|
My
official public comments on the Biscuit Fire Recovery Plan Draft EIS
January
18, 2004 To:
Mr. Scott Conroy
ACT2 P.O. Box 377
Happy Camp, CA 96039 541-471-6500
Fax: 530-493-1775
Mr.
Conroy: This
email, in its entirety, is to be construed and accepted by you as my
official Public Comment on the Biscuit Fire Recovery Project Draft EIS,
and also my continued intense interest in this project. I expect to
remain on your mailing list for hard copies of all actions contemplated
by the Forest Service in the Siskiyou National Forest, including, but not
limited to, the area known as the "Biscuit Fire." I
realize that my public comments are lengthy (fifteen pages if printed at
their Arial size 12 font), but they are lengthy because of the
importance of this Project to, not just Oregon and its people, but all
of America. To that end, I invite your thoughtful read. My
public comment includes the full text of an article[1], published by The
Idaho Statesman, Boise, Idaho, on January 17, 2004, that perfectly
illustrates the "why" of my own comments and concerns. In violation of the
National Environmental Protection Act (NEPA), the Forest Service has
done no economic analysis relating to "The Biscuit Fire Recovery
Project Draft EIS." I have both Volumes (I and II) of this Project,
as well as the seven maps of the seven current Alternatives and the map
titled, "Biscuit Fire Recovery Project Draft EIS -- Vegetation
Change." This, even with no other considerations, should require an
extension -- both for the Forest Service and for the public. I recommend that the Forest
Service immediately begin this NEPA-mandated economic analysis, and that
it also create and offer for public comment, an alternative that
involves real timbering: including, but not limited to, salvage harvest
after such fires as happened in 2003 in the Biscuit Fire. Conspicuous
by its absence from Forest Service and 'environmental' and
'conservation' groups' documents and public statements is the fact that
trees have life expectancies. Trees do not 'live forever.' Trees sprout.
Trees grow. Trees live, some species and specimens longer than others.
"Prescribed burns" are not always good for trees, and are not
the only form of "management" for them. Trees die. 'Old growth
forests' do not simply exist in perpetuity. It
is neither realistic nor responsible to give schoolchildren or their
parents the wholly wrong idea that such is true. In
this public comment, I recommend that the Forest Service contact Bruce
Vincent of the Provider Pals program to secure the educational help that
he and this program can give to our forests and to the American people.
Bruce may be contacted at: ppals@libby.org
or 406-293-8822 and the Provider Pals website is: http://www.providerpals.com/media/news/journaldoc.html
Included
within the parameters of this public comment of mine is your own Forest
Service News Release number RR-SNF-2/12/03[2] My
comments also include the full text of a "Sample Letter"[3]
posted on the Internet by the Ft. Worth, Texas, Audubon Society. This
"Sample Letter" is included to show that proximity to the
Biscuit Fire has no bearing on who may publicly comment and the validity
of his/her/their comments. No part of the "Sample Letter"
is to be confused with my own thoughts/recommendations/comments --
the "Sample Letter" is included for the reasons just named. This
quote, taken from the article below, is false and misleading, leading
the reader to think that "lack of fire" is the problem, not
"lack of responsible timbering": "Of
the 20 million acres of national forest in Idaho, 5.5 million acres are
so loaded with trees and brush from lack of fire that they are at a high
risk of burning" -----
----- ----- ----- [1]The
nation's forest chief warns of four threats to our national forests -
Timber cutting, road building no longer agency's primary mission
January
17, 2004 By
Rocky Barker rbarker@idahostatesman.com or
208-377-6484 The
Idaho Statesman P.O.
Box 40
Fax:
208-377-6449 To
submit a Letter to the Editor: editorial@idahostatesman.com
U.S.
Forest Service Chief Dale Bosworth told employees Friday how to help him
rebuild trust in the agency as they set up a thinning program to reduce
the threat of fire. "I
want people to be darned sure it's a fuels treatment project and not a
timber sale project cloaked up," Bosworth said at the Idaho
Environmental Forum. The
University of Idaho graduate in charge of managing 191 million acres of
national forest was in Boise as part of his campaign to change
the way people look at the Forest Service and the problems it faces in
the future. No
longer, he said, does the agency consider timber cutting and road
building its primary mission. The
new threats to the nation's forests are fuel buildup and fires,
motorized recreation, the loss of open space and invasive alien species.
"It's
time to stop fighting those old battles from the past," Bosworth
said. "The wars have been fought and won 15 years ago."
