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The long awaited Trout Slope East Timber Sale is rising again (see The Lynx, 2/99, 12/98; the HUPC Newsletters, 10/98, 6/98 and 1/97; and HUPC Alert 2/99). When it comes to timber sales we are rarely optimistic, but we remain hopeful that the re-birth of this once massive proposed timber sale will settle gently on the ground rather than the forced fit of earlier proposals. The first hopeful step (and worthy again of commendation for the Ashley National Forest) was the decision to freshly engage this issue utilizing a new scoping process and displaying the concerns in an Environmental Impact Statement, both proposed by HUPC from the inception of this timber sale.

It is a proposal which produces deep concern, in part, because it is now largely billed as a timber sale to rectify problems created by past timber sales. Thus a meaningful and logical approach is to rehabilitate the area by closing all timber sale access routes and allow time to heal the impacts that the past inappropriate Forest Service management has created.

Certainly no alternative should propose any timber access road construction, reconstruction or opening of closed roads, not even temporary, to-be-closed-at-some-point-in-time roads. As was noted in the original Trout Slope East Environmental Assessment, those very roads, constructed and then closed years ago, are now the roads to be re-opened for timber access. Closure and rehabilitation should mean closure and rehabilitation.

The supposition in the scoping letter and past documents is that the area is functioning at some risk and the only solution to this problem is timber harvesting with construction of a significant number of roads or the opening of a significant number of previously closed roads. These actions will, of course, simply add to the as they further fragment the forest in areas where roads and harvesting have not occurred or have not occurred for many years.

It is important to re-state the problem-- the risk is solely a function of past timber harvesting, road building and alteration of the natural function, structure and form of this particular landscape. Continuing down that same path may be okay for getting out the cut, but it is not in the interest of landscape/ ecosystem.

In this context it is important to show why and how dead trees are in some fashion threatening the system and that not opening roads or harvesting trees threatens the system or adds to the risk. It is not imperative or important that any additional timber harvesting occur in this area.

Only 35 years ago this whole region was largely roadless and undeveloped. Today there are no real roadless areas within this 18,000 acre assessment area and we can count the clearcuts from satellite photography! BUT there are many important areas that are undeveloped and not accessed by roads. Clearly they have profound importance in offering this larger landscape the necessary engine to operate with some degree of ecological integrity-- they buffer the risk, if you will. Thus roadlessness is an issue. We have urged the Ashley to identify all of these areas, 500- 1,000+ acres in size, and remove them immediately from any harvest schemes.

Obviously we are deeply concerned about wildlife issues in the context of sensitive and indicator species (avian and amphibian species also) as well as large predators like bear and cougar. This is a very fragmented landscape and in many places void of whole arrangements/guilds of core or interior species, making the unharvested and undeveloped patches, even though dead, very important. Those places offer an opportunity to allow the landscape to return to a structure and function that is less at risk. Any more fragmentation is simply mischievous overkill.

We look forward to how the goshawk strategy will be applied here and how further harvesting will affect the places where the goshawk is able to find security (see accompanying article on the proposed Forest Service goshawk strategy). As the evidence clearly notes, additional harvesting will not help goshawk-- dead and dying stands are no threat to the goshawk. Clearcuts, removal of large trees, and the constant nipping and tugging of the fabric of the landscape are threats.

It goes without saying that we have strong concerns related to the inherent biodiversity (both substance and process) of this region. It is not enough to simply say various insects or pathogens have killed a whole bunch of trees and turned the visual landscape from green to gray, forcing the Forest Service to remove the gray! What is wrong with a gray landscape? If the particular landscape is not within the inherent natural variability, why?

In essence we are asking the Forest Service to directly and honestly address these questions: Should timber harvesting take place? Can the concerns inherent in the landscape be met without timber harvesting with less management input and less additional forest fragmentation? In this framework it is imperative that a discussion of timber suitability/capability be ana-lyzed-- this is significant!

No additional logging should be allowed in this area. The forest is not healthy because of the overflow of roads which have fragmented the integrity of forest patches and ecological processes. It is not healthy because of culverts, clearcuts, saws and the like! Dead and dying trees are as much a part of a healthy integral forest as the moon is part of the night sky.

Dick Carter

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