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HUPC Pole Mountain post-Neola North Fire salvage timber harvest comments

14 November 2007
J. R. Kirkaldie
District Ranger
Roosevelt-Duchesne Ranger District,
Ashley National Forest
Roosevelt, UT 84066

Dear J.R.,

We have a few comments on the proposed Pole Mountain post-Neola North Fire salvage timber harvest. We do appreciate the prompt responses from Lesley Tullis and Mike Elson to questions concerning the extent of this and other salvage sales likely to appear on Neola North. Mike stated in his email response and reiterated at the last
Ashley/conservationist meeting on 24 October 2007 that at this time there are no other salvage sales planned. He noted very clearly that this proposal emerged because of its flat terrain and proximity to the existing road but that, indeed, others may also arise as additional information is developed. He emphasized none are planned now but others
could not be ruled out.

We mean not to cast aspersions, but we honestly can’t tell whether these statements are evasive or candid. They problem is they are both! We fully believe no other salvage sales are planned now simply because with one disjunct salvage sale at at time it is easy for the Ashley to categorically exclude each action and do the minimal review while
isolating the environmental impact analysis. Into the future we go anticipating yet another 225 acre salvage sale (Pole Mt. II) that will, of course, be identified after this one is “analyzed.” Certainly the evaluation, not at this time, but not to be counted out in the future, allows the district to be, in a convoluted manner, honest.

Knitting together a bunch of fragmented salvage timber sales in Neola North, arguing they are independent sales, seems disingenuous, certainly in violation of NEPA and not good natural resource planning/evaluation. Obviously, this harvest and any future harvests are deeply related and connected, resulting from the fire. Of course, we only know this is a possibility because the district and forest will not come out and say this is the only salvage sale we are proposing or this is the first of additional salvage sales we will be proposing. For the forest to simply say, in essence, we just don’t know, begs the question.

This, of course, leads to a broader issue. While this fire was started off-forest and not a result of a “natural” environmental event, it was noted, nonetheless, numerous times by the Forest Service during the fire event that it would have beneficial value to forest resources. Furthermore the Burned Area Emergency Stabilization Plan clearly shows HUPC-Neola North post-fire slvg 5 11/13/07 the fire burned quite “gently” on the Ashley National Forest with no need for re-planting. Only 4% of the soils were affected by a high burn severity--most of those off-forest with
only 25% of the vegetation on the forest in the high mortality rating. The vast majority of the soils were lightly or un-burned. There is simply no biological/ecological/ecosystem context for a salvage timber harvest.

So why this proposal?

Back to an old fashioned silvicultural context! What an irony that the Ashley goes on and on about ecosystem management yet falls back into stride with a timber proposal which has no ecological rationale. Furthermore, this area has not been “targeted” in the past as a timber production area. No harvests were planed prior to the fire in this area--that was reconfirmed at the 24 October meeting. And all of this in the face of the brief discussion that ensued at that meeting about the difficulties the forest is having in selling timber. By way of this letter, would you please provide the offer and sell reports and a summary of volumes offered and sold on the forest over the last decade. Thank

Given all of these concerns, we suggest before proceeding with this harvest, unless the forest clearly notes this will be the only post-fire salvage harvest emanating from the Neola North Fire, the Ashley National Forest proceed with a comprehensive post-fire salvage logging analysis and review. This would assure a systematic evaluation of whether harvesting should occur, why and where, all in one document, assuring a full environmental analysis rather than a disjointed and fragmented review.

There was a day, not that long ago, as you know, J.R., that the Forest Service would have initiated just such a review. The current obsession with Categorical Exclusions to get around broad ecological analyses and public concerns and accountability is a recent direction coming from an administration hell-bent on diminishing public issues and ecological literacy. It is a sad statement that the Forest Service has been so willing to engage this direction. Over ninety years of effort by the Forest Service to be open, honest, and welcoming of public input and concerns and a clear direction of moving more and more toward ecosystem and landscape management has been shattered in a short decade. It is not necessary that the district engage this CE process wherein a scoping/proposed action/substantive comment request is made in a single letter, nary 2 pages in length!

We urge you to proceed within the normal NEPA process of scoping, preparation of an environmental document, in this case an EIS, and seek public input in a meaningful way. How can there be any dispute that this process will more likely result in a decision fully analyzed by Forest Service resource specialists and fully accountable to public issues and concerns versus the path now charted to minimize review and analysis and crop public input in order to just to get it done?

Numerous issues and concerns must be analyzed. First and foremost, of course, is the efficacy of post-fire salvage logging. It is incumbent upon the Ashley National Forest to HUPC-Neola North post-fire slvg 5 11/13/07 show post-fire salvage logging is necessary to assist in recovery of the fire impacted area and that it is ecologically appropriate to initiate harvesting within a forest system presently recovering. While we know from the Neola North Burned Area Emergency Stabilization Plan that much of the fire area received only a light to moderate burn, it is still an ecosystem in
stress and recovery is not aided by timber harvesting. The scientific literature is replete with this conclusion. It seems ONLY the Forest Service consistently ignores this research. The Neola North Burned Area Emergency Stabilization Plan makes it very clear there is no need for timber harvesting to assist in tree regeneration. Nothing in this report suggests any need for a traditional silvicultural approach. Removing individual hazardous trees (one tree length) along roadsides or campgrounds is one thing, timber harvesting is another. It was plainly indicated at our 24 October meeting that the primary reason this particular stand of trees was selected was that the area was relatively flat, easily accessible and had a meaningful density of still-standing trees and if not logged their economic value would be lost to blue stain or deformed by weather events and the passage of time. Ecological value is ignored in this calculation!

