percent 
of the State cut comes off of Federal lands. In my State we have 
25,000 small woodlot owners, every one of them suffering financial 
penalties because of unfair Government competition. 

What are in the public interest decisions regarding public prop- 
erty? Should we create a natural resource management program 
for the Smithsonian and have various interests fighting over the 
consumption of what is in the Smithsonian or Fort Knox or the 
Grand Canyon? 

No, I don't believe in public timber sales, period. Those should 
be public lands cared for for the national heritage for all time. Why 
are we selling public timber? Are we spending tax dollars to liq- 
uidate billions, hundreds of billions or even trillions of dollars' 
worth of assets at a loss? 

These questions haven't been asked, let alone answered. If they 
were answered, I believe that it would be clear, it is time for these 
Federal management agencies to obey the law, to answer the ques- 
tions, what is the condition of our forests, and what needs to be 
done about it to make them healthy, living resources that don't 
provide just timber commodities, but they provide air and water, 
quality of life, just like the parks downtown. 

That is not for somebody to go in there and say, well, I need a 
job or I need to make a dollar, so I am going to cut it down and 
take it away from the public. I believe yes, you can get ideologues 
to sit in the same room to solve problems, but only when they have 
an interest in solving the problem. 

I think that can be done, too. I don't know how. I do know that 
if you get respected nonideologues in the same room, you can get 
lots of agreement about what are the questions, what are the an- 
swers and what should be done about it. 

[The prepared statement of Mr. Hermach appears at the conclu- 
sion of the hearing.] 

Mr. Rose. We are going to have to go vote, and I want to ask 
you a question, because I know some of you may have schedules 
that have gotten tighter. Are you happy with the administration 
decision not to go after new legislation? 

Mr. Hermach. No, I am not. 

Mr. Rose. Well, then, by God, we got something we can agree on. 
We haven't agreed on what is going to be in the legislation or 
whether — see, I am of the opinion that it would be better to have 
all this stufi" clearly nailed down and in legislation to the best de- 
gree that we could do it, try to get it through this body in one 
piece, which might be difficult in the other body. 

Mr. Hermach. Difficult in this body, but it could be done. 



44 

Mr. Rose. Well, we have more tools available over here. But I 
want to thank all of you for coming. Whose maps are they on the 
board? 

Ms. Norman. That is my aerial photo right there. Would you like 
to keep that? 

Mr. Rose. Yes. What mountain is that in the upper right? 

Ms. Norman. That is Mt. Adams. 

Mr. Rose. Mt. Adams, OK. 

Ms. Norman. Southwest Washington. 

Mr. Rose. All right. Well, is it just one picture? I would like to 
keep — she lives in Eugene, Oregon, no? 

Ms. Norman. Ashland, Oregon. Would you like a copy of that? 

Mr. Rose. Yes. Either that one, or just tell us where to get one 
or mail one to my office or whatever is convenient for you. 

Ms. Norman. Fine. 

Mr. Rose. We will continue this discussion, but if you have any 
ideas about my suggestions, I want you to write the Agriculture 
Committee Subcommittee on Specialty Crops and Natural Re- 
sources, and we look forward to continuing this shortly after the 
first of the year. We will have some more hearings then on this 
subject. Thank you all very much. 

[Whereupon, at 4:20 p.m., the subcommittee was adjourned, to 
reconvene, subject to the call of the Chair.] 

[Material submitted for inclusion in the record follows:] 



45 



STATEMENT FOR THE RECORD OF JAMES GEISIN6ER 

PRESIDENT NORTHWEST FORESTRY ASSOCIATION 

BEFORE SUBCOMMITTEE ON SPECIALTY CROPS AND NATURAL RESOURCES 

OF THE COMMITTEE ON AGRICULTURE U.S. HOUSE OF REPRESENTATIVES 

November 18, 1993 
Introduction 

My name is James Geisinger, I am President of the Northwest 
Forestry Association in Portland, Oregon. The Northwest Forestry 
Association represents forest products companies in Oregon and 
Washington who are fully or partially dependent on the balanced and 
sustained management of our federal forest lands in these two 
states. Several of our members are vitally affected by the Clinton 
Administration plan for federal forest lands in the Pacific 
Northwest. 

I appreciate the opportunity to testify today. I am offering 
this testimony on behalf of my own organization, the Northwest 
Forest Resources Council (a consortixim of associations in Oregon in 
Washington) , the California Forestry Association, and the American 
Forest and Paper Association. All of these groups have been active 
in the development of the Clinton Administration Forest Plan. 
Additionally, all of these groups worked together to sxibmit 
extensive comments on the draft Plan during the comment period 
which closed last month. 

As a consequence of our extended involvement in the events 
leading up to and including the publication of the draft Forest 
Plan, we have come to some very specific conclusions about the 
technical and legal adequacy of the Administration's efforts. I 
Page 1 



46 



will review the legal issues surrounding the development of the 
draft Forest Plan. My colleagues on this panel will review the 
deficiencies of the proposal in a number of important technical 
areas. 

We submit that the current decision-making process utilized by 
the Clinton Administration does not in any way comply with 
applicable Federal Land Management laws, or the procedural 
requirements of federal administrative and environmental statutes. 
The draft Plan cannot, therefore, result in a legally sustainable 
program. . . _ 

We urge the Congress to recognize these defects, abandon the 

current process, and work with the Administration to initiate a 

new, legally defensible decision-making effort that will produce a 

Federal Land Management program that serves the needs of the 

country and can withstand legal challenge in court. For the 

current course to continue will only result in a perpetuation of 

the gridlock that has infected decision-making on federal lands for 

the past several years. This is the case for the following 

reasons. 

Point One: The DSEIS does not analyze the environmental 
impacts of not harvesting timber or building roads on the 
reserved portions of Forest Service and BLM Land. 

Forests throughout the range of the northern spotted owl are 

dynamic systems that continually evolve and change over time. All 

forests die eventually, from fire, insects, disease, windthrow or 

other causes (human or non-human induced) . 



Page 2 



47. 



Forest management has dramatically altered forest evolution 
through fire suppression, insect control, management to control and 
limit disease, and other beneficial regimes. Each of these tools 
depends heavily on the availability of roads to bring firefighters 
and other land management experts close to affected areas. 

The DSEIS does not analyze the environmental impacts that will 

result from not harvesting timber, not managing forest stands for 

timber production and not building the roads to access timber for 

harvest. The dramatic reduction in timber harvest and roads 

resulting from Option 9 will certainly increase the number and 

severity of fires, and the amount of acres of forest afflicted by 

insects and disease. Increased fires and prevalence of insects and 

disease have clear and undesirable environmental impacts which must 

be analyzed before a decision is made to adopt Option 9. American 

Timber Co. v. Berqlund . 473 F. Supp. 310, 314 (D. Mont. 1979). 

Point Two; The DSEIS does not contain accurate 
scientific, economic or social analysis and must be 
revised to correct many analytical errors. 

The DSEIS contains numerous errors in the biological, economic 
and social impacts analysis that must be corrected so the decision- 
makers can base their decisions on complete and accurate 
information. 

Drs. Irwin, Bonnickson, Palmisano, Froehlich and Oliver all 
have pointed out errors, flaws and omissions in the scientific and 
biological analysis in the DSEIS, as has Robert Zybach. Drs. 
McKillop and Schallau and Mark Rasmussen and Alberto Goetzl have 
identified similar problems in the economic analysis. All of those 

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48 



views are included in our comments which we will submit for the 
record of this hearing. Additionally, Dr. Brian Greber — a member 
of FEMAT — testified to Congress that the job losses resulting 
from Option 9 should be measured at 66,000 compared to recent 
levels rather than the 6,000 number used in the DSEIS and FEMAT 
Report. 

Drs. Lee and Beuter have identified serious flaws in the 
social impacts assessment and the risk assessment portions of the 
DSEIS and FEMAT Report. These are also included in our comments 
for the record. 

The FSEIS must address and correct all these errors to assure 

that the decision-makers are fully and accurately informed of the 

impacts of their decision. 

Point Three: There is no rational biological reason, and 
no legal justification, to maintain the viability of 
other species in the range of the northern spotted owl 
where the other species have a different range. 

The DSEIS proposes a new management regime for federal lands 

within the range of the northern spotted owl. It proposes, as 

required by the FCEC in its mission statement to FEMAT, that the 

new regime have as a key objective maintaining the viability of 

some 1,084 species associated with old-growth forest ecosystems in 

that area. Yet the FEMAT alternatives do not propose to adopt new 

management for federal lands within the range of those 1,084 

species. Nor do they propose to manage federal lands to maintain 

a viable population of each species within its current range. 

Rather, all the FEMAT options only propose to adopt new management 

for whatever portion of the range of each species happens to fall 

Page 4 



49 



within the range of the northern spotted owl. If successful, the 
preferred alternative would maintain viable populations of these 
species on whatever portion of its range happens to fall within the 
range of the northern spotted owl . 

This goal has neither biological or legal justification. 
There is nothing more than coincidence that relates the range of a 
species to the range of the northern spotted owl. Many species 
have a range that is only partly covered by the range of the 
northern spotted owl. Adopting a management regime for federal 
lands in one part of a species' range that differs dramatically 
from the management regime on federal lands in the rest of the 
species' range makes little sense. The DSEIS and the FEMAT Report 
fail to explain why this approach makes sense biologically. While 
the FEMAT Report acknowledges that the majority of the range of 
some species is outside the range of the northern spotted owl 
(Figure IV-1) , the viability assessment teams were instructed to 
disregard this fact and to limit their viability assessment to 
federal lands within the range of the northern spotted owl. id. ; 
see DSEIS Appendix A at IV-44-45. 

Legally, there is no authority for the Forest Service to 
maintain the viability of species in an arbitrary geographical area 
defined by the range of the northern spotted owl. Neither the 
viability rule nor the NFMA permit such an arbitrary exercise in 
land management. If land management is to have a rational basis, 
it must be aimed at maintaining viability in biologically-grounded 

Page 5 



50 



areas not arbitrarily defined by the first species to reach the 

courtroom. 

The circumstances of the DSEIS do not justify this arbitrary 

and biologically indefensible proposal. Judge Dwyer did not order 

the Forest Service to adopt a management plan to maintain the 

viability within the range of the northern spotted owl of every 

species found there. At most, he requested a study of the impacts 

the spotted owl management plan would have on other species. He 

did not order or authorize the Forest Service to use the northern 

spotted owl's range as a new de facto administrative area in which 

to maintain the viability of other species. 

Point Four: The DSEIS unlawfully excludes alternatives 
that cannot be analyzed vithin the arbitrary deadline 
imposed on FEMAT by the Administration. 

The DSEIS admits that it and the FEMAT Team excluded 

reasonable alternatives if it was not "feasible to analyze the 

alternatives within the timeframe available to the team." DSEIS 

2-46. FEMAT was arbitrarily given a 60-day deadline for coming up 

with options. This deadline was strictly for administrative 

convenience; no statute, regulation or court order required FEMAT 

to complete its work within 60 days. NEPA does not allow an agency 

to exclude reasonable alternatives from consideration because it 

cannot complete the work within an arbitrary deadline imposed by 

decision-makers. The essence of NEPA is that major decisions must 

await thorough analysis of every reasonable alternative even if it 

takes longer than 60 days. 



Page 6 



51 



Point Five: The portion of tbe FEMAT options aimed at 
maintaining or restoring viable populations of anadromous 
fish is biologically and legally indefensible in the 
absence of a comprehensive federal management plan 
governing every stage of the life cycle of the anadromous 
fish. 

Anadromous fish biologists universally recognize that 
salmonids have complex life histories and require multiple habitats 
to successfully complete their life cycles. Maintaining and 
restoring viable populations of anadromous fish stocks requires 
management of every portion of the life cycle that currently 
affects the salmon. Dr. John Palmisano emphasizes this point in 
his comments on the DSEIS which are submitted for the record. 

Dr. Palmisano reports that there is at present no credible 
scientific evidence showing that spawning and freshwater early 
rearing habitat — the habitat provided on federal land in the 
spotted owl region — are limiting salmonid abundance, or that 
there is a high probability of increasing abundance in these areas 
by increasing the amount of available habitat. 

Thus, the aquatic ecosystem portion of Option 9 and the other 
FEMAT options is destined to fail to achieve its goal of 
maintaining and restoring fish populations unless it is accompanied 
by a management plan for each of the other essential habitats 
required by salmonids, as well as a management plan to control 
direct salmon mortality from commercial and sport fishing harvest. 
Overfishing is the primary cause of declining salmon runs. Without 
a comprehensive harvest and habitat management plan, there is 
nothing to stop the fisheries agencies from increasing allowable 
harvests to consiame any additional fish resulting from Option 9 (if 
Page 7 



52 



there were any) , and there is nothing to stop the federal water and 
power agencies from altering hydropower operations to take more 
fish. Nothing could be more pointless than imposing extreme 
freshwater habitat protection measures on forest management so that 
any increased salmonid population can end up dead in a fish market 
or at the bottom of a dam. 

The Secretaries of Interior and Agriculture do not have the 
power to adopt such a comprehensive salmonid management plan. The 
recovery plan for listed Snake River salmon could contain all the 
elements of such a plan for those stocks, but the recovery plan is 
voluntary and cannot be imposed on other federal agencies or non- 
federal decision-makers. There is no recovery plan for non-listed 
species or stocks. 

Unless there is in place a comprehensive management plan for 
at-risk salmonid stocks that controls harvest of these stocks and 
regulates each of the habitats in their life cycle, the aquatic 
ecosystem protection measures proposed in Option 9 cannot 
contribute to the maintenance or restoration of salmonid stocks. 
Adopting a plan that cannot succeed is arbitrary and capricious. 
The Secretaries should abandon this half-baked attempt to solve one 
small part of a problem when it is clear they lack the ability to 
control the primary causes of the problem. 



Page 8 



53 



Point Six; The assessment of likelihood of maintaining 
a functional, interconnected late-successional ecosystem 
vas based on a historically flawed and scientifically 
insupportable assumption about the long-term regional 
abundance of such ecosystems. 

The DSEIS and the FEMAT Report set as their goal a management 
regime that comes as close as possible to returning federal land in 
the range of the northern spotted owl to the condition in which it 
existed prior to the time of European settlement in the early 19th 
century. DSEIS 3&4-32; Appendix A IV-51. Each FEMAT option was 
evaluated to judge its likelihood of returning this three-state 
range to pre-settlement condition within 100 years. DSEIS 3&4-41. 

The analysis assumed an average regional fire rotation of 250 
years for severe fires. The FEMAT analysts then calculated 
mathematically from this assumption that, at any one time, 60-70% 
of the landscape was covered by late-successional and old growth 
forests (meaning over 80 years of age). DSEIS 3&4-32. They 
converted this range to the single figure of 65% and used this 
figure as "an estimate of the long-term average percentage of the 
regional landscape covered by late-successional forest." Id. This 
became the management goal against which the options were judged as 
to their likelihood to create a functional, interconnected late- 
successional ecosystem. DSEIS Table 3&4-1. 

Neither the DSEIS nor the FEMAT Report contain any historical, 
factual or scientific basis for the assumption that pre-settlement 
forests were 65% late-successional and old growth. There is no 
historical, factual or scientific evidence for this assumption. 
Robert Zybach shows in his comments on the DSEIS (included in the 

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54 



record) that the assvunption that a blanket of old growth covered 
the forests of the pre-settlement Northwest is a myth with no 
historical support. He documents the best available historical 
sources to show that Native American burning practices over 
centuries had created a forest mosaic with far less late- 
successional and old-growth forest than hypothesized by the DSEIS 
and FEMAT. 

FEMAT claims there is no historical evidence to gauge the 
amount of late-successional/old-growth forest in pre-settlement 
times, and therefore justifies exclusive reliance on "the 
subjective opinions of the ecosystem experts." DSEIS 3S;4-34. Mr. 
Zybach demonstrates that this statement is clearly wrong. 
Historical evidence exists from prehistorical times, from 18th 
century chronicles of early European visitors, and from 19th 
century sources. None of this was considered or analyzed in FEMAT, 
and all of it contradicts the key "blanket of old growth" 
assumption that drives the FEMAT analysis. A new analysis must be 
conducted utilizing all the available historical and scientific 
information on this key issue. 

Had the analysis used the correct conclusion that the 
percentage of pre-settlement late-successional/old growth forest 
was well below the assumed 65% figure, all the FEMAT options would 
have received higher rankings. More importantly, additional 
options involving smaller amounts of late-successional/old growth 
reserves could have been developed and would have received 
reasonably high rankings. 

Page 10 



55 



The "blanket of old growth" assumption drove not only the 

ecosystem assessments but the species assessments as well. The 

viability panels must have assumed the same blanket of old growth, 

and they clearly believed that the highest viability ratings should 

be assigned to options that closely paralleled pre-settlement 

conditions. Had they been properly informed as to the much smaller 

amount of late-successional/old growth forest in pre-settlement 

times, their ratings would have been much different. 

Point Seven: The Forest Service has no legal authority 
to maintain viability of non-vertebrate species. 

The Forest Service viability rule requires that agency's 
planning efforts to include measures to manage fish and wildlife 
habitat "to maintain viable populations of existing native and 
desired non-native vertebrate species . . . ." 36 C.F.R. § 219.19. 
This regulation, which interprets the National Forest Management 
Act, grants the Forest Service no authority to manage the national 
forests to maintain the viability of non-vertebrate species. No 
other statute or regulation allows the Forest Service to maintain 
viability of non-vertebrate species at the expense of other uses of 
the national forests. 

Nonetheless, FEMAT crafted all its options, including 
Option 9, to maintain the viability of over 1084 non-vertebrate 
species in the national forests (and BLM lands) . See DSEIS 3&4-31. 
FEMAT was required by the FCEC to develop all its alternatives to 
achieve the objective of "maintenance and/or restoration of habitat 
conditions to support viable populations, well-distributed across 
their current ranges, of species known (or reasonably expected) to 
Page 11 



56 



be associated with old-growth forest conditions." DSEIS, Appendix 
C at 4. There is no legal authority for the Forest Service to 
restrict other uses of the national forests in order to maintain or 
restore the viability of well-distributed populations of non- 
vertebrate species present or "reasonably expected" to be present 
on national forest lands. The Forest Service has no legal 
authority to adopt any of the FEMAT options because all the options 
were designed to implement this impermissible goal. 

Point Eight: The President adopted Option Nine as 
Administration policy without any environmental analysis 
or public involvement in violation of NEFA, NFMA and 
FLPMA. 

The fundamental requirement of NEPA, NFMA and FLPMA is that 
environmental analysis and public involvement must precede any land 
management decision with significant environmental impacts. In 
this case the Administration has turned this process on its head. 
On July 1, 1993 the President announced Option 9 as his 
administration's policy without the benefit of any environmental 
analysis or public involvement. The President did not know the 
environmental impacts of his decision, nor did he have an 
opportunity to learn the public's views on his program. After the 
decision was announced, his administration then began the 
environmental analysis and public involvement procedures that 
should have occurred before a final decision was made. 

This ElS/public involvement process is a sham — a phony 
exercise to create the appearance of complying with the law even 
though the real decision has already been made by the President. 
Neither Secretary Babbitt nor Secretary Espy are going to overrule 
Page 12 



57 



the President, and reflect poorly on the President's knowledge or 
judgment, by choosing a different alternative than the one 
announced by the President on July 1. 

Further, starting on July 1 the entire administration 
immediately launched a program to begin implementing parts of 
Option 9 at once, and to create a new bureaucracy to implement the 
balance of Option 9 as soon as formally announced by the 
Secretaries on December 31, 1993. Literally dozens of memoranda 
and other documents reveal the administration's unrestrained 
intention to implement Option 9 fully — months before the final 
decision has been made. Everyone in the administration knows that 
the Secretaries are going to adopt Option 9 in the Record of 
Decision. 

This process violates the basic principles of NEPA, NFMA and 

FLPMA. 42 U.S.C. § 4332; 16 U.S.C. § 1604; 43 U.S.C. § 1712. 

Point Nine: Neither the Preferred Alternative nor the 
other "ecosystem management" alternatives comply vitb the 
Oregon and California Lemds Act, 43 D.8.C. § 1181a. 

We submit that the Secretary of Interior may not legally adopt 

the current Preferred Alternative (FEMAT Option 9) nor any of the 

other FEMAT "ecosystem management" options for the lands managed by 

the BLM under the Oregon and California Lands Act or the Coos Bay 

Wagon Road Act. Those statutes limit management options on those 

lands to programs in which "the primary use of the lands is for 

timber production to be managed in conformity with the provision of 

sustained yield." Headwaters. Inc. v. BLM. Medford District . 914 

F.2d 1174, 1183 (9th Cir. 1990) (quoting O'Neal v. United States , 

Page 13 



58 



814 F.2d 1285, 1287 (9th Cir. 1987)). In Headwaters the court 
specifically rejected the very proposal offered here — "exempting 
certain timber resources from harvesting to serve as wildlife 
habitat" — as "inconsistent with the principle of sustained 
yield." Id. at 1183. 

In upholding the BLM's interpretation of the O & C Act as 
"establishing timber production as the dominant use," the court 
stated: "Nowhere does the legislative history suggest that 
wildlife habitat conservation or conservation of old growth forest 
is a goal on a par with timber production, or indeed that it is a 
goal of the O & C Act at all." Id. 

Adopting Option 9, or any of the FEMAT options, violates the 

O & C Act as interpreted in Headwaters since it transforms timber 

production from the dominant use of the O & C lands to a secondary 

goal of less importance than habitat conservation or conservation 

of old growth forest. 

Point Ten; Pre-settlement conditions do not provide a 
valid basis for judging the viability of species or 
ecosystems. ,. , ._ 

Apart from the erroneous assumption as to the amount of late- 

successional/old growth forest in pre-settlement times, the FEMAT 

Report never explains why pre-settlement distribution of forest 

stages is the only valid measure of the existence of a functional, 

interconnected late-successional ecosystem. It could be assumed 

that the pre-settlement conditions were a functional, 

interconnected system. But the FEKAT Report never explains why 

those conditions would be considered the only definition of such a 

Page 14 



59 



system. There is no scientific basis provided for the assumption 

that an ecosystem with a different amount of late-successional/old 

growth stands is not a functional, viable system. 

Point Eleven: Because the Forest Service failed to 
comply with Judge Dwyer's rulings on the alternatives in 
the January 1992 Forest Service EI8, it has unlawfully 
precluded the Secretary from selecting any of those 
alternatives and it cannot rely on that legally-defective 
document to support the current decision. 

To the extent the Forest Service might claim that it is 
relying on the January 1992 EIS, it can not legally adopt or rely 
on any of the alternatives in the January 1992 Forest Service EIS 
because the agency has failed to cure the legal defects in that 
document identified by Judge Dwyer and affirmed by the Ninth 
Circuit in Seattle Audubon Societv v. Moseley . 798 F. Supp. 1473 
(W.D. Wash. 1992), aff 'd sub nom Seattle Audubon Societv v. Espv . 
998 F.2d 699 (9th Cir. 1993). 

In 1992 Judge Dwyer ruled that the January 1992 EIS was 
inadequate under NEPA because the Forest Service had not analyzed 
the impacts that any of the alternatives in the document would have 
on other species within the range of the northern spotted owl. 
Moseley . 798 F. Supp. at 1483. He enjoined the Forest Service from 
acting on the EIS until this defect was cured. Seattle Audubon 
Society v. Moseley . 798 F. Supp. 1484, 1493. 

The Forest Service never cured that defect. While the current 
DSEIS analyzes the impacts of the FEMAT options on other species 
within the range of the northern spotted owl, it does not provide 
a similar analysis for any of the original alternatives in the 
January 1992 EIS. The Forest Service has never done this analysis 
Page 15 



60 



despite Judge Dwyer's order. Thus, the Forest Service is legally 

barred from selecting any of those alternatives, and the Forest 

Service has improperly eliminated those alternatives from 

consideration by failing to do the required analysis. Instead, it 

unlawfully restricted the alternatives it can select to the FEMAT 

options which did receive the required analysis. 

The failure to comply with Judge Dwyer's order means the 

original EIS is still legally defective, and also means the Forest 

Service cannot rely on it as any part of the basis for the decision 

on the current DSEIS. Without providing the information required 

by Judge Dwyer for the original 1992 alternatives as well as the 

new FEMAT options, the decision-makers have no way of knowing how 

the original alternatives compare to the FEMAT options. The 

omission of the very information deemed essential by Judge Dwyer is 

unlawful, and must be remedied before any lawful decision on the 

DSEIS can be made. 

Point Twelve: All the FEMAT options unlawfully impose 

the Forest Service "viability rule" standard on the o s c ' ' 

Lands. 

All the FEMAT options analyzed in the DSEIS suffer from a 
common legal flaw: they apply the Forest Service "viability 
standard" set out in 36 C.F.R. § 219.19 to the BLM lands covered in 
the DSEIS. There is no legal authority to apply the Forest Service 
viability standard to the O & C lands. 

The DSEIS indicates that neither the Secretary nor the BLM 
ever made a decision to apply a viability standard to the O & C 
lands. This decision was made by the Forest Conference Executive 

Page 16 



Committee in its May 7, 1993 statement of mission to FEMAT (DSEIS 
Appendix C) . It directed FEMAT as follows: "To achieve similar 
treatment on all federal lands involved here, you should apply the 
'viability standard' to the BLM lands." DSEIS, Appendix C at 4. 
FEMAT interpreted this direction to be a reference to the Forest 
Service viability rule. DSEIS, Appendix A (FEMAT Report) at II-5. 

There is no statutory or other legal basis to "apply the 
•viability standard' to the BLM lands." The Forest Service 
viability standard is derived from the National Forest Management 
Act, which does not apply to BLM land. The Forest Service 
viability standard is clearly prohibited on O & C lands by the 
O & C Act, as held by the Ninth Circuit in Headwaters. Inc. v. BLM. 
Medford District . 914 F.2d 1174, 1183 (9th Cir. 1990). The BLM has 
no legal authority to manage the & C lands to maintain the 
viability of any species or to preserve old growth or late- 
successional ecosystems. 

None of the FEMAT options can lawfully be applied to the O & C 

lands since they all are based on the viability standard which may 

not be applied to those lands. 

Point Thirteen: The agencies' stated objective in the 
DSEIS has been unlawfully and unreasonably narrowed to 
require the adoption of a FEMAT option to the exclusion 
of all other alternatives. 

An agency's definition of the objective it seeks to achieve is 

critical to its full compliance with NEPA. The proper range of 

alternatives is determined by the agency's definition of its 

objective. The agency's definition of its objective must be 

reasonable. Citizens Against Burlington. Inc. v. Busev . 938 F.2d 

Page 17 



78-799 0-94-3 



62 



190, 196 (D.C. Cir.)» cert, denied . 112 S. Ct. 616 (1991), and it 
is not permissible to define the agency's objective in such a 
manner so as to preordain the outcome. Residents in Protest — 
I-35E V. Dole . 583 F. Supp. 653, 660 (D, Minn. 1984), or to narrow 
the objective of the action artificially to restrict the 
alternatives to be considered. City of New York v. United States 
Department of Transportation . 715 F.2d 732, 743 (2d Cir. 1983), 
cert, denied . 465 U.S. 1055 (1984). 

The DSEIS violates these rules. The agencies artificially and 
impermissibly narrowed the objective to require the selection of a 
FEMAT ecosystem management alternative. The stated underlying need 
is for the agencies to coordinate their management "to maintain and 
restore biological diversity as it applies to late-successional and 
old-growth forest ecosystems," DSEIS 1-2, and the stated purpose 
of the action is "to take an ecosystem approach to forest 
management . . . ." DSEIS 1-3. Not surprisingly, "[e]ach 
alternative is an ecosystem management plan for managing habitat 
for late-successional and old-growth forest related species 
. . . ." DSEIS 2-1. 

This unduly narrow statement of purpose and need is 

unreasonable, and violates NEPA: 

The statement of proposed action and 
underlying need can never be the same. "We 
propose to build a dam because we need a dam" 
is not a proper statement of underlying need; 
it is just a repetition of the proposal, and 
in any event it is not analytic. 

Owen L. Schmidt, The Statement of Underlying Need Defines the Range 

of Alternatives in Environmental Documents . 18 Envtl. L. 371, 380 

Page 18 



63 



(1988) . Similarly, the agencies cannot state that the purpose of 
the proposed action is to adopt ecosystem management, and then 
propose to adopt ecosystem management to achieve that purpose. 

An agency's definition of its objective can be sustained only 
if it is based on "hard thought" by the agency. Here the agencies 
gave no thought to their objective. The Forest Service and BLM 
were unilaterally told by the FCEC what their objective was, and 
how they would meet it. This imposition of a self-defining 
objective on the agencies, without any thought or analysis by the 
agencies, cannot be sustained under NEPA. 

The proper and lawful need and purpose of this action is to 
adopt management plans for Forest Service and BLM lands within the 
range of the northern spotted owl. Ecosystem management is one 
approach to land management; a means to an end — not an end in 
itself. There are many ways of managing federal forest lands; 
ecosystem management in some form may or may not be one of them, 
but it is certainly not the only one. The agencies should have 
defined their need and purpose in light of the statutory objectives 
of the NFMA and the O & C Act. City of New York . 715 F.2d at 743. 
The statutory objective of NFMA is to manage the national forests 
under the doctrines of multiple-use and sustained yield for the 
optimum benefit of the American people. The statutory objective of 
the O & C Act is to provide timber on a sustained yield basis to 
benefit local communities and industries. Had the agencies defined 
their purpose and need in light of these statutory objectives, they 
would have defined a far broader purpose and need than ecosystem 

Page 19 



64 



management, and a far broader range of alternatives, each requiring 

development and analysis, would have been available to meet this 

purpose and need. 

Had the agencies properly considered the statutory objectives 

of the governing land management laws, they could not have proposed 

ecosystem management as the goal of this decision. Ecosystem 

management is not a permissible goal for the O & C lands, and is 

permissible for the national forests only to the extent it is 

consistent with multiple-use management principles. Thus, in this 

case the stated purpose and need is clearly illegal, and cannot be 

sustained. The agencies need to adopt a proper, lawful purpose and 

need, and then identify all reasonable alternatives to meet that 

need. 

Point Fourteen: The range of alternatives is too narrow; 
the agencies have not analyzed all reasonable 
alternatives. 

The DSEIS violates NEPA, NFMA and FLPMA by failing to analyze 
all reasonable alternatives. Every alternative in the DSEIS is an 
ecosystem management alternative developed by FEMAT. 

As discussed above, the agencies improperly narrowed their 
purpose and objective to require them to adopt ecosystem management 
in order to meet the need of having ecosystem management. A proper 
statement of purpose and objective, based on the statutory 
objectives of NFMA and the O & C Act, should have produced a far 
broader range of alternatives. Perhaps ecosystem management could 
be one alternative (although none of the ecosystem management 
alternatives designed by FEMAT are legal under the O & C Act and 

Page 20 



65 



NFMA) , but numerous other non-ecosystem management alternatives 
should also have been analyzed. There should have been an 
alternative with an emphasis on timber production, an alternative 
with emphasis on early-successional forest stands and species, and 
one with a recreation emphasis. 

The DSEIS commits the very same error identified by the Ninth 
Circuit in California v. Block . 690 F.2d 753, 767 (9th Cir. 1982). 
The alternatives are limited to options with 66-88% of all federal 
land set aside in reserved areas where no timber production or 
other land management can occur. No alternative places more than 
34% of federal lands into the "matrix" where land management is 
allowed. In Block the Ninth Circuit held the range of alternatives 
was too narrow where no alternative considered placing more than 
one-third of roadless areas in to wilderness. Here, no alternative 
places more than one-third of the land base into active land 
management. Unde r Block this range of alternatives is too narrow. 

Even if the purpose and need of the action could properly be 
limited to adopting ecosystem management, the DSEIS still fails to 
analyze all reasonable alternatives. All the FEMAT options rely 
exclusively or primarily on the natural reserves approach to 
ecosystem management. The DSEIS lacks a landscape management 
alternative, as suggested by Dr. Chadwick Dearing Oliver, in which 
management rather than preservation is used as the primary tool for 
achieving biological diversity including late-successional and old- 
growth forest ecosystems. The complete failure to analyze any 
alternative utilizing landscape management violates NEPA. The 

Page 21 



66 



DSEIS also fails to analyze the reasonable alternative identified 

by Dr. Thomas M. Bonnicksen in his conunents. 

Point Fifteen: The public could not comment fully and 
properly on FEMAT options without the documents 
supporting the FEMAT analysis, which have been unlawfully 
withheld from the public. 

The DSEIS relies almost entirely on the analysis in the FEMAT 
Report. The FEMAT Report, in turn, relies on the analysis of the 
scientists who participated on it, including the viability experts 
who participated in the viability ranking panels. 

Almost none of the documents supporting the FEMAT analysis 
have been made available to the public. Without these documents, 
the public (including the industry) cannot comment fully and 
meaningfully on the FEMAT Report. The agencies have violated NEPA 
by failing to make available to the public the documents on which 
the environmental analysis relies. 

We sought FEMAT documents under the Federal Advisory Committee 
Act and the Freedom of Information Act. The FACA request was 
rejected in its entirety, and litigation is pending on that issue. 
Northwest Forest Resource Council v. Espy . No 93-1621 TPJ (D.D.C.). 
The FOIA request has been met with very little actual response to 
date, although a few boxes of miscellaneous FEMAT documents have 
been made available in the BLM state office in Portland. Some 
material has been redacted, and there is virtually nothing that 
explains any of the biological analysis in the FEMAT Report. 

The agencies should allow the public to review the underlying 
documents and to comment based on those documents before making the 
final decision. 
Page 22 



67 



Point Sixteen; All tbe FEMAT options fail to assess 
whether viable populations of early-successional species 
will be maintained on federal land, improperly relying 
instead on the presence of such species on non-federal 
land. 

The Forest Service viability rule is not limited to vertebrate 
species associated with old-growth forest. It applies equally to 
species associated with early-successional forest stages. Yet the 
FEMAT was not asked to assess, and did not assess, whether its 
options will maintain viable populations of native vertebrate 
species associated with early-successional forest stages. 

The DSEIS indicates that there are fish and wildlife species 
associated with early-successional forest stages (DSEIS at 3&4- 
101) , and assumes that the small unpreserved "matrix area" of 
federal land "as well as nonfederal forest lands are likely to be 
maintained in various levels of early-successional forests." DSEIS 
at 3&4-102. It summarily concludes: "The extent of these lands 
throughout the region should assure adequate habitat for species 
which depend on early-successional forests." Id. 

This conclusion does not satisfy the Forest Service viability 
rule, which requires adequate habitat to be available on federal 
land to maintain the viability of species. Federal land managers 
may not rely on private land to maintain early-successional 
species; their duty is to maintain these species on federal land 
just as they maintain old-growth-associated species on federal 
land. They must analyze the viability of these species on federal 
land in as much detail as they analyzed the viability of the 1084 

Page 23 



68 



old-growth-associated species described in the DSEIS and FEMAT 

Report. 

There is scientific evidence that conservation strategies must 

consider the fact that wildlife species using the open-canopy 

habitats of early-successional forests are declining significantly 

in abundance in the Pacific Northwest: 

[C]onservation strategies in the Pacific -i . 
Northwest that advocate only the retention of 
old-growth habitats and late successional 
species probably err in assuming that open- 
canopy species are "weedy" and will always do ^ „ 
well in disturbed landscapes. Some of these 
species are presently declining in abundance, 
possibly because the microhabitats or patch 
sizes they require are not being created at ^, 
sufficient levels. 

Andrew J. Hansen and Dean L. Urban, Avian response to landscape 

pattern; The role of species' life histories. 7 Landscape Ecology 

163, 172 (1992). 

Point Seventeen; The Forest Service has no authority to 
establish and preserve a connected or interactive old- 
growth forest ecosystem on national forest land except to 
the extent appropriate under multiple-use management. 

The FCEC also required all the FEMAT alternatives to meet the 
objective of "maintenance and/or creation of a connected or 
interactive old-growth forest ecosystem on the federal lands within 
the region under consideration." DSEIS, Appendix C at 4. All the 
FEMAT options, including Option 9, met this objective. 

This direction violates the Multiple-Use Sustained Yield Act 
("MUSY") and the National Forest Management Act ("NFMA"), both of 
which require the Forest Service to manage the national forests 
under the principles of multiple use and sustained yield. The MUSY 

Page 24 



69 



states: "It is the policy of the Congress that the national 
forests are established and shall be administered for outdoor 
recreation, range, timber, watershed, and wildlife and fish 
purposes." 16 U.S.C. § 528. The Secretary of Agriculture is 
"directed to develop and administer the renewable surface resources 
of the national forests for multiple use and sustained yield of the 
several products and services obtained therefrom." 16 U.S.C. 
S 529. These statutes do not allow the Forest Service (or other 
government officials) to decide at the beginning of a land 
management planning process that preservation of old-growth forest 
ecosystems must be achieved without regard to principles of 
multiple use and sustained yield. Yet that is the result of the 
FCEC directive to FEMAT. 

Thus, all the FEMAT options are unlawful under the Multiple- 
Use Sustained Yield Act and the National Forest Management Act 
because they are not multiple-use management plans. All the FEMAT 
options make preservation of old-growth forest ecosystems the 
highest priority of the national forests, and make all other uses 
and resources secondary. This is impermissible under multiple-use 
management. The Forest Service may not decide that old-growth 
forest ecosystems must be preserved at the expense of all other 
uses and resources. 



Page 25 



70 



Point Eighteen: The DSEIS does not comply with NEPA's 
requirements for an EXS and cannot properly be considered 
a supplemental EXS since it relates to a fundzuaentally 
different proposed action than was originally identified 
in the documents it purports to supplement. 

The Forest Service and BLM labelled this document a draft 
supplemental EIS, claiming that it supplements the Forest Service 
1992 EIS on Management For The Northern Spotted Owl In The National 
Forests (January 1992) and seven draft EISs and one final EIS for 
resource management plans for BLM districts or portions of 
districts. DSEIS, Abstract, On this basis the agencies attempt to 
justify the elimination of scoping, the failure to identify a new 
no action alternative and a sharply reduced range of alternatives. 

The agencies' label is not correct. This EIS is not 
supplemental to any prior EIS. It stands alone in support of an 
entirely new proposed action, and must satisfy all NEPA 
requirements for an EIS. It does not satisfy these requirements, 
and must be redone in compliance with NEPA. 

The defined purpose and need of this DSEIS is completely 

different from the purpose and need expressed in January 1992 

Forest Service EIS and in the draft BLM EISs. The USFS and the 

BLM's underlying purpose and need in the DSEIS is: 

to coordinate the management of lands they 
administer within the range of the northern 
spotted owl to maintain and restore biological 
diversity as it applies to late-successional 
and old-growth forest ecosystems. 

DSEIS at 1-2. The Forest Services 's 1992 FEIS in contrast states 

that the underlying purpose and need to its proposed action is: 



Page 26 



71 



to manage habitat for the northern spotted owl 

. , . to satisfy the court order "to submit to the 
court and have in effect by March 5, 1992 revised 
standards and guidelines to ensure the northern 
spotted owl's viability . . . ." 

FEIS at 1-1. The purpose and need of the BLM EISs is even more 

different. The Medford District Resource Management Plan and 

Environmental Impact Statement^ ("Medford DRMP/EIS") states that 

it will: 

establish guidelines for the management of , 
BLM-administered land in the Medford District. 
It will provide a comprehensive framework for . 
allocating and managing BLM-administered 
resources in the planning area for the life of 
the plan, which is expected to be at least ten 
years, within the principles of multiple use 
and sustained yield. 

Medford DRMP/EIS at 1-3. The Areata RMP/EIS states that it: 

provides a broad framework for multiple-use 
management on public lands in accordance with 
the Federal Land Policy and Management Act of 
1976 (FLPMA) for land use planning. . . . The 
RMP makes land use allocations, sets broad 
production goals, and establishes restrictions 
on resource programs to protect important 
resource values. 

Areata RMP/EIS Record of Decision at 2. The Redding RMP/EIS 

identifies that it will: 

guide the Bureau of Land Management's (BLM) of 
247,500 acres of public land and an additional 
142,000 acres of Federal mineral reserve 
estate (split estate) .... 



The Draft Resource Management Plans and Environmental 
Impact Statements for the Coos Bay, Eugene, Klamath Falls, Medford, 
Roseburg and Salem BLM districts were prepared concurrently and are 
almost identical. 

Page 27 



72 



The primary purpose of this RMP is to 
update and integrate BLM land use planning 
. . . into a single, comprehensive land-use 
plan. This RMP will provide the overall 
direction for managing and allocating public 
land resources and uses in the Redding 
Resource Area over the next 15 years. 

Redding RMP/EIS at 1-1. 

None of the previous EISs propose to protect and enhance late- 

successional and old-grovrt;h forest ecosystems. In fact, the 1992 

Forest Service FEIS expressly states that "the Forest Service is 

not attempting to resolve the entire spotted owl issue or resolve 

the old-growth forest issue." 1992 FEIS at 1-2. Moreover, the 

1992 FEIS rejected alternatives focusing on old-growth forest 

management and management of other old-growth associated wildlife 

species. 1992 FEIS at 2-73. 

All old growth is not spotted owl habitat; all 
spotted owl habitat is not old growth. While 
an alternative that would provide management 
direction for old-growth forests and wildlife 
species would provide management direction for 
habitat for the spotted owl, it would impose 
greater change on Forest management and the 
economy than necessary to meet the underlying 
purpose and need of the proposed action. 

1992 FEIS at 2-73 (emphasis supplied) . The proposed action in all 

of the BLM RMP/EISs is to adopt a new comprehensive resource 

management plan for each BLM district as part of the standard FLPMA 

land use planning process. 

The DSEIS could not supplement the BLM DEISs because the DSEIS 

does not make the decision for which those documents were prepared: 

district resource management plans. The BLM still must complete a 



Page 28 



final EIS and adopt a resource management plan for each district, 
with or without Option 9. 

If this decision were the same as the original agency actions 
for which the prior EISs were prepared, the purpose and need would 
have remained the same. The fact that the purpose and need of the 
proposed action have been so radically redefined shows that this is 
not the same action as that for which the prior EISs were prepared, 
and the agencies should have initiated the NEPA process from the 
beginning, with scoping, a proper no action alternative and a full 
range of alternatives rather than attempt to shoehorn this decision ^ 
into the existing inapplicable NEPA processes that were already v 
ongoing for different decisions. 

There is also a different decision-maker for the BLM portion 

of this decision than for the RMPs it supposedly supplements. The 

Secretary of Interior is the decision-maker for BLM on this 

decision; for the RMPs the decision-makers are BLM officials at the 

district and state level. Further, even after this decision by the 

Secretary is made, it will still be necessary for the BLM state 

officials to adopt new RMPs for each of its districts. Thus, this 

cannot be same decision as in the original RMP/EISs. The current 

decision is fundamentally different than the original agency 

decisions for which the prior EISs were prepared. 

Point Nineteen: The agencies have violated NEPA by 
failing to engage in scoping prior to issuing the DSEIS. 

The agencies did not engage in scoping as required by 40 

C.F.R. 1501.7. Their attempt to avoid scoping by calling the DSEIS 

a supplement is legally incorrect for the reason stated above. In 

Page 29 



74 



truth, no prior EIS has ever asked the public to identify the 
issues relating to preserving late-successional and old-growth 
forest ecosystems. The Forest Service January 1992 EIS explicitly 
disclaims addressing that very issue. 

Any reliance by the agencies on the June 21, 1993 memorandum 
from Dinah Bear to David Cottingham is misplaced. Contrary to the 
DSEIS, Ms. Bear is not a member of the Council on Environmental 
Quality. She is an employee of the council. In fact, the Clinton 
Administration has proposed to abolish the CEQ, and has never 
appointed any members to it. There is no CEQ for whom Ms. Bear can 
speak, and her interpretation of NEPA, which is incorrect, is 
entitled to no weight. 

Neither the Forest Conference nor other miscellaneous contacts 
with the FEMAT Team substitute for scoping. The White House 
controlled attendance at the Forest Conference, and insisted on 
approving the script of what each participant could say at the 
Forest Conference. There was no open exchange of ideas that could 
substitute for scoping. The FEMAT Team operated in secrecy, and 
refused to allow the public to attend its meetings. There was no 
chance for the public to identify issues for consideration. 

The breadth of these comments illustrates why scoping should 
have occurred. The FEMAT Team and the DSEIS Team missed major 
legal issues they should have addressed, and failed to consider 
major environmental concerns that scoping would surely have 
identified. The Administration should begin the new EIS process 
with the scoping required by NEPA. 

Page 30 



75 



Point Twenty: The BLM cannot rely on any of the 
alternatives in the draft BLM RMP/EISs because the BLM 
has not responded to public comments or issued a final 
EIS on those alternatives, and the agencies cannot rely 
on a draft EIS to support a final decision. 

While the DSEIS maintains that it is supplementing the draft 
BLM RMP/EISs for six BLM districts in Oregon (DSEIS 2-7) and 
therefore relying on the alternatives in those documents, it cannot 
legally do so. Draft EISs cannot form the legal basis for any 
decision. The agency must consider and respond to public comments 
on the draft EIS, and must publish a final EIS before a legally 
supportable decision can be made under NEPA. 4 C.F.R. § 1502.9; 
§ 1503.4. The BLM has not responded to public comments on those 
drafts, and has not released a final EIS for any of its district 
RMPs. It may not lawfully base any decision even in part on the 
draft EISs. 40 C.F.R. § 1506.3. 

Conclusion 

We urge the Subcommittee to direct the agencies to withdraw 
the DSEIS and to begin a new decision-making process in compliance 
with NEPA, NFMA and the O & C Act. The preferred alternative is 
not legal, and cannot lawfully be adopted or implemented. Congress 
must step in to avoid the continuation of agency gridlock. 

I appreciate the opportunity to offer my views. I would be 
happy to respond to the Subcommittee's questions. 

(Attachment follows:) 



Page 31 



76 



Comments on the Draft Supplemental 

Environmental Impact Statement on 

Management of Habitat for Late- 

Successional and Old-Growth Forest Related 

Species within the Range of the Northern 

Spotted Owl 



October 1993 



Submitted by: 



Northwest Forest Rcsburrc Cour.cU American Forest & Paper Association 

Northwest Forestr}' Association California Forestry' Association 

Douglas Timber Operators Associated Oregon Loggers 

Helicopter Logging Association Siuslaw Timber Operators 

Oregon Forest Industries Council Northwest Independent Forest Manufacturers 

^^'ashington Citizens for World Trade Southern Oregon Timber Industries Association 

Washington Forest Protection Association Wasliington Contract Loggers Association 

Western Forest Industries Association Western Wood Products Association 



77 




NORTHWEST FOREST 



RESOURCE COUNCIL' 



500 S.W First Avenue. Suite 770 * Pomgna. Oregon 97201 • ^503) 222-9505 



October 27. 1993 



Choirmon 

John C Hampton 

Vice Choirmon/Legal 
Committee Ct^oirman 

Sob Rogon 

finance Commrttee 
Chairman 

Bud Johnson 

Public eelattons/ 
PoiHlcal Action 
Committee Cholrnion 

Cathy BolOwin 

Tectinical Committee 
Chaimion 

Chanes h Buriev 

wildlife Committee 

Chairman 

R K,rk Ev«3rt 



Mr. Roben T. Jacobs. Team Leader 

Interagency SEIS Team 

P.O. Box 3623 

Portland. OR 97208-3623 

Dear Mr. Jacobs: 



The following comments are submitied to the Interagency SEIS Team in accordance with the 
public comment period specified for the Draft Supplemental Environmental Impact Statement 
on Management of Habitat for Late-Successional and Old-Growth Forest Related Species 
within the Range of the Northern Spotted Owl (DSEIS). These comments are submitted on 
behalf of the Northwest Forest Resource Council, Amencan Forest and Paper Association, 
Northwest Forestry Association. California Forestry Association, Associated Oregon Loggers, 
Douglas Timber Operators, Siuslaw Timber Operators, Helicopter Logging Association, 
Northwest Independent Forest Manufacmrers, Oregon Forest Industnes Council, Southern 
Oregon Timber Industries Association, Washington Citizens for World Trade. Washington 
Contract Loggers Association, Washington Forest Protection Association, Western Wood 
Products Association, Western Forest Industries Association, the employees and members of 
the above organizations, and the employees of the companies that belong to the above 
organizations. 

These organizations represent the majority of forest product manufacturers, logging contractors , and other 
related business that would be impacted by the implementation of the preferred alternative in the DSEIS. 
They have been dependent on federal lands for their raw material supply for decades. Many of the 
companies were founded on the government's promise of a stable supply of timber from tlie federal lands. 
The preferred alternative of the DSEIS breaks this conmiiiment to the companies and the communities that 
depend on them. 

We have enlisted the help of forest scientists, analysts, economists, and aaomeys from throughout the 
Nation to prepare our review of the DSEIS. Their entire comments are included. We have not prepared 
a summary of our comments because we believe each of the papers presented are important and should 
be reviewed in full. Given the exieiu of these conmients, and the clear demonstration of need for 
revision, we hope you will produce a significantly different and scientifically and legally soimd final 
Supplemental Environmental Impact Statement and Preferred Alternative. 

If you have any questions regarding the materials submined. please contact Ralph Saperstein, Northwest 
Forestry Association, 1500 S.W. First Ave., Suite 770, Pordand. Oregon 97 201. (5 03) 222-9505. 



Sincerely. 



// John Hampton, Chairman 

Northwest Forest Resource Council 



-fU-^ 




Mark Rey, Vice President Forest Resources 
American Forest & Paper Association 



■Receseniing 

Associated Oregon Loggers 

Columoid River Rv^«xia Coooerotives 

Oougios limber Ooeiarors 

HeitcoDtor Logging Association 

Nortnwest Forestry Association 



William Dennison, President 

California Forestry Association 

Northwest indeDenoent forest 

Mdnutocturers Association 

Oregon forest industties Coutv^ii 

Southern Oregon rimber industnes Asscciotion 



Washington Citizens tor World troae 

Washington Contioct Loggen Association 

Western Wood Ptoducts Associotion 

Western forest Industties Association 

Willometre foresiv Council 



78 



Comments on the Draft Supplemental Environmental Impact Statement on Management of 
Habitat for Late-Successional and Old-Growth Forest Related Species within the Range of the 
Northern Spotted Owl by the Northwest Forest Resource Council and the American Forest & 

Paper Association. 

Table of Contents 



A. An Analysis of a Plan to Maintain Old-Growth Forest Ecosystems. By Thomas M 
Bonnicksen, Ph.D. 

B. Forest History and FEMAT Assumptions: A Critical Review of President Clinton's 1993 
Northwest Forest Plan. By Bob Zybach 

C. Comments on the Draft Supplemental Environmental Impact Statement on Management 
of Habitat for Late-Successional and Old-Growth Forest Related Species within the Range 
of the Northern Spotted Owl. By Chadwick Dearing Oliver, Ph.D. 

D. Northwest Forest Resource Council's Comments on the Aquatic Chapters of the 
FEMAT/DSEIS Reports on the President's Forest Plan: Salmonid Fisheries Issues. By 
John F. Palmisano, Ph.D. 

E. Technical Comments on the Draft Supplemental Environmental Impact Statement on 
Management of Habitat for Late-Successional and Old-Growth Forest Related Species 
within the Range of the Northern Spotted Owl and Report of the Forest Ecosystem 
Management Assessment Team. By Larry Irwin, Ph.D. 

F. Review of FEMAT Report Chapter V - Aquatic Ecosystem Management, Chapter VIII - 

Implementation and Adaptive Management, A Brief Review in Stream Ecology Research. 
By Henry A. Froehlich, Ph.D. 

G. Legal Comments on the Draft Supplemental Environmental Impact Statement on 
Management of Habitat for Late-Successional and Old-Growth Forest Related Species 
within the Range of the Northem Spotted Owl. By Preston, Thorgrimson, Shidler, Gates 
& Ellis 

H. Comments on the FEMAT Report on Ecosystem Management, and the DSEIS on Old- 
Growth and Late-Successional Forest Management. By John R Beuter, Ph.D. 

L An Economic Analysis of the FEMAT Report. By William McKillop, Ph.D. 

J. A Constructive Critique of the FEMAT Social Assessment. By Robert G. Lee, Ph.D. 

K. Evaluation of Report of the FEMAT Resource Analysis Group. By Mark Rasmussen 



79 



L. Evaluation oftheTAMM Analysis for the President's Timber Plaa By Mark Rasmussen 
and Alberto Goetzl 

M. A Critique of The Outlook of Projected Timber Dependent Employment. By Douglas C. 
Olson, Ph.D. and Wilbur Maki, Ph.D. 

N. Comments on the Draft Supplemental Environmental Impact Statement on Management 
of Habitat for Late-Successional and Old-Growth Forest Related Species within the Range 
of the Northern Spotted Owl. By Bmce Lippke 

O. Option 9 and the Northwest Pulp and Paper Industry. By Bill Crapser 

P. Draft Supplemental Environmental Impact Statement on Management of Habitat for Late- 
Successional and Old-Growth Forest Related Spe<iies within the Range of the Northern 
Spotted Owl, A Biological and Economic Critique. By American Forest & Paper 
Association 

Q. Considering Global Implications of Option 9: A Regional Perspective Ignores Substantial 
Social and Environmental Costs. By Con Schallau, Ph.D. 

R, Northwest Economic Adjustment Initiative: A Critique by Con Schallau, Ph.D. 



80 



An Analysis of a Plan to Maintain 
Old-Growth Forest Ecosystems 



By 



Thomas M. Bonnicksen, Ph.D. 

Professor 

Department of Forest Science 

Horticulture/Forest Science Building 

Texas A&M University 

CoUege Station, Texas 77843-2135 

Tel. (409) 845-6098 

Fax (409) 845-6049 



A Report to the 

American Forest & Paper Association 

Washington, D.C. 

September 27, 1993 



81 



TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY iii 

INTRODUCTION 1 

THE MANAGEMENT PLAN 2 

The Goals 2 

The Process 3 

The Options 3 

The Plan 3 

Management Implications 4 

ANCIENT FORESTS AND OLD-GROWTH 4 

Old-Growth in Surface Fire Regimes 5 

Old-Growth in Massive Fire Regimes 8 

Management Implications 12 

OLD-GROWTH RESERVES 14 

Indians and Fire 1 5 

EflFects of Reserves in Surface Fire Regimes 1 6 

Effects of Reserves in Massive Fire Regimes 1 9 

Management Implications 23 

MANAGEMENT OPTIONS 24 

Long-Rotation Timber Harvest 24 

Managed Old-Growth Islands 24 

Floating Habitat Centers 25 

Sustainable Old-Growth 25 

Management Implications 28 

TABLES 

Table 1 . Estimated natural or prcsettiement old-growth forest 9 
and fire cycles, giant sequoia-mixed conifer forest. Kings Canyon 
National Paric, California. 

Table 2. Estimated natural or presettiement old-growth forest 1 1 
and fire cycles, western Oregon and Washingtoa 

Tables. Effects of errors in data on estimated area of natural or 13 

presettiement old-growth forest, western Oregon and 

Washington. 



82 



Page 



Tabfe4. Estimated natural or presettlement old-growth forest 17 

and fire cycles compared to current and future forest conditions, 
giant sequoia-mixed conifer forest. Kings Canyon National Park, 
California. 



HGURES 

Figure 1 . Physiographic regions within the range of the northern 6 

spotted owl. 

Figure 2. Estimated stand age distribution within reserves 22 

compared to a 400-year fire cycle, western Oregon and 

Washington. 

Figures. Sustainable Old-Growth option: harvesting schedule ' 27 

and stand age class distribution that mimics a 400-year fire cycle, 
western Oregon and Washington. 

LITERATURE CITED 29 



t '■,•; 



83 



EXECUTIVE SUMMARY 



The Clinton Administration commissioned the Forest Ecosystem Managem-" t Assessment 
Team (FEMAT) to formulate and assess an array of management options to help resolve 
the northern spotted owl issue in the Pacific Northwest (FEMAT 1993). The bias against 
timber management apparent within the FEMAT report deprived the Administration of 
information on many effective options. Consequently, the Administration was persuaded 
to adopt a preservation-oriented management plan based on Option 9 in the FHvlAT 
(1993) assessment. 

My analysis focuses on the assumptions and conclusions used to support the section of the 
plan that involves maintaining late-successional forest ecosystems on Federal lands. 
Three questions are addressed in my analysis. Separate sections are used to answer these 
questions. The analysis begins with an examination of the management plan to maintain 
late-successional forest ecosystems adopted from the FEMAT (1993) assessment. 



The Management Plan 

The FEMAT (1993) assessment states that the team considered all management plans for 
northern spotted owls and forest ecosystems from 1970 to the present. They limited their 
assessment to forty-eight of these plans that they said represented the fiill range of 
options. They disqualified six additional options. The process used to reduce the range of 
options remains mysterious. Ten options survived this process of elimination. 

The selection of an assessment team was imfortunate. Generally, the same scientists 
played a key role in the FEMAT (1993) assessment that authored previous studies on 
managing old-growth to maintain the viability of the northern spotted owl (Johnson et al. 
1991; Thomas et al. 1990, 1993). Using the same team to address the same question 
produced the same answer. As a result, the FEMAT (1993) assessment presents ten 
options that actually constitute variations of one previously recommend^ alternative — 
setting aside protected reserves. These reserves are divided into several categories. 

The Clinton and Gore (1993) management plan incorporates Option 9 from the FEMAT 
(1993) assessment. This option consists of 7.05 million acres of Late-Successional 
Reserves (of which only 37 percent contain medium and large conifer trees); 2.23 million 
acres of Riparian Reserves; no Managed Late-Successional Reserves; 1.49 million acres 
of Adaptive Management Areas; 4.85 million acres of Matrix (FEMAT 1993, Table III- 
5). The later two categories allow restricted timber harvesting. 

The management plan focuses on preservation not management. Of special concern is the 
lack of a convincing rationale in the plan to justify the amount of old-growth set aside in 
reserves. Even more troubling is the lack of a plan to maintain this old-growth in the 
future. Maintaining old-growth in the future requires understanding ancient or 
presettlement forests, and the amount of old-growth they supported. 



m 



84 



Ancient Forests and Old-Growth 



This section addresses the first question. Is the assumption correct that the age class 
distribution of the natural or presettlement forest included a large component of old- 
growth? Answering this question requires understanding the structure and dynamics of 
ancient or presettlement forests. 

Although many people think ancient forests and old-growth are the same, they are actually 
two separate things. Old-growth represents a late stage in the development of a patch of 
forest that is characterized by large old trees. Ancient forests are called ancient because 
they are old, not because they contain old-growth. Ancient forests did contain patches of 
old-growth, but they also included patches with different age trees and other vegetation. 
Therefore, an ancient forest is more than old-growth. Differences in the amount of old- 
growth in ancient forests depended primaiily on the fi'equency, intensity and size of fires. 

The proposed management plan affects forests that developed under two fire regimes: 
infi-equent and massive (high-intensity) fires that killed most of the trees; fi-equent and 
small surface (low-intensity) fires that thinned the forest and killed few large trees. 
Although the distinctions between these fire regimes are great, the natural or presettlement 
forests they produced shared a common attribute - they both formed a mosaic pattern on 
the landscape. The main difference between these forests is that the size of the patches 
within the mosaic are large in the massive fire regime and small in the surface fire regime. 



Conclusions 

1. The FEMAT (1993) assessment concludes that "60 to 70 percent of the forest area of 
the region was typically dominated by late-successional and old-growth forests." This 
statement is misleading because it includes 80 to 100 year old trees, which are not 
usually called old-growth. The percentages presented in the assessment also cover 
regions dominated by two distinct fire regimes which produce major differences in the 
proportion of old-growth represented under presettlement conditions. 

2. Old-growth occupied a small fi-action (18% to 21%) of the natural or presettlement 
forest in areas dominated by a surface fire regime. Therefore, less than one quarter of 
the reserved area within these forests should be occupied by old-growth at any one 
time. In contrast, old-growth occupied a relatively large proportion (56% to 66%) of 
the presettlement forest in areas dominated by a massive fire regime. 

3. The FEMAT (1993) assessment concludes that "the regional natural fire rotation was 
about 250 years." This conclusion is probably wrong and, more importantly, of little 
scientific value. The fire cycle must be based on the dominant fire regime within a 
re^on. The fire cycle in the surface fire region probably lies between 1 1 5 years and 
129 years. The average fire cycle in the massive fire region is about 400 years. 



85 



Old-Growth Forest Reserves 

This section addresses the second question. Is the conclusion correct that a series of 
large (thousands of acres) reserves is needed to establish and maintain healthy and 
functioning old-growth forests? This question can only be answered by understanding the 
underiying ideology that leads to the idea that reserves are essential. Of particular 
importance is the decisive role humans played in the development of ancient forests. 

Unfortunately, the FEMAT (1993) assessment appears to accept a typical preservationist 
bias against aboriginal people. To admit that Indians played a decisive ecological role 
opens the door to admitting that humans are natural. Such a conclusion obviously 
jeopardizes the idea that old-growth can only be preserved in dehumanized reserves. 
Nevertheless, the world-wide literature is replete with studies documenting the importance 
of aboriginal burning. At the time of European settlement, Indians were the dominant 
force responsible for creating and maintaining ancient forests in most surface fire and 
massive fire regions of North America. 



Conclusions 

1. A series of large (thousands of acres) reserves is not needed to establish and maintain 
healthy and fiinctioning old-growth forests. The removal of Indians, the suppression of 
fires and the locking up of forests within national park and wilderness areas has ah-eady 
led to dramatic ecological changes. The establishment of a network of reserves will 
spread these changes and produce imsustainable, artificial forests unlike any that 
existed in the past. 

2. In the surface fire dominated region, fire cycles will shift toward longer intervals and 
larger fires than would be natural under presettlement conditions. Therefore, threats to 
himian life and property from wildfires also will increase. The dominant trees will also 
shift from shade intolerant species like ponderosa pine and to shade tolerant species like 
fir. Such a large-scale replacement of species did not occur in ancient forests without 
major climatic changes. 

3. Ancient or presettlement forests in surface fire dominated regions were diverse, 
dynamic, fiiU of wildlife, beautifiil and safe to live in because fires were small. Today's 
forests are becoming thicker and more sterile as each day passes because of the lack of 
Indian and lightning fires. Locking up the remaining Federal forests available for 
timber harvesting within protected reserves will compound the problem already faced in 
national park and wilderness areas. No one has the will to manage these reserves and 
Congress will not pay the cost. It may even be impossible to manage these reserves in 
the fiiture as natural forests because they will be dominated by large old trees that were 
allowed to grow in the absence of fire. 

4. In the massive fire dominated region small western hemlock trees will gradually replace 
the huge Douglas-fir trees that people associate with ancient forests. Unlike natural or 
presettlement forests, today succession is moving all patches in the forest mosaic 



86 



toward the elimination of Douglas-fir because of the removal of Indian burning and fire 
suppression. Douglas-fir cannot regenerate without fire or other large-scale 
disturbances. Furthermore, as the patches in the mosaic converge the fire cycle will 
increase. The establishment of additional reserves will expand the Douglas-fir 
replacement problem. 

5. Placing reserves in massive fire dominated regions creates monumental management 
problems. Under natural or presettlement conditions, the forest mosaic consisted of 
huge adjacent patches that spread across the entire region. Some of these patches were 
larger than the area within the proposed reserves. The reserves represent fragments of 
this presettlement mosaic that are isolated from one another. These isolated Segments 
can never fimction as an interconnected, natural and self-sustaining forest. 

6. Instead of active management, the FEMAT (1993) assessment advocates passive 
management. It reconmiends protecting reserves while aciaiowledging that chance 
disturbances such as fire will destroy them — an apparent abdication of responsibihty 
for the end result. Partial control of unplanned disturbances will not maintain old- 
growth forests. A series of reserves creates a series of dilemmas that cannot be 
resolved without active management. 



Management Options 



This section addresses the third question. Are there other options involving forest 
management (including commercial harvest) that would maintain healthy and 
functioning old-growth forests? This question is answered by presenting several 
management options that involve timber harvesting. These options were either ignored or 
rejected in the FEMAT (1993) assessment. Nevertheless, any of these options would be 
superior to protected reserves as a method for maintaining healthy old-growth forests. 



Conclusions 

1. There are at least four distinct management options that should be considered for 
restoring and maintaining old-growth forests. These options include 1) the Long- 
Rotation Timber Harvest option; 2) the Managed Old-Growth Island option; 3) the 

. Floating Habitat Center option; 4) the Sustainable Old-Growth option. Any of these 
four options would be more successfijl at sustaining old-growth than the option 
adopted from the FEMAT ( 1 993 ) assessment. 

2. A limited number of reserves are needed for scientific purposes, but reserves are not 
effective as a management technique for sustaining old-growth. The four management 
options presented in this section would create a continuous supply of old-growth. The 
Sustainable Old-Growth option has the added advantage of approximating the natural 
or presettlement forest mosaic. These management options are also economically 
sustainable. In contrast, the reserves proposed in the FEMAT (1993) assessment 
would create costly, unnatural old-growth forests that cannot be sustained. 

vi 

(The complete report is held in the committee files.) 



87 



WRITTEN STATEMENT FOR THE RECORD 
OF 

DR. THOMAS M. BONNICKSEN 

PROFESSOR 

DEPARTMENT OF FOREST SCIENCE 

TEXAS A&M UNIVERSITY 

HEARING ON THE ADMINISTRATION'S 
FORESTRY PLAN FOR THE PACIFIC NORTHWEST 

BEFORE THE 

SPECIALTY CROPS AND NATURAL RESOURCES 

SUBCOMMITTEE 

OF THE 

AGRICULTURE COMMITTEE 

UNITED STATES HOUSE OF REPRESENTATIVES 

November 18, 1993 



INTRODUCTION 

My name is Dr. Thomas M. Bomiicksen. I am a forest ecologist and professor of forestry 
in the Department of Forest Science at Texas A&M University. 

I have conducted research on the restoration and management of ancient forests for more 
than twenty-three years. I am currently writing a book titled Restoring Ancient Forests. I 
am cofounder, and a former elected member of the Board of Directors, of the Society for 
Ecological Restoration, and I serve on the editorial board for their scientific journal -- 
Restoration Ecology . I am also a member of the Society of American Foresters. I have 
published over 60 scientific papers. 

My written statement begins with an executive summary. The summary is followed by a 
comprehensive analysis of the assumptions and conclusions contained in the section of the 
Administration's forestry plan for the Pacific Northwest that involves maintaining late- 
successional forest ecosystems. 



88 



EXECUTIVE SUMMARY 



The President commissioned the Forest Ecosystem Management Assessment Team 
(FEMAT) to formulate and assess an array of management options to help resolve the 
northern spotted owl issue in the Pacific Northwest (FEMAT 1993). The President 
should be commended for his efforts to resolve this diflRcult issue. Unfortunately, the bias 
against timber management apparent within the FEMAT report deprived the President of 
information on many effective options. Scientific flaws in the report also undermined the 
President's attempt to formulate an ecologically sound and effective plan. Consequently, 
the poor advice received by the President led to the adoption of a preservation-oriented 
management plan based on Option 9 in the FEMAT (1993) assessment. 

My analysis focuses on the assumptions and conclusions used to support the section of the 
President's plan that involves maintaining late-successional forest ecosystems on Federal 
lands. Three questions are addressed in my analysis. Separate sections are used to 
answer these questions. The analysis begins with an examination of the management plan 
to maintain late-successional forest ecosystems adopted from the FEMAT (1993) 
assessment. 



The Management Plan 

The FEMAT (1993) assessment states that the team considered all management plans for 
northern spotted owls and forest ecosystems from 1970 to the present. They limited their 
assessment to forty-eight of these plans that they said represented the fiall range of 
options. They disqualified six additional options. The process used to reduce the range of 
options remains mysterious. Ten options survived this process of elimination. 

The selection of an assessment team was unfortunate. Generally, the same scientists 
played a key role in the FEMAT (1993) assessment that authored previous studies on 
managing old-growth to maintain the viability of the northern spotted owl (Johnson et al. 
1991; Thomas et al. 1990, 1993). Using the same team to address the same question 
produced the same answer. As a result, the FEMAT (1993) assessment presents ten 
options that actually constitute variations of one previously recommended alternative ~ 
setting aside protected reserves. These reserves are divided into several categories. 

The President's plan (Clinton and Gore 1993) incorporates Option 9 from the FEMAT 
(1993) assessment. This option consists of 7.05 million acres of Late-Successional 
Reserves (of which only 37 percent contain medium and large conifer trees); 2.23 million 
acres of Riparian Reserves; no Managed Late-Successional Reserves; 1 .49 million acres 
of Adaptive Management Areas; 4.85 million acres of Matrix (FEMAT 1993, Table III- 
5). The later two categories allow restricted timber harvesting. 



89 



The management plan focuses on preservation not management. Of special concern is the 
lack of a convincing rationale in the plan to justify the amount of old-growth set aside in 
reserves. Even more troubling is the lack of a plan to maintain this old-growth in the 
future. Maintaining old-growth in the future requires understanding ancient or 
presettlement forests, and the amount of old-growth they supported. 



Ancient Forests and Old-Growth 

This section addresses the first question. Is the assumption correct that the age class 
distribution of the natural or presettlement forest included a large component of old- 
growth? Answering this question requires understanding the structure and dynamics of 
ancient or presettlement forests. 

Although many people think ancient forests and old-growth are the same, they are actually 
two separate things. Old-growth represents a late stage in the development of a patch of 
forest that is characterized by large old trees. Ancient forests are called ancient because 
they are old, not because they contain old-growth. Ancient forests did contain patches of 
old-growth, but they also included patches with different age trees and other vegetation. 
Therefore, an ancient forest is more than old-growth. Differences in the amount of old- 
growth in ancient forests depended primarily on the fi'equency, intensity and size of fires. 

The proposed management plan affects forests that developed under two fire regimes: 
infi'equent and massive (high-intensity) fires that killed most of the trees; frequent and 
small surface (low-intensity) fires that thiimed the forest and killed few large trees. 
Although the distinctions between these fire regimes are great, the natural or presettlement 
forests they produced shared a common attribute — they both formed a mosaic pattern on 
the landscape. The main difference between these forests is that the size of the patches 
within the mosaic are large in the massive fire regime and small in the surface fire regime. 



Conclusions 

1. Old-growth occupied a small fi^action (18% to 21%) of the natural or presettlement 
forest in areas dominated by a surface fire regime. Therefore, less than one quarter of 
the reserved area within these forests should be occupied by old-growth at any one 
time. In contrast, old-growth occupied a relatively large proportion (56% to 66%) of 
the presettlement forest in areas dominated by a massive fire regime. 

2. The FEMAT (1993) assessment concludes that "the regional natural fire rotation was 
about 250 years." This conclusion is probably wrong and, more importantly, of little 
scientific value. The fire cycle must be based on the dominant fire regime within a 
region. The fire cycle in the surface fire region probably lies between 1 1 5 years and 
129 years. The average fire cycle in the massive fire region is about 400 years. 



u 



90 



3. The FEMAT (1993) assessment concludes that "60 to 70 percent of the forest area of 
the region was typically dominated by late-successional and old-growth forests." This 
statement is misleading because it includes 80 to 100 year old trees, which are not 
usually called old-growth. The percentages presented in the assessment also cover 
regions dominated by two distinct fire regimes which produce major differences in the 
proportion of old-growth represented under presettlement conditions. Old-growth 
covered only 18 to 21 percent of the presettlement forest in the surface fire region. 
Old-growth covered between 56 and 66 percent of the presettlement forest in the 
massive fire region. 



Old-Growth Forest Reserves 

This section addresses the second question. Is the conclusion correct that a series oj^ 
large (thousands of acres) reserves is needed to establish and maintain healthy and 
functioning old-growth forests? This question can only be answered by understanding the 
underlying ideology that leads to the idea that reserves are essential. Of particular •• ' 

importance is the decisive role humans played in the development of ancient forests. 

Unfortunately, the FEMAT (1993) assessment appears to accept a typical preservationist 
bias against aboriginal people. To admit that Indians played a decisive ecological role 
opens the door to admitting that humans are natural. Such a conclusion obviously 
jeopardizes the idea that old-growth can only be preserved in dehumanized reserves. 
Nevertheless, the world-wide literature is replete with studies documenting the importance 
of aboriginal burning. At the time of European settlement, Indians were the dominant 
force responsible for creating and maintaining ancient forests in most surface fire and 
massive fire regions of North America. 



Conclusions 

1. A series of large (thousands of acres) reserves is not needed to establish and maintain 
healthy and functioning old-growth forests. The removal of Indians, the suppression of 
fires and the locking up of forests within national park and wilderness areas has already 
led to dramatic ecolo^cal changes. The establishment of a network of reserves will 
spread these changes and produce unsustainable, artificial forests unlike any that 
existed in the past. 

2. In the surface fire dominated region, fire cycles will shift toward longer intervals and 
larger fires than would be natural under presettlement conditions. Therefore, threats to 
human life and property from wildfires also will increase. The dominant trees will also 
shift from shade intolerant species like ponderosa pine and to shade tolerant species like 
fir. Such a large-scale replacement of species did not occur in ancient forests without 
major climatic changes. 



ui 



91 



3. Ancient or presettlement forests in surface fire dominated regions were diverse, 
dynamic, full of wildlife, beautiful and safe to live in because fires were small. Today's 
forests are becoming thicker and more sterile as each day passes because of the lack of 
Indian and lightning fires. Locking up the remaining Federal forests available for 
timber harvesting within protected reserves will compound the problem already faced in 
national park and wilderness areas. No one has the will to manage these reserves and 
Congress will not pay the cost. It may even be impossible to manage these reserves in 
the fiature as natural forests because they will be dominated by large old trees that were 
allowed to grow in the absence of fire. 

