The Ecology Center, Inc. 314 North First Street Missoula, mt 59802 (406) 728-5733 (406) 728-5779 fax




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The Ecology Center, Inc.
314 North First Street
Missoula, MT 59802
(406) 728-5733
(406) 728-5779 fax
ecocenter@wildrockies.org

July 26, 2005


Bryan Donner, Planning Team Leader
Tally Lake Ranger District

1335 Highway 93 West

Whitefish, Montana 59937


Transmitted via email--please acknowledge receipt!

Mr. Donner:

These are comments on the Valley Face Fuels Reduction project proposal (your June 24, 2005 letter), on behalf of the Ecology Center and the Alliance for the Wild Rockies.


The June 24, 2005 Proposal letter states that you have a “summary document” (Page 1) available upon request. Please send the Ecology Center a copy as soon as it’s available.


The FS is taking a cart-before-the-horse approach to this proposal. The Fire Plan mentioned in the Proposal letter is not ready, yet the Forest Service has already identified areas for fuel reduction (suspiciously, mostly logging) and the exact treatments to be used. The Proposal letter claims that expedited procedures are needed and will be used, yet this also predisposes the assumption that the Fire Plan will arrive at the same recommendations as the Forest Service did in its “watershed level analysis.” It’s clear the Forest Service is not really interested in collaboration with the wide range of public having a stake in management of this national forest, and will take administrative actions that will lead to more administrative delays, then blame it on the public who object to the FS’s predetermined outcome.


In proposing to protect private property and human health and safety from wildland fire destruction, we ask that you adopt the concepts of Community Protection Zone and Home Ignition Zones (Nowicki, 2002). The Community Protection Zone is an overlapping area where vegetation manipulation can provide opportunities for firefighters to protect other flammable features of a community (Nowicki, 2002). Most communities require treatment extending less than 400 meters (1312 feet) from the house (Id.).


This proposal purports to focus attention on a need to deal with the wildland fire issue, however it is not apparent that the proposal is to perform actions of the highest priority, which are dealing with vegetative conditions in the immediate vicinity of private homes and other structures. The proposed fuel reduction will make little difference when spotting from wildland fires miles away can cause a home to burn if fuel conditions right next to the home are not dealt with. Only in the context of the Forest Service (FS) doing firewise education programs for private landowners in the vicinity would such a proposal make sense.


The FS (Cohen, 1999) reviewed current scientific evidence and policy directives on the issue of fire in the wildland/urban interface and recommended an alternative focus on structure ignitability rather than extensive wildland fuel management:

The congruence of research findings from different analytical methods suggests that home ignitability is the principal cause of home losses during wildland fires… Home ignitability also dictates that effective mitigating actions focus on the home and its immediate surroundings rather than on extensive wildland fuel management.


[Research shows] that effective fuel modification for reducing potential WUI fire losses need only occur within a few tens of meters from a home, not hundreds of meters or more from a home. This research indicates that home losses can be effectively reduced by focusing mitigation efforts on the structure and its immediate surroundings. Those characteristics of a structure's materials and design and the surrounding flammables that determine the potential for a home to ignite during wildland fires (or any fires outside the home) will, hereafter, be referred to as home ignitability.

The evidence suggests that wildland fuel reduction for reducing home losses may be inefficient and ineffective. Inefficient because wildland fuel reduction for several hundred meters or more around homes is greater than necessary for reducing ignitions from flames. Ineffective because it does not sufficiently reduce firebrand ignitions (Cohen, 1999)


That research also recognizes “the imperative to separate the problem of the wildland fire threat to homes from the problem of ecosystem sustainability due to changes in wildland fuels” (Ibid).


Please consider that thinning can result in faster fire spread than in the unthinned stand. Graham, et al., 1999a point out that fire modeling indicates:

For example, the 20-foot wind speed1 must exceed 50 miles per hour for midflame wind speeds to reach 5 miles per hour within a dense Stand (0.1 adjustment factor). In contrast, in an open stand (0.3 adjustment factor), the same midflame wind speeds would occur at only a 16-mile-per-hour wind at 20 feet.


Graham, et al., 1999a also state:

Depending on the type, intensity, and extent of thinning, or other treatment applied, fire behavior can be improved (less severe and intense) or exacerbated.” … Fire intensity in thinned stands is greatly reduced if thinning is accompanied by reducing the surface fuels created by the cuttings. Fire has been successfully used to treat fuels and decrease the effects of wildfires especially in climax ponderosa pine forests (Deeming 1990; Wagel and Eakle 1979; Weaver 1955, 1957). In contrast, extensive amounts of untreated logging slash contributed to the devastating fires during the late 1800s and early 1900s in the inland and Pacific Northwest forests.


