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The Duchesne/Roosevelt Ranger District on the Ashley National Forest is proposing to remove beetle infested trees and utilize natural beetle pheromones and an insecticide to protect vegetation in a number of campgrounds on the district.

We understand the context and need of the proposal and fully support the effort to protect the investment in developed campgrounds. This is a major, on-going recreational management issue that, surprisingly, has received limited attention... at least until the predictable crisis arrives! Campgrounds are heavily used, trees grow old and face senescence, sites are so heavily impacted that natural regeneration can't take place, and the quality of the campground diminishes.

Thus, we suggested that concurrent with this project, the entire forest begin to address and prepare some kind of developed campground site vegetation management plan.

The restoration proposals which include removal of infested trees, planting of native saplings taken from areas immediately adjacent to the particular campground, and irrigation on the drier sites are notable. The utilization of the pheromones for pine beetle on the Uintas campgrounds and the Douglas fir beetle on Avintaquin represent meaningful, reasonably effective and hopeful strategies at protecting the large shade producing trees not yet seriously infected.

The primary concerns that we have are with the use of the insecticide, Carbaryl. While the use of Carbaryl on Avintaquin is isolated from any water sources (that is not the case with the Uintas campgrounds), the analysis on both sets of campgrounds ought to be focused on whether the use of Carbaryl is necessary and what it actually adds to the outcome, rather than simply determine - pre-decision - that it is an appropriate management scenario.

The likelihood that using Carbaryl will not simply be a one time action is obvious. That is a major concern ignored in the analysis. Numerous studies have been done on forestry Carbaryl use and have been shown to have major effects on non-target species, including native bees. It is toxic to fish, many crustaceans, and may adversely affects many species of birds.

If we've learned one thing over the last four or five decades, it is the reliance on insecticides to solve natural insect population variations has failed, particularly at the broad scale over any length of time.

Why take that course and risk when it is exceptionally clear the outcome of the project can be accomplished without Carbaryl?

Dick Carter

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