4. In the massive fire dominated region small western hemlock trees will gradually replace 
the huge Douglas-fir trees that people associate with ancient forests. Unlike natural or 
presettlement forests, today succession is moving all patches in the forest mosaic 
toward the elimination of Douglas-fir because of the removal of Indian burning and fire 
suppression. Douglas-fir cannot regenerate without fire or other large-scale 
disturbances. Furthermore, as the patches in the mosaic converge the fire cycle will 
increase. The establishment of additional reserves will expand the Douglas-fir 
replacement problem. 

5. Placing reserves in massive fire dominated regions creates monumental management 
problems. Under natural or presettlement conditions, the forest mosaic consisted of 
huge adjacent patches that spread across the entire region. Some of these patches were 
larger than the area within the proposed reserves. The reserves represent fragments of 
this presettlement mosaic that are isolated fi-om one another. These isolated fragments 
can never function as an interconnected, natural and self-sustaining forest. 

6. Instead of active management, the FEMAT (1993) assessment advocates passive 
management. It recommends protecting reserves while acknowledging that chance 
disturbances such as fire will destroy them — an apparent abdication of responsibility 
for the end result. Partial control of unplanned disturbances will not maintain old- 
growth forests. A series of reserves creates a series of dilemmas that cannot be 
resolved without active management. 



Management Options 

This section addresses the third question. Are there other options involving forest 
management (including commercial harvest) that would maintain healthy and 
functioning old-growth forests? This question is answered by presenting several 
management options that involve timber harvesting. These options were either ignored or 
rejected in the FEMAT (1993) assessment. Nevertheless, any of these options would be 
superior to protected reserves as a method for maintaining healthy old-growth forests. 



92 



Conclusions 



There are at least four distinct management options that should be considered for 
restoring and maintaining old-growth forests. These options include 1) the Long- 
Rotation Timber Harvest option; 2) the Managed Old-Growth Island option; 3) the 
Floating Habitat Center option; 4) the Sustainable Old-Growth option. Any of these 
four options would be more successful at sustaining old-growth than the option 
adopted from the FEMAT (1993) assessment. 

A limited number of reserves are needed for scientific purposes, but reserves are not 
efiFective as a management technique for sustaining old-growth. The four management 
options presented in this section would create a continuous supply of old-growth. The 
Sustainable Old-Growth option has the added advantage of approximating the natural 
or presettlement forest mosaic. These management options are also economically 
sustainable. In contrast, the reserves proposed in the FEMAT (1993) assessment 
would create costly, unnatural old-growth forests that cannot be sustained. 



m 



An Analysis of the President's 
Pacific Northwest Forest Plan 

By 

Thomas M. Bonnicksen, Ph.D. 

Professor of Forest Science 

Texas A&M University 

November 18, 1993 



INTRODUCTION 

The President commissioned the Forest Ecosystem Management Assessment Team 
(FEMAT) to formulate and assess an array of management options to help resolve the 
northern spotted owl issue in the Pacific Northwest (FEMAT 1993). The President 
should be commended for his efforts to resolve this diflBcult issue. Unfortunately, the bias 
against timber management apparent within the FEMAT report deprived the President of 
information on many efifective options. Scientific flaws in the report also undermined the 
President's attempt to formulate an ecologically sound and effective plan. Consequently, 
the poor advice received by the President led to the adoption of a preservation-oriented 
management plan based on Option 9 in the FEMAT (1993) assessment. 

My analysis focuses on the assumptions and conclusions used to support the section of the 
President's plan that involves maintaining late-successional forest ecosystems on Federal 
lands. Three questions are addressed as part of the analysis: 

1 . Is the assumption correct that the age class distribution of the natural or presettlement 
forest included a large component of old-growth? 

2. Is the conclusion correct that a series of large (thousands of acres) reserves is needed 
to establish and maintain healthy and fianctioning old-growth forests? 

3. Are there other options involving forest management (including commercial harvest) 
that would maintain healthy and functioning old-growth forests? 

My analysis begins with an examination of the management plan to maintain late- 
successional forest ecosystems adopted fi-om the FEMAT (1993) assessment. The next 
section compares the objectives in the plan to the structure and dynamics of ancient 
forests. The following section evaluates the efifectiveness of reserves as a method for 
maintaining old-growth forests. Finally, several management options are presented for 
maintaining old-growth forests. 



94 



THE MANAGEMENT PLAN 



The Goals 



The FEMAT (1993) assessment describes many issues that should be resolved, such as 
threats to the northern spotted owl, erosion and dwindling amounts of old-growth. 
Therefore, the goals given to the assessment team focus on 1) maintaining and/or restoring 
habitat for the northern spotted owl, marbled murrelet, anadramous and other fish, and 
other species associated with old-growth forest conditions, and 2) maintaining and/or 
creating old-growth forest ecosystems. My analysis concentrates on the second goal. 



The Process 

The FEMAT (1993) assessment states that the team considered all management plans for 
northern spotted owls and forest ecosystems from 1970 to the present. They limited their 
assessment to forty-eight of these plans that they said represented the full range of 
options. They disqualified six additional options. The options were reduced in number 
based on five criteria, such as viability of the northern spotted owl, that were evaluated 
with one rating scale that extended from low to high. Ten options survived this process of 
elimination. 

The process used to reduce the range of options remains mysterious. Little information 
exists in the assessment to describe each option or to document the rationale for its 
elimination. The FEMAT (1993) assessment even states that members of the team were 
only given "brief descriptions of the options." A matter of such importance as the 
management of millions of acres of land and the livelihood of thousands of people 
deserves a more thoughtful exploration of options. My analysis shows that this process 
eliminated several efifective options. 

The selection of an assessment team was unfortunate. Generally, the same scientists 
played a key role in the FEMAT (1993) assessment that authored previous studies on 
managing old-growth to maintain the viability of the northern spotted owl (Johnson et al. 
1991; Thomas et al. 1990, 1993). Using the same team to address the same question 
produced the same answer. As a result, the FEMAT (1993) assessment presents ten 
options that actually constitute variations of one previously recommended ahemative ~ 
the ISC strategy of setting aside protected reserves within a matrix of land governed by 
restrictive timber harvesting regulations. The options only differ in the amount of land 
allocated to reserves and other uses. The assessment rejects other options involving 
timber harvesting as a tool to maintain a constant supply of high quality old-growth. A 
new team may have given more careful consideration to all management options. 



95 



The Options 

All ten FEMAT (1993) options consist of mixtures of various types of reserves and 
restricted timber management areas. For example, Late-Successional Reserves are 
supposed to retain forests in "their natural condition" (FEMAT 1993). The area allocated 
to reserves varies within the ten options. Depending upon the option, however, they 
consist of between 47 and 58 percent young forest, including plantations on cutover land. 
Therefore, only 42 to 53 percent of the area within reserves actually consist of late- 
successional forest (FEMAT 1993). The amount of old-growth forest (> 200 years old) 
covers even less area since late-successional is defined by FEMAT (1993) as forests older 
than 80 years. As a result, most options permit silvicultural treatments in young stands so 
long as they "attain or accelerate development of late-successional conditions." Such 
treatments are unlikely to occur in many areas because of severe restrictions on road 
construction. 

Four options (but not the option selected) include a small area of Managed Late- 
Successional Reserves in which "silvicultural experiments" can be conducted "to produce 
stands that are similar in structure to existing old stands." The assessment team made it 
clear, however, that they doubt that these managed stands will ever duplicate existing old 
stands. No scientific information exists in the FEMAT (1993) assessment to verify or 
substantiate the assertion that old-growth cannot be created. 

Riparian Reserves augment Late-Successional Reserves in all options. These reserves 
serve as buffers along perennial and intermittent streams and wetlands. The area allocated 
to Riparian Reserves varies within the ten options. The remainder of the land within the 
options is allocated to restricted forms of timber management in Adaptive Management 
Areas and Matrix Areas. Adaptive Management Areas include private land. Even these 
areas still have requirements that favor late-successional forests and old-growth. For 
example, the FEMAT (1993) assessment states that "Silvicultural systems for stands in the 
Matrix should provide for retention of old-growth ecosystem components." Adaptive 
Management Areas should create and maintain "a variety of forest structural conditions 
including late-successional forest conditions." 



The Plan 

The President's plan (Clinton and Gore 1993) incorporates Option 9 fi-om the FEMAT 
(1993) assessment. This option consists of 7.05 million acres of Late-Successional 
Reserves (of which only 37 percent contain medium and large conifer trees); 2.23 miUion 
acres of Riparian Reserves; no Managed Late-Successional Reserves; 1.49 million acres 
of Adaptive Management Areas; 4.85 million acres of Matrix (FEMAT 1993, Table III- 
5). The later two categories allow restricted timber harvesting. 



96 



Management Implications 

The proposed management plan focuses on preservation not management. Of special 
concern is the lack of a convincing rationale in the plan to justify the amount of old- 
growth set aside in reserves. Even more troubling is the lack of a plan to maintain this 
old-growth in the future. Thus, the management plan does not address the central 
questions of how much old-growth is wanted, why it is wanted, or how to keep it. 

One of the most important decisions to make before managing for old-growth is to 
determine how much you want. Of course, determining what you want also depends on 
what you can get and how much you can keep. For example, if you want to retain the 
existing old-growth on Federal lands then you also need to determine how much forest 
land is needed to regenerate that much old-growth in perpetuity. Thus, the total area set 
aside must include the old-growth and the area needed to reproduce it after the existing 
old-growth dies. On the other hand, if you want to convert all Federal forests to old- 
growth you have an unresolvable problem. There is no practical way to retain all Federal 
forests as old-growth. Natural or presettlement forests included various amounts of old- 
growth, but they were never composed completely of old-growth. The amount of old- 
growth present also varied by forest type. Maintaining old-growth in the future requires 
understanding ancient or presettlement forests, and the amount of old-growth they 
supported. 



ANCIENT FORESTS AND OLD-GROWTH 

This section addresses the first question. Is the assumption correct that the age class 
distribution of the natural or presettlement forest included a large component of old- 
growth? Answering this question requires understanding the structure and dynamics of 
ancient or presettlement forests. It is especially important to recognize the distinction 
between ancient forests that developed in regions dominated by fi^equent and small surface 
(low-intensity) fires and those that developed in regions dominated by infi-equent and 
massive (high-intensity) fires. 

Although many people think ancient forests and old-growth are the same, they are actually 
two separate things. Old-growth represents a late stage in the development of a patch of 
forest that is characterized by large old trees. Variations in the sizes and ages of trees, 
layers in the canopy, standing dead trees, fallen dead trees, and litter depends on the forest 
type. Thus, the definition used for an old-growth Douglas-fir/westem hemlock forest 
cannot be applied to old-growth mixed-conifer forests. As Hunter (1989) points out, 
"There is no generally accepted or universally applicable definition of old-growth." 

Ancient forests, on the other hand, are called ancient because they are old, not because 
they contain old-growth. Ancient forests did contain patches of old-growth, but they also 
included patches with different age classes of trees and other vegetation. Therefore, an 
ancient forest is more than old-growth. Again, depending upon the forest type, old- 
growth represented a small or a large part of the ancient forest. Differences in the amount 



97 



of old-growth in ancient forests depended primarily on the frequency and size of 
disturbances, such as fire, that created openings where young trees could grow. 

The proposed management plan affects forests that developed under two broad fire 
regimes: infrequent and massive fires that killed most of the trees; frequent and small 
surface fires that thinned the forest and killed few large trees. Massive fires were 
characteristic of forests in western Oregon and Washington. Surface fires were 
characteristic of the eastern Oregon and Washington Cascades, much of southwestern 
Oregon and northwestern Cahfomia, and the CaUfomia Cascades (Figure 1). 

Although the distinctions between these fire regimes are great, the natural or presettlement 
forests they produced actually shared a common and important attribute ~ they both 
formed a mosaic pattern on the landscape. The main difference between these forests is 
that the size of the patches within the mosaic are large in the massive fire regime and small 
in the surface fire regime. Insect infestations, disease, blowdowns and other disturbances 
also contributed to this mosaic pattern. Patches in the mosaic continually changed in 
relation to each other in both space and time as the trees grew older and were replaced by 
younger trees (Bonnicksen and Stone 1982b). We can visualize this process with the aid 
of a checkerboard. 

The checkerboard forms a mosaic of squares, and each square can be considered to be 
occupied by a group of trees that are similar in size and roughly the same age. However, 
the average age of the trees differs on each square. Seedlings cover one square, large old 
trees cover another and still another is covered by pole-size trees. As time passes, the 
large old trees are killed and are replaced by seedlings, and the pole-size trees become 
large old trees. As a resuU, the old trees appear to float around the mosaic over time. 
Fire was the primary force that drove this process by clearing squares on the 
checkerboard. Squares on the checkerboard would be large in a massive fire regime and 
small in a surface fire regime. 



Old-Growth in Surface Fire Regimes 

Surface fires dominated four of the nine physiognomic regions recognized in the FEMAT 
(1993) assessment (Figure 1). First, the east slope of the Cascades Range in Washington 
and Oregon form a region where mixed-conifer and ponderosa pine forests dominate low 
and middle elevations, and true fir forests dominate high elevations. Second, the Klamath 
region covers much of southwestern Oregon and northwestern California. Mixed-conifer 
and mixed-conifer/hardwood forests dominate much of this region. Third, the California 
Coast Range forms another region where redwood dominates coastal areas and a mixture 
of Douglas-fir and hardwoods dominate inland areas. Finally, the California Cascades 
form the fourth region, which is dominated by mixed-conifer and ponderosa pine forests. 
Most of the natural or presettlement forests in these four regions were subjected to 
frequent, low-intensity surface fires (Kilgore 1985) that produced a mosaic of small, 
relatively even-aged patches of trees (Bonnicksen and Stone 1981, 1982b). 



98 



Figure 1 

Physiographic Regions Within the Range of the 
Northern Spotted Owl 
(FEMAT1993) 



Easton Washington Cascades 
Olympic Peninsula 
Western Wadiingtco Lowlands 
Western Washington Cascades 



Oregon Coast Range 
Willaroette Valley 
Eastern Oregon Cascades 
Western Oregon Cascades 
Oregon Klamath 

CBlifomla Cascades 
California Klamath 
Califotnia Coast 




dd 



No one has reconstructed the relative proportions of different even-aged patches of trees 
that existed in these regions during presettlement times. Fortunately, reconstructions exist 
for mixed-conifer forests in the southern Sierra Nevada mountains. These forests were 
also subjected to frequent, low-intensity surface fires that produced a mosaic pattern 
similar to other forests in these regions (Martin et al. 1974). In addition, the Sierra mixed- 
conifer forest includes many of the same tree species. Therefore, presettlement Sierra 
mixed-conifer forests can serve as a model for determining the condition of ancient forests 
in surface fire regions covered by the FEMAT (1993) assessment. 

The ancient mixed-conifer forests of the Sierra Nevada formed a complex and dynamic 
mosaic of plant and animal communities. Early descriptions portray the ancient forest as a 
mosaic of even-aged groups of trees ~ some old and some young ~ vwth openings 
carpeted with wildflowers and patches of shrubs. Dr. Edward C. Stone (University of 
California-Berkeley) and I conducted the first detailed studies to verify the group structure 
of ancient forests observed by early explorers (Bormicksen and Stone 1981). We used 
statistical pattern analysis techniques to show that these early observations were accurate. 
The even-aged groups or patches of trees in ancient forests were generally less than 0.2 
acres in size (Bormicksen and Stone 1981). Means (1981) found a similar patch size for 
dry Douglas-fir forests in Oregon, and Cooper (1960, 1961) produced similar results for 
ponderosa pine forests in Arizona. 

A persistent myth about ancient forests is that they were composed mostly of large old 
trees. Old trees were present, but young and middle-aged trees, shrubs and wildflowers 
also were a prominent part of the ancient forest mosaic. For example, our study of the 
Redwood Creek watershed in Kings Canyon National Park showed that patches of 
sapling-size trees covered 17 percent of the watershed when it was an ancient forest. 
Patches of pole-size trees covered 15.4 percent of the watershed, and 19 percent was 
covered by shrubs. Only 17.6 percent was covered by patches of mature trees when it was 
an ancient forest (Bormicksen and Stone 1982b). The remainder of the watershed 
consisted of seedlings, meadows, gaps and rocks. Clearly, setting aside forests that are 
dominated by mature trees cannot be justified as preserving ancient forests. 

The ancient forest mosaic changed continuously. Trees in each group in the mosaic grew 
older, died and were replaced by other trees, shrubs or wildflowers. Lightning, fire, 
insects, disease and other forces accelerated the process by thinning or destroying patches 
of trees. The most powerfijl force was fire. Fires were frequent in ancient mixed-conifer 
forests of the Sierra Nevada. Studies of fire scars in tree rings show that one or two fires 
burned each decade in some places, but fire free intervals could last thirty years. Since 
fires were frequent enough to clean up most of the debris on the forest floor, they 
generally burned as surface fires. Large stand-replacing wildfires were extremely rare. 
However, ancient surface fires occasionally flared up and killed small patches of large 
trees (Bonnicksen 1993; Bonnicksen and Stone 1985, 1982b, 1981; Stephenson et al. 
1991). These hot spots opened gaps in the forest that provided opportunities for young 
trees to grow. Surface fires also weakened some patches of old trees and predisposed 
them to attack by insects and diseases. Thus, fire-created gaps served as the single most 
important force sustaining the mosaic structure of mixed-conifer forests. 



100 



The frequency of gap formation created by hot spots is also known as the fire cycle. The 
natural or presettlement fire cycle that maintained the ancient mixed-conifer forest mosaic 
can be computed using Van Wagner's (1978) equations. These equations require 
converting the size classes of trees to age classes. I made this conversion using age- 
diameter equations developed fi^om hundreds of trees within the Redwood Creek 
watershed. Old-growth was defined as trees > 200 years old. The equations were then 
applied to data gathered fi-om the entire 2042 hectare (5044 acre) Redwood Creek 
Watershed, and fi-om an intensively sampled 84 hectare (207 acre) area (the Control Area) 
within the watershed. The two areas produced similar results. 

As Table 1 shows, the percentage of the ancient mixed-conifer forest covered by old- 
growth varied between 17.6 and 21.2. The fire cycle varied between 115 and 129 years. 
Similar results will probably be produced for mixed-conifer and ponderosa pine forests in 
surface fire regions covered by the FEMAT (1993) assessment. Therefore, using natural 
or presettlement conditions as a guide, less than one quarter of the reserved area within 
these forests should be occupied by old-growth at any one time. 



Old-Growth in Massive Fire Regimes 

Massive fires dominated five of the nine physiognomic regions recognized in the FEMAT 
(1993) assessment (Figure 1). The regions include the Olympic Peninsula, the Western 
Washington Lowlands, the Western Washington and Oregon Cascades, the Oregon Coast 
Range and the Willamette Valley. Vegetation consists primarily of various mixtures of 
Douglas-fir, western hemlock, western red cedar. Pacific silver fir and Sitka spruce. 
Douglas-fir forests dominate most of the region. 

Most of the natural or presettlement forests in these five regions were subjected to 
infi-equent massive fires (Kilgore 1985) that produced a mosaic of large relatively even- 
aged patches. In the case of Douglas-fir, even-aged can mean trees of similar size but with 
a spread in age of 100 to 200 years (Franklin and Waring 1980). This is a small variance 
for trees that live 1,000 years or more (Oliver and Larson 1990). It also reflects the time 
it takes for trees to occupy huge burned over areas. For example, the patches in the 
mosaic could cover over 100 thousand acres (Franklin and Hemstrom 1981). The sizes of 
the burned patches, however, decrease at lower latitudes although they still remain large 
(Franklin and Hemstrom 1981). 

Since most of the forests in these regions grow in a relatively wet environment, massive 
fires usually occur during major droughts (Heinsebnan 1983). For example, Franklin and 
Hemstrom (1981) found that many Douglas-fir forests in widely separated locations 
developed from major fires that occurred about 500 years ago. In addition, these forests 
contained sufiBcient fiiel at all ages to carry a fire, so the frequency of massive fires cannot 
be attributed to fiiel increases between fire episodes (Franklin and Hemstrom 1981). 
Ignition sources also remained relatively constant. Therefore, the observed pattern of 
infrequent massive fires is best explained by periodic droughts that cover a wide area. 



101 



Table 1 



Estimated Natural or Presettlement Old Growth Forest and Fire Cycles 

Giant Sequoia-Mixed Conifer Forest 
Kings Canyon National Park, California 



Study Area 



Period 



Area of Old 
Growth > 

(%) 



Control Area^ Ancient Forest (1875) 21.2 
Watershed^ Ancient Forest (1890) 17.6 



Probability Fire Cycle 
of Burning^ (Years)^ 



.007763 
.008686 



129 
115 



• Old growth defined as trees 2 200 years old. All estimates computed using Van Wagner's (1978) age-class distribution and fire cycle 

equations. 
^ Sampling data for area of old growth from an 84 hectare study area in the Redwood Creek watershed. 
^ Sampling daU for area of old growth from the entire 2042 hectare Redwood Creek watershed. 
^ The value of p (the probability of fire in any one stand or the proportion of the whole forest that bums every year) computed as 

-lii(l-Z/(i)yx, where Zfix) is the cumulative frequency of all age classes up to and including age class x (the age of a mature trees). 
' The niunber of years requir^ to bum over an area equal to the whole area of the forest (computed as 1 /p). The fire cycle exceeds the 

fire return interval for all fires (about 20 years) betkuse most fires bum as surface fires. Therefore, the fire cycle is a rough measure of 

stand replacing fires. 



102 



The frequency of massive fires can be approximated using Van Wagner's (1978) fire cycle 
equations. The fire cycle is the number of years required to bum over an area equal to the 
whole area of a forest. During a single fire cycle some patches of trees in the forest 
mosaic may bum more thah once and others may not bum at all. These equations can also 
be used to compute the proportion of a forest mosaic covered by patches of trees above or 
below a certain age. The age-class distribution of a forest provides the minimum data 
needed for the equations. Therefore, Van Wagner's (1978) equations can be used to 
estimate both the fire cycle and the area covered by old-growth in presettlement times. 

There are three main studies that attempt to determine fire cycles and the proportion of 
old-growth in the presettlement forests of westem Oregon and Washington. Two of these 
studies are based on Van Wagner's (1978) equations. For example, Fahnestock and Agee 
(1983) used these equations to compute fire cycles in westem Washington, but they did 
not determine the area of presettlement old-growth. Booth (1991) used them to estimate 
acres of prelogging old-growth, but he did not estimate the proportion of the forest in old- 
growth. The third study conducted by Teensma et al. (1991) actually mapped forests by 
stand age class in 1850 to estimate the proportion of old-growth, but they did not 
compute fire cycles. In addition, their study underestimated the actual area of old-growth 
because they used a "recently bumed" category to determine the proportions. 
Nevertheless, all three studies provide usefiil information. Therefore, I used data from 
these three studies to develop equations based on Van Wagner's (1978) model. Then I 
used the equations to determine fire cycles and the area covered by old-growth forest 
(defined as trees > 200 years old) in westem Oregon and Washington during 
presettlement times. 

Table 2 presents the results of these computations for Douglas-fir and westem hemlock 
forests. The fire cycle in Douglas-fir forests varied between 233 years and 392 years. The 
fire cycle in westem hemlock forests varied between 349 years and 776 years. The 
proportion of the area covered by presettlement old-growth forest varied in the same way. 
Old-growth covered between 41.9 percent and 60.1 percent of the presettlement Douglas- 
fir forest. The range is higher for westem hemlock where old-growth covered between 
56.4 percent and 77.3 percent of the presettlement forest. Westem hemlock forests, 
however, covered only a small part of the region. 

Data from Teensma et al. (1991) cover both forest types. I used a proportion-weighted 
average to allocate the "recently bumed" area among age classes to obtain the area of old- 
growth. This method also carried the data back an additional 50 years to 1800. I used an 
area-weighted average to combine Booth's (1991) data for Douglas-fir and westem 
hemlock forests in both westem Oregon and westem Washington. Table 2 shows that the 
results of analyzing the adjusted data are nearly identical. The fire cycle is about 400 years 
and the proportion of presettlement old-growth is about 61 percent. Such agreement was 
unexpected since the two studies were not based on the same mix of data sources. 



10 



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104 



All three studies pointed to potential errors in determining age class distributions for the 
Van Wagner (1978) equations. As a result, I re-computed the proportion of presettlement 
forests covered by old-growth based on the assumption that these errors were at least 5 
percent. The results are shown in Table 3. Several conclusions can be made from my 
analysis. First, the proportion of presettlement Douglas-fir forests represented by old- 
growth could have been as low as 38.4 percent or as high as 64.7 percent. Second, the 
proportion of presettlement western hemlock forests represented by old-growth could 
have been as low as 5 1 .8 percent or as high as 82.4 percent. Combining these forest types 
for a regional estimate shows that the proportion of old-growth in presettlement forests 
probably varied between 56 percent and 66 percent. The regional fire cycle was probably 
about 400 years. . 



Management Implications 

The answer to the question posed at the beginning of this section is that old-growth 
occupied a small fraction (18% to 21%) of the natural or presettlement forest in areas 
dominated by a surface fire regime. In contrast, old-growth occupied a relatively large 
proportion (56% to 66%) of the natural or presettlement forest in areas dominated by a 
massive fire regime. 

The FEMAT (1993) assessment concludes that "the regional natural fire rotation was 
about 250 years." This conclusion is probably wrong and, more importantly, of little 
scientific value. The fire cycle must be based on the dominant fire regime within a region. 
My analysis shows that the average fire cycle in the surface fire region probably lies 
between 115 years and 129 years. The average fire cycle in the massive fire region is 
about 400 years. However, Douglas-fir forests would have fire cycles somewhat lower 
than the regional average. Western hemlock forests, which cover a small part of the 
region, would have fire cycles that are somewhat higher than the regional average. 

In addition, the FEMAT (1993) assessment concludes that "60 to 70 percent of the forest 
area of the region was typically dominated by late-successional and old-growth forests." 
This statement is misleading because it includes 80 to 100 year old trees, which are not 
usually called old-growth. The percentages presented in the assessment also cover regions 
dominated by two distinct fire regimes which produce major differences in the proportion 
of old-growth represented under presettlement conditions. My analysis shows that old- 
growth covered only 18 to 21 percent of the presettlement forest in the surface fire region. 
Old-growth covered between 56 and 66 percent of the presettlement forest in the massive 
fire region. Like the fire cycles, however, Douglas-fir forests would have proportions 
somewhat lower than the regional average and western hemlock forests would have 
proportions that are somewhat higher than the regional average. 



12 



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106 



OLD-GROWTH FOREST RESERVES 

This section addresses the second question. Is the conclusion correct that a series of 
large (thousands of acres) reserves is needed to establish and maintain healthy and 
functioning old-growth forests? This question can only be answered by understanding the 
underlying ideology that leads to the idea that reserves are essential. Of particular 
importance is the decisive role humans played in the development of ancient forests. The 
removal of Indians, the suppression of fires and the locking up of forests within national 
park and wilderness areas has already led to dramatic ecological changes. The 
establishment of a network of reserves will spread these changes and produce artificial, 
unsustainable forests unlike any that existed in the past. Again, these changes can best be 
understood by distinguishing between ancient forests that developed in regions dominated 
by frequent surface fires and those that developed in regions dominated by infrequent 
massive fires. 

The FEMAT (1993) assessment reflects a dangerous myth. Flawed reasoning and 
ideology have led some people to believe that humans are not part of nature. Thus, the 
FEMAT (1993) assessment contains many references to "natural" that either implicitly or 
explicitly exclude humans. According to this belief, humans are inherently destructive and 
natural forests can only be found and maintained in dehumanized landscapes. As Franklin 
(1993) states, "A comprehensive strategy for the conservation of biodiversity is going to 
require reserves ~ areas where human disruption is minimized." 

Such erroneous, misanthropic beliefs form the foundation of the proposed plan to set aside 
76 percent of all Federal lands within a three state area as reserves (FEMAT 1993, Tables 
IV-14, 15 and 16). The plan more than doubles the amount of land already protected 
fi-om humans within national park and wilderness areas. The plan also imposes rigid 
restrictions on timber management within the remaining 24 percent of Federal lands in the 
area. 

Symptomatic of a misanthropic bias is the statement in the FEMAT (1993) assessment 
concerning the management of reserves that "Distrust of agency motives can be expected 
to be high." In short, the plan is based on the assumption that reserves and severe 
restrictions are needed to protect forests fi'om people. As a result, the plan will eliminate 
most timber harvesting on federal lands, with devastating consequences to people living in 
local communities. It will also fail to achieve its primary goal of ensuring the fiiture of 
old-growth forests. 

Ironically, excluding people fi'om nature is an unnatural change that will ukimately destroy 
the forests that the authors of the FEMAT (1993) assessment wish to preserve. Humans 
have played a natural and decisive role in guiding evolutionary change for at least 2.6 
million years. The tools and fire humans used to help shape and maintain plant and animal 
communities are an integral part of the forces of nature. Erecting barriers that exclude 
people removes this natural force and begins chains of events that create new, artificial and 
unsustainable ecological communities. Locking up forests within dehumanized reserves 
radically alters nature to calm the fears and satisfy the esthetic and ideological tastes of 
one segment of society. 

14 



107 



Indians and Fire 



Unfortunately, the FEMAT (1993) assessment appears to accept a typical preservationist 
bias against aboriginal people. To admit that Indians played a decisive ecological role 
opens the door to admitting that humans are natural. Such a conclusion obviously 
jeopardizes the idea that old-growth can only be preserved in dehumanized reserves. 
Nevertheless, the world-wide literature is replete with studies documenting the importance 
of aboriginal burning. - 

Many people erroneously think that lightning was the principal source of fire in ancient 
forests. However, scientific evidence shows that Indian bunung played an important role 
in creating and maintaining ancient mixed-conifer forests and other forests throughout 
North America. For example, Kilgore and Taylor (1979) found that the fi-equency of fires 
declined dramatically after 1875 in the Redwood Creek watershed in Kings Canyon 
National Park. This is about the time that the local Monache Indian culture disappeared. 
This decline in fires also occurred long before the initiation of an effective fire suppression 
program. Since the number of lightning fires remained constant before and after 1875, 
they concluded that "aboriginal ignitions augmented the lightning caused ignitions to give 
us the frequencies we have found." There is no doubt that human hands helped to fashion 
the ancient forests of the Sierra Nevada. 

Indians were intelligent and sophisticated managers of their environment. Indians burned 
mixed-conifer forests to regenerate and protect black oak trees that produced the acorns 
that were their principal source of food. They also used fire to flush game and to clear 
underbrush that could hide their enemies. Barrett and Amo (1982), Gruell (1983), Lewis 
(1982, 1983), Stewart (1954) and many others have documented the importance of Indian 
burning and numerous ways they used fire. As Lewis (1983) stated "Asking a hunter his 
reason for burning is analogous to asking a farmer why he plows." The role of Indians as 
a natural force in the ancient forests of North America may go back 10,000 years or 
longer. Over these many thousands of years of extensive Indian management the ancient 
forest gradually evolved into the condition that was described and admired by European 
explorers. 

At the time of European settlement, Indians were the dominant force responsible for 
creating and maintaining ancient forests in most surface fire and massive fire regimes. 
Indian burning in the Pacific Northwest is well documented and several additional studies 
are underway (Teensma, personal communication; Boyd 1986; Johannessen et al. 1970; 
Lavender 1972; Loy 1976). For example, in 1826, David Douglas (after whom the 
Douglas-fir was named) recorded extensive burned areas between Fort Vancouver and the 
Umpqua River. He was told that the natives burned to make it easier to hunt deer and to 
find wild honey and grasshoppers (Pyne 1982). The dominant role of Indian burning also 
was inadvertently documented by Agee and Flewelling (1983) when they failed to fit a 
climate-based fire occurrence model to the Coast Range. Their model underestimated 
historical fires, which left only Indian burning as the remaining source of fire. This study 
parallels the findings of Kilgore and Taylor (1979) for mixed-conifer forests. 



15 



108 



Effects of Reserves in Surface Fire Regimes 

Again, the presettlement Sierra mixed-conifer forests can serve as a dependable model for 
determining the condition of ancient mixed-conifer and ponderosa pine forests in surface 
fire regions covered by the FEMAT (1993) assessment. The role of Indians as a natural 
force in the Sierras started at least 4,500 years ago, and probably much earlier. Indian 
burning affected almost all of the Sierra Nevada. Unfortunately, eliminating Indians 
created a shock wave that began the dramatic deterioration of ancient forests throughout 
the Sierra Nevada. 

Ancient forests of the Sierra Nevada have undergone pronounced changes since they were 
first seen by European explorers. The elimination of Indian burning and the suppression of 
lightning fires caused these changes. Large quantities of debris have accumulated on 
forest floors and many forests are choked with thickets of understory trees. Thus, 
protected forests no longer represent their ancient appearance, and fire hazards are now 
extreme. In no other area are the changes in ancient forests more dramatically displayed 
than within the mixed-conifer forests of Sierra Nevada national parks. 

Many scientists have documented the deterioration of ancient forests using old 
photographs and observations. Dr. Stone and I added to this knowledge by comparing 
our reconstruction of ancient forests with the same forests as they exist today (Bonnicksen 
and Stone 1982b). These studies were conducted in Kings Canyon National Park. I also 
used computer graphics to create the first visually accurate three-dimensional images of a 
real ancient giant sequoia-mixed conifer forest. These images describe an area about the 
size of a football field. The data include the species, size, age and location of 100 percent 
of the trees and shrubs. This computer visualization also shows the forest as it exits 
today. A multimedia presentation that describes this ancient forest is available on a 
diskette for IBM compatible computers (Bonnicksen 1993). 

The resuhs of our studies show that ancient forests that are supposed to be protected are 
actually disappearing at an alarming rate (Bonnicksen and Stone 1982a, 1982b). For 
example, in the Redwood Creek watershed the area covered by aggregations of sapling- 
size trees declined fi-om 17 percent of the ancient forest to only 6.2 percent of the current 
forest. The area covered by shrub aggregations dropped from 19 percent of the ancient 
forest to only 10.9 percent of the current forest. On the other hand, aggregations of pole- 
size trees increased from 15.4 percent of the ancient forest to 35.2 percent of the current 
forest. Mature trees also increased from 17.6 percent of the ancient forest to 27 percent 
of the current forest. An intensive analysis of an 84 hectare (207 acre) control area in the 
watershed showed the same change (Table 4). Table 4 also shows that the fire cycle 
increased from 129 years to 152 years. Thus, frequent surface fires made the ancient 
forest more diverse than the current forest, and the ancient forest contained fewer old 
trees and more young trees and shrubs than the current forest. 



16 



109 



Table 4 

Estimated Natural or Presettlement Old Growth Forest and Fire Cycles 

Compared to Current and Future Forest Conditions 

Giant Sequoia-Mixed Conifer Forest 

Kings Canyon National Park, California 

(Control Area') 





Area of Old 








Growth^ 


Probability of 


Fire Cycle 


Period 


(%) 


Burning^ 


(Years)4 


Ancient Forest (1875) 


21.2 


.007763 


129 


Current Forest (1983) 


26.8 


.006581 


152 


Future Forest (2085) 


56.3 


.002872 


348 



Sampling data for area of old growth front an 84 hectare study area in the Redwood Creek watershed 
^ Old growth defined as trees 2 200 years old Alt estimates computed using Van Wagner's (I97S) age-class distribution and fire cycle 

equations. 
' The value of p (the pfx>bability of fire in any one stand or the proportioo of the whole forest that bums every year) computed as 
-ln(l-2^x)yx, where Ifi^x) is the cumulative fi^quency of all age classes up to and including age class x (the age of a mature trees). 
The number of yeara required to bum over an area equal to the whole area of the forest (computed as 1/p). The fire cycle exceeds the 
fire return interval for all fires (about 20 years) because most fires bura as surface fires. Therefore, the fire cycle is a rough measure of 
stand replacing fires. 



no 



Equally dramatic is the 37 percent increase in patches dominated by white fir trees. White 
fir can germinate in thick litter and grow in the shade of larger trees. That is why most 
understory thickets are composed of white fir. On the other hand, ponderosa pine, sugar 
pine, giant sequoia and black oak require gaps large enough to allow sunlight to reach the 
forest floor. The soil also must be nearly fi-ee of litter for these trees to germinate and 
survive. Such gaps were created in the ancient forest by Indian and lightning fires. Since 
gaps are no longer being created, these species are gradually declining. Today's forest is 
thicker and older than the ancient forest, shrubs, oak trees and wildflowers are less 
abundant, and white fir is gradually becoming the dominant tree species. Such changes in 
protected forests present a serious threat to wildlife and the biological diversity of the 
forest. 

I also projected these changes to the year 2085. I used a transition matrix developed fi-om 
data collected in the control area to make the projection. The results are striking. Table 
4 shows that the area of the forest mosaic covered by patches of large old trees could 
increase 166 percent to form over 50 percent of the fijture forest. Even more ominous is 
an increase in the fire cycle fi-om 129 years to 348 years. This means that the forest will 
shift fi-om a surface fire regime to a massive fire regime. 

These projections show that by the end of the next century the national parks of the Sierra 
Nevada will be visually impressive because of the large trees, but they will be completely 
artificial and dangerous. Biological diversity also will be drastically reduced. Equally 
important is the ecological fact that these forests of old trees cannot be sustained because 
of the lack of patches of young trees. Eventually the large old trees will die, probably at 
the same time. This means that farther into the fiiture the national parks will look more 
like forest plantations than parks as young trees become established within the debris of 
the dead old trees. 

The change in the fire cycle also shows that infi-equent massive fires will probably sweep 
through the forest and bypass the stage when most trees are old and decadent. Instead, 
the forest will move directly to the plantation stage where young trees are growing over 
extensive areas of burned forest. The ancient forest had only a few tons of fiael per acre 
on the ground, but today's old-growth forests have over 50 tons of fiiel per acre. Since 
ancient forests had few understory trees, fires could rarely climb up into the canopy. 
Today's forests are choked with several layers of trees that allow fires to easily climb up 
into the canopy. Fires also had diflBculty moving over extensive areas in ancient forests 
because they were patchy and broken into a mosaic of different size trees. Now fires can 
move fi-eely because the mosaic structure is disappearing as the trees reach similar sizes. 
The wildfire hazard already is extreme and it can only become worse. However, it doesn't 
matter whether wildfires destroy the forest or the forest simply grows old and dies, it will 
still be an artificial and dangerous forest. 

The US National Park Service uses low-intensity prescribed fires to reduce heavy ground 
fixels to forestall catastrophic wildfires. Congress is reluctant to appropriate money for 
such efiForts so the areas burned are small. However, the lack of money for prescribed 
fires may not be a problem because data collected fi'om burned areas in Kings Canyon 
National Park show that little has been accomplished. Low-intensity fires create additional 

18 



Ill 



fiiels and they do nothing to prevent the loss of patches of young trees, or reduce the over 
represented patches of pole-size trees. The changes are already too great to correct 
without mechanical treatment. It is ironic that the prescribed fires set by the Park Service 
are also killing the largest and oldest trees that they are trying to protect. Prescribed fires 
burning through unnaturally thick layers of ground fiaels are creating extremely high soil 
temperatures and cooking the roots of some of the most valuable trees in the parks. These 
prescribed fires are not only failing to restore natural conditions but they are actually 
destroying what is left of the ancient forest. 



Effects of Reserves in Massive Fire Regimes 

The effects of reserves on forests in regions dominated by massive fires will be just as 
dramatic as changes that are already occurring in regions dominated by surface fires. 
However, these changes will take a long time to become visible to the average person. As 
a resuh, many people are fooled into believing that old-growth composed of huge 
Douglas-fir trees is relatively immortal. This false perception of permanence also lulls 
people into thinking that the best way to maintain old-growth is to protect it fi-om humans. 
It is true that this generation of modem humans will probably see cathedral groves of old- 
growth Douglas-fir as long as they live. Unfortunately, each successive generation will 
see less and less old-growth Douglas-fir. Eventually it will all be gone. In place of the 
huge Douglas-fir trees will be less impressive forests of small western hemlock trees and 
other shade tolerant species (Franklin and Hemstrom 1981). Douglas-fir, for example, can 
reach a height of over 300 feet, a diameter of over 15 feet and live to be over 1000 years 
old (Fowells 1965). Western hemlock, on the other hand, only lives about 500 years and 
rarely grows larger than 4 feet in diameter and 225 feet tall (Fowells 1965). It also is 
more susceptible to disease, insect attack and wind throw than the, sturdier Douglas-fir 
(Fowells 1965). Similar changes will occur in Sitka spruce forests. 

Douglas-fir is a pioneer species that regenerates on bare soil with abundant sunlight. 
Under natural or presettlement conditions, favorable sites for Douglas-fir regeneration 
were created by massive wildfires that cleared most of the old forest and prepared the new 
seedbed. Often some large trees and heavy logs were spared the flames and became part 
of the new forest (Hansen et al. 1991). Each newly cleared site represented one large 
patch in the ancient forest mosaic. Sometimes another smaller fire would create additional 
seedbeds in the patch as the forest developed. Because of slow colonization and rebums, 
Douglas-fir reseeded into these areas over periods that could last fi-om 100 to 200 years. 
Finally the site would be completely covered by large relatively even-aged Douglas-fir 
trees with smaller western hemlock and other shade tolerant species in the understory 
(Franklin and Hemstrom 1981). 

If another massive fire did not bum the patch of Douglas-fir, the large old trees would 
eventually die and release the westem hemlock growing in the understory, which then 
became the dominant tree in the patch. Westem hemlock remained dominant because it 
can regenerate within small, shaded gaps created by the death of single large trees or small 
groups of trees. However, few patches reached the westem hemlock dominated stage. In 
natural or presettlement forests, massive fires cleared the forest fi^om most patches before 

19 



112 



the process was complete. Thus, only a small proportion of the patches in the ancient 
forest mosaic were dominated by western hemlock at any one time. 

Dale et al. (1985) constructed a computer model that projects successional change in a 
Douglas-fir forest. In the absence of disturbances, their model shows that the time it takes 
for the oldest Douglas-fir to die and be replaced by western hemlock varies between 750 
and 1000 years. Many of the existing old-growth Douglas-fir forests are more than half- 
way through this successional process because they are about 500 years old. After the 
Douglas-fir disappears, their model verifies that western hemlock reproduces itself 
indefinitely by regenerating within small gaps that are created by the death of single large 
trees. 

A series of reserves will create artificial conditions that never existed in the past and would 
not exist in the fiiture without the proposed management plan. Unlike natural or 
presettlement forests, today succession is moving all patches in the forest mosaic toward 
the elimination of Douglas-fir because of the removal of Indian burning and fire 
suppression. Furthermore, as the patches in the mosaic converge the fire cycle will 
increase. This successional process is most advanced within national parks and wilderness 
areas. For example, 73 percent of the forest area in Mount Rainier National Park is 
covered by trees over 200 years old because of the lack of Indian and lightning fires 
(Hansen et al. 1991). The establishment of additional reserves will ensure that the 
remaining magnificent forests of old-growth Douglas-fir will also be replaced by less 
impressive western hemlock forests. The FEMAT (1993) assessment assures the eventual 
destruction of old-growth Douglas-fir forests because the proposed reserves will be 
protected "fi-om loss to large-scale fire, insect and disease epidemics." Without such 
disturbances Douglas-fir cannot regenerate, so it will die and be replaced by less desirable 
forests of western hemlock. The Douglas-fir replacement problem will affect most of the 
proposed reserves. 

The FEMAT (1993) assessment presents an incredible plan composed of a series of 
contradictions that will fail to correct the Douglas-fir replacement problem. Contradiction 
one: the assessment says that the reserves "are retained in their natural condition, with 
natural processes such as fire allowed to fianction to the extent possible." Then it argues 
that old-growth forests must be protected by instituting an "aggressive fire control 
strategy." Contradiction two: the assessment predicts that eflforts it advocates to protect 
reserves fi^om wildfire will fail. The assessment even quantifies this failure by assuming 
that 12.5 percent of the area within the reserves will be "subject to severe disturbance over 
50 years." Contradiction three: the assessment calls for using silvicultural methods to 
stimulate "natural succession" toward old-growth in places where it is killed by the 
inevitable disturbances. However, the assessment also predicts that the stimulated forest 
will be unnatural because "replacement stands may never be duplicates of existing old 
stands." In short, the FEMAT (1993) assessment says that reserves should be protected 
fi-om fire, but these efforts will fail, so old-growth in the reserves will all be killed and then 
it will be replaced with artificial old-growth that is declared "natural." 



20 



113 



Why does the FEMAT (1993) assessment advocate the establishment of old-growth 
reserves when it predicts that these forests will be destroyed and replaced with artificial 
forests? If disturbances destroy all of the existing old-growth, then the new cultivated old- 
growth will be artificial. If the existing old-growth is protected, it will still be artificial 
because human intervention allowed western hemlock to replace the Douglas-fir forest. In 
either case, partial control of unplanned disturbances cannot be relied upon to maintain 
old-growth forests. The FEMAT (1993) assessment appears to abdicate responsibility for 
future forest conditions by relying on dangerous chance events instead of thoughtfijl 
action. Old-growth forests are too important for such haphazard management. 

Continued technological advances coupled with the generally isolated locations of the 
reserves indicates a high probability that existing old-growth forests will be protected fi-om 
massive fires for a long time. As a result, I used data fi-om the FEMAT (1993) assessment 
to project fiiture changes in the age class distribution of the old-growth forest mosaic 
protected within reserves. The analysis focused on western Oregon and Washington 
because it is dominated by a massive fire regime. 

Figure 2 compares the existing age class distribution for forest mosaics within the 
proposed reserves to the distribution that is likely to occur 400 years in the fiiture. These 
age class distributions are also compared to the distribution that would have been 
produced by the estimated natural or presettlement 400-year fire cycle. As Figure 2 
shows, a large area within the proposed reserves is currently covered with young 
coniferous forests, much of it in plantations on cutover land. I divided the remainder of 
the forests within the reserves among the older age classes in proportion to what would be 
expected under the 400-year fire cycle. A relatively large area is shown in the oldest age 
class because it consists of trees 900 or more years old. 

Since the FEMAT (1993) assessment calls for using silvicultural prescriptions to 
accelerate the development of old-growth in young stands, the large area in young trees 
moves up in age class as a unit (Figure 2). These managed stands gradually enter the 
oldest age class as artificial old-growth. Because human intervention protects the forest 
fi-om fire and allows the Douglas-fir trees to grow to an extreme age, trees gradually pile 
up in the oldest age class. Eventually, these extremely old Douglas-fir trees will die and 
be replaced by western hemlock trees that regenerate within small shaded gaps formed by 
tree falls. Since western hemlock lives half as long as Douglas-fir, the age class 
distribution of the fiiture forest mosaic will terminate at about 500 years. This type of old- 
growth could not exist under natural or presettlement conditions. Therefore, fiiture old- 
growth reserves will be composed of unimpressive artificial forests. 



21 



114 



Figure 2 

Estimated Stand Age Distribution of Forest IVIosaic 

Within Reserves Compared to a 400-Year Fire Cycle 

(Western Oregon and Washington) 



c 
o 



(0 
0) 



Young Natural and 
Plantation Forest 



Young Forest 
(Carried Forward 400 Years) 




400-Year Fire Cycle 
Reserves (400 Years) 
Proposed Reserves 



»C^ fp^ <S^ tS^ <5^ (3^ A^ (^ r^ 
Stand Age Class (Years) 

Based on 5.48 million acres of conifer forest in reserve status (all categories plus Congressionally withdrawn 
reserves in the range of the northern spotted owl) of which 56% is old-growth. Age class distribution of old 
growth in reserves estimated from mosaic produced by a 400-year fire cycle. Proposed plan (FEMAT 
Option 9) will gradually shift the natural Douglas-fir dominated forest that Is only regenerated by infrequent, 
massive fires and other large disturbances to an artificially large Westem Hemlock dominated forest that is 
regenerated within small gaps created by tree falls. 



115 



Management Implications 

The answer to the question posed at the beginning of this section is that a series of large 
(thousands of acres) reserves is not needed to establish and maintain healthy and 
functioning old-growth forests. Furthermore, such reserves will create unsustainable 
artificial forests unlike any that existed in the past. In the surface fire dominated region, 
fire cycles will shift toward longer intervals and larger fires than would be natural under 
presettlement conditions. Therefore, threats to human life and property from wildfires 
also will increase. The dominant trees will also shift from shade intolerant species like 
ponderosa pine to shade tolerant species like fir. In the massive fire dominated region 
small western hemlock trees will gradually replace the huge Douglas-fir trees that people 
associate with ancient forests. Such large-scale replacements of species did not occur in 
ancient forests within either region without major climatic changes. 

In surface fire dominated regions, ancient or presettlement forests were diverse, dynamic, 
fUll of wildlife, beautiful and safe to live in because fires were small. Today's old-growth 
forests are*becoming thicker and more sterile as each day passes. Locking up the 
remaining Federal forests available for timber harvesting within protected reserves will 
compound the problem akeady faced in national park and wilderness areas. No one has 
the will to manage these reserves and Congress will not pay the cost. It may even be 
impossible to manage these reserves in the future as natural forests because they will be 
dominated by large old trees that were allowed to grow in the absence of fire. Some 
people argue that such reserves are needed to maintain biological diversity, yet old-growth 
forests are far less diverse than real ancient forests. Clearly, the best way to protect 
biological diversity is to have a diverse forest, and the best model for diversity is the 
ancient forest mosaic. 

Placing reserves in massive fire dominated regions creates monumental management 
problems. Under natural or presettlement conditions, the forest mosaic consisted of huge 
adjacent patches that spread across the entire region. Some of these patches were larger 
than the area within individual reserves. The proposed reserves represent fi-agments of 
this presettlement mosaic that are isolated fi-om one another. These isolated fi-agments can 
never function as an interconnected, natural and self-sustaining forest. 

The FEMAT (1993) assessment could have proposed setting fire to entire reserves so that 
the regional mosaic looks like the natural or presettlement mosaic. Thus, each reserve 
would represent one patch in a fi-agmented mosaic. Unfortunately, the isolation of the 
reserves fi-om one another would prevent them fi-om being recolonized in a natural manner 
after they are burned. It would also be difficult to justify burning thousands of acres of 
old-growth forest. A better solution would be to shrink the regional mosaic down to the 
size of the individual reserve. This means that the size of the patches in the mosaic would 
be small so that all of the different stages of succession are represented in one reserve. 
This solution would require active management. Instead of active management, the 
FEMAT (1993) assessment advocates passive management. It recommends protecting the 
reserves while acknowledging that chance disturbances such as fire will destroy them — an 
apparent abdication of responsibility for the end result. Obviously, a series of reserves 
creates a series of dilemmas that cannot be resolved without active management. 

23 



116 



MANAGEMENT OPTIONS 



This section addresses the third question. Are there other options involving forest 
management (including commercial harvest) that would maintain healthy and 
functioning old-growth forests? This question is answered by presenting several 
management options that involve timber harvesting. These options were either ignored or 
rejected in the FEMAT (1993) assessment. Nevertheless, any of these options would be 
superior to protected reserves as a method for maintaining heahhy old-growth forests. A 
limited number of reserves are needed for scientific purposes, but reserves are not 
effective as a management technique for sustaining old-growth. 

There are at least four distinct management options that should be considered for restoring 
and maintaining old-growth forests. These options include 1) the Long-Rotation Timber 
Harvest option; 2) the Managed Old-Growth Island option; 3) the Floating Habitat 
Center option; 4) the Sustainable Old-Growth option. Any of these four options would 
be more successful at sustaining old-growth than the option adopted in the FEMAT 
(1993) assessment. 



Long-Rotation Timber Harvest 

The Long-Rotation Timber Harvest option involves continued cutting, but on a long 
rotation. This option usually uses 250-350 year rotations between cuts on the same site. 
Longer rotations are also possible. Since old-growth is partially defined as 200-year old 
or older forest, the Long-Rotation Timber Harvest option could easily produce a large 
number of old trees for an unlimited amount of time. The Old-Growth Definition Task 
Force (1986) added additional criteria to the definition of old-growth, such as the size of 
trees, layers in the canopy, snags, and logs on the ground. These criteria could easily be 
met within the Long-Rotation Timber Harvest option (Newton and Cole 1987). This 
option was presented and rejected in two sentences within the FEMAT (1993) assessment. 



Managed Old-Growth Islands 

The Managed Old-Growth Island option was not even listed among the options rejected 
by the FEMAT (1993) assessment. Harris (1984) wrote a book describing this option 
called The Fragmented Forest . Members of the assessment team must have been familiar 
with this outstanding and widely acclaimed book. Dr. Harris used island biogeography 
theory as the foundation for his book. He proposed creating an interconnected network of 
forest islands composed of small old-growth reserves (about 130 acres) surrounded by 
forest that is cut in a programmed sequence on a 320-year rotation. The old-growth 
reserve in the center of each island provides the protected gene pool and the surrounding 
forest provides a bufifer and a diversity of habitats. As a result, the island would sustain 25 
percent of the cut area in rotating old-groAvth forest and 75 percent in recruitment stands. 
The reserve in the center of the island would remain untouched. This option is 
scientifically sound, carefiilly planned, thoroughly documented, effective and economically 
viable. 

24 



117 



Floating Habitat Centers 

The Floating Habitat Center option (also called "Owl Population Centers") was developed 
by the California Department of Forestry and Fire Protection (CDF) as part of their 
Habitat Conservation Plan for the northern spotted owl (CDF 1992). The CDF involved 
the affected stakeholders in a decision-making process that led to a consensus on 
recommending this option for two of the five sub-regions in northern California 
(Bonnicksen 1992). The Floating Habitat Center option was not listed among the options 
rejected in the FEMAT (1993) assessment. Again, members of the assessment team must 
have been familiar with this option. 

The Floating Habitat Center option involves maintaining a continuous supply of managed 
old-growth habitat that floats around the landscape. The habitat center provides the forest 
conditions needed to support 20 pairs of northern spotted owls. Dispersal habitat is 
provided between habitat centers. Silvicultural techniques are used to create new owl 
habitat that replaces the habitat lost to timber harvesting. Thus, a certain proportion of 
the landscape remains in old-growth, but the old-growth is not restricted to particular 
locations. 



Sustainable Old-Growth 

The Sustainable Old-Growth option is the only option, including the reserve option 
advocated in the FEMAT (1993) assessment, that mimics the natural or presettlement 
forest. It would ensure the future of old-growth forests and protect the economies of 
local communities by keeping Federal forests open to timber production. It is based on 
the assumption that in order to have old-growth forests in the future a continuous supply 
of young trees must be generated to replace the old trees that are lost. This option also 
resolves the Douglas-fir replacement problem. The Sustainable Old-Growth option could 
be applied to all Federal lands or it could be used just within reserves. 

Since the Indians are gone and lightning fires are too dangerous, natural fires can be 
mimicked with carefully managed timber harvesting. The best way to mimic these fires is 
to cut patches of trees in a way that ensures that all essential ages of trees and associated 
vegetation exist in the forest mosaic. Prescribed fires could be safely used on some cut 
areas to produce natural seedbed conditions. Recently cut patches also are important 
because they support many plant and animal species that specialize in early successional 
habitats (Hansen et al. 1991). According to Hansen et al. (1991), fire suppression has 
made this the least common habitat in the Pacific Northwest. Thus, the Sustainable Old- 
Growth option would also sustain this essential habitat. In regions dominated by a surface 
fire regime the cut patches would be small. In regions dominated by a massive fire regime 
the cut patches would be large. Larger cutting units have the added advantage of reducing 
forest fragmentation (Li et al. 1993) in regions dominated by massive fires. The size of 
the area cut also would depend on the overall size of the forest mosaic. 



25 



118 



This option could maintain approximately the same proportion of old-growth in the future 
forest that existed in the ancient or presettlement forest. Decadent old-growth cut in one 
part of the mosaic would be replaced with renewed old-growth as the trees grow larger in 
another part. Thus, dramatic stands of old-growth would float around the future forest 
mosaic in the same way that they floated around the ancient forest mosaic. However, the 
size of the mosaic would be reduced to the area contained within individual reserves or 
Federal forests. Optimum mixtures of old-growth and other stages of tree growth and 
vegetation would also vary depending upon local ecological conditions. Each mosaic 
would be managed to sustain a continuous supply of old-growth and an optimum nuxture 
of associated vegetation and wildlife habitats. 

In order to describe the Sustainable Old-Growth option I used data fi^om the FEMAT 
(1993) assessment for conifer forests in western Oregon and Washington. This region is 
dominated by a massive fire regime. My analysis includes 3.84 million acres of conifer 
forest proposed for inclusion within reserves in northern spotted owl areas. It excludes 
Matrix forest and Congressionally withdrawn reserves. I assumed a 400-year natural or 
presettlement fire cycle as the model for the ancient forest mosaic. The age class 
distribution was normalized to this fire cycle to sustain stands up to 800 years old. As a 
result, harvest in each stand age class is proportional to the estimated area affected by 
natural fires. My analysis approximates what would occur on a smaller scale within an 
individual reserve or Federal forest. 

Figure 3 shows that this option retains the natural or presettlement age class distribution 
and mosaic structure indefinitely. The only difference is that the size of the patches and 
the overall mosaic is smaller than the natural or presettlement forest. Equally important is 
the dependable supply of timber produced from areas that would otherwise be unavailable 
for timber harvest. This option has the added advantage of using timber revenues to pay 
for management. In other words, the Sustainable Old-Growth option is both ecologically 
and economically sustainable. It also helps to sustain local economies. 

Adopting the Sustainable Old-Growth option for reserves or other Federal lands would 
maintain both old-growth forests and jobs. It also would maximize biological diversity 
and ensure the survival of the northern spotted owl and other threatened species. There 
are no known technological barriers to carrying out the Sustainable Old-Growth option. 
Some people argue that humans carmot reproduce real old-growth forests. That is a 
philosophical argument, not a scientific argument. If we want sustainable old-growth we 
must accept our place in nature and manage the forest. 



26 



119 



1 



Figure 3 

Sustainable Old-Growth Option 

Harvesting Schedule and Stand Age Class Distribution 

that Mimics a 400-Year Fire Cycle 

(Western Oregon and Washington) 



0.8- 



(0 
0) 

o 

< 

c 
o 



CO 
(D 



■400-Year Fire Cycle 

I Harvest 

I Residual Stands 




100 200 300 400 500 600 700 800 900 
Stand Age Class (Years) 

Based on 3.84 million acres of conifer forest in FEMAT Option 9 within the range of the northern spotted owl 
(excludes matrix forest and Congressionally withdrawn reserves). Age class distribution normalized to 
sustain stands up to 800 years old and to retain the natural age class distribution and mosaic structure 
indefinitely. This method sustains 56% of conifer forest in old-growth (at least 200 years old). Harvest in 
each stand age class is proportional to the estimated area affected by natural fires. Total harvest per decade 
is 95,022 acres for all age classes. Sustaining stands up to 600 years old would increase the harvest 
to102,886 acres per decade. Harvest does not include thinning. 



120 



Management Implications 

The answer to the question posed at the beginning of this section is that several other 
options involving forest management (including commercial harvest) exist that would be 
superior to protected reserves as a method for maintaining healthy old-growth forests. 

A limited number of reserves are needed for scientific purposes, but reserves are not 
efifective as a management technique for sustaining old-growth. As DeBell and Franklin 
(1987) point out, "old-growth stands cannot be guaranteed in perpetuity by simply 
preserving existing old-growth tracts." They further state that "long-term management 
strategies must include plans to recreate stands." All of the management options 
presented in this section would create a continuous supply of old-growth. The Sustainable 
Old-Growth option has the added advantage of approximating the natural or presettlement 
forest mosaic. These management options are also economically sustainable. In contrast, 
the reserves proposed in the FEMAT (1993) assessment would create costly, unnatural 
old-growth forests that cannot be sustained. 



28 



121 



LITERATURE CITED 

Agee, J. K. and R. Flewelling. 1983. A fire cycle model based on climate for the Olympic 
Mountains, Washington. Proc. Fire and Forest Meteorology Conferences. 7: 32-37. 

Barrett, S. W., and S. F. Amo. 1982. Indian fires as an ecological influence in the 
northern Rockies. Journal of Forestry 80:647-651. 

Bonnicksen, T. M. 1993. Restoring ancient giant sequoia forests. An electronic 
publication (IBM computer compatible multimedia program on a diskette). 
Department of Forest Science, Texas A&M University. 

Bonnicksen, T. M. 1992. Northern spotted owl habitat conservation plan for California. 
The Wildland Resources Center, University of California-Berkeley. 80 pp. plus 
appendices. 

Bonnicksen, T. M. and E. C. Stone. 1985a. Restoring naturalness to National Parks. 
Environmental Management 9(6): 479-486. 

Bonnicksen, T. M. and E. C. Stone. 1982b. Reconstruction of a presettlement giant 
sequoia-mixed conifer forest community using the aggregation approach. Ecology 
63(4): 1134-1148. 

Bonnicksen, T. M. and E. C. Stone. 1982. Managing vegetation within U. S. National 
Parks: a policy analysis. Environmental Management 6(2): 101-102,109-122. 

Bonnicksen, T. M. and E. C. Stone. 1981. The giant sequoia-mixed conifer forest 
community characterized through pattern analysis as a mosaic of aggregations. Forest 
Ecology and Management 3(4): 307-328. 

Booth, D. E. 1991. Estimating prelogging old-growth in the Pacific Northwest. Journal 
of Forestry. 89(10): 25-29. 

Boyd, R. 1986. Strategies of Indian burning in the Willamette Valley. Canadian Journal 
of Anthropology. 5: 65-86. 

California Department of Forestry and Fire Protection. 1992. Northern spotted owl 
habitat conservation plan for private forestlands in California. 61 pp. plus appendices. 

Clinton, W. J. and A. Gore, Jr. 1993. The forest plan for a sustainable economy and a 
sustainable environment. The White House. Washington, DC. 4 pp. plus appendices. 

Cooper, C. F. 1961. Pattern in ponderosa pine forests. Ecology 42: 493-499. 

Cooper, C. F. 1960. Changes in vegetation, structure and growth of southwestern pine 
forests since white settlement. Ecological Monographs 30: 129-164. 

Dale, V. H., M. Hemstrom and J. Franklin. 1985. Modeling the long-term effects of 
disturbances on forest succession, Olympic Peninsula, Washington. Canadian Journal 
of Forest Research. 16:56-67. 



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DeBell, D. S. and J. F. Franklin. 1987. Old-growth Douglas-fir and western hemlock: a 
36-year record of growth and mortality. Western Journal of Applied Forestry. 2(4): 
111-114. 

Fahnestock, G. R. and J. K. Agee. 1983. Biomass consumption and smoke production by 
prehistoric and modem forest fires in western Washington. Journal of Forestry. 
81(10): 653-657. 

Forest Ecosystem Management Assessment Team. 1993. Forest ecosystem management: 
an ecological, economic, and social assessment. USDA Forest Service, USDC 
National Oceanic and Atmospheric Administration, National Marine Fisheries Service, 
USDI Bureau of Land Management, Fish and Wildlife Service, and National Park 
Service, Environmental Protection Agency. 

Fowells, H. A. 1965. Silvics of forest trees of the United States. USDA Agriculture 
Handbook No. 271 762 pp. 

Franklin, J. F. 1993. Preserving biodiversity: species, ecosystems, or landscapes? 
Ecological Applications 3(2): 202-205. 

Franklin, J. F. and M. A. Hemstrom. 1981. Aspects of succession in the coniferous 
forests of the Pacific Northwest. In D. C. West, H. H. Shugart and D. B. Botkin 
(eds.). Forest Succession. Springer- Verlag, New York. Pp. 212-229. 

Franklin, J. F. and R. H. Waring. 1980. Distinctive features of the northwestern 

coniferous forest, pp. 59-86. In R. H. Waring (ed). Forests: Fresh Perspectives from 
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Corvallis, Oregon. 

Gruell, G. E. 1983. Indian fires in the interior West: a widespread influence. Proc. 
Symposium and Workshop on Wilderness Fire. Missoula, MT. November 15-18. 
USDA Forest Service Gen. Tech. Rep. INT-182. Pp. 68-74. 

Hansen, A. J., T. A. Spies, F. J. Swanson, and J. L Ohmann. 1991. Conserving 
biodiversity in managed forests. BioScience 41(6): 382-392. 

Harris, L.D 1984. The fi-agmented forest. The University of Chicago Press. 211pp. 

Heinselman, M. L. 1983. Fire regimes and management options in ecosystems with large 
high-intensity fires. Proc. Symposium and Workshop on Wilderness Fire. Missoula, 
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109. 

Hunter, M. L., Jr. 1989. What constitutes and old-growth stand? Journal of Forestry 
87(5): 33-35. 

Johannessen, C. J., W. A. Millet, and S. McWUliams. 1970. The vegetation of the 
Willamette Valley. Annals of the American Association of Geographers, No. 61. Pp. 
286-302. 



30 



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Johnson, K. N., J. F. Franklin, J. W. Thomas, and J. Gordon. 1991. Alternatives for 
management of late successional forests of the Pacific Northwest. A report to the 
Agric. Comm. and the Merchant Marine Fish. Comm., U. S. House of Rep., 
Washington, DC. 59 pp. 

Kilgore, B. M. 1985. The role of fire in wilderness: a state-of-knowledge review. Proc. 
National Wilderness Research Conference, Issues, State-of-Knowledge, Future 
Directions. Fort Collins, CO. July 23-26. Pp. 70-103. 

Kilgore, B. M. and D. Taylor. 1979. Fire history of a sequoia-mixed conifer forest. 
Ecology 60: 129-142. 

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Book Society. Ashland, Oregon. 

Lewis, H. T. 1983. Why Indians bum: specific versus general reasons. Proc. 

Symposium and Workshop on Wilderness Fire. Missoula, MT. November 15-18. 
USDA Forest Service Gen. Tech. Rep. INT-182. Pp. 75-80. 

Lewis, H. T. 1982. A time for burning. Boreal Institute for Northern Studies, Occasional 
Publication Number 17. The University of Alberta, Edmonton, Canada. 62 pp. 

Li, H., J. F. Franklin, F. J. Swanson, and T. A. Spies. 1993. developing alternative forest 
cutting patterns: a simulation approach. Landscape Ecology 8(1): 63-75. 

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- perspectives and problems. Proc. Tall Timbers Fire Ecology Conference Number 15. 
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in the Northwest. Oregon State University, Corvallis. March 26. Forest Research 
Laboratory, Oregon State University. Pp. 142-158. 

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Western Journal of Applied Forestry. 2: 22-25. 

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mixed conifer forests in the Pacific Northwest and California. USDA Forest Service 
Pacific Northwest Forest and Range Experiment Station, Research Note PNW-447. 

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31 



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University Press. 654 pp. 

Stephenson, N. L., D. J. Parsons and T. W. Swetnam. 1991 . Restoring natural fire to the 
sequoia-mixed conifer forest: should intense fire play a role? Proc. 17th Tall Timbers 
Fire Ecology Conference, High Intensity Fire in Wildlands: Management Challenges 
and Options. Tall Timbers Research Station. Tallahassee, FL. Pp. 321-337. 

Stewart, O. C. 1954. The forgotten side of ethnogeography. In Robert, F. (ed.). Method 
and Perspective in Anthropology. University of Minnesota Press. Pp. 221-248. 

Teensma, D. A., J. T. Rienstra and M. A. Yeiter. 1991. Preliminary reconstruction and 
analysis of change in forest stand age classes of the Oregon Coast Range from 1850 to 
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Viability assessments and management considerations for species associated with late 
successional and old-growth forests of the Pacific Northwest. USD A Forest Service, 
Washington, DC. 530 pp. 

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Interagency Scientific Committee to address the conservation of the northern spotted 
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Journal of Forest Research. 8(2): 220-227. 



32 



125 



WRITTEN STATEMENT FOR THE RECORD 

OF 
.. DR. VICTOR W. KAC2YNSKI 
CERTIFIED FISHERIES SCIENTIST 
ST. HELENS. OREGON 

HEARING ON THE ADMINISTRATION'S 
FORESTRY PLAN FOR THE PACIFIC NORTHWEST 

BEFORE THE 
SPECIALTY CROPS AND NATURAL RESOURCES 
SUBCOMMITTTEE 
OF THE 
AGRICULTURE COMMITTEE 
UNITED STATES HOUSE OF REPRESENTATIVES 



NOVEMBER 18. 1993 



I ntr oaoct ion 



My name is Dr. Victor Kaczynski. I am a practicing 
fisheries scientist with 24 years of professional experience 
with salmonid issues in the Pacific Northwest. My clients 
have included practically all agencies, industries and 
parties affecting and managing salmonids in the region. I 
have conducted research on salmon ecology in Puget Sound, 
mio-Cclumbia River salmon and steelhead trout production, 
hatchery methods, invertebrate (salmon food) production in 
Puget Sound and the north Pacific Ocean, and turbine and 
spillway mortalities at hydroelectric plants. In addition, 
I was the project manager or senior researcher on numerous 
studies evaluating salmonid problems and most of these 
studies identified solutions to these problems. An example 
was the Klamath River Basin Fisheries Management Plan which 
became federal law with a 20 year funded recovery plan. I 
have been a senior author on three major reports that have 
analyzed and described the reasons for salmonid declines in 
northern California. Oregon, and Washington States and I was 
a senior researcher on the salmon Impacts from the Exxon 
Valdez oil spill. I have published over 19 papers on salmon 
ecology, hatchery methods development, water quality, 
aquatic ecology, and ethics in fisheries biology. 



126 



Brief Summary: i 

My presentation today summarizes the highlights of the 
testimony submitted by Dr. John Palmisano (October 22, 
1993). I helped Dr. Palmisano in the development of that 
test imony . 

Most Pacific salmon and trout migrate through several 
distinct habitats during their complex life cycles. Large 
rivers, small streams and even lakes provide spawning and 
rearing habitats and migration corridors in fresh water. 
Estuaries provide critical feeding areas and the brackish 
waters are necessary for the physiological transition 
between fresh and ocean waters. The north Pacific Ocean is 
where most growth and maturation occurs for salmon and 
steelhead trout. Any of these three major habitat areas can 
be the primary limiting factor for our Pacific salmonids. 

Forest streams are a small part of the complex of 
habitats required for the growth and survival of these fish. 
Most forest streams are relatively small and steep (have a 
medium to high landscape gradient). The large majority of 
forest streams are not primary spawning or rearing habitat 
for salmon. Forest streams are secondary habitat for salmon 
but are primary habitat for the common resident cutthroat 
trout. No credible scientific literature exists that 
demonstrates that medium to high gradient forest streams are 
limiting the abundance of our Pacific salmonids. In fact, 
there is much scientific evidence that the forest streams, 
even though they are secondary habitat for salmon, are very 
much underutilized today. 

Some improvement in survival and growth can be made 
through the enhancement of forest stream habitat, but the 
increase in absolute numbers of anadromous salmonld adults 
from such actions will be relatively small. Much more 
significant gains in numerical abundance and recovery of 
stocks that are in trouble can be made by actions downstream 
of the forest. These lower gradient reaches of our streams 
and rivers are severly degrat^ed relative to forest streams. 
Downstream stream reaches have little to no riparian zones, 
little large woody debris to create pools, simplified 
channels because of local flood control projects, lowered 
water flow because of water withdrawals for our civilization 
and economy, relativey high point and nonpoint water 
pollution problems, and several of the larger rivers have 
hydroelectric development. 

Further significant gains can be made in estuary 
restoration because too much critical estuary habitat has 
been physically lost throughout the Pacific Northwest. And 
finally very significant gains in fish stock restoration can 
be made through the proper management of our ocean, bay, and 
river fisheries. Overharvest must be controlled. Only the 



127 



harvest of surplus adults not needed to fully seed our 
presently underseeded habitat can be allowed. 

These conclussions are not presented to negate 
reasonable and prudent protection and restoration of forest 
stream habitats. ^^ Please review Dr. Henry Froehllch's 
testimony in this regard. Rather the conclussions are 
presented to show the need for a much more balanced and 
effective salmonid restoration plan. The draft Snake River 
Recovery Team Plan just released is an example of the needed 
more comprehensive approach. 

The FEMAT/DEIS report is an interagency document 
authored by the USDA Forest Service; USDI Bureau of Land 
Management, Fish and Wildlife Service, and National Park 
Service; USDC National Marine Fisheries Service; and the 
Environmental Protection Agency. The FEMAT/DEIS is glaring 
in its omission of appropriate mission actions by other 
report authors (agencies) downstream of forest streams. And 
such appropriate actions would have a much higher 
probability of success in restoring salmonid fish stocks 
that are in trouble. The actions proposed in the report are 
only for federal forest streams and will only offer a 
limited possibility of success by themselves. In fact, the 
probability of failure to restore the at-risk stocks is 
quite high from the proposed actions by themselves. The 
same relatively low level of limited success can be gained 
by much less radical levels of streamside protection 
measures on federal forest streams. 