In their conclusion, Graham, et al., 1999a state:

Depending on intensity, thinning from below and possibly free thinning can most effectively alter fire behavior by reducing crown bulk density, increasing crown base height, and changing species composition to lighter crowned and fire-adapted species. Such intermediate treatments can reduce the severity and intensity of wildfires for a given set of physical and weather variables. But crown and selection thinnings would not reduce crown fire potential.


Also, Hessburg and Lemkuhl (1999) suggest that prescribed burning alone can be utilized in many cases—possibly here—where managers typically assume mechanical fuel reductions must be used. This is particularly important to state in these comments, since the FS seems to have already rejected this option for most areas without adequate scientific basis.


What is the species mix in the areas proposed for precommercial thinning? Is it possible that such areas would be the least expensive and most efficient areas to focus on for dealing with your expressed anxieties about tree species composition?


“Thinning” a forest would “artificialize” the forest ecosystem. Lodgepole pine is particularly subject to blowdown, once thinned. And any forest condition that is maintained through mechanical manipulation is not maintaining ecosystem function. The proposed management activities would not be integrated well with the processes that naturally shaped the ecosystem and resulted in a range of natural structural conditions. Thus, the need for standards guiding both the delineation of zones where “artificializing” fuel reduction actions may take place, and that also set snag and down woody debris retention amounts.


Veblen (2003) questions the premises the Proposal letter puts forth to justify the “uncharacteristic vegetation patterns” conclusions, leading to the perceived need to take management activities to alter vegetation patterns in response to fire suppression:

The premise behind many projects aimed at wildfire hazard reduction and ecological restoration in forests of the western United States is the idea that unnatural fuel buildup has resulted from suppression of formerly frequent fires. This premise and its implications need to be critically evaluated by conducting area-specific research in the forest ecosystems targeted for fuels or ecological restoration projects. Fire regime researchers need to acknowledge the limitations of fire history methodology and avoid over-reliance on summary fire statistics such as mean fire interval and rotation period. While fire regime research is vitally important for informing decisions in the areas of wildfire hazard mitigation and ecological restoration, there is much need for improving the way researchers communicate their results to managers and the way managers use this information.


In response to this scientific concern, we ask that the FS acknowledge the limitations of its fire history methodology and disclose if it relies upon summary fire statistics such as mean fire interval and rotation period, or disclose just what the data is it’s relying upon.


In claiming that the proposal addresses “forest health” the FS is misplaces the threats instead of correctly identifying the true threats to watershed health. The Western Montana Level I Bull Trout Team (Riggers et al., 2001) state:

(T)he real risk to fisheries is not the direct effects of fire itself, but rather the existing condition of our watersheds, fish communities, and stream networks, and the impacts we impart as a result of fighting fires. Therefore, attempting to reduce fire risk as a way to reduce risks to native fish populations is really subverting the issue. If we are sincere about wanting to reduce risks to fisheries associated with future fires, we ought to be removing barriers, reducing road densities, reducing exotic fish populations, and re-assessing how we fight fires. At the same time, we should recognize the vital role that fires play in stream systems, and attempt to get to a point where we can let fire play a more natural role in these ecosystems.


The biologists emphasize, “the importance of wildfire, including large-scale, intense wildfire, in creating and maintaining stream systems and stream habitat.” The biologists continue “in most cases, proposed projects that involve large-scale thinning, construction of large fuel breaks, or salvage logging as tools to reduce fuel loading with the intent of reducing negative effects to watersheds and the aquatic system are largely unsubstantiated.” The biologists point out that logging, thinning (as now proposed) and fire suppression (foreseeable based upon the Proposal letter) can have harmful effects on watersheds (Id.). We ask that the FS explicitly respond to Riggers et al., 2001 in your subsequent NEPA document.


Even ponderosa pine forests have been found to originate in stand replacing fire events (Arno et al. 1995).


