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Short notice, sorry!

This is but the first step--SCOPING--by the Kamas Ranger District to propose removing 200-500 pine beetle infested trees from campgrounds on the Mirror Lake Highway up to the Cobble Rest Campground and over on the Weber River side of the district at the Ledgefork Campground on the Smith and Morehouse Reservoir. The primary purpose is to remove the trees infested with beetles to help slow the spread. Forest Service crews will cut down the trees after the campgrounds have been closed in the fall and allow fire permit holders to remove them. Permit holders will not be allowed to drive into the campgrounds.

To further slow the spread the Forest Service is proposing to use the insecticide Carbaryl on trees not infected or lightly infected. The spraying will occur this fall and likely in future years as well. Furthermore, the Kamas District is proposing the possibility of a commercial timber sale along the Mirror Lake Highway associated with the infested campground trees. That proposal may be formally proposed this winter.

While we agree the campgrounds are a huge capital investment and the felling of beetle infested trees makes sense, particularly the way the district is proposing it, we have serious reservations about the use of Carbonyl and the possibility of a commercial timber or fuel wood timber sale in the future.

Carbaryl is a registered pesticide and one of the most widely used in the United States. It comes with significant precautions and formal WARNING level for the use in forestry practices. Study after study has shown it is toxic to bees, other beneficial insects, fish and aquatic insects and birds even at low levels and particularly when used over long time frames. Studies have shown it has suppressed predators on beetles thus actually increasing forest beetle survival. It is extremely toxic to fish and bird populations in forested settings.

The fact that the Forest Service has already suggested a timber sale is likely to help reduce the beetle infestation suggests they have already made up their mind independent of the requirements to analyze and document the impacts of such a sale.

These campgrounds are important and need to be protected. But a timber sale is not the way nor is the use of insecticides. Beetles and forests go hand in hand. What is needed is an aggressive operation as proposed--cut down the infested trees at the end of the year and remove them. Where appropriate the agency should initiate a vigorous planting of lodgepole seedlings and saplings. Campground planners have long recognized that campgrounds may face structural changes as trees grow older and regeneration is limited by site conditions.

Any comments you have should be sent by 8/20/02 to

Tom Contreras
Acting District Ranger
Kamas Ranger District
P.O. Box 68
Kamas, UT 84036

16 August 2002
Tom Contreras
Acting District Ranger
Kamas Ranger District
Wasatch-Cache National Forest
Kamas, UT

Dear Tom

We are in receipt of the Scoping Document, "Potential Hazard Tree Removal and Spraying of Primarily Lodgepole Pine Trees and Other Conifers with Epidemic Levels of Bark Beetle Infestation."

While we fully agree the project has merit due to the high value of the campground facilities, it doesn’t appear the campgrounds show a hazard that much greater than any year in the past few years. As you know extensive work has already been done on the Yellow Pine site. Thus I would like to see a bit more of a documentation that suggests the level of problem that the scoping document alleges.

If, indeed, you proceed, we support the process whereby Forest Service crews fell the trees and they are then carefully, as noted in the scoping document, removed by fire wood permit holders. And we certainly agree that the concern is not further up the highway than the Cobble Rest Campground. In fact, the scoping document notes that only 200-500 trees are likely to be removed thus a very real analysis needs to be undertaken to determine just how serious of a problem these campgrounds face. The analysis needs to show that the proposed action will have the desired outcome--green trees and shady conditions. A more detailed review of the safety issue is a must as well. The simple matter of fact is the trees in all of these campgrounds are getting older, are being significantly more stressed by the long term (and likely to be longer term) drought, and have minimal opportunities for new growth because of site conditions. It may well be a vigorous effort at planting new trees and closure of some individual sites will be a smarter long term management action. This must be fully analyzed and reviewed as an alternative. Campground planners have long been aware of the problem of aging trees and minimal reproduction.

Our primary hesitation with the specific proposal is the use of Carbaryl--not just the use, but as the scoping document notes, long term use may be necessary. While we recognize application of the insecticide will be in the fall, this is still not an issue to be taken lightly as the scoping document suggests and if the use is going to be long term a categorical exclusion is inappropriate. While it is true Carbaryl is one of the most heavily used pesticides and registered, it also carries, as used in forestry settings, a WARNING level label. Numerous studies have been done on forestry Carbaryl use and have been shown to have major effects on non-target species1. Within label use it has been shown to kill native bees2, decreased pollinators in a spruce budworm spayed area3, and actually increased a disease carrying beetle in pine forests by killing beetle predators4. It is profoundly toxic to fish5 and adversely affects many species of birds.6 At even at very low levels it can have negative effects on many crustaceans7. Only one major ecosystem study has been completed on Carbaryl, but it showed serious and long term effects to numerous unintended, non-target species8.

If we’ve learned one thing over the last four decades it is the reliance on insecticides to solve natural insect population variations has failed. Thus, we strenuously object to the use of Carbaryl in this instance and insist that at least an EA be completed if the insecticide is to be used. Pheromone treatments and non-insecticide treatments exist, as you well know, and are available and should be used first in national forest settings. Physical treatment, such as thinning along with careful and appropriate removal of infected trees is the single most effective action in situations like this one.

Beetles go with the territory and campers will understand and accept that when it is explained in an ecologically literate manner. Campground planners also must accept change in campground structures--this is becoming an issue of consequence.

Finally, Tom, we are deeply concerned with the discussion in the scoping letter proposal that notes it is likely that a firewood sale (or commercial timber sale) will be initiated this winter. While we appreciate the notice that this is not being proposed now, and the clear statement that such an activity will be fully and openly reviewed, we are concerned with the very positive statement that it is necessary even before an analysis and public review is initiated. From the outset we are set back on our heels with the likelihood of an analysis justifying the proposal rather than an honest review of the situation! We are asking you to be sure and include us early in this discussion--we don’t want to simply see the proposal for the first time when it is initially scoped.

Also, I went back through the Winter, Spring and the just arrived Summer 2002 Quarterly NEPA schedules for the forest and found nothing suggesting this particular proposal was in the works. The point is this project seems to have appeared out of nowhere and seems to be moving far more rapidly than conditions warrant.

Thanks much.


Dick Carter

1-Cox, Catherine. Carbaryl. Journal of Pesticide Reform, Spring 1993, Vol. 13, #1.

2-Johansen, C.A., et al. Pesticides and bees. Environmental Entomology, 1983 12(5).

3-Hansen, R.W., et al. Effects of spilt application of Sevin-4-Oil on pollinators and fruit set in a spruce-fir forest. Can. Ent. 1984, 116.

4-Togashi, K. Effects of aerial application of insecticide on the survival rate of Monochamus alternatus within Pinus densiflorus logs. 1990 Appl. Ent. Zoo 25(2).

5-Sanders, H.O., et al. Acute toxicity of six forest insecticides to three aquatic invertebrates and four fishes. 1983. Technical Papers of the U.S. Fish and Wildlife Service (#110), Washington, D.C.

6-Moulding, J.D. Effects of a low-persistence insecticide on forest bird populations. 1976. The Auk (93).

7-Gibbs, K.E., et al. Persistence of carbaryl in woodland ponds and its effects on pond macroinvertebrates following forest spraying. 1984. Can. Ent. (116)

8-Barrett, G.W. The effects of acute insecticide stress on a semi-enclosed grassland ecosystem. 1968. Ecology 49(6).

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