128 



NORTHWEST FOREST RESOURCE COUNCIL'S COMMENTS ON 

THE AQUATIC CHAPTERS OF THE FEMAT/DEIS REPORTS 

ON THE PRESIDENT'S FOREST PLAN: 

SALMONID FISHERIES ISSUES 



Submitted by: 



John F. Palmisano. Ph.D. 
Fisheries Biologist 
Beaverton, Oregon 

October 22, 1993 



129 



that the probability of increasing abundance in these areas is high. In sharp contrast, scientific 
information suggests that much available freshwater habitat is unused, or underseeded, because 
an insufficient number of adult spawners annually escape the fisheries. Overwintering coho 
salmon habitat is the only known freshwater habiut limiting fish survival. Such habitat is only 
markedly supplied by deep and off-channel pools that are mostly restricted to floodplain reaches, 
and thus scarce in forested streams of higher gradient. Because streams are clearly disturbance 
dependent svstems, natural events such as floods and landslides can destroy stream restoration 
modifications, structures, and materials. Large financial sums will be required to adequately 
design and engineer restorations projects to withstand the forces of nature, and several decades 
may pass before these projects are devised and implemented. Even then, there are no guarantees 
that fish abundance will increase. Projects may fail to accurately mimic nature, they might not 
be productively used by fish, or too few fish may escape harvest efforts to use them. 

Recovery efforts in the Columbia basin provide the best scientific evidence that simply 
increasing juvenile abundance will not result in increased numbers of adult fish. Historically, 
the annual number of outmigrating juveniles was estimated at 265 million fish with a 3 percent 
annual return of 7.5 million adults. Recent annual production of juveniles in the basin has been 
augmented to 350 million fish. However, only 0.3 percent, or 1.2 million adults, returned in 
1992. Obviously, factors other than juvenile abundance determines the abundance of adult fish. 

To be effective, any salmonid restoration plan must be balanced. Under a balanced plan, if 
factors that limit salmonid abundance are within human control, changes could be made to 
ensure the plans's success. For example, water withdrawals may have to be reduced and 
minimum year-round stream flows established. For factors beyond human control, such as the 
level of ocean productivity, or for factors that humans prefer not to control, such as increasing 
growth rate of marine mammal populations, harvest levels could be adjusted to insure the plan's 
success. None of these options are included in the proposed plan. Without them, increases in 
salmonid abundance appear unlikely. 

Focusing on one life-history requirement, while ignoring all others, not only jeopardizes the 
plan's success, but greatly diminishes the ability to accurately assess its value. Evaluation may 
be difficult because any plan-induced increases in fish abundance could subsequently be 
unknowingly lost to factors that the plan does not control or consider. Such losses will not only 
be detrimental to salmonid recovery, but also to the credibility of the plan and its supporters. 

Implementing the plan and electing not to control fisheries management and water-use and land- 
use activities that annually reduce salmonid abundance, will not greatly increase the chances of 
salmonid recovery. If successful, the plan may simply produce more fish in the long run only 
to be lost to water-use and land-use activities and to overharvest. However, addressing these 
management and environmental factors that have contributed to fish declines, without 
implementing the plan, would assuredly increase fish abundance in the short term. Finally, 
intelligently dealing with all the factors of decline and implementing a stream restoration plan 
in the most productive salmonid habitats, would greatly increase the chances for recovery of 
Pacific Northwest salmonids stocks. 



Ill 



130 

Table of Contents 

Page 
Summary ii 

List of Tables vi 

Introduction : 1 

Approach 2 

Problem Summary 3 

Plan's Weaknesses 4 

General 4 

References 5 

Weakness of Proposed Action 6 

Habitat Issues 6 

Lost Habitat 6 

Vulnerability 7 

Is Freshwater Habiut Limiting? g 

Forest Habitat Issues 10 

Salmonid/Old-Growth Forest Relationship 10 

Pacific Salmonid/Old-Growth Forest Distributions 10 

Habitat Requirements 10 

Optimal Stream Gradients for Salmonid Production 11 

Blanket of Old-Growth Myth 11 

Unseeded Habitat 11 

Riparian Zone Width 13 

Key Watershed Approach 13 

Forest Practices Acts 13 

Non-Forest Habitat Issues 14 

Dam Related Mortality 14 

Inadequate Stream Flows 14 

Unscreened Water Diversions 15 

Freshwater Fish Predation 15 

Freshwater Fish Competition 16 

Ocean Conditions 17 

Ocean Carrying Capacity 18 

Estuaries 18 



IV 



lai 

Table of Contents (continued) 

Page 
Non-Forest Habitat Issues (continued) 

Marine Mammal Predation 19 

Sea Bird Predation 21 

Marine Competition 21 

Non-Habitat Issues 22 

Canadian Interception of Pacific Northwest Salmon 22 

High Seas Interception of Pacific Northwest Salmonids 25 

Mixed-Stock (Preterminal) Fisheries Issues 25 

Indirect Fisheries Mortality 26 

Management Objectives 27 

Overharvest 28 

Underescapement 28 

Reduced Fish Size 30 

Fish Hatcheries 32 

The Plan's True Objective 32 

Role Of Federal Resource Agencies In Salmonid Recovery 33 

USPS and BLM 33 

Other Federal Agencies 34 

Society's Role In Salmonid Recovery 34 

Ecological Assessment of Take 35 

Recommendations 36 

References 37 



132 
List of Tables 



Table 1. Estimated Columbia Basin Smoit Production and Run Size of Returning 

Adults 8 

Table 2. Percent of Adult Salmonids Commercially Harvested in Washington that 
Spent Little or no Time in Washington Streams as Eggs, Alevins, or Fry 
in the early 1990s 9 

Table 3. Average Channel Gradient of 3,425 Miles of Streams in FEMAT National 

Forests in Washington and Oregon 12 

Table 4. Average Channel Gradient of 3,155 Miles of Streams in Non-FEMAT National 

Forests in Washington and Oregon 12 

Table 5. Average 1987-90 Total Marine Mortality (Catch plus Incidental Mortality) 

of Chinook Salmon by Production Region and Nation 23 

Table 6. Average 1988-90 Total Marine Mortality (Catch plus Incidental Mortality) 

of Coho Salmon by Production Region and Nation 24 

Table 7. Optimum and Realized Harvest Rates for Washington Coastal, Puget Sound, 

and Columbia River Salmonid Stocks between 1989 and 1990 29 

Table 8. Percentages (and Numbers) of Wild Salmonid Runs, by Species and Major 
Washington Fishery Areas, That Were in Compliance with Established 
Spawning Escapement Goals in the Last Year of Record 30 

Table 9. Measured Average Weight (in pounds) and Percent Change of Five Species 
of Pacific Salmon Commercially Caught in Washington between 1935 
and 1989 31 



VI 



133 



Introduction 

Pacific salmonids (salmon and trout) have an inordinately complex life history. They require 
multiple habitats during iheir life that include freshwater for spawning and juvenile rearing; 
estuaries for early growth, predator avoidance, and physiological transition between fresh and 
salt water; and the ocean for adult growth and sexual maturation. Deficiencies in any one of 
these habitats will limit populations. The fish are migratory. Accordingly, they require 
uninterrupted and stress-free passage between freshwater and marine habitats. Survival is 
influenced by several natural and human-influenced factors, and salmonids require good 
environmental conditions, not only to survive on a daily basis, but to successfully complete their 
life cycle and ensure the existence of future generations. 

To be effective, any plan for the restoration, enhancement, or protection of salmonids has to 
encompass all habitat and environmental needs, and be cognoscente of the adverse impacts that 
humans and nature have on these fish; otherwise chances of success are greatly reduced. 
Focusing only on one life-history requirement, while ignoring all others, not only jeopardizes 
the plan's success, but greatly diminishes the ability to accurately assess and evaluate the plan. 
Evaluation may be difficult because any plan-induced increases in fish abundance could 
subsequently be unknowingly lost to factors that the plan does not control or consider. Such 
losses will not only be detrimental to salmonid recovery, but also to the credibility of the plan 
and its supporters. Unsuccessful plans also represent an enormous loss of human, financial, and 
future fishery resources. Thus, for the benefit of the fishery and the public, and for the 
credibility of biologists and politicians, proposed salmon plans must be comprehensive. 

The Presidents's Plan (the plan) for salmonid restoration in the Pacific Northwest, though well 
intended, is extremely limited in scope. The plan only addresses stream habitat in forested 
federal lands managed by the U.S. Forest Service (USFS) and Bureau of Land Management 
(BLM). These lands are at medium to high elevations and contain stream habitats with medium 
to high gradients. Streams at these gradients are the least productive of all salmonids habitats. 
The plan does not consider the possibility of restoring the more productive lowland and low- 
gradient habitats lost to agriculture, flood control, transportation, navigation, and land 
development projects. Historically, these areas had the highest productive capacity for salmon. 
They include floodplain and lowland stream habitats and estuaries not directly managed by 
federal agencies but under the influence of federal regulations. The plan also ignores a series of 
quickly resolvable factors under direct federal control (pre-terminal, mixed stock fisheries; 
foreign interception of U.S. stocks; domestic overfishing and poor spawning escapement) that 
continually deplete salmonid abundance. It also fails to consider a series of water-use factors, 
such as insufficient stream flow, unscreened diversions, and dam related mortalities, that 
severely deplete migratory populations of juvenile and adult salmonids. 

What the plan should embody is a comprehensive program aimed at improving survival of these 
fish at everv stage of their life cycle . Because other federal agencies, such as the National 
Marine Fisheries Service, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, and 
the Environmental Protection Agency, have jurisdiction over these non-forested areas, the 



134 



President's administration has the ability to make the plan comprehensive. 

The key watershed approach, championed in the plan, acknowledges that a fragmented approach 
to salmon recovery will not be successful in the freshwater environment (page V-46). Several 
authors have noted that past attempts to recover fish populations were unsuccessful because the 
problem was not approached from a watershed perspective. A pplying similar logic to any 
proposed salmonid recovery plan , if a fragmented approach will not work in freshwater habitats, 
it certainly will not work within the area of salmonid distribution that include freshwater, 
estuarine, and marine habitats. 

The plan also lacks back up data, support information, and analysis; and contains many faults, 
inaccuracies, and inadequacies. Equally important, the plan does not contain a balanced 
representation of the available scientific literature that identifies the factors responsible for the 
decline of Pacific Northwest salmonid populations, and the approaches needed for recovery. In 
addition, some of the scientific references cited in the plan are grossly and irresponsibly 
misquoted and statements based on these references appear purposely misleading and incomplete. 

Above statements are not intended to deny that forest stream preservation and restoration 
projects may help salmonid recovery. Neither do they deny the forest industry's obligation to 
actively participate in scientifically sound, balanced, and equitable recovery plans. Our 
comments, however, are intended to demonstrate that nothing short of a balanced plan that 
adequately addresses all factors of decline has any chance in succeeding to reestablish depleted 
Pacific Northwest salmonid populations. Forest stream measures alone simply have too limited 
a potential to significantly restore our depleted fish stocks. 



Approach 

We will present credible scientific evidence to show that no single factor, but rather a myriad 
of factors are responsible for the decline in abundance of northwest salmonid populations. We 
will present evidence to show that the proposed restoration plan is not balanced and has little 
chance to increase overall, long-term survival of northwest salmonid populations. To date, there 
is little, if any, credible scientific evidence to suggest that stream habitat restoration projects can 
be successful. Projects have a high potential for failure because they may not correctly mimic 
nature and their structures can be destroyed by high water events and natural land slides. 
Evidence will also be presented to demonstrate that most salmonids are not solely dependent on 
ancient, old-growth forest for survival. And further, that recovery of declining salmonid runs 
can be achieved by methods other than restoration of present-day forested areas. These other 
methods have a higher potential for success and must be part of a comprehensive plan that 
considers all aspects of anadromous salmon and trout life history. Major comment topics include: 

1) Problem Summary 

2) Plan's Weakness 

3) Weakness of Proposed Action 



135 



4) Habitat Issues 

5) Forest Habitat Issues 

6) Non-Forest Habitat Issues 

7) Non-Habitat Issues 

8) Plan's True Objective 

9) Role of Federal Resource Agencies in Salmonid Recovery 

10) Society's Role in Salmonid Recovery 

11) Ecological Assessment of Take 

12) Recommendations 

Comments are precede by a summary and followed by a list of references. 



1) Problem Summary 

Abundance of the seven naturally spawning species of anadromous Pacific salmonids that occur 
in the northwest: 

Sockeye salmon Oncorhynchus nerka (Walbaum) 

Pink salmon O. gorbuscha (Walbaum) 

Chum salmon O. keta (Walbaum) 

Chinook salmon O. ishawytscha (Walbaum) 

Coho salmon O. Idsiach (Walbaum) 

Steelhead trout O. myldss (Walbaum) 

Sea-run cutthroat O. clarld darld (Richardson) 
have been declining since the late 1800s (Van Hyning 1973; Craig and Hacker 1940) when 
records began being kept. Several factors, acting now and in the past, have been implicated in 
the decline and lack of recovery of these fish (CH2M HILL 1985; Kaczynski and Palmisano 
1993; and Palmisano, Ellis, and Kaczynski 1993). These factors can conveniently be place into 
two categories: environmental and management. Environmental factors included water-use and 
land-use practices, natural phenomena, and biological interactions. Management factors include 
state and federal fishery agency policies, and actions; related fish hatchery policies and practices; 
and harvests. Fish abundance has been reduced by increased mortality caused by environmental 
and management factors, by changes in fish size and genetics caused primarily by management 
practices, and by lost productivity caused by habitat loss and degradation in freshwater and 
estuarine areas, and by natural fluctiiations in ocean productivity and climate. 

Several factors have contributed to habitat loss in the Pacific Northwest. Hydroelectric projects, 
primarily in the Columbia-Snake River basin, permanently blocked over half of the available 
spawning and early rearing habitat in the upper basin (Thompson 1976). In addition, navigation 
and fiood control projects, and development of agricultural, municipal, industrial, and 
recreational properties degraded or destroyed much of the most productive salmonid spawning 
and rearing habitat in lowland, floodplain, and estuarine areas throughout the Pacific Northwest. 

A recent surge of interest has focused on measures to restore the dwindling runs of northwest 
salmonids. One politically favored approach is the preservation and restoration of spawning and 



136 



rearing habitat in federally managed forests. Such programs will be expensive and will require 
decades if they have any chance to produce long-term results. While it may be relatively easy 
to initially fund these projects, it will be difficult to maintain long-term projects in a short- 
sighted political arena. In addition, possible short-term rises in abundance, unrelated to a project, 
may halt funding because of a false belief that the program has succeeded. If these short-term 
gains are soon followed by subsequent episodes of low abundance, project funding and 
confidence may cease. At best, these are high risk programs that may offer little chance for 
success. 

At the same time that these forest habiut improvement programs are gaining support, a siz.ole 
body of relatively new scientific evidence has been compiled which indicates that salmonid 
abundance is closely related to natural fluctuations in levels of ocean productivity, and may be 
less closely tied to freshwater habitats. Because these natural cycles of ocean productivity may 
mask the effects of other factors presently believed to influence salmon abundance, it may be 
unwise to initiate habitat-altering programs until more information is obtained on the true cyclic 
nature of salmon abundance and ocean productivity. Until that time, it may be more productive, 
and less expensive, to rely on management practices that reduce excessive harvests and enable 
the annual achievement of numerical spawning escapement goals than to attempt costly 
restoration projects. In fact, the available data indicate serious overhavest as a primary factor 
that has caused the depressed spawning of today. Behnke (1992), an eminent fisheries biologist, 
has advised that "Before any effort is made to improve spawning habitat... managers should 
ascertain that poor spawning success truly limits population size. " 



2) Plan's Weaknesses 

Genera! 

The plan's major weakness is that it is not comprehensive enough to affect salmon recovery. 
It narrowly focuses on preserving and restoring early life history habitat in relatively 
unproductive upland forested streams. Admittedly, the level of preservation proposed will 
provide salmonid stream habitat that is within the bounds of natural variation, and most fisheries 
biologists consider this to be good stream habitat. A major questions about the preservation 
proposed, however, is whether the levels of protection proposed are likely more than necessary. 

Restoration in forested streams will be expensive and non-managed restoration will require 
decades to centuries of time to work, and there are no guarantees that it will be successful. If 
it is successful, success may not be measurable, but instead be masked by natural or human- 
influenced factors that have a greater affect on salmonid abundance. Similarly, the plan may 
fail, but appear successful because measurable changes occurred independent of the actions 
taken. This false success could initiate additional unneeded restoration projects. If habitat 
restoration is truly important (e.g., the restoration removed a limiting factor for survival or 
growth), than chances for potential success would be significantly greater if restoration efforts 
were concentrated in the historically more productive lowland habitats in floodplains and 



137 



estuaries that have been converted to agricultural and other uses. 

The plan also ignores the complex life history and multiple habitat requirements of salmonids, 
and the wealth of scientific evidence which clearly demonstrates that a myriad of factors, not 
just one, influence salmonid abundance. If they were truly interested in increasing salmonid 
abundance, the plan's originators could obtain much quicker results by exerting influence over 
an array of human-caused factors that annually contribute to reduced salmonid abundance over 
several life history stages and habitat areas. For natural factors that are beyond human influence, 
they could recommend management practices and strategies that annually adjust harvest levels 
that would compensate for natural changes in abundance, thus ensuring a relatively constant 
number of returning adult spawners. 

Critics of this more broad approach would suggest that much of the salmon's life history occurs 
away from federal lands and therefore is beyond the jurisdiction of USPS and BLM. However, 
if salmon recovery is truly important, other federal agencies (e.g.. National Marine Fisheries 
Service, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, Environmental 
Protection Agency) that have jurisdiction and responsibility for these fish in national and 
international waters could exen their influence to protect these fish. And because this is the 
President' Plan, surely his administration could exert political pressure and seek cooperation 
from all citizens, agencies, industries, and countries that potentially influence salmonid 
abundance. All this could be accomplished, that is, if salmon recovery is truly an important 
issue. 

References 

Few, if any, credible scientific references were presented in the plan to support the feasibility 
or potential success of the proposed habitat restoration plan. Similarly, there was a noticeable 
lack of citations acknowledging the life cycle complexity of salmonids, their multiple habitat 
requirements, and the myriad of natural and human-influenced factors that affect their abundance 
other than the amount and quality of early life history habitat. 

Some of the references used in the plan did not contain credible scientific data and others were 
misquoted. For example. Tables V-D-1 , V-D-2, and V-D-3 (Water Quality Status Section) were 
derived from information contained in the 1988 Oregon statewide assessment of nonpoint sources 
of water pollution. Much information in that document came from subjective survey 
questionnaires and not from true, quantitatively derived water quality monitoring data. The 
questionnaire-supplied information cannot be scientifically used to assess the status of water 
quality, and FEMAT may be making serious errors in its analysis if it relies on this 
unsubstantiated opinion-based information. 

The Salmon at the Crossroads report (Nehlsen et al. 1991), cited in the plan, is not an American 
Fisheries Society (AFS) report. Authors of the plan are trying to obtain additional stature for 
their arguments by implying that the report is the official findings of AFS. Nehlsen et al. (1991, 
footnote on the bottom of Page 4) clearly states their authorship: "The authors are members of 
the AFS Endangered Species Committee. This paper states the opinions of the Committee and 



138 



docs not necessarily reflect AFS policy or the views of the employers of any of the authors." 
In addition, the report is informational only, may not have been peer reviewed, and there is no 
consensus by fisheries biologists on the definition or number of salmonid stocks mentioned. 

On Page V-11 of their report, the FEMAT authors state that "Loss and degradation of 
freshwater habitats are the most frequent factors responsible for the decline of anadromous 
salmonid stocks (Nehlsen et al. 1991)." In contrast, Nehlsen et al. (1991, Page 4) list the order 
of development activities that have caused extensive losses in salmonid populations and habitats 
as "..hydropower, fishing, logging, mining, agriculture, and urban growth..." Clearly, there 
is a difference between these two statements. 



3) Weakness of Proposed Action 

The plan presented no evidence that medium to high gradient forest stream habitat is limiting 
salmonid growth and/or survival. No credible evidence, either scientific or anecdotal, was 
offered to show that stream habitat restoration projects will be successful in medium to high 
gradient forested streams of the Pacific Northwest. No extensive literature search was 
referenced, no individual references were cited, no case studies were presented, no testimonials 
were introduced. In short, no credible scientific evidence or proof were offered in support of 
the potential success or benefits of habitat restoration. This suggests either an absence of 
supportive data or a less than thorough evaluation of the proposed action. 

Streams are clearly disturbance dependent systems as the plan acknowledges, and are 
periodically significantly altered by natural events, such as landslides and floods. Sufficient data 
exist to show that unless structures and materials are properly designed and engineered to 
withstand these events , such as the 20-year-flood event, they will not last (Beschta et al. 1991). 
Such design considerations will greatly delay implementation of the plan and significanUy 
increase its financial costs. Also, projects may fail if habitat improvements do not accurately 
mimic nature, if they are not productively used by fish (Black et al. 1993), or if too few fish 
escape harvest efforts to use them (Cederholm and Reid 1987). 



4) Habitat Issues 

Lost Habitat 

Before water projects were developed in the Columbia-Snake River basin for flood control, 
irrigation, hydropower, and navigation, total stream drainage area (including tributaries) 
available to wild anadromous fish was about 163,000 square miles. Today, only about 73,0(X) 
square miles of drainage area remain accessible to anadromous salmonids in the Columbia basin 
(Thompson 1976). This is a gross habitat area loss of 90,000 square miles (approximately 55 
percent of the original drainage area). The total number of stream miles accessible to 
anadromous salmonids is another way to evaluate gross area losses. Before development in the 



139 



Columbia basin, about 15,000 linear miles of streams (including tributaries) were available for 
native salmon and steelhead trout (about 12,000 miles above and 3, (XX) miles below Bonneville 
Dam). Today, some 10,000 miles of streams are available, about 7,600 above and 2,500 miles 
below Bonneville Dam. (PFMC 1979). These figures include tributaries and yield a more 
conservative one-third gross area loss estimate for the Columbia basin. A substantial percentage 
of the habitat blockages discussed above occurred after 1950. 

Netboy (1977) reviewed amounts of spawning habitat accessible in 1950 based on data presented 
in the U.S. Army Corps of Engineers' 308 Report. At that time, approximately 50 percent of 
the predevelopment spawning habitat was still accessible. By 1977, only one-third of the 
spawning habitat was still accessible to anadromous fish (ibid.). 

A major cause of lost habitat is most rivers and streams of the northwest has been the 
simplification of stream channels and the losses of habitat complexity, and the loss of flood plain 
and estuarine habitat. Habitat has also been lost along stream margins. Complex edge habitat 
is extensively used by subyekrlings of many fish species, including salmonids. This habitat has 
been destroyed by the reduction in abundance of large flow obstructions, such as, large logs and 
boulders near the stream edge, streambank stabilization, and other measures designed to confine 
flow to a single channel (Bisson et al. 1992). 

The development and maintenance of commercial navigation, combined with flood control for 
agriculture and industrial/urban development have caused large-scale changes in the 
predevelopment conditions of estuaries and lower reaches of many rivers in the northwest. Sedell 
and Luchessa (1982) have shown from historical documents that virtually all coastal valleys were 
"wet," with active complex flood-plain features, multiple channels, sloughs, beaver dams, 
timbered swamps, and marshes. Today, most of the flood plains have been converted to 
agriculture or towns and cities. Much complex, very productive salmonid habitat -especially 
native coho salmon habitat-has been lost. The greatest standing stock of juvenile salmonids 
occurred in side channels and flood-plain tributary streams. The main channel had the lowest 
juvenile salmonid use. For example, in the Hoh River drainage in Washington, side-channel and 
flood-plain tributary habitat accounted for only 6 percent of the salmonid habitat, but it contained 
about 70 percent of the juvenile fish (see Palmisano, Ellis, and Kaczynski 1993). 

Vulnerability 

Changes in the physical conditions of the water or in fish habitats may greatly affect salmonid 
survival and production. Increases in water temperature and resulting decreases in dissolved 
oxygen (D.O.) levels, disposal of toxins, accumulations of smothering sediments, removal of 
riparian vegetation, alterations of stream channels, absence of pool habitat, reduced flows, 
blockage of migration routes, loss of estuarine habitat, and reduced ocean nutrient levels and 
increased ocean temperatures each can reduce salmonid numbers and productivity. 

Such changes may be caused by human activities such as dam and levee construction, bank 
protection, channel improvements, road building, logging, irrigation diversion, pollution, 
livestock grazing, and mining; or by natural events such as floods, fire, winds, land slides. 



140 



volcanic eruptions, and changes in climate and ocean productivity. Management practices that 
favor the production of salmonid predators and competitors also can adversely affect salmonid 
production. In any case, it is important to understand that changes in the environment can and 
do lead to significant reductions in salmonid abundance and production. ,;, 

Is Freshwater Habitat Limiting? 

Has freshwater habitat required for spawning, egg development, and fry rearing limited recent 
anadromous Pacific salmonids fisheries harvested in the Pacific Northwest? Or have other 
factors, such as treacherous freshwater passage and reduced estuarine habitats for outmigrating 
smolts and returning adults, unfavorable ocean conditions, foreign harvest of U.S. stocks, and 
overfishing and inadequate spawning escapement in U.S. waters been contributing or even more 
significant causes? 

If there is one freshwater habitat that most fisheries biologists would probably agree is limiting 
fish survival, it would be coho salmon overwintering habitat. Such habitat is only significantly 
supplied by deep pools and off-channel pools. These pool habitats are mostly restricted to 
floodplain reaches that are scarce in forested streams of higher gradient. 

In the Columbia River fishery almost 60 percent (58.3%) of the commercially harvested adult 
salmonids are hatchery produced fish that have spent no time in the river as eggs, alevin, or fry 
(Table 1). Thus, hatchery production in the Columbia River basin may provide evidence that 
solely increasing the number of juvenile salmonids (a goal of the restoration plan) will not result 
in a proportional increase in the number of returning adults. Prior to development of the 
Columbia basin, the annual number of outmigrating smolts was estimated at 265 million fish 
(NPPC 1986b) with a resulting annual return of 7.5 million adults (Chapman 1986). Thus, 
calculated smolt survival was about 3 percent. During the late 1980s, total annual smolt 
production in the basin was almost 350 million fish, which included over 200 million hatchery- 
produced and 145 million wild fish. Because only 1.2 million adults returned in 1992 (King 
1992), smolt survival rate has been reduced to 0.3 percent, a ten-fold decrease! Obviously, 
increasing smolt production by over 30 percent did not result in a comparable increase in 
returning adults. 

Table 1. Estimated Columbia Basin Smolt Production and Run 
Size of Returning Adults (in millions of fish) 



Era 


Wild 
Smolts 


Hatchery 
Smolts 


. ToUl 
Smolts 


Adult 
Run Size 


% Adult 
Return 


Historical 


265 


— 


265 


7.5 


2.8 


1992 


145 


203 


348 


1.2 


0.3 1 



Sources: Palmisano, Ellis, and Kaczynski 1993; Kaczynski and Palmisano 1993. 



8 



a> 



Similar evidence from Washington suggest that freshwater spawning and rearing habitat is not 
limiting the fishery. Of the adult salmonids commercially harvested in Washington, from 71 to 
89 percent have spent little or no time in Washington streams as eggs, alevin, or fry (Table 2). 
Over 71 percent of the harvest consist of adult sockeye and pink salmon produced in the Eraser 
River in British Columbia, Canada, and of adult coho, chum, and chinook salmon and steelhead 
trout produced in Washington hatcheries. If Washington-produced pink, chum, and sockeye 
salmon, which spend little or no pan of their early life history stages in Washington streams are 
included, then the level is increased to over 89 percent. 



Table 2. Percent of Adult Salmonids Commercially Harvested 
in Washington that Spent Little or no Time in Washington 
Streams as Eggs, Alevins, or Fry in the early 1990s 



Fish not Produced 
in U.S. Streams 



Fry & Smolts 
Having Little 



Species 


Annual 

Average 

Harvest 


Canada 

Origin 

Percent 


US 

Hatchery 
Origin % 


Number 


Percent 


Time in US 

Streams 

Percent 


Pink 


1,890,000 


64 


- 


1,200,150 


19.5 


(30.6) 


Sockeye 


1,670,000 


99 


- 


1,653,300 


26.8 


(27.1) 


1 Coho 


1,320,000 


— 


60 


786.000 


12.7 


— 


1 Chum 


678,000 


-- 


40 


271,200 


4.4 


(10.9) 


1 Chinook 


510,000 


- 


80 


408,000 


6.6 


— 


Steelhead 


107,000 


- 


70 


74,900 


1.2 


— 


! Total 


6,165,000 








71.2 


(89.1) 


Source: Palmisano, Ellis, and Kaczynski 1993. 



Canadian interception of Washington stocks and inadequate spawning escapement have been 
identified as a major cause for the state's limited harvest and reduced escapement (Palmisano, 
Ellis, and Kaczynski 1993). In addition, changing ocean conditions in the strength of the 
California current have clearly limited ocean coho salmon growth and survival from Oregon and 
California, and chinook salmon survival from southern Oregon and northern California since 
1976 (see Ocean Conditions below). 



142 



5) Forest Habitat Issues 

Salmonid/Old-Growth Forest Relationship 

The FEMAT/DEIS reports imply that the reduction and loss of ancient and old-growth forest 
habitats has contributed to the decline in abundance of Pacific salmonid populations. 
Additionally, it implies that as old-growth forests decline and disappear, so will salmonid 
populations. While there is scientific evidence to show that the degradation of forest habitat can 
adversely impact salmonids, and that responsible forest practices activities can contribute to 
salmonid survival and abundance, there is no comparable evidence to show that any salmonids 
rely on old-growth forest for their continued existence. 

Pacific Salmonid/Old-Growth Forest Distributions 

Pacific salmonid distribution extends from Korea, across Russia, Japan, and Aleutian Islands, 
and south from the Arctic Ocean and Bering Sea through Alaska, western Canada and the United 
States (well beyond the east side of the Cascade Mountain Range), to Mexico (Groot and 
Margolis 1991; Meehan and Bjomn 1991; Hart 1973). By comparison, the distribution of the 
old-growth forest has a relatively limited coastal distribution in western North America that 
extends from southeastern Alaska to central-northern California and does not extend beyond the 
west slope of the Cascade Mountain Range (Zybach 1993b). 

Habitat Requirements 

Of the seven anadromous species of Pacific salmonids that occur in the northwest, only the range 
of the coastal cutthroat trout aligns closeN • biogeographic region known as the Pacific 

coast rainforest belt (Trotter et al. iV/ .. cu hroat trout spawn in streams where their 

young rear for an average of 2 years be:; e • .y migr<iie to estuarine and coastal habitats (ibid.). 
Sea-run cutthroat trout are not known, ;.. .vcver, to require late serai stage or old growth forest 
for their freshwater development. 

The remaining six salmonid species rely, to varying degrees, notably less upon forested stream 
habitats, and none are known to require ancient, old growth forests for spawning and early 
rearing habitat. In general, the majority of the life and growth of all anadromous salmonids 
occur in estuarine and marine environments (Groot and Margolis 1991), and salmonids gain 95 
percent of their body weight in the marine environment (Pearcy 1992). 

Pink salmon spawn in river mouths near the ocean, even in intertidal areas. Their young spend 
no more than 7 days in freshwater, then migrate to sea (Heard 1991). Chum salmon generally 
spawn in the lower reaches of rivers and their young spend no more than 30 days in freshwater 
before they too migrate to the estuarine and marine environment (Salo 1991). Most sockeye 
salmon spawn in streams. Some populations, however, spawn in lakes where the young from 
all populations rear for 1 to 2 years before migrating to sea (Burgner 1991). Some coho salmon 
spawn and rear in lakes although most spawn and rear in stream environments where they rear 
for 1 year (Sandercock 1991). Chinook salmon spawn in low gradient floodplain reaches of 
rivers. Spring runs spend from 3 to 12 months in rivers while summer and fall runs spend only 
3 to 6 months in freshwater (Healey 1991). Steelhead trout spawn in streams where their young 

10 



143 



reside for 2 to 3 years (Burgner et al 1992). 

Optimal Stream Gradients for Salmonid Production 

Most, if not all, salmon production in the Pacific Northwest occurs in stream charuiels with 
gradients that are less than 3 percent (Nickelson et al. 1992). Chum and pink salmon spawn in 
the extreme lower reaches of rivers and streams with gradients that are less than 1 percent. 
Chinook salmon spawn in low gradient (up to 1 percent) areas of mainstem coastal rivers and 
in the lower reaches of larger tributaries. Spawning and rearing of juvenile coho salmon 
generally take place in small low-gradient (less than 3 percent) streams, although rearing may 
also take place in lakes as stated above. Spawning and initial rearing of juvenile steelhead trout 
generally take place in small moderate-gradient (3 to 5 percent) tributary streams. Sea-nin 
cutthroat trout tend to spawn in very small tributaries with gradients possibly up to 5 percent. 

Analysis of data summarized from the USDA Forest Service, Region 6 Stream Inventory 
database SMART (Stream Management, Analysis, Reporting, and Tracking) indicates that 71 
percent of 3,425 miles of streams in FEMAT forests in Washington and Oregon have gradients 
that are 3 percent or greater (Table 3). Data in SMART is not a representative sample of the 
streams in the region, nor is it a representative sample of the region's fish bearing streams. 
However, because most of the National Forests in the Pacific Northwest are in upland and 
mountainous areas at elevations that are several hundred to several thousand feet above sea level, 
it is reasonable to assume that the available data reflects a meaningful portrayal of stream 
gradients in the region. The similarity of the data from the non-FEMAT forests of Washington 
and Oregon, i.e. over 76 percent of 3,155 miles of these streams have gradients that are 3 
percent or greater (Table 4), supports this belief. These values indicate that proposed restoration 
programs will take place in sub-optimal habitats for salmonid spawning and early rearing. 

Blanket of Old-Growth Myth 

Even in the area from southeastern Alaska to northern (California, were the distribution of old- 
growth forest and Pacific salmonids overlap, old-growth forests were not uniform in time and 
space. Recent research by Zybach (1993a) of Oregon State University, and other researchers 
(e.g., MacCleery 1992), provide scientific evidence that forest types in the Pacific Northwest 
existed as mosaics of various-aged stands well before the arrival of European settlers. Natural 
forces of nature (i.e. fire, insects, and wind); differences in topography, soil, and climate; and 
burning activities by native Americans prevented the complete coverage of the landscape by old- 
growth forest stands. During this period Pacific salmonid populations, unaffected by human 
development and intensive commercial fisheries, flourished in the northwest. This information 
suggests that Pacific Northwest salmonids do not rely on old-growth forest for their survival. 

Unseeded Habitat 

Habitat "seeding" is described as the relationship between available habitat and fish numbers. 
When good or optimal habitats contain few or no fish, the habitat is considered "underseeded". 
Several examples of underseeded habitat occur in Pacific Northwest rivers and streams of logged 
areas. Cederholm and Reid (1987) and Edie (1975) have documented underseeding for the 
Clearwater River basin of the Olympic Peninsula in Washington, and Carman et al. (1984) and 

11 



144 



Table 3. Average Channel Gradient of 3,425 Miles of Streams 
in FEMAT National Forests in Washington and Oregon 



Stream Miles 


Channel Gradient 


Percent of Total 


Cumulative Total 


92.4 


% 


2.7 


2.7 


335.7 


1 % 


9.8 


12.5 


564.7 


2 % 


16.5 


29.0 


536.2 


3 % 


15.7 


44.7 


1.895.2 


> 3 % 


55.3 


100.0 



Note: Includes Gifford Pinchot, Mt. Baker-Snoqualmi, Mt. Hood, Okanogan, Olympic, Rogue 
River, Siskiyou, Umpqua, Wenatchee, Willamette, and Winema National Forests. 

i 

Source: Apple 1993. 



Table 4. Average Channel Gradient of 3,155 Miles of Streams 
in Non-FEMAT National Forests in Washington and Oregon 



Stream Miles 


Channel Gradient 


Percent of Total 


Cumulative Total 


20.3 


% 


0.6 


0.6 


260.6 


1 % 


8.3 


8.9 


461.1 


2 % 


14.6 


23.5 


617.0 


3 % 


19.6 


43.1 


1,795.6 


> 3 % 


56.9 


100.0 

[=r^. 1 



Note: Includes Colville, Fremont, Malheur, Ochoco, Umatilla, and Wallowa- Whitman National 
Forests. 

Source: Apple 1993. 



Phinney and Bucknell (1975) reported similar underseeding for Capitol Forest streams near 
Olympia, Washington. The larger average size of juvenile coho salmon in streams of the 
Clearwater basin (Edie 1975) and Capitol Forest (Carman et al. 1984) are likely caused by low 



12 



145 



densities and reduced competition attributed to underseeding. Cederholm (1993) has observed 
that various levels of underseeding occur in many of the coastal and Puget Sound rivers of 
Washington. Further, he believes that underseeding is prevalent throughout the Pacific Northwest 
and this belief is supported by the large number of the individual salmon stocks that consistently 
fail to meet agency established annual spawning escapement goals (see below). Cederholm and 
Reid (1987) have stated that overfishing has caused the underseeding. Most notable is the 
underseeding that occurs along the entire coast of Oregon where the annual spawning escapement 
goal, which is related to available habitat, is 200,0(X) adults. As few as 15,(XX) adults may have 
been present in each of the last several years. The Pacific Fisheries Management Council 
(PFMC) has finally significantly reduced coho salmon harvest along the Oregon coast in 1992 
and 1993 to help return more spawners to area streams. 

Classic examples of underseeding also occur in streams and rivers in unlogged and wilderness 
areas of the Columbia-Snake River basin. Fish numbers continue to dwindle in these watersheds 
because of overfishing, dam related mortalities, and competition with hatchery-produced fish. 
The Imnaha River in Oregon (Jonasson 1992; Chilcote et al. 1992) and the Clearwater River in 
Idaho (Megahan 1993; Konopacky 1993) are undereseeded for the reasons described above. 
Similar examples occur in developed areas where water withdrawals cause rivers to go dry 
during summer months. Classic examples include the Yakima Valley in Washington and the 
Walla Walla River in northeastern Oregon, both in the Columbia basin (see Palmisano, Ellis, 
and Kaczynski 1993). 

Riparian Zone Width 

FEMAT's derivation of the riparian reserve width (up to 300 feet) is not readily apparent for 
fish stocks at risk. The derivation of one leave tree riparian reserve rone, based on leave tree 
height, is apparent but the 2x multiplication is not. If the reasoning is to protect microclimate 
and provide downed logs in the initial 150 feet, then the logic for fish protection in the stream 
or for riparian functional distance of an additional 150 feet are neither self evident nor logically 
developed. Are the scientific authors postulating that an additional 150 feet are necessary to 
protect the function of the first 150 feet? What evidence exists for this hypothesis? What 
evidence exists to estimate incremental benefit of the second 150 feet and what is the estimated 
incremental benefit? Has a benefit-cost analysis been performed? 

Key Watershed Approach 

Most of the key watersheds identified in the FEMAT plan are not adjacent to the ocean. Most 
in Washington, and many in Oregon, are more than 100 miles form the sea. If the migration 
routes to the estuaries and the ocean are not included in the plan, how will the plan possibly 
succeed? Thus, the plan has to provide safe and unimpeded migratory pathways between federal 
lands and the sea if it is to be successful. In addition. Tier 2 key watersheds in Oregon are in 
the Cascade Mountain Range. The salmonid stocks of concern do not occur in this area. 

Forest Practices Acts 

Unregulated timber harvest in the riparian zone ended in Oregon in 1972 when the 1971 Oregon 

Forest Practices Act, sponsored by the timber industry, came into effect (Kaczynski and 

13 



146 



Palmisano 1993). These rules began to protect streams and their riparian zones. They were the 
first forest practices enacted in the United States. Practices for protection evolved periodically 
through the 1980s and 1990s which culminated in the adoption of new stream protection 
measures and stream classification by the Board of Forestry in 1992. 

The 1976 Washington Forest Practices Rules and Regulations were developed primarily to 
protect water quality (Palmisano, Ellis, and Kaczynski 1993). They have been updated several 
times (i.e., 1983, 1988, and 1992) to incorporate new measures to protect fish and wildlife 
resources The latest revision, adopted in 1992, attempted to address cumulative effects of forest 
practices through a process termed watershed analysis. 

Similar regulations evolved in California during the 1970s to the 1990s. Today, forest practices 
in the Pacific Northwest are regulated more than any other natural-resource-based land use in 
the region. Stringent enforcement of these rules, and the passage of time, will greatly enhance 
the protection and natural restoration of forested stream habitats of the region. 



6) Non-Forest Habitat Issues 

Dam Related Mortality 

In the Columbia basin, mainstem dams are the primary obstacle to anadromous fish production, 
and dam-related mortality overshadows all other inbasin habitat limitations (CBFWA 1990). 
Upstream ladder passage at mainstem Columbia-Snake projects is estimated to have a 95 percent 
survival (success) rate per dam (NPPC 1986a). However, there is an unaccounted-for loss of 
at least another 5 percent per dam that may be the result of delayed mortality (or possibly 
poaching). Thus, when all adult passage loss estimates are reviewed, the upstream adult passage 
loss per dam appears to be about 10 percent. The cumulative mortality that adult salmon and 
steelhead trout experience in upstream passage over nine projects to reach spawning gravels in 
the Methow River or Okanogan River is about 61 percent. In 1990, approximately 378,400 of 
the 620,300 adult salmonids that migrated up the nine Columbia River dams were lost 
(Palmisano, Ellis, and Kaczynski 1993; Kaczynski and Palmisano 1993). 

Downstream passage for juveniles is even more perilous. Passage mortality is estimated at 15-30 
percent per dam (NPPC 1986b). Cumulative mortalities at Columbia-Snake River projects 
approach 96 percent (ibid.). Turbine mortalities could 15 percent or higher per project, 
depending on turbine type, and reservoir mortalities are about 0.5 to 1 percent per mile of 
reservoir. Spillway mortality at Columbia-Snake hydroelectric projects is generally believed to 
be relatively low: 1 to 2 percent (Schoeneman et al. 1961; NPPC 1986a). 

Inadequate Stream Flows 

About 280 million acre feet (MAF) per year of surface runoff becomes available for fish in the 
Pacific Northwest. This is about 385, 0(X) cubic feet per second (cfs). Average annual Columbia 
River flow at The Dalles is about 140 MAF (USGS 1988). Snake River annual flow is about 
36 MAF and would be 42 MAF without agricultural water losses (Hydrosphere 1991). There 

14 



147 



is ^out 40 MAF of flood control storage in the Columbia basin, most of which becomes 
irrigation water, and much of it passes through several hydroelectric plants (PNRBC 1979). 
These are large amounts of water, but the seasonal availability is insufficient to meet competitive 
water use demands and fish needs (PNRBC 1972). Summer flows are more relevant to fish and 
other user needs. In western and northern Oregon, for example, average summer flows are 
about 20 percent of annual flows and low summer flows are only roughly 5 percent of annual 
flows (PNRBC 1972; USDA 1957). While the Columbia basin has the greatest diversion of 
water needed for fisheries, similar diversions occur each year in the other river basins of the 
Pacific Northwest that deprive fish of minimum stream flows. 

Unscreened Water Diversions 

About 3,200 priority unscreened water diversions have been identified in Oregon, of which 
approximately 1,300 are in coastal streams (Kaczynski and Palmisano 1993). It is difficult to 
assess juvenile salmonid diversion losses to agriculture and other diverted uses in the state, but 
probably billions of anadromous fish have been lost. Although not as bad, the problem with 
unscreened diversions does exist in Washington. The problem reached its peak in the Yakima 
River basin, which remained unscreened from the mid-1850s to the 1930s. Millions of 
anadromous salmonid fry and smolts were lost during this period because of unscreened 
diversions (Palmisano, Ellis, and Kaczynski 1993). 

Freshwater Fish Predation 

The size of predator populations and the numbers of predator species in the Columbia River 
basin have increased as a result of habitat modification and the introductions of exotic species. 
The populations of the endemic northern squawfish (Ptychochilus oregonensis) have increased, 
largely in response to recent changes in the environment. Most of the Columbia River basin has 
changed from a free-flowing river system to a more lake-like habitat brought about by 
construction of large dams and reservoirs. In addition, humans have recently added new 
predator species to the system. These include walleye (Srizostedion viireum), channel catfish 
(laalurus punctatus), and smallmouth bass (Micropterus dolomiem). 

Poe et al. (1991) and Rieman et al. (1988) reported that northern squawfish were the most 
important predator of outmigrant salmon and steelhead trout in John Day Reservoir on the 
Columbia River. Between 1983 and 1986, the mean annual loss of juvenile salmonids to 
predation was estimated at 2.7 million and could have ranged from 1.9 to 3.3 million fish 
(ibid.). Northern squawfish accounted for 78 percent of the total loss. As predators, walleye 
accounted for 13 percent and smallmouth bass for 9 percent of the prey consumed. Estimates 
are that the three predators consumed a mean of 14 percent of all juvenile salmonids that entered 
the reservoir; their consumption could have ranged between 9 and 19 percent of all incoming 
salmonids. These results are similar to the findings of Uremovich et al. (1980), who estimated 
that northern squawfish may have eaten 3.8 million juvenile salmonids in the forebay of 
Bonneville Dam in a 5-month period in 1980. Although no estimates of predation were given, 
TTiompson and Tufts (1967) reported that northern squawfish predation was significant on 
juvenile sockeye salmon in Lake Wenatchee, Washington. Northern squawfish are major 
predators of salmonid smolts in the Yakima River basin and in Lake Washington in Seattle. 

15 



148 



These levels of predation by northern squawfish observed at John Day Dam could be occurring 
at all major dams and reservoirs of the Columbia River system. Studies are currently in 
progress to determine the systemwide significance of this predation to the population of 
outmigrating salmonid smolts (Petersen et al. 1990). The abundance of northern squawfish has 
increased in the system, and their current predation rates on outmigrating smolts are certainly 
higher than in the past. These increases may have contributed to the decline in abundance of 
wild salmonids. 

The population of spawning American shad (Alosa sapidissima) entering the Columbia River 
remained under 200,000 until 1960. Between 1960 and 1990, the population of annual migrants 
rose sharply to more than 4 million adults (WDF and ODFW 1992). Most researchers report that 
adult American shad (normally filter feeders) do not feed during their upriver spawning 
migration. However, Chapman et al. (1991) report, citing Hammann (1981) and Wendler 
(1967), that adult American shad prey on large food items and have consumed large numbers 
of Chinook salmon. Wendler reported that one adult American shad contained 16 chinook 
salmon smolts. If each of the several million adult American shad now present seasonally in the 
Columbia River ate only a fraction of this number, the annual total loss of juvenile salmonids 
consumed by this predator alone would be in the millions. 

Freshwater Fish Competition 

The presence of markedly increased numbers of juvenile American shad in the Columbia River 
system at the same time that juvenile salmonids are present suggests that competition for 
resources is possible. Juvenile American shad are a potential competitor with juvenile chum 
salmon (a species that is very depressed) because both species are plankton feeders. And even 
though the shad is primarily a plankton feeder, the overlap of benthic prey in its diet and in the 
diets of other juvenile salmonids (such as chinook salmon, coho salmon, and steelhead trout) 
provides evidence that competition may be occurring, especially if juvenile American shad 
outnumber juvenile salmonids. The extent of spatial and temporal overlap in diets, however, 
is unknown at this time. Some overlap must occur, however, because shad are present year 
round in the estuary and are salmonid prey (Emmett et al. 1991). 

In addition, the large numbers of adult American shad in the Columbia River present a potential 
problem for salmonid migration. The abundance of this exotic species can contribute to the 
stress, injury, and mortality associated with dam passage by outmigrating salmonid smolts and 
upstream-migrating salmonid adults. Large numbers of adult American shad in the juvenile 
bypass system at McNary Dam formed a barrier to subyearling chinook salmon passage and 
contributed to mortality in the collections system in the early 1980s (Basham et al. 1982, 1983). 
Large numbers of adult American shad may also create passage problems by reducing orifice 
passage efficiency or by reducing fish guidance efficiency for juvenile salmonids in gatewells 
and turbine intakes (Chapman et al. 1991). 

The enormous quantity of adult American shad passing through the adult fish ladders could cause 
an avoidance or delay by adult salmonids. Hourly adult American shad counts at Bonneville 
Dam frequently exceed 2,000 fish, with as many as 7,550 fish per hour recorded at a single 

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station (USAGE 1982). Adult American shad migrate upstream from May to August, with the 
peak from mid-June to late July. This corresponds with the adult migrations of sockeye and 
summer Chinook salmon (Chapman et al. 1991) and could pose a passage problem for these 
species. These factors can and may already have contributed to the decline of Columbia River 
wild salmonids. 

American shad are rare in Puget Sound, but common or abundant in most of the west coast 
estuaries between the Sound and northern California (Emmett et al. 1991). However, their 
interactions with salmonids in these areas are unknown. 

Ocean Conditions 

There is mounting evidence that natural factors in the ocean environment, such as upwelling, 
sea-surface temperatures, and related El Nifio events, and biological carrying capacity determine 
ocean productivity. Reviews by Fisher and Pearcy (1992), Francis and Sibley (1991), Quinn 
and Marshall (1989), and pooper and Johnson (1992) provide confirmation that ocean and 
climatic conditions greatly affect abundance and survival of anadromous salmonids. 0»an 
productivity influences juvenile, survival rates, adult body size, and the ultimate size of returning 
populations that are available to harvest and that provide spawners for future generations 
(Gunsolus 1978; Nickelson 1986; Bakun et al. 1983). 

Ocean productivity is not constant but periodically varies between high and low levels. Levels 
of ocean productivity along the west coast of North America are influenced by the Subarctic and 
West Wind Drift Currents that flow eastward and split into the northflowing Alaska Current and 
southflowing C^ifomia Current. Recently, the California Current flow dominated through 1975 
(Pearcy 1992). Upwelling of nutrient rich near shore waters was enhanced in this period from 
southern Washington to northern California. Generally, near shore waters were cooler during 
this period. Algal and zooplankton production were high, and subsequent growth and survival 
of ocean salmonid stocks were good. 

Since 1976, the Alaska Current has dominated, and the California Current has been weaker. 
Generally, near shore waters of the (California Current have been wanner. This has been 
associated with weaker upwelling and reductions in nutrients, ocean productivity, and reduced 
survival and growth of salmonids from southern Washington through northern California (Pearcy 
1992). These recent unproductive conditions have adversely affected the abundance of coastal 
northern California and Oregon coho salmon and northern California and southern Oregon 
Chinook salmon (Lawson 1993). 

Sockeye salmon runs of Nushagak Bay, located within Bristol Bay, Alaska, have been harvested 
since the late 1800s. Catch abundance has fluctuated widely over the past century, but 
apparently not because of major changes in fishing pressure or spawner abundance 
(Zimmermann et al. 1991). Instead, sea-surface temperatures have been correlated with recent 
increases in abundance. Wanner water temperatures during the salmon's first winter at sea 
appear to be responsible for increased run size. Warmer water temperatures increase prey 
productivity as well as fish growth rates. Thus, physical factors of the marine environment can 

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influence salmonid abundance. Because of the recent dominance of the Alaska Current, Bristol 
Bay sockeye salmon harvests of the 1990s have been the largest ever recorded (Rogers 1993). 

Ocean Carrying Capacity 

Scientists have increasing amounts of evidence, that food, at times, may be limiting in the 
marine environment. We have already presented evidence that the present number of natural 
and hatchery salmonid smolts (348 million) in the Columbia River system is in excess of 
historical smolt numbers (265 million). Together with juveniles of forage and commercial 
species and the annual addition of several hundred million juvenile American shad (see above) 
to the system, the food supply may be incapable of adequately nourishing this large number of 
juvenile salmonids. 

Each year Japan, Russia, Canada, and United States release a combined total of 5 billion 
juvenile salmonids into the North Pacific Ocean (Pearcy 1992). Concern exists that continued 
releases of large numbers of hatchery-produced salmonids may be stressing the system's food 
supply. Pearcy (1992) noted that salmonid stocks from both Asia and North America acquire 
more than 95 percent of their growth in the North Pacific. Evidence from large releases of 
chum salmon from Japan and pink salmon from Alaska show that average weights and lengths 
of returning fish, both hatchery-produced and wild, have decreased significantly (ibid.; WDF 
1992). Obviously, some limit exists for the total productivity of the ocean. This should be 
considered before proposing to increase spawning and early rearing habitats in the Pacific 
Northwest. 

Although overharvesting and habitat alteration can reduce population abundance of Pacific 
Northwest wild salmonids, natural factors not controlled by human activities can also reduce 
population size. Jefferies (1975) has suggested that the ocean was limiting salmon production 
in the Oregon Production Area (OPI), which extends from Leadbetter Point, Washington, to 
Monterey Bay, California. Several authors have correlated the abundance of OPI coho salmon 
with the degree of ocean upwelling that occurs in OPI waters (Gunsolus 1978; Scamecchia 
1981). McGie (1981) suggested that the decline in abundance of Oregon coho salmon between 
1976 and 1980 resulted from density-dependent mortality caused by the release of too many 
hatchery-produced smolts during a period of reduced ocean upwelling. 

Estuaries 

Pacific Northwest estuaries provide critical habitat for salmonids (Simenstad et al. 1982) but 
there area is greatly diminished over per-development estimates. In Washington, approximately 
70 percent of Puget Sound estuaries and 40 percent of coastal estuaries have been lost or 
degraded (see Palmisano, Ellis, and Kaczynski 1993). The area of the Columbia River Estuary 
has been reduced by 40 to 50 percent (see Kaczynski and Palmisano 1993). The exact amount 
of estuarine habitat lost to development in Oregon is unknown, but could be between 25 and 40 
percent of last century's total. Of the area lost in Oregon, 90 percent was related to diking used 
to create agricultural land, and 10 percent was related to fill used to create municipal, 
commercial, and industrial lands (Boule and Bierly 1987). 



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Historically, the Columbia River estuary was an impwrtant feeding area for outmigrating 
salmonid smolts. Large changes in estuary morphology between 1867 and 1958, such as 
navigational improvements, and diking and filling of much wetland areas (Sherwood et al. 1990), 
have changed the estuary food base. Adverse changes in wetland habitat include an estimated 
82 percent reduction in emergent plant production and a 15 percent reduction in benthic 
macroscopic algae. At present, much detritus in the system is derived from phytoplanioon, 
rather than from macroscopic algae. Phytoplankton has had a fourfold increase in the system 
because of large reservoirs created by dams on the Columbia and Snake rivers (Simenstad et al. 
1990). 

In recent food base studies in the Columbia River estuary, Simenstad et al. (1990) found 
suspension-feeding epibenthic zooplankton associated with micro-detritus accounted for 83 
percent of total estuarine primary consumption while benthic herbivores, including insects that 
were associated with macro-detritus of the estuary's wetlands, accounted for only 2 to 17 percent 
of this consumption. Such a shift in the food base from macro-detrital consumption to micro- 
detrital consumption means that about 83 percent of preferred prey of outmigrating salmonid 
smolts has been lost from the estuary since navigational modifications have occurred. Such a 
reduction in food is likely a major contributor to poor ocean survival of juvenile salmonids and 
to recent declines in numbers of adult salmonids returning to the Columbia-Snake River system. 

Marine Mammal Predation 

Since 1972, the Marine Mammal Protection Act (U.S. Depanment of Commerce 1988) in the 
United States (and similar legislation in Canada) has defended marine mammal species from 
harvest and harassment by humans. In the absence of hunting by commercial fishermen and 
bounty hunters, populations of several of these predators have steadily increased in the Pacific 
Northwest at an annual rate of 3 to 12 percent (NMFS 1992). 

The harbor seal (Phoca vitulina), California sea lion (Zalophus califomianus), and killer whale 
(Orcinus orca) are three species of salmonid predators whose populations have increased from 
3 to 12 percent per year over the last two decades (Olesiuk et al. 1990a; Olesiuk and Bigg 1988; 
Olesiuk et al. 1988). Olesiuk et al. (1990a) and Olesiuk and Bigg (1988) estimated that harbor 
seal populations in British Columbia have increased at an annual rate of 12.5 p)ercent. In 1970, 
the population was estimated at 9,000 to 10,500 animals; by 1988 it had increased to 75,(X)0 to 
88,000. At the time of their study they believed that the population may have been at or near 
carrying capacity and that numbers were near or actually exceeded historic levels. The Oregon 
population increased from about 4,000-5000 seals in 1984 (Brown 1988) to about 9,500-12,200 
in 1992 (Huber et al. 1993) while the Washington population increased from about 2,(XX) in 
1972 (Newby 1973) to almost 38,000 in 1992 (Huber et al. 1993). 

The West Coast population of California sea lions, from Mexico to Canada, is about 180,000 
animals (U.S. Depanment of Commerce 1988). This includes about 67,000 sea lions in the U.S. 
population that has increased at an annual rate of 6 percent over the last decade (Boveng 1988). 
Killer whale populations in coastal waters of British Columbia and Washington increased from 
about 190 animals in the early 1970s to about 240 in 1986 (Olesiuk et al. 1988). While marine 

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mammals have always preyed on salmon, recent increases in marine mammal numbers may be 
causing increased levels of predation. Northern or Stellar seal lions {Eumeiopias jubcaus) and 
northern fur seals (Callorhinus ursinus) are known salmonid predators whose numbers have not 
increased since 1972 (Antonelis et al. 1984; Olesiukand Bigg 1988; Antonelisand Perez 1984). 

Marine mammals prey on adult, subadult, and juvenile salmonids (Olesiuk and Bigg 1988; 
Olesiuk et al. 1990b; Antonelis and Perez 1984; Perez et al. 1990; Kajimura et al. 1980). Seals 
and sea lions follow migrating adult salmonids well into freshwater environments. Bite marks, 
scratches, and scars attributable to either sea lions or harbor seals have been observed on 
upstream-migrating spring chinook salmon in the Snake River. Chapman et al. (1991) estimated 
that 19 percent of fish passing Columbia River dams in 1990 had "seal marks." An estimated 
40 to 50 percent of observed adult spring chinook salmon ascending the fish ladder at Lower 
Granite Dam on the Snake River in 1990 had teeth marks and scars attributable to pinnipeds, 
i.e. seals and sea lions (Harmon and Matthews 1990). Recent observations represent a 
significant increase over those of past years. Everitt et al. (1981) reported that only 0.4 percent 
of almost 330,000 salmonids of four species examined by fish counters at Bonneville Dam on 
the Columbia River had marks attributed to seals during 1980. 

Killer whales are known to prey on marine mammals and fish although certain groups feed 
exclusively on fish. Resident killer whale populations occur in nearshore waters of Washington 
and British Columbia known to have high seasonal abundance of Columbia-Snake River 
salmonids. Consumption of these salmonids by killer whales has possibly increased since the 
Marine Mammal Protection Act of 1972. 

Seals and sea lions may have consumed an estimated total of 91 1,200 salmonids in Washington 
during both 1989 and 1990. TTiis was equivalent to 1 1 percent of the commercial catch in 1989 
and to 18 percent in 1990 (Palmisano, Ellis, and Kaczynski 1993). An estimated 43,000 to 
129,(X)0 additional salmonids may have been lost to the fishery by seal and sea lion damage to 
gill-net-trapped fish in 1989, and between 29,000 and 87,500 may have been lost to these 
marine-mammal-related factors in 1990. Total salmonid losses caused by marine mammals in 
both 1989 and 1990 were about 1 million fish. This was about 12 percent of the total 
commercial catch for 1989 and 19 percent for 1990. 

Seals and sea lions consumed an estimated total of 313,500 to 320,500 adult salmonids in 
Oregon in 1990. This was about 89 percent of the total ocean commercial catch for the year or 
about 30 percent of Oregon's 1990 total sport and commercial catch (Kaczynski and Palmisano 
1993). An additional 12,3(X) to 15,400 salmonids were lost to the fishery from seal and sea lion 
net predation and from seal bites. 

Estimated annual total consumption of salmonids by seals and sea lions in nearshore waters is 
more than 2 million pwunds in Oregon (Kaczynski and Palmisano 1993), 6 million pounds in 
Washington (Palmisano, Ellis, and Kaczynski 1993), and 2 million pounds in southwestern 
British Columbia (Olesiuk and Bigg 1988; Olesiuk et al. 1990). The 10 million pounds of 
salmonids consumed were mostly adults and, at an average weight of about 6 to 7 pounds, 

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rq)resented about 1.5 million fish. 



Estimated annual consumption of salmonids by northern fur seals in offshore waters of Oregon- 
Washington is 8.5 million pounds (Antonelis and Perez, 1984). In addition, individual 
salmonids eaten by northern fur seals were subadults that had an average weight of 0.8 pounds 
(Perez et al. 1990; Kajimura et al. 1980). Thus, northern fur seals consume about 10.5 million 
young salmonids off the coast of Oregon and Washington each year. Combined commercial and 
sport salmonid harvests from Washington, Oregon, and Idaho are less than 10 million fish 
annually (Kaczynski and Palmisano 1993; Palmisano, Ellis, and Kaczynski 1993). Total salmonid 
consumption from Oregon to sputhwest British Columbia by these few species of pinnipeds is 
estimated at 12 million fish annually. An additional unreported amount of marine mammal 
predation of salmonids occurs in the rest of British Columbia and Alaska each year. 

Sea Bird Predation 

Beginning in the 1970s, federal protection of marine bird populations caused similar increases 
in predator species known to Iprey on salmonid fish. These include species such as cormorants 
(Phalacrocorax spp.), grebes (Aechmophorus sp. and Podiccps spp.), and alcids (Alcidae), which 
are excellent divers and can readily capture salmonids in the estuarine and marine environment. 
Alcid predators, which include auklets {Cerorhinca, Aethia, and Ptyhoramphus), murres (Uria 
spp.), murrelets {Brachyramphus and Symhliboramphus), gillemots {Cepphus spp.), and puffins 
(Fratcrcula and Lunda), feed on smolts in nearshore waters. Manuwal (1977) presented food 
habits data for a breeding population of Rhinoceros auklets (Cerorhinca monocerata) in 
Washington and estimated that about 5 percent of the prey biomass was juvenile salmon. 
Mathews (1983) reported that the common murre (JJria aalge) can consume six salmonid smolts 
per day. Thus, the estimated 40,000 birds that occur off the Oregon coast each spring could 
account for the loss of 7 million smolts for each month that their presence coincides with ocean 
arrival of Columbia River and southern Washington salmonid smolts. In addition, the marbled 
murrelet {Brachyramphus marmoratum) recently listed as a threatened species under the 
Endangered Species Act, feeds on salmonid smolts at sea. 

Cormorants, especially double-crested cormorants {Phalacrocorax auriyus) prey on juvenile 
salmonids. Of 12,500 double-crested cormorants that occur in Oregon, over 50 percent occur 
in the lower Columbia River (Lowe 1992). These birds have an average weight of 4.5 pounds. 
Each bird will consume about 15 percent of its body weight per day, or about 0.7 pounds of fish 
(ibid.). During the 35 to 42 day nesting period each spring, daily weight of fish consumed is 
doubled by feeding demands of adult and young birds. The nesting period coincides with early 
downstream arrival of salmonid smolts from the Columbia-Snake River system. Other species, 
such as pelagic {P. pelagicus) and Brandt's {P. penicillatus) cormorants, feed on smolts in the 
estuary but are more abundant in the ocean environment. 

Marine Competition 

Compeuiion exists in nature when a resource, such as food or habitat, is limited. Fresh et al. 
(1984) suggested that food is a limiting factor for salmon growth and survival during marine life. 
The recent increase in the population size of pinnipeds off the Washington coast, and of 

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American shad in the Columbia River, suggest that these species (whose diets overlap with that 
of salmonids) may be competing with saJmonids for a limited food resource. 

Seals, sea lions, (Olesiuk and Bigg 1988) and maturing salmon, such as chinook and coho (Hart 
1973), commonly prefer Pacific herring {Clupea pallasi) and Northern anchovy (Engraulis 
mordax). Northern fur seals that feed off the coast of Oregon and Washington consume 13 
million pounds of Pacific herring and 9 million pounds of Northern anchovy each year 
(Antonelis and Perez 1984). Annually, seals and sea lions combined (excluding northern fur 
seals) consume an estimated 24 million pounds of Pacific herring off Washington (Palmisano, 
Ellis, and Kaczynski 1993), about 10.6 million pounds off Oregon (Kaczynski and Palmisano 
1993), and over 12 million pounds in extreme southwestern coastal British Columbia (Olesiuk 
et al. 1990; Olesiuk and Bigg 1988). At an efficiency rate of 10 percent, this nearly 70 million 
pounds of Pacific herring might have produced about 7 million pounds of salmon. At an average 
weight of 6 to 7 pounds per fish, this could be more than 1 million salmon. An unknown but 
possibly comparable amount of bait fish are consumed by all seal and sea lion populations off 
the coast northern California, Alaska, and the rest of British Columbia. 

Other dietary overlaps occur, in addition to Pacific herring and Northern anchovy, between 
marine mammals and salmonids. These include prey such as smelt, sardine, sandlance, and 
squid. Recent increases in seal and sea lion numbers could cause significant competitive 
interactions with salmonids in years of poor ocean biological production. 



7) Non-Habitat Issues 

Most of the non-habitat issues that influence the abundance of salmonid stocks are related to 
fisheries management practices and policies. A concentration of effort in this area, rather than 
in restoration projects, could produce meaningful increases in abundance in a relatively short 
time and at minimal administrative financial cost. Proposed management activities include 
cessation of foreign interception of U.S. stocks, elimination of preterminal mixed-stock fisheries, 
stringent enforcement of harvest regulations, annual attainment of agency established spawning 
escapement goals, and hatchery production practices that are complimentary with wild stocks. 

Canadian Interception of Pacific Northwest Salmon 

According to a report by Natural Resources Consultants, Inc. (NRC 1992), a significant number 
of Washington and Oregon stocks of chinook and coho salmon were harvested away from their 
area of origin between 1987 and 1990 (see Tables 5 and 6). These stocks were intercepted 
predominately by Canadian but also by other northwest fisheries, including those in Alaska and 
off the coasts of Washington and Oregon. These losses include total marine mortality, i.e., 
commercial catch plus incidental fishing mortality. However, they do not include sport catch and 
its related incidental mortality. 

These interception rates have had a significant impact on the total harvest rates of these U.S. 

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Table 5. Average 1987-90 Total Marine Mortality (Catch plus Incidental 
Mortality) of Chinook Salmon by Production Region and Nation (in 
numbers of Hsh) ^ 



Number of Chinook 
Region of Origin 


U.S. 


Canada 


Total Regional 
Harvest by Area 
of Origin 


Puget Sound 


373,002 


288,182 


661,184 


Washington Coast 


107,405 


27,838 


135,243 


Oregon Coast 


92,606 


74,467 


167,073 


Lx)wer Columbia 


421,307 


206,244 


627,551 


Mid-Columbia 


479,507 


221,000 


700,507 


Snake 


8,013 


3,997 


12,010 


Total by Nation 


1,481,840 


821,728 


2,303,568 


Percent of Chinook 
Region of Origin 


U.S. 


Canada 


Percent of Total 
Regional Harvest 
by Area of Origin 


Puget Sound 


56% 


44% 


29% 


Washington Coast 


79% 


21% 


6% 


Oregon Coast 


55% 


45% 


7% 


Lower Columbia 


67% 


33% 


27% 


Mid-Columbia 


68% 


32% 


30% 


Snake 


67% 


33% 


1% 


Total by Nation 


64% -- 


36%- 


100% 



Source: NRC 1992. 



stocks and have no doubt contributed to reduced escapement and run declines. And although 
these data are for recent years, it is likely that these high interception rates have occurred as 
long as there have been preterminal, mixed stock fisheries in the Northeast Pacific Ocean. 

Between 1987 and 1990, the average annual Canadian commercial harvest of these U.S. stocks 
was about 1.4 million coho salmon and 0.8 million chinook salmon. The reported Canadian 



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Table 6. Average 1988-90 Total Marine Mortality (Catch plus Incidental 
Mortality) of Coho Salmon by Production Region and Nation (in numbers 
of fish) 



Number of Coho 
Region of Origin 


U.S. 


Canada 


Total Regional 
Harvest by Area 
of Origin 


Puget Sound 


453,334 


737,854 


1,191,188 


Washington Coast 


623,623 


449,282 


1,072,905 


Oregon Coast 


130,338 


120,410 


250,748 


Lower Columbia 


393,351 


16,156 


409,507 


Mid-Columbia 


924,490 


58,021 


982,511 


Snake 











Total by Nation 


2,525,136 


1,381,723 


3,906,859 


Percent of Coho 
Region of Origin 


U.S. 


Canada 


Percent of Total 
Regional Harvest 
by Area of Origin 


Puget Sound 


38% 


62% 


30% 


Washington Coast 


58% 


42% 


27% 


Oregon Coast 


52% 


48% 


6% 


Lower Columbia 


96% 


4% 


10% 


Mid-Columbia 


94% 


6% 


25% 


Snake 











Total by Nation 


65% 


35% 


100% 1 


Source: NRC 1992. 



harvest represented about 35 percent of the total harvest of these coho and chinook salmon 
stocks. Total Canadian harvest is substantially higher. The recreational harvests of coho and 
Chinook salmon off the west coast of Vancouver Island are not reported by the Canadian 
government (NRC 1992). Additional Washington fish are intercepted by Alaskan sport and 
commercial fisheries. 



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Between 1988 and 1990, Canadian fisheries harvested an annual average of 52 percent of the 
harvested coho salmon originating from the Washington coast and Puget Sound (NRC 1992). 
Canadian fisheries intercepted more coho salmon of north Puget Sound origin (62 percent) than 
U.S. fisheries (38 percent). Canadian fisheries had nearly as high interceptions of south Puget 
Sound and Washington coast coho salmon (42 percent and 48 percent, respectively). These 
fisheries intercepted only 6 percent of the Columbia River coho salmon. 

Between 1987 and 1990, Canadian fisheries annually intercepted almost 40 percent of the 
harvestable chinook salmon produced from the Washington coast and Puget Sound. These 
fisheries harvested a larger percentage of chinook salmon originating in Puget Sound (44 
percent), the lower Columbia River (33 percent), and the mid-Columbia River (32 percent) and 
a lower percentage of Washington coastal chinook salmon stocks (22 percent). 

High Seas Interception of Pacific Northwest Salmonids 

Information gained from American observers on foreign fishing vessels off the coasts of Oregon, 
Washington, and California between 1977 and 1980 showed that incidental salmon catches 
annually ranged from 6,000 to 15,000 fish (ODFW 1982). More than 90 percent of the catch 
was Chinook salmon. The remaining species composition, by order of abundance, included coho 
salmon, other salmon, and steelhead trout. There was no division of the catch by state. 

Recently, an unknown number of salmon and steelhead trout have been incidently caught by both 
legal and illegal high seas driftnet fisheries in the western North Pacific Ocean by fishing fleets 
from east Asian countries. Estimates of the legal incidental catch of salmonids are believed to 
have been small since a monitoring program began in 1989 (Pella et al. 1993). However, 
substantial salmonid interception occurs during illegal fishing, and salmonid interceptions by 
non-salmon producing countries were estimataJ to have been at least 10,0(X) metric tons (5.5 
million fish) in 1988 (ibid.). Total salmonid mortality (bycatch plus dropouts) in the Japanese 
squid drifmet fishery was estimated to be between 231,000 and 181,000 fish in 1990 (ibid.). The 
Washington State Department of Wildlife (Cooper and Johnson 1992) believes that a significant 
number of Pacific Northwest steelhead trout may be lost to these high seas fisheries. These 
illegal harvest could account for the apparent coast-wide decline in steelhead trout abundance 
that has occurred over the last several years (ibid.). Thus, there is concern that illegal catches 
of salmonids in the North Pacific could potentially affect declining, endangered, or threatened 
stocks. 

Mixed-Stock (Preterminal) Fisheries Issues 

The intermingling of several species and stocks of anadromous salmonids in the ocean, or in the 
lower reaches of a river, creates the potential for a mixed-stock fishery. Mixed-stock fisheries 
contain a dynamic mixture of species and stocks, age and maturity groups within and among 
species and stocks, hatchery- and naturally produced fish, weak and strong runs, and small and 
large runs. From a socioeconomic perspective, mixed-stock fisheries contain both positive and 
negative aspects. From a management and biological perspective, however, they have primarily 
a negative or, at best, a neutral aspect. 



25 



78-799 0-94-6 



158 



Because the stocks are intermingled, a mixed-stock fishery harvests all stocks of a species at 
about the same rate in the proportion of their mix. If all stocks are of equal condition, then each 
will experience approximately the same rate of harvest and there will be no adverse biological 
effects if fishing regulations are followed. If, however, the stocks are unequal, which is 
generally the case in the Pacific Northwest, then a mixed-stock fishery will harvest strong and 
weak stocks at the same rate. If harvested at the same rate, strong stocks will survive while 
weaker stocks will decline further and possibly become extinct. Obviously, from a management 
and biological perspective, the latter situation is undesirable and destructive. Thus, fishing 
mixed stocks of unequal condition makes it impossible to control the catch and the spawning 
escapement that is required by both the stronger and the weaker stocks to ensure their continued 
existence and to provide optimum yield for the fishery. 