Since fire exclusion is identified as a culprit, the Flathead NF needs to take a hard look at its fire policies. The development of approved fire management plans in compliance with the Federal Wildland Fire Policy was the number one policy objective intended for immediate implementation in the Implementation Action Plan Report for the Federal Wildland Fire Management Policy and Program Review. In general, the FS lags far behind other federal land management agencies that have already invested considerable amounts of time, money, and resources to implement the Fire Policy. Continued mismanagement of national forest lands and FS refusal to fully implement the Fire Policy puts wildland firefighters at risk if and when they are dispatched to wildfires. This is a programmatic issue, one that the current Forest Plan does not adequately consider. Please see Ament (1997) as comments on this proposal, in terms of fire policy and Forest Planning.


The Northern Region Overview identifies fire suppression as a problem for development of western larch type old growth, yet the Proposal letter outlines more of the same kind of management that would prevent natural development of western larch type old growth. Where do you get the idea that “management” actions can replace natural processes, and result in healthy, intact ecosystems?


The EA or EIS must disclose the ecological or economic cumulative impacts of fire suppression. A true no-action alternative would involve no fire suppression activities, since there’s never been adequate NEPA on the Flathead NF’s fire suppression policy.


Many adverse consequences to soil, ecological processes, wildlife, and other elements of the natural environment are associated with logging, including thinning. (Ercelawn, 1999; Ercelawn, 2000.) For example: “Salvage or thinning operations that remove dead or decayed trees or coarse woody debris on the ground will reduce the availability of forest structures used by fishers and lynx.” (Bull et al., 2001.) How will logging do anything but exacerbate the problem with too little thermal cover for big game?


For every project proposal, it is important that the results of past monitoring be incorporated into planning. All Interdisciplinary Team Members should be familiar with the results of all past monitoring pertinent to the project area, and any deficiencies of monitoring that have been previously committed to. For that reason, we expect that the following be included in the NEPA documents or project files:

  • A list of all past projects (completed or ongoing) implemented in the proposed project area watersheds.

  • The results of all monitoring done in the project area as committed to in the NEPA documents of those past projects.

  • The results of all monitoring done in the proposed project area as a part of the Forest Plan monitoring and evaluation effort.

  • A description of any monitoring, specified in those past project NEPA documents or the Forest Plan for proposed project area, which has yet to be gathered and/or reported.


Please disclose the names of all other past logging projects (implemented during the life of the Forest Plan) whose analysis area(s) encompass the areas to be logged under this proposal. Please disclose if the FS has performed all of the monitoring and mitigation required or recommended in any NEPA documents, and the results of the monitoring.


The FS must disclose if the project area is within the range of any threatened, endangered, proposed, sensitive, or management indicator species, and how those species may use the specific areas now proposed for “treatment.” Please disclose the locations of all designated or proposed critical habitat for ESA-listed species, in relation to the project area.


The fact that the Flathead NF has not monitored the population trends of its old-growth management indicator species (MIS) as required by the Forest Plan bears important mention here. The Flathead NF has failed to insure viability of MIS and TES species to date. Unfortunately, region-wide the FS has failed to meet Forest Plan old-growth standards, does not keep accurate old-growth inventories, and has not monitored population trends in response to management activities as required by Forest Plans and NFMA.


For the proposal to be consistent with the Forest Plan, enough habitat for viable populations of old-growth dependent wildlife species is needed over the landscape. Considering potential difficulties of using population viability analysis at the project analysis area level (Ruggiero, et. al., 1994), the cumulative effects of carrying out multiple projects simultaneously across the Flathead NF makes it imperative that population viability be assessed at least at the forestwide scale (Marcot and Murphy, 1992). Also, temporal considerations of the impacts on wildlife population viability from implementing something with such long duration as a Forest Plan must be considered (id.) but this has never been done by the Flathead NF. It is also of paramount importance to monitor population during the implementation of the Forest Plan in order to validate assumptions used about long-term species persistence i.e., population viability (Marcot and Murphy, 1992; Lacy and Clark, 1993).


State-of-the-art conservation biology and the principles that underlie the agency’s policy of “ecosystem management” dictate an increasing focus on the landscape-scale concept and design of large biological reserves accompanied by buffer zones and habitat connectors as the most effective (and perhaps only) way to preserve wildlife diversity and viability (Noss, 1993).


The FS has stated: “Well distributed habitat is the amount and location of required habitat which assure that individuals from demes,2 distributed throughout the population’s existing range, can interact. Habitat should be located so that genetic exchange among all demes is possible.” (Mealey 1983.)