That is an old fashioned silvicultural approach to forest management and, in this case, the peer-reviewed scientific literature clearly notes, regardless of the size or intensity of the fire, that such an approach is outdated and inappropriate. A place to start in reviewing the problems with salvage logging is the article, “Salvage Logging, Ecosystem
Process and Biodiversity Conservation
,” Conservation Biology, August 2006. This is only a start and has been augmented over and over with numerous research efforts over the last couple of years, all showing post-fire salvage logging almost always creates notable additional impacts detrimental to ecosystem integrity. There is no rush to move forward with this proposal from an ecological perspective thus it would be wise to analyze the issue in a broader context as we’ve suggested (see “Salvage Harvesting Policies After Natural Disturbance,” SCIENCE, 27 February 2004).

Issues dealing with biological legacies, disturbance to soils, highly specific but essential habitat elements dealing with snag dependent and cavity nesting woodpeckers, small mammals and invertebrates all must be carefully analyzed. Simply attempting to dismiss them by suggesting alternative habitats exist elsewhere within the burned area is not an adequate analysis. Knowing this specific area and having reviewed maps of the area, it is clear this is a special place within Neola-North as it now represents avery important habitat type. The same issue of Conservation Biology noted above also has an article dealing with just this concern: “Toward Meaningful Snag-Management Guidelines for
Postfire Salvage Logging in North American Conifer Forests

Over and over again Forest Service management has resulted in notably dysfunctional forest ecosystems as a result of fire exclusion--it is particularly clear right here in this place on the Ashley National Forest. The Ashley now threatens to add the proverbial insult to injury by intervening with old time forestry into a system finally benefiting from a fire! It just doesn’t make any sense from a policy or budget perspective and management context. It is disingenuous!

The context most needed to help bring this large South Slope coniferous forest system back to an integral structure and function is an event such as this fire producing standing dead and dying forest patches of notable size. These are the very things missing within the forest system.

We obviously have concerns surrounding invasive plant species that always come with logging operations, including seeding of non-native species as either a result of the logging operation or part of the post-fire stabilization efforts (see “Fire Management Impacts on Invasive Plants in the Western United States.” Conservation Biology, April 2006). This is particularly meaningful given the fact the Forest Service has identified invasive species as one of the major threats engulfing forest landscapes. It goes without saying that endangered, threatened and vulnerable species must be fully
analyzed and documented. This would include, of course, species listed as part of the Utah Natural Heritage Program. A broader wildlife analysis must be extended to include disturbance to wildlife as a result of logging, additional fragmentation of habitats and increased access surely to follow the logging operation. The bygone argument that additional habitat is available, not-to-worry, is simply no longer tolerable since we know many impediments to wildlife utilizing other areas fails the common-sense test, not to mention professional resource management. Other habitats are likely occupied, territorial constraints are significant and temporal/geographical barriers to movement abound.

Of course, all of this is tied to proper evaluation and monitoring of MIS and sensitive species. Goshawks are of deep concern on this particular landscape along with pine marten. Forest Service regs are clear in this case that monitoring activities must be conducted to determine that population and habitat goals are being met.

Lynx are of clear concern as this project is within a Lynx Analysis Unit, requiring incorporation of the Lynx Conservation Assessment and Strategy (LCAS). This requires a meaningful review of denning and foraging areas, migration and dispersal routes. This alone should trigger the preparation of an EIS in conjunction with the other concerns raised.

Important archeological sites must be inventoried and properly protected from logging operations.

And certainly livestock grazing should be deferred and removed from the fire area for several years at least. This is certainly a meaningful issue that must be fully reviewed and disclosed in light of this proposed action.

The proposal suggests no roads are necessary but allows roads to be constructed. This is, of course, exacerbated by the failure of the Ashley to firmly, openly and honestly state whether additional timber sales will be offered in the fire area. Thus it is important that road issues be fully disclosed including the density of roads in the area. This includes the fire roads utilized in “fighting” the fire. Even temporary roads have significant impacts upon the physical habitat required by so many species, but also upon the behavior of many wildlife species. Again the scientific literature is replete with peer reviewed research showing the impacts of roads. Of course, these impacts are enhanced when placed over an already disturbed system recovering from fire. Roads have a far greater effect than the simple road prism itself as effective habitat is diminished for a considerable distance from the road--for many species this may represent a buffer from one-half to one mile.

This particular area has been harvested in the past thus it is important that past harvesting and road building be fully evaluated in terms of present day and cumulative impacts. How has past harvesting already affected wildlife species, soil integrity, riparian quality, old growth, forest function and structure? Will this particular project be credited
to the forest ASQ? Is it within the suitable timber base? Most of the area falls within Management Area n (MA n), requiring commodity outputs or production to be modified for amenity protection. The simple and truthful matter of fact is MA n is a low intensity prescription (almost all of the pertinent lodgepole/spruce habitat types in this area have
a low timber productivity, see Coniferous Forest Habitat Types of Northern Utah. Gen. Tech. Report INT 170, July 1984) which did not foresee meaningful investment in timber harvesting during this planning horizon and at best timber harvesting is to be “modified” for amenity protection, to retain old growth and coordinate with wildlife and recreation. We have raised this issue consistently for 20+ years now--please show us how this proposal has been modified to meet the requirements of MA n. The Ashley has been intellectually dishonest in utilizing MA n as the basis for timber harvesting--that is not the appropriate context of this management area. For too long the forest has hidden behind the proverbial two-step!

Clearly there is no rationale for this post-fire salvage timber harvest proposal. Please keep us updated on this project.

Thanks much!
Dick Carter

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