The
timber harvest on national forest lands has dropped from about 11.5
billion board feet in 1989 to about 2 billion board feet today, enough
to built 133,000 homes. The agency has eliminated 10,000 miles of road
since 2001 and built only 900 miles of new roads. Leftover
from the polarizing debates over the size and scope of timber cutting is
a lack of trust the agency must overcome if it is to be successful,
Bosworth said. Congress and President George Bush have cleared away many
of the institutional obstacles that Bosworth had characterized as "analysis paralysis." The
Healthy Forests Restoration Act approved last year by Congress allows
more timber and brush to be cut and cleared with less environmental
scrutiny. So did administrative actions promoted by the Bush
administration. Fire
and Fuels
Now
Bosworth hopes to increase the speed with which the Forest Service
treats the more than 73 million acres of national forest and nearby
communities threatened by wildfire. Critics have charged the new rules
reduce the public involvement in the decisions of how and where to thin,
log and burn forests. Instead,
Bosworth is challenging his employees to get the public involved early
to help shape the program. "I want people to engage the public
better than we have in the past," he said. Boise
attorney Bernie Zaleha, a member of the board of directors of the Sierra
Club, one of the nation's most powerful environmental groups, remains
skeptical that the Forest Service's intent is fuels treatment and not
timber sales. He
said a 518,000-board feet timber salvage sale in Southwest Oregon, where
the Biscuit Fire burned in 2001, is an example of a timber sale
disguised as a fuels reduction project. "If
what he said was true, they would not be doing the Biscuit sale in the
name of fuels reduction," Zaleha said. Invasive
species
Bosworth's
second threat is invasive species. He pointed to the spread of spotted
knapweed in the Selway-Bitterroot Wilderness, the killing of 95 percent
of Idaho's western white pine by blister rust and the loss of wildlife
habitat from yellow star thistle as examples of a slow but insidious
destroyers of public lands. "These
invasives could have more effect on biodiversity than anything else
going on," Bosworth said. Loss
of open space
The
third threat, he said, is the loss of open space. The threat to the
national forests is the fragmentation of important wildlife habitat and
such impacts as the spread of invasive species. The
agency contributes to this loss, he said, when it forces ranchers off
the land in their efforts to prevent damage to watersheds and range from
grazing. He said the agency needs to find ways to restore the health of
the land without destroying the rancher's business. "We
need creative new solutions," he said. Ted
Hoffman, a former president of the Idaho Cattle Association, a rancher
and veterinarian, applauded Bosworth's recognition that the agency has
needlessly hurt ranchers. "That's
a profound comment," he said. Motorized
recreation
The
fourth threat, Bosworth said, is unmanaged motorized recreation. He
is telling every national forest to force motorized users to stick to
roads and trails. "The
day we can take off-highway vehicles cross-country across the national
forests are over," he said. Bosworth
has the support of the organized motorized recreation community for
this, said Bill Dart, executive director of the Blue Ribbon Coalition, a
national group based in Pocatello dedicated to motorized access on
public lands. "We
support limiting use to roads and trails on most places on the national
forests," Dart said. He
pointed to an initiative by the Boise, Payette and Sawtooth national
forests that would ban all cross-country motorized travel. Officials of
the three forests will allow travel to continue on all current routes.
Then the Forest Service will do a local review of all routes to see
which ones are appropriate. "We
think they're on the right track," Dart said. Bosworth's
success in restoring trust in the agency will come if people on the
fringes of the debate, both on the environmental side and the
development side, lose their appeal, said John Freemuth, a Boise State
University political science professor. "You'll
see the people that oppose everything get marginalized," Freemuth
said.
To
offer story ideas or comments, contact Rocky Barker http://www.idahostatesman.com/Story.asp?ID=58699 -----
----- ----- ----- Simply
locking up an area and effectively stopping all timber harvest and
access by removing the area's roads -- which is, in effect, the
federal implementation of The Wildlands Project -- and walking away, is
NOT doing anything positive for the 'species biodiversity' that is
touted as the end result of such activity. It is, in fact, creating a
LOSS of diversity. In tandem with this is the very real fact that no
human ingress (the power or liberty of entrance or access; Webster's
ninth Collegiate Dictionary) in such areas is a
de facto denial of people from the very lands that their taxpayer
dollars paid for, lands that were there for public use! -----
----- ----- ----- [2]News
Release No: RR-SNF-2/12/03 December
12, 2003 Contact:
Judith McHugh jmchugh@fs.fed.us
or 541-659-2851 Biscuit
Fire Recovery Project Draft EIS Public Comment Period Extended
Medford,
Oregon - The public comment period for the Biscuit Fire Recovery
Project Draft Environmental Impact Statement (DEIS) has been extended by
15 days and now ends on January 20, 2004. In
choosing the length of the extension, Conroy sought a balance between
busy holiday schedules and the economic losses anticipated from further
wood decay. In
the last two weeks, the Forest Service and the Bureau of Land Management
have conducted four public open houses. An oral public hearing is
scheduled for Wednesday, December 17, 2003, from 5:00 to 9:00 p.m.