The FS has acknowledged that viability is not merely a project area consideration, that the scale of analysis must be broader:

Population viability analysis is not plausible or logical at the project level such as the scale of the Dry Fork Vegetation and Recreation Restoration EA. Distributions of common wildlife species as well as species at risk encompass much larger areas than typical project areas and in most cases larger than National Forest boundaries. No wildlife species that presently occupy the project area are at such low numbers that potential effects to individuals would jeopardize species viability. No actions proposed under the preferred alternative would conceivably lead to loss of population viability. (Lewis and Clark NF, Dry Fork EA Appendix D at p. 9.)


The FS should firmly establish that the species that exist, or historically are believed to have been present in the analysis area are still part of viable populations. Since Forest Plan monitoring efforts have failed in this regard, it must be a priority for project analyses. Identification of viable populations is something that must be done at a specific geographic scale. The analysis must cover a large enough area to include a cumulative effects analysis area that would include truly viable populations. Analysis must identify viable populations of MIS, TES, at-risk, focal, and demand species of which the individuals in the analysis area are members in order to sustain viable populations.


The context of the Flathead NF’s management of native forests—within the Northern Region—is important to keep in mind; unfortunately, region-wide the FS has failed to meet Forest Plan old-growth standards, does not keep accurate old-growth inventories, and has not monitored population trends in response to management activities as required by Forest Plans and NFMA (Juel, 2003).


Please disclose how stands to be logged compare to Forest Plan or Regional old-growth criteria. In order to disclose such information, please provide all the details, in plain language, of these areas’ forest characteristics (the various tree components’ species, age and diameter of the various tree components, canopy closure, snag density by size class, amounts of down logs, understory composition, etc.).


The FS has failed to cite any evidence that its managing for old growth habitat strategy (i.e., logging old growth or logging to facilitate development of old growth) will improve old growth species’ habitat over the short-term or long-term. In regards to the FS’s “managing for old growth habitat” theory:

(T)here is the question of the appropriateness of management manipulation of old-growth stands… Opinions of well-qualified experts vary in this regard. As long term results from active management lie in the future – likely quite far in the future – considering such manipulation as appropriate and relatively certain to yield anticipated results is an informed guess at best and, therefore, encompasses some unknown level of risk. In other words, producing “old-growth” habitat through active management is an untested hypothesis.


(Pfister et al., 2000, pp. 11, 15 emphasis added). Furthermore the FS never discloses if the areas “treated” will retain characteristics meeting Forest Plan or Regional old growth criteria—and if they won’t, how they will at some specified time in the future. There is no scientific certainty in the FS’s approach.


The FS has admitted that the use of database habitat information, as the Flathead NF relies upon for project analyses, is suspect: “Habitat modeling based on the timber stand database has its limitations: the data are, on average, 15 years old; canopy closure estimates are inaccurate; and data do not exist for the abundance or distribution of snags or down woody material…" (U.S. Forest Service, 2000c). How similar in quality to the IPNF’s is the Flathead NF’s database information? What wildlife analysis or modeling to be used relies on such databases? On average, how old is the Flathead NF’s database information? Please indicate the Flathead NF databases’ levels of reliability, citing verification studies.


The continued fragmentation of the Flathead NF is a major ongoing concern. It is documented that edge effects occur 10-30 meters into a forest tract (Wilcove et al., 1986). The size of blocks of interior mature and old-growth forest that existed historically before management (including fire suppression) was initiated must be compared to the present condition. Again, this should be a landscape ecology analysis that looks at the larger picture of the fragmentation of habitat in surrounding concentric circles.


The FS has still not sufficiently dealt with the issue of fragmentation, road effects, and past logging on old-growth species’ habitat. The EA/EIS must disclose the degree to which edge effects on old growth species’ habitat exist, and how much total edge effect would be increased, by the alternatives. Cumulative effects on old-growth habitat and on old-growth associated species include increased fragmentation, reduced older forest patch sizes, increased high-contrast edge, reduced availability of interior habitat, and decreased forested connectivity. Such effects would reduce the ability to provide for the habitat needs of old-growth associated species for decades to come following implementation of the project and other activities in the project area.


Mills (1994) points out the necessity of considering habitat fragmentation and current landscape pattern, caused by past logging and road building, for wildlife movements and therefore viability. Mills points out that the FS’s use of the term “viable” refers to habitat characteristics, not population dynamics. Mills goes on to explain the range of parameters that must be used to make a scientifically sound assessment of the viability of wildlife species. Population dynamics refers to persistence of a population over time—which is key to making predictions about population viability. Population dynamics include assessing population size, population growth rate, and linkages to other populations and must be included in a scientifically sound Population Viability Analysis (hereafter “PVA”). Ruggiero, et. al. (1994) also point out that a sound PVA must utilize measures of population dynamics.


