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 been _ Improved
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
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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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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
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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
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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.
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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
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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.
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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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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.
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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
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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
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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,
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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
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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
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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 0 & 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. Under 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 0 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 97201. (503) 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
103
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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
105
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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
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Publication Number 17. The University of Alberta, Edmonton, Canada. 62 pp.
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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.
October 16-17, 1974. Portland, Oregon. Pp. 1-23.
Means, J. E. 1981 . Developmental history of dry coniferous forests in the central western
Cascade Range of Oregon. Proc. Forest Succession and Stand Development Research
in the Northwest. Oregon State University, Corvallis. March 26. Forest Research
Laboratory, Oregon State University. Pp. 142-158.
Newton, M. and E. C. Cole. 1987. A sustained-yield scheme for old-growth Douglas-fir.
Western Journal of Applied Forestry. 2: 22-25.
Old-Growth Definition Task Force. 1986. Interim definitions for old-growth Douglas-fir
mixed conifer forests in the Pacific Northwest and California. USDA Forest Service
Pacific Northwest Forest and Range Experiment Station, Research Note PNW-447.
Oliver, C. D. and B. C. Larson. 1990. Forest stand dynamics. McGraw-Hill, Inc. 467
PP
31
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University Press. 654 pp.
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sequoia-mixed conifer forest: should intense fire play a role? Proc. 17th Tall Timbers
Fire Ecology Conference, High Intensity Fire in Wildlands: Management Challenges
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analysis of change in forest stand age classes of the Oregon Coast Range from 1850 to
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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. Applying 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
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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
0 %
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 %
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
16
149
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
0
0
0
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
0
0
0
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.
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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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160
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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161
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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162
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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163
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
31
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.
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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.
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169
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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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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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185
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
ll/lS/93
186
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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187
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
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196
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.
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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:
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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.
Page 2
September 23, 1993
Comments oa DSEIS
235
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.
Page 3
September 23, 1993
Comments on DSEIS
236
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".
Page 4
September 23, 1993
Comments on DSEIS
237
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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(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;
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(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
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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
Page 20
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.
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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.
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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
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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 restoration 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 0 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 region 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 Evergreen 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^
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^
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
10
349
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
11
350
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
12
351
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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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)
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