Mixed-stock fisheries occur in the Pacific Northwest ocean troll fisheries. They occur to a 
lesser extent in the lower Columbia River commercial fishery and in the upper Columbia River 
Treaty fishery where individual stocks start returning to their natal streams. It is easy to 
understand how declining stocks, such as fall Chinook salmon, can be depleted in an ocean 
mixed-stock fishery containing them and more stable stocks. However, more subtle effects of 
a mixed-stock fishery, such as one that favors the hatchery component over the wild component 
of a species, are not always immediately obvious. 

The Columbia River coho salmon run, which has about 5 percent wild fish, is managed for 
maximum production of the hatchery component (Cramer et al., 1991). There is little effort by 
the agencies to regulate the ocean fishery to protect wild and natural Columbia River coho 
salmon (ibid.). In fact, the high harvest rates allowed have effectively eliminated any remanent 
native population of coho salmon (NMFS 1991). However, because this run is managed to 
maximize harvest production, its overall estimated harvest rate (in the ocean and in the lower 
river) has been allowed to range between 75 and 94 percent between 1961 and 1991, for an 
annual average rate of 88 percent (ibid.). By comparison, the allowable harvest rate to achieve 
maximum sustainable yield (MSY) for wild coho salmon in Washington and Oregon is between 
40 and 69 percent (ODFW 1982). While hatchery coho salmon can survive a harvest rate of 
88 percent, it certainly is excessive for the continued survival of wild coho salmon, whose 
harvest rate should be closer to zero if the population is to survive. At this rate, there are too 
few wild spawners escaping the fishery to perpetuate the population. Thus, this mixed-stock 
fishery has significantly contributed to the decline of wild coho salmon in Washington and 
Oregon. 

Indirect Fisheries Mortality 

Some harvest methods and gear used in salmonid fisheries of the Pacific Northwest are an 
indirect cause of fish mortality. The troll, gill-net, and sport fisheries have associated mortality 
rates. Shaker loss has been identified as die principal indirect cause of salmonid mortality by 
the commercial and sport troll fisheries (Ricker 1976). This occurs when undersized or 
nontargeted species of fish are removed or "shaken" from the hook and released, or when the 
speed of the boat causes the hook to be pulled from the mouth of small fish. The resulting 
injury and stress frequently result in mortality. Hook scarring or other nonfatal damage also 

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occurs that can lead to impaired feeding or behavioral changes. 

Shaker loss in ocean fisheries was extensively reviewed by Ricker (ibid.), who concluded that 
one additional fish is killed for every two legal fish landed and reported (i.e., 50 percent 
additional mortality). Boydston (1972) estimated the shaker mortality in the troll catch off 
northern C:alifomia to be equivalent to 43 percent of the reported chinook catch. The U.S. Fish 
and Wildlife Service (1983) uses a shaker mortality rate for Klamath River fall chinook in 
northern California equivalent to 40 percent of the reported catch. Recent studies of the ocean 
troll fishery in Alaska (Wertheimer 1988) estimated a hooking mortality rate of about 25 percent 
for Chinook salmon. This is close to the percentage estimated by PFMC for Washington and 
Oregon troll fisheries. PFMC assumes a shaker mortality of 30 percent from the use of barbed 
hooks and 26 percent from barbless hooks (Coon 1992). 

PFMC (1991) estimates that an annual hooking mortality between 1984 and 1989 has ranged 
from 25, (XX) to 1CX),0(X) co^o salmon in the Oregon Production Index (OPI) fishery south of the 
Columbia River. The average annual ocean commercial catch of coho salmon in Oregon during 
this period was about 300,000 fish (ibid.). Based on these data, the mortality rate was between 
8 and 33 percent of the catch. In 1990, 74,000 coho salmon were estimated to have been lost 
to hooking mortality. Based on the 1990 Oregon ocean commercial coho salmon catch of 
300,000 coho salmon, this gave a mortality rate of 25 percent. 

For 1990, PFMC (1991) estimated a hooking mortality of 4,100 coho salmon in the chinook 
salmon fishery between the U.S. -Canada border and (Jape Falcon that caught 63, (XX) chinook 
salmon. This is an incidence rate of 7 percent. No estimate was given for chinook salmon, or 
for pink salmon whose abundance would be low during an even-numbered year in Washington. 

The values presented above suggest that shaker mortality in the ocean commercial troll fishery 
could be between 10 and 30 percent. Because coho salmon are half as abundant off Washington 
as in the OPI, their encounters during chinook and coho salmon fisheries would be lower than 
in Oregon. From this information, we conservatively estimated a shaker mortality rate for the 
Washington ocean commercial troll fishery of between 5 and 15 percent. 

Dropout loss is an indirect adverse effect on salmonids from the commercial gill-net fisheries 
of Washington. Fish that become tangled in gill nets may escape but be injured or stressed to 
the point that subsequent mortality occurs. Fish that have died in the nets may also fall out and 
be lost. Chapman et al. (1991) report that the Klamath River Technical Team assumed that 3C 
percent of salmon dropping out of nets would subsequently die. The team estimated that this 
represented a total unrecorded mortality of about 8 percent caused by gill nets. CH2M HILL 
(1985) reported that dropout mortality of chinook salmon in the Klamath River gill-net fishery 
was about 12 percent. The Washington Department of Fisheries assumed that dropout mortality 
caused by gill nets used in Puget Sound was about 4 percent (Cramer et al. 1991). 

Management Obiectives 

To sustain any exploited fishery, harvest levels (catch) must be limited and the number of adults 

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escaping the fishery to spawn (spawning escapement) must be maximized. Historically, this has 
not occurred in the world's commercial fisheries. Almost every major fishery, whether 
freshwater, anadromous, or marine, has declined because of overfishing. This is illustrated best, 
not by examples of decline of traditional fish stocks, many of which have freshwater and 
estuarine habitat requirements, but by the near extinction of marine mammal species, which have 
no estuarine or freshwater habitat requirements and whose stocks were depleted long before the 
major development of the twentieth century, such as the great whales and the sea otter. Thus, 
these marine mammals were driven to the brink of extinction not because of habitat destruction 
or degradation, but simply because of overexploitation. 

Overharvest 

Today, the majority of salmonid stocks in the Pacific Northwest are overharvested. Optimal 
harvest rates, depending upon the stocks and species in question, range between 40 and 70 
percent. Yet many of our stocks are harvested at rates in excess of 80 and 90 percent (Table 
7). While terminal harvest rates are generally within accepted values, ocean harvest rates cause 
total rates to be unacceptable. The main problem is from the ocean interception of Puget Sound 
and Columbia River coho and Chinook salmon stocks. Any restoration plan that did not demand 
that optimal harvest levels be met and try to eliminate mixed-stock ocean fisheries would 
therefore not be increasing the number of additional spawners needed to recover dwindling 
stocks. Such a plan, if successful, would at best, increase the number of fish to be 
overharvested, and not increase the number of returning adult spawners. 

Underescapement 

Because of overharvesting, an insufficient number of adults are returning to spawn in the region. 
Analysis of annual spawning escapement data collected in the Pacific Northwest between 1969 
and 1984 suggested that salmonid escapement trends were down (Gunsolus 1978; Konkel and 
Mclntyre 1987). This appeared true for the Puget Sound, Oregon and Washington coastal 
rivers, and Columbia River basins. 

Agency established annual spawning escapement goals have not been met for the majority of 
northwest stocks for the last several years of records. Unless assurances are made to continually 
meet these goals, any gains made in habitat restoration will be wasted. There will be fewer 
returning adult fish to spawn in these areas, and the progeny of those that do spawn will have 
a greater chance of being harvested than of spawning. 

The recent history of spawning escapement in the Pacific Northwest demonstrates how 
infrequently spawning escapement goals are met. Of 113 wild salmonids stocks in Washington 
with established spawning escapement goals, only 46 (41 percent) were in compliance between 
1987 and 1990 (Table 8). In 1990, spawning escapement goals were met for only three of eight 
populations (38 percent) of wild anadromous salmonids in the Columbia River and Oregon. In 
Oregon, for example, since the rebuilding schedule for coastal coho salmon was started in 1979, 
the escapement goal has been met in only half of the 12 years. The varying goal of 135,000 to 
200,000 adults was met only in its initial year of 1986. Based on long-term monitoring in 
standard survey areas, the annual spawning escapement estimated to achieve maximum sustainable 

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Table 7. Optimum and Realized Harvest Rates for Washington Coastal, 
Puget Sound, and Columbia River Salmonid Stocks between 1989 and 1990 

OPTIMUM HARVEST GOALS FOR WILD SALMONIDS: 40 TO 75% 

Recent Harvest Rates 



1 Washington Stocks 


Ocean 


Terminal 


Total 


Coastal Chinook 


48% 


34% 


65% 


Coastal Coho 


51% 


44% 


71% 


Puget Sound Chinook 


71% 


61% 


87% 


Puget Sound Coho 


62% 


72% 


92% 


Puget Sound Pink 


- 


37% 


(37%) 


Puget Sound Chum 


— 


70% 


(70%) 


Total Steelhead 


- 


69% 


(69%) 



Recent Harvest Rates 



Columbia River Stocks 


Ocean 
Canada 


Ocean 
US 


Ocean 
Total 


Columbia 
River 


Total 
Harvest 


Lower River Fall Chinook 


37% 


61% 


79% 


32% 


87% 


Upper River Fall Chinook 


32% 


61% 


80% 


50% 


93% 


Coho 


6% 


56% 


64% 


55% 


89% 



Note: Harvest rates across columns are not additive; the rates depict the percentage of total 
available fish per stock harvested at each fishery location. 

Source: Palmisano, Ellis, and Kaczynski 1993. 



yield has not occurred since 1971 (PFMC 1992). Annual estimates of escapement since 1970 
range from a low of 59,800 adults in 1983 to a high of 324,000 in 1971. As stated earlier, 
spawning escapement in recent years may have been as low as 15,00 adult fish annually, because 
of errors (that overestimated escapement up to 500 percent in some years) in the methods use 
to predict escapement. Although exhibiting some fluctuations over time, the trend in escapement 
has generally been downward since 1971. Data from Cooney and Jacobs (1990) show that the 
trend has been downward since the early 1950s. 



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Table 8. Percentages (and Numbers) of Wild Salmonid Runs, by Species and 
Major Washington Fishery Areas, That Were in Compliance with 
Established Spawning Escapement Goals in the Last Years of Record (i.e., 
1985-89, 1990, or 1991) 



Species Coast Puget Sound' Columbia Total 

River 


Pink 


- 


56% 
(5/9) 


- 


56% 
(5/9) 


Chinook 


89% 
(8/9) 


29% 
(4/14) 


50% 
(2/4) 


52% 
(14/27) 


Chum 


- 


45% 
(13/29) 


- 


45% 
(13/29) 


Sockeye 


: 


0% 
(0/2) 


100% 
(1/1) 


33% 
(1/3) 


Coho 


80% 
(4/5) 


8% 
(2/25) 


_ 


20% 
(6/30) 


Total salmon 


86% 
(12/14) 


30% 
(24/79) 


60% 
(3/5) 


40% 
(39/98) 


Steelhead 


80% 
(4/5) 


25% 
(2/8) 


50% 
(1/2) 


47% 
(7/15) 


Total 
salmonids 


84% 
(16/19) 


30% 
(26/87) 


57% 
(4/7) 


41% 
(46/113) 


•Includes Strait of Juan de Fuca. 



Source: Palmisano, Ellis, and Kaczynski 1993. 



Reduced Fish Size 

Fishing regulations and gear create selective pressures on salmonid populations that skew size 
and age structure. Harvests now occur earlier in the season and farther at sea. Fishing gear, 
which continues to evolve, tends to select for larger fish. These pressures may have reduced 
the size and age of adult fish returning to spawn in Washington waters. Thus, the predominance 
of smaller and younger fish now present in the populations may have adversely affected the 
migration and spawning capabilities of the stocks. In addition, earlier and more seaward 
harvests catch significant numbers of immature feeding fish. This practice causes the loss of 



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significant remaining growth potential and a loss to the commercial markets. Coho salmon, for 
example, may gain as much weight while feeding during their last summer at sea as they gained 
in their first 2 years of life (Smith 1920). 

The average size of commercially harvested salmon in Washington, for example, decreased by 
almost 23 percent between 1935 and 1989 (Table 9). Over this 55-year period, coho salmon 
decreased in weight by almost 30 percent, chinook salmon by more than 24 percent, pink salmon 
by 19 percent, and sockeye salmon by more than 13 percent. It is interesting to note that chum 
salmon, a species not caught extensively by hook-and-line gear, did not decrease in weight over 
this period. Wright (1992) reports that chinook salmon in Washington are only about one-half 
their historical average size and that coho salmon have declined about 3 pounds in average size 
since the early 1950s. It is unknown how the introduction of hatchery fish into the fishery has 
contributed to reduced body size 

Table 9. Measured Average Weight (in pounds) and Percent Change of 
Five Species of Pacific Salmon Commercially Caught in Washington' 
between 1935 and 1989 



Time Period 


Coho Chinook 


Pink 


Sockeye 


Chum 


Total 


1935-39 


8.8 


19.7 


5.7 


6.6 


10.0 


8.4 


1940s 


8.8 


19.7 


5.8 


6.0 


10.0 


8.1 


1950s 


8.6 


16.4 


5.8 


6.3 


11.7 


7.8 


1960s 


7.8 


16.3 


5.3 


5.8 


10.5 


7.4 


1970s 


7.2 


15.3 


5.3 


6.0 


10.9 


7.5 


1980s 


6.2 


14.9 


4.7 


5.7 


10.3 


6.5 


1935-1989 


-29.5% 


-24.4% 


-19.0% 


-13.6% 


+2.9% 


-22.6% 


Change 














' Coast, Puget S< 


>und, and Columbia Rive 


r. 








Source: WDF 


1991. 











Fecundity is directly related to fish size. Larger fish produce more eggs. Thus, a 20 to 50 
percent reduction in body size, even if the population size remained constant over time, could 
cause a significant reduction in fish productivity and subsequent stock abundance. And if 
population size were also declining with body size, then the resultant decline in fish abundance 
could be catastrophic. 

Larger body size of mature fish can also increase the potential for successful spawning. Larger 
females can construct deeper redds with larger materials. These practices can ensure higher egg 
survival during both flood events and low-flow conditions. Larger fish have more muscle and 
stored body fat that will enable them to more successfully travel long distances upstream to their 
natal spawning grounds. Larger body size not only increases the success of a long migration, 
but it also helps adults to pass stream barriers successfully. It may also aid in predator 



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164 



ivoidance and in survival from episodes of infectious diseases. These are important factors for 
upper Columbia and Snake River fish that have to swim through warm waters and ascend several 
fish ladders on their upstream migration. 

Fish Hatcheries 

Artificial propagation has often been seen as a way to maintain and increase, or augment fish 
stocks that have suffered from habitat loss and overexploitation. Newly gained in-sights of 
hatchery-produced fish, based on observations and scientific data, suggest that these programs 
not only may fail, but may pose the greatest single threat to the long-term maintenance of 
salmonids in the Pacific Northwest (Hilbom 1992; Meffe 1992). 

Because fish stocks used in the Pacific Northwest for artificial propagation have not always been 
matched to the environmental and genetic requirements of the wild stocks they replaced, many 
hatchery-produced fish are unfit or maladapted to survive in the wild. Thus, if hatchery 
produced fish are allowed to breed with wild stocks, the genetic strain of the resulting progeny 
may not always be sufficient to ensure the continued survival of the stock. 

Hatchery-produced fish are daily fed to satiation before released. Thus they are larger and can 
often outcompete their wild counterparts of the same age. This may cause fewer wild fish to 
return as adults, thus further diluting the gene pool required for wild stock survival. Finally, 
because hatchery-reared fish are spared the rigors of nature during early development and 
rearing, their survival rates are greater than that of wild fish. 

Survival rates for hatchery-produced fish are about 80 percent compared to 2-10 percent for wild 
fish reared under natural conditions. This allows harvest rates of 80-90 percent for hatchery- 
produced fish versus 40-75 percent for wild fish. If both stocks occur together in the fishery 
(mixed-stock fishery) that is fished at the harvest rale of the hatchery-produced fish, the wild 
stocks will be over fished. If these mixed stocks are fished at the wild-stock rates, too many 
hatchery-produced fish will escape the fishery. These excess fish may not be needed at the 
hatchery and could escape or be intentionally released to spawn with the wild stocks, further 
reducing the adaptability of wild fish to the natural environment. 

Thus, to overcome the problems caused by past hatchery practices, concerted fisheries 
management efforts have to be made today to use hatchery production programs that are 
complementary to wild fish populations. 



8) The Plan's True Objective 

While the primary goal of the plan is to improve salmonid spawning habitat and juvenile 
survival, its ultimate objective, apparently, is to increase the number of adults that return to 
spawn - and thus perpetuate the species. Thus, the best test of any restoration plan is the 
number of additional spawners that it ultimately produces. Therefore, survival has to be 
increased at all life history stages to ensure the production of spawners above pre-plan numbers, 

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165 



or the plan will fail. Nothing is gained if initially more young fish are produced only to then 
parish before a significant number return as adult spawners. 

Obviously, to succeed the plan has to be balanced over the fishes' complete life cycle. Under 
a balanced plan, if factors that limit salmonid abundance are within human control, changes 
could be made to ensure the plans's success. For example, water withdrawals may have to be 
reduced and minimum year-round stream flows established. For factors beyond human control, 
such as the level of ocean productivity, or for factors that humans prefer not to control, such 
as increasing growth rate of marine mammal populations, harvest levels could be adjusted to 
insure the plan's success. None of these options are included in the proposed plan. Without 
them, increases in salmonid abundance appear unlikely. 

Is the true purpose of the plan the creation of more salmon to ensure perpetuation of the species, 
or is it the creation of more fish to harvest? This has ecological, economic, political, and ethical 
overtones, because some groups may benefit from the plan while others will be unaffected or 
harmed. If the true purpose of the plan is ecological, i.e. to save and perpetuate the fish, than 
all harvesting should stop temporarily. However, if the true purpose is to create more fish to 
harvest, then it is inequitable if some groups gain from the plan while others suffer. It appears 
that the plan is designed so that groups that eventually will take the most fish have the 
government keep all other groups from taking any fish. If the groups that are prohibited from 
taking fish, or even adversely affecting the fish's habitat, suffer under the plan, then they should 
be compensated by the government or the group that eventually harvests the most fish. 
Otherwise, the groups prohibited from taking fish are subsidizing the harvest groups. 



9) Role Of Federal Resource Agencies In Salmonid Recovery 

USFS and BLM 

Trees are rooted plants while salmon are migratory fish. This obvious distinction helps explain 
the roles of USFS and BLM in the management of these two natural resource. While managers 
of forested lands have jurisdiction and control over the complete life cycle of trees, their role 
in salmon management is generally restricted to providing protection and habitat for fish that 
spawn and rear on their lands. In addition, because these agencies are required to manage their 
lands for multiple uses, such as timber, wildlife, water, and recreation, they must balance the 
needs of salmon with those of the other resources. 

Under present management plans, USFS and BLM must rely on the downstream assistance of 
other resource and government agencies, and of public land owners as well, to ensure continued 
survival of salmon stocks that leave forested areas. Without this cooperation, any efforts to 
increase salmon survival by forest managers is wasted if responsible water-use, land-use, and 
fisheries management practices do not occur in downstream areas. To date, this cooperation has 
not always occurred. Better cooperation would be needed for any salmonid restoration plans 
developed for federal forests, otherwise theses plans too would fail. This cooperation, however, 
is not mandated or requested in the plan. 

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166 



USPS and BLM administrators must be aware of the limitation of salmon production in today's 
forested habitats, and they should not attempt, or be expected, to achieve more than is capable 
from the streams on their lands for present or future fisheries management plans. Faleral 
forested lands that remain in the Pacific Northwest are at higher elevations, and their streams 
have steeper gradients than most of the forested lands that provided salmon habitat prior to 
human development of the region. Historically, the most productive salmon habitats were in 
river floodplains and in streams with low gradients, generally up to 2 percent. Today, little, if 
any, of these prime habitats remain. Most have been lost to navigation and flood control 
projects, and to transportation, agricultural, municipal, industrial, and recreational development. 
Therefore, it is unrealistic to expect restoration projects in forested lands to achieve the historical 
productive capacity of the altered or lost habitats of the floodplains and low gradient streams, 
especially if fish loose all protection once they leave federal lands. 

Other Federal Agencies 

Salmonid recovery efforts of other federal agencies, such as the National Marine Fisheries 
Service, Environmental Protection Agency, U.S. Fish and Wildlife Service, and the Corps of 
Engineers, are not restricted to forested federal lands. These agencies have the jurisdiction to 
protect U.S. stocks of anadromous salmonids and their habitats throughout the fishes' range. 
These agencies have to supplement USFS and BLM actions on forested lands and be more 
proactive in non-habitat issues to reduce foreign interception, domestic overharvest, freshwater 
migration related stress and mortalities, and to ensure annual compliance with agency established 
spawning escapement goals. 



10) Society's Role In Salmonid Recovery 

It is unrealistic to expect the same level of salmon resources in the 1990s as occurred in the 
1890s. Development in the Pacific Northwest has altered or destroyed the historical productive 
capacity of salmon in the region. However, if and when salmon restoration plans are 
implemented, the degree of restriction proposed for various human activities should be 
proportional to the adverse affect that each has on salmon survival. In other words, the plan 
should be equitable. To date, this has not been proposed. 

Society accepts a certain amount of salmon mortality, or "take," for various human activities and 
practices. Ironically, the level of "take" seems directly proportional to the dependency of the 
activity on the aquatic environment. Water-use practices are allowed more take than land-use 
practices. Commercial fisherman are allowed to take from 40 to over 90 percent of returning 
adult fish, depending on the species and heredity (wild or hatchery-produced) of the catch. They 
are permitted to waste an additional amount equivalent to 10-40 percent of the catch in indirect 
or incidental losses caused by the fishing methods and processes they use, such as "shaker" 
mortality in hook-and-line troll fisheries, drop out in gillnet fisheries, etc. The river projects 
that generate electricity for industry and human use are permitted to kill, at each facility in the 
Columbia-Snake River basin, between 5 and 10 percent of upstream migrating adults and 



34 



between 15 and 30 percent of the downstream migrating smolts. Water withdrawals were 
allowed to operate for years from salmon-bearing waters without the use of screens that would 
keep fish from being removed from the water and killed. In Oregon alone, unscreened 
diversions accounted for the loss of billions of salmon fry and smolts during the recent past. 

Cederholm and Reid (1987) have astutely accurately observed that much of the economy of the 
Pacific Northwest is based on logging and fishing, two industries whose raw materials are 
inextricably linked. If these industries are to remain compatible, both must be managed to 
minimize the impact on the other. Therefore, to restrict logging practices that may adversely 
impact fisheries while failing to limit the fishery harvest to insure adequate escapement of adult 
spawners, does not insure the sustainability of the fishery resource. Obviously, there as to be 
a balance between the two. 



11) Ecological Assessment of Take 

Mortality rates are naturally high for salmonids. Under ideal natural conditions, less than 10 
percent of newly hatched fish will return to spawn. Survival rates of less than 1 percent are not 
uncommon. For a population to maintain itself, one spawning pair must return to replace their 
parents. Depending on the species, one female salmon will produce form 1,500 to 6,000 eggs 
(Bell 1973). The return of one spawning pair per female for this range of egg production 
represents a survival rate of only 0.033 to 0. 13 percent. For a population to grow or to avoid 
extinction, survival from each year's young must be greater than one spawning pair for each 
previous spawner. These additional survivors provide insurance against the random events of 
nature that could seriously deplete the numbers of potential spawners and start the population 
on a downward decline towards extinction. 

If human influences increase the number of mortalities above the natural level, than fish 
populations will decline, even become extinct. If, however, human actions cause the death of 
fish that would have died naturally, but do not increase mortality among the fish that would 
normally survive in nature, then there would be no net increase in mortality attributable to man. 
Mortality caused by man or nature, if not too severe, can actually reduce competition for food 
or habitat among surviving salmonids (Wood 1987). This is the well-documented ecological 
tenet of density-dependent growth and survival. It is not possible, however, to always determine 
whether human induced mortality is above or within natural background levels. 

The ecological and genetic impact of mortality to the population is not the same for each age- 
class of fish. Because juveniles are relatively abundant and several years from sexual maturity, 
their death is not as costly to the population as that of less abundant adults that are weeks or 
days away from spawning. Juveniles are more expendable than adults because they do not have 
the "investment' of time and growth that adults have, nor the proof that they contain the genetic 
traits that are required to survive to adulthood and that would have survival value if inherited 
by the next generation. In addition, mortality rates decrease with increasing fish size and 
experience. Smaller, less experienced fish are more likely to die. 

35 



168 



Adult fish are relatively rare, have a naturally low mortality rate, are proven survivors, and are 
ready to spawn. In contrast, juvenile fish are relatively abundant, have a high natural mortality 
rate, have untested potential, and are sexually immature. This suggests that adults are 
ecologically more valuable than juveniles, and accordingly that juvenile are more expendable. 
Potentially, then, the mortality of adult salmonids harvested (or overharvested) may be more 
ecologically damaging to the population than a similar level of mortality experienced by eggs 
or juveniles. Yet harvest rates of adult salmonids that exceed optimal catch levels and prevent 
adequate escapement of spawners are condoned in the Pacific Northwest while land-use practices 
that have any measurable adverse affect on salmonids eggs or young are not tolerated. 



12) Recommendations 

Rather than solely embarking on an expensive, long-term stream habitat restoration project, 
federal administrators should aJso extend their influence, efforts, time, money, etc. on a 
comprehensive, balanced plan that also includes addressing management factors that will adjust 
harvest levels to reflect natural fluctuations in climate, ocean productivity, and populations of 
marine predators and competitors; and that will minimize foreign harvests, preterminal mixed- 
stock fisheries, domestic harvest levels, and f)oor hatchery practices. Similarly, they should 
promote water-use practices that will minimize juvenile and adult mortality and maximize annual 
stream flows; and promoted fisheries management practices that minimize competition and 
predation from introduced freshwater fish species and maximize spawning escapement. 

If required, stream habitat restoration projects should be primarily limited to areas of high 
productivity, i.e., low-gradient, lowland, and floodplain streams, and estuaries on federal lands; 
or the government should purchase, rent, or acquire easements for nonfederal lands. Without 
a balanced plan, they will be unable to assess their contribution, if any, to salmonid recovery. 
Finally, the federal forests have a role to play in salmonid restoration. The role should be in 
balance with other measures that have a higher probability of success. 



36 



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178 

WRITTEN STATEMENT FOR THE RECORD 
OF 

DR. WILLIAM MCKILLOP 

PROFESSOR OF FOREST ECONOMICS 

COLLEGE OF NATURAL RESOURCES 

UNIVERSITY OF CALIFORNIA, BERKELEY 

HEARING ON THE ADMINISTRATION'S 
FORESTRY PLAN FOR THE PACIFIC NORTHWEST 

BEFORE THE 

SPECL\LTY CROPS AND NATURAL RESOURCES 

SUBCOMMITTTEE 

OF THE 

AGRICULTURE COMMITTEE 

UNITED STATES HOUSE OF REPRESENTATIVES 

NOVEMBER 18, 1993 



Introduction 

My name is Dr. William McKillop. I am Professor of Forest Economics in the College 
of Natural Resources, University of California, Berkeley. I have authored over 100 
research publications and conference papers in the area of forest and natural resource 
economics. Prior to joining the UC Berkeley faculty in 1964, 1 was a research officer 
with the Canadian Forestry Service. In addition, I have undertaken temporary 
assignments with a number of national and international organizations, including the 
United Nations and the U.S.D.A. Forest Service. A major focus of my research and 
teaching is analysis of the forest economy of California and the Pacific Northwest. 
Recently, I have engaged in a number of activities related to the effects of restricting 
timber output in the region, including a study for the State of Washington, service as an 
expert witness for the U.S. Bureau of Land Management in its Spotted Owl petition to 
the Endangered Species Committee, and Chair of the Oregon Lands Coalition Socio- 
economic Panel which reviewed President Clinton's Forest Plan. 



179 



An Economic Analysis of the FEMAT Report 

William McKillop, Professor of Forest Ekronomics 
College of Natural Resources, University of California, Berkeley 

November 18, 1993 

Executive summary 

This analysis focuses on the treatment by the FEMAT report (Forest Ecosystem 
Management Assessment Team, 1993) of economic issues relating to: (a) outlook for 
government revenues, (b) effects on U.S. consumers, and (c) regional non-timber 
activities such as recreation and tourism, service employment in forestry, marketing of 
special forest products, and commercial fisheries. 

Baseline harvest levels 

The charge to FEMAT and other Working Groups did not require them to gauge the 
social and economic costs of various options by comparing them to a baseline 
alternative which reflected concern for local communities and regional economies. 

The most appropriate baseline period for assessing the deficiencies of the FEMAT 
options is the ten-year period, 1980 through 1989. 

Reductions in timber outputs 

FEMAT option 9 calls for a federal scheduled timber harvest level in the owl region of 
1.084 billion board feet (Bbf) per year. This is lower by 3.440 Bbf (76 percent) than 
the 1980-89 average federal harvest level of 4.524 Bbf 

FEMAT assumes that the three-state owl region net timber harvest decrease under 
option 9 will be 3.065 billion board feet because nonfederal harvests will rise in 
response to decreases in the federal cut. This assumption is untenable. Environmental 
constraints and lack of mature growing stock will prevent increases in the overall level 
of private harvests. 

Decreases in regional employment and income 

The 3.440 billion board feet reduction in federal timber harvests indicated by option 9 
will result in the loss of 34 thousand jobs in the timber industry and a loss of 38 
thousand other jobs in Washington, Oregon and California, for a total loss in 
employment of 72 thousand jobs. 

There will be a corresponding reduction in regional income of $1.7 billion per year. 



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The above estimates do not include job losses due to reductions in reforestation and 
other silvicultural activities. Olson and Maid included the effect of those reductions in 
their estimate of 81.5 thousand lost jobs. 



Losses to federal, state and local government 

The loss in net timber sale receipts to the U.S. Treasury will be $289 million per year 
under option 9. 

Option 9 will result in a reduction in federal payments in-lieu-of-taxes to counties and 
school districts of $209 million per year. 

There will be losses of over $5 million per year in sales taxes and over $6 million p>er 
year in timber yield (excise) taxes in California and Washington. 

State personal and business income tax receipts will decrease by $56 million per year. 
Federal income tax receipts will drop by $117 million per year. 

Unemployment compensation payments to cover laid-off workers for a twelve-month 
period will be $746 million. Costs of supplementary programs to assist the unemployed 
will be additional and substantial. 

Consumer losses 

Data in the FEMAT report permit a conservative estimate of longer term losses to U.S. 
consumers under option 9 of $1.2 billion per year because of higher timber prices. 

In the shorter term, annual losses to consumers because of higher lumber and plywood 
prices will be almost $3 billion in each of the next several years. 

If timber outputs in other regions do not increase in response to the decline in West 
Coast harvests, as FEMAT suggests, the annual $3 billion consumer loss could 
continue indefinitely. 

Aggregate national losses 

Aggregate national losses due to decrease in regional income and losses to consumers 
from higher wood product prices will amount to $4.6 billion per year in the initial 
years of the implementation of option 9. This level of aggregate loss could continue 
indefinitely if other regions are unable to increase timber output to partially compensate 
for the reduction in Pacific Coast timber harvests. 



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Land allocations 



The argument that the economic benefits of timber harvesting on the National Forests 
can be replaced by economic benefits from increased recreation or by setting aside 
more areas where timber harvesting is banned or severely restricted is false. 

FEMAT attributes to its proposed alternatives, economic effects of government 
expenditures that are more readily justifiable or more feasible under policies that permit 
1980-89 levels of timber sales to continue. 

Timber harvesting is already precluded on 6.98 million acres of Congressionally- 
withdrawn federal land which is 29 percent of the 24.26 million acres of federal land 
within the range of the Northern spotted owl. 

Harvesting is also precluded on 1.65 million acres that were administratively 
withdrawn during earlier forest planning efforts. 

These Congressional and administrative withdrawals, totaling 8.63 million acres (36 
percent of the total federal acres) represent a substantial prior commitment to 
preserving natural ecosystems on the public forests. 

According to the draft environmental impact statement, 9.28 million acres will be 
withdrawn from timber production to provide "late-successional reserves" and "riparian 
reserves", in addition to 8.63 million acres in Congressionally and administratively 
withdrawn status. 

f 

Timber harvesting will thus be precluded on 17.91 million acres (74 percent) of 
federal lands in the owl region, and will be subject to intense regulation on the 
remaining acreage. 

On-site recreation 

FEMAT claims that there will be advantages to increasing non-motorized recreation 
opportunities at the expense of recreation opportunities that are motorized or require 
vehicular access. This claim is based on estimates of values (average willingness-to- 
pay) per visit whose reliability and validity are highly suspect. 

FEMAT uses a value per daily visit of $35.86 for hiking, biking, horsebacking and 
other "nonmotorized visits". It is inconceivable that this type of recreationist would be 
willing to pay such a large fee per daily visit. 

Optimal allocation of forestland should be based on the benefits that are provided per 
acre in each use. On the basis of recreational value per acre, the FEMAT report shows 
that vehicular-based recreation is a superior form of land use. 



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The vast majority of persons who use the National Forests require roads for pursuing 
fishing, hunting and general recreation activities; and most back-country users need 
access by road to the trailhead. Without timber harvesting, most National Forest roads 
would not have been built. 

Vehicular-based recreation and timber harvesting are joint and complementary uses of 
the federal forests. FEMAT's promotion of nonmotorized recreation opportunities does 
not make a legitimate contribution to its arguments for adopting option 9. 

Sport fishing 

FEMAT is distinctly misleading in its attempt to imply that current timber harvesting 
creates a problem with regard to fish habitat. The effect on fisheries of the proposed 
FEMAT alternatives will be little different than would occur with maintenance of 
timber sales programs at the 1980-89 level. 

Tourism 

FEMAT is similarly misleading in its attempt to create the impression that its 
alternatives will increase tourism. An objective appraisal would find that its alternatives 
will have no significant beneficial effect relative to recent policies. 

FEMAT discusses jobs created by tourism and sport fishing under prior forest plans as 
if they were to be created by its proposed alternatives. This is improper. 

FEMAT fails to acknowledge that the bulk of recreationists on BLM and U.S. Forest 
Service forestland are regional residents. An increase in attendance at new or expanded 
recreation areas will come mainly through reduction in attendance at other areas. Thus 
there will be no net increase in overall economic benefits to the region from levels of 
recreation under the FEMAT alternatives as implied in the report. 

Service employment in forestry 

FEMAT correctly notes that the decline in timber harvesting under its alternatives will 
"greatly diminish the need for forestry services workers" for reforestation and timber 
stand improvement work. 

It claims that wildlife surveys and watershed assessments, as well as "some 
recommendations for watershed restoration and forest stand improvement will likely 
help offset some of the declines in the forestry services sector - and potentially increase 
employment in the sector". It improper to suggest that these activities will increase 
employment in the sector. 

FEMAT notes that costs for these projects would be substantial. No meaningfiil 
analysis has been made of potential funding sources . The fact that these projects have 



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183 



not been undertaken in the past indicates that they were not competitive in the budget 
allocation process. It is obvious, in the face of continuing federal budget deficits and 
reduced timber revenues, that they will be substantially less competitive in the future. 

Furthermore, wage scales for employment on forest rehabilitation projects are much 
less than timber industry rates so there is very little chance that such projects will 
provide meaningful opportunities for the many thousands of laid-off timber workers. 

Special forest products 

It is unlikely that the overall supply of special forest products such as floral greens, 
Christmas ornamentals and wild edible mushrooms will increase under FEMAT's 
options. 

FEMAT fails to acknowledge that timber and many special products are 
complementary rather than competitive in their production and that special products 
harvesters require access by road to successfully pursue their activities. Thus the 
FEMAT options may reduce, rather than increase, the overall level of activity in the 
special forest products industry. 

Commercial fisheries 

FEMAT says that improved watershed and management policies may aid fish stocks in 
the longer term. A more accurate statement would be that current logging and road- 
building practices do not significantly affect fish habitat and that watershed 
improvements could be undertaken without reducing recent levels of timber harvest. 

As early as 1968, Van Hyning pointed out that an increase in ocean fishing was the 
major factor in the decline of the fall chinook run. Kaczynski and Palmisano (1992) 
indicate that modem timber harvesting practices have a very minor effect on salmon 
stocks. 

Quality of life 

FEMAT discusses quality of life in the Pacific Northwest but fails to recognize that the 
most important element in determining quality of life is to have a job and to provide for 
one's family. 



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Table of contents 



Executive summary 2 

Introduction 8 

Outlook for government revenues 8 

Baseline harvest levels 8 

Reductions in timber output under FEMAT option 9 9 

Decreases in regional employment and income 9 

Revenue losses 10 

Effects on U.S. consumers 12 

Alternatives to timber harvesting 13 

Introduction 13 

On-site recreation 14 

Weakness of FEMAT estimates of recreation values 15 

Defects of FEMAT analysis of recreation needs 16 

Sport fishing 17 

Tourism 17 

Service employment in forestry 18 

Special forest products 19 

Other commodity production 20 

Commercial fisheries 20 

Quality of life 21 

Conclusion 21 

Literature cited 22 



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Introduction 

This analysis focuses on the treatment by the FEMAT report (Forest Ecosystem 
Management Assessment Team, 1993) of economic issues relating to: (a) outlook for 
government revenues, (b) effects on U.S. consumers, and (c) regional non-timber 
activities such as recreation and tourism, service employment in forestry, marketing of 
special forest products, and commercial fisheries. 



Outlook for government revenues 

Baseline harvest levels — - 

A major change in the ability of the federal agencies to manage lands under their 
jurisdiction within the range of the Northern spotted owl occurred in 1989 with the 
decision of the U.S. District Court for Western Washington regarding of the adequacy 
of the U.S. Forest Service environmental impact statement for its spotted owl 
management option. Therefore, the most appropriate baseline period for assessing the 
effects of FEMAT options/alternatives is the ten-year period, 1980 through 1989. 

The period 1980-89 contains a range of highs and lows in forest product markets. It is 
equivalent in length to the 10-year period used by the U.S. Forest Service in 
calculating decade-by-decade sustainable levels of allowable sale quantities on the 
National Forests. 

Federal timber harvesting in the period 1980-89 was conducted under comprehensive 
and detailed land use plans of the U.S. Forest Service and U.S. Bureau of Land 
Management which ensured a supply of timber on a sustained yield basis, and struck a 
balance between protecting natural ecosystems and meeting the obligations of these 
agencies to support local and regional economies. 

After 1989, in response to political pressures as well as court decisions, the U.S. Forest 
Service and Bureau of Land Management initiated substantial replanning efforts. It is 
important that the baseline alternative does not include the effects of these replanning 
efforts so that the full cumulative impacts of policy changes can be properly assessed. 

U.S. Forest Service Region 6 harvest levels in 1980-89 have been incorrectly 
characterized as record highs. Average harvests of the 1960's and the 1970' s were 
higher than during the 1980' s (Rasmussen 1993). 

It is improper to claim that existing Forest Service management plans significantly 
overestimated the amount of timber available for harvest, and prescribed high harvest 
levels that could not be sustained. Harvest levels projected in existing plans were 



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sustainable, given the land allocations permitted prior to court decisions (Rasmussen 
1993a). 

Reductions in timber output under FEMAT option 9 

FEMAT option 9 calls for a federal scheduled timber harvest level in the owl region of 
1.084 billion board feet (Bbf) per year. This is lower by 3.440 Bbf (76 percent) than 
the 1980-89 average harvest level of 4.524 Bbf (Forest Ecosystem Management 
Assessment Team 1993). 

The FEMAT report implies that, if the federal cut is reduced, nonfederal harvest levels 
will increase in response. Close familiarity with California conditions indicates there 
will be no nonfederal increase in that state (Krumland and McKillop 1990). Analyses 
by Rasmussen (1993a, 1993b) properly conclude that there will be no significant 
increase in nonfederal timber harvests in Oregon and Washington in response to the 
decline in federal output. 

Among the factors limiting the first decade allowable sale quantities (ASQs) calculated 
for the recently completed NFMA forest options is the fact that the national forests 
have an unbalanced age class distribution. Under a non-declining harvest constraint, 
harvest during the first decade can be limited by the number of acres available for 
harvest in the future. Withdrawing a large number of additional acres for late- 
successional reserves and riparian reserves will likely exacerbate the effects of an 
unbalanced age class distribution (Rasmussen 1993a). 

FEMAT option 9 refers to an average federal cut of 1.2 biUion board feet per year. 
This is based on the addition to the 1.084 Bbf mentioned above of some 116 mUlion 
board feet of unscheduled timber harvest such as salvage cuts. This 1 16 million bf is 
not included in this analysis because information, such as its probable location, has not 
been made available. 

This analysis is, however, conservative with respect to the effect of the drop in harvest 
because it does not consider the lower quality of timber that will be produced under 
option 9 relative to that which was harvested in the 1980-89 period. FEMAT estimates 
of employment per million bf (FEMAT table VI- 14) are based on timber harvest and 
employment data for 1989-90. Timber harvested under the option 9 will provide less 
employment per million bf than timber harvested in 1989-90. The lower quality of 
timber will also dampen rises in stumpage prices anticipated by FEMAT. 

Decreases in regional employment and income 

Using sub-regional estimates of timber industry employment per million board feet of 
timber harvested in FEMAT table VI-14, it is estimated that the 3.440 Bbf net 
reduction in cut called for by option 9 will result in the loss of 34 thousand jobs in the 



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timber industry. The July 1, 1993 White House announcement of President Clinton's 
forest plan said that it "will directly impact 6,000 jobs". It appears that this 6 thousand 
job loss was derived by comparing the option to some alternative that already had 
incorporated in it a major degree of damage to the economy of the owl region, rather 
than comparing it to an alternative that represented a balance between biological and 
socio-economic concerns. In Washington, Oregon and California, timber industry job 
losses due to the option will be 7.4, 23.8 and 2.6 thousand respectively. These 
estimates do not include losses in employment due to reductions in reforestation and 
other silvicultural activities. 

The FEMAT report uses an employment multiplier of 2. 122, indicating that each 
timber industry job supports just over one other "nonbasic" job in the rest of the 
economy. Use of this multiplier shows that FEMAT option 9 will lead to a loss of 38 
thousand nontimber jobs and a total employment loss relative to 1980-89 of 72 
thousand jobs in the regional economy. In Washington, Oregon and California, total 
job losses due to the option will be 16, 50 and 6 thousand respectively. 

Olson and Maid (1993) estimate that 81.5 thousand jobs will be lost under option 9. 
Their analysis included the loss of 6 thousand direct jobs and 6.7 thousand indirect jobs 
due to reduced activity in the forestry services sector. Addition of job losses in this 
sector would significantly increase the estimate of 72 thousand lost jobs derived above. 

Data provided by Rasmussen et al. (1991) on average annual earnings per job in 
Washington, Oregon and California were used to estimate that FEMAT option 9 will 
lead to a reduction in payrolls of $1.6 billion per year for the three states combined. 
Losses to the individual states will be $393, 1092 and 130 million respectively. 

Reduction in total regional income will be exacerbated because of a loss in proprietors' 
income and net coiporate earnings of some $58 million per year. The total loss in 
regional income will thus be almost $1.7 bilUon per year. 

Revenue losses 

Neither the DSEIS (U.S. Forest Service and U.S. Bureau of Land Management 1993) 
nor the FEMAT Report (Forest Ecosystem Management Assessment Team 1993) 
provide information on 1980-89 average levels of gross and net timber receipts or 
disbursements to local governments in the owl region. However, reports by the U.S. 
Forest Service (1992), and the U.S. Bureau of Land Management (1992) permit 
estimates to be made of these levels for the 1986-90 period. FEMAT estimates that 
FEMAT option 9 will generate $355 million in gross annual timber sale receipts. This 
is $690 million less per year than was generated in 1986-90. 

The loss in net receipts to the U.S. Treasury is estimated to be $290 million per year 
under the assumption that timber sales costs per million feet do not increase under 



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FEMAT option 9. In fact, these costs will undoubtedly be much higher than they were 
in 1980-89. As a result, the loss to the Treasury will be significantly greater than $290 
million per year. 

FEMAT estimates that federal payments "in-lieu of taxes" (PILT) to local governments 
(counties and school districts) under FEMAT option 9 will be $110 million per year. In 
1986-90, they averaged approximately $319 million per year. The option, therefore, 
will result in a loss in revenue to counties and school districts from this source of $209 
million per year relative to 1986-90. In Washington, Oregon and California, annual 
PILT losses will be $26, 172 and 12 million respectively. 

Losses in revenues from sales taxes, timber yield taxes, property taxes, personal 
income taxes and corporate income taxes are not estimated by the DSEIS or the 
FEMAT report but they, also, will be substantial. For example, on the basis of 
McKillop and Spriggs (1993) it is estimated that there will be losses of approximately 
$5 million per year in sales taxes and $6 million per year in timber yield (excise) taxes 
in California and Washington. (These taxes are not levied in Oregon). 

Annual reductions in personal and corporate income tax payments will also be 
substantial. Based on McKillop et al. (1993), it is conservatively estimated that 
FEMAT option 9 wiU result in reductions in state personal income tax receipts of $51.1 
million per year in Oregon and $0.3 million per year in California. (Washington does 
not have a state personal income tax). Losses in state business tax receipts will be $1.7 
million in Washington, $2.4 million in Oregon and $0.2 million in California. 

Based on McKillop et al. (1993), it is conservatively estimated that FEMAT option 9 
will result in reductions in federal personal income tax receipts of $101 million per year 
for the three-state region. Losses in federal corporate income tax receipts will be $16.3 
million per year. 

Accentuating the burden of tax revenue losses, will be substantial increases in 
governmental costs to assist persons rendered unemployed by option 9. For example, 
on the basis of McKillop and Spriggs (1993), it is estimated that unemployment 
compensation payments to cover laid-off workers for a twelve-month period will be 
$660 million. In Washington, Oregon and California payments will be $163, 525 and 
58 million respectively. These amounts do not include costs of supplementary 
programs to assist the unemployed. Such costs will be substantial. 



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Effects on U.S. consumers 

On page VI-38 FEMAT gives a very brief discussion of increased costs to consumers. 
Because consumer surplus is included in FEMAT estimates of recreational values, an 
objective, scientific analysis would include estimates of losses in consumer surplus to 
buyers of wood products, but FEMAT pays no attention to this aspect. 

Although the FEMAT report fails to provide an estimate of aggregate losses to 
consumers it contains some information to permit an approximate estimate of them. 

As Schmalensee (1971 and 1976) indicates, losses in consumer welfare resulting from 
increases in wood prices may be estimated using changes in markets for primary goods 
such as standing timber (stumpage). The FEMAT report shows estimates of timber 
prices from runs of the TAMM model (Haynes and Adams 1985) for federal harvest 
levels of 1.0 and 2.5 Bbf. This is a 1.5 Bbf difference in "cut. FEMAT option 9 
reduction relative to the 1980-89 average will be more than twice that. A price change 
of twice the difference in prices for these alternative TAMM runs will be used as an 
estimate of the effect of the option on stumpage markets. An estimate of the resulting 
loss to consumers is obtained by multiplying this price change by the 1980-89 average 
harvest level (McKillop 1974). This results in a conservative estimate of losses to 
consumers of wood products at the national level of $1.2 billion per year in the first 
decade. Additional losses will occur in succeeding years. 

The above estimate of consumer loss is based on analyses which assume that increases 
in lumber shipments from other regions will offset the decline in West Coast production 
to a significant extent. Even if such an increase is possible it will take time for 
adjustments to occur. An estimate of immediate losses to consumers because of the 
restriction in federal timber supply may be obtained in the following alternative way. 
Random Lengths (1993) provides monthly average composite prices for framing lumber 
in the U.S. (This underestimates the average price for all categories of lumber). The 
unweighted average increase in this composite price for January through April of 1993 
versus 1992 was $136 per thousand board feet (Mbf). The level of U.S. softwood 
lumber consumption for this period in 1993 was 14.653 billion board feet, and the 
levels of U.S. housing starts for the first part of the year are similar for 1992 and 1993 
(Western Wood Products Association 1993). A conservative estimate of the consequent 
loss to consumers in the January - April, 1993 period is obtained by multiplying the 
price increase by the level of consumption (McKillop 1974). The consumer loss for the 
four month period is therefore estimated to be $2 billion. 

The first four months of 1993 contained a spike in lumber prices due to the traumatic 
effects of court decisions and actions by federal agencies. By May, lumber markets had 
settled down and the average price for May, June and July 1993 was only $51 per Mbf 
greater than for the same period in 1992. This $51 increase will be used as a measure 
of the medium term effect of timber sales restrictions in California, Oregon and 



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Washington. TAMM model runs suggest that the average annual level of U.S. 
softwood lumber consumption for the next decade will be approximately 48 billion , 
board feet. On this basis, it is estimated that the annual loss to consumers will be 
approximately $2.46 billion in each of the next several years. If timber outputs in other 
regions do not increase in response to the decline in West Coast harvests, as FEMAT 
suggests, this level of loss could continue indefinitely. 

The above estimates reflect increases in only softwood lumber prices. There will also 
be a significant loss in consumer welfare due to increases in softwood plywood prices. 
The Random Lengths average price for 3/8" exterior CD plywood was used to estimate 
the effect on national plywood prices. This price for May, June and July 1993 was $27 
per thousand square feet (Msf) greater than for the same period in 1992. TAMM model 
runs suggest that the average annual level of U.S. softwood plywood consumption for 
the next decade will be approximately 18 billion board feet. On this basis, it is 
estimated that the annual loss to consumers will be $490 million in each of the next 
several years. 

The total loss to consumers from increases in softwood lumber and plywood prices will 
therefore be $2.95 billion per year over the next several years, or beyond if other 
regions are unable to make up the losses in output that will occur in the Northern 
spotted owl region. 



Alternatives to timber harvesting 



Introduction 



An attempt has made in recent years to argue that the economic benefits of timber 
harvesting on the National Forests can be replaced by economic benefits from increased 
recreation or by setting aside more areas where timber harvesting is banned or severely 
restricted. This argument is false but FEMAT attempts to use it to claim that there will 
be detectable increases in regional economic activity due to its proposed alternatives. 

In its attempt, FEMAT violates the basic principle of economic analysis that 
assessments of change should be "ceteris paribus" (holding other things equal). It 
attributes to its proposed alternatives, economic effects that were already taking place 
under prior forest options. It also attributes to its proposed alternatives, economic 
effects of government expenditures that are more readily justifiable or more feasible 
under policies that permit 1980-89 levels of timber sales to continue because they can 
be funded out of timber revenues rather than by increasing federal borrowing. 

Timber harvesting is already precluded on 6.98 million acres of Congressionally- 
withdrawn federal land which is 29 percent of the 24.26 million acres of the federal 
land within the range of the Northern spotted owl. Harvesting is also already precluded 



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on 1.65 million acres that were administratively withdrawn during earlier forest 
planning efforts (U.S. Forest Service and U.S. Bureau of Land Management 1993). 

These Congressional and administrative withdrawals, totaling 8.63 million acres (36 
percent of the total federal acres), represent a substantial prior commitment to 
preserving natural ecosystems on the public forests. 

Furthermore, over the last twenty years or more, regulations governing timber 
harvesting and road building on federal lands have become increasingly more stringent 
to ensure adequate protection for water quality, fish habitat and soil productivity. Land 
use options that were in force prior to 1989 cannot legitimately be characterized as 
promoting timber production without regard to other values. 

Under FEMAT option 9, 9.28 million acres will be withdrawn from timber production 
to provide "late-successional reserves" and "riparian reserves", in addition to the 8.63 
million acres in Congressionally and administratively withdrawn status. 

Timber harvesting will thus be precluded on 17.91 million acres (74 percent) of 
federal lands in the owl region, and will be subject to intense regulation on the 
remaining acreage. 

On-site recreation 

FEMAT page 11-62 says that "Policies that provide more recreation opportunities that 
are deemed in short-supply could bolster the region's tourism. This primarily means 
offering more opportunities for primitive and semiprimitive nonmotorized activities." 

FEMAT page 11-62 also says that "Retirement of road systems within some Key 
Watersheds as part of watershed restoration activities could thus provide side benefits 
for recreation and tourism." 

FEMAT page 11-62 says that "Because we currently fail to fuUy charge for recreational 
use of the forest, we tend to understate the value of recreation outputs. Recreation fees, 
while contentious with much of the public, could provide a source of replacement 
revenues to the agencies and the local governments. Traditionally, much of the 
recreation improvement had been funded out of timber receipts. With declining 
receipts, charges may be required to guarantee a continual offering of public recreation 
opportunities." 

Referring to noncommodity outputs, FEMAT page VI-16 says "While these outputs 
may not have a direct economic value as expressed through market prices, they are 
valued by society and can lead to tangible economic returns through tourism and 
through increasing attractiveness of the region to new firms." 



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On page VI- 16 FEMAT claims there is an "excess supply of ...more developed 

motorized forms of recreation" and that "Forests of the region appear to be 

providing less of the primitive and semiprimitive nonmotorized than is desired by forest 
recreationists". FEMAT appears to base these claims on estimates in tables VI-7, 8 
and 9, which are derived from an unpublished draft report prepared for FEMAT by 
Swanson and Loomis (1993) and made available to the public in mid-September 1993. 
The values per visit used by Swanson and Loomis are based on RPA program estimates 
(U.S. Forest Service 1990) which in turn are based on a 1984 report by Sorg and 
Loomis. Their reliability and validity are highly suspect. 

Weakness of FEMAT estimates of recreation values 

Table VI-7 lists a value per daily visit of $35.86 for hiking, biking, horsebacking and 
other "nonmotorized visits". This value per daily visit is obviously an estimate of 
average willingness-to-pay because it is multiplied by 10.803 million visits in 1990 to 
get a total annual value of $213,429 million. (Expenditures by these recreationists, over 
and above willingness-to-pay, is listed as $8.53 per visit, for a total annual expenditure 
of $92. 150 million. Those expenditures are presumably for purchases made in 
conjunction with the recreational activity). 

It is distinctly implausible, in fact inconceivable, that this type of recreationist would be 
willing to pay such a large fee per daily visit. It should also be noted that willingness- 
to-pay values incorporate consumer surplus which is the net benefit derived by the 
consumer after paying any fee that may be charged. Because recreational on the federal 
forests are mostly provided free, the values in tables VI-7, 8 and 9 are made up almost 
entirely of consumer surplus. 

In FEMAT table VI-7, motorized sightseeing and exploring is given a value of only 
$4.00 per visit; boating, canoeing and rafting only $6.00; and swimming and wading 
only $3.00 per visit. 

The information in FEMAT tables VI-7, 8 and 9 comes from the Swanson and Loomis 
(1993) report. The Swanson and Loomis data is, as noted, is taken from the 1990 U.S. 
Forest Service RPA "program" report. The data in the RPA report come from a 1984 
publication by Sorg and Loomis which describes Sorg as a wildlife biologist with the 
U.S. Forest Service and Loomis as an economist with the U.S. Fish and Wildlife 
Service. 

The Sorg and Loomis publication is essentially a review of willingness-to-pay estimates 
from various, quite disparate studies. Wilderness values, for example, were drawn 
from a 1982 study by Walsh and Gilliam in the Indian Peaks Wilderness Area in 
Colorado, a 1981 study by Walsh et al. for Colorado, 1979 and 1980 studies by 
Loomis for southern Utah, a 1978 study by Smith and Kopp for the Ventana 
Wilderness in central California, and a 1979 study by Brown and Plummer for the 



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Glacier Peaks, Goat Rocks, Diamond Peaks and Eagle Cap areas of Washington and 
Oregon. Walsh and Gilliam used contingent valuation; the others used the travel cost 
method. 

Table VI-8 shows acres required per visit for various types of recreation and values per 
acre assigned to each type. In spite of the use of an implausibly high value per visit for 
nonmotorized versus motorized recreation, table VI-8 shows that the value per acre for 
primitive recreation is only $1.01 and only $2.45 for semiprimitive nonmotorized 
recreation. Semiprimitive motorized and "roaded natural" recreation on the other hand 
show a value per acre of $7.35 and $9. 18 respectively. 

Forest land is a resource to be allocated among different uses (including both 
commodity and noncommodity uses) for the benefit of society. Optimal allocation of 
land should be based on the benefits that are provided per acre in each use. On the 
basis of recreational value per acre, table VI-8 shows that vehicular-based recreation is 
a superior form of land use. 

Defects of FEMAT analysis of recreation needs 

In arguing the case for increasing recreational opportunities of the primitive and 
semiprimitive nonmotorized type, FEMAT relies on statements by Swanson and 
Loomis (1993) which are based on reports such as the Oregon Statewide 
Comprehensive Outdoor Recreation Plan (SCORP). 

SCORP-type estimates of recreation needs were based on a recreation demand survey 
of households in Oregon, Washington and Idaho. Settings for location of recreation 
were listed as "primitive/semi-primitive", "roaded natural", "roaded-modified" and 
"rurab'urban. Respondents were asked which type of setting they actually used for 
various types of activity such as fishing, hiking, sightseeing and sports. They were also 
asked which setting they would have preferred to use for each type of activity. When 
the percentage preferring one type of setting was greater than the percentage using that 
type of setting, it was asserted that there was a shortage of that type of setting. 

This type of analysis on which the FEMAT arguments are based is not scientifically 
sound. It does not allow for the fact that it requires more time and effort for a 
recreationist to travel to a primitive or semi-primitive setting to engage in recreation. In 
other words it ignores monetary and non-monetary cost to the user. It is akin to asking 
a sawmill owner what quality of logs the sawmill uses and then asking what quality the 
owner would prefer to use, without reference to the cost of the logs. 

A related defect is that this type of analysis also ignores the possibilities of substituting 
one type of recreation for another depending, for example, on their relative monetary 
and non-monetary costs. A more penetrating analysis would have attempted to 



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determine why the observed behavior of respondents did not correspond to their stated 
preferences. 

As McKillop et al. (1993) noted, the vast majority of persons who use the National 
Forests require roads for pursuing fishing, hunting and general recreation activities; 
and most back-country users need access by road to the trailhead. Without timber 
harvesting, most National Forest roads would not have been built. If timber had not 
been sold and logged, the National Forests would be largely unroaded, and would be 
the private preserve of a very limited number of backpackers who are able to spend a 
lengthy period of time to get into the backcountry without using a vehicle for 
preliminary access. 

Vehicular-based recreation and timber harvesting are thus joint and complementary uses 
of the federal forests. Addition of the substantial values per acre that are obtainable 
from timber production to those for vehicular-based recreation in FEMAT table VI-9 
make it abundantly clear that nonmotorized recreation values displayed in tables VI-7, 
8 and 9 do not make a legitimate contribution to the case for adopting option 9. 



Sport fishing 

In discussing sport fishing for trout, salmon and steelhead, FEMAT page VI-16 says 
"Forested watersheds can have marked impacts on these species. Radtke and Davis 
(1993a) show that, while it is not attributable solely to forest conditions. Pacific 
Northwest salmon fishing catch rates and angler days have declined greatly from the 
1970's". 

The statement is distinctly misleading. Although logging and road building practices of 
20 or 30 years ago may have reduced spawning potentials for these species, modem 
logging and road building practices followed for the last 20 years or more do not 
contribute significantly to reduced fish stocks. As early as 1968, Van Hyning pointed 
out that an increase in ocean fishing was the major factor in the decline of the fall 
Chinook run. In addition, a recent review by Kaczynski and Palmisano (1992) indicates 
that modem timber hjirvesting practices have a very minor effect on salmon stocks. 

In mid- 1993 the Interagency SEIS Team released two studies by Radtke and Davis 
(1993a, 1993b). Neither of them warrant the FEMAT statement and neither, in any 
way, provide an assessment of the effects of the FEMAT altematives in spite of the fact 
that the FEMAT report refers to them as if they did. 

Tourism 

On page VI-29 FEMAT says that tourism is a "large and important part of the coastal 
economy" and that "Many thousands more are supported by the inland recreation 



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industry as well". It also says "In the near term, the alternatives proposed will likely 
not radically change the nature of coastal tourism, but in future decades, restoration of 
salmon and trout runs could have marked impacts on coastal recreation activities". 

This statements is misleading and defective in several respects. It is improper to insert 
the word "radically" to create the impression that the alternatives will have a non- 
radical effect on coastal tourism. An objective appraisal would find that the alternatives 
will have no appreciable effect. Current logging practices are designed to avoid 
significant impact on fish habitat. The effect on fisheries of the proposed FEMAT 
alternatives will therefore be little different from that which would occur with 
maintenance of timber sales programs at the 1980-89 level. 

As noted earlier, it is improper to violate the basic principle of economic analysis that 
assessments of change should be "ceteris paribus" (holding other things equal). All of 
the FEMAT options will result in a substantial decrease in federal revenues. If 
watershed improvements can be undertaken when federal revenues are decreased, they 
certainly can be undertaken if recent levels of timber sales are maintained. In other 
words, if the federal government is truly wiUing to spend more on watershed 
improvement projects this can be done while continuing to maintain a substantial timber 
sales program. 

A major defect in the charge given to FEMAT was that it was not required to use a 
meaningful baseline alternative. Use of a meaningful baseline alternative would have 
provided an assessment of the substantial opportunity cost, and loss to society, of the 
options it considered. 

t 

FEMAT discusses jobs created by tourism and sport fishing under prior forest options 
as if they were to be created by its proposed alternatives. This is improper. In addition, 
FEMAT fails to acknowledge that the bulk of recreationists on BLM and U.S. Forest 
Service forestland are regional residents. At any point in time, the total level of outdoor 
recreation activity in the region is virtually fixed. An increase in attendance at new or 
expanded recreation areas will come mainly through reduction in attendance at other 
areas. Thus there will be no net increase in overall economic benefits to the region 
from levels of recreation under the FEMAT alternatives. This is contrary to what is 
implied in the FEMAT report. 

Service employment in forestry 

FEMAT page VI-31 correctly notes that the decline in timber harvesting under its 
alternatives will "greatly diminish the need for forestry services workers" for 
reforestation and timber stand improvement work". However, it claims that wildlife 
surveys and watershed assessments, as well as "some recommendations for watershed 
restoration and forest stand improvement will likely help offset some of the declines in 
the forestry services sector - and potentially increase employment in the sector". The 



18 



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validity of these claims is extremely doubtful. It improper to suggest that these 
activities will increase employment in the sector. 

FEMAT notes that costs for these projects "would be substantial ... in excess of $250 
million per year". No meaningful analysis has been made of potential funding sources 
The fact that these projects have not been undertaken in the past indicates that they 
were not competitive in the budget allocation process. It is obvious, in the face of 
continuing federal budget deficits and reduced timber revenues, that they will be 
substantially less competitive in the future. 

Furthermore, wage scales for employment on forest rehabilitation projects are much 
less than timber industry rates so there is very little chance that such projects will 
provide meaningful opportunities for the many thousands of laid-off timber workers. 



Special forest products 

The harvesting of special forest products such as floral greens, Christmas ornamentals 
and wild edible mushrooms has become "the subject of intense interest in the Pacific 
Northwest" over the past several years (Schlosser and Blatner 1993). Schlosser et al. 
(1991) note that the special forest products industry has become an "important factor in 
forest management". 

On page 11-62, FEMAT says that "To adequately capture the economic value of 
products such as mushrooms, boughs and ferns, and to guarantee that the inherent 
productivity of the resources is not adversely impacted by the harvesting of timber, the 
agencies will have to take a more active role". It fails to point out that this active role 
could be undertaken even if timber harvests were maintained at recent levels. In fact, 
rather than imply that its recommendations would help the industry, it would have been 
appropriate for FEMAT to acknowledge that timber and many special products are 
complementary rather than competitive in their production and that special products 
harvesters require access by road to successfully pursue their activities. Thus the 
FEMAT options may reduce rather than increase the overall level of activity in this 
industry. 

Schlosser and Blatner (1993), in a rqwrt prepared for FEMAT, note that "Forest site 
disturbances, such as fire and timber harvesting often create early succession 
conditions" which favor species desired by floral greens producers. They say that the 
mountain hemlock forest zone is "utilized to a high degree for timber production, 
which can be matched with floral greens management", that "Evergreen boughs are 
normally harvested from young trees", and that "In the Pacific silver fir zone, 
management prescriptions can target the joint production of floral greens and traditional 
forest uses". Schlosser and Blatner also note that because chemical taxol has now been 
synthesized in the laboratory, the "future of the Pacific yew harvest is limited". 



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Schlosser and Blatner also say that "employment in the special forest products industry 
is not a panacea", and that economic development experts "rarely discuss the 
predominant characteristics associated with the harvest and processing of these products 
-- relatively low paying, often seasonal jobs with no benefits and a high degree of 
uncertainty". They note that "approximately 70% of the edible wild edible mushroom 
harvesters also received welfare, and 50% received unemployment compensations". 
Thus it is highly unlikely that this industry can in any way offset the job losses due to 
decreased timber harvests. 



Other commodity production 

FEMAT page VI- 10 notes that it "did not deal explicitly with the management of the 
federal lands for commodities other than timber". It did, however, note that the likely 
future expansion of mining and mineral processing in the xegion "may be limited to 
some degree" by its proposals. It also recognized that the proposals would have adverse 
economic consequences for the range livestock industry but that these "would likely be 
overwhelmed by other economic considerations in the region". 

Commercial fisheries 

In mid-September 1993 the Interagency SEIS Team released a 1993 study by Radtke 
and Davis on commercial fishing. Although the study draws attention to the decline in 
commercial fisheries it does not provide an assessment of the effects of the FEMAT 
alternatives and does not suggest that the alternatives would increase fish stocks. 

As noted above. Van Hyning (1968) pointed out that an increase in ocean fishing was 
the major factor in the decline of the fall chinook run, and that Kaczynski and 
Palmisano (1992) indicate that modem timber harvesting practices have a very minor 
effect on salmon stocks. 

FEMAT page 11-62 says "A key concern in the commercial industry is the failure to 
institute adequate limits on the off-shore catch and processing of Pacific whiting". On 
page VI- 14, referring to the decline in the salmon catch, it says "A variety of factors 
contributed to this, including depressed fish prices, unfavorable ocean conditions, and 
increasing competition from other consumers of this resource". 

It also says that options proposed by FEMAT "likely would not influence the 
immediate future of commercial fisheries operations. However, improved watershed 
and management policies may aid fish stocks in the longer term". A more accurate 
statement would be that current logging and road-building practices do not significantly 
affect fish habitat and that watershed improvements could be undertaken without 
reducing recent levels of timber harvest. 



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Quality of life 



FEMAT page VI- 19 talks about quality of life in the Pacific Northwest. It also says 
"Swaiison and Loomis (1993) highlight that all Americans place a high value on 
maintenance of viable ecosystems, even when those systems are far removed from their 
homes". 

The claim by Swanson and Lxx)mis is, apparently, based on contingent valuation studies 
of wUlingness-to-pay for preserving additional spotted owl habitat by Hagen et al. 
(1991) and Rubin, Helfand and Loomis (1991). These studies, as noted by McKillop 
(1992), are highly defective. For example, they failed to provide respondents with 
adequate information about the issue, so that there was no way in which respondents 
could grasp the very great complexities of the situation (such as the true costs of 
additional preservation). And, of course, respondents could state what they would be 
willing-to-pay to preserve additional habitat while knowing full well that they would 
not actually have to pay anything for the program, or even be required to write their 
Congressional representative urging that taxes be increased to pay for it. 

If the respondents in these studies could have witnessed the misery and hardships 
imposed on families, businesses and communities by the spotted owl program, their 
responses to the surveys might have been quite different. They would have recognized, 
as FEMAT fails to do, that the most important element in determining quality of life is 
to have a job and to provide for one's family. 



Conclusion 



As indicated in table 1 , adoption of option 9 will lead to major economic losses to 
California, Oregon and Washington and to the nation as a whole. 

Aggregate national losses due to decrease in regional income and losses to consumers 
from higher wood product prices will amount to $4.6 billion per year in the initial 
years of the implementation of option 9. This level of aggregate loss could continue 
indefinitely if other regions are unable to increase timber output to partially compensate 
for the reduction in Pacific Coast timber harvests. 

Net revenue loss to the federal government through reductions in tax receipts and net 
revenue from timber sales will amount to more than $4(X) million per year. State and 
local governments will suffer losses of $277 million per year and, furthermore, will be 
forced to pay more than $746 million in unemployment compensation to laid-off 
workers, not including costs of supplemental programs to assist the unemployed. The 
loss to federal, state and local governments in the first year of adoption of option 9 will 
thus be over $1.4 billion. 



21 11/18/93 



199 



The FEMAT report either ignores these very large and tangible economic losses or tries 
to mask them by claiming the existence of dubious economic benefits associated with 
option 9. FEMAT's claims of economic benefits to be derived by adding to the Pacific 
Coast's already extensive areas of wilderness, parks and reserves are not based on 
rigorous, objective analyses and have very limited credibility. 

The report spends much time describing activities such as recreation, fishing, service 
forestry and special forest products gathering as if their levels could be increased by the 
adoption of option 9. In this, it violates the crucial "ceteris paribus" rule of economic 
analysis. It fails to hold "all other things equal" by claiming, for option 9, benefits of 
governmental actions that would be more feasible, or more readily achievable, if timber 
harvest levels were maintained at recent levels instead of being decreased as required 
by the option. 



Literature cited 

Forest Ecosystem Management Assessment Team. 1993. Forest ecosystem 

management: an ecological, economic, and social assessment. Appendix A to U.S. 

Forest Service and U.S. Bureau of Land Management 1993. July. Portland OR. 
Hagen, Daniel A., James W. Vincent and Patrick G. Welle (1991). The benefits of 

preserving old-growth forests and the Northern Spotted Owl. Department of 

Economics, Western Washington University. Bellingham WA. April 30, 1991. 

41p. 
Haynes, Richard W. and Darius M. Adams. 1985. Simulations of the effects of 

alternative demand-supply assumptions on the timber situation in the United States. 

U. S. Forest Service, Forest Resource Economics Research. Washington D.C. 

113p. 
Krumland, Bruce, and William McKillop. 1990. Prospects for supply of private timber 

in California. University of California. California Agricultural Experiment Station. 

BuUetin 1931. Berkeley, CA. 61p. 
Kaczynski, V.W. and J.F. Palmisano (1992). A review of management and 

environmental factors responsible for the decline and lack of recovery of Oregon's 

wild anadromous salmonids. Technical report to Oregon Forest Industries CounciL 

June, 1992. Salem OR. 292p. 
McKillop, William. 1974. Economic impacts of an intensified timber management 

program. U.S. Forest Service. Division of Forest Economics and Marketing 

Research. Research paper WO-23. July. Washington, D.C. 116p. 
McKillop, William 1992. Use of contingent valuation in Northern Spotted Owl studies: 

a critique. Journal of Forestry. August. Vol. 90 no. 8, pp 36-37. 
McKillop, William, and Mark Spriggs. 1993. Cumulative revenue losses to state and 

local government due to harvest restrictions. In "Building towards a better solution: 



22 



11/18/93 



200 



position papers on Northwest Forest Issues". Presidential Forest Conference. 

Northwest Forest Resources Council. April 2. Portland OR. lip. 
McKillop, William, Jim L. Bowyer and Mark Rasmussen. 1993. An analysis of 

President Clinton's July 1, 1993 Forest Option. Report of the Oregon Lands 

Coalition Socio-Economic Review Panel. Salem OR. 
Olson, Douglas C, and Wilbur R. Maid. 1993. A critique of the outlook of projected 

timber employment. Department of Agricultural and Applied Economics. 

University of Minnesota. St. Paul. October 15, 1993. 
Radtke, Hans D., and Shannon W. Davis. 1993a. Economic description of coastal 

fisheries in the Pacific Northwest. Prepared for Interagency Team. April. 
Radtke, Hans D., and Shannon W. Davis. 1993b. Economic description of coastal 

tourism in the Pacific Northwest. Prepared for Interagency Team. April. 
Random Lengths. 1993. A weekly report on North American forest product markets. 

Various issues. Portland OR. 
Rasmussen, Mark, Douglas Olson and Wilbur Maki. 1991. Social and economic 

impacts in Washington, Oregon and California associated with implementing the 

proposed critical habitat designation. Timber Data Company. Eugene OR. June 1. 

32 p. 
Rasmussen, Mark. 1993a. Preliminary review of the Draft Supplemental 

Environmental Impact Statement on Management of Habitat for Late-Successional 

and Old-Growth Forest Related Species within the Range of the Northern Spotted 

Owl. Timber Data Company. Eugene OR. August 5. 
Rasmussen, Mark. 1993b. Evaluation of the TAMM analysis for the President's timber 

plan. Draft. Timber Data Company. Eugene OR. October 10. 
Rubin, Jonathan, Gloria Helfand and John Loomis. 1991. A benefit-cost analysis of the 

Northern Spotted Owl: results from a contingent valuation survey. Journal of 

Forestry. Vol. 89 no. 12. December, pp. 25-30. 
Schlosser, William E., Keith A. Blatner and Roger C. Chapman. 1991. Economic and 

marketing implications of special forest products harvest in the coastal Pacific 

Northwest. Western Journal of Applied Forestry, vol. 6 no. 3. 
Schlosser, William E. and Keith A. Blatner. 1993. Critical aspects of the production 

and marketing of special forest products. Prepared for the President's Forest 

Conference. May 3. Portland OR. 
Schmalensee, Richard. 1971. Consumer's surplus and producer's goods. American 

Economic Review. September. Vol. 61, pp 682-687. 
Schmalensee, Richard. 1976. Another look at the social valuation of input price 

changes. American Economic Review. March. Vol. 66, pp 682-687. 
Swanson, Cindy, and John Loomis. 1993. Role of non-market economic values in 

benefit-cost analysis of public forest management options. Working document. 
U.S. Forest Service. 1990. Forest Service program for forest and rangeland resources: 

a long-term strategic plan. Recommended 1990 RPA program. May. Washington 

D.C. 
U.S. Forest Service and U.S. Bureau of Land Management. 1993. Draft supplemental 

environmental impact statement on management of habitat for late-successional and 



23 11/18/93 



201 



old-growth forest related species within the range of the Northern spotted owl. July. 