Please include in your analysis the possible effects of noxious weed introduction on Sensitive plant populations and other components of biodiversity. Please include in the analysis the results of monitoring of noxious weed infestation from past management actions in the Forest.


One of the biggest problems with the FS’s failure to deal forthrightly with the noxious weed problem on a forestwide basis is that the long-term costs are never adequately disclosed or analyzed. The public is expected to continuously foot the bill for noxious weed treatments—the need for which increases yearly as the Flathead NF continues the large-scale propagation of weeds, and fails to monitor the effectiveness of all its noxious weed treatment plans to date. There is no guarantee that the money needed for the present management direction will be supplied by Congress, no guarantee that this amount of money will effectively stem the growing tide of noxious weed invasions, no accurate analysis of the costs of the necessary post-treatment monitoring, and certainly no genuine analysis of the long-term costs beyond those incurred by site specific weed control actions.


We request the FS adopt the Forest Restoration Assessment Principles found within the Forest Restoration Principles and Criteria (DellaSala, et al., 2003) as a screen for all proposed actions beyond the Community Protection Zone.


Our goals for the area include fully functioning stream ecosystems that include healthy, resilient populations of native trout. The highest priority management actions in the project area are those that remove impediments to natural recovery. We request the FS design a restoration/access management plan for project area streams that will achieve recovery goals. The task of management should be the reversal of artificial legacies to allow restoration of natural, self-sustaining ecosystem processes. If natural disturbance patterns are the best way to maintain or restore desired ecosystem values, then nature should be able to accomplish this task very well without human intervention (Frissell and Bayles, 1996).


Please utilize the NEPA process to clarify any roadless boundary issues. It is not adequate to merely accept previous, often arbitrary roadless inventories—unroaded areas adjacent to inventoried areas were often left out. Additionally, there is a lot of public support for adding unroaded areas as small as 1,000 acres in size to the roadless inventory.


We request a careful analysis of the impacts to fisheries and water quality, including considerations of sedimentation, increases in peak flow, channel stability, risk of rain-on-snow events, and increases in stream water temperature. Please disclose the locations of seeps, springs, bogs and other sensitive wet areas, and the effects on these areas of the project activities. Where livestock are permitted to graze, we ask that you assess the present condition and continue to monitor the impacts of grazing activities upon vegetation diversity, soil compaction, streambank stability and subsequent sedimentation.


Please disclose in the NEPA document the results of up-to-date monitoring of fish habitat and watershed conditions, as required by the Forest Plan.


It is extremely important the FS disclose the environmental baseline for watersheds. Generally, this means their condition before development or resource exploitation was initiated. For example, the baseline condition of a stream means the habitat conditions for fish and other aquatic species prior to the impacts of road building, logging, livestock grazing, etc. Therefore, proper disclosure of baseline conditions would mean estimates of stream stability, pool frequency conditions, water temperature range—essentially the values of Riparian Management Objectives along with such parameters as sediment levels. When such information is provided, comparison with the current conditions (after impacts of development) will aid in the assessment of cumulative effects of all alternatives.


We ask that the FS utilize the Roads Analysis Process and analyze travel management, including road obliteration, and include an alternative that would not leave any deferred or outstanding maintenance needs/BMP upgrades in the analysis area. Roads often have devastating impacts on water quality and fish habitat by increasing landslides, erosion, and siltation of streams. Roads also fragment forests and degrade or eliminate habitat for species that depend on remote landscapes, such as grizzly bears, wolves, and other large, wide-ranging predators (Trombulak and Frissell 2000).


Also on the subject of roads, it is clear that the FS has already rejected the idea of obliterating unneeded roads from the landscape—without allowing the public to participate in the Roads Analysis Process—and sees building new roads as the only way to manage the area. The FS thus reveals that it hasn’t changed from a resource extraction agency into one that recognizes the processes that define truly healthy ecosystem function and integrity.


The Proposal letter at p. 6 reveals that “temporary” roads built upon “existing, historic road templates” is a way for the FS to claim that roads are temporary when in fact there are undisclosed FS plans (i.e., a hidden agenda) for keeping their “templates” on the land permanently.