at the Josephine County Fairgrounds Pavilion Building. Up to 3 minutes
will be allotted for any individual who wishes to comment. A court
reporter will record all comments. The
Biscuit Fire Recovery Project Draft EIS was publicly released on
November 21, 2003, for a 45-day public comment period and was scheduled
to end on January 5, 2003. All written, faxed, or electronic comments
should be sent to: Scott Conroy, care of ACT2 Enterprise Team, P. O. Box
377, Happy Camp, CA 96039, faxed to 530-493-1776, or e-mailed to: r6_biscuit@fs.fed.us.
The DEIS is posted on the Internet at http://www.biscuitfire.com For
more information about the Biscuit Fire Recovery DEIS, contact Judy
McHugh 541-471-6500. Other
related websites: http://www.fs.fed.us/r6/siskiyou In
case one might think that not living in or near this area -- Biscuit
Fire -- means there's no need to get involved, here's what the Ft.
Worth, Texas, Audubon Society, has for its members at this website
address: http://www.fwas.org/topic.asp?TOPIC_ID=638&FORUM_ID=9&CAT_ID=10&Forum_Title= Conservation+Alerts&Topic_Title=Audubon+Action+%2D+010704 [3]SAMPLE
COMMENT LETTER End
of Ft. Worth Audubon Society's Sample Letter. -----
----- ----- ----- The
fact that the chief of the USDA Forest Service considers "fuel
buildup and fires, motorized recreation, the loss of open space and
invasive alien species" to be threats to America's forests
should be raising many Red Flags to everyone that values America's
natural resources, her citizens" ability to responsibly harvest
those resources for the betterment and economic self-reliance and
independence. 'Fuel
buildup and fires' would not be such a threat if the actions of the
USDA Forest Service over the past two decades had not precipitated such
crisis situations. Had the lands under Forest Service control been
timbered by private companies, such fuel buildup and fires would not
have occurred. "Motorized
recreation" is not a "threat" to our forests! Where did
this idea come from, other than "his campaign"? "Loss
of open space" is a phrase that could have and likely did come from
either an IUCN (International Union for the Conservation of Nature) or
Nature Conservancy brochure/website. Our country is vast, from ocean to
ocean and border to disappearing border. There is no "threat"
to this "loss," as this is something perceived only by those
intending to implement The Wildlands Project. I've spent three decades
traveling America, both in my career and in my personal life. While the
larger "urban areas" are indeed growing, this very language
deception is decimating the heartland of America and "flyover
country." Why, the "rural cleansing" that has happened
during the past few decades has been engineered by the misinterpretation
of such as the "Endangered Species Act," which has done little
to nothing for species of any kind, other than to put many more species
in true peril! Open space is not a threat, and should not be touted as
such by Chief Bosworth. What can he be thinking? It cannot be that he is
thinking about the health of America's people and their economic
well-being, gained by both the recreational use of and the economic use,
planting, harvest and replanting of her resources. While
Alternative 7, at first glance, looked promising, its 'decommissioning
of 14.8 miles of existing roads' and 'prescribed burns' do nothing to
regain the health of the Siskiyou National Forest or the Biscuit Fire
area. Alternative 6
-- as printed in Volume I of the DEIS, The Biscuit Fire Recovery
Project, October 2003 -- the Maximum Salvage Alternative, is
my preferred alternative, due to its being the only Alternative that is
doing a real, concerted effort to clean and replant. 193 miles of
50' wide fuel treatment and replanting 36,918 areas in the IRA
(Inventoried Roadless Areas), among other planting and reseeding
activities, is the only Alternative that will help the forest
recover and keep this unnecessary and needless sort of 'fire event' from
occurring again. I
want my thoughts duly noted by the Forest Service: that even this
Alternative (6) is not enough -- that I believe, from many conversations
and study about such large forests and their health, that much more
timber harvesting is needed, not just 'salvage harvest.' I
also strongly recommend that the roads within the 'inventoried roadless
areas' be recommissioned as roads, reopened to both visitors of the
national forests and to the timber industry -- for responsible timber
projects and firefighting. It
is noticeably absent from Forest Service and 'environmental' and
'conservation' groups' documents and public statements, that trees --
like all people, plants and animals -- have life expectancies.