Portland OR. 
Van Hyning, Jack M. 1968. Factors affecting the abundance of fall Chinook salmon in 

the Columbia river. Ph.D. thesis. Oregon State University, Corvallis OR. 
Western Wood Products Association. 1993. Western Lumber Facts. May. Portland 

OR. 



(Attachment follows:) 



24 11/18/93 



202 

Table 1. Regional and national economic costs of FEMAT option 9 



Total Total 

WA OR OR&WA CA 3 state 

Reduction in federal harvest level mil. bf/y 841.0 2190.0 3031.0 409.0 3440.0 

Loss in gross federal timber revenue mil. $/yr 102.3 548.8 651.1 41.9 693.0 

Loss in net federal timber revenue mil. $/yr 36.1 237.8 273.9 15.1 289.0 

Loss in direct jobs tfious. 7.4 23.8 31.2 2.6 33.8 

Loss in indirect & induced jobs thous. 8.3 26.7 35.0 2.9 37.9 

Loss in total jobs thous. 15.7 50.5 66.2 5.6 71.7 

Loss in regional payrolls mil. $/yr 393.4 1092.4 1485.8 129.7 1615.5 

Loss in business net income mil. $/yr 14.2 37.1 51.3 6.9 58.2 

Loss in total regional income mil. $/yr 407.6 1129.5 1537.1 136.6 1673.7 

Loss in personal income taxes - state mil. $/yr 51.1 51.1 0.3 51.4 

Loss in personal income taxes - federal mil. $/yr 24.7 67.5 92.3 8.4 100.7 

Loss in business tax receipts - state mil. $/yr 1.7 2.4 4.1 0.2 4.3 

Loss in business tax receipts - federal mil. $/yr 4.0 10.4 14.4 1.9 16.3 

Loss in federal county & school payments mil. $/yr 25.5 171.8 197.3 11.7 209.0 

Loss in timber tax receipts mil. $/yr 5.1 5.1 1.3 6.4 

Loss in sales taxes mil. $/yr 4.0 4.0 1.4 5.5 

Net revenue loss to federal govt. mil. $/yr 64.9 315.7 380.6 25.4 406.0 

Revenue loss to state & local govt. mil. $/yr 36.3 225.4 261.7 14.9 276.6 

Revenue loss to fed., state & local govt. mil. $/yr 101.2 541.1 642.2 40.3 682.5 

Increase in unemployment compensation mil. $ 163.1 525.0 688.2 57.8 745.9 

First year loss to state & local govt. mil. $ 199.5 750.4 949.9 72.6 1022.5 

First year loss to fed., state & local govt. mil. $ 264.3 1066.1 1330.4 98.0 1428.5 

Aimual loss to US consumers 1994-96 mil. $/yr 2950.0 

Annual consumer & regional income loss mil. $/yr 4623.7 

Notes 1. Base for timber receipts is 1986-90 average, otherwise 1980-89 average. 

2. Excise taxes on public timber and sales taxes are not levied in Oregon. 

3. Personal income taxes are not levied in Washington. 

4. Costs of supplemental programs to assist the unemployed are not included 



11/1^93 



203 



WRITTEN STATEMENT FOR THE RECORD 

OP '' ' 

DR. ROBERT J. TAYLOR t J f ^ -.-l.yr. .,■■,, 

DIRECTOR OF WILDLIFE ECOLOGY '^ - ^^ - 

CALIFORNIA FORESTRY ASSOCIATION =' .^lac:? t >. * 



HEARING ON THE ADMINISTRATION'S 
FORESTRY PLAN FOR THE PACIFIC NORTHWEST 

BEFORE THE 
SPECIALTY CROPS AND NATURAL RESOURCES 
SUBCOMMITTEE 
OF THE 
AGRICULTURE COMMITTEE 
UNITED STATES HOUSE OF REPRESENTATIVES 
NOVEMBER 18, 1993 



.■JS/.S 



My name is Robert Taylor. I have a Ph.d. in biology from the 
University of California at Santa Barbara. For eighteen years I 
taught biology, ecology, and wildlife biology at the University 
of Minnesota, Clemson University, and Utah State University. I 
have published in the fields of animal population biology, 
predator-prey relationships, biodiversity and landscape ecology. 
I am Director of Wildlife Ecology for the California Forestry 
Association, where I do research and policy work on threatened 



204 



and endangered species. 

I am here to represent to you some of the concerns I share 
with other wildlife biologists in the forest products industry 
and elsewhere over the report of the Forest Ecosystem Management 
Assessment Team (FEMAT) and the resultant Option 9, the 
Administration's plan for managing the federal forests of the 
Pacific Northwest and northern California. 

In preparing this testimony, I was overwhelmed with 
frustration over the extent to which this document is being 
portrayed as both the voice of the scientific community and even 
more categorically as "science." I want to state in the 
strongest possible terms that the FEMAT Report is not a 
scientific document. 

It has three major flaws. The most obvious is a distorted view 
of the application of scientific methods to natural resources 
decision-making. Here is a sample: 

1. The Administration and FEMAT team chose to 
interpret the wildlife viability standard for the 
natural forests as applying to all federal lands 
and the restriction to vertebrate species to apply 
equally to insects, snails, plants and fungi. 

2. The reserve approach to managing northern 
spotted owls is fundamental to all options in the 



205 



FEMAT Report in spite of the fact that two members 
of the Interagency Scientific Team that crafted 
that approach have publicly repudiated it. 
(McKelvey, et al. 1983) 

3. The majority of the reported " associations" 
of species with old-growth forests hides the fact 
that many of these species do perfectly well in 
second-growth forests. 

4. Preserving national forest watersheds for Coho 
Salmon in California does no good because there 
are almost no Coho Salmon spawning in the national 
forests, (personal communication, Cal Dept. Fish & 
Game, Division Inland Fish.) 

The list goes on, and I cannot address it all in five minutes. 
Our detailed comments citing a number of these flaws is included 
for the record of the hearing. 

The second major problem is that the FEMAT team chose to 
accept the administration's charge to plan for the viability and 
distribution of species known or reasonably expected to be 
associated with old-growth forest conditions. This is an 
impossible task. Viability, as the FEMAT team interpreted that 
word, is the probability that a species will be present and well- 
distributed one-hundred years from now. The hard fact is that 



206 



the ecological sciences cannot with confidence predict the 
abundance and distribution of any animal species more than ten 
years into the future, much less one-hundred. To come up, as 
this team did, with numerical assessments of viability under 
different management scenarios is to do little more than quantify 
wild guesses. Ignorance expressed in numbers is still ignorance. 

The participation of scientists in so-called Delphi panels 
is much more than merely unwise, it is a misapplication of 
professional skills and a miscarriage of the scientific method. 
Because these panels give the imprimatur of science to what is in 
many cases little more than hunch and supposition, they can . :^ 
seriously mislead. As a scientist, let me make an admission 
against my own interest — the opinions of a scientist without data 
or solid theory to back him or her up are no more to be respected 
than are those of any other citizen. 

The third major flaw is the FEMAT team's refusal to 
incorporate the latest data readily available to them. An 
example of this is the recent information on the occurrence of 
and habitat use by the northern spotted owl obtained under 
standard Fish & Wildlife Service approved survey protocols. For 
example the FEMAT report shows only 587 pairs of spotted owls on 
private lands across the full three-state range covered by the 
report. Yet, we know there are almost twice that many on private 
lands in California alone. The California Forestry Association's 
research, coordinated with the California Department of Fish & 
Game, has found 2,262 known owl territories in California (half 



207 



on private lands) with only 50%-60% of the region surveyed. The 
FEMAT report has similarly understated owl numbers in Washington 
and Oregon. 

And it is not only a matter of nmabers. Many of the recent 
surveys have been conducted in habitat considered by FEMAT 
scientists as non-habitat. As a result, many of the new 
locations of spotted owls carry with them habitat use information 
that is strikingly different than earlier assumptions on habitat 
use. It is unconscionable for the FEMAT team to have developed 
recommendations based on only part of the data. 

The only responsible options for the FEMAT team should have 
been either to refuse the charge or to issue a report in which 
the dominant output from the nation's forests would not be logs 
or birds or water but scientific information. Why did the team 
not do this? The Administration has stated that the scientists 
were merely following what the decision makers ordered. The 
charter under which they worked bears this out. At the same 
time, I am forced to conclude that the team was overwhelmingly 
dominated by below-average scientists and non-scientists. Let me 
defend that assertion. 

Working scientists publish in the peer-reviewed literature. 
And any publication worthy of the paper it is printed on is cited 
by others. I tabulated the scientific citations for the year 
1992 of all members of the Federal Ecosystem Management 
Assessment Team and all members of the species expert viability 



208 



panels of the terrestrial ecosystem assessment.' - 

To provide you with a perspective for the nvimbers I am about 
to present, I examined the citation records of ecologists in 
several university departments with which I am familiar and 
compared those records to my subjective assessment of the 
scientific reputations of the individual faculty. "Non- 
scientists" and "poor" scientists are not cited at all. "Below- 
average" scientists are usually cited 10 or fewer times per year. 
"Average" ecological scientists are cited 11-30 times per year. 
And "above-average" scientists are cited more than 30 times per 
year. By this yardstick I am an average scientist; I was cited 
17 times in 1992. ' ' 

Of the 44 biologists on the FEMAT team, 7% were above 
average, 14% were average, 34% were below average, and 45% were 
poor scietists or non-scientists. In other words, only 9 out of 
44 were average-to-good scientists. Of the 74 biologists who 
comprised the species-expert viability panels, 9% were about 
average, 7% were average, 49% were below average, and 35% were 
poor scientists or non-scientists. In other words, only 12 out 
of 74 were average-to-good scientists. What we have here, I 
submit, is a collection of policy-makers, biological bureaucrats, 
and below-average scientists cloaked in a false mantle of 
scientific certainty that they have not earned the right to wear. 
The Administration has empowered only one school of thought 



' This analysis was done using Science Citation Index . The 
citations counted were those made by others than the author. 



209 



within the scientific community, and that reserve-happy cabal has 
effectively suppressed all opposing viewpoints in this debate. 
Many scientists with established reputations do not agree with 
the reserve approach characteristic of all options in the FEMAT 
Report. I urge you to listen to them. 

If you are inclined to dismiss my comments, I direct your 
attention to the independent evaluation of Option 9 released last 
week by the Resources Agency of the state of California (CDFFP 
1993). It is extremely critical and buttresses a number of the 
complaints I have made this afternoon. 

I suggest, in conclusion, that it would be a mistake to 
consider the FEMAT Report as anything other than a work of 
political advocacy masquerading as a scientific document. 



REFERENCES 

California Department of Forestry and Fire Protection. 1993. An 
evaluation of option 9 of the federal forest plan as it 
relates to northwest California. 

McKelvey, K.S., B,R. Noon, J. Verner, and C.P. Weatherspoon. 
1993. Letter to President Clinton 

(Attachments follow:) 



210 



J) 



^Y^ 



An Evaluation of Option 9 of the Federal Forest Plan as it 
Relates to Northwestern California 

State of California 

The Resources Agency 

California Department of Forestry and Fire Protection 

October 1993 . 



Executive Summary 



This report provides an analysis of the report and recommendations of President Clinton's Forest 
Ecosystem Management Assessment Team (FEMAT) and of the supporting Draft Supplemental 
Environmental Impact Statement (DSEIS). It critiques the process by which alternatives were 
generated, and assesses long-term, forest ecosystem management and the protection of ecological and 
human values for northwestern California. 

The DSEIS proposes a three step process to achieve its goals. First, Option 9 proposes actions aimed 
at ensuring the maintenance of biological diversity, with an emphasis on threatened species. Next it 
proposes a reinstitution of forest planning which will affect the four national forests in California 
impacted by the DSEIS. Lastly, it calls for implementation, monitoring, and adaptive management. 

Unfortunately, the State of California must conclude that Option 9 fails to provide a viable blueprint 
for sound management of our national forests, at least as it relates to the four forests in California's 
Klamath Province. In fact. Option 9's implementation, as currently proposed, would adversely affect 
this region's (and the state's) economy and ecology. 

Specifically, Option 9 falls short in the following important areas: c 

Places too large of area in resers'es'. ■ ■ 

Fails to use an ecosystem approach. 

Does not adequately address the potential role of fire. 

Fails to recognize the contribution of private lands and the state's extensive regulatory 
scheme to protect these lands. 

Does not provide adequate ftinding for implementation. 

Nonetheless, there is an opportunity to use the work done in preparing the DSEIS as a foundation to 
construct a viable management plan for California's national forests. This reports suggests a number of 
specific actions that can be taken in this regard. 



211 



Adopt ecosystem management plamiing which addresses the role of public and private 
lands. 

Provide adequate funding to assure successful implementation of the plan. 

Develop better information for planning, implementation, monitoring, and adaptive 
management. 

Conduct a more thorough analysis of potential impacts of the fire environment in 
California. 

Involve local "watershed" citizen groups in developing management plans for the 
forests. 

Develop incentives to encourage private landowner participation. 

Recognize California's extensive regulation of forest practices and protection of critical 
habitat. 



Only with such changes can Option 9 sene as a basis for sound management of our national forest 
and break the gridlock which has surrounded these forests in the recent past. 



212 



An Evaluation of Option 9 of the Federal Forest Plan as it 
Relates to Northwestern California 

State of California 

The Resources Agency 

California Department of Forestry and Fire Protection 

October 1993 

Overview 

This report provides an analysis of the report and recommendations of President Clinton's Forest 
Ecosystem Management Assessment Team (FEMAT) and of the supporting Draft Supplemental 
Environmental Impact Statement (DSEIS). It critiques the process by which alternatives were 
generated, and assesses the contribution of the preferred Option 9 to long-term, forest ecosystem 
management and to protection of ecological and human values for northwestern California. 

Option 9 represents a proposed first step in a continuing federal planning process. The first phase of 
this process is to ensure the maintenance of biological diversity, emphasizing threatened species. The 
second phase will be a reinstitution of forest planning, and the third will provide for implementation, 
monitoring, and adaptive management. 

Option 9 responds to the first phase primarily by proposing a network of late successional reserves. 
This report evaluates the recommendations and analyses that support the proposed option, and 
discusses a range of needs for additional analysis, planning, and implementation. 

WILL OPTION 9 ACHIEVE ECOSYSTEM MANAGEMENT AND PROTECTION? 

Does the plan provide a backbone for ecosystem management? 

To understand the implications of the FEMAT report, the feasibility of ecosystem management must 
be addressed. Option 9 falls short of providing an ecosystem approach needed to ensure ecological 
integrity of forests and rangelands in California and the human society dependent upon them in three 
ways: 1) it fails to address desired ecosystem structure across the whole province because the plan's 
scope is limited to federal lands; 2) it is based primarily on northern spotted owl and marbled murrelet 
habitat needs, rather than a multiple species approach; and 3) it emphasizes a reserve and serai stage 
strategy rather than the provision of information and options for ecosystem management protection. 

Will the plan ensure maintenance of diversity? 

The prescriptive zoning recommended in Option 9 cannot ensure diversity in the face of human and 
natural disturbances. The proposed zoning cannot ensure protection for all ecosystem types nor will it 
provide the range of information needed for sound management. Furthermore, federal lands alone 
cannot ensure the viability of several species. 

• The potential effects of fire and timber harvest on ecosystem integrity across the 

region were not adequately addressed by FEMAT. 



213 



Proposed Adaptive Management Areas (AMAs) and reserved lands do not represent 
the full range of biological diversity. 

Aquatic habitat protection will not succeed if conservation mechanisms are restricted to 
federally reserved watersheds. 

• Protection on federal lands alone will not likely result in delisting of the owl. 

• Private lands are likely to be critical to the viability of the marbled murrelet and coho 
salmon in northwestern California. 

What are the potential effects on fire risk and fire protection, and how will 
they affect ecosystem integrity? 

Long-term fire suppression has resulted in a high hazard fire environment. Under these conditions, the 
impacts of fire on ecosystem integrity may overwhelm those of zoning and plaruied management. 
Therefore, the effects of Option 9 on fire suppression capabilities, fire risk, and funding for fuels 
management warrant much more attention. 

Fire-fighting capability will be reduced due to a decrease in federal support personnel 
and a decline in the presence of persoruiel and equipment associated with the timber 
industry. This will result in greater costs and liabilities for state and local governments. 

• An independent evaluation of fire ignitions in old growth reveal little difference 
between old growth and earlier serai stages, but further investigation is needed. 

The federal government must ensure funding for long-term fuels management. 

Were all timber management options considered? 

Option 9 fails to consider a full range of options. Analysis suggests that shorter rotation ages for 
harvesting Matrix areas may have minimal impacts on forest structure while yielding substantial 
economic benefits. Alternative approaches to traditional area control rotations are needed to achieve 
ecosystem management. 

Option 9 fails to identify a desired forest structure as the basis for timber management 
prescriptions. 

Analysis of the Shasta-Trinity National Forest indicated that harvests in the Matrix 
under 90, 180, and 300-year area control rotations yield similar acreage by tree size 
classes across the forest. 

• Timber yields for 90-year area control rotations on the Shasta-Trinity National Foresf 
were 38 percent higher than for 180-year rotation. 



214 



DOES THE DSEIS PROVIDE ADEQUATE EVALUATION OF ECONOMIC 
IMPACTS? 

What is the likelihood that Option 9 can achieve possible sale quantity 
projections? 

The DSEIS fails to fiilly assess probable harvest yields on federal lands. These are likely to be lower 
than projected due to increased costs and fewer resources for administering sales. 

• Reductions in Forest Service work force and new sale preparation requirements will 
slow the sale preparation process. 

• Watershed assessments, road treatments, and other new requirements associated with 
timber management may result in more below-cost timber sale conditions. 

Does Option 9 adequately discuss economic and social impacts? 

Option 9 fails to provide enough detail about economic effects. It does not provide an in-depth 
disclosure of individual or cumulative effects on counties, private lands, and the forest industry. This 
information is needed to develop appropriate mitigation. 

• The decade of the 19S0s should be used to fully evaluate the extent of cumulative 
economic and social effects. 

• Analysis showed substantive differences in economic impacts between counties, 
ranging from Trinity County as the most impacted to Mendocino County as the least. 

• Harvest response by nonindustrial private forest landowners (NIPFs) may be greater 
than suggested and may provide some mitigation for reduced federal supplies. 

• The assessment for economic effects does not represent the full geographic area that 
will be affected by Option 9. 

• Decreases in log supply, smaller log size, and increased log prices may impact smaller, 
older mills. 

Does the report fully address state and county administrative costs? 

Option 9 does not fully explore increased costs to local and state government that will result from 
changes in management on private lands, decreases in federal fire fighting support, and social services 
associated with job loss and redevelopment. Mitigations for these impacts are inadequately addressed 
by the DSEIS. 

Potential increases in harvest on private lands will increase demand on CDF personnel 
for timber harvest plan reviews and other forest management activities. 

CDF and counties will be responsible for a greater share of fire suppression and will 
incur additional liabilities. 



215 



• Reduced timber revenues will impact county funding for roads, schools, and other 
services. 

RECOMMENDATIONS FOR IMPROVED PLANNING, ADMINISTRATION AND 
IMPLEMENTATION 

What should federal ecosystem management planning include? 

Federal planning must address the role of private and public lands in ecosystem management. 

• The contribution and condition of private lands must be assessed. 

• Planning must address the interaction of policy decisions and management actions 
between private and federal lands. 

How can planning and administrative processes be organized to include 
public and private interests? 

Institutional processes must be managed to ensure broad participation, rebuild trust, and incorporate 
innovative management planning models. They should take advantage of groups which have formed to 
protect natural diversity and to develop plans for sustainable forestry. State, federal, and local policy 
development should be coordinated to streamline administrative procedures, promote cooperative 
management, and ensure ecosystem protection across ownership boundaries. 

• The process should take advantage of groups such as the Trinity Bioregion Group, 
Redwood Coast Watershed Alliance, and Shasta-Tehama Forest Work Group. 

Incentives should be developed to encourage private landowner participation. 

• The contributions to ecosystem management of forest practices regulation and efforts 
such as the State's draft Habitat Conservation Plan (HCP) for the nonhem owl should 
be assessed. 

• Federal policy actions such as the 4(d) process for endangered species planning should 
be integrated with a state effort. 

• Cooperative planning and voluntary agreements such as CRMPs ought to be 
incorporated into the planning process. 

• Interagency committees which work at the physiographic province level are an 
important basis for plan implementation. 

• Institutional arrangements that reflect regional or watershed perspectives, such as those 
fostered by California's Biological Diversity MOU, should be used to seek innovative 
management options and to streamline administrative procedures. 



216 



• The State of California needs to assist in providing technical and institutional options 
for completing phase one and achieving phases two and three of the FEMAT planning 
process. 

Will resources be available to ensure adequate planning and implementation? 

Option 9 does not include the funding information necessary to evaluate the feasibility of successful 
implementation. Ecosystem management implementation will entail a variety of new programs. The 
Forest Service must make a firm commitment to staffing and funding for Option 9 implementation. 

• Resources must be provided for watershed assessments, research, monitoring, 
restoration, and interagency coordination. 

• Funding allocations must not impact the management of other national forests, such as 
those in the Sierra. 



What will the commitment be to providing the information needed for 
ecosystem management? 

Information is critical to achieving ecosystem management across ownership. Resources must be 
provided to ensure timely collection, analysis, and use of information for planning, implementation, 
monitoring, and adaptive managcTP.ent. 

• Historic fire information mus* be provided to develop management goals and plans to 
minimize potential fire impacts. . - 

• Federal and state agencies and private landowners shoulo cC>operate on data collection 
and analysis. 

• Research needs must be prioritized. 

Monitoring must be timely, well funded and administered with broad cooperation to 
promote adaptive management. 

How can adaptive management be implemented to enhance ecosystem 
management and social and economic good? 

Adaptive management, to be successfully implemented, will require broad participation and adequate 
resources. If properly managed, it can be used to generate greatly needed information and innovative 
management options. 

• Adaptive management must include the public in local areas. 

The location of AMAs should reflect the biological diversity of the region in order to 
generate adequate information needed for management. 



217 



• AMA boundaries must be flexible enough to take advantage of social, economic, and 
biological opportunities. 

• Firm commitments of liinding, personnel, and administration are necessary. 

How can the potential cumulative effects of Option 9' s impleiTientation on 
the fire environment be mitigated? 

The DSEIS must address the role of fire in California's forest environment in greater detail. The plan's 
potential effects on fire risks and suppression capabilities must be fiilly assessed, and appropnate 
management and mitigation must be fully funded. 

• A database of fire history information about private and federal lands should be 
developed. 

• Changes in fire risks associated with different forest structures must be assesseci. 

• Fuels management programs must be designed and Junded to reestablish a m ore stable 
forest environment. 

• Long-term fire suppression funding must be ensured to minimize increased liabilities 
to the State. 



218 




'^'vSi^'^"'^ 



THE WILDERNESS SOCIETY 



STATEMENT OF DR. MARK L. SHAFFER, VICE PRESIDENT FOR RESOURCE 
PLANNING AND ECONOMICS, BEFORE THE SUBCOMMITTEE ON SPECIALTY 
CROPS AND NATURAL RESOURCES OF THE COMMITTEE ON AGRICULTURE, 
U.S. HOUSE OF REPRESENTATIVES, NOVEMBER 18, 1993. 



Thank ycxi Mr. Chairman and Members of the Subcommittee for the opportunity to be 
here today and provide you with our views on the Clinton Administration's proposed 
plan for the long-term management of Federal forest lands in the Pacific Northwest. 
My comments are on behalf of The Wilderness Society, the National Wildlife Federa- 
tion, and the Natural Resources Defense Council. 

First, let me say that we have been extremely gratified by this Administration's 
willingness to tackle the Ancient Forest issue. From the President's Forest Confer- 
ence, to the expeditious work of the interagency Forest Ecosystem Management 
Assessment Team (FEMAT Report, 1993), we are finally seeing a government serious 
about solving problems, not creating them. This stands in stark contrast to the 
preceding administration's deliberate refusal to uphold the environmental laws of the 
land. 

We have also been impressed that, in these efforts, there is finally a recognition of 
what scientists and conservationists have been saying for some time-this isn't an 
issue of owls versus jobs, its about the integrity, survival, and sustainable productivity 
of an entire regional ecosystem. Both the FEMAT Report and the Draft Supplemental 
Environmental Impact Statement on Management of Habitat for Late-Successional and 
Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl 
(DSEIS, 1993) begin to address the overall regional ecosystem and the needs of the 
myriad species that rely on that ecosystem. 

Sadly, despite all this positive progress, the result of these good efforts thus far falls 
well short of the President's goal of producing a plan that is "scientifically sound, 
ecologically credible, and legally responsible." Option 9, the Administration's preferred 
alternative, is neither an adequate nor acceptable solution to the ancient forest issue 
for a host of reasons that we have documented in A Critique of the Clinton Forest Plan 
(Anderson, et al. 1993). We submitted this critique to the Administration during the 
formal comment period and I have attached a copy for the record. Here, I will only 
summarize the broad themes of the inadequacies of Option 9 and then illustrate these 
by presenting to the Subcommittee maps that The Wilderness Society's Mapping Pro- 
gram has prepared to further analyze the plan. 



900 SEVENTEENTH STREET, N.W., WASHINGTON, DC. 20006-2596 
(202) 833-2300 
Printed on recycled paper 



219 



Option 9's inadequacies can be lumped into three broad areas. First , if implemented, 
the plan would not protect a sufficient amount or distribution of the remaining Ancient 
Forests to prevent the eventual listing and possible extinction of roughly 840 species-- 
78% of those species dependent on these old and highly structured forests. This is 
not the result of any controversial analyses conducted outside the government's 
process, it is the finding of the government's own viability analyses as presented in the 
FEMAT Report . 

Second , irrespective of the Ancient Forests themselves, implementation of Option 9 
would not provide a level of riparian protection sufficient to prevent future listing 
and/or extinction of various species dependent on these riparian and associated 
aquatic habitats, including many salmon stocks. Again, this is not the result of some 
outside analyses. The Forest Service's own Scientific Analysis Team (Thomas et al., 
1993) recommended that adequate protection of these aquatic species required a level 
of protecnon across the landscape that has- been dubbed "full-SAT". Option 9 
arbitrarily reduces this protection by half outside of what the FEMAT Report identifies 
as key watersheds. Once again, it seems that management is disregarding the expert 
opinion of its own scientists on the level of protection necessary to prevent an 
accelerating cascade of species that will require protection under the Endangered 
Species Act (ESA). 

Third . Option 9 does not contain adequate prescriptions for the management of matrix 
areas that will return the region to one dominated by the old and highly structured 
forests that are the regional ecosystem. Yet it is only through such an approach that 
the viability and sustainable productivity of the regional ecosystem, and all the species 
it supports, can be assured. 

At this point, Mr. Chairman, I would like to illustrate these points to Members of the 
Subcommittee by inspecting the maps I have brought with me today. Once again, 
thank you for the opportunity to appear. 

References 

Anderson, M., G. Aplet, S. Balikov, J. Thomson and D. Wilcove. 1993. A Critique of 
the Clinton Forest Plan . The Wilderness Society, National Wildlife Federation, and 
Natural Resources Defense Council. Washington, DC. 47 pp. 

Thomas, J.W., M.G. Raphael, R.G. Anthony, (and others). 1993. Viability assessments 
and management considerations for species associated with late-successional and 
old-growth forests of the Pacific Northwest. The Report of the Scientific Analysis 
Team . Portland, OR: U.S. Department of Agriculture, Forest Service, National Forest 
System. Forest Service Research. 530 pp. 



220 



USDA Forest Service and USDI Bureau of Land Management. 1993. Draft Supplemen- 
tal Environmental Impact Statement on Management of Habitat for Late-Successional 
and Old-Growth Forest Related Species Witlnin the Range of tl-ie Northern Spotted Owl . 
Portland, OR: U.S. Department of Agriculture, Forest Service, National Forest System. 
1 vol., Sep. App. A, 9 maps. 

USDA Forest Service. 1993. Forest Ecosystem Management: An Ecological. Eco- 
nomic, and Social Assessment . App. A of the Draft Supplemental Environmental 
Impact Statement on Management of Habitat for Late-Successional and Old-Growth 
Forest Related Species Within the Range of the Northern Spotted Owl. Portland, OR: 
U.S. Department of Agriculture, Forest Service, National Forest System. 1,000 pp. 



(Attachment follows:) 



221 



A CRITIQUE OF THE CLINTON FOREST PLAN 



THE WILDERNESS SOCIETY 

NATIONAL WILDLIFE FEDERATION 

NATURAL RESOURCES DEFENSE COUNCIL 



OCTOBER 1993 



78-799 0-94-8 



222 



PREFACE 

For years scientists have warned that continued logging of 
the remaining ancient forests in the Pacific Northwest would have 
devastating ecological consequences. And for years the federal 
government ignored the warnings. Rather than make the necessary 
changes, the government attempted to continue unsustainable 
timber production by denying the scientific evidence and falsely 
portraying the policy debate over ancient forests as a choice 
between owls and jobs. 

The Clinton Administration's efforts to develop an 
ecologically sound plan for Northwest federal forests are a 
welcome and important turning point in the ancient forest debate. 
President Clinton has devoted personal attention to the problem 
and promised to do what is needed to protect the long-term health 
of the forests and streams. Literally hundreds of scientists 
were involved in the process of developing and evaluating a range 
of options, from which the draft plan was derived. 

As discussed in this critique, the draft plan is a major 
step toward an ecologically sound blueprint for Northwest 
forests. But it contains a number of serious flaws that leave 
the plan well short of the goal of preserving healthy forests and 
streams. Most important, too much ancient forest is slated for 
logging, forest reserves are not truly protected, streams are not 
adequately buffered, and many landslide-prone areas remain 
vulnerable. 

The principal authors of this report are Forest Resource 
Analyst Michael Anderson and Forest Ecologist Dr. Greg Aplet. 
Susan Balikov and Dr. Janice Thomson conducted the GIS analyses 
contained in the report. Dr. David Wilcove of the Environmental 
Defense Fund assisted in evaluating the viability analysis 
process used in evaluating alternatives. 

Funding for this critique was provided by the Pew Charitable 
Trusts and the W. Alton Jones Foundation. 



Karin P. Sheldon Mark L. Shaffer, Ph.D. 

Acting President Vice President 

The wilderness Society Resource Planning and Economics 



223 



EXECUTIVE SUMMARY 

This critique evaluates the adequacy of the forest 
management plan proposed by the Clinton Administration in July 
1993 to resolve the controversy over federal forest management in 
the Pacific Northwest. Timber sales in old-growth forests 
administered by the U.S. Forest Service and Bureau of Land 
Management (BLM) have been halted by a series of court decisions 
declaring current agency plans legally inadequate. Following a 
day-long Forest Conference in Portland, Oregon, President Clinton 
instructed Administration officials to develop a scientifically 
and legally sound plan. The draft plan, called Option 9, was one 
of 10 options developed by a Forest Ecosystem Management 
Assessment Team (FEMAT) . The 10 options are evaluated in a draft 
environmental impact statement (DEIS) and in a lengthy report by 
the FEMAT. 

Overview of the Plan 

The draft plan divides the previously unprotected federal 
forest lands into four basic management categories. Lat«- 
succ«sslonal forest res«rv«s are intended to provide a system of 
large habitat areas for old-growth species. Under Option 9, 
considerable thinning and salvage logging would be allowed in 
forest reserves. Riparian reserves are strips of protected land 
along streams, lakes, and wetlands. Adaptive manageaent areas 
are areas where experimentation would be encouraged. The rest of 
the unprotected forest would be designated as "natrix" lands and 
be managed primarily for timber production. Under Option 9, 37 
percent of the previously unprotected lands would be in forest 
reserves, 17 percent in riparian reserves, 9 percent in adaptive 
management areas, and 37 percent in the matrix. 

Forest Ecosystem Protection 

Our evaluation found a number of important flaws in the 
Clinton plan's analysis and forest ecosystem management strategy. 
The overall effect of Option 9 would be devastating to the 
ecological integrity of the region's old-growth forests. 

* Option 9 would allow much of th« •cologically significant 
old growth to b* dastroyed. A congressionally-established 
scientific panel in 1991 identified the remaining areas of 
ecologically significant late-successional and old-growth forests 
(LS/OG 1 and 2) in the Pacific Northwest. Based on our 
geographic information system (CIS) analysis of Option 9's 
reserves and the scientific panel's LS/OG 1 and 2 reserves, we 
estimate that 1.6 million acres of ecologically significant LS/OG 
forests would be unprotected from logging under Option 9. This 
amounts to 25 percent of all previously unprotected LS/OG 1 and 2 
forests. 



224 



* Option 9 '3 forest reserves are inadequate to ensure the 
survival of spotted owls and other old-growth species. The 

proposed reserve system protects half a million fewer acres of 
suitable owl habitat than the system proposed in 1992 by the 
Spotted Owl Recovery Team. Less than 10 percent of the recovery 
team's proposed owl reserves contained sufficient old-growth 
habitat to sustain stable owl populations in the long term. 
Option 9's reserves evidently would provide even less protection 
to the owl and other species. 

* The plan does not adequately take into account the dynamic 
nature of forest ecosystems. The plan's reserve system assumes 
that fire and other natural disturbances will not have a 
significant impact on current and future old-growth forests. 
This assumption appears to be little more than wishful thinking, 
especially with respect to forest reserves in highly fire-prone 
area? of the region. A more realistic approach would be to 
increase the number and size of reserves in order to ensure 
sufficient old-growth habitat to maintain ecosystems and the 
viability of plant and animal species. 

* Proposed fire management in reserves is misguided. 

Thinning, burning, and other fuel-reduction techniques would lead 
to a direct reduction in old-growth habitat quality by 
eliminating multi-storied canopy conditions. Construction of 
fuelbreaks would increase habitat fragmentation and pose 
increased threat to species that require forest interior habitat. 
Moreover, use of chain saws and other equipment for purposes of 
fire-reduction could actually increase the risk of severe fire. 

* Proposed thinning and salvage in reserves amount to risky 
experimentation. There is no empirical evidence that thinning 
will accelerate development of old-growth characteristics. On 
the other hand, there is ample evidence of fire hazards, insect 
and disease spread, and watershed disturbance associated with 
extensive thinning operations. Salvage logging would have even 
greater adverse impacts on old-growth forest conditions. Salvage 
operations would remove ecologically valuable coarse woody debris 
and leave small stems that are most likely to fuel fires. The 
appropriate place to experiment with thinning and salvage is 
outside of reserves, as proposed by other scientific panels. 

* Management guidelines in the matrix would not protect 
ecosystem values. Interior old-growth conditions would be 
entirely eliminated from the matrix, and residual patches of old 
growth in cutting units would be so small and isolated as to be 
of little ecological value. The plan allows continued use of 
traditional intensive management practices such as fertilization, 
precommercial and commercial thinning, and pruning. The overall 
effect would be a highly fragmented landscape with small patches 
and strips of old-growth trees, but dominated by small trees and 
essentially devoid of old-growth ecosystem characteristics. The 
plan claims that 180-year logging rotations would be used in 



225 



California conifer stands, but those stands would actually be cut 
on about 120-year rotations. 

* Tb« FEMAT's assassment of the ability of diffarant options 
to protact tba L8/oa forast acosystea is sariously aaiss. 

Incredibly, the team rated Option 9, which allows substantial 
logging of old growth, as high or higher than the option that 
protects all remaining old growth. The team's assessment was 
based on a skewed rating system that downplays the importance of 
retaining the extant old growth and overemphasizes the ability of 
thinning and other experimental "restoration silviculture" 
techniques to accelerate development of old-growth 
characteristics. The team also boosted Option 9's ranking based 
on speculation that adaptive management areas will produce 
greater knowledge about forest ecosystem management, even though 
much of the old growth in these areas would be destroyed. 

* Tba plan lacks raconunandations for tha management of thosa 
non-fadaral lands that ara assantial to tba baaltb of LS/OG 
forast acosystaffls and to tba viability of spacias that raly on 
tham. The plan's reserve system is based entirely on federal 
lands. Yet, as pointed out by previous scientific panels and the 
spotted owl recovery team, certain non-federal lands are 
essential for the viability of the owl. The same is very likely 
to be true for many other species. 

Aquatic Ecosvstem Protection 

The Clinton plan seeks to protect habitat for salmon and 
other riparian-dependent species through an "aquatic conservation 
strategy." The major elements of the strategy are to establish 
riparian reserves along all streams, limit road construction and 
require watershed analysis in key watersheds, and undertake an 
ambitious watershed restoration program. 

* Tha OBIS and rSMAT raport lack iaportant infomation about 
tha plan's inpact on salaon. Our recently completed study of 
Pacific salmon and federal lands fills significant information 
gaps relating to salmon. Based on GIS analysis of our salmon 
data and Forest Service data on Option 9, we estimate that 3.4 
million acres of land within the salmon's existing range are 
located outside of reserves and would be subject to logging and 
road building. Moreover, only 30 percent of the non-reserved 
land containing salmon habitat is inside key watersheds; the 
remainder would be subject to extensive land-use disturbance 
without the safeguards provided in key watersheds. 

* Straaa habitat on federal lands is in versa condition than 
tha DEIS and FEMAT report indicate. Two-thirds of BLM's streams 
are so degraded that fish productivity is only 10 to 50 percent 
of potential. Available data indicate that national forest 
streams are mostly in poor condition in areas that have been 
logged. Consequently, much stronger measures to protect and 
restore habitat are needed than those proposed. 



226 



* The draft plan fails to protect a large aaount of steep, 
unstable land. Excessive sediment produced by logging and road 
building on steep, unstable slopes is a major cause of stream 
damage. Our GIS analysis of slope steepness data indicates that 
roadless areas and ancient forests tend to be located on steeper 
slopes than federal lands generally. We estimate that about 1.5 
million acres of land located on steep slopes would not be 
protected from logging under the draft plan. 

* The plan provides no assurance that unstable lands will be 
identified. In theory, the unstable lands would be identified 
and protected through the watershed analysis process. But 
watershed analyses are not required outside of key watersheds and 
roadless areas; therefore, there is no formal mechanism for 
locating many unstable lands. In addition, the Forest Service 
and 3LM have been notoriously reluctant to remove unstable lands 
from the timber base. 

* "Half-SAT" riparian reserves are inadequate. Option 9 
provides interim riparian buffers along intermittent streams 
outside key watersheds that are only half the size recommended by 
agency fisheries scientists. Information in the FEMAT report- 
makes clear that the proposed riparian reserves would only be 
adequate to protect ecological values of intermittent streams in 
areas without steep slopes. In steep terrain, the necessary 
riparian width is two to four times larger than the width 
proposed in Option 9. 

* Thinning and salvage activities in reserves would be 
detrinental to watershed restoration efforts. A key element of 
the Aquatic Conservation Strategy is to restore watersheds by 
closing and decommissioning unnecessary logging roads. But 
proposed management activities in forest reserves would require 
continued or even greater road access, making watershed 
restoration difficult or impossible in reserves. 

* Watershed analysis is no substitute for protection. 

Previous Forest Service efforts offer scant hope that watershed 
analysis will result in protection of aquatic ecosystems. On the 
contrary, the agency has tended to use watershed analysis to 
justify logging watersheds that are in relatively good condition. 
An ecosystem-oriented approach should protect the remaining high 
quality habitat and prevent further degradation of other stream 
habitats. 

Sp^gjes VUbiiitY Ass^s^p^nt 

To help the Administration select a scientifically and 
legally defensible plan, the FEMAT evaluated each option's 
ability to satisfy the legal requirement of maintaining species 
viability. The team identified more than 1,374 plant and animal 
species closely associated with old-growth forest habitat and 
estimated the viability prospects of more than 1,000 of those 



227 



species. Based on the FEMAT analysis, it appears that Option 9 
would threaten the survival of at least 403 old-growth species, 

* Tta« DEIS falls to assess c\iaulativ« impacts on sp«cies. 
The FEMAT made a cnicial mistake by intentionally excluding from 
its species viability assessments any impacts associated with 
management activities and environmental conditions outside of 
federal lands. The team specifically instructed scientists on 
viability panels to "assume that conditions other than habitat on 
federal lands are adequate to provide for well-distributed, 
stabilized populations." Injecting this absurd assumption into 
the assessment process undoubtedly inflated the viability ratings 
of many species. It also misleads the public and policy makers 
into believing that much of the remaining old-growth habitat can 
be destroyed without seriously risking the loss of species. 

* Tb« viability assessments lack scientific docunentation. 

While the species viability assessment process involved many 
knowledgeable experts, the viability analysis lacks any estimate 
of population sizes of the various species. Data and population 
viability models are available for at least some species to 
provide a scientifically based assessment of the options. Until 
more information is available, the prudent approach is to protect 
as much old-growth habitat as possible. 

* Option 9 violates legal requirements for maintaining 
species viability. Even ignoring the serious flaws in the 
FEMAT 's viability analysis, Option 9 does not comply with the 
National Forest Management Act's species viability rule. More 
than 400 species, including salmon and several other vertebrate 
species, would fall below the FEMAT' s threshold of viability if 
Option 9 were adopted. 

Conclusion and Recommendations 

The FEMAT has contributed significantly to society's 
understanding of the species that rely on old-growth forests, the 
severity of the threats to those species, and some of the steps 
needed to ensure species viability. The team's work represents a 
major scientific advancement in the debate over old-growth 
forests. However, important flaws in the team's assumptions and 
analysis have resulted in a conservation strategy that is 
deficient in several fundamental respects. 

The Clinton Administration should revise the DEIS and its 
preferred alternative based on these comments and on the 
following recommendations: 

* Expand the old-growth reserve system substantially to 
protect all remaining stands of ecologically significant old 
growth . 

* Allow no thinning, salvage, road development, or other 
logging activity in reserves. 



228 



* Forests that are outside the reserve system and are 
otherwise suitable for timber management should be managed on at 
least 200-year rotations. Experimental thinning, salvage, and 
adaptive management should only be conducted in areas outside 
reserves. 

* Eliminate the adaptive management area category from the 
plan and add all ecologically significant old growth in those 
areas to the forest reserve system. 

* Include recommendations for the management of non-federal 
lands as necessary to ensure forest ecosystem integrity and 
species viability. 

* Treat key watersheds and roadless areas as reserves to be 
managed for conservation of aquatic biodiversity by removing them 
from the suitable timber base, prohibiting new road construction, 
and decommissioning most existing roads. 

* Remove all forest land on steep and moderately steep 
slopes from the suitable timber base until specific sites are 
certified as having low landslide risk. 

* Apply Riparian Reserve Scenario 1 (full SAT) perinanently 
to all streams, including intermittent streams outside key 
watersheds. 

* Include in the viability ratings the cumulative impacts of 
both federal and non-federal actions on species viability, taking 
into account the true condition of habitat on non-federal lands. 

* Viability assessments based on professional judgment 
should be accompanied by at least crude population estimates for 
species that have low population densities and large ranges or 
small total population sizes. 

* The objective of the management plan should be to provide 
at least a 95 percent likelihood that all old-growth species will 
remain viable for at least the next 200 years. 



(The complete report is held in the committee files.) 



229 



Testimony of the Pacific Rivers Council 

Concerning the President's Pacific Northwest Forest Plan 

before the House Agriculture Subcommittee on Specialty Crops 

and Natural Resources, November 18, 1993 

Judy R. Guse-Noritake 

Over the course of the last few years a series of reputable, high-level scientific 
studies, including studies conducted at the request of Congress and the Administration, 
have examined the plight of sj>ecies that defiend on the old growth watersheds of the 
Pacific Northwest. All these studies have come to the same conclusion — namely, that 
the protection of key watershed refuges, protection of riparian areas, and a regional 
program of watershed restoration are essential to the survival of species that depend on 
healthy rivers and watersheds. The species in question include hundreds of stocks of 
Pacific salmon, trout and steelhead, and a long list of other animals and plants. The 
scientific studies are unified as well in their conclusion that current public land 
management of rivers and watersheds is inadequate. Without substantial change in land 
management, watershed ecosystems and habitat for river-related species cannot be 
maintained. Without substantial change in land management, the Pacific Northwest will 
face a continuing and rising tide of extinctions. 

Salmon are not the only aquatic species at risk. Many of the nearly 200 lesser- 
known species that depend on old growth forest and watershed ecosystems are in as 
much trouble as the salmon. The plight of these other species cannot be blamed on 
agriculture, or on commercial fishing, or on variable ocean conditions, or on seals and 
sea lions. The loss of most river and riparian species, including salmon, is directly and 



Pacific Rivers Council 

Testimony on the Presidents Forest Ran 

MUFT: November 18 1993 

P*«el 



230 



unequivocally associated with the degradation of their habitats — and on federal land 
that degradation is overwhelmingly caused by logging, grazing and roadbuilding. Every 
reputable study agrees on this point. 

Paid apologists for the timber industry have gone to great lengths to point out 
that, historically sp>eaking, salmon habitat was lost to agriculture, streamside 
development, stream channelization, dike building and the like. This is certainly correct 
— historically speaking. The post-European development of Northwest cities and 
agriculture destroyed much salmon habitat - so much so that today most remaining 
high quality habitat is high up in the forested watersheds on federal lands. Most private 
land salmon habitat was compromised long ago. But this is not the 7S90's and we must 
remember that it is to the future we must look, not the past. Today the last best salmon 
habitat is on public land in the national forests, where it is not threatened by urban 
development, it is threatened by logging. 

.V 

The Oregon Chapter of the American Fisheries Society Critical Watersheds 
Database; The Scientific Panel on Late Successional Forest Ecosystems; The Scientific 
Analysis Team Report to Judge Dwyer; The Eastside Forests Scientific Society Panel; 
The USDA Forest Service Pacific Salmon Work Group (Pacfish); and finally the 
document before us, the Presidents Plan (FEMAT), are in deep and broad agreement: to 
protect salmon and the other species that depend on river and watershed ecosystems, we 
must protect key watersheds; eliminate logging, roadbuilding and grazing in riparian 
areas; and begin a regionwide program of watershed restoration. 

In a word, the aquatic conservation principles in the President's Plan are based 
on sound science. The plan details a four part strategy of key watersheds, riparian 



Pacific Rivers Council 

Testimony on the Presidents Forest Plan 

DRAFT: November 18 1993 

Page! 



231 



protection, watershed analysis, and watershed restoration. While we believe each of the 
four parts could and should be strengthened as discussed below, we fully support the 
FEMAT ajjproach. Our analysis is that if the aquatic strategy were strengthened, and if 
it were fully and fiiithfully implemented it would have a high prd^ability of maintaining 
the habitat for river and watershed related species on Northwest national forests. 

However, the plan must be strengthened to provide a high probability of 
preserving species and ecosystems. We support strengthening that plan exactly as the 
FEMAT team themselves recommended: first, key watersheds must be completely 
protected from logging (including salvage and thinning) and roadbuilding until they are 
no longer needed as refuges; and second, riparian protection must be uniformly 
improved across the federal landscape. 

Implementation of the aquatic strategy will present two serious challenges. First, 
the embryonic techniques of watershed analysis must be synthesized into a workable 
tool. We believe that the administration will need to bring in the best and the brightest 
to aid in the detailed development of this new approach. Current drafts of watershed 
analysis procedures do not inspire confidence. We believe therefore that these 
developing techniques should be tested first outside of key watersheds, in the areas 
where the watershed's integrity is already compromised. 

Second, skilled personnel must be trained and empowered in the watershed 
approach. We would like to underscore the critical need for part of the monies 
appropriated for FY94 watershed restoration analysis to be applied to this training 
immediately. Those who are unwilling or unable to adapt to a truly new perspective 
will need to step aside. Since the passage of the National Forest Management Act in the 



Pacific Rivers Coaocil 

Testimony on the Presidents Forest Plan 

DRAFT: November 18 1993 

Page3 



232 



1970's the agencies have provided continuous assurance that timber sales have been 
consistent with maintaining fish habitat. Even though those assurances have proved to 
be dramatically false, there remain a significant number of officers within the agencies 
who defend them. It is difficult to see how such defenders can faithfully implement an 
approach that contradicts their earlier work. Substantial changes in staffing and lines of 
authority may be required if the President's Plan is to hit the ground intact. 

While none of the changes needed in the President's Plan are trivial, neither are 
they insurmountable, nor do they require new study. The steps required to strengthen 
the plan are already spelled out in the plan. The steps required for implementation 
defjend on leadership ftom the administration; 

Mr Chairman, the President's Plan, if strengthened in ways that are well 
understood and if faithfully implemented, would bring the management of aquatic 
ecosystems on public lands within the range of the spotted owl into line with the 
reputable science concerning watershed ecosystems. We commend the President's 
aquatics team for that achievement, and we stand ready to assist this committee in the 
further examination of these issues at any time. A copy of our detailed comments on the 
President's Plan is attached to these remarks as an appendix. Thank you. 

(Attachment follows:) 



Pacific Rivers Council 

Testimony on the Presidents Forest Plan 

DRAFT: November 18 1993 

Page 4 



233 



Initial Comments on the Draft Supplemental Environmental Impact Statement 

(DSEIS) on Management of Habitat for Late-Successional and Old-Growth Forest 

Related Species Within the Range of the Northern Spotted Owl 

and Forest Ecosystem Management: An Ecological Economic and Social 

Assessment (FEMAT) 

^ The Pacific Rivers Council 
September 23, 1993 



I. The preferred alternative provides less protection for at-risk fish than is provided 
for other vertebrates, including the owl. This is unacceptable. At least an 80% 
chance of survival is required for at-risk fish given the substantial economic and 
social factors associated with fish. 

II. The preferred alternative fails to provide adequate protection for key watershed 
refugia by failing to prohibit new human disturbance. The key watersheds should be 
removed from the timber base, no scheduled timber harvest should be planned in 
these areas, and key watersheds must be managed as new separate and distinct 
management units. 

in. The preferred alternative proposes a "Watershed Analysis" process that is 
unproven, unduly complicated, and not organized so as to provide effective decision 
points and cost-elTective action priorities. The experimental watershed analysis 
process should be utilized only outside of key watersheds. Within key watersheds, 
only a Watershed Restoration Action Plan should be utilized to reduce or eliminate 
the effects of human-caused disturbances. 

IV. The preferred alternative fails to adopt needed and mandated riparian protection 
for all riparian dependent vertebrate species, and gives arbitrary preference to 
maintenance of at-risk fish. We believe that Ml riparian protections are required 
outside of key watersheds in order to meet the requirements of the National Forest 
Management Act to protect all vertebrate species well distributed across their range. 

V. No alternative will work effectively given the lack of public faith and trust in the 
current agency leadership. No matter what final alternative is chosen, it will fail 
without a significant change in the agency leadership and mindset. While there are 
many highly professional staffers within the Forest Service and Bureau of Land 
Management, the public has no faith or trust in the current agency staff to properly 
implement any technically appropriate or possible solutions. Without substantial 



Page 1 

September 23, 1993 

Comments on DSEIS 



234 



changes in agency staffing — from top to bottom — along with intensiFied skill 
improvement, all alternatives will fail. 

VI. The preferred alternative prescribes adaptive management that allows, even 
encourages, pseudo-sdentiric experiment with public resources in absence of dearly 
defined controls and in absence of any monitoring worthy of the name. 

Vn. The preferred alternative allows entry into old-growth reserves. Old-growth 
areas anchor the health of the watersheds and many species. All of the remaining 
reserves should be protected. 

Vm. The preferred alternative allows roading of some of the roadless areas. All 
roadless areas should be protected. 

IX. The plan is coupled with an attempt to find timber volume in other areas. No 
area, including the east-side forests of Oregon and Washington, should be sacrificed 
due to poor land management practices on the west side. 

X. The Relationship of Current Plans and Draft Plan Preferred Alternatives to 
Option 9 is Unclear. 

XI. The Standards and Guidelines Applicable to the Seven Land Allocations are 
Unclear. 

Xn. There are Many Inconsistencies That Need Clarification 

Xlll. The Implementation of Standards and Guidelines in the Preferred Alternative 
Is Unclear 

XrV. The Adaptive Management and Implementation Process Outside of AMAs is 
Unclear 

XV. The DSEIS Fails to Include Other Federal Management Agencies as Lead 
Agencies 

XVI. Summary: The DSEIS fails to comply with NEPA Standards. 



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The following are the Pacific Rivers Council's comments on the DSEIS and FEMAT 
Relating to the Preferred Alternative, Option 9: 



I. The preferred alternative provides less protection for at-risk fish than is 
provided for other vertebrates, including the owl. This is unacceptable. At least 
an 80% chance of survival is required for at-risk fish given the substantial 
economic and social factors associated with fish. 

A. While the spotted owl and other species are given an 80% chance 
of survival under the preferred alternative, at-risk fish are provided 
only a 60-70% chance of survival. We find no scientific or legal 
justification for why fish are, or should be, provided less protection 
than other species. Given the tremendous economic and social factors 
associated with fish, we find this willingness to take a greater chance 
with a precious resource simply unacceptable. 

B. Option 9 provides only a 60-70% likelihood of achieving 
"sufficiency, quality, distribution, and abundance of habitat to allow 
the species populations to stabilize on federal lands" (FEMAT V-77). 
This 65% risk viability is predicated on all components of the federal 
lands aquatic conservation and restoration strategy being implemented, 
and some restoration occurring on private lands. These are unproven 
methods. No guarantee exists that effective restoration will occurred 
on the federal lands. Even less of a guarantee exists that private land 
restoration will occur, or be effective. Since funding for such 
restoration depends on the whims of Congress, the FEMAT and 
DSEIS do not, in and of themselves, provide a mechanism to maintam 
viable well distributed populations of vertebrates as required by 
NFMA. 

C. The FEMAT report states that options exist to improve the chances 
of survival for at-risk fish. These steps should be taken (see 
comments below). 

n. The preferred alternative fails to provide adequate protection for key 
watershed refugia by failing to prohibit new human disturbance. The key 
watersheds should be removed from the timber base, no scheduled timber harvest 
should be planned in these areas, and key watersheds must be managed as new 
separate and distinct management units. 



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A. Refugia are the centeq)iece of the aquatic conservation efforts. 
Factors that affect the ftinction of refugia over long time periods have 
been extensively discussed in the literature. 

B. The preferred alternative establishes a system of "key watersheds" 
whose role as refiigia is described as "crucial" [FEMAT V-46]. The 
key watersheds are the remaining "safe" places for at-risk fish and will 
form the anchors of potential watershed recovery efforts. For these 
key watersheds to function as refugia, they must maintain ecological 
integrity over the time period to allow for their own ecological 
recovery, and for the recovery and fish recolonization of adjacent 
watersheds — which will surely involve decades to centuries. 

C. During these very long time periods, the effectiveness of key 
watersheds as biotic refugia will already be limited by the cimiulative 
effects of ongoing natural disturbance combined with the legacy of 
previous human disturbances. 

D. The FEMAT correctly observes that "Stewardship of aquatic 
resources has the highest likelihood of protecting biological diversity 
and productivity when land use activities do not substantially alter the 
natural disturbance regime to which these organisms are 

adapted. "[FEMAT V-29] By recommending key watersheds as 
maintenance and prime restoration sites, the FEMAT tacitly concedes 
that the key watersheds are already substantially impacted by human 
disturbance. Nevertheless the FEMAT prescribes a Watershed 
Analysis process which is scientifically and procedurally unproven, 
and, based on our analysis of the draft document entitled A Procedure 
for Watershed Analysis (14 July 1993), is fatally flawed. Further, 
this scientifically unproven process is prescribed to determine which 
new additional disturbances may be introduced into the refugia, in the 
form of "land use activities compatible with disturbance patterns." 
[FEMAT V-55]. The net effect of this strategy is that the already 
disturbed refugia will be subject to: 

1 . the natural disturbance regime, 

2. the legacy of past disturbance, 

3. new disturbance "compatible with disturbance patterns". 



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In this context, introduction of any new disturbance seems manifestly 
inconsistent with the "crucial" role of refugia. It is important to 
remember that key watersheds are only the slightly less disturbed areas 
in a universally disturbed landscape. Science has no way, at present, 
to accurately assess the current risk to these areas, or to assess the 
likelihood of future risk under different management scenarios. There 
is very little basis for estimating the ability or rate of large disturbed 
watersheds to regain effective ecological ftmction or for wide ranging 
species (e.g. anadromous salmonids) to redeploy population structures 
and life history strategies consistent with those recovering ecosystems. 
Similarly, at the ecosystem level science cannot yet tell us the general 
conditions under which disturbance is or is not reversible. 

These already altered key watersheds will be subject to an ongoing 
rate, pattern, and intensity of natural disturbance regardless of future 
management. Even total protection does not ensure their continuing 
functioning. This suggests that any further disturbance of key 
watersheds is unjustified until the watersheds and at-risk fish recover: 
that is, until these areas are no longer needed as refugia. These 
decisions should be made by agency scientists with independent 
scientific review and approval. We believe that if the management of 
key watersheds is to be modelled on the rate, pattern and intensity of 
natural disturbance then natiu"al disturbance alone will provide exactly 
that, and that management activities within refugia should be 
appropriately limited to reducing the effects of prior human-caused 
disturbance. 

E. Removal of the key watersheds from the timber base would be 
consistent with the recent recommendation of the Eastside Forests 
Scientific Society Panel's report to Congress and the President, which 
recommended complete cessation of logging and roadbuilding within 
Aquatic Diversity Management Areas, which include "key 
watersheds. " 

F. This deficiency in the preferred alternative may be remedied by 
removing key watersheds from further logging, reading and other 
increase in disturbance, as suggested in the FEMAT report [FEMAT 
V-72]. Management that reduces or eliminates the effects of previous 
human-caused disturbance is the only appropriate action. 



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III. The preferred alternative proposes a "Watershed Analysis" process that is 
unproven, unduly complicated, and not organized so as to provide efTective 
decision points and cost-effective action priorities. The experimental watershed 
analysis process should be utilized only outside of key watersheds. Within key 
watersheds, only a Watershed Restoration Action Plan should be utilized to 
reduce or eliminate the effects of human-caused disturbances. 

A. A comprehensive watershed analysis, watershed restoration, and 
long term monitoring program is required under the Aquatic 
Conservation Strategy (FEMAT V-58). The watershed analysis is "a 
systematic procedure to. guide management prescriptions, setting and 
refining Riparian Reserve boundaries, development of restoration 
strategies and monitoring programs. " A watershed analysis is required 
in "...all roadless areas prior to resource management recommended in , 
all other watersheds... and required to change the Riparian Reserve .- i 
boundaries in all watersheds." (FEMAT V-73). The watershed 
analysis is a scientifically and procedurally unproven process that is 
easily misused. It should not be used to identify new logging and 
roadbuilding opportunities in key watersheds. As an experimental 
process, it should not be applied within the remaining few "safe" areas 

— the key watershed refugia. It should only be utilized outside of key 
watersheds, where even greater disturbance has already occurred, 
where the pressure for future timber harvest will go, and which, at 
present, are proposed to have even less riparian protections. In these 
areas, safeguards are needed through clear and definitive rules and 
regulations for the analysis, decision making and implementation 
aspects. The process as it currently exists should be streamlined to 
increase its usefulness by prioritizing restoration aaivities on a 
watershed basis. 

B. The watershed restoration program utilized within key watersheds 
should be aimed at controlling and preventing road-related runoff and 
sediment with a primary focus on hiJlslopes, improve the conditions of 
riparian vegetation, and improve the habitat structure in stream 
channels. Stormproofing and/or removing the most damaging of the 
roads within key watersheds should be the first priority. Following 
this, the priority should be the remaining roads in the region [FEMAT 
V-76]. 



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C. Within key watersheds, a Watershed Restoration Action Plan 
should be developed that prioritizes the restoration activities required. 
A thorough, on-going monitoring program is needed to complement 
the restoration work. If done properly, this program would go a long 
way toward recovery of aquatic habitat and salmon recovery, while 
providing some employment for rural communities. However, we find 
no evidence of how the monitoring program will work. Further, tfie 
funds for restoration are already significantly less than what the 
President first announced and even the lesser amount is uncertain over 
the long term. The agencies also seem reluctant to commit to any 
specific use of the fiinds for the restoration strategy stated in FEMAT, 
should they eventually get them. This makes the restoration program 
wonderful in concept, but extremely questionable in reality. 

IV. The preferred alternative falls to adopt needed and mandated riparian 
protection for all riparian dependent vertebrate species, and gives arbitrary 
preference to maintenance of at-risk fish. We believe that full riparian 
protections are required outside of key watersheds in order to meet the 
requirements of the National Forest Management Act to protect all vertebrate 
species well distributed across their range. 

A. The protection of riparian ecosystems is essential in maintaining 
well-distributed populations of a host of species, including but not 
limited to at-risk fish [FEMAT V-25, V-E, SAT 444^W6, 274, 281- 
283]. 

B. While an elaborate conservation scheme is provided for fish, the 
same cannot be said of other riparian-dependent species [DSEIS 2-5 1 
to 2-56 ]. While at-risk fish are generally provided with full riparian 
protection and other measures within "key watersheds", [FEMAT, V- 
46] no such full protection or key watersheds are provided to other 
species (including vertebrate species) equally vulnerable and equally 
dependent on riparian protection and watershed/riparian interactions 
(e.g. Olympic salamander complex, tailed frogs). No analysis is 
provided for which watersheds are "key" for other species. As a 
result, the outcome of the preferred alternative for non-fish riparian 
dependents is poor. For example, only half of the 16 protected 
amphibian and reptile species in the preferred alternative will maintain 
well-distributed populations [DSEIS, S-I3], primarily because of 
inadequate riparian protection outside of key watersheds, particularly 



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on intermittent streams, seeps, and other headwater watercourses that 
are the habitats for these species. FEMAT discloses the failure of 
narrow ( < 1 tree height) riparian reserves to maintain the cool, moist 
conditions that are associated with the maintenance of some well- 
distributed amphibian populations [FEMAT V-27]. Additionally the 
FEMAT discloses that a pattern of local extirpation of such species is 
already imderway [FEMAT V-11]. 

C. The disparity in effort for at-risk fish and other riparian dependent 
species reflects an arbitrary preferential maintenance of habitat of 
some vertebrates over others. The preferred alternative thereby fails to 
be a comprehensive attempt to meet the National Forest Management 
Act (NFMA) requirement to maintain well-distributed populations of 
vertebrates. The preferred alternative's recommendation that 
ecologically effective riparian protection be limited to selected fish 
areas — largely anadromous salraonid areas - is not supportable 
ecologically. Not enough is known about the distribution of 
amphibians to justifiably claim that any mitigation strategy can work. 

D. In addition, the knowledge that a pattern of extirpation of riparian 
dependent species is already underway suggests that the adoption of 
the inadequate preferred alternative will precipitate another 
Endangered Species battle over time. This is precisely the outcome the 
FEMAT was meant to preclude. 

E. These deficiencies should be remedied by: 

1 . Full riparian protection outside of key watersheds on permanent and 
ephemeral streams [FEMAT V-78]. 

2. Establishing a system of key watersheds for other species dependent on the 
integrity of watershed/riparian interactions, e.g. the Olympic salamander complex. 
Although much information on current distributions and status of these species may be 
lacking, the preferred alternative could at least provide a process to address these 
known and significant issues. 

V. No alternative will work effectively given the lack of public faith and trust in 
the current agency leadership. No matter what final alternative is chosen, it will 
fail without a significant change in the agency leadership and mindset. While 
there are many highly professional staffers within the Forest Service and Bureau 



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of Land Management, the public has no faith or trust in the current agency staff 
to properly implement any technically appropriate or possible solutions. Without 
substantial changes in agency staffing — from top to bottom — along with 
intensified skill improvement, all alternatives will fail. 

VI. The preferred ahernative prescribes adaptive management that allows, even 
encourages, pseudo-scientific experiment with public resources in absence of 
deariy defined controls and in absence of any monitoring worthy of the name. 

A. The degraded and depleted National Forests that we have before 
us, and the Endangered Species controversies that necessitated the 
production of the DSEIS and FEMAT reports are, in large part, the 
result of an uncontrolled landscape-level experiment scandalously 
deficient in evaluation and monitoring of past practice - namely 
current forest management. Chief among the failures of that 
management has been the failure to monitor the effects of our activities 
and change them accordingly. The FEMAT concedes this point, 
saying: "Currently, adequate monitoring is essentially 
nonexistent... despite being required by forest plans." Then, in a series 
of hair-raising passages, the FEMAT proposes an entirely new series 
of fast track "experiments" — with no more restriaive monitoring than 
is required in the discredited Forest Plans. This really is outrageous. 
Until the failure of the last 1 5 years of monitoring is addressed, any 
proposal for new uncontrolled experimentation is unconscionable. 

B. One example should suffice: the FEMAT suggests that a priority 
topic for the so-called adaptive management areas is "Integration of 
timber production with maintenance or restoration of fisheries habitat 
and water quality." We should all remember that every timber sale 
sold since the enactment of the National Forest Management Act, and 
every Forest Plan, have claimed to integrate timber production with 
the maintenance of fish habitat. The entirety of the Pacific Northwest 
is carpeted with sites where the relationship between timber production 
and water quality can be examined in limitless detail. The basis for 
planning new "experiments" can only be a thorough understanding of 
the effects of our past experiments, which the FEMAT concedes has 
not been done. 

C. For adaptive management to be any improvement over historical 
Forest Planning, it must allow only bona fide controlled experiment. 



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subject to all the rigor that implies, in small sites that can withstand 
failed experiments. To do less is to mock the notion that the 
management is adaptive. If we are going to experiment, let us do so 
properly, with refutable hypotheses, experimental controls, referees, 
and at a long enough temporal scale that we have some possibility of 
detecting the true ecosystem level consequences of our actions. This 
will not be easy. 

VII. The preferred alternative allows entry into old-growth reserves. All of the 
remaining reserves should be protected. 

The plan proposes old growth "Reserve Areas" that include only about half of 
the old growth forests and designated conservation areas to protect specific species. 
Activities would be permitted in the reserves-including salvage logging and thinning, 
to "accelerate the development of old growth conditions." The old-growth that 
remains is vital to the continued functioning of watershed ecosystems. Permanent, 
clear protection for the reserves must be included. Salvage, thinning and new forestry 
are unacceptable within reserves and within Key Watersheds that are already at risk. 

Vni. The preferred alternative allows roading of some of the roadless areas. All 
roadless areas should be protected. 

Roadless areas are the anchors to the existing health of the watersheds and are 
vital for all watershed restoration efforts. They also tend to be the most unstable areas 
because of their location high in the headwaters of watersheds. Road construction in 
these areas often causes catastrophic land slides and chronic sedimentation problems as 
the unstable slopes give way. New roads must be prohibited in all large or 
biologically significant roadless areas . This is consistent with the recommendation of 
the Eastside Forests Scientific Society Panel's report to Congress and the President. 

IX. The plan is coupled with an attempt to find timber volume in other areas. No 
area, including the east-side forests of Oregon and Washington, should be 
sacrificed due to poor land management practices on the west side. 

A. Intensified salvage is proposed on the East-side of the Cascades. 
Many scientists say this may further degrade East-side streams and 
salmon. No east-side salvage plan should be allowed that is 
inconsistent with the this report. The East-side must have a permanent 
protection/restoration plan. 



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X- The Relationships Between the Current Plans and Draft Plan Preferred 
Alternatives to Option 9 Are Unclear 

Option 9 standards and guidelines are to apply except where current plans and draft 
preferred alternatives "provide greater benefits to late-successional and old-growth 
related species." DSEISat2-12. 

A. The DSEIS does not state how a determination of "greater benefits" 
is ultimately made, or whether such a determination has already been 
made in some or all cases. For example, as discussed below with 
reference to specific land allocations, the plan appears to presume that 
Congressionally and administratively withdrawn lands are currently 
managed in a manner which meets the conservation objectives of 
Option 9. 

B. The plan does not define the "benefits" to be considered in making 
the greater benefits determination. 

XI. The Standards and Guidelines Applicable to the Seven Land Allocations Are 
Incomplete, Insufficient, or Unclear. 

/. Congressionally Reserved Lands: Management of these lands is to follow current 
direction written in the applicable legislation or plans. DSEIS at 2-13. 

A. Option 9 does not acknowledge the possibility that current 
management direction for some of these lands may not be ftiUy 
consistent with the ecological objectives of the new plan. For 
example, designation as a wilderness area does not ensure that grazing 
will not be permitted in riparian zones. The same is true of lands 
included by Congressional action in the Wild and Scenic River system, 
where many types of agricultural and grazing activities may be 
permitted under current management plans. The preferred alternative 
should clearly state the threshold standards and guidelines applicable to 
all congressionally withdrawn areas, rather than simply deferring to 
those applicable under current plans and draft plans. This will ensure 
that withdrawn lands excluded from old-growth, riparian or key 
watershed designations are not managed in a manner which 
compromises the management goals for these designations. 



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B. It also appears that Wild and Scenic rivers are not consistently 
treated. They are referred to as part of Congressionally withdrawn 
lands in some places, such as DSEIS page 2-13 and FEMAT rX-7, but 
as administratively withdrawn in others, such as FEMAT II-6. 

2. Maps of Late-Successional Reserves: Option 9 includes some parts of LS/OGl and 
LS/0G2, and some or parts of the Designated Conservation Areas (DCAs) from the 
USDI Recovery Plan for the western portion of the owl's range. The land allocations 
are indicated on the Maps. 

A. These maps do not close the question of whether a particular sale 
or unit is within a reserve or other land allocation category. Site-level 
determinations and map refinements will have to be made to 
implement the intended reserves. The scope of these reserves should 
be stated in narrative form as part of the standards and guidelines 
applicable to the reserves. This important guidance should not be left 
to large scale maps (the maps are not drawn on a fine enough scale to 
make site-level determinations) or to blanket references to the 
Scientific Panel's report. The criteria for determining LS/OGl and 
LS/0G2 categories and the areas to die which they apply should be 
clearly stated as standards and guidelines. Likewise, the geographical 
area in which the reserves are determined using the Recovery Plan's 
DCA criteria should be clearly stated, and these criteria should also be 
included as standards and guidelines. 

3. Standards and Guidelines for Late Successional Reserves: There are four sets of 
standards and guidelines stated in Alternative 9 for Late-Successional Reserves: A. 
those generally applicable; B. those ^plicable West of the Cascades; C. those 
applicable East of the Cascades and the Eastern Portion of the Klamath Province, and 
D. those applicable to Other Late-Successional Reserves. Comments follow pertaining 
to three of these four sets. 

A. Generally Applicable Standards and Guidelines for all LS Reserves. 
"Thinning and other silvicultural treatments inside reserve requires 
review by an interagency oversight team to ensure that they are 
beneficial to the creation of late-success ional forest conditions .... 
Salvage of dead trees would be based on guidelines adapted from the 
Final Draft of die Northern Spotted Owl Recovery Plan (see Appendix 

B, Recovery Plan Standards and Guidelines) and would be limited to 
areas where catastrophic loss exceeded 10 acres." DSEIS at 2-40. 



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1. Where and what are the standards and guidelines for the interagency 
oversight team? What is this team's composition, authority etc.? This 
guidance should be included as part of the F*referred Alternative. 
Without this, there is no way to judge the effectiveness of the 
standards and guidelines. 

2. What does "based on guidelines adapted from" mean? Does the 
plan adopt the reference standards and guidelines wholesale? If so, 
why not say "salvage will comply with the standards and guidelines" 
set forth in the Recovery Plan or at a particular place in the FEMAT 
report? (e.g. General guidelines for silviculture, reduction of 
large-scale disturbance and salvage are stated at III-34 through 39). 
The plan must clearly state what standards will apply or it will not be 
impleraentable. The best way to do this is state the applicable 
standards and guidelines in one place, without reference to extraneous 
documents. We have no way to determine the actual guidelines. 

3. "Catastrophic loss" is not defined. "Loss" jq)pears to mean "where 
trees have been lulled." FEMAT n-9. 

4. It is not clear whether thinning will be allowed both when it is 
"beneficial" to the creation of late-successional forest conditions and 
when it is "neutral" to the creation of such conditions. FEMAT page 
II-9 states that "Option 9 also allows thinning that has a neutral effect 
on the attainment of late-successional forest condition. " (We 
understand that an errata sheet was issued with regard to the use of the 
term "neutral," but have not seen it). 

B: East of the Cascades and Eastern Portion of the Klamath Province. 
"Guidelines to reduce risk to large-scale disturbance are adapted from 
the Final Draft of the Northern Spotted Owl Recovery Plan" with 
reference to Appendix B. 