The EA/EIS must contain a discussion of the connection between the major individual management actions carried out in the past, and the environmental harms or benefits of each of those actions.


The EA/EIS must explicitly state the funding mechanisms that would be used to carry out all the post-logging slash (“fuel”) treatment. How certain would each funding source be, i.e., how likely is it that slash could remain untreated? Also, the EA/EIS must state the expected time frame for treating all slash (nor for other “fuel” treatments, such as prescribed burning outside logged areas).


It is erroneous to assume that BMPs will assure water quality will be maintained, if present conditions are in many locations already in violation of the standards. The failure of BMPs is obviously implicated in the scientific literature. Beschta et al. (2004) state:

It is perhaps widely accepted that “best management practices” (BMPs) can reduce damage to aquatic environments from roads. Time trends in aquatic habitat indicators indicate, however, that BMPs fail to protect salmonid habitats from cumulative degradation by roads and logging (Espinosa et al. 1997.) Ziemer and Lisle (1993) note a lack of reliable data showing that BMPs are cumulatively effective in protecting aquatic resources from damage.


The FS should always include an alternative that removes or fixes all the roads having design flaws, are otherwise contributing to soil and watershed problems, or are not needed for foreseeable management activities. The EA/EIS must consider an alternative that gets the streams in the project area to meet RMOs. The public needs to know how much it costs to manage these watersheds up to acceptable conditions.


Among other things, we are concerned that project activities will accelerate soil erosion, increase soil compaction, and degrade soil productivity. Prescribed fires and mechanical treatments have the potential to adversely affect soil productivity. NFMA requires the FS to “not allow significant or permanent impairment of the productivity of the land.” [36 C.F.R. § 219.27(a)(1).] NFMA requires the Forest Service to “ensure that timber will be harvested from National Forest System lands only where—soil, slope, or other watershed conditions will not be irreversibly damaged.” [16 U.S.C. 1604 (g)(3)(E).]


The Sheep Creek Salvage FEIS (USDA Forest Service, 2005a) states at p. 173:

Noxious weed presence may lead to physical and biological changes in soil. Organic matter distribution and nutrient flux may change dramatically with noxious weed invasion. Spotted knapweed (Centaurea biebersteinii D.C.) impacts phosphorus levels at sites (LeJeune and Seastedt, 2001) and can hinder growth of other species with allelopathic mechanism. Specific to spotted knapweed, these traits can ultimately limit native species’ ability to compete and can have direct impacts on species diversity (Tyser and Key 1988, Ridenour and Callaway 2001).

Please disclose how the productivity of the land been affected in the project area and forestwide due to noxious weed infestations, and how that situation is expected to change in the coming years and decades.


The FS has essentially admitted that it is in the dark as far as doing scientific research on soil productivity changes following management activities. In response to comments on the Black Ant Salvage DEIS, Lewis & Clark NF (USDA Forest Service, 2002a) states:

Soil Quality Standards “provide benchmark values that indicate when changes in soil properties and soil conditions would result in significant change or impairment of soil quality based on available research and Regional experience” (Forest Service Manual 2500, Region 1 Supplement 2500-99-1, Chapter 2550 – Soil Management, Section 2554.1).


A formal research study, the “Long Term Soil Productivity Study,” is currently being conducted by the Research Branch of U.S. Department of Agriculture, Forest Service to validate these soil quality standards.


The Forest Management Handbook at FSH 2509.18 directs the FS to do validation monitoring to “Determine if coefficients, S&Gs, and requirements meet regulations, goals and policy” (2.1 – Exhibit 01). It asks what we are asking: “Are the threshold levels for soil compaction adequate for maintaining soil productivity? Is allowing 15% of an area to be impaired appropriate to meet planning goals?” The Ecology Center recently asked the Northern Region if they have ever performed this validation monitoring of its 15% Standard, in their February 26, 2002 Freedom of Information Act request to the Regional Forester, requesting:

The Forest Management Handbook at FSH 2509.18 provides the Forest Service with examples of validation monitoring to “Determine if coefficients, S&Gs, and requirements meet regulations, goals and policy.” It asks “Are the threshold levels for soil compaction adequate for maintaining soil productivity? Is allowing 15% of an area to be impaired appropriate to meet planning goals?” We request all documentation of validation monitoring by the Forest Service in the Northern Region that answers those two questions.