Trees do not 'live forever.' 'Old growth forests' do not simply exist in
perpetuity. It is neither realistic nor responsible to give
schoolchildren or their parents the wholly wrong idea that such is true.
In this public comment, I am hereby recommending that the Forest Service
contact Bruce Vincent of the Provider Pals program based in Libby,
Montana, to secure the experienced, responsible help that he and this
program can give to our forests and to the American people. http://www.providerpals.com/media/news/journaldoc.html Bruce
may be contacted at: ppals@libby.org
or 406-293-8822 The
Biscuit Fire area of the Siskiyou National Forest is a glaring symptom
of 'forest management practices' gone terribly wrong. Huge
artificially dense fuel loads on the forest floor, caused by the
LACK of responsible timber practices -- knowledgeable and caring
timber practices that would have kept any fire from becoming
catastrophic -- precipitated the massive destruction of this
fire. Another factor that made the Biscuit Fire so massively destructive
to people, trees, birds, animals, and water, was the removal
-- by vertical mulching or other means, or the outright closure
-- of many miles of forest roads. Such actions by the Forest
Service are consummate to 'arbitrary and capricious' denial of
responsible management of this National Forest area that is where the
Biscuit Fire raged, and others like it in many states. I
have included the official Department of Interior Bureau of Land
Management definition of 'vertical mulching'[4] for your perusal.
Please bear with me and read this definition, which, although it is
addressing an area in California, can and will be coming to other states
and federal lands: [4]Vertical
Mulching
- A high priority recovery need for the federally-listed desert tortoise
and other sensitive species occurring within the California Desert is
the restoration of unauthorized routes, or road reclamation (refer to
West Mojave Route Designation, Ord Mountain Pilot Unit, Biological
Resource Screening Components; Bureau of Land Management 1997). Such
restoration allows for the protection of large contiguous blocks of
habitat that are relatively unencumbered by vehicle use impacts and
related activities. Restoring unauthorized routes would
significantly reduce identified habitat fragmentation occurring within
designated tortoise critical habitat units and yield tremendous positive
benefits affecting recovery of this species. Of the 22 major threats to
the tortoise identified in recent research, ten would be significantly
reduced by restoring unauthorized roads and trails, including
the following: fire, off highway vehicle recreation, animal
collection, garbage and litter, handling and manipulation, invasive
weeds, noise, vandalism, predation (by ravens and similar subsidized
predators), and non off-highway vehicle recreation. The Barstow
Field Office of the Bureau of Land Management is currently seeking
support among potential cooperators to use "desert
tortoise habitat compensation" funds for road and trail restoration.
Such funds are occasionally generated, pursuant to guidelines in BLM's
Desert Tortoise Rangewide Plan, when habitat-impacting
projects are approved within the range of the tortoise that cannot
be fully mitigated on-site. In the past, these "habitat
compensation" funds have typically been used to acquire private
inholdings within designated tortoise critical habitat units.
Recently, however, the Barstow Field Office determined that compensation
funds generated by several large-scale projects would enable cooperating
agencies to protect/enhance a much larger amount of tortoise habitat
if these funds were used for route restoration, rather
than habitat acquisition. Both methods of offsite habitat
compensation are necessary for long-term recovery of the desert
tortoise and other sensitive species in certain critical habitat units,
and these options should be carefully evaluated on a case-by-case basis.
To accomplish both tortoise habitat restoration and route designation
objectives in critical habitat units, BLM staff have developed a
reclamation strategy commonly referred to as vertical mulching."