1 . Again, we do not clearly know exactly what the applicable 
standards and guidelines will be. 

C. Other Late Successional Reserves. These LS Reserves result from 
the identification of "occupied marbled murrelet sites" and the 
application of "some protection buffers for other species." DSEIS at 
2^; FEMAT at in-22. 



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1. The meaning of "occupied murrelet sites" is described at 2-17 and 
FEMAT IV 23-24. Standards and guidelines should be clearly 
enunciated which apply to the identification of occupied sites and the 
interim management scenario pending identification of these sites. 

2. The meaning of "some protection buffers for other species" is not 
clear - it appears to mean "some" of the SAT recommendations for 
protection of nine at-risk species. See Appendix B-67 to 69. It is not 
clear, however, what comprises "some" of the protection buffers. The 
modifier "some" is used at one place in the FEMAT report's 
description of Option 9 (III-22) but Table III-2 (\U-1) simply states - 
that "buffers for other species" shall apply in LS reserves. 

4. Managed Late-Successional Areas: Buffers for other species as per the SAT report 
are presumed to apply, as per Table III-2 at FEMAT 111-7. 

A. However, it is not clear whether there are any "managed late 
successional areas" in Option 9. No such category is reference in the 
description of this alternative in the DSEIS, though there appear to be 
small managed areas included. FEMAT II-l 1. 

5. Adaptive Management Areas: The standards and guidelines applicable to adaptive 
management areas are unacceptably vague or nonexistent. 



A. First, are the "standards and guidelines" intended to be completely 
stated at page 2-41 of the DSEIS or do they include the "additional 
information" from the FEMAT report which appears at B-57 through 
B-66 (also FEMAT m-28 through 22). While we prefer the latter, the 
"standards and guidelines" which emerge here still lack sufficient 
specificity to enable implementation. 

This is not surprising given that the goals and objectives of these areas 
are multiple and even conflicting. For example, the AMAs are 
supposed to "encourage the development and testing of technical and 
social approaches to achieving desired ecological, economic and other 
social objectives," including well-distributed late successional habitat 
outside of reserve, retention of structure in harvested forests, the 
restoration and protection of riparian zones and the provision of a 
stable timber supply. B-57. However, the "overarching objective" is 



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"to learn how to do ecosystem management in terms of both technical 
and social challenges, and in a manner consistent with applicable law." 
B-57. This "experimental" objective permits land managers to apply 
"localized, idiosyncratic methods that may achieve the conservation 
objectives" of Option 9 - which clearly implies that a level of risk to 
these objectives will be tolerated. However, it is not clear exacdy 
what level of risk is implied, how it is to be measured, or what 
thresholds will be set. 

B. Although it is stated that "[m]onitoring is essential to the success of 
any selected option and to an adaptive management program," there 
are no standards and guidelines which define "adequate monitoring." 
Rather, the FEMAT simply states that "adequate monitoring is 
essentially nonexistent throughout the federal resource management 
agencies," (B-59) and states that "development and demonstration of 
monitoring and training of the workforce are technical challenges and 
are suggested for emphasis." B-59. A list of technical topics are 
suggested as "a priority" for AMAs. In order to be even remotely 
implementable. Option 9 must include minimum management 
requirements for monitoring of the "experimental" techniques which 
are to be applied — this key component cannot be left to the same 
agencies who failed to adequately monitor the implementation of 
techniques not considered to be experimental. This is the very failure 
which largely precipitated the need for the emergency planning process 
in which we are now engaged. 

C. The FEMAT states that each AMA "should have an 
interdisciplinary technical advisory panel, including specialists from 
outside government agencies, that would provide advice on research, 
development and demonstration programs." B-60. We find no 
standards and guidelines which enumerate the requirements of such 
panel, its authority etc.? Why were such standards and guidelines not 
included? Clear standards and guidelines for technical review must 
be included as part of the preferred alternative. 

D. "Social" and "institutional' experimentation are included as part of 
the raison d'etre for AMAs: the FEMAT language appears to 
anticipate new relationships between local communities and federal 
land managers (B-60) as well as interagency plans which both 
expedite planning and set up new internal working mechanisms for the 



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agencies. (B-60-61). This entire discussion is vague and should be 
translated into more specific guidance. Also, it is stated that new 
agency approaches to planning "should" receive initial direction and 
continuing oversight from "a regional interagency group, possibly 
working through the Provincial Interagency Team if this concept is 
adopted from the implementation plan." B-61. This mechanism 
should be more clearly stated as part of the preferred alternative, and 
initial guidance and oversight should be stated clearly as a 
requirement, with further detail about the oversight mechanism. 

6. Administratively Withdrawn Areas: The DSEIS appears to assume that in all areas 
not currently scheduled for timber harvest and therefore not included in calculations of 
ASQ, the standards and guidelines of the current plans and draft plan alternatives 
provide greater benefits to late-success ional and old-growth related species than does 
Option 9. See DSEIS at 2-13 & 2-14.. Option 9 does not include any guidance for 
ftiture activities affecting these lands, although the FEMAT clearly recognized that the 
management status of these "administratively withdrawn" lands varies depending on 
the type of administrative withdrawal, and that under current plans and draft plans 
some of these lands are eligible for reevaluation of their status by administrative 
action. III-4 «& n-25. 

A. The preferred alternative should clearly state both optimum and 
minimum standards and guidelines applicable to all adminisfratively 
withdrawn areas, rather than simply deferring to those applicable 
under current plans and draft plans. 

7. Riparian Reserves: The DSEIS description of Option 9 states only the applicable 
riparian widths, presumed to be the "interim" reserve widths pending watershed 
analysis and approval of an interagency oversight team. 

A. The standards and guidelines applicable to riparian reserves should 
be clearly stated in a single location. We presume them to be fully 
stated in Appendix B to the DSEIS, which excerpts Chapter V of the 
FEMAT report. However, it is unclear whether the standards and 
guidelines are all stated AB B-84 through B-88, or whether other parts 
of the Aquatic Conservation Strategy can be considered to constitute 
standards and guidelines. We urge the inclusion of more information 
from the FEMAT - but which recommendations apply is not at all 
clear from the format of the DSEIS. Such confusion can only hinder 



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speedy implementation of the final plan. We remain unclear about the 
fiill standards and guidelines for riparian reserves. 

B. There are portions of the ACS which should be considered as 
standards and guidelines and incorporated as such in a format similar 
to that found on pages B-84-88.. For example, the standards and 
guidelines should specifically include: 

(1) the objectives and the components of the Aquatic Conservation 
Strategy listed on page B-76 and B-77. This only makes sense, since 
they are repeatedly referenced in the standards and guidelines. 

(2) the minimum required widths of Riparian Reserves - both the 
interim designations and the standards and guidelines which should be 
met for permanent designations. At present, interim buffers are stated 
in one place (2-41), the management standards in another (B-84-88) 
and the criteria for establishing permanent buffers in another 
(B-77-79). 

(3) a description of the criteria which led to the Key Watershed 
system and management standards applicable there. Standards and 
guidelines should specifically state that watersheds or portions not 
initially included in the system but which are found to meet the criteria 
through watershed analysis shall be included and managed as key 
watersheds. (Designation as a key watershed affects riparian reserve 
areas as well as restoration priorities). 

(4) the goals and procedures applicable to Watershed Analysis such as 
exist in the FEMAT report (DSEIS B-80-82 & FEMAT Ch. V, 
Appendix I (19 pages, unnumbered appendix). This information 
should be explicitly digested into standards and guidelines regardless 
of the fact that a Watershed Analysis Handbook is anticipated - The 
guidance provided by this plan will govern agency actions until such 
time as Handbook is adopted, so it should at least be as clear as 
possible. It is not adequate to state that "an overview of the watershed 
analysis process and objectives is included in Appendix B and that 
"additional information is presented in the FEMAT report." DSEIS at 
2-18. 



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September 23, 1993 
Comments on DSEIS 



250 



(5) a more detailed description of the Watershed Restoration program 
than appears at B-88, WR-1 through WR-3. Namely, include as 
standards and guidelines the specific recommendations made in 
Appendix V-J of the FEMAT report (13 page unnumbered appendix). 
These should include at least the specific ten items listed at pages 
V-J-1 1 and V-J- 12 (numbers inserted). ((We assume that the DSEIS is 
using the FEMAT's definition of site-potential tree, as stated at 
Appendix B-78 lines 2 and 3), 

C. As currently stated, the Option 9 Riparian Reserve interim buffers 
do not clearly comply with the FEMAT's requirements for interim 
buffers: (See B-78). The DSEIS, page 2^1, indicates that it 
considers interim riparian reserve widths for Option 9 to consist of the 
buffers described as follows: ,. 

Fish bearing streams, lakes & reservoirs : Twice the height of a 
site-potential tree, or 300 feet, whichever is greater. 

Permanently flowing non fish-bearing streams, ponds. & wetlands 
greater than one acre : One site-potential tree or 150 feet, whichever is 
greater. 

Intermittent streams & wetlands less than one acre in Aquatic t 

Conservation Emphasis Key Watersheds : One site-potential tree or 
100 feet, whichever is greater. 

Intermittent streams & wetlands less than one acre in All Other 
Watersheds : Half the height of a site-potential tree or 50 feet, 
whichever is greater. 

At page 2-16, however, it is recognized that interim riparian reserve 
widths are described by the FEMAT either in terms of minimum 
widths "or site-specific geomorphic criteria such as the 100-year 
floodpiain, whichever is greater." The geomorphic criteria for 
riparian reserves must be explicitly included in the standards and 
guidelines for interim buffer widths as they appear in the FEMAT 
report at V-35 & 36 [DSEIS Appendix B-78]. These criteria include 
possible alternative measurements of reserve areas based on: (1) the 
distance from the active channel to the top of the inner gorge; (2) the 
width of the 100-year floodpiain; (3) the extent of riparian vegetation; 



Page 18 

September 23, 1993 
Comments on DSEIS 



251 



(4) the extent of seasonally saturated soil, and (5) the extent of 
unstable and potentially unstable areas. 

8. The Matrix Lands: These are to be those lands outside the previous 
six categories, and in the case of Option 9, there appear to be six 
applicable standards and guidelines (from 2-42): 



(i) National Forests in the Oregon Coast Range, the Olympic and 
the Mt. Baker Snoqualmie, current plan and draft plan provisions 
apply "for the retention of snags, logs, and green trees in cutting 
units." 

(ii) For other National Forests in Oregon and Washington, 15% of 
the area in each cutting unit is to be retained, with at least half of this 
in small (1/2 to 4 acre) patches of intact late-successional forest or the 
next oldest stand available. The remaining half is to be left in green 
trees dispersed throughout the unit. 

(iii) For BLM lands north of Grants Pass. 

(iv) For BLM lands south of Grants Pass. 

(v) For all federal lands in California, "manage using area control 
to achieve 180-year rotations in conifer stands, l(K)-year rotations in 
hardwood stands, and retain 15 percent of the volume on each cutting 
unit.." 

(vi) SAT protection buffers for nine at-risk species ("other species") 
apply on all matrix lands. 

A. As a general conMient, there is no explanation for why the 
retention and rotation requirements vary as between the majority (i.e. 
mostly non-coastal, non-murrelet) of the National Forest lands (15% 
standard per harvest unit) and the Oregon BLM districts (variable 
green tree retention requirements per acre, with 150-year rotations for 
some areas). We can only guess that the intent was to preserve some 
of the structure of the respective agencies' plans and draft plans, but 
we can see no practical reason why leave-tree requirements shouldn't 
at least be determined according to the same methodology, i.e. either a 



Page 19 

September 23, 1993 
Comments on DSEIS 



252 



percent per harvest unit type of requirement or a number of trees per 
acre requirement. We note that BLM land and National Forest lands 
in Northern California are subject to the same standards, and suggest 
that the same should be true of those in Oregon and Washington. 

B. The DSEIS appears to include the full text of the SAT report set 
forth at B-67 through 69 as the applicable standards and guidelines. 
These range from the specific (Del Norte salamander has a riparian 
buffer and canopy closure requirement, and the white-headed 
woodpecker has a specific snag per acre requirement) to the vague 
("provision of snags" for pygmy nuthatches). In some cases, such as 
for the flammulated owl, the standards and guidelines under existing 
forest plans are assumed to provide adequate habitat. We note that 
these standards and guidelines contain a number of policy 
recommendations for site-specific analyses, special reviews, formation 
of interagency groups and development of species-specific timber, 
reading and fire management plans. B-69. 

Xn. Many Other Items are Inconsistent and Need Clarification 

A. It is not clear whether the preferred alternative accepts the FEMAT 
conclusion that calculations of Allowable Sale Quantity are neither 
possible nor consistent with the imposition of ecological parameters 
under the new management regime. For example, in describing the > 
Matrix, it states that: "All scheduled timber harvest (i.e. that 
contributing to the ASQ) takes place in the matrix" (DSEIS at 2-14). 
The FEMAT, however, makes it clear that determination of even 
"probable" sale quantities under any of the options, and particularly 
Option 9, are problematic at best. See e.g. FEMAT at 1 M7; 11-104. 
We urge that the preferred alternative include clear guidance on how 
any estimate of available timber should be used, such that any attempt 
to use this estimate as a floor amount or as a management "goal" (such 
as was done with the ASQ) is thwarted. 

B. The DSEIS acknowledges the FEMAT's incorporation of land 
allocation and standards and guidelines from four prior scientific 
efforts: (1) the ISC report; (2) the Scientific Panel's report; (3) the 
1992 USDI Spotted Owl Recovery Plan, and; (4) the SAT report. 
DSEIS at 2-14 and 2015. Although the recommendations borrowed 
from these reports are explained at various points in the DSEIS and 



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September 23, 1993 
Comments on DSEIS 



253 



the FEMAT report, it is stated that "Further details for specific 
standards and guidelines can be found in the parent documents..." 
DSEIS at 2-15. We suggest that such references not be retained in the 
final plan and that the standards and guidelines applicable to a specific 
land allocation or action be fully stated such that no ": further details" 
are necessary to determine their meaning. That is, the standards and 
guidelines should be "fully integrated" in a single document and stated 
as such. We note that no changes to the action alternatives developed 
and described in the FEMAT report were intended through translation 
into the DSEIS format: "No changes to the land allocations or 
standards and guidelines were intended in presenting them as 
alternatives in this document." DSEIS at 2-12. However, this general 
statement does not obviate the need to be clear about what standards 
and guidelines in the referenced document actually are. 

Xm. The Implementation of Standards and Guidelines in the Preferred 
Alternative Is Unclear 

A. "oversight groups would be responsible for interpretation of 
guidelines provided by any selected option, as well as review and 
approval of proposed modifications." FEMAT rV-28. It is not clear 
to us that tiiis procedure is part of the preferred alternative? If so, 
guidance should be provided as to how the oversight process will 
work. 

XIV. The Adaptive Management and Implementation Process Outside of AMAs is 
Undear 

A. The FEMAT states diat "A formal process of adaptive management 
would maximize the benefits of any option described in this report and 
achieve the long-term objective of ecosystem management [11-36]." It 
is not clear to what extent the preferred alternative is intended to adopt 
the recommendations set forth in FEMAT' s Giapter VIII on 
Implementation and Adaptive Management? 

XV. The DSEIS Fails to Include Other Federal Management Agendes as Lead 
Agendes 

A. As currently structured, the DSEIS includes only the Forest Service 
and the BLM as the lead agencies. The final Record of Decision 



Page 21 

September 23, 1993 
Comments on DSEIS 



7R-7Qq n - Q/1 - Q 



254 



implementing the preferred alternative will not include the National 
Park Service or other agencies, such as the U.S. Fish and Wildlife 
Service, that manage 2.2 million acres within the range of the northern 
spotted owl [FEMAT at 11-23]. This is true despite the fact that the 
FEMAT was instructed by the Forest Conference Executive 
Committee to develop alternatives which meet the objective of 
maintaining and/or restoring spawning and rearing habitat on Forest 
Service, BLM, "National Park Service and other federal lands to 
support the recovery and maintenance of viable populations of 
anadromous fish species and stocks and other fish species and stocks 
considered sensitive or at-risk by the land management agencies or 
which are listed under the ESA. See e.g. FEMAT II-5. 

XVI. Summary: The DSEIS fails to comply with NEPA Standards. 

The preceding comments have identified a niunber of areas in which the details of the 
preferred alternative are sufficiently unclear or conflicting so as to prevent a full 
assessment of the impacts of the proposed action. Therefore, for the reasons stated 
herein, the Pacific Rivers Council believes the DSEIS is "so inadequate as to preclude 
meaningful analysis" of the proposed action and its impacts as required by the 
National Environmental Policy Act (40 C.F.R. § 1508 (a). We therefore conclude 
that the SDEIS does not comply with NEPA standards. 



Page 22 

September 23, 1993 
Comments on DSEIS 



255 



Invited Testimony by Juue Kay Norman, 
President of Headwaters 

TO THE 

House Subcommittee on Specialty Crops and Natural Resources 
Representative Charles Rose, Chair 

November 18, 1993 

Roadless Area Protechon in Option 9 
OF President Clinton's Draft Forest Plan 



I'd like to speak with you today about the largest areas of undisturbed forest 
that remain unprotected in the Pacific Northwest, the Roadless Areas, and then 
describe why they should be added to the Reserve system in President Clinton's 
Forest Plan. 

Most of the federal forest landscape in the Pacific Northwest has already been 
fragmented by logging roads and dearcuts. The forests that formerly stretched from 
ridge to ridge are now cut up into patches so small that the survival of many 
wildlife spedes is threatened. In a House subcommittee meeting on July 25, 1990, 
Forest Service Chief Dale Robertson admitted that only 10% of the public's andent 
forests were left. 

Roadless Areas are the best remaining places large enough to allow the full 
range of ruitural ecosystem processes to function. By defirution. Roadless Areas are 
greater than 5,000 acres in size, so they are big enough to encompass a diverse 
array of andent forest groves and watersheds. 

They were first mapped in the 1970's to evaluate lands for protection by the 
Wilderness Ad. Those that were not chosen for Wilderness designation by 
Congress and have survived into the 1990's are becoming more valuable each year 
as the forest is cut up around them. It would be a great loss to the Nation to cut 
these last intad forests now, when the biological importance of unfragmented forest 
ecosystems is finally being recognized. They are critical for the protection of 
wdldlife, and provide the last refuge for spedes like the salmon and steelhead that 
depend on dear cool water. 

The best single way to improve President Clinton's Forest Plan would be to 



256 



include all of the Roadless Areas wdthin Late-Successional Reserves. The chance for 
long-term survival for many spedes would be significantly improved by reserving 
the remaining 1.4 million acres of unprotected Roadless Areas, which is important if 
the President is to succeed in designing a scientifically and legally credible solution. 

And it is importamt to note that protecting all the Roadless Areas can be had 
for a disproportionately small price in cutting levels. It would increase the size of 
the Reserves by 18%, but would reduce annual timber sale levels by only 6%, 
because Roadless Areas have so much less land designated as commercially 
"suitable" for logging. In fact. Headwaters has determined that the proportion of 
Roadless Areas "suitable" for logging is only 23%! That's half of what it is in the 
already roaded lands. Since only protection of "suitable" acres reduces the annual 
cut levels, three out of four acres in the Roadless Areas get protected for free. 
That's why we say that protecting thp Roadless Areas is a biodiversity bargain. 

Specifically, protecting all the Roadless Areas would only lower Option 9's 
annual timber sale level by 6%, to approximately 1.1 billion board feet per year 
(from Johnson, et al., 1993: Roadless Area Probable Sale Quantity of 69 mmbf/yr. 
divided by Total Probable Sale Quantity of 1,155 mmbf/yr. = .06). 

Other factors make the Roadless Areas even more of a biodiversity bargain. 
Roadless Areas contain more steep slopes than other areas of the forest, and this 
results in higher logging costs and road-building costs. And because there is less 
land suitable for logging, many more miles of expensive roads will need to be built 
to access the same amount of timber. 

Environmental analysis costs for Roadless Areas are also high. In contrast to 
other places in the forests, legcil precedent has established that logging in Roadless 
Areas will always have a significant impact on the environment, so that a full 
Enviromental Impact Statement (EIS) is required. Because outstanding fisheries 
values are better protected by undisturbed watersheds like Roadless Areas, 
comprehensive "Watershed Analyses" are required by Option 9 before timber sales 
can proceed. These intensive surveys (that may not be pciid for by the value of the 
, timber removed) will be needed to measure a host of variables such as unstable 
soils, landslide locations, stream pool depth, water temperature, and fish 
populations. And there is a high likelihood, based 6n scientific evidence presented 
in the Clinton Plan, that such analyses will result in a recommendation for "no 
action." 

As Professor Norm Johnson of the President's team was quoted as saying in 
The Oregonian (October 20, 1993), 

"It's going to be a major investment in resources to enter those Roadless 
Areas. They're going to have to have Environmental Impact Statements, 
they're more expensive to log. We really do have to ask the question of each 
one, is it worth it?" 



257 



Because we believe strongly that Roadless Areas should be protected. 
Headwaters hcis spent a considerable amount of time analyzing exactly how this 
could best be accomplished. In consultation with the Sierra Biodiversity Institute, 
we have assembled the information needed to measure acres of suitable timberland 
with a computerized GIS system. Using this methodology, we have demonstrated 
how Roadless Areas could be exchanged (if necessary) for roaded lands already 
within the Late-Successiorial Reserves. Large areas of ecologically significant 
Roadless Areas could be traded for fragmented lands with no net decline in annual 
cut levels. The Forest Service and the BLM have this capability as well, and we 
would like to work together with them to improve the efficiency of the Reserve 
system's design. 



In conclusion. Roadless Areas are the biodiversity bargain that provides the 
best way of strengthening the President's Forest Plan. These large blocks of intact 
watersheds are crudal to the viability of the ecosystem as a whole. The rugged 
landscape that has protected these places for so long is also the reason to expect 
expensive analysis, roadbuilding and logging. If Roadless Areas were profitable to 
log, they would have been logged already. 

Now that the great biological cind economic value of undisturbed ecosystems 
is finally being recognized, it makes good sense to include full protection for all 
Roadless Areas in the Final Forest Plan. 



il^^ Z^^^^^^^^^O 



Headwaters is a grassroots forests advocacy group based in Southwest Oregon 
that has been monitoring federal forest plaiming processes since 1976. 



Headwaters 

POB729 

Ashland, Oregon 97520 

(503) 482-4459 / fax 482-7282 



(Attachments follow:) 



258 



ALLOCATION OF ROADLESS AREA ACRES 

OUTSIDE OF OPTION 9's 

LATE-SUCCESSIONAL RESERVES 



OPTION 9's 
MATRIX & AMAs 



17% 



23% 




ADMINISTRATIVELY 
WITHDRAWN 



10% 



50% 



259 



Table #1. The relative proportion of suitatjle timberlands outside of Option 9's Late- 
Successional Reserves in national forests within the range of the northern spotted owl: 

Roadless Areas vs. roaded areas in the already rrmnaged landscape 

a. Roadless Areas = 23% suitable 

Suitable timberland = 318,153 acres! 

Total Roadless Areas outside of Late-Successional Reserves = 1361,644 acres^ 





Proportion of suitable acres = 318,153 / 1361,644 f = 23% 

b. Roaded areas = 43% suitable 

Total suitable timberlaiui = 4,086,000 acres^ 

minus suitable timberland in Roaded Areas - 318,153 acres^ 

Total suitable timberland in roaded areas = 3,767^47 acres 

Total roaded areas outside of Late-Successional Reserves 

= Administratively Withdrawn Areas 1,652,900 acres^ 

+ Riparian Reserve Arejis: 2,231300 acres 

+ Adaptive Management Areas 1,487,700 acres 

+ Matrix Areas 4353300 acres 

- Total Roadless Areas outside of Late-Successional Reserves 

10,225^00 acres - 1361,644 acres^ 

8363356 acres 

Proportion of suitable acres = 3,767347 / 8,863356/^ 43% 



^ Jc^utson, et al., 1993, 'Sustainable Harvest Levels and Short Term Timber Sales....", Table 19, p. 62. 

^ Sierra Biodiversity Institute, October 10, 1993 report to Headwaters. 

3 JcAnscm, et al., 1993, Table 16, p. 54. 

* Johnson, et al.. Table 19, p. 62. 

^ FEMAT report Table ID-S, p. 111-44. This Table is also the source for acres in Riparian Reserves, Adaptive 

Management Areas, and the Matrix. 

^ Siem Biodiversity Institute. October 10, 1993 report to Headwaters. 



260 



ScffiNTinc AND Legal Cites 
Regarding Roadless Areas 

1. Paul Ehrlich and E.O Wilson: "The first step (to preserve biodiversity)... would be to 
cease 'developing' any more relatively undisturbed land." 

"Biodiversity Studies: Science and Policy," Science , vol. 253, Aug. 16, 1991, p. 761. 

2. Eastside Forests Scientific Society Panel: 

"Because roads crisscross so many forested areas on the Eastside, existing roadless regions 
have enormous ecological value.... Although roads were intended as innocuous corridors to 
ease the movement of humans and commodities across the landscape, they harm the water, 
soils, plants, and the other animals in those landscapes." (p.3) 

"Do not construct new roads or log within (1) roadless regions larger than 1,000 acres or (2) 
roadless regions that are biologically significant but smaller than 1,000 acres. Roadless 
regions exemplify the least human-disturbed forest and stream systems, the last reservoirs of 
ecological diversity, and the primary benchmarks for restoring ecological health and integrity. 
Roads fragment habitat; alter the hydrology of watersheds; supply excessive sediment to 
streams; increase human access and thus disturbances to forest animals; and influence the 
dispersal of plants and animals, especially exotic species, across the landscape." (p. 4) 

"Interim Protection for Late-Successional Forests, Fisheries, and Watersheds....", 
September, 1993. * 

3. Reed Noss: "An increasingly common saying among wildlife biologists is 'nothing is 
worse for wildlife than a road.'" 

Declaration in support of plaintiffs application for preliminary injunction. Marble 
Mm. Audubon Society, et al. v. U.S. Forest Service, December 11, 1989. 



(Additional attachments are held In the committee files.) 



261 



STATEMENT OF TIMOTHY P. CULLINAN 

WILDLIFE BIOLOGIST 

NATIONAL AUDUBON SOCIETY 

BEFORE THE HOUSE AGRICULTURE SUBCOMMITTEE 
ON SPECIALTY CROPS AND NATURAL RESOURCES 

REGARDING THE "PREFERRED ALTERNATIVE" FOR 

MANAGEMENT OF FEDERAL FOREST LANDS WITHIN THE 

RANGE OF THE NORTHERN SPOTTED OWL 

WASHINGTON, D.C. 
NOVEMBER 18, 1993 



Mr. Chairman, my name is Tim CuUinan. I am a wildlife biologist for the 
Washington State office of the National Audubon Society. Since 1988 I 
have represented the National Audubon Society in a variety of programs 
and processes which have sought to achieve resolution of natural resource 
management conflicts through principled negotiation, collaborative 
planning, and application of rigorous science. I have participated 
extensively in Washington's Timber-Fish- Wildlife (TFW) process, and for 
four years chaired a TFW scientific subcommittee charged with 
investigating the relationships between forestry practices and maintenance 
of viable wildlife populations. I worked to negotiate a settlement in 
Washington's Sustainable Forestry Roundtable, which, unlike TFW, did not 
result in an agreement. I served on scientific advisory groups for both the 
Olympic Experimental State Forest and the Washington State Forest 
Practices Board. Recently I was appointed by Governor Lowry to the 
Advisory Board of the Olympic Natural Resources Center, a research 
institution created by our state legislature to seek new ways of integrating 
forest management with environmental protection. 

Therefore, I come here today with considerable experience in both 
landscape scale Adaptive Management and consensus-based collaborative 
management and planning efforts. It is these two topics I wish to address 
today, particularly as they relate to the concept of Adaptive Management 
Areas (AMAs) proposed in the preferred alternative for the 
Administration's forest plan. My experiences of the past six years allow 
me to offer some insights on the feasibility of successfully achieving the 
objectives of these AMAs, and to advise your conunittee of some potential 



262 



Timothy P. Cullinan Management of Federal Forest Lands ' Page 2 

problems which may be encountered if this component of the forest plan is 
implemented. 

Adaptive Management Areas are defined in Option 9 as landscape units 
designated to encourage the development and testing of technical and social 
approaches to achieving desired ecological, economic, and social objectives. 
Ten proposed units are identified, each with multiple but specific 
objectives. Cumulatively these areas comprise nearly two million acres. 

Although the overall objectives of AMAs are not succinctly stated and are 
often contradictory, it appears diat the intent is to create experimental 
forest units where unconventional harvest scheduling and logging practices 
will be used. The imphed purpose is to test the hypothesis that foresters 
can develop timber production methods which more closely mimic natural 
processes and thereby result in reduced detrimental impact on wildlife, 
fish, and other non-timber resources. A prominent feature of this proposal 
is to enlist the assistance of local residents in developing new management 
approaches, presumably through some consensus-based cooperative 
exercise. 

My comments are organized in two parts. First, I will address some of the 
technical problems that may be encountered in implementing adaptive 
management under the conditions proposed in Option 9. Second, I will 
point out some of the unrealistic assumptions made about the feasibility of 
reaching negotiated agreements on management practices, and offer an 
environmentahst's perspective on what might be interpreted as Option 9's 
proposal to give local residents a disproportionately strong voice in 
influencing management policy. 



Technical problems 

Conflicting objectives 

The DSEIS hsts numerous goals and objectives for the Adaptive 
Management Areas. Although the fundamental goal is "to learn how to do 
ecosystem management" (B-57, para. 3), it appears that the authors tried to 
make AMAs everything to everybody. Among the purposes stated are the 

"provision of well-distributed late successional habitat outside 
of reserves, retention of key structural elements of late- 
successional forests on lands subjected to regeneration harvest, r 



263 



Timothy P. Cullinan Management of Federal Forest Lands Page 3 

and restoration and protection of riparian zones as well as 
provision of a stable timber supply" (B-57, para. 4). 

No timber sale quantities are mentioned in this section of the document. 
The authors merely state that AMAs "are expected to produce timber" and 
that "rates and methods of harvest will be determined on an area-by-area 
basis" (B-62, para. 2). In a discussion of timber sales levels in the 
FEMAT report, however, the authors state that 

"probable sale calculations are based on the assumption that 
harvest levels would not be reduced significantly in these 
adaptive management areas compared to the Matrix in which 
they exist" (FEMAT, 11-47, para. 3). 

This is as confusing as it is alarming. If the intent is to maintain logging 
levels in AMAs equivalent to those on matrix lands, there will be Uttle or 
no opportunity to provide late serai stage habitat or old-growth habitat 
structural components. Furthermore, there will be Uttle opportunity to 
accomplish the other stated objectives of AMAs, most of which involve 
scientific and technical innovation and experimentation. If management of 
AMAs is to be driven by matrix-hke logging quotas, there will be little 
latitude for foresters and scientists to explore unconventional management 
strategies. 

As an example of how inflated timber production quotas can Umit 
opportunities to experiment with alternative management techniques, 
consider the experience of Washington State's Olympic Experimental State 
Forest (OESF). Although established with scientific goals similar to those 
of AMAs, a state-wide commission mandated that OESF produce a 
specified timber volume each year. The commission acknowledged that in 
the initial years of OESF's existence, the harvest would remain above a 
sustainable level. The mandated cut level was so high that in many cases, 
forest planners were denied the management discretion necessary to 
accommodate experimental designs. In short, the forest was "driven" so 
hard by production quotas that there wasn't much room left for 
experimentation. 

Delayed planning 

Option 9 requires that agencies develop a plan for each Adaptive 
Management Area. Part of this plan is to include "a strategy for ecosystem 
management to guide implementation, restoration, monitoring, and 
experimental activities..." (B-62, para. 2). The DSEIS makes it clear. 



264 



Timothy P. CuUinan Management of Federal Forest Lands Page 4 

however, that planning will not stand yi the way of timber sales programs 
(B-60), and requires that timber sales be expedited before such plans are in 
place. There are two very serious problems with this approach. 

First, it allows potential study sites to be eliminated before an experimental 
design can be put in place. This is a concern because Adaptive 
Management is a scientifically rigorous procedure, which often depends on 
replicated experiments involving both experimental and control sites. If 
the ultimate objective of AMAs is "to learn how to do ecosystem 
management," then research efforts will require a coordinated approach 
which evaluates the potential of all existing forest stands for inclusion in 
the experimental design. 

Any proposed management activity should be designed to contribute to the 
overall objectives of the AMA. This is not possible unless a plan is in place 
before management activities begin. Haphazard, trial-and-error timber 
sales unrelated to the overall experimental plan have no place in ecosystem- 
scale Adaptive Management. In order to obtain maximum scientific benefit 
from the AMAs, the plans promised in the DSEIS must be complete before 
any land-disturbing management actions are proposed. 

The second problem is that conducting timber sales prior to the completion 
of AMA plans runs counter to the intent of the National Forest 
Management Act (NFMA). NFMA requires that forest plans explain how 
land is to be managed. Insofar as option 9 is an amendment to 17 national 
forest plans, it too should define the management regime for the affected 
areas, to include a description of 

"multiple use prescriptions and associated standards and 
guidelines for each management area including proposed and 
probable management practices such as the planned timber sale 
program" [36 C.F.R. §219.1 1(c)]. 

The discussion of Option 9 in the DSEIS fails to provide specific standards 
and guidelines for the management of AMAs. It merely states that 
"agencies are expected to develop plans," and that "rates and methods of 
harvest will be determined" after implementation of Option 9 has begun. 
(B-60 and B-62). 

Consequently, it appears that Option 9 fails to live up to the expectation 
that the public will be kept informed of plans for management of their 
forest lands. This problem can be rectified by requiring that specific 



265 



Timothy p. Cullinan Management of Federal Forest Lands : ••' Pagg 5 

Standards and guidelines for AMAs be in place before management 
activities begin. 

Risky experimentation 

In their assessment of the various alternatives, the authors of the FEMAT 
report acknowledge that unconventional, ecosystem-based forest 
management techniques remain largely untested in the Pacific Northwest 
and should be regarded as working hypotheses. These techniques have not 
yet proven capable of meeting the objectives of ecosystem management. 
Thus it appears that the management regimes anticipated in AMAs will 
involve considerable risk. Although some level of risk is to be expected in 
the testing of new technologies, every effort should be made to minimize 
or avoid these risks in critically important areas. 

If implemented as currently proposed, Option 9 may place biological 
resources in some AMAs at unacceptably high risk. This is particularly 
true in cases where AMAs are located on critical Unks in the regional 
reserve system. To reduce these risks, the authors of Option 9 should re- 
evaluate the placement of AMAs on the regional landscape. In some cases, 
it would be more appropriate to include these critical links in the reserve 
system. 

For example, the DSEIS acknowledges that the Snoqualmie Pass area is "a 
critical connective link in the north-south movement of organisms in the 
Cascade Range" (B-66), yet recommends that an AMA be placed there. 
This is an area severely impacted by unsustainable logging on 
checkerboarded private lands in recent years. We question the wisdom of 
any further logging and road building in an area such as this where the 
environment has already been so severely degraded. 

An AMA is similarly inappropriate in the Cispus area of the Gifford 
Pinchot National Forest. This proposed AMA contains 22 active spotted 
owl territories, yet the goal statement for this AMA in the DSEIS (B-64) 
makes no mention of the need to protect or provide for spotted owls. If 
owls were to receive their appropriate priority, it is difficult to imagine 
how any "innovative approaches" to timber production could be en^loyed 
at all. 



266 

Timothy P. Cullinan Management of Federal Forest Lands Page 6 

Process problems 
Negotiated agreements 

One objective stated for AM As is to 

"provide opportunities for land managing and regulatory 
agencies.. .nongovernmental organizations, local groups, land 
owners, communities, and citizens to work together to develop 
innovative management approaches" (B-60, para. 2). 

This suggests that planning for AMAs will involve some kind of 
negotiating process designed to bring various interest groups to consensus 
on how AMAs should be managed. 

The National Audubon Society, through its Washington State Office, has 
had extensive experience in attempting to resolve resource management 
conflicts through negotiated agreements. Although we generally support 
this approach, and prefer it to outright conflict, we also recognize that 
there are limitations on its application. It is not always possible, even with 
the best intentions, to resolve disagreements through negotiation. 

Option 9 makes the unrealistic assumption that by simply mandating 
interest groups to "work together," resource management conflicts on the 
AMAs will be resolved. This confidence in negotiation is not unique. In 
recent years, resource managers throughout the region have used 
Washington's TFW agreement as an example of how resource management 
conflicts can be resolved. More recently, we've been hearing about the 
Applegate project in southern Oregon, and its potential for resolving long 
running disputes over resource allocation. It is important to note that in 
both of these cases — unlike Option 9 — negotiations were convened by the 
conflicting parties. Interest groups came to the negotiating table 
voluntarily. They set their own agenda and scope of work, and set their 
own goals. They were not ordered to come to the negotiating table. 

The Administration should not expect conflicting parties to welcome 
negotiations simply because an executive order is given. Efforts to achieve 
negotiated agreements must be initiated from the bottom up, not from the 
top down. Furthermore, there must be positive incentives for parties to 
attempt negotiation, i.e. carrots — not sticks — must be waiting at the table. 
If the Administration creates a situation in which people feel compelled to 



267 



Timothy P. Cullinan Management of Federal Forest Lands :. . ; Page 7 

be at the table merely to avert disastei:, negotiations will not be very 
constructive. 

Our experience with TFW and other conflict resolution processes has 
shown that there are other conditions that must be present before a 
constructive negotiating process can begin. These are: 

• No legitimate interest group can be excluded. 

• There must be a balance of power among the participants. 

• There must be an equal ability to participate. 

• There must be a similar level of risk and potential gain for all parties. 

• Participants must not have a need to "win it all." I.e. there must be 
room for compromise. 

• Participants must not have access to better alternatives to negotiation. 
I.e. they should not be looking to "cut a better deal" elsewhere. 

• Representatives must be authorized to speak (and make commitments) 
for their constituencies. . 

• There must be equal access to information and logistical support. 

As an example of how noi to conduct conflict resolution, consider the case 
of the infamous Section 3 1 8 advisory groups (pursuant to § 3 1 8 of the 
House Interior Appropriations Bill, passed by Congress on 10/23/89). The 
message there was "talk or else," and there was a limited and very onerous 
agenda over which participants had no control. There certainly were no 
positive incentives; most environmentalists participated only to forestall the 
most destructive timber sales. Worst of all, the section 318 experience 
only served to increase polarization in the communities, so if there ever 
was a chance to seek common ground among the conflicting parties, it was 
dealt a serious setback as a result of the contentious nature of the 318 
process. 

We recommend that the parties charged with implementing Option 9 take 
the time to determine whether the conditions noted above exist for each of 
the proposed AMAs. In cases where these conditions do not exist, the 
administration should reconsider its decision to initiate efforts at 
collaborative decision making. 

In some localities, negotiated agreement on management of AMAs are 
certainly possible. In those cases, "working together" should be 
encouraged. In other places, I fear that attempts to force this approach 
would lead to undesirable results. Given the conflicting messages about 
the level of timber volume expected from AMAs, I suspect that in some 
cases talks would bog down from day one about how to reconcile the 



268 



Timothy P. Cullinan Management of Federal Forest Lands Page 8 

objectives of matrix-level timber production and "well-distributed late- 
successional forest conditions." ; 

In some areas of the Pacific Northwest, I fear that the debate over Ancient 
Forests is still too heated to allow constructive negotiations. The level of 
polarization among conflicting interest groups can be extremely high. On 
the Olympic Peninsula, where I hve, the leader of one timber advocacy 
group has threatened to use guns to seek redress of grievances. There have 
been several incidents of arson at Olympic National Park, and one can't 
drive more than a few miles without seeing a "save a logger, kill an owl" 
bumper sticker. This is hardly the cUmate in which negotiations over 
resource management are likely to be successful. Perhaps some effort to 
defuse tensions among conflicting groups would be in order before any 
attempt to begin AMA negotiations is made in these localities. 

Even in those cases where the climate for negotiation is favorable, 
interested parties may not find a level playing field. Participation in 
protracted discussion is expensive in terms of time invested, travel and 
communications costs, and logistical support. There is a disparity in the 
ability of the various interest groups to pay the costs of participation. This 
is especially true of conservationists, who most often depend on the 
services of volunteers. If the intent of collaborative decision making is to 
empower people, some stakeholders will need to "have help with funding. 
Otherwise they may see other alternatives as more attractive. 

Local influence on management decisions 

The description of AMAs in the DSEIS makes repeated references to the 
involvement of local "communities" in both implementation of management 
and "development of new forest policies." These local interests are not 
well defined, but the language of the DSEIS, at minimum, implies 
increased local influence over management, if not promising it outright. 
While the National Audubon Society encourages the involvement of all 
citizens in management of public lands, we object to allowing a select few 
to wield disproportionate influence simply because they are local. 

Most conservationists in the Northwest regard "local control" as a problem, 
not a solution. Historically, the most egregious forest ecosystem abuses 
have occurred in ranger districts near isolated, timber dominated 
communities far from the watchful eyes of other resource user groups. In 
such areas, where forest conservation activists are rare, resource allocation 
decisions often have been unduly influenced by timber interests. 



269 



Timothy P. Cullinan Management of Federal Forest Lands Page 9 

We must not lose sight of the fact that_Option 9 applies to lands of national 
interest, that all Americans are entitled to an equal voice in influencing 
both policy and management, and that public employees are responsible for 
managing public lands for the benefit of all citizens, regardless of where 
they live. The federal agencies must not be permitted to abdicate ultimate 
federal responsibiUty for management decisions in the AMAs to undefined 
"local" interests. 

In conclusion, potentially high timber production quotas and lack of 
advance planning proposed for AMAs may hinder efforts to practice 
rigorous experimentation at the ecosystem level, and some AMAs are 
proposed in areas that would be better placed in reserve status. 
Furthermore, the administration appears to have unrealistic expectations 
about the feasibility of successful conflict resolution at the local level, and 
appears to promise too much decision making authority to local interests. 

To rectify these problems, the National Audubon Society recommends that 
AMA management be driven by the need to conduct scientific investigation, 
not by the need to produce timber. We ask that the administration comply 
with the spirit of NFMA by completing plans for AMAs before ecosystem 
disturbing management actions begin, and direct disruptive management 
activities away from sensitive Unks in the regional reserve network. We 
recommend that implementation teams re-evaluate the potential for 
successful negotiated agreements, and eliminate AMAs from the plan in 
cases where they are not appropriate. Finally, we ask the administration to 
guarantee all 248 million owners of the federal forest lands an equal voice 
in influencing their management. 

Thank you for the opportunity to to share my concerns and 
recommendations with your committee. I will be pleased to answer any 
questions you may have. 



270 



STATEMENT OF TIMOTHY G. HERMACH, 

Executive Director of the Native Forest Council 

BEFORE THE HOUSE AGRICULTURE SUBCOMMITTEE 

ON SPECIALTY CROPS AND NATURAL RESOURCES, November 18,1993. 



My name is Tim Hermach and I am the Executive Director of the Native Forest Council, a 
national grassroots organization headquartered in Eugene, Oregon. Our comments 
regarding the specifics of Option 9 are attached but I will begin my comments by defining 
what we consider to be the complete and proper framework for the forest debate. 

I am here today to testify on behalf of the over six million people who supf>ort our ^ 
efforts to bring about an end to the uneconomic and senseless liquidation of the nation's 
little remaining publicly-owned native forests. 

Why is this important? All human life depends on the existence and health of our planet's 
land, air, soil, and water, atmosphere and climate. Much of this human life-support 
system depends on global forests, 60 percent of which are now gone. Half of that loss 
took place in just the last 30-50 years. 

NASA satellite photos, published last year in the New York Times, of rainforest in Brazil 
compared with the Mt. Hood National Forest, Oregon, serve as but one example. The 
reality, indeed, speaks for itself. Flying over US National Forestlands we may all see the 
rampant destruction for ourselves. It cannot be denied. 

A majority of US conservation organizations and the heads of many nations are united in 
asking Brazil to stop logging of its rainforests. But Brazil has logged only 14 percent of 
the Amazon basin, while the US has logged 95 percent of its nearly one billion acres of 
native forest, including tens of millions of acres of the publicly-owned national forests. 

How did this happen? The Forest Service has blamed Congress, and Congress has blamed 
the Forest Service. 

But today, blame is not so much the issue, as determining what is the problem, what is 
the solution, and making it happen. President Clinton promised a legal and scientifically 
sound forest plan. Discovering the condition of the nation's forests, especially all publicly- 
owned forestlands, and repairing the damage, is the first step. 

Federal court decisions have demonstrated that the federal land management agencies 
have logged in unsustainable, damaging, destructive, and illegal amounts and methods for 
the past 30 to 50 years. Still the Forest Service refuses to acknowledge that 500 or 1,000 
year-old trees are not a renewable resource. Nor, that ecosystems and fisheries are not 
renewable. Nor, that they don't know how to grow a forest and perhaps do not even how 
to grow healthy tree farms. Nor, that those federal employees who would tell us the truth 
about these matters are often too afraid for their jobs to do so. 

Because of the high-volume export figures it's clear that there is no wood shortage. 

There never was. According to the US Department of Commerce, we export over ten 
billion board feet as unfinished raw-material wood products (per quarterly reports 
published by the USDA PNW Research Station in Portland Oregon). This is far more than 
the amount of public timber logged in the PNW ^five billion board feet) and is nearly the 



271 



NFC Testimony November 18, 1993 

Subcommittee on Specialty Crops and Natural Resources P^gc 2 

equivalent of the nation's entire cut from federal lands! Reducing or eliminating these 
low-value exports and investing in value-added manufacturing instead could create 
productive jobs and real economic growth, fully costed. 

Today, the US Forest Service must be made to stop its unfair competition and instead 
suppon the nation's private landowners growing trees for a living. These efforts at private 
enterprise are harmed by Forest Service asset liquidations which are sold in the domestic 
market. 

Even more importantly, preserving our remaining public native forests means we can stop 
wasting taxpayer dollars liquidating tens of billions of dollars worth of pristine public 
forest assets while it fails to admit to enormous inventory losses of the nations's natural 
resource capital accounts. These inventory losses may be $25 billion to $100 billion 
dollars, or more, a year. Nor, is the USFS fully accounting for the costs they create and 
pass on to the general public, such as losses of: water quality, fishing, recreation, and 
many other life-sustaining values. 

(a) Federal government accounting claims that our national forests — the water, fish 
and wildlife, and the giant trees, are worth nothing. The only value currently 
acknowledged is when public trees and forests are liquidated and turned into logs 
on a truck. They claim our forests, using their jargon, have a "zero-cost basis" and 
are a "free good", worth nothing, alive and standing in the forests. The US Forest 
Service sells our trees for much less than the cost to replace them, while unfairly 
undercuning the nation's private landowners. The money from the sale of public 
trees does not begin to recover the cost of repairing the damage caused by logging, 
let alone restoring the forests. 

(b) Furthermore, while the US Forest Service claims they make money selling the 
public's trees, analyses performed at the request of Congress show that the US 
Forest Service logging program has lost at least $5.6 billion tax dollar outlays over 
the past decade using theirjaccounting system. 

As for solutions, the World Resources Institute has said that "It becomes increasingly 
difficult to say what are practical suggestions, when one's research tends to show that 
what is politically feasible is usually too minor to make any difference, while changes 
significant enough to be worthwhile are often unthinkable in practical political terms." 

But that should not stop us from standing up for what is plainly the right thing to do. 

It wasn't politically feasible to free slaves, until the people directed it. It wasn't politically 
feasible to give women the right to vote, until people required it. It wasn't politically 
feasible to grant civil rights, until the people demanded it. It will not be politically 
feasible to save the last of our native forests, until the people of this country cry out for it. 



Solutions begin with clear goals of what is necessary and right. Protecting public assets, 
preventing theft, and spending public funds in ways that benefit, not harm, the general 
public, are clearly right. And, to do otherwise would be wrong. 



272 



NFC Testimony November 18, 1993 

Subcommittee on Specialty Crops and Natural Resources pagc 3 

Our Zero-Cut-Jobs SOLUTION is both. ■ , 

i> it's protection for what's left of our national forests; 
<f it's jobs rebuilding forests, watersheds, and fisheries; 
if it's reducing exports and generating revenues by an inverse excise tax on 

unfinished raw-material woodproducts; 
■ft it's making Government agencies and employees not only obey but uphold 

the law; 

Nearly a century ago, then President Teddy Roosevelt thought he had protected 
these forests firom the seemingly insatiable appetites of the logging industry. In 
1937, tliirty years later after seeing the logging in the Olympic national forests. 
President Franklin D Roosevelt was so angered by the logging-caused destruction he 
saw there that he said, 1 hope the son-of-a-bltch that logged that Is roasting In hell." 
What do you think these two strong presidents would do or say, one a Republican 
and the other a Democrat, if they could see what we've allowed to happen to 
America's national forest heritage today? 

We believe that the USPS must be ordered to gather all the currently unavailable 
information vital to making informed decisions and complying with our nations laws 
regarding public lands. Allow us to determine how well the US Forest Service can repair 
and restore our children's and grand children's damaged forests and watersheds. 

No further timber sales of any kind should be planned or allowed until the 
following questions have been asked and answered, to your fiill and complete 
satisfaction. Then, we suggest putting people to work making America's forests 
great again and ending further liquidations of public forests. 



Vital Questions Which Must Be Answered Prior To More Sales Decisions: 

1) What is the status of our nation's forests, public and private, their condition, and 
what would it take to get them all healthy, productive, and sustainable? 

2) What are the environmental cumulative effiects of the respective conditions of these 
/forest lands? 

3) Where are the annual aerial photo mosaics with the mylar overlays of all of our 
public forests the US Forest Service used K) provide? These existed as late as 1984 
so Congress and the public could see for themselves what was happening on the 
ground. 

4) How many of the 360,000 miles of roads are contributing how much silt Into our 
streams and rivers, causing what impacts to how many fish, creating what problems 
for downstream water users, and what resources will it take to correct these 
problems? 



273 



NFC Testimony November 18, 1993 

Subcommittee on Specialty Crops and Natural Resources page 4 

5) What is the age, size, and condition of all federal lands clearcut and already 
convened to tree plantations? 

6) What is the age, size, and condition of all federal native forest lands not yet logged 
and converted to tree farms, and how many acres by district, of the commercial, 
suitable, and unsuitable categories have been cut, and what's left? 

7) How many miles of streams, by each of the four class sizes, have been degraded or 
destroyed by logging and or grazing practices? 

8) How is that a federal employee who obeys the law can get harassed out of the 
agency while those employees patently breaking the laws get promotions and cash 
bonuses? And how will this be stopped and reversed? 

9) To what degree is each agency by state, forest, and district, in compliance with 
existing laws? Why is it not 100 percent? What will it take to correct? 

10) When will federal agencies be caught up with accurate data gathering, inventories, 
monitoring, negative cumulative effects analyses, accurate, up-to-date and legal 
forest plans, etc.? Why should irreversible and irreparable logging be allowed if 
not? 

11) What amount of public and private timber is logged by state each year for the past 
fifty years, and what amount is exported by unfinished category per US Customs 
district for these same years? 

12) What roles do federal timber supplies and unfinished wood exports/imports play in 
the economy, local, regional, and national? And, how and to what degree do these 
exports-imports affect the market values of private lands and trees; and how do 
these exports-imports affect the financial ability of private landowners to replant 
their lands by state and region? 

f 

13) How is Congress going to reassert its authority and control over federal agencies? 

14) And, what can be done to assist communities, industries, and workers, who have 
been impacted by these often illegal federal practices to transition to long-term 
sustainable, non-destructive wealth creating forms of economic development and 
employment? 

15) How can the federal government make up for the lost revenues to counties and 
schools from timber receipts without further compromising the people or the 
forests systems? 

16) What is the best use of our nation's public lands in the interest of the general 
public for the next one thousand generations? 



274 



NFC Testimony November 18, 1993 

Sutxromminee on Specialty Crops and Natural Resources , page 5 

SOME PRACTICAL AND IMMEDIATE IDEAS FOR CONSIDERATION: 

The public loses living life-sustaining capital assets at taxpayer expense; and the nation's 
private landowners suffer lower values on their land and reduced revenues from their 
timber from the unfair Government competition. And furthermore, they seek increased 
revenues, relative to their investments, by exporting minimally-processed and unfinished 
wood products. The nation loses and the economy loses. 

However, to break the legislative logjam some volume lasting nearly 20 years may be 
tolerable to most factions. The National Forest Management Act of 1976 (NFMA) 
mandates that national forests maintain their native biodiversity and that any cutting is 
adequately restocked. All areas clearcut or converted to " even-aged management " violate 
NFMA. however, true restocking v*ith a full mix of diverse native species, pruning, and 
thinning of managed areas could help the US Forest Service get into compliance with the 
letter and intent of NFMA, especially if they were done in a fashion designed to bring back 
native diversity. NFMA has not been honored since its passage in 1976. Before any 
further road building, salvage, or other sale volume is considered, getting into compliance 
with and obeying existing laws is in order . 

This proposal could provide one to two billion board feet per year, solely from planted 
national forest tree plantations, until all areas are returned to their natural state. 

Diven the 348 million dollars in the FY 93 budget for timber-salvage sale preparation to 
timber stand improvement (TSI) and timber stand conversion (TSC) programs. Unlike the 
salvage program, these sales would be free from the threat of legal challenge as it's either 
already in the law, or, it's in the interests of all parties. This proposal is labor intensive 
and instead of allocating tax dollars in ways that anger the public because they damage, 
degrade, even destroy public wealth, this proposal would instead repair and rebuild. All 
funds would be invested in the rehabilitation and restoration of the public's propertv : 
ecosystems, watersheds, forests, rivers and fisheries, hunting, camping, and other 
recreational opportunities. 

Further suggestions for legislative inclusion: 

1. Divert all new-road-building monies to maintenance, mitigation, or revegetation of 
existing roads for a net reduction of 2% miles/year. 

2. Include salvage-sale volume in the annual ASQ; return all salvage revenues to their 
treasury; salvage sales are to conform to all EIS, EA, and other legal requirements. 

3. Repeal K-V effective FY 94 

4. Establish inverse excise taxes on all unfinished US wood exports and imports . 100 
percent finished equals zero tax. Zero percent finished equals 250 percent tax. All 
funding to go towards restoring public (and later private) forests, ecosystems, 
watersheds, fisheries, and other parts of this proposal. An incentive for global 
domestic processing. 

5. Conduct one year study to Revest Railroad Grant Lands . 220 million acres. 

6. End all federal unfinished wood export subsidies. 

Native Forest Council - PO Box 2171 - Eugene, OR 97402 - 
503-688-2600, fax: 503-461-2156 

(Attachments follow:) 



275 



1of/(7 
To: 



From: 



Robert Jacobs 

Interagency SEIS Team Leader 
P.O. Box 3623 
Portland, Oregon 97208 

Jim Britell 

Conservation Chair 

Kalmiopsis Audubon Society 

P.O. Box 1 349 

Port Orford, Oregon 97465 



10/28/93 



Tim Hermach 

Director 

Native Forest Council 

P.O. Box 21 71 

Eugene, Oregon 97402 



COMMENTS ON THE CLINTON FOREST PLAN 

"Making plans is often the preoccupation of an opulent and boastful 
mind, which thus obtains the reputation of a creative genius by 

demanding what it cannot itself supply, by censuring what it cannot 

Improve, and by proposing what it knows not where to find." 

(Immanuel Kant) 

GENERAL OBSERVATIONS ON THE PLAN 
if one disregards Option 9, the Report of the Forest Ecosystem Manaoement 
Assessment Team (FEMAT Report) itself is an excellent case for no more logging on 
federal lands. For a number of years the Native Forest Council has advocated the 
abolition of logging on public lands, a position usually referred to as the "zero cut" 
Option. While we have presented a number of economic arguments to support our 
position, we have never fully documented the ecological argument for this position. The 
FEMAT Report, while not disclosing the ecological effects on all species of a "no cut" 
alternative, does provide enough information to strongly suggest that our alternative 
may be the best approach to complying with existing NEPA and NFMA requirements 
regarding species protection on public lands. We surmise this is true because, although 
the species viability ratings were not disclosed for this alternative, it is clear that the 
less logging and the more reserve, the higher the species viability ratings. " ' 

If one regresses the data in the Draft Supplemental Impact Statement (DSEIS), implied 
alternatives appear to the left of Option 1 , which we would like developed. Reserve size 
increases and harvest level decreases as one moves down numerically though the 
alternatives - and the species viability increases. If one assumed that the reserve could 
increase to greater than the sum of federal lands by including private lands and that 
the harvest could become a minus number by buying back sales and restricting private 
land logging, then at some reserve size and harvest level we could ,at least 
theoretically, provide for 95% species viability of some greatly increased number of 
species. We see no reason why these potential alternatives could not be displayed. 
Moreover, we believe it is a clear requirement of present law to truly disclose a "no 
change" or "no action" alternative, and that the DSEIS is flawed by its absence. 



276 



2of/o 



"The following chart shows a regression of the data to determine what Late 
Successional reserve size might insure a well distributed viability for all the 1 1 00+ 
species analyzed in the FEMAT Report. A reserve of approximately 1 3 million acres 
might provide well distributed populations for ail species. This would require all the 
matrix land in option 1 to be added to the reserve in option 1 , and an additional 1 .5 
million acres of other (State or private) land to also be added. 



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PROBLEMS WITH THE PLAN 
The Clinton Forest Plan is a wickedly political "attractive nuisance". While ostensibly a 
pre-decisional document in the fonm of a Draft Supplemental Environmental Impact 



277 



3 oMO 

Statement (DSEIS)^, the document actually presents as "science" a decision made 
months ago that much of the remaining Ancient Forest, roadless areas, and species in 
the Pacific Northwest must be sacrificed. To package this decision as sound ecological 
science it presents data in a way that underestimates the amount of Ancient Forest 
that will be placed at risk and the benefits of creating reserves, but overestimates the 
benefits of logging. It arrays data so that it cannot be compared with previous 
reports, and assumes the success of major projects neither funded nor designed. The 
process records and meeting minutes are sealed or nonexistent, and the methodology 
received inadequate peer review. The Plan's technical and legal construction is so weak 
and species protection so poor it probably wouldn't survive a legal challenge. 

Option 9, the preferred Option , trades protection of 60% of the remaining multi- • 

canopy Ancient Forest for clear cutting the other 40%.2 If implemented, it will rely on 
the logging of Ancient Forests for over half the timber volumes projected in the Plan 
into the indefinite future. The Plan tries to present the continued liquidation of the 
forests in the Pacific Northwest in the best possible light; nevertheless, the impact of 
the Plan's annual 1.2+ billion board feet of logging is painfully obvious. Logging abuses 
on the Northwest's forests are of such magnitude that even the option which 
according to the document itself is most restrictive of logging. Option 1 - scientists call 
this "the big green alternative" - is inadequate to preserve the viability of many species 
within the forests. 

The effects of the preferred alternative are not fully described because the location 
and magnitude of logging depends on future studies and processes not yet designed. 
Specifically, the amount and effects of thinning and salvage, and of the roads that will 
be built are not disclosed. Much of the logging will be done after watershed analysis, 
but this is an untried process and the methodology was not disclosed - the chapter on 
this being merely an encyclopedia of practices, not required procedures. 

The DSEIS3 states that watersheds will recover under Option 9. But some scientists 
believe that most, if not all watersheds, are a on downward path and that when 
normal rainfall resumes roadsand denuded slopes-wilt fail. The Ellc River watershed • 
analysis, claimed as a model for watershed restoration, is in fact a highly controversial 
failure, which many believe was merely justification for logging a fairiy intact watershed. 

A draft watershed restorati on guidance document (a companion to the FEMAT 

1 The DSEIS includes the Forest Ecosystem Management: An EcoloQical. Economic, and Social 
Assessment, and the Report of the Forest Ecosystem Management Assessment Team (FEMAT Report). 
Option 9 of the DSEIS is the preferred alternative. 

2The DSEIS classifies as late successional forest trees 21 inches and up. The amount of multi-story late 
successional forest is shown in table IV-10 as 4 5 million acres, and the report says that 20% of this is in the 
matrix (open for logging). But what activists think of as Ancient Forest • 36" dbh and larger mutti-story 
canopy - constitutes only 2.5 million acres. The real question is what percent of that is in the matrix? Data 
currently being compiled will probably show 30-40% of the true Ancient Forest in the matrix. Another 
reason for the 20-40% discrepancy is that the grids used to calculate the amount of late successional 
forest were 40 acres in size and thus may have overlooked smaller stands and left them in the matrix. In any 
case, the estimates in the DSEIS are clearly labeled "error prone", and "non-field verified". At this point, 
the 1 year old debate about what data base to use in calculating the amount of Ancient Forest, where it is, 
and how to define it is still unresolved Until mutually agreed upon numbers are developed, the best 
estimate is that from 20-40% of the remaining Ancient Forest is at risk under this plan. 
3 DSEIS Chs. 3&4, Pgs 48.49 



278 



Report) is now out for comment and will be published by 1 1/1 5/93. It should be 
obtained by anyone with an interest in watersheds. "■' ■ 

The historical pattern of forest planning clearly shows that successive administrations 
attempt to establish a predetermined level of logging on public land, and then apply 
endangered species protection to whatever habitat remains; rather than adhere to 
clear legal mandates by setting aside land for the survival of species and then 
scheduling any logging on what land is left. This practice is continued in the Clinton 
Forest Plan. This administration, and the scientific and environmental communities, must 
face the fact that billions of board feet more of timber cannot be cut in the Pacific 
Northwest National Forests unless a number of environmental laws are repealed. 

Despite 1 800 pages we still have no answer to the basic question that should have 
been asked: what is the maximum amount of species protection that is yet possible on 
federal lands? The conclusion the data suggests is not even mentioned in the report: 
except thinning for restoration and fire prevention, further logging of National Forests 
in the Pacific Northwest should probably be ended; restrictions on private land legging 
imposed; and timber sales sold but not yet cut repurchased. 

As a practical matter, this report may be consigned to the dumpster by a current 
timber industry lawsuit. The briefs and affidavits filed in that suit allege widespread 
illegal administrative procedures by the DSEIS and FEMAT teams. Lawyers familiar with 
the suit say the timber industry case is strong. 

The fast track this DSEIS is on guarantees that the public comment period is a sham. 
A report of a meeting of Forest Service supervisors on 9/1/93 says that the Final SEIS 
will be filed with the EPA on 1 1/19/93. How can the team possibly assimilate and weigh 
the comments that arrive during the legal comment period when the schedule it follows 
requires that final decisions are made before the comment period ends on 10/28/93? 
The response of the interagency DSEIS team to phone calls asking that the comment 
period, which began 7/28/93, be extended because so many people received their 
DSEIS late or not at all was that the final Record Of Decision must be ready for Judge 
Dwyer by 1 2/31/93. It is just one of the plan's many ironies that the interagency DSEIS 
team feels compelled to bend and break NEPA rules to get the document to Judge 
Dwyer; yet the reason they must go before the Judge is because the agencies were 
found guilty of a consistent pattern of NEPA and NFMA violations. 

The whole issue of adherence to NEPA Involves the question of species viability yet 
DSEIS reviewers have no access to process records or minutes of deliberations, and so 
cannot know the the identity of species viability raters. Since the scientist's individual 
species ratings are not given, only averages of panels, reviewers do not know the 
ranges of viability ratings for Individual species. Displaying averages leads to some very 
misleading and overconfident predictions. For example, I am told that the 80% viability 
rating for spotted owls was an average of four scientist's opinions. One of the raters 
was an industry scientist who ranked Option 9's ability to protect Northern Spotted 
Owls at 1 00%. Two other scientists gave estimates of only 60%. So 80% is just an 
average of widely divergent numbers. If the divergence In ratings is widespread, this 
would Indicate that the model and methodology are probably flawed and should not be 



279 



5 of 10 

considered as accurate. 

No credible peer review of the document was done. One scientist said that the FEMAT 
research methodology was too poor to be published in a scientific journal. Usually in a 
scientific process the results and methodology are sent to an independent scientific 
body or journal who then chooses the scientists who will do the peer review. While the 
authors can suggest the peer reviewers, they don't actually select them. FE.MAT's 
authors selected the peer reviewers, gave them little or no time to comment, and 
won't release their comments. This is not a new phenomenon. The Forest Service and 
BLM have historically refused to subject the models, methodology and conclusion of 
their scientific studies to bona fide peer review. It is unlikely the scientific community will 
ever formally object to this since logging, directly or indirectly, funds much of the 

"research and science" at state, federal and university ieve!.'^ 

While the many process violations of this report are disturbing, it is the substance that 
is truly appalling. One thing that jumps out of the report are the several thousand 

viability ratings that show Option 1 protects every species better than Option 9;5 but, 
when the writers rank all the Options together, miraculously. Option 9 does better than 
Option 1 in terms of the entire ecosystem. How can this be? Is Option 9 a neutron 
bomb that destroys species without harming the ecosystem? 

The key to understanding this plan is to tease out the underlying drivers behind the 
viability ratings that implicitly or explicitly treat Option 9's high legging levels as a plus 
for the ecosystem and Option 1 's inviolate reserves as bad for the ecosystem. (Option 
1 produces the lowest timber volume available for continued cutting and the largest 
reserves. It is similar to Option 14C in the Gang of Four report, but with better stream 
buffers.) 

One alleged plus for Option 9 was to posit that the forest is so damaged siivicultural 
restoration is necessary to restore its function. Since the biggest reserves are in 
Option 1 , and assumed to be closed to "restoration", this means that even thinning 
plantations to protect against fire 'is not possible in Option 1 . On the other hand, ■ , 
Option 9 allows "restoration" activities in reserves. 

Another imagined plus, available only in Option 9, is Adaptive Management Areas 
(AM^'s). Now, although AMA's might strike activists as merely turning forests over to 
the same locals that caused the problems in the first place; the scientists who did the 
ratings assumed they could somehow trade reduced protection on federal lands in 
AMA's for increased protections on adjacent private lands. Clearly, Adaptive 



4 The FEMAT Report was prepared under the supervision of Jack Ward Thomas and Jerry Franklin, two 
scientists whose pioneering work is largely respwnsible for there being any Ancient Forest left to fight 
about. We owe them a lot. While they displayed the 10 Options, they did not select the preferred Option. 
Neither has publicly endorsed Option 9 Since the deliberations of this team are sealed, it is not possible to 
know how the team could have such good people and such a bad result. 

5 These viability ratings express In percents the likelihood for surviva! of over one thousand species under 
the 10 DSEIS Options. For example, the Silver Ha"^ed bat has a S3% likelihood of sup/iving across its ra-n^e 
under Option 9 and 98% under Option 1 . Some species are so dependent on pnvate land or so rare that 
apparently nothing land managers do with federal la.nds alone can save them now. 



280 



6 0f/^ 

Management Areas represent the triumph of hope over experience. The Applegate 
Project, which served as a model for this idea, is still in its honeymoon stage, and 
hasn't proved anything except that injunctions make the industry sit down and talk. A 
better model would have been any of the unsuccessful experiments like the Illinois River 
Basin or the Shasta Costa Roadless Area, or any of the several other community 
planning efforts that have come to impasse and failure. The sham public participation in 
this DSEIS/FEMAT process is probably a harbinger of what can be expected in the AMA 
public participation process 

Another assumed plus for Option 9 is the assumption that long tenm ecosystem health 
is contingent on forest ecologist's logging experiments! They appear to have credited in 
advance the knowledge scientists expect to gain about ecosystems from AMA's and 

incorporated this dubious rationale into the ratings.^ In numerous places in the plan 
they admit they have very little knowledge about old growth ecosystems and it will be 
a long time before they acquire it. How many trees will be left standing by the time 
they acquire this knowledge? 

Finally, the ratings assumed that large amounts of money would be forthcoming for 
restoration and AMA's, and that these experiments would succeed. These speculations 
were then used to offset the problems Option 9's high logging levels might cause. From 
a process point of view the report should cleariy explain the effect that future funding 
assumptions had on the ratings. If expected ecosystem funding is delayed or reduced, 
the numbers in the report will be wrong. Also, if the "experiments" fail the numbers will 
be off. Viability ratings should not be fluffed up by assuming funding not yet allocated, 
studies not yet designed, and oversight by agencies not yet reformed. 

Further problems include the disturbing reports that Option 1 reserves were 
deliberately and sloppily drawn to increase the amount of LSOG 3; this would have 
artificially reduced the timber volume available for logging for this Option. Also, Option 
9's rankings and ratings were allegedly done at different times and by different people 
than the other Options. 

Once they had claimed such enormous real or imagined benefits for thinning in 
preserves, silvicultural restoration and AMA's, the proper, logical, and legal actton for 
the scientists who drafted Option 9 would have been to create a new alternative for 
comparative purposes. That alternative should have presented how various species 
would fare if all logging of National Forest was stopped, except to convert plantations 
and fire suppressed stands back to their natural uneven aged condition. 

This other alternative could have displayed the effects of no logging at all in National 
Forests. This would have been a more appropriate, not to mention legal, way to satisfy 
the NEPA requirement that a 'no action" alternative be considered in writing EIS's. As it 
is, the "no action" alternative in the DSEIS (Option 7) assumes implementing existing 
Forest Plans. This is an oxymoron if there ever was one since the report's analysis 
shows that Option 7 is devastating for species and doesn't meet NFMA, or NEPA. How 
could this constitute the alternative that shows the decision maker what the results of 
"no action" would be? 



6 DSEIS Chs. 3&4. DQ. 40-46 



281 



lo'.lQ 



A DISTRESSING DEVELOPMENT 
The FEMAT team leaders have said repeatedly that all species cannot be saved. What 
hats do they wear when they say this -scientist? -politician? -acting chief of the Forest 
Service? What assumptions lie behind this? A dangerous threshold is crossed when key 
scientists, with scant political experience, decide it is politically impossibie or too 
expensive, to save species. These are decisions for politicians and the public to make. 
Scientists owe it to their fellow citizens to at least lay out an alternative that shows 

what is possible on public and private lands, especially since the FEMAT report'' 
displays public opinion polls showing that the American public and the citizens of the 
Pacific Northwest clearly want strong protection for federal forests. The issue is not 
whether all species can be saved or that some species depend on private land over 
which the Forest Service has no control: the issue is how much protection can be found 
for species that depend on federal land. 

Confusion has arisen about how many species are evaluated in the DSEIS, and how they 
fare under Options 1 and 9. Some have said that 1 000 species were rated and 1 00 
were put at risk from Option 9. Actually, many thousands of species were rated and 
Option 9 creates problems for many hundreds of them. Confusion arises because in the 
long lists of species some individual entries are really groups of species. For example, 
Lichens: table iV-1 8 rates only 1 6 Lichens, but these represent 1 25 different species. 
Fungi: table IV-1 7 rates 48 Fungi, but this represents almost 600 individual species. An 
overall assessment of the Clinton Plan's effect on species needs to be done. 

We can tell from even a cursory review that there is no question that Option 9 is much 
worse for aH Ancient Forest dependent species than Option 1 . For example, 46 species 
of Lichens, which show over a 50 % chance of surviving in a well distributed fashion 
under Option 1 , have less than a SO % chance under Option 9. 62 species of Fungi have 
a better than 50% average of surviving welt distributed under Option 1 , but less than 
50% under Option S. 71 species of Moilusks drop from better than 50% under Option 
1, to less than 50% under Option 9. And we are not talking about marginal changes. 
These Mollusk ratings are typically about 70% under Option 1 versus about 30% under 
Option 9. Not only these species that scientists call "low lifes" are affected, most fish '■ 
ratings drop from 80% under Option 1 to 65% under Option 9. So the specific question 
Is not whether we can save all species, but why can't we try to save the ones we stilt 
have? 

The answer appears to be j^ that the Forest Service views forests as merely an 
agricultural commodity, the extraction of which is hindered by inconvenient rules on 
endangered species. The Forest Service receives the bulk of its money for administering 
programs, everything from restoring fish runs to training staff, from cutting trees - 
they know it and so does everyone else. Some may assert that there's much we don't 
know about these forests and that if scientists cafi't do logging experiments the 
ecosystem is put at mortal risk, but we now know enough to know that deforestation 
is bad for many species. The real threat to our forests is that our leading scientists 
still refuse to say so. 



7 FEMAT Reoort ch. VII. oqs 29-31 



282 



8 qMo 

HOW DID THE CLINTON FOREST PLAN GO OFF TRACK? 
The problems with this DSEIS began at the forest summit when historian Kimbark 
MacColl was asked by the White House to tone down his prepared opening remarks 
because they were too critical of the timber industry. If the summit had been a real 
hearing that followed the rules of evidence, the anguished and heartbreaking testimony 
about mill closures would have been followed by cross examination. We would have 
learned the real reasons the mills closed; e.g. that the mill in Areata was replaced by 
one in Chile. 

That Dillard, Oregon, where the heartbreaking pictures of a displaced timber family 
were taken, is a town dominated by Roseburg Forest Products, a company that 
exports wood chips to Japan. 

That Pacific Lumber and Shipping, whose representative Mr. Spence was very 
impassioned about the need to resume federal log sales in the Gifford Pinchot National 
Forest where his company is a major buyer, is a major exporter of timber. 

The Mayor of Hoquiam, Washington said the largest mill in her town closed because of 
injunctions over federal timber, but a Washington State government report concluded 
that: "lack of investment in new equipment was the prime cause of the closure." 