The Northern Region office’s reply letter stated that there is no documentation that responds to this request. If the Flathead NF is aware of any new or other documentation that would respond to this request, we ask that you please disclose it to us now.


Harvey et al., 1994 state:

The ...descriptions of microbial structures and processes suggest that they are likely to provide highly critical conduits for the input and movement of materials within soil and between the soil and the plant. Nitrogen and carbon have been mentioned and are probably the most important. Although the movement and cycling of many others are mediated by microbes, sulfur phosphorus, and iron compounds are important examples.


The relation between forest soil microbes and N is striking. Virtually all N in eastside forest ecosystems is biologically fixed by microbes... Most forests, particularly in the inland West, are likely to be limited at some time during their development by supplies of plant-available N. Thus, to manage forest growth, we must manage the microbes that add most of the N and that make N available for subsequent plant uptake. (Internal citations omitted.)


Please disclose what inventory or monitoring information of soil functioning indicators the Forest has, including lichens, fungi, insects, etc. since these can and do define existing and probable future forest conditions, especially related to natural recovery following fire. Lichens in particular, while capturing atmospheric nitrogen for later release to higher plants and trees, are sensitive indicators of atmospheric and ground conditions and cannot be ignored in attempts at ecosystem management. Fungi and insects indicate and largely drive forest condition. Those that act as antagonists or parasites to destructive forms like root disease fungi or bark beetles should be recognized, as should tree pathogens and pests.

Enumeration of and monitoring of specific small, non-game birds and animal populations that are important in keeping destructive insect populations at low levels must also be disclosed.


The rationale and analysis of this proposal must look at the forest as an ecosystem with interrelationships coequal to timber production. Please use the ecosystem management approach to assess fungal and insect organisms as capable of operating in a self-regulatory manner and exist as beneficial organisms within the project area. Some species of trees, native insects, and disease organisms are often described by the FS as “invasive” or somehow bad for the ecosystem. Such contentions that conditions are somehow “unnatural” runs counter to more enlightened thinking on such matters. For example, Harvey et al., 1994 state:

Although usually viewed as pests at the tree and stand scale, insects and disease organisms perform functions on a broader scale.


…Pests are a part of even the healthiest eastside ecosystems. Pest roles—such as the removal of poorly adapted individuals, accelerated decomposition, and reduced stand density—may be critical to rapid ecosystem adjustment


…In some areas of the eastside and Blue Mountain forests, at least, the ecosystem has been altered, setting the stage for high pest activity (Gast and others, 1991). This increased activity does not mean that the ecosystem is broken or dying; rather, it is demonstrating functionality, as programmed during its developmental (evolutionary) history.


The FS often makes a case for logging as a way to reduce insect and disease damage to timber stands. As far as we are aware, the FS has no empirical evidence to indicate its “treatments” for “forest health” decrease, rather than increase, the incidence of insects and diseases in the forest. Since the FS doesn’t cite research that proves otherwise in its NEPA analyses, we can only conclude that “forest health” discussions are unscientific and biased toward logging as a “solution.” Please consider the large body of research that indicates logging, roads, and other human caused disturbance promote the spread of tree diseases and insect infestation.


For example, multiple studies have shown that annosus root disease (Heterobasidion annosum, formerly named Fomes annosus), a fungal root pathogen that is often fatal or damaging for pine, fir, and hemlock in western forests, has increased in western forests as a result of logging (Smith 1989). And researchers have noted that the incidence of annosus root disease in true fir and ponderosa pine stands increased with the number of logging entries (Goheen and Goheen 1989). Large stumps served as infection foci for the stands, although significant mortality was not obvious until 10 to 15 years after logging (Id.).


The proportion of western hemlock trees infected by annosus root disease increased after precommercial thinning, due to infection of stumps and logging equipment wounds (Edmonds et al. 1989, Chavez, et al. 1980).


Armillaria, a primary, aggressive root pathogen of pines, true firs, and Douglas-fir in western interior forests, spreads into healthy stands from the stumps and roots of cut trees (Wargo and Shaw 1985). The fungus colonizes stumps and roots of cut trees, then spreads to adjacent healthy trees. Roots of large trees in particular can support the fungus for many years because they are moist and large enough for the fungus to survive, and disease centers can expand to several hectares in size, with greater than 25% of the trees affected in a stand (id.). Roth et al. (1980) also noted that Armillaria was present in stumps of old-growth ponderosa pine logged up to 35 years earlier, with the oldest stumps having the highest rate of infection.


