Dubrasich, Michael E. and Gregory J. Brenner. 2008. Comments to the Rogue River-Siskiyou National Forest Regarding “Appropriate Management Response”. Western Institute for Study of the Environment.

Full text [here]

Note: If you would like a free CD with the Comments and the Appendices (450+ MB), please email W.I.S.E. a request with your address.

Selected Excerpts:

Executive Summary

The purpose of this document is to request that the Rogue River–Siskiyou National Forest prepare an Environmental Impact Statement (EIS) before altering or amending their Forest Plan to include unprepared fire, known as Wildland Use Fires.

We believe unprepared fires can have significant effects upon natural resources and the human environment. The National Environmental Policy Act requires the preparation of Environmental Impact Statements before the U.S. government engages in activities that might have significant effects.

The EIS process aids in revealing, analyzing, and public discussion of the potential effects before they happen. That is a beneficial process, as well as required under federal law.

This document is a statement of our rationale for requesting an EIS process. We present this document to the Rogue River – Siskiyou National Forest so that they might understand and comply with federal law. …

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April 1, 2008 | Comments Off | Topic:  Policy, Management

George M. Leonard - Chairman, Board of Directors, National Association of Forest Service Retirees (NAFSR)

Recommendations to the Subcommittee on Interior, Environment, and Related Agencies Regarding the FY2009 Budget for the U.S. Forest Service

Full text [here]

Selected excerpts:

The following recommendations relate to all programs of the U.S. Forest Service. In developing these recommendations, we used the FY2008 Omnibus appropriation, as enacted, as the starting point. We find the Administration’s FY2009 budget proposals for the Forest Service to be irresponsible. We believe the base funding for all programs should be the FY2008 appropriation level adjusted for pay act and other uncontrollable costs (an increase of $77 million across all program areas). …

The most critical issue that needs to be addressed in the Forest Service budget is the funding of fire suppression. The current procedure of including the ten-year average cost of fire suppression within the agency’s discretionary budget is destroying the capability of the Forest Service to carryout the remainder of its statutory missions. From 25 percent in FY2000, fire funding is now approaching 50 percent of the budget. The suppression cost trend means the ten-year average is going to continue to grow, further cannibalizing funding for other programs. While the overall Forest Service budget has increased nine percent over the last six years, the diversion of funds to fire suppression has had a major impact on the workforce available to carry out the multiple-use mission of the agency. The number of foresters, biologists, and other resource specialists, along with supporting technicians, is a good measure of the capability of a resource management agency to carry out its mission. As illustrated in the following table, the capability of the Forest Service has been seriously compromised. …

There is wide spread recognition of the need to thin our overstocked forests to reduce their vulnerability to fire, insects, and disease. Funding for hazardous fuel reduction is important and must be continued, but it is only scratching the surface. Annual growth on the currently roaded portion of the timberlands on the National Forests is about 4 billion cubic feet. Not all of the material that needs to be removed has economic value, but portions are suitable for conventional wood products. Much more is suitable for energy production, including ethanol. Capturing these economic values is essential for making real progress in improving the conditions of our forests. It can also contribute to meeting our energy needs. …

One of the primary purposes for which the National Forests were established is to provide favorable conditions of water flow. Our forested watersheds provide much of the water that meets the needs of our growing population, particularly in the West. Resource management specialists and supporting technicians available to protect and enhance our watersheds have declined by 44 percent in the last six years. This decline must be reversed. …

The National Association of Forest Service Retirees believes that the National Forests and Grasslands should be managed so they are an asset to the communities within and adjacent to these lands. In too many instances, rather than being an asset, the overstocked, insect-infested, poorly maintained, understaffed Forests are becoming a liability. We believe the funding increases recommended above will begin the process of restoring the capability of the Forest Service to provide proper stewardship for these national treasures.

March 6, 2008 | Leave a Comment | Topic:  Policy

Hageman, Harriet M. The “Roadless Rule” and Global Warming - What You Should Really Know. Wyoming Agriculture Dec. 2007/Jan. 2008

Full text [here]

Selected excerpts:

On Oct. 19, 2007 the parties to the ongoing dispute over the “Roadless Rule” appeared once again before Judge Brimmer to argue about whether the Rule violated numerous federal environmental statutes, including the National Environmental Policy Act (NEPA) and the Wilderness Act. The current dispute is a continuation of the State of Wyoming’s 2001 lawsuit, and stems from Judge Brimmer’s 2003 decision (found at 277 F.Supp.2d 1197 (D.Wyo. 2003)) to enjoin enforcement of the Roadless Rule based on the fact that it violated NEPA and the Wilderness Act.