If we allow the issue of timber "harvest" to devolve from science to essentially a 
welfare issue, to be decided on the basis of human need, then we need to apply the 
standards of proof and evidence that any welfare office would apply. We would not 
allow a welfare claim on the basis of photographs and anecdotes, but that is exactly 
what the Clinton Plan does. 

Many activists hoped that the unraveling of the forest ecosystem created by the 
collusion of the timber industry, federal land managers and local politicians would finally 
be exposed at the summit for the whole country to see. Alas, it was not. Of course, 
sometimes it's best in public policy debates to accept the fact that mistakes were 
made and go forward without assessing guilt. But this is practicable only when the 
parties have -genuinely agreed on a new path.- From observing the timber industry public 
relations during and after the conference it's hard to see where they admit they have 
made mistakes. And if the Forest Service has changed their approach to forest 
management since Clinton's election, it certainly has not been visible on the ground. This 
is not surprising because the current process holds thousands of timber and Forest 
Service families hostage to timber cutting. As a local ranger recently said to her staff, 
"If you want to keep your jobs you better start making stumps". 

The new administration is willing to acknowledge that the forest problem is about more 
than just spotted owls, but is no more willing to publicly surface the underlying Issues 
than its predecessors. They repeat the same old canards: "Maybe people did some 
bad things in the past, but we have to go forward." "Guilt is everywhere and nowhere." 
"Preservationist and devastationists arguments are equally valid." "Both sides are 
equally guilty of extreme demands." Except of course, large employers like Weyerhauser 
who are senior members at the table are to be treated with utmost respect. 



283 



9of/£? 

OTHER ISSUES 
One of the less examined aspects of the Clinton Forest Plan is a program of economic 
development to ease the transition of rural communities impacted by the so called 
"timber crisis". The intent is to fast track the awarding of hundreds of millions of 
dollars to rural counties and communities in the Pacific Northwest. 

Rural development means condo's, docks, RV parks, dams, gas lines, water mains, paid 
staff for the chamber of commerce and generally increasing the population of rural 
areas - all projects that benefit the right wing leadership of rural areas, not 
unemployed timber workers. Projects envisioned as "infrastructure development" may 
well do more damage in the floodplains and estuaries of Northwest rivers than Forest 
Service clear cutting has ever done in the head waters. Even more ironic and tragic, the 
prime beneficiaries of these projects may well be the same individuals and companies 
who have profited from exporting logs from private land. Just as sending food to third 
world countries for starving children usually means enriching the local warlords; so too, 
money sent to rural areas primarily benefits the rural oligarchy. It is ironic that a 
Democratic administration would develop a pork barrel program whose prime 
beneficiaries are its most virulent adversaries. 

ADDITIONAL POINTS 
1 . Are reserves for Martens, Pileated woodpecker and other late-successional species 

already in the Fx>restPJans canceled and returned to the matrix?8 

2. How much of the volume of 1 .2 billion comes from Ancient Forest in the short term 

and long tenm?9 

3. Who paneled which Options, especially Option 9? When and how did they do it? Were 

the ratings changed? Many tables imply a level of accuracy that simply does not reside 

in the data. 

4 The legal basis of this Plan needs to be analyzed, especially the possibility that the 

ratings in Option 9 were artificially inflated by assumptions of unrealistic future funding. 

5. Are the Option 1 reserves drawn to include more non-ancient forest and cut over 
areas than one would expect, thu^ artificially reducing the land base and the volume 
available in this Option ? Further, the agencies are now in the process of "revising? the 
reserve boundaries so maps included with the DSEfS are not final. 

6. The FEMAT Report^O takes shots at scientists who advocate policy. Since this 
report is essentially a political document,, not a scientific one, this is the pot calling the . 
kettle black. 

7. Because of the internal logic of the Plan, and the way thinning is credited as a big 
"benefit", advocating changes in these Options is very complicated. If Option 1 's 
reserves could be entered for thinning, its viability ratings would increase. If Option 9 
was only "improved" by making its preserves inviolate, its ecosystem viability ratings 
would fall. If ail the changes were made to Option 9 that some activists suggest, the 
result would be to convert Option 9 to Option 1 . 

S.The Clinton Plan increases agency discretion about where and how to log, despite a 
Ions track record of abuse of any discretion that has ever been granted. 



8 FEMAT Report ch.lll, pg.23 

9 FEMAJ Report ch.VI. p9.9 

10 FEMAT Reoort ch.Vll. dj. 112 



284 



10 of 10 

9. The Plan avoids preserve protection in favor of complex procedural prescriptions 
that require careful monitoring, despite clear evidence that the agencies are 
institutionally incapable of monitoring themselves. 

1 0. The volume mills claim they need to avoid shutdown can be found on the Pacific 
Northwest export docks, where the equivalent of 9 billion board feet of of logs, chips 
and pulp is exported yeariy. 

1 1 . The Clinton Forest Plan is not science. It is a template for the destruction of most 
of the Pacific Northwest's remaining native forests - and will demoralize forest activists 
around the world. 

A FINAL NOTE 
The political process must reflect balance, as must a person or an ecosystem, but that 
does not mean that every part of the system must itself be in balance or take a 
balanced position. It is the overall system that must have balance. If you wish to 
balance a teeter-toter and a big fat person is sitting at one end, you will not create 
balance if you sit in the middle. You must sit far out at the other end. Powerful forces 
want it all, and are getting it. 



285 



Everybody in Oregon 
is mad at everbody else 
over jobs, owls, trees ... 

Solution to the whole, sad mess may be at hand: 
Japanese tourists, a renewable resource, love the place. 



© 1993 Creators Syndicate 



FORTLAMD, Ore. — Back in "Ory- 
gun," as the locals say, where I once used 
to make a living writing about environ- 
mental issues, I find tiiat the debate has 
not progressed mucii. 

It's still spotted owls vs. loggers' jobs, 
with everybody mad at everybody, an un- 

" MOLLY IVINS ~ 

acknowledged class hostility making the 
debate nastier and the growth of a wiggy 
extreme element somewhat influenced by 
survivalists and white supremacists. 
Aside from that, everything's fine. 

The environnientalists-vs.-loggers de- 
bate has taken on a ritualized quality, as 
thougli it were some odd form of Kabuki 
dance. 

The new players include a wave of im- 
migrants from California who, having 
watched that state get "ruint" by develop- 
ers, arc now preparing to make a last 
stand in favor of Quality of Life. They arc 
about as welcome here as immigrants ev- 
erywhere. 

Also in the mix is the Clinton adminis- 
tration's Northwestern forest plan, which 
the Clintonistas are quite proud of on the 
grounds that nobody likes it, so it must be 
fair. 

Wrong. In fact, that badly reported 
plan is an environmental stinker. 



One definition of insanity is making 
the same mistake over and over without 
ever learning anything from it. Under 
that rubric, the Northwestern forest plan 
can fairly be called crazy. 

Meanwhile, without anyone having no- 
ticed, the solution to the whole mess is 
right here on the ground, practically ubiq- 
uitous. 

What is seen more frequently in the 
Northwest these days than cither en- 
dangered owls or endangered loggers? 
What is almost as common as the spruce 
tree? The Japanese tourist. 

The Japanese tourist, beloveds, will pay 
more to come sec old-growth forest than 
he will for the timber that comes from 
cutting it down. The Japanese tourist is a 
renewable, non-polluting resource that 
can be milked from now lo eternity — or 
certainly a lot longer than the first-growth 
'"nresi will last at the present rate of log- 

> )ncc again, decisions are being made 
>ol of greed and stupidity, with only 
short-term profits in mind. 

To give you an idea of how it works, 
here is the beginning of a story that ap- 
peared last week on the front page of J'lic 
New York Times: 

"Throughout the 1 980s, the Champion 
International Corp. went on a tree-cutting 
binge in Montana, leveling entire forests 
' at a rate that had not been seen since the 



78-799 0-94-10 



286 



cul-and-run logging days of the last cen- 
tury. 
' "Now the hangover has arrived. 

"After liquidating much of its valuable 
timber in the Dig Sky country, Champion 
is r.ulling out of Montana, leaving behind 
hundreds of unemployed mill workers, 
towns staggered by despair and more than 
a thousand square miles of heavily logged 
land. 

"In one of the nation's biggest private 
land deals. Champion this month is sell- 
ing all 867.000 acres of its Montana land 
— for $3,000 an acre — to the Plum 
Creek Timber Co., based in Seattle. 

"I'lum Creek has been called 'the Darth 
Vader' of timber companies by former 
Rep. Rod Chandler of Washington, a Re- 
publican, but now says it is committed to 
a less destructive type of forestry." And 
so on, and so forth. 

I guess the only remaining question for 
the Northwest is how many limes it is 
going to play Charlie Urown while Lucy- 
Ihc-timber-company holds the football. 

This has been going on for at least 100 
years. To add insult to injury, the trees 
idled here aren't even milled here. 
They're shipped directly to Japan. 
So now what they've got is both ruinous 
logging rates and unemployed mill work- 
ers. 

Some of the unemployed workers arc 
said to have retreated into the forests to 
live off the land, getting a little weird out 
there in the bysli and bitterly blaming en- 
vironmentalists for all their problems. 



Misdirected anger is a common phe- 
nomenon m both life and politics, but this 
IS one of the saddest cases yet seen. 

in Montana, in the wake of the Cham- 
pion disaster, unemployed workers and 
environmentalists are now making com- 
mon cause — too late. 

"Champion came in here promising 
they would be here forever and then just 
(cut) all the trees and left," said Dr. Tho- 
mas Power, chairman of the economics 
department at the University of Montana 
in Missoula. "We are left paying the 
piper." 

Oregon is looking right into the face of 
the same fate, but, alas, its political repre- 
sentatives are not real focused on all this 
on account of Sen. Robert Packwood is iii 
this ridiculous tangle of allegations about 
improper sexual advances. 

Why that man doesn't have the grace, 
the class, the decency or the common 
sense to simply resign is beyond me. Or- 
egon needs all the people it can get in 
Washington paying full attention to their 
knitiin'. 

It's perfectly understandable why log- 
gers, faced with the prospect of unem- 
ployment .sooner or later, would choose 
later. The time to start finding them new 
training and new jobs is now, but all of 
this is buried underneath the latest-dap 
about Dob Packwood's diaries. 
' Poor Oregon — so far from heaven, so 
close to California. 



(Molly Ivins is a columnist {orTlie Fort 
Worth Star-Telegram.) 



*^nsAiCt4«< Sj»r 



/C'/j7/73 



287 



SAN FKANCISCO KX AMIN liK 



Friday, Oclobcr 22. 1993 





Coercive 
harmony' 

and the 

Northwest 

chain saw 

massacre 



« 

Pctrolin 

IF ALL runs smooLlily alonjj 
the lines of a deal hatched 
between the Clinton admin- 
istration and certain cnvi- 
ronniontal groups, 'lOO-ycar- 
old Douglas firs will start falling 
next spring in the national forests 
of the Pacific Northwest. 

These tracts of ancient forests 
— eiyoined from logging because 
they are habitat for the endan- 
gered spotted owl — face clear-cuts 
in the name of one of the most in- 
sidious catcliwords of the Clinton 
era: consensus. 

The very moment when, in ear- 
ly October, the environmental 
groui)S bowed their necks and gave 



the green light for the chain saws, 
Agriculture Secretary Mike Espy 
o.xulfxjd that the deal (surrender is 
the more accurate word) moves 
timber sales "away from the time- 
consuming and adversarial 
process . . . away from cttnilict and 
toward consensus." Espy's boss, 
President Clinton, similarly 
liymned the end to "giidlix;k." 

"Win-win" and "consensus" arc 
the verbal soR toys of the Clinton 
era. They signal a sinister trend 
Mcll described recently in llie Ex- 

incr by Laura Nader, professor 
• 1 anthropology at Berkeley. 

Nader first recognized what she 
calls the growth of "coercive har- 
mony" in the rise of "alternative 
dispute resolution," itself a re- 
sponse to the confrontation and 
litigiousness of the 19G0s civil 
rights movement. 

T IS basically a movement 
against the contentious in 
anytliing," she says. "It has 
very strange bedfellows, from peo- 
ple with various jjsychiatric tliera- 
py movcmeiUs, Christian funda- 
mentalists, corporations sick of 
jjaying lawyers, activists who be- 
lieve we should love each other . . . 
and it's spread into different jjarts 
of American life. We're talking 
about coercive harmony — an ide- 
ology that says if you disagree, you 
should really keep your mouth 
shut." 

Sec how the pressure for con- 
sensus and coercive harmony have 
compelled 12 environmental 
gioujis — among them the Wilder- 
ness Society, National Audubon 
Society, California's Northcoast 
.Environmental Center and the 
Oregon Natural Resources Council 
— to fly in the face of their man- 
dates and give the nod to clear-cuts 
of ancient and native forests. 



'I 



288 



Option 9, the Clinton plan de- 
vci()i)C(l in the wake of the spiinf,'- 
tiine forest suuwnit in Portland, 
Ore., sanctions destruction of up to 
'10 iicrccntof the remaining native 
and ancient foicsts in the Pacific 
Northwest. 

But by tills time, despite public 
assertions to the contrary, some 
in.'yor environmental grou])s had 
been mired in the treacle of coer- 
cive harmony. The administration 
called for gestures of goodwill, like 
release of 54 timber sales — po- 
tentially yielding 83 million board 
feet. These are in tracts of national 
forests previously protected in the 
spotted owl suit by U.S. District 
Judge William Dwyer because log- 
ging on them was clearly illegal. 

Mow much better it would have 
been if those environmental 
groups had stuck to their guns, 
llatly denounced the Clinton plan 
as a prescription for clear-cutting 
and gone public with a vigorous 



campaign for Option One, the best- 
case strategy developed after Poi-t- 
iand, or something better. 

There arc signs of mutiny at the 
grass-roots against coercive har- 
mony. Toui- Oregon-based groups, 
including two local Audubon chap- 
ters and the Native Forest Council, 
are intervening as plaintiffs before 
Judge Dwyer in order to stop the 
cave-in. 

Some Sierra Club chapters arc 
pushing for a petition for a simple 
No Logging on Public Lands club • 
policy, an initiative being fought by 
the club's leadership. 

Sharon Duggan, a North Coast 
environmental lawyer disgusted by 
the ravages of coercive harmony, 
has called for "radical optimism" — 
the strength to take a stand and 
abide by it. < 

Alexander Cmkburn, a writer fur 
tlic Nation, Hues in Humboldt 
County. 



289 



VW-wv*<A. 



West Coast Softwood Products Exports 

Seattle, Columbia-Snake, San Francisco and Anchorage Custonis Districts 



Type Volume in Billion Board Feet (Scribner)/equivalent 

1992 1982-1992 Avg 

Wood Chips 2.72 2.71 

Pulp 3.93 3.82 

Raw Logs 3.45 3.41 

Veneer 0.50 0,81 

UNFINISHED TOTAL: 10.60 10.75 



Lumber 1.42 1.85 

GRAND TOTAL: 12.02 12.60 

NOTE: Lumber includes Cants, Merches and Raih-oad Tics 
(Possibly up to one-half total volume of lumber) 

Seattle Customs Distria includes all coastal and inland ports in the State of Washington, except Longvicw and 

Vancouver. 

Columbia-Snake Customs District includes all Oregon ports and Longview and Vancouver, Washington. 

Anchorage Customs District is the State of Alaska 

San Francisco Customs District iiKludes Monterey and all California ports north of Monterey, CA. 

SOURCE: US Department of Commerce 

SOURCE: Production, Prices, Employment, and Trade in Northwest Forest Iixlustries 
Pacific Northwest Research Station Author - Debra Warren 

Research BuUetin PNW-RB-196 



Michael DonncUy FAX: (503) 375-9334 

(Additional attachments are held In the connnlttee files.) 



290 
STATEMENT ON THE PRESIDENTS FOREST PLAN 



by 



JENNIFER M. BELCHER 

Commissioner of Public Lands 
State of Washington 



Mr. Chairman, members of the subcommittee. Thank you for allowing me this 
opportunity to comment on the President's Forest Plan. 

I want to commend the President and the administration for the courage they've 
shown in attempting to end the gridlock that has existed in the Northwest over 
forestry issues. However, I have grave concerns about the profxjsals they are 
formulating and I want to bring those concerns to your attention. 

Let me tell you first that, as the elected Commissioner of Public Lands for 
Washington State, I am responsible for overseeing the management of 5.2 million 
acres of lands, including 2.1 million acres of forested lands. These lands were 
granted, in trust, to the state at statehood, and in addition to being some of the most 
commercially productive forest lands in the world, are also home to the spotted owl, 
the marbled murrelet, and many other important species. Our lands do not exist in 
isolation, but are co-mingled with federal, other public, and private lands across the 
state. 

As Commissioner, I also am responsible for the regulation of 12 million acres of state 
and private lands for forest practices. This year we will process more than 13,000 
applications to build roads, harvest timber and conduct other forest practices. As you 
can understand, we are intimately involved with the issues of timber supply and 
protection of wildlife. We were, therefore, encouraged to learn of the President's 
plans to hold a conference in the Northwest and bring to bear on this issue the full 
influence of his office. 



291 



Page 2 '■ ~^'l 

Officials from the Governor's cabinet and I have met with administration officials 
since the President took office, offering our assistance and the knowledge that comes 
from many years of involvement in these issues. From the begiiming we have worked 
to assure that the President and his advisors develop a comprehensive approach to 
resolving the forestry conflicts. The people of the Northwest are ready for solutions. 
Our requests were straight forward: 

1. Do not treat this as a "federal lands only" issue. Wildlife do not recognize 
property boundaries, and there are many spotted owls on nonfederal lands. 
We must have a solution that acknowledges this fact and acts accordingly. 

2. The proposed solutions must be scientifically sound and, therefore, legally 
defensible. 

3. Recognize, as do we, that the harvests of the mid-1980's will probably not be 
possible again, and provide financial assistance to support our communities 
while they respond to lower levels of timber supply. 

Therefore, when we first learned of Option 9, we had concerns that it did not meet 
our first requirement ~ a comprehensive approach. We worked diligently to both 
review Option 9 and to convince the administration that it was only a partial answer. 
We discussed with them again the need for legitimate relief (based on a biological 
analysis) for nonfederal landowners, through the development of a 4(d) rule that 
would clarify what part nonfederal lands should play in conservation of the species. 



292 



Page 3 , 

Governor Lowry and I submitted a joint state response to Option 9 (a copy of that 
letter is attached). Even with its deficiencies. Option 9 is probably the best that we 
could expect on federal lands in this region given our past practices. However, it is 
only one piece of the solution. And recent discussions with Department of Interior 
officials lead me to believe that the 4(d) rule that is being considered is seriously 
flawed as it relates to our second requirement ~ that it be scientifically sound. That, 
then calls into question the entire package. 

For the past several months we have had a group of Washington scientists working to 
reconunend critical habitat for the spotted owl on nonfederal lands, given likely 
conservation actions on federal lands. The group includes two scientists from state 
government, one from the industry and one from a tribe. All have recognized 
expertise in spotted owl biology. This group's report to the State Forest Practices 
Board concludes that areas of Southwest Washington are essential to the conservation 
of the owl, among other recommendations. The proposed 4(d) rule, however, does 
not include coverage of this area. If it is indeed an essential geographic area it 
should be covered by the rule. My grave concern is that the proposed rule, coupled 
with Option 9, does not constitute a scientifically sound, and therefore legally 
defensible proposal. And we will, once again, be caught in the dilemma of having 
proposals before us which appear to be political in nature rather than sotmd 
biologically. The administration's attempts to protect this area through voluntary 
efforts should come after the 4(d) rule is adopted ~ not before . It must be made 
clear that healthy ecosystems and species viability are not "^ises" to be traded or 



293 



Page 4 

"balanced" with commodity production. Healthy ecosystems must be the baseline from 
which all other uses are considered. 

I believe Option 9 should be considered as only one part of our solution. The critical 
role played by nonfederal forest lands in protecting wildlife species viability should 
also be recognized. While federal forest lands often provide the backbone of species 
protection, it is nonfederal forest lands that help ensure species diversity, distribution, 
and viability. Again, I ask the federal government to assist and support us in our 
efforts by adopting section 4(d) regulations under the Endangered Species Act that 
are scientifically rigorous and based on an ecosystem approach to species protection, 
rather than an ownership approach. The 4(d) rule, Option 9, and a new federal-state 
partnership designed to develop agreement on sustaining our forest ecosystems, our 
timber-producing capacity, and our communities form a coherent package. To adopt 
one component of this package without the others, or in disregard of the others, will 
weaken our efforts. 

We must define common goals and make them our shared focus. The Washington 
State Department of Natural Resources shares many federal agency goals. Like our 
federal counterparts, we recognize the importance of healthy, vital ecosystems 
for their inherent value, and as the basis for sustainable economies. We can have 
both timber and wildlife if we work together. We look forward to continued 
cooperation and coordination in the months ahead. 

(Attachments follow:) 



294 




STA'^E OF WASHINGTON 

October IS. 19Q3 

The Honorable Bill Clinton 

Prcsiaent 

The White House 

1600 Pennsylvania Ave 

Washinuton. DC. 20500 

Dear President Clinton 

We uant to commend you for the courage you ha\e shown in attempting to end the gndlock that 
has occurred over manauement of federal forest lands in the Nonhwest Your Forest Ecosystem 
Management Assessment Team (FEMAT) faced a tremendous challenge m developing options for 
dealing with this problem, and given the short deadline they faced, we think they did an excellent 
job We believe that this plan is a good faith attempt to implement the Endangered Species Act 
and the .National Forest Management Act, and this is the proper focus. Option 9 is the first 
serious attempt to solve this problem t'airly and comprehensively 

We \'>ould like to respond not only to the Supplemental Environmental Impact Statement (SEIS), 
but also to your larger plan for dealing with the social and economic impacts of this new initiative, 
and to the inter-governmental coordination etTon that will be needed to implement the plans. We 
hope the concerns and recommendations that we express will strengthen Option 9 and the SEIS 
bO your forest plan nmII serve as a solid sianing point for improved stewardship of federal and 
non-icderal forest lands in our state 

The enclosed comments t'rom scseral of our state agencies provide additional analysis of the SEIS 
.ind Ortion 9 as well as some suggesfions lor maKinu the plan work better. Our main areas of 
vjonccrn are as follow s 

" Pro'.iding immediate help for nmber communif.es and taniilies 

■ Avoiding tiiture listings of native species under the Endangered Species Act (ES.\) 

' Recognizing the contributions of non-federal forest lands to wildlife conservation and 
commodity production 

" .Achieving better protection for fisheries 

" Clarity ing the environmental restoration strategy 

. " Using state-federal pannerships to resolve regional forest management issues. 



295 



OctoDerZS. 1993 ■■ ' '^'- .-i;.-<' 

Pane Two ->''' 



*.«rj^. 



First and foremost, we want to reiterate our deep concern for the welfare of our rural 
communities and the thousands of proud, hard working families who are paying a ven.- high price 
for protection of public resources. The proposed SI 2 billion in economic assistance and worker 
retraining programs is needed and welcomed. But these programs do not address the immediate 
stresses faced by families in our timber communities A wide range of social services is needed 
now, including short-term rent and mongage assistance, health care, family counseling, drug and 
alcohol counseling, and support for local food banks. Like the flood victims in the midwest, 
thousands of families in our timber communities need a life boat to keep them afloat while they 
are making the transition to a new future Since changes in federal policy gave rise to this 
hardship, the federal government has a responsibility to supplement state and local effons to meet 
the emergency short-term needs of individuals and families as they attempt to deal with this very 
real human cnsis. 

Option 9 deals primanly with federal land management. However, the Forest Ecosystem 
Management Assessment Team and others have indicated that conservation measures on state and 
pnvate lands may be necessary for the survival and recovery of threatened and endangered 
species Section 4(d) of the Endangered Species Act offers an opponunity to develop rules that 
go beyond regulatory prescriptions for protecting single species from direct harm As we have 
previously advocated, the federal government should adopt a Section 4(d) rule that gives non- 
federal landowners the opportunity to develop their own "local option" ecosystem management 
plans to protect diverse habitats and to help avoid future species listings. If the forest plan 
recognized the contribution that non-federal lands can and should make to wildlife habitat, we 
would have a more holistic approach to species protection, and it might be possible to manage 
with ureater flexibility on federal lands 

In previous discussions with your Administration, we have stressed the importance of non-federal 
lands in meeting regional ecosystem and commodity objectives. Federal lands are not an island 
either biologically or economically In most cases, species cannot be conserved solely on a single 
ownership Likewise, the continuing and growing need for timber, and the presence in the Pacific 
Northwest of some of the world's most productive forests, justifies preserving our timber 
producing capacity Regional issues such as maintaining a healthy and diverse forest ecosystem, 
strengthening our rural communities, and preserving our pre-eminence as a timber-growing area 
can only be resolved under collaborative state and federal leadership. 

Commodity objectives must also be addressed from a regional perspective. Timber demand is 
projected to increase dramatically over the next few decades; yet we are losing timber production 
capacity in one of the world's best timber-growing areas through the creation of an increasing 
number of federal reserves, changes in land tenure, and conversion of private forest lands to non- 
forest uses. State and federal governments need to work together to preserve our region's timber- 



296 



October ;S. 1993 <>"- 

Paue Three 



urowing capacity by creating; additional incentives tor keeping land in forestry, by protr.oting 
caretul stewardship and management as essential for meeting increasing demands on our forests, 
and by developmg complementary forest product niches that best suit the productive capacity and 
management objectives of vanous landowners With the FEMAT plan providing critical 
environmental protection of public resources on federal lands and a sustained, if reduced, supply 
of timber, government and the timber industry have an excellent opportunity to consider creative 
alternatives for securing a sustainable, predictable, and environmentally sound supply of timber 
from pnvate and public lands 

Regarding the need to avoid fiiture species listings, the courts have atTirmed that the Forest 
Service must provide for viable populations of native species. The SEIS indicates that Option 9 
will provide a high level of protection for spotted owls and marbled murrelets. But it also 
indicates that other options do a better job of protecting habitat for other native species If this is 
true, then we are concerned that adoption of Option 9 may be followed by additional species 
listings under the ESA that could have been avoided, and it raises the possibility we will be back 
in coun again fighting over individual species recovery plans The SEIS should provide additional 
discussion on how this scenario can be avoided under Option 9 

With regard to fisheries, the proposed forest plan needs to be improved for protection of native 
fish populations. Spons fishing as well as tribal and non-tribal commercial fishing are an 
important component of our state's history, culture and economy We need to do more than 
simply avoid the extinction of individual species or fish runs We need to restore and maintain our 
fisheries so that they will continue to suppon the jobs and recreational opportunities that make the 
■ Northwest such a special place to live .\s the enclosed comments from our state depanments of 
Fisheries. Wildlife and Ecology indicate, there are numerous ways Option 9 can be improved for 
the beneiit offish habitat and water quality In addition, the final SEIS should detail fullv the 
economic benefits that will be forthcoming with maintenance of sustainable tishenes. 

On the environmental restoration program, the plan needs a more detailed discussion of what the 
strategy will be. In these tight budget times, we need to know what the restoration pnorities are 
going to be and how we can get the greatest environmental return tor each dollar invested. In 
addition, the SEIS should discuss the overall viability of Option 9 if fijnding for restoration 
programs is not available Finally, it is unclear to what degree, and how, workers in our timber- 
dependent communities will be pan of this restoration strategy 

Finally, since ecosystem management entails close, cooperative management across all land 
ownerships, there is a need to develop a federal-state partnership for coordinated management of 
federal and non-federal lands As part of this effon, we also need to look at ways to establish 
better coordination of the ever increasing number of watershed related initiatives in our state. In 
addition, we need to explore funher the potential for some formalized mechanism to provide an 



297 



October IS. 
Page Four 



1993 



earlier warning of new problems, allowing time tor corrective actions which avoid the stnngent 
steps we are seeing now under the ESA 

With leadership from state and federal elected officials, we can develop a strategy to protect and 
restore our forest environment, diversify and strengthen our rural communities, and maintain the 
timber growing capacity of our forest lands. We are committed to working with your 
administration and Congress in suppon of Option 9 To meet its objectives, however, the plan 
must be accompanied by a commitment to funher study and to full and complete implementation, 
including adequate long term tunding, long term monitoring of both environmental and social 
etTects. and adaptive management 

Your administration has opened the door for a new and productive working relationship between 
the states and federal agencies We welcome this new opponunity, and we look forward to 
strengthening our cooperative pannership as we tace the challenges ahead. 



Sincerelv, 

— / 

Mike Lo\vry7~\ 
Govemoi>^ / 

cc Bruce Babbitt, Secretary of Interior 
Mike Espy, Secretary of Agriculture 
Interacencv SEIS Team 




Sincerely, 



/ 



O'^ -'Ucu 



Jennifer Belcher 
Commissioner of Public Lands 



(Additional attachments are held in the committee files.) 



298 



American Fisheries Society; 



Oregon Chapter 

PO B<.v722 

Corvailii Oregon 97.339 



November IS. 1993 



Char1 ie Rose 

U.S. House of Representatives 

Corwittee on Agriculture 

Room 1301, Longworth House Office Building 

Washington, DC 2051S 




The Oregon Chapter of the American Fisheries Society has completed a review of 
the report Oregon's l^ild Salmon and Steelhtad Trout: A Review of the Impact 
of Management and Environmental Factors by V. W. Kaczynski and J. F. 
Palmlsano, 1993. The Oregon Chapter of the American Fisheries Society is ^ 
professional scientific organization of fisheries and aquatic scientists. 
managers, and administrators. Members of the review panel were selected for 
their familiarity with the topics addressed In the report. As you are aware, 
this report Is a revision of the previous report, A Review of Management and 
Environmental Factors Responsible for the Decline and Lack of Recovery of 
Oregon's Wild Anadronous Salmonids, 1992. We conducted our review to assess 
the changes that were made in the report in response to the extensive connents 
and criticisms of the first report and to specifically answer the four 
questions posed In your June 1993 letter. 

The original report was criticized extensively for major technical and 
analytical weaknesses that resulted from: 1) pooling biological, 
environmental, and management information across species, geographical areas 
and life history stages, thus ignoring the importance of variation 1n factors 
Influencing mortality, production, and productivity among species, 
populations, lifestages, and watersheds throughout Oregon; Z) inappropriate 
and Incomplete presentation and Interpretation of scientific studies; 3) 
inaccurate citations and unspecified or incomplete data sources; 4) the use of 
a hig|hly subjective, non-repeatable, non-quantifiable approach to ranking 
relative importance of mortality factors responsible for losses and lack of 
recovery of wild anadromous salmonids in Oregon; S) development of conclusions 
in the report that were not based on analyses and information presented in the 
report; and 6) inappropriate use of inference. 

We would like to acknowledge the efforts of the authors in that we recognize 
that this type of review is an extremely ambitious project involving an 
immense amount of information and complexity. We found the revised report to 
contain a significant number of changes from the earlier draft; however, there 
were few substantive changes even where serious errors or misinterpretations 
were called to the authors' attention. 



299 



Charlie Rose 
November IS. 1993 
Pa9e Two 

Following are our responses to the four questions asked In your letter to the 
Chapter. 

Question One : Does the report present statisticalTy end seientlfictlly vtUd 
analysis? 

We do not believe the report presents a statistically and scientifically valid 
analysis. For a number of reasons, it is very difficult to conduct 
statistically valid analysis with the approach of pooling Information at a 
geographic level of the entire state of Oregon and the biological level above 
species. As identified in the weaknesses of the first report, it is 
inappropriate to pool information across species and watersheds because 
factors Influencing mortality and productivity are highly variable between 
species, populations, lifestages, and watersheds. Stratified analyses that 
take into account the variability as well as similarity of management, 
environmental, and biological factors Is essential to developing a 
scientifically credible estimate of the relative magnitude of various causes 
of declines of wild anadromous salmonlds. The report falls to address 
variability and its importance. 

The treatment of all potential mortality factors Is not consistent and appears 
biased. There is extensive treatment given to analysis of data from harvest, 
predatlon by marine manuals, and hydroelectric Impacts In the Columbia River, 
for example, but the analysis of impacts due to forest manaaeoMnt practices Is 
laraely an historical narrative. The availability of data Is not a reason for 
falling to adequately address the extent and magnitude of lopacts of forest 
management practices. The authors failed to mention analysis of data from two 
long-term studies of the effects of logging on salmon in the Pacific 
Northwest: the Alsea Watershed Study in Oreaon and the Carnation Creek study 
In British Columbia. Even though it Is well documented that water 
temperature, large woody debris, pool volumes, riparian vegetation, 
sedimentation, and substrate condition are all critical aspects of anadromous 
fish habitat and profoundly influence salincn survival (Meehan 1991), the 
report contains only scattered and fragmented data on tne relationship of 
forest practices and these critical factors. The report fails to address the 
Importance of the long-term persistent nature of forestry and other land use 
impacts on watersheds. 

The main conclusions In the report reside In the tables and matrices that 
present the rankings of factors responsible for loss and lack of recovery and 
the relative biological population impacts from factors contributing to loss 
and lack of recovery. A numerical ranking process is an inappropriate means 
for assessing factors responsible for decline and lack of recovery of Oregon's 
wild salmonlds. Our review indicates that there is no change in the ranking 
and analytical methodology from the first to the second report. The methods 
used in the ranking analysis were inappropriate because: 1) they were 
subjective and cannot be substantiated with scientific information; 2) Impact 
ratings appeared arbitrary; 3) many impacts were listed multiple times 
resulting in multiple counting of the same effect; 4) the method 



300 



Char] le Rose 

November 15. 1993 fS-. 

Page Three 

did not allow for assessment of cumulative or synergistic effects; 5) the 
assessment was not stratified; and 6) relative impacts were not based on the 
effect on production or productivity. 

Question Tmo : Does the revised report now present scientifically Justified 
conclusions? 

We do not believe the report presents scientifically Justified conclusions. 
The conclusions in the report are not substantially different than those 
presented in the first report. Scientifically justified cenclusloi.s cannot be 
drawn from this study because of the inadequacies described above. 

The report fails to incorporate any reasonable or useful estimates of the 
magnitude and extent of activities over time needed to develop scientifically 
sound rankings of factors causing salmon decline. Instead the report provldas 
qualitative Information on some types of land use activities In an aggregated 
fashion, such as the summary of timber harvest In board feet. The inromation 
presented on grazing, mining, and agriculture 1$ either too general or too 
fragmented to assess Impacts on a statewide level. The failure to adequately 
address the magnitude and extent of forestry activities are grazing, mining, 
and agriculture completely undermines the conclusions reached. It Is clear 
that no scientifically sound conclusions can be drawn without adequate data 
and reasonable estimates of the magnitude and extent of activities over time 
within specific watersheds. 

It Is well documented that logging and reading has had a dramatic, adverse 
effect on freshwater habitat quality throughout the Pacific Northwest (Everest 
et al. 1985; Beschta et al . 1987). Habitat factors that have been affected by 
these activities Include: increased summer water tenperatures, altered flow 
patterns, altered stream channels. Increased sedimentation, decreased 
streambank stability, and reduced Inputs of large wood. The report provides 
no real assessment or overview of the effect these changes have had on salmon 
production or survival ror does It discuss the extent o< this activity. 
Extensive logging and reading has occurred In nearly every river basin. In 
many, It Is the dominant land use. There Is Inadequate assessment of the 
effect of roads on habitat conditions and roads are inappropriately treated 
independently of forestry impacts even though many watersheds have been 
extensively roaded for timber harvest. 

The report inaccurately states that the recent US Forest Service Forest Plans 
are adequate to protect fish habitat from further damage. The Forest Service 
reviews and monitoring plans as well as other scientific assessment, to date, 
have concluded that the Forest Plans in Oregon are inadequate to protect 
existing habitat conditions, much less allow for recovery of these degraded 
systems (Johnson et al . 1991; Thomas et al . 1993; USDA Forest Service et al . 
1993). State Forest Practices Rules are considerably less restrictive than 
the US Forest Service Forest Plans, and are grossly inadequate to maintain any 
good to excellent quality habitat or to achieve the conditions needed for 
recovery. 



301 



CharHa Rose 
November 15. 1993 
Page Four 

Question Three: Have the authors adequately addressed legitimate issues 
raised by peer reviewers? 

To determine If the authors addressed significant Issues, we assessed changes 
In the report that were In response to the issues identified In the Oregon 
Department of Fish and Wildlife Reviw of the Oregon Forest Industries Council 
Report, 1992. As mentioned earlier, we found a substantial number of changes 
In the report, however, most were of an editorial nature (citation 
corrections, spelling, additional references, etc.) and did not deal with the 
principle scientific weaknesses. Many of the errors. Inaccuracies, and 
omissions identified 1n the Initial report were once again present In the 
final report. The methodology used for ranking relative biological population 
impacts was not changed even though peer review indicated that it was 
inappropriate and without scientific merit. It appears there was little 
attempt to correct the major weaknesses in the report. 

Question Four: Should the U. S. Congress, Governor, and the public rely on 
the scientific soundness and accuracy of this study? 

We do not believe this study should be relied on because of all the reasons 
described previously in this letter. 

He thank you for the opportunity to comment on the merit of this report. At 
thesi critical crossroads in the Mnagement and recovery effort of our 
salBonid resources it is imperative that decisions be based on the' very best 
scientific Informtion available. 



Respectfully, 

Richard U. Carmichael 
President, Oregon Chapter AFS 



302 



Charlie Rose 
November IS, 1993 
Page Five 



References 



Beschta, R. L., Bilby, R. E.. Brown, G. W., HoUby, L. B., and Hofsta, T. D., 
1987. Stream temperature and aquatic habitat: Fisheries and forestry 
interactions. //>: Streamside Hanagement: Forestry and Fishery 
Interactions, pp. 191-232, Univ. of Wash. Inst, of Forest Resources 
Contribution No. 57. 

Everest, F. H., Amiantrout, N. B., Keller, S. H., Parante, M. D., Sedell , J. 

R. Niclcelson, T. E.. Johnson, J. N., Maugen, G. N., 1985. Salmonlds. 

In: Management of Wildlife and Fish Habitats In Western Oregon and 
Washington, pp. 200-230, USDA Forest Service WW Region. 

Johnson, K. N., Franklin, J. F., Thomas, J. W.,, Gordon, J. 1991. 
Alternatives for management of late-successional forests of the Pacific 
Northwest. A report to the Agriculture Comnlttee and the Merchant 
Marine Committee of the U. S. House of Representatives. 59 p. 

Heehan, W. R., ed. 1991. Influences of forest and rangeland management on 
salmonid fishes and their habitat. American Fisheries Society Special 
Publication 19. 750 p. 

Thomas, J. W., Raphael. M. G., Anthony. R. G.. [and others]. 1993.' Viability 
assessments and management considerations for species associated with 
late-successional and old-growth forests of the Pacific Northwest. USOA 
Forest Service. 530 p. 

United States Department of Agriculture Forest Service and five co-author 
agencies. 1993. Forest Ecosystem Management: An Ecological, Economic, 
and Social Assessment. 



303 



American Fisheries Societi; 



Oregon Chapter 

P.O. Box 722 

Corvallis, Oregon 97339 



October 27, 1993 

To VAioo it may concer: 



The attached is a review of the DSEIS on Management of Habitat for 
Late-Successional and Old-Growth Forest Related Species Within the 
Range of the Northern Spotted Owl by the Oregon Chapter of the 
American Fisheries Society 

The Oregon Chapter of the American Fisheries Society is a 
professional scientific organization of fisheries and aquatic 
scientists, managers and administrators. This review was prepared 
by members versed in forest and aquatic ecosystem management and 
research. Our comments primarily relate to the Aquatic 
Conservation Strategy (ACS). 

In general, we strongly support the ACS and applaud efforts to 
restore forest ecosystems on federal lands. 




Respectfully, 



Richard W. Carmichael 

President 

Oregon Chapter 



304 



Riparian Reserves 

The two key aspects of the riparian reserve strategy are 1) their 
spatial location on-the-ground and 2) the standards and guidelines 
that govern their management. The riparian reserve strategy, 
overall, must be praised as an integral part of the Aquatic 
Conservation Strategy (ACS) . Maintenance of riparian connectivity 
throughout all watersheds is critical in order to achieve the ACS 
objectives. 

1) Riparian Reserve 1 scenario should be the standard for all 
watersheds (FEMAT, V-73)' The strategy allows for modifications 
after a full watershed analysis if indicated. We are particularly 
concerned with the reduced reserve widths of intermittent streams 
in tier 2 "key" and "other" watersheds. Although the choice of 
riparian widths for intermittent streams in Tier 2 Key Watersheds 
and non-Key Watersheds is stated to be sufficient to provide full 
ecological effectiveness (page 'i^k'^S) > no rationale is provided. 
This appears to ignore the information presented in FEMAT on 
necessary widths (pages V-28 and V-38, and Figure V-l4) to protect 
the ecological integrity of intermittent streams, which is 
"consistent with the height of 1 site-potential tree" (page V-38) . 



2) We recommend changing the width standards on all Riparian 
Reserves from tree height and slope distance to tree height and 
horizontal distance as recommended by the Scientific Analysis 
Team. Horizontal distance is a more consistent measure of 
function, and it is compensatory for differences in hillslope 
steepness. This will result in variable slope distances that 
better responds to the potential for contributing large wood, 
shade, and microclimate. 

Beginning on DSEIS p 2-22, Riparian Reserves are defined based on 
slope distance or some fraction^ of a site potential tree. This 
should also include 100 year floodplain,- inner gorge, extent of 
riparian vegetation, unstable and potentially unstable areas in 
accordance with FEMAT p V-35- Defining reserve boundaries as the 
edges of the floodplain or riparian vegetation does not account 
for affects on microclimate and other functions (e.g., 
contribution of LWD to the floodplain) of the transition between 
riparian and upland areas. 

3) For the DSEIS, we recommend using the FEMAT definition of 
site-potential tree, to wit, "the average maximum height of the 
tallest dominant trees (200 years or more) for a given site 
class." 

^) The definitions of a fish-bearing and permanently flowing 
streams should be clarified. A fish-bearing stream may be either 
perennial, intermittent, or ephemeral. Thus, any fish-bearing 
stream would receive interim riparian reserve width of the average 
of two site potential trees or 3OO feet on both sides. 



305 



Additionally, streams that flow for most of the year (e.g., 9 
months or longer) tmd throughout most of their lengths should be 
treated as permanent streams. 

5) It is not clear why a distinction was made in protection 
standards for fish-bearing vs. non- fish-bearing streeuns. The 
ecological processes and functions of streams and their associated 
riparian areas are similar whether or not they contain fish. Some 
streams have fish only seasonally, which may not coincide with the 
time the streams are inventoried for fish presence. Focusing on 
fishes is underprotective of the multitude of other aquatic and 
terrestrisil organisms that require healthy riparian areas for 
reproduction, feeding, nesting, or as migration corridors. 
Buffers should be designed to protect all streams from memagement 
impacts regardless of their permanence and residents; this 
protects not only the headwaters but their receiving streams as 
well. History has shown us that we cannot have healthy rivers fed 
by unhealthy headwaters. 

6) The process for instituting changes in the Riparian Reserve 
boundaries from a Watershed Analysis needs to be better defined, 
and scientific oversight will be essential for any changes. We 
support the second paragraph on V-44 in the FEMAT report. The 
interim widths, which are supported by a considerable amount of 
scientific evidence presented in FEMAT, should serve as a starting 
point and any changes made during watershed analysis should be 
required to have scientific justification and to provide a 
comparable level of protection as a minimum. As stated in FEMAT 
(V-44), "...we consider the interim widths to approximate those 
necessary for attaining Aquatic Conservation Strategy 
Objectives." The make-up of the Interdisciplinary Team needed to 
conduct the Watershed Analysis described in the third paragraph on 
page B-80 of the DSEIS needs to specifically identify "fisheries 
biologists or aquatic ecologists", not just "biologists". 

Stsindards and Guidelines 

In general , several of the standards and guidelines rely on a 
reference to "meeting" or "attaining" the ACS objectives. While 
there is a discussion on current efforts underway to establish 
quantifiable objectives for desired conditions of riparian 
reserves, the ACS objectives stated are not quantifiable and 
therefore do not serve as a solid anchor upon which to base 
standards and guidelines for management of riparian reserves. 
Without a quantifiable basis, there will be great inconsistencies 
experienced when implementing many of these standards and 
guidelines. We should embrace the recognition that quantifiable 
objectives for desired conditions should be "watershed-specific" 
and we should suggest that these desired conditions be defined as 
part of the watershed analysis. In the mean time, those standards 
and guidelines that rely subjectively on non-quantifiable ACS 
objectives should be restructured in a manner that maintains the 
original intent of the FEMAT. 



306 



The Standards and Guidelines (S&G) for Riparian Reserves are seen 
as a "minimum set of land management prescriptions necessary to 
meet Aquatic Conservation Strategy Objectives" (Appendix V-F, 
FEMAT). However, these objectives are so generally worded that 
there is no measurable way of knowing when they are attained or 
even how much progress has been made toward attaining them. The 
S&G wording is also such that results cannot be measured for the 
most part. Many of the StG call for "minimizing" impacts. Given 
the state of aquatic resources and habitat conditions on federal 
lands, S&G should be more explicitly worded so as to reverse 
habitat degradation. 

Timber management: We agree that Riparian Reserves should be 
removed from the timber base and that timber harvest should be 
prohibited (TM-1). We do not agree that natural events such as 
fire, flooding, wind, or insect damage should be classified as 
"catastrophic", especially given the acknowledgement that aquatic 
ecosystems are dependent on disturbance events and the need to 
"maintain features of the natural disturbance regime" (page 
3&^-22). If the riparian area has been burned, salvage activity 
will likely increase erosion on exposed soils, additional roads 
may be built, and streams may suffer more damage than if left 
alone to recover naturally. Recovery time for streams may be 
relatively quick if they are protected from further damage. In 
addition, the state of knowledge about how much woody debris a 
stream needs is presently inadequate to determine how much may be 
surplus (and thus considered for salvage) (see page 6-75)- 

Some manipulation of riparian areas may be necessary in some 
areas, but for many streams or sections of streams simply 
protecting them from further degradation and allowing nature to 
take its course will achieve desired riparian conditions. "Active 
silvicultural programs may be necessary to restore large conifers" 
(page V-57 FEMAT, our emphasis, changed to will in DEIS, page 
B-82). "There has never been a regionwide assessment of need or 
opportunity for watershed restoration through riparian 
silviculture." (page V-58 FEMAT. 'left out of DEIS, page B-82). 

Roads management: First, both the DEIS and FEMAT report are clear 
about the damage roads have caused to watersheds and streams. 
Given these acknowledgements about the effects of roads, 
especially on sedimentation to streams, about the extent of 
streams that are moderately or severely impaired {35% or 20, '400 
miles, page "iic^-Zk) , about the existing network of roads (110,000 
miles on federal lands within the range of the northern spotted 
owl - page 'i&.h-Zk) , and about the role of roads on nonfederal 
lands making "an incremental contribution to the cumulative 
impacts disclosed" (page 3^^-3) . we find the Standards and 
Guidelines on roads to be inadequate. This is especially true 
given Objective 5 of the Aquatic Conservation Strategy to address 
sediment input to streams. 

We agree with some provisions of the Standards and Guidelines, 
especially reconstructing roads that pose a substantial risk. 



307 



closing or obliterating roads, and building and upgrading culverts 
to acconuDodate 100-year floods. However, we feel the overall 
objective of these SiG should be to reduce the road mileage in 
Riparian Reserves on federal lands. "Minimizing road and landing 
locations in Riparian Reserves" {RF-2a) and "[minimizing] sediment 
delivery to streams from roads" {RF-5) will not be adequate to 
achieve many of the objectives of the Aquatic Conservation 
Strategy, given the current state of habitat conditions. FEMAT 
recommends that there be no net increase in road mileage in Key 
Watersheds if there is not funding to reduce roads. In effect, 
this would maintain excessively high road densities in many 
watersheds. These provisions are not explicit enough to achieve 
the overall goal of "maintaining and restoring ecosystem health at 
the watershed and landscape level", especially with the degree of 
damage that is attributed to roads. For example, sediment 
delivery is recognized as a major problem to the health and 
function of streams, therefore the StG RF-5 should call for a 
measurable reduction in sediment delivery to streams. Otherwise, 
the current S&G merely continues status quo conditions at best and 
may result in an increase in sediment if new roads are built. 
Wording similar to that used for the grazing and recreation SiG 
should be used for roads: Where Aquatic Conservation Strategy 
Objectives cannot be met through efforts such as proper design, 
maintenance, and operation of roads, reduction in sediment 
delivery to streams, etc., then roads should be relocated, closed, 
or obliterated. 

We agree that development and implementation of a Road Management 
Plan can help to establish the purpose of existing roads and 
identify potential problems. We feel this plan should also 
include justification for keeping existing roads and should 
identify strategies to reduce the road mileage on federal lands. 
Until an adequate plan is written and approved, no new roads 
should be built in Riparian Reserves. In summary, the Standards 
emd Guidelines call for much action but in lig^t of the reduced 
ability of the federal agencies just to maintain roads (page V-57 
FEMAT) , we feel the SLG for roads should be more restrictive and 
should reflect an active effort to reduce road mileage on federal 
lands in general and in Riparian Reserves in particular. 

Grazing management: Allotment management plans should be written 
and implemented that will identify problems with grazing, benefits 
of grazing allotments, costs to administer the grazing program, 
costs to aquatic resources, and costs to mitigate damage. The 
plans should also establish the purpose and rationale for 
maintaining the grazing program. Grazing should be eliminated 
where it cannot be justified. After a grazing plan is written, 
then S&G GM-1 through GM-3 will be applicable for those grazing 
allotments than can be justified. 

Minerals management: Overall, the S&G for mineral management are 
very weak. Although little can be done about existing claims 
because of provisions of the I872 Mining Act, Riparian Reserves 
could be administratively withdrawn from filing of future claims. 



308 



The main text of the DEIS or FEMAT should discuss impacts of 
mining and also the inadequacies of existing regulatory authority 
under the I872 Mining Act. Given the inadequacies of this act, 
S&G for mining should be more restrictive in order to prevent 
further habitat degradation of streams. 

Fire/Fuels management: S&G FM-1 should be more explicit in 
requiring a minimum of fire suppression activities (where deemed 
appropriate) that create more problems than the fire would have 
itself. Excessive use of heavy equipment, construction of broad 
firebreaks, construction of roads, etc. can result in greater 
damage to riparian and upslope areas than a fire alone, thus 
retarding the recovery time. FM-3 should be a prohibition of 
chemical retardants, foam, or additives to surface waters, with 
justifiable exceptions for safety or for preventing greater 
long-term damage to a watershed. 

General riparian area memagement: It is unclear to us how RA-2 is 
necessary to achieve any objectives of an Aquatic Conservation 
Strategy. If the S&G refers to some specific areas such as along 
roads or in campgrounds , then the wording should be more 
explicit. Also, use of herbicides, insecticides and other 
toxicants should be discouraged in Riparian Reserves. Again, as 
in other StG, the use of such chemicals should be reviewed and 
justified before they are used. 



Several standards and guidelines are essential for the achievement 

of the ACS objectives. These include: 

TM-1 Prohibiting general timber harvesting within riparian 

reserves. 

RF-3 A strong emphasis on restoring existing roads with riparian 
reserves . 

RF-^ The requirement for new stream crossings to accommodate a 
100-year flow event. 

RF-6 Providing fish passage at all new and existing stream 
crossings. 

MM-1 The requirement of a reclamation plan, approved Plan of 
Operations, and reclamation bond for all minerals operations that 
include riparian reserves. 

WR-3 Mitigation and restoration should not be a substitute for 
habitat degradation. 



Specific recommended changes: 

TM-1 a) Fuelwood cutting will not help achieve ACS objectives and 
should be dropped. 



309 



c) silviculture practices should be developed and 
implemented only as an output from Watershed Analysis, not as a 
separate activity. Salvage logging after catastrophic events 
within riparian reserves ignores the important timeframe for large 
woody debris (LWD) recruitment to stream channels. Natural 
recruitment of LWD is episodic and depends on catastrophic 
events. Large recruitments of LWD may be somewhat infrequent and 
therefore catastrophic events may be absolutely critical for the 
long term ecological functioning of riparian reserves and 
associated streams. Lastly, silvicultural practices should be 
used only to restore riparian reserves in a sub-standard condition 
and should not result in extraction or removal of wood fiber from 
riparian reserves. Silvicultural practices should only be used 
within riparian reserves where they mimic natural ecological 
functions. 

RF-2 Roads and landings should not be located within riparian 
reserves (see FEMAT V-I6-I9) . 



RF-3 c) This is a very important standard that should be a major 
emphasis of all Watershed Analyses, particularly Key Watersheds. 

RF-4 Suggest the following word changes: "Provide and maintain 
fish passage at all new and existing road crossings of existing 
and potential resident and anadromous fish-bearing streams. 

MM-1 Suggest the following word changes: "Require a reclamation 
plan, approved Plan of Operations, and reclamation bond for all 
new and existing minerals operations either within or outside of 
Riparian Reserves that may directly or indirectly affect Riparian 
Reserves or their associated streams ." 

MM-2 This standard and guideline references meeting "Road 
Management Standards." These Road Management Standards are not 
identified in the draft SEIS. FEMAT Report, or SAT Report. 

MM-7 (new) Assess potential impact of mineral development in the 
Watershed Analysis process and, where appropriate to meet 
ACS objectives, pursue withdrawals from mineral entry. 

FM-1 This standard and guideline must call for the development of 
fire management plans in order to develop, document and track 
fuel treatment and fire suppression strategies, practices, 
and activities. Similar to RF-7 which calls for the 
development of Road Management Plans, this standard and 
guideline relies heavily on the development and 
implementation of a long range plan for fire management. 

FM-3 Suggest the following word changes: " Prevent delivery of 
chemical retardant, foam, or additives to surface waters." 
An exception may be warranted where . . . when an escape would 
cause more long-term damage. In the case of these 



78-799 0-94-11 



310 



exceptions, the delivery of chemical retardant. foam, or 
additives to surface waters would be minimized . " 

RA-2 Suggest that trees felled within Riparian Reserves for safety 
reasons be required to be kept on-site. 

WR-1 Suggest that a standard and guideline be added that requires 
the development of a comprehensive watershed restoration plan 
prior to the implementation of watershed, riparian, or stream 
habitat restoration projects within all watersheds. See 
comments directed at "Restoration," below, for specific 
elements of this plan that will be addressed. 

FW-3 This standard and guideline seems inappropriate for 

ecosystems west of the Cascade divide, and furthermore seems 
out of balance with an ecologically ttased management 
approach. 

FW-4 (add) If coordination fails to achieve the ACS objective, 

require the affecting activity to cease and a NEPA analysis 
be conducted prior to resumption of the activity. 

GM-1, GM-2. GM-3. RM-1, RM-2, MM-4. MM-5, MM-6, LH-2, LH-3, RA-3. 

RA-t*, WR-1, FW-1, FW-2 

The success of these standards and guidelines depends heavily 
on quantifiable desired conditions that should be defined 
through watershed analysis. These standards and guidelines 
should be rewritten so that they are tied directly to 
achieving those desired conditions. 



Restoration 

Due to existing conditions, watershed restoration is absolutely 
essential. We highly commend the integrated watershed-approach to 
restoration. No longer can rest'oration be conducted in a 
piece-meal fashion. The three primary restoration opportunities 
identified accurately reflect watershed restoration needs on a 
regional scale -- roads, riparian vegetation, and in-stream 
habitat. Without the implementation of watershed restoration, it 
is safe to say that all nine ACS objectives will not be met in 
full, whereby each objective begins with "Maintain and 

RESTORE " Therefore, full congressional funding for watershed 

restoration is absolutely essential to the success of the Aquatic 
Conservation Strategy. We strongly support that watershed 
protection supersedes restoration, and that restoration is not to 
be used as a mitigation in the absence of watershed protection. 

We recommend that comprehensive watershed restoration plans -axe 
developed prior to the implementation of restoration activities. 
Restoration plans will serve to document and track the rational, 
reasoning, and recommendations by restoration planning teams. At 
a minimum, the watershed restoration plan should include: 1) a 
summary of existing and desired conditions (much of which can be 



311 



derived from the watershed analysis): 2) the watershed-specific 
restoration goals and objectives; 3) a prioritization and timeline 
for implementation of projects; 4) complete project descriptions, 
plans, and designs (including cost estimates); and 5) a monitoring 
plan. 

It needs to be recognized that the final cost of restoration will 
be high, very high, but it is essential that adequate funding be 
provided for planning, implementing, and monitoring. There are no 
shortcuts or easy answers. Success of the ACS requires all 
components. The over-riding assumption in the risk analysis and 
consequences sections of the DSEIS is that all aspects of the ACS 
would be implemented. 

Roads : 

The complete, comprehensive coverage of road restoration is 
commendable. We support Approach #1 to road restoration and 
encourage road restoration in all watersheds not just Key 
Watersheds. Approach #1 would allow for the greatest mileage of 
roads to be decommissioned and upgraded. One very important area 
that was not adequately addressed is the impact that roads in the 
riparian zones have, particularly floodplain or valley bottom 
roads. The magnitude and cost of re-connecting streams with their 
flood plains was not adequately discussed. Many of these roads 
are adjacent to the larger, more productive rivers and streams. 
The roads themselves are major arterials, often paved, and 
represent a major capital investment. To truly meet the 
objectives of the ACS, many of these roads will need to be removed 
and/or relocated. This removal and subsequent re-habilitation of 
the stream and riparian zone will be a major activity. This 
aspect should be a major focus of the Watershed Analyses in each 
Key Watershed and many of the non-key watersheds as well. 

Riparian Vegetation: 

We agree that there is great potential for restoration of riparian 
vegetation. Silvicultural practices for riparian vegetation 
restoration, however, are in their infancy. A greater 
understanding of riparian silvics is needed, and we strongly 
support greater research in this area. Where silvicultural 
practices are used within Riparian Reserves, we recommend that 
they are designed and implemented in a manner that simulates 
natural disturbances and processes at work within riparian 
ecosystems. Furthermore, we recommend a "no- fiber loss policy" 
for Riparian Reserves--there will be no removal of trees or wood 
fiber for commercial or special uses. 

In-Stream Habitat 

We strongly support that in-stream habitat restoration is carried 
out only as part of a comprehensive watershed restoration plan. 
Stream habitat restoration efforts should be conducted in a manner 
to mimic natural processes and functions at work in lotic 



I 



312 



ecosystems. Greater technical oversight and training are needed 
at a regional level to ensure appropriate stream habitat 
restoration. We would encourage an additional Riparian Reserve 
standard and guideline under the section of watershed and habitat 
restoration that would require interdisciplinary technical 
oversight teams at the U.S. Forest Service Forest level or USDI 
Bureau of Land Management District level. Interdisciplinary 
technical oversight teams would be composed of a aquatic ecologist 
or fish biologist, hydrologist or fluvial geomorphologist, 
wildlife biologist, riparian or plant ecologist, and soil 
scientist. These oversight teams would be responsible for 
providing technical support to the development and implementation 
of restoration plans, reviewing restoration plans and 
on-the-ground projects and operations, and providing annual 
training for resource professionals. 

Key Watersheds ' ' 

Key Watersheds as well as increased habitat protection for 
watersheds in Late-Successional Reserves (LSR) play an 
important role in meeting the objectives of the Aquatic 
Conservation Strategy. The concept of providing for refugia 
is well accepted. However, implicit to the success of these 
refugia is the assumption that at some time in the future 
these refugia will contain high quality habitat for aquatic 
organisms. Without very restrictive measures in place to 
limit road building, timber harvest, and other threatening 
activities, there is no assurance of preventing further 
deterioration of watershed and aquatic habitat conditions. 

Key watersheds that contain high quality habitat need to be 
distinguished from those identified on the basis of their 
restoration potential. Development should be prohibited in 
the key watersheds and roadless areas that contain high 
quality habitat because of the uncertainties and risks 
associated with timber harvest arid management activities and 
the need for minimally disturbed benchmarks for comparison 
with managed watersheds. 

Because of the importance of Key Watersheds , we feel they 
should receive high levels of protection. First, inclusion of 
roadless areas in Key Watersheds is important to achieving the 
stated objectives, especially given the fact that Key 
Watersheds in themselves receive no special protection outside 
of the Late-Successional Reserves or Riparian Reserves 
contained within them (page 2-l8) . For example, timber sales 
from Tier 1 Key Watersheds are estimated to provide 15-20^ of 
the probable sale quantity (page II-*!? FEMAT) . Second, we 
agree that no new roads should be built in inventoried 
roadless areas in Key Watersheds (page 3i'^"50) . We also agree 
that there should be a reduction in road mileage in Key 
Watersheds. Although we agree with the concept of no net 
increase in road mileage, priority should be given to 
achieving a reduction in road mileage, especially given the 



313 



extent of the road network on both federal and private lands 
and the cumulative effects of these roads. 

Third, because of the importance of Key Watersheds, the amount 
of disturbance should be minimized. Twenty percent of the 
area of Key Watersheds in Oregon is either in the Matrix or in 
Adaptive Management Areas (AMA) , which means they are open to 
land meinagement activities. In addition, portions of LSRs are 
also open to various land management activities including 
timber harvest Eind road construction. These two activities 
pose threats to watersheds from federal land management 
practices (page W-^^ FEMAT) and contribute to cumulative 
effects on watersheds from federal and nonfederal activities 
(page 3&^~3)' Administratively withdrawn areas could also be 
included in land designations that are open to timber harvest 
in the future (page 11-25, FEMAT). These threats and 
uncertainty lead us to support removing Key Watersheds from 
the timber base and providing them with maximum protection as 
proposed on page S&'^'lOl- 

It is unclear to us what portion of the 31^ at-risk anadromous 
fish stocks (259 on federal lands, page V-10 FEMAT) are 
contained within the Tier 1 Key Watersheds. Do the key 
watersheds contain systems historically occupied by bull 
trout? Population modeling indicates fragmented populations 
will be extirpated unless their distributions can be expanded 
beyond currently occupied habitat (Rieman and Mclntyre 1993). 
With the exception of the Metolius-Billy Chinook population, 
the bull trout populations in the range of the spotted owl in 
Oregon are highly fragmented. 

Because LSRs tend to be relatively undisturbed areas, offer 
good stream habitat in degraded landscapes, and contain 
streams that may be important for locally distributed fish 
species and stocks (page 3&'+-'+7). they should be designed to 
capture watershed boundaries where they fall outside of the 
Key Watershed designations. In addition, under Option 9. more 
of the relatively undisturbed area is open to road 
construction and timber harvest than in several other options, 
increasing the risk to aquatic and riparian habitat (over 20?! 
in Matrix and 6% in AMAs, only Option 7 opens more area to 
management, ^^% of the roadless areas fall outside Key 
Watersheds, 56jl! for Oregon {Table V-8, page V-52}; and under 
Option 9. 23% of the roadless area is in the Matrix). Because 
of the threats these activities pose to watersheds, several 
measures should be taken to provide additional protection to 
watersheds on federal lands. 

First, all inventoried roadless areas should remain intact. 
Despite the fact that roadless areas are often characterized 
by unstable land, management activities will increase (Table 
V-9, page V-53) • Second, because many watersheds are not 
included as Key Watersheds, they receive less riparian 
protection. These areas should receive the more protective 



314 



Riparian Reserve Scenario 1 as proposed In one of the 
mitigation strategies (page 'SL^-100) . Because Tier 2 Key 
Watersheds contribute to the water quality of the Tier 1 Key 
Watersheds, they should also receive equal protection and 
incorporate the Riparian Reserve Scenario 1 . 

There needs to be an opportunity to review and revise Key 
Watersheds as necessary when new information becomes 
available. Proposed Key Watersheds were identified and 
recommended based on the best information available at the 
time. Much information and data were lacking or incomplete at 
the time of Key Watershed identification and designation. As 
new information and data become available. Key Watersheds need 
to be revised and updated. 

Watershed Analysis 

Watershed analysis is a "relatively new concept", which 
currently appears to focus on physcial processes (Page V-56) ; 
however, social and biological factors may be equally 
important and deserving of attention. For example, fish 
stocking and harvest, depleted numbers of carcasses, 
vegetation fragmentation, invasion by more tolerant species 
(including predators, competitors, disease, and parasites), 
and introductions of exotics are often more limiting than the 
physical setting of the system. Watershed analysis must also 
incorporate information pertaining to such biological factors 
as abundance, life histories, habitat requirements, and 
limiting factors of critical species (Appendix V-I). However, 
these data are generally lacking and "understanding of fish 
habitat relationships is inadequate. . .at the watershed level" 
(page B-75)- Thus watershed analysis should be considered an 
experimental approach. The effectiveness of watershed 
analysis in defining such important parameters as width of 
Riparian Reserves should be evaluated in non-Key Watersheds 
before the analysis is used in K$y Watersheds. A guideline 
for silviculture cautions that implementation experience is 
not extensive and therefore the rate of iinplementation should 
be modest and should provide opportunity to assess and refine 
activities (page B-7I). We suggest this wording be applied to 
guidelines for implementing watershed analysis. 

Watershed analysis is not a substitute for adequate standards 
and guidelines and other measures to protect aquatic 
resources. Some of these standards are biologically 
fundamental and need to be established as minimums not subject 
to reduction through watershed analysis. 
It is also unclear how local watershed analysis will 
incorporate broader regional concerns and cumulative effects, 
which in the past have been largely overlooked. 
Watershed Analysis is required for Key Watersheds before 
management activities proceed except for those that are 
Categorically Excluded under NEPA. FEMAT states that 
Categorical Exclusions should be consistent with Aquatic 



315 



Conservation Strategy Objectives (FEMAT, p V-^6, last 
paragraph). The DSEIS should also contain this caveat (DSEIS, 
p2-17, last paragraph, and DSEIS appendix b-79, paragraph 4). 

Late Successlonal Reserves 

Option 9 calls for no entry in stands >80 years old. It is 
unclear how much of this habitat is protected under Option 9. 
compared to other options. 

Adaptive Management Areas 

The purpose of these areas is to generate creative and 
innovative approaches to forest management. This seems to 
imply that management outside of AMAs need not be creative and 
innovative. It needs to be recognized that ecosystem 
management in all areas is essentially experimental requiring 
imagination, planning, and monitoring. 



Page B-60 states "...it is absolutely critical that 
initiation of activities [in AMAs] not be delayed by 
requirements for comprehensive plans or consensus 
documents..." This suggests that watershed analysis is 
incompatible with AMAs. Requirements for watershed analysis 
and meeting ACS objectives should also apply to AMAs. If 
these areas are truly for broad-scale experimentation, 
comprehensive planning is in order to assure that activities 
are set up so they can be properly implemented, evaluated, and 
altered. Experimentation in how watershed analysis is 
conducted and ACS objectives are achieved is appropriate. 
The time to learn the ecological effects from many of these 
activities will be long, while there will be a pressing desire 
to more broadly apply those activities with apparently 
successful short-term results. 



Ecosystem Management 

We applaud the intent of the BLM and FS to work cooperatively 
at the catchment and regional scales; however, the 
checkerboard BLM land ownership patterns, as well as private 
lands in many FS catchments, hinder efficient catchment or 
basin level planning and management. Consolidation of land 
ownership into federal forest lands and nonfederal forest 
lands will facilitate this process. Consolidation of forest 
management under a single federal agency seems like another 
necessary step, both to facilitate management and to save on 
administrative costs. 

Who will make the ultimate decisions on the large number of 
options available for adaptive meinagement areas, key 
watersheds, riparian reserves, and province/watershed 



316 



integration and analysis? What sort of public review is 
needed and at what stages of development? How will immediate 
and direct pressures to cut trees be countered with the long 
term and indirect needs to restore and protect ecosystems? 
These social Issues require much more thought, for ultimately 
they, not the natural science, will determine the success of 
this endeavor. 

Provincial and Regional Perspectives 

There are at least two different province maps used in these 
documents and they are based on quite different perspectives 
as to the important variables. They do not agree in the 
number of provinces or in their orientation. This indicates a 
substantial gap in how the aquatic and terrestrial ecologists 
view the landscape eind the watershed analyses that may 
result. Physiographic provinces are based purely on 
physiography; they do not explicitly incorporate many of the 
other features of the landscape that are critical to 
understanding it as an ecosystem (climate, soil, surficial 
geology, vegetation, fauna, land use), and this particular map 
doesn't even distinguish the Olympic Mountains from the rest 
of the peninsula. Provinces split at state boundaries for no 
ecological reason. In addition, the province and basin 
boundaries are often orthogonal to each other. This makes it 
very difficult to integrate ecosystems between the two. A 
hierarchical ecoregion map is needed to facilitate this 
process; the USEPA has already completed such a map for the 
Oregon and Washington Coast Range. Their state and national 
maps also appear more accurate and informative than the 
province maps displayed herein. Were they considered for this 
purpose? 

The concept of a sustainable economy is an interesting one. 
What does it mean? What aspects and levels of the economy are 
to be sustained and for how long? Our short history with 
commercial fisheries in the North Atlantic, North Pacific, and 
Great Lakes has shown a distinct inability to develop a 
sustainable economy based on -fishing. Our timber industry in 
those same general regions has not been sustained for more 
than a few decades. The socioeconomic changes needed for 
sustainable fisheries and forestry are not evident in these 
documents. How can a timber industry be sustained that does 
not degrade the environment when the access to, and the 
harvest, processing, use and disposal of, the products all do 
so? 

Monitoring 

As stated in FEMAT, the key is conscientious implementation. 
Monitoring and oversight are the keys to successful 
implementation. Monitoring is so important, it could be a 
fifth component or at a minimum, given very high emphasis in 
/ the existing four. "Currently, adequate monitoring is 



rn' 



essentially nonexistent throughout the federal resource 
management agencies despite being required by forest plans" 
(III-26 FEMAT and B-59). Conscientious implementation this 
time will require major changes in those agencies. Although 
monitoring is emphasized in several places in the documents, 
there are no discussions of the monitoring designs necessary 
nor of major national monitoring programs (EMAP, NAWQA, MBS) 
or of state biocriteria progreims, all of which should be major 
components of monitoring and assessment. Will there be 
adequate funding for design studies, pilot studies, 
pre-project sampling, centuries-long monitoring? How will a 
sufficient number of representative (random) sites be 
selected? What indicators will be monitored? Is it possible 
to obtain interpreted remote sensing data (as well as plane 
exchanges) from the military intelligence community (further 
interagency cooperation)? 

Technical oversight and authority is an absolute requirement 
for the implementation of the ACS. An interagency technical 
oversight committee composed of representatives from the 
scientific community and management needs to be established in 
order to implement the ACS. The committee would be gjranted 
authority in areas needed in order to ensure full attainment 
of ACS objectives and to provide consistency throughout the 
Pacific Northwest Region. 

Ecological Justifications for the Alternatives 

What alternative was recommended by the scientific panel in 
chapter 5? What is the ecological rationale for supporting 
alternative 9? Alternative 1 prohibits salvage (which has 
historically been an excuse for logging) , supports larger 
reserves and wider buffers, protects much more old growth, and 
has the highest probability of protecting all old growth 
species (including fishes, mollusks, and other 
invertebrates). Why was it not supported? All the other 
alternatives listed increase local restrictions and reduce 
species distributions, and, therefore, increase the chances 
that species will be extirpated. Preserving less than the 
maximum old growth and riparian areas , when there are so few 
left, is a gamble with species extinction, depleted biological 
integrity, and loss of fisheries. We can always cut more 
timber once the species and stocks recover, but once they are 
gone we can do nothing about it. 

There are no quantitative data presented that describes the 
certainty with which we should view the assessments of the 
options. Given that the alternatives were evaluated through a 
Delphi process of expert opinion, figures for each alternative 
showing the central tendency (medians) and distribution 
(percentiles) of those opinions are needed. 



318 

October 26, 1993 



Interagency SEIS Team 
Post Office Box 3623 
Portland, OR 97208-3623 



Re: My Comments on the "Draft Supplemental Environmental Impact Statement 
(DSEIS) on Management of Kabitat for Late-Successional and Old-Growth 
Forest Related Spedes Within the Range of the Northern Spotted Owl" 



THE FOLLOWING SPECIFIC COMMENTS ADDRESS THE ADEQUACY OF THE DSEIS AND the 
MERITS (OR LACK OF MERIT) OF THE ALTERNATIVES DISCUSSED. THESE COMMENTS 
ESTABLISH MY PARTICIPATION IN THIS ACTION. THEY ARE STRUCTURED AND 
INTENDED TO BE MEANINGFUL AND TO ALERT THE RESPONSIBLE PARTIES TO MY 
POSITIONS AND CONTENTIONS. FAILURE TO ADEQUATELY REVIEW, CONSIDER AND 
RESPOND TO THESE COMMENTS MAY RESULT IN APPROPRIATE LEGAL PROCEEDINGS ON 
BEHALF OF MYSELF OR CLASSES TO WHICH I BELONG (INCLUDING BUT NOT LIMITED 
TO, STOCKHOLDERS AND/OR EMPLOYEES OF CORPORATIONS UNFAIRLY AND ADVERSELY 
AFFECTED BY THE PROPOSED ACTION. TAXPAYERS AND CITIZENS OF THE UNITED 
STATES OF AMERICA, CONSUMERS OF FOREST PRODUCTS, PROFHSSIONAL FORESTERS, 
ETC.). 