Filip (1979) observed that mortality of saplings was significantly correlated to the number of Douglas-fir stumps infected with Armillaria mellea and laminated root rot (Phellinus weirii). McDonald, et al. (1987) concluded the pathogenic fungus Armillaria had a threefold higher occurrence on disturbed plots compared to pristine plots at high productivity sites in the Northern Rockies. Those authors also reviewed past studies on Armillaria, noting a clear link between management and the severity of Armillaria-caused disease.


Morrison and Mallett (1996) observed that infection and mortality from the root disease Armillaria ostoyae was several times higher in forest stands with logging disturbance than in undisturbed stands, and that adjacent residual trees as well as new regeneration became infected when their roots came into contact with roots from infected stumps.


Precommercial thinning and soil disturbance led to an increased risk of infection and mortality by black-stain root disease (Leptographium wageneri) in Douglas-fir, with the majority of infection centers being close to roads and skid trails (Hansen et al. 1988). Also another Black-stain root disease (Verticicladiella wagenerii) occurred at a greater frequency in Douglas-fir trees close to roads than in trees located 25 m or more from roads (Hansen 1978). Witcosky et al. (1986) also noted that precommercially thinned stands attracted a greater number of black-stain root disease insect vectors.


Complex interactions involve mechanical damage from logging, infestation by root diseases, and attacks by insects. Aho et al. (1987) saw that mechanical wounding of grand fir and white fir by logging equipment activated dormant decay fungi, including the Indian paint fungus (Echinodontium tinctorium).


Trees stressed by logging, and therefore more susceptible to root diseases are, in turn, more susceptible to attack by insects. Goheen and Hansen (1993) reviewed the association between pathogenic fungi and bark beetles in coniferous forests, noting that root disease fungi predispose some conifer species to bark beetle attack and/or help maintain endemic populations of bark beetles.


Goheen and Hansen (1993) observed that live trees infected with Laminated root rot (Phellinus weirii) have a greater likelihood of attack by Douglas-fir beetles (Dendroctonus pseudotsugae). Also, Douglas-fir trees weakened by Black-stain root disease (Leptographium wageneri var. pseudotsugae) are attacked and killed by a variety of bark beetle species, including the Douglas-fir bark beetle (D. pseudotsugae) and the Douglas-fir engraver (Scolytus unispinosis) (id.).


The root disease Leptographium wageneri var. ponderosum predisposes ponderosa pine to several bark beetle species, including the mountain pine beetle (D. ponderosae) and the western pine beetle (D. brevicomis) (Goheen and Hansen 1993).


A variety of root diseases, including black-stain, Armillaria, and brown cubical butt rot (Phaeolus schweinitzii), predispose lodgepole pine to attack by mountain pine beetles in the interior west. The diseases are also believed to provide stressed host trees that help maintain endemic populations of mountain pine beetle or trigger population increases at the start of an outbreak (Goheen and Hansen 1993).


Grand and white fir trees in interior mixed-conifer forests have been found to have a high likelihood of attack by the fir engraver (Scolytus ventralis) when they are infected by root diseases, such as laminated root rot, Armillaria, and annosus (Goheen and Hansen 1993).


More western pine beetles (Dendroctonus breviformis) and mountain pine beetles (D. ponderosae) were captured on trees infected by black-stain root disease (Ceratocystis wageneri) than on uninfected trees (Goheen et al. 1985). The two species of beetle were more frequently attracted to wounds on trees that were also diseased than to uninfected trees. They also noted that the red turpentine beetle (Dendroctonus valens) attacked trees at wounds, with attack rates seven-to-eight times higher on trees infected with black-stain root disease than uninfected trees. Spondylis upiformis attacked only wounded trees, not unwounded trees (Id.).


It has been well-established that site-specific Biological Evaluations (BEs) or Biological Assessments (BAs) must be prepared for all actions such as this. Further, the Forest Service Manual requires that BEs/BAs consider cumulative effects. The Forest Service Manual states that project BEs/BAs must contain “a discussion of cumulative effects resulting from the planned project in relationship to existing conditions and other related projects” [FSM 2672.42(4)]. “Existing conditions” obviously are the current conditions of the resources as a result of past actions.


It is our intention that you include in the record and review all of the literature and other incorporated documents we’ve cited herein, and explicitly respond in writing to the scientific information as it applies to the project proposal.
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