Despite Judge Brimmer’s injunction, and because of the numerous lawsuits that have been filed challenging any sort of active and effective forest management, many National Forest Managers have continued to adhere to the mandates of the Roadless Rule, thereby implementing an illegal, politically-driven, and ecologically-devastating policy.

In 2004 I explained in several editorials that the Roadless Rule is bad for forest health and is bad for Wyoming. It was developed in the waning days of the Clinton administration to deny access, management and use of, 58.5 million acres of National Forest lands (30% of the National Forests; 2% of the total land mass of the United States; 3.2 million acres in Wyoming). It was adopted following what was arguably the most truncated, superficial and scientifically-devoid NEPA rulemaking in history. The alleged “public process” associated with the Roadless Rule was politically driven rather than scientifically supported, with less than thirteen (13) months having elapsed between the announcement of the proposed Rule and publication of the Final Environmental Impact Statement (FEIS).

It was an illegal, Washington, D.C. driven, one-size-fits-all approach to management of 1/3 of our National Forests. It was designed to ignore the physical aspects, management considerations, economic issues, and social/cultural dimensions that make each National Forest unique. It treated Wyoming’s National Forests exactly the same as the National forests in North Carolina and Puerto Rico, and violated the individualized Forest Management Plans that have been painstakingly developed pursuant to the National Forest Management Act (NFMA). The Roadless Rule bypassed scientific analysis; hijacked local participation in forest management; and anointed Washington, D.C. as the supreme authority on forest management decisions …
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March 5, 2008 | Leave a Comment | Topic:  Policy, Management

Petersen, James D. Your Political Will Does Not Mean A Damn Thing. Speech to the Lolo Resource Advisory Council, Hamilton, Montana, November 27, 2007

James D. Petersen is Executive Director, The Evergreen Foundation [here]

Full text [here]

Selected excerpts:

Good evening,

Thanks for inviting me to join you.

Before I get started, would everyone in this room who works in the forest products industry please stand.

My message to the rest of you in this room is that if western Montana’s already teetering sawmilling infrastructure collapses – as it already has in Arizona and New Mexico – you can forget about your dreams for restoring western Montana’s beleaguered national forests, including those here in the Bitterroot Valley…

But radical environmentalists will tell you a very different story. They will tell you that the dead and dying trees that need to be removed from national forests… should be removed at taxpayer expense – that the trees that need to be removed from overstocked, diseased and dying forests should then be piled and burned or simply buried in the ground – at costs exceeding $1,000 per acre. Let me assure you, there is not enough gold in Fort Knox to pay for all of the restoration work that needs to be done in the West’s national forests.

Why would any environmentalist take such a bizarre stand, when everyone knows that some of the trees that need to be removed… have commercial value – and that some of these thinning projects could actually pay for themselves?

The answer is both simple and direct: radical environmentalists hate the free enterprise system more than they love the environment.

And the law is on their side. All of the angels in Heaven are no match for the astonishing power Congress has granted to environmental extremists – and until Congress finds the courage to stuff the litigation genie back in the bottle, there is nothing that you or anyone else can do to reverse the eminent ecological collapse of the West’s federally-owned forests. So a fairly strong case can be made for the fact that I wasted my time driving down here to talk to you – and you are wasting your time listening to me…

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December 14, 2007 | Leave a Comment | Topic:  Policy

By Mike Dubrasich

Full text [here]

Selected excerpts:

The Grand Canyon is a national icon, a symbolic monument that echoes through American literature, art, and science. The Grand Canyon is a piece of our national identity.

It is thus ironic (or perhaps entirely appropriate) that the principal feature of the Grand Canyon is nothing. The GC is a big hole in the ground. The viewer’s startling revelation is in regards to what is not there (terra firma) rather than what is there (thin air)…

To be sure, the shape of the nothingness is also important. The sides of the empty space are spectacular cliffs, with domed and flat-topped pinnacles and spires. The enclosure of the void is colorful and sculpted with form and line, but what makes the terrain so amazing is its sheer verticality. From the top it’s a long ways to the bottom, and more or less straight down…

There is another feature of the Grand Canyon. If you stand at the northern edge and look away from the Canyon, that is, with your back to the Rim, you will see a forest. It’s not just any forest, either. It is the Kaibab Forest, the ponderosa pine forest of the Kaibab Plateau, one of the most magnificent forests in the world…

The Kaibab Forest has never captured the American imagination in the way the Canyon has. This is ironic (and tragically inappropriate in our opinion) because the Kaibab Forest has substance, while the Grand Canyon is, principally, nothing.