I. All of the concerns over Alternative 9 of the FEMAT report ("the 
President's Plan") expressed irr the September/October 1993 issue of 
Evergreen Magazine are hereby incorporated as part of my comments and 
should be addressed in the DSEIS. 



319 



Interagency SEIS Team Page 2 

II. The DSEIS violates scoping and disclosure requirements required under 
the National Environmental Policy Act (NEPA): 

A. The DSEIS fails to acknowledge and discuss the national and 

international social, economic and environmental consequences of 
permanently eliminating 3.3 billion board feet equivalent of 
solid wood products and associated residues used in pulp and 
paper manufacturing annually. These consequences include: 

a) increased cost or reduced availability of wood products to 
meet hunidn needs. 

b) substitution of non-renewable materials that require 
substantially more fossil fuel energy to manufacture and 
thus contribute more to atmospheric C02 concentrations. 

c) potential harvesting of forests from other regions or 
countries at rates or using methods having more adverse 
environmental consequences than would recent practices 
employed on federal lands in question in the Pacific 
Northwest. 

d) other potential consequences. 

Currently ongoing litigation involves whether the FEMAT report was 
written in violation of federal law by explicitly excluding public 
input and comment. Additionally, the DSEIS represents i significant 
policy deviation from both the "No Action" alternative and the "Final 
Environmental Impact Statement on Management for the Northern Spotted 
Owl in National Forests" (FEIS) (which the OSEIS is supposed to 
Supplement). 

The FEIS was based primarily on providing Critical Habitat for the owl 
as designated by the Fish and Wildlife Service. The FEIS land use 
allocations would be temporary pending recovery of the spotted owl, at 
which time management direction might be modified, for example, to 
allow resumed harvesting as long as sufficient owl habitat was 
maintained. 

By contrast, the DSEIS proposes to establish various "reserves" to 
protect large numbers of relatively minor plant and animal species, 
about which relatively little scientific information exists (including 
the extent of their dependence on late-successional or old growth 
forest conditions). Due to the difficulty cf obtaining such infor- 
mation on these sperips, the land use allocations proposed under the 
DSEIS would have little short-term potential to change. 



320 



Interagency SEIS Team Page 3 

B, The DSEIS also fails to address and balance numerous scientific, 
economic, and social considerations ordered by the President or 
discussed at the Forest Conference in 1992. The plan fails to 
sufficiently address all of the human social and economic factors 
discussed at the conference and it ignores research presented 
indicating the compatibility of owls with certain historical 
forest management/disturbance regimes, including even-aged mana- 
gement, uneven-aged management, and "new forestry" concepts. 

C. The DSEIS, by my calculations, allocates at least 17.0 million 
acres of federal forest land to non-timber designations. This 
constitutes about 32% of the forest land in this region, an 
unprecedented amount of land in a r e gion to be excluded from 
forest management. The plan fails'to disclose the percentage ot 
the forest land excluded from (all but the most limited) timber ~ 
tnanagement in this region and to nutnerically evaluate thp long^ 
term economic costs and impacts. 



D. The DStlS erroneously concludes that there will be little or no 
impact on the region's pulp and paper industry, despite testimony 
to the contrary provided at the Forest Conference and contrary to 
public comments made by the American Pulpwood Association and the 
American Forest and Paper Association. The DSEIS Team should 
conduct surveys, interviews and other investigations to support 
its contention of no impact. It is my contention that the DSEIS 
permanently removes the fiber supplies equivalent of four worfH " 
class pulp and paper mills and that current levels of recycling 
in the region exceed the available supply of potentially recycled 
material , 

III. The DSEIS violates the National Forest Management Act (NFMA) by not 
seeking public input and participation in a significant amendment to 
forest plans (as described for NEPA above) and by failing to address 
multiple use and sustained yield requirements (see also. Appendix A): 

NFMA requires provisions for viability of vertebrate populations only. 
Additional NFMA language provides for management prescriptions that 
" where appropriate and to the extent practicable , will preserve and 
enhance the diversity of plant and animal communities." But there is no 
. scientific basis whatsoever in assuming that the ten alternatives pre- 
sented are the only way to accomplish this direction, especially in 
association with other NFMA directions to sustain multiple use values 
including non-declining outputs of timber products. Examples of alter- 
natives that would better meet aV^ NFMA requirements are provided later 
in my comments. Furthermore, many ecologists believe land preservation 
strategies such as the ten DSEIS alternatives result in less biological 
diversity, not more (see enclosed article, "Biodiversity of Rangelands," 
by Neil £. west and the enclosed September/October 1993 issue of 
Evergreen Magazine, 



321 



Interagency SEIS Team Page 4 

IV. The DSEIS potentially violates the Endangered Species Act (ESA) 
because it does not properly identify or provide for the "ecosystem" 
on which the northern spotted owl depends. The DSEIS proposes to 
create "static state," preserved late-successional or old-growth 
forests throughout the landscape. Considerable research of fire and 
other disturbance history and owl habitat requirements suggest that 
1) such a "static state" is not sustainable, 2) owls live and breed 
in landscapes historically disturbed by either fire, logging, or 
both as long as sufficient nesting and foraging characteristics 
(vegetative structure) is created, and 3) these conditions can pro- 
vide equal or better breeding success than old growth stands (see 
enclosed articles by Everett, et.al. and Irwin, et.al. and 
September/October 1993 issue of Ev ergreen magazine). 

V. Alternatives that should be added to the DSEIS analysis: 

A. Riparian zones, by far, provide the most crucial, productive and 
diverse habitat for practically all species of concern or poten- 
tial concern. They also provide undisturbed connectivity. The 
current DSEIS imposes restrictive land use allocations, prescri- 
bes restrictive guidelines and standards to the remaining 
"matrix," then superimposes "riparian reserves" of varying widths 
subject to "watershed analysis." 

An alternative should be formulated and evaluated where 
Congressional set asides and riparian management areas are the 
only land use allocations made. Management direction for the 
remainder of the landscape would be based on proximity to the 
riparian management areas and ecological significance (especially 
proximity or suitability for threatened, endangered or rare 
species). Riparian management areas should initially be defined 
as 75 feet wide for perennial streams, 150 feet wide for fish- 
bearing streams, and partial retention of varying width for 
intermittent streams. The majority of the area outside the 
riparian management areas should allow at least some form of 
timber harvest and the targeted annual sale volume should be at 
least 792 million cubic feet of softwood (see Appendix A). 
Congress should be asked to mandate that of this annual target, a 
minimum of 2.25 billion board feet of softwood sawtimber 
(Scribner Scale) should be offered for sale. Congress should 
also be asked to mandate that for the first five years, a minimum 
of 3,0 billion board feet be offered, decreasing to 2.25 bbf 
annually thereafter. Rationale for these sale quantities is pro- 
vided in Appendix A of this letter. 

The standards and guidelines imposed under this alternative 
would, in general, be more flexible than those prescribed for 
existing alternaLives In the management matrix. They would 
be the most restrictive in proximity to riparian management 
areas and sensitive species. Development of the standards 
and guidelines should include a broader range of 



322 



Interagency SEIS Team Page 5 

scientists and philosophies than embodied in the existing FEMAT 
report. Based on public input, a new scientific team should be 
created that would include Dr. Chad Oliver of the University of 
Washington, Dr. Larry Irwin of NCASI, and others identified in 
the September/October 1993 issue of Evergreen Magazine 
(enclosed). Composition of the committee and its activities 
should be subject to public revipw and input. 

Impacts of the guidelines and standards would be monitored, eva- 
luated, and modified as needed. Also, individual projects would 
be subject to scientific, adninistrative and limited public review 
prior to implementation. Public review would be limited to mat- 
ters such as impacts on sensitive species or similar impacts. 
This alternative would represent a more balanced approach to 
Ecosystem Management that provides outputs and significant habi- 
tat for humans and other species. 

B. Congressional action would be required under the above alter- 
native to resolve conflicts over intent of NEPA, NFMA, ESA and 
other applicable laws so as to allow for the specified reasonable 
flow of timber products. An alternative such as the one above 
which seeks Congressional authorization through amendments of 
existing laws and any new enabling legislation shoulrt h«» pva- 
luated. The delay required in obtaining Congressional approval 
probably would not be longer than delays currently anticipated in 
providing significant sale volumes under the draft preferred 
alternative. Furthermore, the timber outputs realized through 
this approach would provide a better compromise between histori- 
cal and future harvest levels, better stabilizing the region's 
economy and social needs. 

VI, I am confused by two statements in the DSEIS: 

A. In chapters 3 i 4, page 104, it is stated that there is "little 
risk that the spotted owl population will drop below a viable 
level during the transition period." If this is correct, it only 
adds credence to my contention that the preferred alternative 
(and the FEIS and the Recovery Plan) goes beyond what is 
necessary to provide habitats for the northern spotted owl at the 

'■ expense of economic and social concerns, 

B. On page 107, it is stated that 1980' s harvest levels "averaged 
5.6 BBF" when in fact, they averaged 4.5 BBF based on other 
information in the report. 



323 



Interagency SEIS Team Page 6 

VII. This letter may not represent the full extent of my comments on this 
document because I was not provided with a copy of the complete 
FEMAT report (only an 138-page summary) which I requested. I was 
unaware that scoping and the No Action alternative were established 
in the FEIS and consequently I did not have time to request or 
receive copies, and if I had received copies of any of the aforemen- 
tioned, there probably would not have been sufficient time to ade- 
quately review and provide comment. 

Additionally, the public has never been provided with adequate forest 
statistics specific to the range of the Northern spotted owl which 
would allow proper analysis of the impacts and potential harvests of 
any of the alternatives. These concerns are explained more fully in 
Appendix A of this letter. 

For these reasons I am requesting that either 1) the conment period 
be extended and all commenters (including myself) be mailed copies of 
the aforementioned documents, or 2) that the DSEIS be rewritten to 
include the alternative I have suggested above and distributed along 
with the aforementioned documents for review and comment. 



Yours truly. 



John R. Helms 

54g westlawn Road 

Columbia, SC 29210 

S. C. Registered Forester No. 850 



(Attachment follows:) 



324 



APPENDIX A 

Comments of John R. Helms on DSEIS to FSEIS on 
Northern Spotted Owl 

A. References used in this Appendix: 

1) The DSEIS 

2) "Forest Statistics of the U. S., 1987," USDA Forest Service 

Resource Bulletin PNW-RB-188 (1989). 

3) "An Analysis of the Timber Situation in the United States 

1952-2030," USDA Forest Service Forest Resource Report 
N\Mnber 23 (1982). 

4) "An Anslysis of the Timber Situation in the United States 

1989-2040," USDA Forest Service General Technical Report 
RM-199 (1990). 

5) "An Alternative to the President's Proposal for Managing 

Northwest Federal Forest Lands," Evergreen magazine 
(Sept. /Oct., 1993). Evergreen Foundation, Medford, OR 
(copy enclosed and made a part of my comments), 

6) "Trends In Commercial Timberland Area in the U.S.... 

1952-77 " USDA Forest Service , General Technical 

Report WO-31 ( 18Q1 ) . 

B. Adequacy of Data 

The analysis that follows Involves forest statistics 
primarily for all National Forests in the states of 
Washington, Oregon and California because the reference 
documents cited above do not provide sufficient data 
specifically for the area to which the management action will 
apply (i.e.. National Forest and BLM lands within the range of 
the northern spotted owl (NSO), in portions of these three 
states). TO MY KNOWLEDGE, NO SUCH INFORMATION HAS BEiSN MADE 
AVAILABLE TO THE PUBLIC BEYOND A VERY LIMITED AMOUNT IN THE 
FQIAT REPORT AND THE DSEIS. WHERE APPROPRIATE. AN ATTEMPT HAS 
BEEN MADE TO INCORPORATE THE DSEIS INFORMATION HERE. 

Based on data shown in Table 1, about 64X of the 1980-1989 
National Forest harvest in these three states capie from within 
the range of the NSO. It should be evident from Table 1 that^ 
no attempt was made within the DSEIS to coordinate the timber 
harvest data presented there with any meaningful information 
that Is publicly available outeldft of the DSEIS document. 
If not evident, my analysis (which follows) will make it 
evident. 



325 



Page A- 2 



Table 1. Average 1980-89 harvests from National Forests In 
Washington, Oregon and California (from Table VI-2 of the 
DSEIS, with necessary supplemental data from other soxirces), 

ANNUAL HARVEST 
SOURCE OF HARVEST (million bd.ft., Sorlbner) 

1. National Forests within the 
range of the NSO: 

Washington and Oregon 3,048 

California 661 



Subtotal 3,609 63. 5X 



2. National Forests outside the 
ranee of the NSO: 



Washington and Oregon 1,076 

CJallfornla (Sierra Nevada mtns.)* 1,000 



Subtotal 2,076 36.535 
TOTAL, National Forests 5,685 100. 0« 



3. BLM Owl Forests 

(Oregon and (California) 915 



TOTAL, BLM & Nat. Forests 6,600 

* Estimates for Sierra Nevada mountains based on reports 

from American Forest and Paper Aeen. and American Pulpwood 
Asan. regarding management of California spotted owl. 

Note: BLM Owl Forests added 16. IX to the harvest from National 
Forests. 



78-799 0-94-12 



326 



Page A-3 



The lack of rijflt.a for siifflcient analysis by the public is 
exacerbated by the fact that references 1 through 4 and 6 all 
have slightly different methods of presenting data, especially 
with regard to vol^ume units. The 1982 RPA planning document 
(ref. 3) presents and projects timber volumes in board feet 
(International rule) for sawtimber sized trees and in cubic 
feet for all growing stock (which includes the sawtimber trees 
plus smaller trees 5.0 inches and above d.b.h.). The 1987 
forest inventory document (ref. 2) provides statistics of some 
attributes for both sawtimber (board feet. International) and 
growing stock (cubic feet), but other attributes (for example, 
mortality and growth) are presented in cubic feet only. The 
1990 RPA planning document (ref. 4) provides projections only 
in cubic feet, reflecting a recent change in policy by the 
Forest Service. Terminology and description of regions and 
the types of data presented are not entirely consistent, even 
between these documents. 

To increase the confusion and difficulty, the DSEIS provides 
essentially no data or discussion of hlotorical inventories of 
forest products, growth or mortality. The harvest data it 
presents are in board feet, Scribner rule. Depending on the 
size of tree being considered, Scribner rule contains 84» (for 
a 14-inch dbh tree) to 90% (for a 20- inch dbh tree) to as low 
as 75X (for a 10- inch dbh tree) of the volume based on 
International Rule. 

Another misleading aspect of these data (ref. 2,3,4 & 6) is 
that since 1962, National Forest and other federal lands have 
been permananently withdrawn from commercial timber harvest 
through Wilderness and National Wild & Scenic River desig- 
nations. These lands, along with National Parks and other 
Congroselonal set asldce, are pef erred to in the documents as 
"productive reserved" lands. Unfortunately, the statistics 
and documents do not readily point out that much of the inven- 
tory that appears to have disappeared since 1962 has been in 
fact, removed solely on paper and continues to exist (unless 
it has died) within these (^ngressionally designated areas. 

Despite all of this confusion, I will attempt to define 
what constitutes a eustainable harvcet level based on 
historical data. Quite obviously, both the FEMAT report and 
the DSEIS take a considerably more careless and casual 
approach to justifying the sustalnablllty of ^heir harvest 
levels (from the standpoint of inherent forest productivity) 
than I have taken here . 



327 



Page A-4 



C. Analysis of Resource Trends 



Tables 2, 3, and 4 summarize forest resource growth, 
mortality, harvest and Inventory trends. These data are for 
National Forests in the •bhreo states. Data for BLM lands or 
for the specific range of the NSO are not available in these 
reference documents. 

In 1952, there were 597,126 million (597.1 billion) board 
feet (International rule) of softwood sawtimber (Table 2) and 
100,582 million (100.5 billion) cubic feet of softwood growing 
stock (Tables 3 & 4) in National Forests In the three states. 
Annual harvests were 0,Q% of sawtimber inventory volume (Table 
2) and 0.5% of growing stock volume (Tables 3 & 4). Mortality 
growing stock was 0.6% of inventory volume (Table 3). 

Between 1952 and 1962, there was a small increase In 
softwood growing stock (Tables 3 & 4) and a small decrease in 
sawtimber volume (Table 2). By 1962, the rate of harvest of 
growing stock had increased by 68%, while net annual growth 
(i.e., growth in excess of mortality) increased only 15% 
compared to 1952. By the year 1970, net annual growth had 
shown a dramatic improvement and harvest rates "leveled off" 
(Tables 2, 3, and 4). Growing stock inventory m 1970 was 5% 
less than in 1952; sawtimber inventory was only 0.5% less. 

Thus, inventory did not drop substantially during this 
period, in spite of an apparent shortfall betvreen harvest 
rates and net annual growth. One reason for this is that a 
substantial (unreported) amount of mortality is included in 
the haurvest volumes shown. According to reference 3 
(pp. 443-4 & 448). in 1976 salvaged (i.e. harvested) mortality 
was 163.4 million cubic feet. Since the total harvest that 
year was 1,089 million cubic feet (Table 3), only 926 million 
cubic feet of living timber was harvested, compared to net 
annual growth of 902 million cubic feet. 

Another reason that inventories did not decline 
substantially was that commercial timberland on National 
Forests increased 4.4% over the period 1952-1970 (Table 5). 
This trend reversed itself thereafter due to the Roadless Area 
Reviews (RARE I and RARE ID and eubseauent wilderness set 
asides during the 1970s and 1980s- Through 1986, National 
Forests in the three states had lost 1.5 million acres 
compared with 1952 (Table 5). Perhapo more Importantly, they 
had lost 2.8 million acres since 1962, which is a better 
reference point because it is the peak of commercial 
timberland acreage and immediately precedes the Wilderness Act. 



328 



Page A-5 



Ufllng 1977 average softwood volume per National Forest 
commercial timberland acre (3.837 cubic feet, ref. 3) in the 
three-etate region, the loss of 2.8 million acres equates to 
10,744 million cnbio £ect of softwood growine etoek betna 
"lost" from inventory. No data is available on the actual 
amount removed in this manner. However, the amount removed Is 
material to determining what constitutes a Buotainable harvest 
because between 1962 and 1986, growing stock inventory fell 
24,695 minion cubic feet (Table 4). 

If we assume that 40% of mortality is salvaged (as occurred 
In 1976), then no of 1986, harvesta of live growing stock 
exceeded net growth by only 230 million cubic feet per year. 
At that rate, inventory would have dropped from 95,810 million 
cu. ft. in 1976 to 93,510 million cubic feet in 1986. In 
reality, inventory fell to 78,151 million cubic feet, leaving 
15.359 million fftet being lost to unexplained sources (i.e., 
salvaging less, or more likely. Congressional set aeldes). Even 
if no voltime had been salvaged, the difference between 
harvests and growth (373 million cubic feet per year) would 
have left 92.080 million cubic feet of inventory in 1986 
(Table 4). 

Ecologists such as those interviewed in reference 5 believe 
it is imperative to maintain and enhance \ipon improvements in 
forest health that are evidenced by historical decreases in 
mortality rates. There is strong evidence, including 
historical trends and recent correlation of northern spotted 
owl nesting sites with a forest fire hazard index, to suggest 
that catastrophic fires and mortality of softwood growing 
stock would increase under all alternatives examined in the 
DSEIS. 

My contention is that restoring harvests to pre-1962 levels 
would provide a sustainable timber harvest in addition to 
short-term stabilization and long-term Improvement of both 
spotted owl habitat and old growth ecosystems. Using 
appropriate silviculture, such an alternative could, in fact, 
provide better habitat conditions by reducing risks of fire 
and other catastrophic mortality better than any of the 
altemativeo conaidored in the DSEIS and FEMAT report. 

Due to the data used, my estimate of a sustainable harvest 
must first be based on the entire S-state region. Tbe 
sustainable harvest level would represent an average between 
the 1952 and 1962 harvest levels because after 1962, harvests 
exceeded growth and inventories began to decline. This 
harvest level is 792 million feet (average of 1952 and 1962 
from Table 4) and would treinslate to rnughly the ©QUlvalent of 
5.28 billion board feet. International Rule. For comparison 
to the existing FEMAT alternatives, multiplying by 80% 
converts International rule into 4.22 billion board feet, 
Scribner Rule. 



329 



Paga A-6 



Table 2. Met annual srovtb, inv«ntory and harvests of softwood 
aawtloibar from National Porests In Washington, Oregon and California, 
1952 to 197B, with projections to 2010 (source: referenes 3. p. 192>. 



VolusB in Hilllon Bd.Pt., Intarnational Rule 
1952 1962 1970 1976 1990 2000 2010 



Growth 

Inventory 

HarvBBt 

HarvBst % of 
Invsntory 



2,630 3.239 4.637 4.444 5.204 5.826 6.363 

587,126 595,360 666.120 544.581 466,246 42S.30S 406,946 

3.7B5 6.895 7,655 7.121 7,517 7,948 8.051 



0.6% 



1.2X 



1.4X 



1.3X 



i.ex 



1.9X 



2. ox 



Tabla 3. Net annual growth, Invnttory. harvests and mortality of 
softirood growing stock froa National Forsste In Washington, Oragon and 
California. 1952 to 1976. with ^^Jections to 2O10 (sovarcs: reference 
3, p. 1901. 



1962 



VoluMS in Million Coble Fbet 
1962 1970 1976 1990 2C0O 



2010 



OroNth 




603 




693 




907 


902 1.066 


1.212 


1,340 


Inventory 


100 


,582 102 


.652 100 


.063 


95.610 82.nRf> 


80.427 


78,692 


Harvest 




550 


3 


.034 


1 


.121 


1,089 1.183 


1.276 


1.324 


Harvest K of 
Inventory 




0.5X 




l.OX 




I.IX 


i.lX 1.4X 


i.ex 


1-7X 


Mortality 




eo7 




615 




471 


408 NA 


NA 


HA 


Mortality X o< 
Inventory 




o.ex 




O.ex 




0.5X 


0.4X 







330 



Pago A- 7 

Table 4. Not anaual srowt^h. Inventory, and harvoBte of softwood 
growins stook frost Hatlonal Forests In Uashlngton, Oregon and 
California. 1952 to 1938, with projections to 2010 (source: rsferenco 
4). 

Volume In Million Cublo Feet 





1952 


1962 


1970 


1876 


1986 


2000 


2010 


QroMth 


603 


693 


907 


902 


1.011 


MA 


HA 


Inventory 


100.582 


102 ,852 


100.083 


95,610 


78,151 


89,667 


66,649 


Harvest 


550 


1.034 


1,121 


1.0B9 


1.364 


1,174 


1,202 


Harvest X of 
Inventory 


O.BX 


l.OX 


I.IX 


I.IX 


l.BX 


1.7X 


i.ex 


Mortality 


NA 


NA 


NA 


NA 


358 


NA 


HA 


Mortality X of 
Inventory 










o.sx 







Table 5. Araa oC conmarcial forest land on National Forests and 
all federal ownership in Washington , Oregon and California, 
195Z to 1986, with projections to 2010 Csources: National Forests, 
ref. 6, all federal ref. 3, 1966 data, ref. 2). 

Unreserved Commercial Tlnberland (thousand acres) 
igE2 1962 1870 1976 1966 2000 2010 

National Forest 26,263 26.577 26,380 24,968 23.763 21,494 21.343 
All Federal 26.266 29,369 29,090 27,633 26,539 HA NA 

Note: In 1976, there were o total of 3.8 million productive 
reserved acres (all owners), of which 2.3 million were on 
National Foreete (ref. 3*6). By 1986. there wore a total of 
7.6 million productive reserved acres (all ownerB)(no data 
available on aaiount on National Forests, but figures above 
suggest another 1.2 million acres were added, bringing total 
to 3.5 million acres on National Forests). In my snalysls, I 
aseumed that 2.B nillion acres were transferred to productive 
reserved etatus on National Forests between 1962 and 1986. 



331 



Page A-8 



Since only 63.5% of the harvest in thia region comes from 
the range of the Northern Spotted Owl (Table 1), the harvest 
to be supplied from National Forests would be only 2.68 
billion board feet, Soribner Rule. BLM lands, whleh 
historically supplied 16.135 of the region's harvests (Table 1) 
would provide another 0.68 billion board feet, Soribner Rule. 
This makes the total sustainable harvest level from within the 
NSO'b range equal to 3.36 billion board feet annually. 

In addition to the FEMAT report and DSEIS. similar plane 
aimed at improving fish stocks (east side forests) and 
conserving California spotted owie (Sierra Nevada mountains) 
threaten to reduce the harvests from federal lands in these 
three states far below the sustainable levels I have 
illustrated. Including Option 9, the level of federal 
harvests would be only about 2.2 billion board feet compared 
to the 4.90 billion board feet f Including BLM) I have 
suggested here. Clearly, the DSEIS fails to examine the wide 
range of social, economic and environmental impacts from this 
degree of shortfall from what has traditionally proven to be 
sustainable. 

On page 4 of my comments on the DSEIS, I recommend an 
alternative in which there are Congressional ly mandated 
minimum annual harvest levels of sswtlmber lovrer than the 
volxomee calculated above. There are several reasons. One Is 
that according to scientists (reference 5), many of the trees 
that need to be removed fur ecological reasonEi might b© 
smaller than sawtimber size or of too poor quality for solid 
wood products. Thus, they would contribute to the sustainable 
harvest of 792 million cubic feet, but not to the maximum 
theoretically sustainable sawtimber harvest. Another reason 
io that 2.26 billion board feet (Srribner rule) is about half 
the traditional harvest level. This level is enough to 
sustain existing mills on at least one shift, while looking 
for alternative sources of supply, developing methods to 
process smaller or lower value logs, or developing value added 
products. I am proposing 3 billion board feet as a minimum in 
the first five years to make up for delays and shortages 
created as a result of ongoing legal gridlock, and to further 
smooth the transition. 

(continued on following page) 



332 



Page A-9 



My proposal is a plausible approach that attempts to 
minimize economic and social impacts, which, is what President 
Clinton ordered at the Forest Conference. The FEMAT report's 
authors failed in their mission and the DSEIS failed in its 
scope to analyse such an alternative. The 792 million cubic 
feet harvest level reflects a time (30 to 40 years ago) when 
few of today's concerns over environmental quality existed. If 
we assume that our future efforts will be directed toward 
enhancing forest health and the production of large trees 
across the majority of the National Forest landscape, there is 
reason to believe that recent growth rates of 1,100 million 
cubic feet per year, and possibly higher as has been projected 
(Table 3) can be sustained, at least for several decades. 
With an annual harvest of only 792 million cubic feet (as much 
as 150 million cubic feet being salvaged material), inventory 
and size of trees on the region's National Forests will 
continue to Increase and In 20 to 30 years could be restored 
to 1952 inventory levels (assuming volumes previously removed 
as Congressional set asides are accounted for) . 



END OF APPENDIX A 



333 



Statement of the Honorable Wally Merger 

House Agriculture 

Subcommittee on Specialty Crops and Natural Resources 

Hearing on Option 9 

November 18, 1993 

Mr. Chairman, I want to commend you for once again holding a 
hearing to review President Clinton's Forestry Proposal, better 
known as Option 9. Your continued interest in resolving this 
controversy is of vital importance to our communities in northern 
California. 

As many of you know, 80 percent of the communities in 
California's 2nd Congressional District, which I have the 
privilege of representing, depend on the harvesting of timber for 
their economic survival. Already, 70 to 80 percent of our 
forests in California are off limits to timber harvesting. This 
has resulted in unemployment rates that are double the national 
average in my district. Several of my counties have even 
experienced unemployment rates at or around 20 percent. 

Mr. Chairman, the substantial loss of jobs due to this 
controversy has caused tremendous strains on family life in our 
area. Alcoholism as well as spousal and child abuse have 
increased dramatically in recent years. Many of our children 
have been forced to deal with the separation of one if not both 
of their parents as they leave the area in search of a brighter 
future . 



334 



with this severe decline in timber harvests, our local area 
services such as schools and roads have suffered due to the fact 
that 25 percent of the receipts that come from the sale of timber 
are used to fund these essential services. With less timber to 
harvest, our local services have seen a profound shortfall in 
funds . 

As hard as it is to believe. President Clinton's forest 
proposal which was originally touted "to offer new economic 
opportunities and ensure the region's long term economic health," 
actually makes our current situation in northern California 
worse. By locking up 70 percent of the remaining national 
forests in our area. Option 9 will cause thousands of additional 
job losses and even less funding for local services. 
Restrictions in future harvests will undoubtedly drive up lumber 
prices. This will ultimately increase the cost of buying a home 
and hinder economic growth throughout the country. 

The President's plan also fails to address the unique 
biological characteristics of the forests in northern California. 
The most recent science clearly indicates that drastic reductions 
in timber harvests are not necessary to protect spotted owls or 
old growth forests. We have documented as many as 8,500 northern 
spotted owls living in California, more than the 8,000 total the 
Fish and Wildlife Service originally estimated for the entire 
Pacific Northwest region when it first listed this species of owl 
under the Endangered Species Act. Just last month, the 
California Forestry Association formally petitioned the 



335 



3 

government to de-list the owl in California. I would also like 
to call your attention to a September 17 NBC Nightly News story 
highlighting the fact that the owl is flourishing in my state. 
For those of you wishing to view this report, my office can 
provide you with tapes or transcripts. 

Perhaps most importantly, our forests in California have 
been historically more vulnerable to catastrophic fires, insects 
and diseases because of the state's warm, dry climate. The fires 
which have devastated southern California this fall are no 
anomaly. In 1987, for example, my area of northern California 
lost over 400,000 acres of pristine forest land due to similar 
fires. Clearly, our forests throughout California must be 
managed to prevent similar disasters from recurring. However, by 
severely limiting management activities through the 
implementation of a reserve system. Option 9 fails miserably in 
this area and will only put more human lives at risk and the 
health of our forests in further danger. 

Another area that Option 9 fails to address is the effect it 
will have on forests in other parts of the world. By ignoring 
the substitution of timber from other regions of the globe and 
the substitution of other materials that are not renewable. 
Option 9 is likely to cause environmental damage on biodiversity 
around the world. We must not forget that the need for wood 
products will not subside even though under this plan, we are 
shutting down an area where they are produced in large numbers . 
The only difference will be that by unnecessarily shutting down 



336 



4 

the federal lands in northern California, Oregon, and Washington, 
we will be forcing other regions of the world to unnecessarily 
increase the burden placing many of them in great danger. 

The people of northern California are deeply disappointed 
that the President's plan is not balanced and does not address 
the unique characteristics of California's forests. They are not 
willing to accept temporary government make-work jobs in exchange 
for permanent family- wage jobs provided by the timber industry- 
The Administration should objectively review the management of 
California's unique forests and look to scientific evidence to 
determine the best management practices. Efforts are already 
underway to develop an eco- system management approach which 
should be reviewed. In the interim. Congress should move 
immediately to pass legislation specific to California which 
allows the state to harvest sufficient timber to sustain our 
communities and provide for healthy forests. 

Again, I want to thank you for allowing me this opportunity 
to express the concerns of northern Californians on how Option 9 
will impact our lives. 



337 




25 October 1993 
R.Jacobs, SEIS Team Leader 
PO Box 3623 
Portland, OR 97208 

WESTTRN Dear SEIS Team: 

North 

Carolina On behalf of the Westem North Carolina Alliance, an 800-member grassroots citizens' 

ALLIANCE group based in Asheville NC, I would like to offer the following comments on the 

MAIN OFRCE Supplemental Environmental Impact Statement (SEIS) and President Clinton's Preferred 

70 woodtin Place, » 03 Alternative "Option 9" for "spotted owl forests" of the Pacific Nonhwest. 

Asheville. NC 28801 "^ 

704-258-8737 

704-258-9141 FAX WNCA's members include many expert biologists, botanists, ecologists, foresters and 

fishery scientists, as well as "everyday' people, hunters, and fishers, all of whom feel we 
WESTERN OFFICE have much at stake in the public lands and forests of the NW. Our organization has had 
11 Clock Tower Square deep and ongoing involvement in the forest planning and on-the-ground implementation 
704"524'3899^^"''' °^ ^^^ Nantahala-Pisgah National Forest LRMP, tlms-we-afc aware of many of the 

systemic problems (forest stand condition data that are poor or tacking, lack of biological 
STEERING coMMiTTE^'*'*""'""' Spatial shottcomings of FORPLAN, even-aged assumptions behind Plans) 

C. J. Wilson 
Chair 



Jim Barnes 
1st Vice-Chair 

Scot Sanderson 
2nd Vice</iair 

Rusty Sivils 
Secretary 

Sarah Oram 
Treasurer 

Monte Cunningham 
Elmer Hall 
Gil Johnson 
Dan King 
John McBnde 
Rob Messick 
Louise O'Connor 
Speed Rogers 
Chip Smith 
Cynthia Strain 
Chns Walters 

STAFF 

K/lelissa Lane 
Coordinator 

Mary Sauls Kelly, PhD 
£cofog«r & Organtzer 

Grady Speigel 
Community Organizer 

Bess Ledford 
Community Organizer 

Ron Lambe 
Operations Manager 



which plague ALL forest plans. As in the forests of the N'W, our 1986 Forest Plan for 
Nantahala-Pisgah was subject to political interference (by Asst Sec. John Crowell and 
cronies during the Reagan era), causing the Allowable Sale Quantity (ASQ) to be 
artificially inflated, too many steep and fragile lands to be included in the timber base, 
and overly aggressive roadbuilding plans. As in the Northwest, it's now become very 
clear that the "promises" made by the Forest Service regarding annual harvest levels, 
"Finding of No Significant Impact" etc. were unrealistic and simply could not be kept. 
Here, we are fortunate that the people arose in time to reject the 1986 LRMP. 
successfully appealed it, and have now won to chance to reveal and correct the 
shoncomings through a detailed revision and amendment of the original Plan. 

But in the National Forests and BLM lands of the Northwest, these same problems and 
worse were magnified across a huge landscape, political influence kept the cut levels 
high, and now the continued viability of entire ecosystems and hundreds of species is 
seriously at risk. The many human communities that depended on USES "promises" are 
suffering, needlessly. All of this should have been entirely predictable when the USPS 
(along with private timber companies) made a deliberate choice two decades ago to depart 
from sustained yield and began to implement a policy to replace complex old growth 
forests with "faster growing tree farms." across an entire landscape in 3 states! This was 
a crisis that could and should, have been avoided. Now the law (and Judge Dwyer) say 
it's time for strong corrective measures, not continued political compromise. 

Overall, WNCA's members are of the opinion that Option 9 is NOT the "scientifically 
credible, legally defensible" plan that was promised by the President at the Forest Summit 
last April. Instead, we are concerned that Option 9 is the result of unfonunate political 
interference and it will provide inadequate protection for anadromous fish and many other 
threatened and sensitive species which depend on the few remaining intact old growth 
forest stands, riparian zones and watersheds. The SEIS team failed to consider a 



I 



^-roM Tn AacyOM Pmttn 



'People working together to conserve our natural heritage. ' 



338 



reasonable alternative which would have protected ALL old-growth and roadless areas, which we view 
as key to protecting at-risk fisheries and late-successional species. Of all the alternatives considered, 
we prefer Option 1, as it provides the greatest hope for probable viability for a wide suite of species. 
Conversely, Option 9 poses unacceptable levels of risk and low chances for survival for important 
species such as the silver-haired bat, land snails, rainbow trout, salmon and steelhead. 

Here are some specific comments: 

We applaud the multi-species, watershed-level approach taken in the document. It's about time! 

Option 9 does not protect the few remaining classic old-growth forests! The 950,200 acres of classic 
old growth open for cutting in Option 9 should be provided further protection in special reserves to 
provide a VERY HIGH liklihood that all forest species will survive. 

All roadless areas (including the North and South Kalmiposis, Soda Mtn Wilderness Area, and others) 
should be placed off-limits to logging and added to the reserve system. 

Because so many fish and riparian-dependent species have ALREADY been placed at nsk, all rivers 
and streams, including small and intermittent streams, should be granted full 100-ft buffers, as 
recommended by the Scientific Analysis Team Report of March 1993. 

Stop all Clearcutting and Even-aged management. Even with "15% green" retention, such cuts would 
be functionally too similar to the detrimental ecological and visual effects of clearcutting. It makes a 
mockery of the Forest Service's stated goal of "ecosystem management." 

Option 9 ignores the ISC's "50-11-40" rule within the commercial logging zones, yet another instance 
where careful science has been politically compromised to meet a pre-specified cut level. The 50- 
11-40 rule must be restored to protect landscape connectivity and dispersal routes for spotted owls and 
other species. 

BLM lands must receive immediate full protection, especially from clearcutting. 

Forest-wide inventories of sensitive species must be completed in all areas, and until they are 
complete, older stands ever^vhere should be granted full protection. 

Tne assessment of Option 9's (and other alternatives'!) effects on the environment, species survival etc., 
are premised on levels of monitoring, inventory and on-the-ground mitigation programs which are 
UNLIKELY to occur given reasonably forseeable budget and staffing scenarios from the USPS and 
Congress. This is another reason why Option 9 is unrealistic, dangerous, and poses^ unacceptable and 
undisclosed risks to the envirormient and the public interest. The final alternative which is adopted, 
panicularly its logging levels, MUST be revised to be more realistic and conservative. 

Thank you for considering our comments, and please protect the forests. ..NOW! 

Sincerely, 

Mary Sauls Kelly, PH6( Ecologist^ 




339 



^ 



WWF 

25 October 1993 



Robert T. Jacobs - Team Leader 

Interagency SEIS Team 

US Bank Tower Building 

111 Southwest 5th St. Room 1440 

Portland, Oregon 97204 

Subject: World Wildlife Fund's Comments on the DSEIS and FEMAT 
Dear Mr . Jacobs : 

On behalf of the 1.25 million members of World Wildlife Fund 
(WWF) in the United States, we submit the following comments on 

the Draft Supplemental Environmental Impact Statement on 
"Management of Habitat for Late-Successional and Old-Growth 

Forest Related Species Within the Range of the Northern Spotted 

Owl" (DSEIS) and "Forest Ecosystem Management: An Ecological, 

Economic, and Social Assessment" (FEMAT) . 

WWF is encouraged by the Administration's proposed shift in 
forest policy from decades of mismanagement of our public forests 
toward a broader based ecosystems management approach. We are 
also encouraged by President Clinton's desire to adopt a forest 
plan that is "scientifically sound, ecologically credible, and 
legally responsible" and "that meets the requirements of the 
applicable laws and regulations". We believe, however, that 
Option 9, the Administration's preferred alternative, requires 
substantial modification before it is capable of meeting the 
President's mandate and complying with applicable environmental 
statutes . 

To strengthen the scientific and legal credibility of the 
preferred alternative, WWF strongly recommends that the FEMAT 
scientific team be reconvened to: 

(1) provide a scientifically-based spatial analysis (e.g., 
GAP analysis) of reserves and harvest areas that is 
designed to minimize fragmentation of remaining low 
elevation and contiguous late-successional forests and 
to maximize connectivity between reserves and . 
wilderness areas; 

World WUdlife Fund 

1250Twenty.FourhSi,N\X' Washington. DC 20037- 1 175 USA 
Tel (202) 293-4800 Telex; M505 FANDA FAX; (202)293-9211 

Incorporanng The Comenaacn Foundanon Affiliated with Wurld Wide Fumi for Nanirc 



340 



(2) use the spatial analysis to ensure protection of 
threatened ecosystems including all remaining low 
elevation and contiguous late-successional forests and 
species rich areas in the Klamath-Siskiyou region, 
Oregon Coast, Shasta-Trinity, and Siskiyou Mountain 
regions; 

(3) recalculate the annual allowable cut after such 
areas have been removed from the timber base; 

(4) develop more appropriate standards and guidelines 

to ensure that logging practices such as "high grading" 
do not result in further ecosystem degradation; 

(5) conduct additional studies to determine salvage and 
thinning impacts in late-successional forests and the 
effectiveness of riparian buffers in maintaining viable 
populations of all riparian species; 

(6) extend riparian reserves to at least Reserve 1 buffer 
widths until the results of monitoring studies are 
available; 

(7) provide scientifically reliable nest site buffers and 
ecosystems management recommendations to ensure 
population viability of the northern goshawk and 
marbled murrelet; 

(8) develop a more reliable strategy for obtaining funds to 
accomplish restoration targets and more detailed 
standards and guidelines to accomplish monitoring 
goals; 

(9) reduce the number and size of Adaptive Management Areas 
and include sustainable extraction of non-timber forest 
products as an alternative to timber harvest; and 

(10) pursue other revenue sources to make up for large-scale 
reductions in timber receipts including, increasing 
user fees on extraction operations and recreation 
activities, phasing out below-cost-timber sales, and 
removing tax incentives for log exports to 
facilitate the transition of timber dependent 
communities to more sustainable and diversified 
economies. 

Each of the above concerns is discussed in detail as follows: 
General Comments 

The DSEIS and FEMAT provide ambiguous and unclear estimates 
(e.g., contrast Administrative Withdrawn Areas under Option 9 in 



341 



the DSEIS Table 3&4-4 vs FEMAT Table IV-9) of the amount and 
distribution of late-successional forest subject to timber 
harvest under each alternative and management category. Although 
it is not clearly stated in either document, we assume that 
approximately 22% of the remaining late-successional forests 
would be subject to additional timber harvest under Option 9 

(Matrix plus Adaptive Management Area) . Both documents, however, 
fail to provide sufficient information on the amount of 
unprotected late-successional forests within each classification 

(LS/OGl, LS/0G2, LS/0G3) and management category (reserves. 
Matrix, etc) . Therefore, it is impossible for us to determine 
whether the preferred alternative provides adequate protection 
for the most ecologically important (i.e., low elevation, 
coastal, and contiguous LS/OGl) late-successional forests. These 
biologically rich areas represent the last remaining habitat for 
many threatened fish and wildlife populations and are the most 
threatened ecosystems within the range of the northern spotted 
owl. The DSEIS needs to provide a spatial analysis of the 
location and amount of late-successional forests within each 
management category to ensure that disproportionate amounts of 
these ecologically important late-successional forests are not 
included within the Matrix and Adaptive Management Areas. 

The remaining patches of late-successional forests protected 
under Option 9 are inadequate in number, size, and distribution 
to support the many species that are strongly dependent on late- 
successional forests. Since only 10-15% of late-successional 
forests remain in this region, additional cutting in this 
ecosystem would drop existing late-successional forest cover 
further below critical thresholds for maintaining vital ecosystem 
functions and fish and wildlife populations. Option 9 justifies 
further cutting in late-successional forests by assuming that the 
structural characteristics that define these forests can be 
restored over time using appropriate silviculture practices. As 
indicated in FEMAT (see Tables IV- 12, IV- 13) , however, some 
ecosystems, particularly those in the dry provinces, are already 
so poorly degraded that even with full protection and 
restoration, significant recovery (i.e., outcome probabilities > 
80%) will not be possible within the next century. Moreover, 
late-successional forests have been eliminated over such wide 
areas that source populations of late-successional species may no 
longer be available to colonize restoration areas. The truly 
unique characteristics of late-successional communities have 
taken thousands of years to evolve, and, once gone, cannot be 
restored through "management". 

Given the uncertainties in modeling long-term impacts of timber 
harvest and recovery rates for degraded ecosystems, and the lack 
of examples where managed forests have developed late- 
successional characteristics over time, it is absolutely crucial 
that the preferred alternative protect all remaining intact and 
low elevation late-successional forests from further degradation. 



/ 342 



WWF therefore recommends that the Administration's preferred ;':^ 
alternative include a network of core reserves containing 
contiguous {> 100 ac) and low elevation (0 to 2,000 ft) late- 
successional forests within which timber harvest would be 
permanently prohibited. These core reserves would function as 
baseline areas to evaluate the effectiveness of restoration 
efforts in managed areas and to refine model assumptions used to 
estimate species recovery rates. The addition of contiguous and 
low elevation late-successional reserves to each of the 
management categories in Option 9 would increase the likelihood 
of maintaining vital ecosystem processes and functions (see also 
DSEIS 11-49) , and would strengthen the credibility of this option 
so that it is more consistent with the requirements of the 
environmental statutes (i.e.. National Forest Management Act, 
Endangered Species Act) . 

WWF is also concerned that Option 9 is based on a poorly-defined 
process used to designate the location and amount of late- 
successional forests within the various management categories, 
and, as such, we are unconvinced that the preferred alternative 
will result in a significant improvement from the past inadequate 
forest policy. Our concerns are outlined in greater detail for 
each of the management categories included in Option 9 as 
follows . 

Administratively Withdrawn Areas (AWAs) 

AWAs identified in all options include important recreation 
areas, viewsheds, and late-successional forests. These areas have 
been only temporarily withdrawn as identified in regional Forest 
plans, and may thus be subject to future cutting in response to 
changes in the nation's timber supply on both public and private 
lands (see discussion of nonfederal lands below) . We recommend 
that the Administration identify biologically significant AWAs 
containing late-successional and low-elevation forests and seek 
Congressional approval to permanently withdraw these areas from 
the timber base. This should be done for all options. 

Late-Successional Reserves (LSRs) . 

The proportion of late-successional forests contained within LSRs 
ranges from 42% to 53% for all alternatives but includes only 42% 
for Option 9 (DSEIS Table 3&4-4) . As such, LSRs under all 
alternatives, and especially Option 9, provide little protection 
for the remaining late-successional forests. The spatial location 
of LSRs depicted in the DSEIS maps for Option 9 indicate that 
several of these areas (e.g., dry provinces, BLM lands) were 
selected without regard for connectivity between reserves, intact 
watersheds, and wilderness areas. A more detailed spatial 
analysis is needed to minimize isolation of the reserves and to 
ensure appropriate connectivity at regional and landscape levels 
(see also our discussion of Protected Areas Network below) . Even 



343 



though the FEMAT study was based on probability outcomes that 
consider ecosystem connectivity, the DSEIS does not specify the 
process used to determine the selection, placement, and 
configuration of LSRs . Therefore, it is impossible for us to 
determine whether LSRs provide adequate protection for the most 
biologically significant areas (e.g., low elevation, contiguous 
late-successional forests; areas of high endemism; etc) . WWF 
recommends that an independent panel of landscape ecologists be 
assembled to ensure that LSRs are well distributed and adequately 
connected to each other and to late-successional forests within 
all management categories. 

WWF agrees with the Administration's intent to manage LSRs so 
that over time more of the land base is represented by late- 
successional forests. We also agree with the use of silvicultural 
techniques to accelerate the development of late-successional 
characteristics in forest plantations within LSRs, however, we 
see no scientific justification for thinning in "naturally" 
regenerating stands that are characterized by late-successional 
structural components. Our experience indicates that naturally 
regenerating forests (i.e., stands regenerating following low to 
moderate burns) often retain many of the structural 
characteristics of late-successional forests and thus may not 
require thinning to accelerate the development of these important 
characteristics. Therefore, we recommend that thinning in 
naturally regenerating stands be confined to a controlled 
experiment to ensure that such activities will not interfere with 
the inherent biodiversity or structure of these stands. Such 
experiments should be carried out under the careful auspices of a 
team of interagency scientists. Moreover, no new roads should be 
built in any inventoried roadless areas to accomplish thinning 
objectives in any stand, regardless of its origin. 

WWF is opposed to salvage logging in LSRs until research shows 
that this activity is comparable with maintenance of ecosystems 
functions and does not jeopardize late-successional species 
dependent on dead wood. The Option 9 management prescriptions for 
salvage of standing dead trees {i.e., snags) and downed logs 
(i.e., woody debris) within LSRs are based on unproven 
assumptions regarding impacts to late-successional species 
dependent on these important ecological characteristics. The 
discussion of salvage impacts in particular focuses primarily on 
larger vertebrates and overlooks the impacts on more sensitive 
invertebrates, herpetofauna, and fungi, and the important 
ecosystem functions such as decomposition and nutrient cycling 
that are performed by these organisms. Loss of coarse woody 
debris reduces nutrient availability, habitat complexity, and 
microclimatic features that these ecologically significant 
species depend on. 

While we agree with the FEMAT (11-17) that no consensus exists 
within the scientific community regarding salvage impacts, the 



344 



absence of consensus reflects the need for additional scientific 
research and should not be viewed as justification for proceeding 
with salvage operations even if such operations are carefully 
scrutinized by interagency teams (FEMAT 11-17) . The FEMAT itself 
concludes that "experience with interagency teams on the review 
of salvage operations has revealed that most situations are not 
beneficial for maintaining habitat conditions over time for the 
owl" (11-17) . It is further stated, however, that "the 
interagency team did not thinlc that at least in some cases 
salvage would be detrimental to achieving maintenance of habitat 
conditions for the owl over the long term" . This apparent 
contradiction underscores the need to conduct a detailed 
scientific analysis of the effects of salvage operations on the 
inherent structure of late-successional forests and species 
dependent on snags and woody debris before proceeding with such 
operations. WWF recommends conducting an experiment to determine 
whether salvage operations are beneficial or neutral to the 
development or retention of late-successional characteristics and 
their associated species. Only after it has been established that 
such activities are not detrimental to all late-successional 
species and the structural integrity of these forests should 
salvage logging be permitted within LSRs . In addition, we 
strongly recommend that no new roads be built in any inventoried 
roadless areas to accomplish salvage objectives. 

Managed Late-Successional Areas (MLSAs) 

The FEMAT report indicates that only a small portion of the total 
area will be included within MLSAs under Option 9 (p. 11-11) . 
While the area included in MLSAs may be small relative to other 
management categories, it does include approximately 1.5 million 
acres (DSEIS Table S-1) . It is unclear, however, whether 
management objectives in this category differ from Adaptive 
Management Areas. In addition, as for all management categories, 
the specific amount and distribution of late-successional forests 
subject to harvest is not specified (see FEMAT Table IV-9) . 
Without a more accountable -process for selecting areas as MLSAs, 
it is impossible for us to determine whether ecologically 
sensitive and remaining low elevation and contiguous late- 
successional forests will be subject to additional degradation. 
Furthermore, standards and guidelines for this category do not 
ensure that the practice of "high grading" and forest 
fragmentation will be discontinued in remaining late-successional 
forests in this category. 

Adaptive Management Areas (AMAs) 

Option 9 identifies 10 AMAs that were strategically positioned 
near timber -dependent communities most significantly impacted by 
reductions in the supply of timber on public lands. These 
management areas would be subject to extreme pressure from 
economic and timber interests, even if the intent is to manage 



345 



them using ecosystems management approaches as defined by- 
regulatory agencies, interagency teams, and nongovernmental 
organizations (FEMAT Appendix B-59, 60). The AMAs, however, lack 
standards and guidelines on how research objectives and harvest 
levels will be determined and what processes will be used to 
prevent further degradation of existing late-successional forests 
in these areas. As such, WWF recommends that AMAs be eliminated 
as an option for ecosystems management. If, however, AMAs are 
included in the preferred alternative we recommend that, at the 
very least, the following areas be eliminated: (1) Applegate in 
Oregon, (2) Goosenest in California, (3) Mayfork in California, 
(4) Northern Coast Range in Oregon, and (5) Olympic Peninsula in 
Washington. These areas contain high levels of species endemism 
and biological diversity and have already been subject to 
widespread cutting and fragmentation. The remaining AMAs should 
be used only to develop appropriate standards and guidelines to 
ensure that harvest prescriptions will not target important late- 
successional features (i.e., large trees, snags) and existing low 
elevation and contiguous late-successional forests. 

WWF also recommends that the objectives of any adaptive 
management program include sustainable extraction of non-timber 
forest products as an alternative to timber harvest. Non-timber 
forest products are currently being extracted profitably from 
public lands (see FEMAT 11-51) , particularly along the coast 
where mushrooms have been commercially harvested. Therefore, we 
strongly recommend that a team of natural resource economists 
evaluate the potential for including sustainable extraction of 
non-timber products in any adaptive management program. 

Riparian Reserves 

Option 9 identifies a strategy for protecting key and 
intermittent streams that is based on varying levels of 
streamside protection. Although we agree with the intent to 
provide buffers within which logging and road building are 
prohibited, the proposed buffer widths were arbitrarily 
determined and lack supporting documentation from the scientific 
literature. As such, up to 50% of 16 herpetofauna (DSEIS 2-54) 
and 20% of 100 mollusc species (DSEIS 2-53) would have 
substantially reduced distributions or would face extirpation. 
These risks are inconsistent with the National Forest Management 
Act (1976) and the U.S District Court ruling prohibiting the 
Forest Service from adopting a plan that they know or believe 
will probably cause the extirpation of other native vertebrate 
species in the planning area (see DSEIS 3&4-102) . 

FEMAT (V-11) itself acknowledges that the process of population 
declines of various herpetofauna is already underway and that 
riparian reserves based on 1/2 tree height (i.e., 50 ft) widths 
may not be sufficient to maintain the cool, moist conditions 
associated with microclimates that riparian species require. The 



346 



FEMAT team based these recommendations on presumed distances over 
which edge-related effects influenced streamside microclimates. 
Edge-effect distances, however, were derived primarily from a 
single study of vegetation responses to edge environments in 
forest patches (Chen et al . 1992, Ecol . Applications Vol 2:387- 
396) and, as such, may not represent impacts to streamside 
herpetofauna and invertebrate communities. Because of the linear 
nature of streamside areas, they are extremely vulnerable to edge 
related changes in microclimate from timber harvest in adjacent 
uplands. These effects extend well beyond those projected by the 
FEh4AT team. In addition, there are many examples of riparian 
species that occur at upslope distances much greater than 50 ft 
from seeps and intermittent streams. Species are suppressed or 
lost up to 600 ft from forest edges because of changes in 
temperature, moisture, and biotic interactions at the forest 
edge. Many species of invertebrates, plants, fungi, and 
herpetofauna that require cool, moist conditions may therefore be 
eliminated under the current buffer width guidelines and this is 
reflective of the low survival probabilities estimated for these 
taxa (DSEIS 2-53 and 54). Moreover, because blowdown risks extend 
to at least two tree-heights from forest edges, we recommend a 
minimum of a 600 ft wide buffer to compensate for tree loss along 
forest edges and to provide a narrow 300 ft wide strip of 
suitable microclimate and interior forest conditions. This same 
recommendation would apply to the 100 to 300 ft buffer widths 
proposed under Option 9 for other watershed categories as well. 

The riparian reserve strategy developed for Option 9 also fails 
to identify a means for defining key watersheds for riparian 
species other than fish. Instead it recommends monitoring 
riparian species to determine their distribution within riparian 
reserves. Both the DSEIS and FEMAT lack appropriate standards and 
guidelines for monitoring riparian associates other than fish, 
and a process by which the results of such studies can be used to 
adjust buffer width recommendations (see also our discussion of 
mitigation and monitoring below) . 

To address these deficiencies, WWF recommends the following 
process be used in all streamside reserves prior to timber 
harvest: (1) conduct full scale surveys to determine the 
distribution of sensitive herpetofauna and streamside 
invertebrates in relation to upslope distances from streams using 
established survey protocols, (2) evaluate all streamside buffer 
widths based on distribution patterns of riparian associates in 
relation to upslope distances from streams and known patterns of 
edge effects and blowdown risks, (3) develop riparian reserves 
for all sensitive herpetofauna and streamside invertebrates 
identified in Table IV-25 of FEMAT, and (4) implement protective 
streamside buffers around intermittent streams and riparian 
reserves based on monitoring results. Alternatively, buffer 
widths for intermittent streams could be increased to Riparian 
Reserve 1 so that they are consistent with the recommended 



347 



mitigation for timber impacts along intermittent streams (DSEIS 
3&4-100, FEMAT IV-149) . Riparian Reserve 1 guidelines should be 
applied at least until further information is available on the 
effectiveness of buffer widths and the distribution of sensitive 
herpetofauna and streamside invertebrates. Moreover, since most 
streamside areas are currently denuded, projected buffers should 
not be included in calculations of late-successional totals for 
several decades until restoration targets have been met. 

Matrix 

The majority of timber harvested under all options will come from 
the Matrix within which environmental restrictions will be 
substantially relaxed relative to other management categories. As 
such, timber harvest within the Matrix will result in further 
degradation and fragmentation of remaining late-successional 
areas. As for all other management categories, WWF strongly 
recommends no further degradation of low elevation and contiguous 
late-successional forests. In addition, we recommend extending 
the rotation age within the Matrix to at least 200 years to allow 
sufficient recovery of degraded ecosystems. 

Option 9 also fails to examine the impacts of intensive timber 
harvest within the Matrix on the surrounding reserves. In a 
September article published in Ecological Applications, Dr. J. 
Franklin, a member of the FEMAT team, indicated that the quality 
of the Matrix was of utmost importance in buffering reserves. Dr. 
Franklin indicated that reserves which are embedded in a Matrix 
that is highly dissimilar in forest structure from the reserves 
will require a much larger protected area to achieve the same 
level of protection. Thus, a protected patch of late-successional 
forest will need to be much larger to provide an unmodified 
interior environment if it is located within a clearcut landscape 
than if it were surrounded primarily by partially cut or more 
similar forest age classes. The proposed standards and guidelines 
for retention trees in the Matrix would result in precisely this 
situation: patches of late-successional forests in a "sea" of 
intensively managed areas. This would be the case for at least 
the next 100 years at which time some of the surrounding area 
will revert to older and more similar serai stages. As such, 
reserves will need to be much larger than proposed under Option 9 
to compensate for intensive timber management in the Matrix and 
the relatively low percentages (i.e., 42%) of late-successional 
forests within LSRs. 

In addition to our concerns regarding loss of existing late- 
successional forests, we can find no biological justification for 
the regionally specific guidelines on green tree retention for 
Matrix areas. These guidelines were derived from existing Forest 
plans and range from 12 to 18 green trees per acre for BLM lands 
in northern Oregon to 15% of the volume of each cutting unit on 
National Forest lands in Oregon and Washington (DSEIS III-22) . It 



348 



is our experience that retention guidelines specified in regional 
Forest plans are inadequate for maintaining viable populations of 
cavity-nesting species and, as such, the Matrix will be 
characterized by substantially reduced populations of cavity- 
nesting species. For instance, since the number of green trees 
specified under Option 9 is only a subset (e.g., 12-18 
trees/acre) of the original tree densities within those units, 
the number of snags is likely to be an even smaller subset of 
retention trees. Retention areas will therefore lack snags of 
sufficient quality to maintain viable populations of cavity- 
nesting species within the Matrix. It is also highly unlikely 
that the few trees left standing in harvest areas will provide 
sufficient resources and habitat conditions for populations of 
herpetofauna and invertebrates that have limited dispersal 
capabilities and rely on live trees for food or shelter. The 
scientific literature indicates that even small patches of late- 
successional forests (< 4 ac) provide refugia habitats for 
species with limited dispersal capabilities. As such, LS/0G3 
habitat areas should be included within the Matrix to act as 
refugia for species with limited dispersal capabilities, source 
populations for recolonization of the Matrix, climatic refugia 
for large vertebrates and other wildlife, and "stepping stones" 
for dispersing owls. 

We recommend that the Administration's preferred alternative 
include more detail on (1) the number of snags that will be 
retained within the Matrix, (2) an analysis of snag recruitment 
rates within and outside retention patches, (3) more appropriate 
standards and guidelines governing the size and type of snags and 
live trees to be retained, (4) increased tree densities within 
retention areas to buffer them from blowdown effects (5) 
inclusion of larger patches (e.g., LS/0G3) of late-successional 
forests to provide habitat for species with limited dispersal 
capabilities, and (5) an analysis of the relationship between 
snag and green tree densities and projected population densities 
of cavity-nesting species under all alternatives (see Thomas 
1979: Wildlife Habitats in Managed Forests the Blue Mountains of 
Oregon and Washington, p. 69) . In addition, WWF recommends that 
Forest plans at the very- least adopt snag guidelines consistent 
with Thomas et al . 1993 (Report of the Scientific Analysis Team, 
p. 296) . These guidelines include no removal of snags > 20 inches 
diameter-at-breast height. 

Other Concerns 

Forest Fragmentation 

Timber harvest under Option 9 would subject approximately 22% of 
the remaining late-successional forests within the range of the 
northern spotted owl to additional fragmentation. Although the 
various management categories (e.g., LSRs) will allow for the 
development of late-successional characteristics over time, these 

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characteristics may take up to 100 years to develop and in some 
cases may not develop for centuries. As such, the level and 
effects of fragmentation of existing late-successional forests 
will continue well into the next century and possibly even 
longer. This is reflective in the low outcome probabilities for 
connectivity in the dry provinces (DSEIS Table IV-13) . Therefore, 
reserves should include all remaining large (> 100 ac) 
unf ragmented and low elevation habitat and remove these areas 
from timber harvest. 

Continued fragmentation of late-successional forests within the 
range of the northern spotted owl will also increase the 
likelihood that owls in some areas will become geographically 
isolated. Owl populations on the Olympic Peninsula, southwestern 
Washington, and along the 1-90 corridor may already be 
geographically isolated due to extensive cutting outside 
protected areas. For instance, extensive cutting on the Olympic 
Peninsula and within the Puget Sound lowlands, has severed 
important linkages between owl populations on the Peninsula and 
those along the western slopes of the North Cascades region. 
Additional cutting within the proposed Olympic Adaptive 
Management Area, which is along the boundary of the Olympic 
National Park, would increase the likelihood of further 
geographic isolation. 

VJWF recommends that the Olympic Adaptive Management Area, if 
designated, emphasize restoration management instead of timber 
harvest as a basis for linking owls on the Peninsula to 
populations in other geographic areas. We also recommend that the 
FEMAT team include an analysis of the effects of forest 
fragmentation on all species for each of the management 
categories and alternatives and an effective strategy for 
mitigating the effects of existing fragmentation levels. 
Mitigation for existing fragmentation should include: (1) "laying 
to bed" and reforesting logging roads on unstable slopes; (2) 
preventing further loss of contiguous and low elevation late- 
successional forests; and (3) extending rotation ages for late- 
sujcessional forests within the Matrix to at least 200 years. 

Ecologically Sensitive Areas 

Option 9 would subject several ecologically sensitive areas to 
further cutting. We have identified several areas that are 
ecologically vital at the landscape and regional levels that 
support high levels of species endemism. The following areas 
should be incorporated into a protected areas network: Grider 
Creek and Dillon Creek watersheds in the Klamath region; all 
forests in the vicinity of Mt . Eddy and Ball Mountain in the 
Shasta-Trinity region; the Siskiyou Mountains southwest of the 
Medford, Oregon; the Siskiyou National Forest region; and the 
Klamath-Siskiyou region in southwest Oregon and northwest 
California. These areas represent the last remaining intact 

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watersheds containing the full range of environmental gradients, 
undisturbed hydrologic regimes, and important corridors between 
wilderness areas. Because of high levels of endemism and species 
richness, the Klamath-Siskiyou region can be considered the 
"Galapagos" of North America. Further logging of forests in this 
region would constitute an unacceptable loss of biodiversity for 
the entire region. 

■ 

Protected Areas Network '- . \ 

In order for Option 9 to be more consistent with applicable 
environmental statutes (e.g.. National Forest Management Act, 
Endangered Species Act) and to reduce the degradation and 
fragmentation of existing low-elevation and contiguous late- 
successional forests, we recommend the following analysis and 
strategy be included in the preferred alternative. 

The FEMAT team should conduct a gap analysis to identify all 
areas of high species richness and endemism within the range of 
the northern spotted owl. This analysis should be set up using a 
hierarchial approach for ranking areas based on (1) the number 
and kinds of species they support; (2) the location of 
ecologically important areas (e.g., low elevation, species rich 
areas, large contiguous areas, intact watersheds, etc); and (3) 
the extent of timber harvest that has already occurred in the 
area. Proposed land management categories should then be 
overlayed onto spatial maps of ecologically sensitive and 
biologically important areas to determine which areas would be 
most vulnerable to additional timber harvest. Those areas should 
then be removed from the timber base and designated as inviolate 
reserves and other highly fragmented areas should be identified 
for restoration only. In addition, the analysis should 
incorporate available information on "natural" disturbance cycles 
(e.g, fire) that can be used to determine the range of ecosystem 
variability within the different physiographic regions and to 
establish timber extraction thresholds. Allowable cut levels then 
could be calculated once these ecologically sensitive areas have 
been removed from the timber base and resource extraction 
thresholds established. -This approach provides several advantages 
over the existing criteria used to develop the 10 forest options 
in the DSEIS, including (1) identifying critically threatened 
ecosystems requiring full protective status, (2) providing a 
scientifically credible and accountable planning process for 
setting critical resource thresholds (restoration targets, 
allowable cut levels, etc) based on "natural" disturbance 
regimes, and (3) identifying highly degraded areas in need of 
restoration. 

Northern Goshawk 

The northern goshawk is a federal candidate category 2 species 
and a Forest Service sensitive species within the range of the 

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northern spotted owl. The Forest Service is required to monitor 
the status of this species and to ensure that management 
activities do not result in future listing under the Endangered 
Species Act. Although the population status of the northern 
goshawk within the range of the northern spotted owl is largely 
unknown, numerous studies (e.g., Crocker-Bedford 1990, Wildl . 
Soc. Bull. Vol. 18:262-269) have established a relationship 
between goshawk population declines and logging intensity. Option 
9 provides unclear recommendations regarding mitigation for 
logging related impacts to the northern goshawk. The DSEIS states 
that "impacts to the northern goshawk habitat could be mitigated 
by protecting occupied and key nesting and foraging habitat 
within the Matrix as per Thomas et al . (1993) or the Forest 
Service Regional guidelines (whichever are more protective) " 
(DSEIS 3&4-89) . The Thomas et al . (1993) mitigation 
recommendations (Steps 1 through 4, p. 276-290), however, refer 
back to individual Land and Resource Management Plans for 
National forests within the range of the northern spotted owl. 
Forest Service guidelines in these areas include protecting 
varying amounts of nesting habitat (i.e., late-successional 
forest) from timber harvest, but recent evidence from the Klamath 
National Forest of northern California and elsewhere indicate 
that small set asides (e.g., 30-100 ac no cut buffers) typically 
used to protect goshawk nest sites are unlikely to ensure a pair 
will remain on site. WWF recommends that the Scientific Advisory 
Committee conduct a detailed analysis of the effects of all 10 
options on goshawk nesting, foraging, and post-fledgling habitat 
and that this analysis is included in the Final EIS for public 
comment. At a minimum, WWF recommends that the advisory committee 
adopt more rigorous standards and guidelines based on 
scientifically credible nest site buffers and ecosystems 
management principles both inside and outside designated goshawk 
protective zones. 

Marbled Murrelet 

Marbled murrelet breeding sites in the Pacific Northwest would be 
subject to timber harvest under Option 9, despite current efforts 
to locate and protect nest sites. Marbled murrelets nest only in 
the top of tall trees in mature coastal forests in the Pacific 
Northwest and have extremely cryptic nesting behaviors. Even with 
a concerted effort by the Fish and Wildlife Service to survey 
these birds, it is likely that only a fraction of the actual 
breeding pairs will meet the Option 9 standard because of 
inherent difficulties in sampling this species. To optimize the 
outlook for this species, the previous standard should be 
reinstated requiring protection of all late-successional forests 
within 11 to 55 miles of the coast, depending on the zone. This 
must be viewed as a minimum because of uncertainties regarding 
the effectiveness of recovery efforts for this species. For 
example, the Scientific Interagency Team indicated that even full 
protection of murrelet habitat may not be adequate. A 

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conservation strategy for this species must provide for 
recruitment of nesting habitat to ensure adequate recovery and 
eventually delisting of this species as specified under the 
Endangered Species Act. As such, all existing coastal late- 
successional forests should be removed from timber harvest. 
Allowing further cutting in coastal late-successional forests and 
relying on silviculture to recreate these characteristics in 
plantation areas is an uncertain and risky approach that may not 
meet the goals of recovery and the intent of the Endangered 
Species Act. 

Nonfederal Lands 

The FEMAT outlook for nonfederal timber harvests indicates that 
in the 1990s private and state timber growers within the region 
will likely respond to higher timber prices and cut at levels 
greater than is sustainable over the long-term (FEMAT 11-52) . A ' 
long history of overcutting on private lands has been 
responsible, in part, for the enormous pressures to provide a 
continuous flow of timber from public lands that has been both 
economically and ecologically unsustainable. This link between 
private and public timber harvest has resulted in the current 
timber crisis experienced throughout the region. This situation 
may be further complicated by the Administration's expected 
ruling under Section 4 (d) of the Endangered Species Act, and its 
reevaluation of its policy regarding protection of endangered 
species on private lands. Should the ruling result in a weakening 
of the Endangered Species Act regulations on private lands, 
cutting levels on these lands can be expected to accelerate even 
more than projected by FEMAT. Accelerated cutting on private 
lands is likely to result in yet another decline in timber 
supplies (see also FEMAT 11-52) and future pressures on remaining 
unprotected late-successional forests on public lands. Therefore, 
it is absolutely critical that Option 9 protect substantially 
more of the remaining late-successional forests on public lands 
to avoid future pressures from changes in timber supplies on 
private lands. 

t 
Mitigation and Monitoring 

The Administration is relying on mitigation and monitoring 
strategies to restore degraded ecosystems and to allow further 
cutting within existing late-successional forests. Ecosystem 
models provided in the DSEIS and FEMAT are based on the 
assumption that degraded ecosystems will be rehabilitated and 
that depressed fish and wildlife populations will respond 
accordingly. Although we agree with the need to monitor species 
and to mitigate impacts, we found numerous examples within both 
the FEMAT and DSEIS that discuss these recommendations only as 
possibilities. Furthermore, the DSEIS (Appendix B-59) 
acknowledges that adequate monitoring is essentially nonexistent 
on public lands despite being required by Forest plans. Given the 

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uncertainties in funding and the lack of a credible history of 
the federal agencies to implement monitoring and mitigation 
requirements, the DSEIS overestimates recovery rates for degraded 
ecosystems and is thus likely to fall short of its intended goals 
to restore degraded ecosystems. Moreover, the DSEIS lacks 
appropriate cost estimates and a proven strategy for obtaining 
Congressional appropriations to meet monitoring requirements. 
Given the uncertainties regarding Congressional appropriations 
and the lack of a credible history of implementing "monitoring 
recommendations, we see no assurance of improvements over the 
existing inadequate policy. 

WWF recommends that the SEIS team include more specific and 
measurable outputs that can be used as indicators of agency 
compliance with the objectives of the preferred alternative, 
including whether monitoring recommendations and mitigation 
guidelines are being achieved. To this end, an independent 
committee of scientists should be assembled to develop 
appropriate criteria and quantifiable resource condition 
objectives. This information should be made available to the 
public to help reduce the level of mistrust that currently exists 
with regard to agency compliance with standards and guidelines 
and environmental statutes. In addition, we recommend that the 
FEMAT team reexamine the outcome probabilities for all ecosystems 
and species recovery rates in the absence of receiving sufficient 
funds to carry out restoration and monitoring targets. This 
analysis should be used to further reduce timber harvest in the 
event that federal appropriations are not available to meet 
restoration targets. 

Economics 

The current economic crisis in timber dependent communities in 
the Pacific Northwest has been fueled by overcutting on public 
lands supplemented by Congressional appropriations^'that encourage 
below-cost timber sales. WWF strongly recommends that the 
Administration vigorously pursue the immediate phasing out of all 
below-cost timber sales on public lands and redirect 
Congressional appropriations to assist timber dependent 
communities with the transition to more diversified economies. 
Appropriation requests to Congress should supplement the 
Administration's FY' 94 budget request of $1.2 billion for these 
communities. In addition, we recommend that the federal agencies 
increase user fees for grazing, mining, and other natural 
resource extraction operations and recreation fees on public 
lands to compensate for large-scale reductions in federal timber 
receipts and shares to local governments. The DSEIS (3&4-116) 
indicates that recreation within federal lands totaled 135 
million visits in 1990 and several national polls suggest a 
willingness to pay higher user fees to maintain the quality and 
integrity of our National Forests and Parks. 

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3 9999 05018 505 5 

We further recommend that the Administration remove tax 
incentives on private lands that encourage exportation of raw 
logs. A ban on raw log exports would likely have two positive 
effects: (1) more volume would be available to supply local 
mills, and (2) private lands would have less incentive to overcut 
due to reduced stumpage prices in the log-export region (FEMAT 
11-60) . This could extend the supply of timber on private lands 
and allow a smoother transition away from timber dependency on 
public lands. 

Conclusion « 

\ 
In -conclusion, WWF is encouraged by the Administration's effort 
to develop an ecosystems management, approach to help resolve the 
conflict over the management of late-successional forests within 
the range of the northern spotted owl. We strongly recommend, 
however, that the preferred alternative provide full protection 
for the remaining low elevation and contiguous late-successional 
forests by including these areas as inviolate reserves in each of 
the management categories. No further cutting should be allowed 
within these reserves. WWF has provided these comments to assist 
the Administration with the preparation of a more scientifically 
credible and legally responsible option for the proposed forest 
plan. We believe that the above recommendations will strengthen 
the preferred alternative so that it is consistent with the 
President's mandate and the applicable environmental statutes. 

If you have any questions regarding our review, please feel free 
to contact our Senior Program Officer, Dr. Dominick DellaSala at 
(202) 822-3465. We appreciate your time in considering our 
comments. 



Sincerely, 



/ 



Michael Sutton 

Acting Vice President 

U.S. Land and Wildlife Program 



o 



78-799 0-94 (360) 



[ 



ISBN 0-16-046301-7 




9 780 




60"463013 



90000