This
technique involves the placement of structure (live vegetation, rocks,
dead shrubs and "snags," bunch-grasses, and various woody
material) within the confines of the closed roadway surface, both on the
ground surface and in a vertical manner, designed to conform with
adjacent vegetation and terrain. Use
of this technique is further described below. Discussion:
Lessons learned by BLM over past decades have shown that route
designation cannot be effectively implemented by simply installing red
carsonite "closed to vehicle use" signs on or adjacent to
unauthorized routes of travel. Efforts must include encouraging vehicle
travel on designated open routes, and making designated closed routes
literally disappear into the landscape. To
begin this "disappearing act" decompaction and mulching
techniques must be applied to closed routes, extending at least to
the visual horizon, especially where the closed routes intersect
with other routes. The Barstow Field Office has demonstrated that
unauthorized roads and trails can be economically restored through use
of vertical mulching techniques. These techniques involve placement of
boulders and organic structure, such as live/dead and down vegetation,
within the disturbed soil portion of affected roadbeds. Only vegetation,
rock and woody structure native to the immediate closed route vicinities
are used. The estimated cost for restoring tortoise habitat using this
technique is $500 per acre, using current technology. The target
restoration areas consist of roads and trails that facilitate a
variety of anthropogenic impacts to designated desert tortoise critical
habitat. The specified collection and installation of mulching material
occurs under the supervision of a qualified natural resource
specialist, archeologist, biologist or technician, to ensure a
minimization of impacts to biological or cultural resources. Areas
adjacent to where route closure/rehabilitation is planned may
occasionally be used to gather dead vertical mulching material, in a
manner designed to avoid causing local dead and down habitat loss, yet
also accomplish restoration objectives. In no circumstances are shrubs
that shade animal burrows or that are located adjacent to cultural
resources, removed for use as mulching material. However, live and
dead vegetation from the immediate region, salvaged from land clearing
or road maintenance operations, may occasionally be used as mulching
material in such restoration projects. Memorandums
of understanding developed between land management agencies and local
transportation departments, regarding salvage and storage of native
material for this application, can facilitate large-scale projects. The
use of pitting, ripping, or other scarification techniques within the
confines of route or roadbed soil disturbance is sometimes necessary for
rapid site recovery. Such scarification is done with hand-tools or
through the use of heavy equipment and machinery (toothed rake, pitter,
or similar device pulled by a tractor). After scarification, the live or
dead vegetation is placed in a vertical fashion within the confines of
route or roadbed soil disturbance, in a manner designed to conform to
adjacent terrain and vegetation. The Barstow Field Office is able to
restore Mojave Desert habitats for about $500 per acre, due to relationships
and agreements it has in place with the California Conservation Corps
and other local young adult labor groups. Under an existing
agreement, the California Conservation Corps will match BLM contributed
project funds on a dollar for dollar basis. As a consequence, funds
generated by large habitat-disturbing projects could also qualify
for matching by the state of California, in the form of matching labor
funds available via the use of the California Conservation Corps.
Conclusion: Vertical mulching can be an economical technique for
restoring unauthorized roads and trails in desert tortoise and other
sensitive species" habitats. In some circumstances it may provide
much more "bang for the buck" when compared to traditional
forms of offsite compensation. Its application in selected areas of the
California Desert will reduce anthropogenic impacts to the listed desert
tortoise, contributing significantly to the recovery of this threatened
species. References: Bureau of Land Management (BLM), 1997, West Mojave
route designation, Ord Mountain pilot unit, biological resource
screening components. California Desert District BLM Office, Riverside,
California. http://www.blm.gov/nstc/resourcenotes/rn16.html
End
of definition. The
above definition contains highly questionable content -- from
the standpoint of 'protecting' or 'restoring' the health of any plant or
animal, endangered or otherwise. It certainly bids each reader to
consider: whether the actual intent is to remove people's ability to
visit, use in any way, or enter such lands to exercise responsible,
multiple use of these touted 'public lands.' How can responsible forest
practices take place in ever-increasing vast areas from which roads have
been 'vertically mulched'? How can any effective firefighting take place
in these areas? The answer, in my studied and thoughtful opinion, is,
"It can't." If
the Forest Service intends to pursue such human-unfriendly 'management
practices,' including the removal of vast swaths of America from the use
or visitation by the American People, it should immediately cease any
operation under the USDA (US Department of Agriculture) banner, because
trees are a renewable resource. That is why the Forest Service was
placed under the USDA in the first place, because timber is part of
agriculture. The
'ripple effect' of ash and mudflows clogging and damaging streams, loss
of both flora and fauna -- both endangered and not -- can only result in
the destruction of a beautiful National Forest. While
I am not a timber authority, I do know enough from my years of property
rights and resource providing research and activism to recognize poor or
nonexistent 'management practices' when I see them. This is of great
concern to me, as it rightfully should be to all Americans who value the
natural resources of America that their taxpayer dollars purchased. Julie
Kay Smithson 213
Thorn Locust Lane London,
Ohio (OH) 43140 740-857-1239
or propertyrights@earthlink.net
[1]
Idaho Statesman article: The nation's forest chief warns of four
threats to our national forests - Timber cutting, road building no
longer agency's primary mission [2]
USDA Forest Service News
Release No: RR-SNF-2/12/03 [3]
Ft. Worth, Texas, Audubon Society 'Sample Letter [4]
DOI / BLM 'Vertical Mulching' definition End of my official public comment. |