The Kaibab Forest is a ponderosa pine forest. About half the forest is nearly pure pine, and a third is mixed conifer (ponderosa pine, Douglas-fir, Engelmann spruce, Colorado blue spruce, white fir, and subalpine fir). Pure spruce forests, aspen groves, and meadows make up the rest…

For at least the last 9,000 years people have been living in the Kaibab Forest. Thousands of archaeological sites have been found, indicating that the entire Forest has been almost continuously occupied by somebody or other since way back when. The residents were variously hunters, gatherers, farmers, and herders. They were human beings. They interacted with the landscape just like human beings everywhere: through the agency of fire.

People have been setting fire to the Kaibab Plateau for thousands of years. They set fires to clear land for farming, to remove hazards, to drive game, and for dozens of other practical reasons. They probably also set fires by accident, although the majority were likely by intent.

Lightning fires also occurred every year. However, the lightning fires encountered a pre-burned landscape and so they behaved like anthropogenic fires. Catastrophic fires that killed all the trees across vast tracts were rare, because fuels were never allowed to build up to catastrophic levels…

The early explorers widely attributed the open character of the Kaibab Forest to anthropogenic fire, although Indian burning was called “Paiute forestry” by detractors. John Wesley Powell, the greatest Grand Canyon explorer, was a supporter of anthropogenic fire as a forest management tool, and had a public political fight with Gifford Pinchot over the practice. Both men’s careers were crippled by the battle, but Pinchot’s ideas prevailed.

Over the last 100 years the US Forest Service has fought tooth and nail against Paiute forestry. The animus ran and runs deep, so deep that the USFS denies to this day the impact of Prehistoric Man and anthropogenic fire on American forests.

This Denial of the Obvious is a form of institutional intellectual schizophrenia. An odd mix of the precise detail, together with a romantic but false grand impression so characteristic of the eco-religious, suffuse the USFS oeuvre…

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December 8, 2007 | Leave a Comment | Topic:  Policy, Management

by John F. Marker

[John Marker is a retired Forest Service District Ranger, Fire Management, and Information Officer and a co-founder of Wildland Firefighter Magazine. This article was first published in National Forestry, (Sp ‘07, here), the magazine of the National Forestry Association, 374 Maple Ave East, Suite 310, Vienna, VA 22180.]

Reaffirmation of the mission of the National Forests

The Organic Act of 1897 was explicit in describing the reasons for establishing the National Forest System: to provide a sustainable supply of water and timber for the use of citizens, and to allow other uses that did not diminish the ability of the forests to provide the primary resources. However, legal and policy debates over management of the lands for the past 40 years or so have clouded the original intent of the Act. Today, in my opinion, few people understand the fundamental reason the National Forests were established, including some agency employees and too many political leaders.

It seems to me the future of the forests rests upon some form of new top-level federal process to clarify both the purpose of the forests and the direction that their management should be heading. A second component of the process must be a public awareness program to promote understanding of the National Forests’ essential natural resources role, which is essential before successful land management can be carried out. Clearly, a serious effort needs to be made to resolve the endless controversy surrounding the concept of scientific forest management, and a clarification of the mission.

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December 6, 2007 | Leave a Comment | Topic:  Policy

Testimony of Dr. John A Helms: Responses to Questions for the Record
Following Sept 24, 2007, Hearings by the Senate Committee on Energy and Natural Resources

Full text [here]

Selected excerpts:

Wildfires require a combination of fuel, temperature, and oxygen. Of these, the only factor that can be managed is the presence and distribution of fuels. Given that the most intense and catastrophic fires occur in dense forests, and since experience has shown that when wildfires encounter less dense and more open stands fire intensity commonly drops (USDA PSW 2007), it seems clear that increased efforts must be made to thin overly-dense stands. In doing so, irregular mosaics of stand density should be created that remove ladder fuels to reduce opportunities for fire to burn into tree crowns.

Since it is clearly impossible to rapidly treat all 180 million acres the Forest Service estimates are in hazardous condition, current efforts to create “Defensible Fuel Profile Zones” (DFPZs — Quincy Library Group/USDA FS, California), “shaded fuelbreaks” (Agee et al. 2000) and “Strategically Placed Landscape Area Treatments” (SPLATS or SPOTS in California’s Sierra Nevada — USDA FS) are all worthwhile exploring. These are areas 1/4 - 1/2 mile wide, usually along roads or strategically placed in which fuel loadings are reduced to reduce potential for crown fires, interrupt fire spread, and to provide defensible space to fight the fires.

Although not free from criticism, these efforts are initial steps in the right direction. More adaptive management and pilot studies (such as the Fuels Management National Pilot Project 2007 funded by the Forest Service) are needed to demonstrate efficacy and cost effectiveness and to communicate lessons learned from these and other projects and forest treatments (Wildland Fire Lessons Learned Center 2007)…

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December 4, 2007 | Leave a Comment | Topic:  Policy, Management