MFMU SCOPING COMMENTS
Jimmy J. DeHerrera, District Ranger
Robert-Wedge Canyon Post Fire Project
Box 190340
Hungry Horse, MT 59919
Dear Mr.
DeHerrera:
First, after all the effort that the Flathead
National Forest and the approximately 90 citizen volunteers put into
the collaboration effort, it would seem appropriate if you would
have explained just how
you used that input in the design
of the proposed action, especially how that input helped to
formulate anything different that what your team was already
planning.
Second, we want to object to the lack of
information provided to the public to provide a basis for making
reasonable and informed comment on the proposal.
The collaboration group, nor the Proposed Action package
provided no maps or summaries of what the salvage opportunities were
in acres or volumes of potentially merchantable wood for suitable
and unsuitable Management Areas.
How are people going to make comments on the adequacy of the
proposal when such fundamental information is lacking?
The collaboration process for this project
clearly demonstrated that road closures and decommissioning is a
huge public issue. Previous
project maps have clearly shown the existing situation with historic
roads as roads that were reclaimed by natural re-vegetation or road
reclamation by pre-amendment 19 projects.
Roads previously decommissioned as a result of amendment 19
were clearly shown as well as the roads being proposed for
decommissioning. Why is
it now the maps no longer show which roads have previously been
decommissioned, but are instead blended in with “historic
roads”? Why is
it that this project no longer clearly shows which roads are being
proposed for “decommissioning?
How do you expect to get informed comments from the public on
what is likely the most controversial issue when the information
concerning that decision is absent or obscured with maps that do not
clearly disclose the issue being decided?
Snag
Down Wood and Fuels Reduction Issues:
The Forest Service provided no summary of
basic information on specific issues and no opportunity for
exchange of information among all the people in the collaboration
exercise. As a result, people were immediately required to discuss
issues that most participants had little factual knowledge. The Forest Plan Standards for snags and down wood is an
example. Most people would agree that following the standards should
be required. How
many people would agree if they knew that the standards set by
Amendment 21 prescribes over 25 tons/acre of down wood, a
prescription that by definition provides a high fire hazard and high
resistance to control as the desired condition on all acres?
We have an existing situation where the Forest
is blanketed with vast expanses of
wild stands choked with dead and down trees providing optimal
conditions for catastrophic fires as we have experienced..
Inventory data from this undesirable situation was used as
the basis for amending the Forest Plan snag and down wood standards
for suitable areas to more closely provide “natural conditions”.
Here we have the single biggest problem on National Forests,
an issue National in scope, requiring special legislation from
Congress to attempt to get the Forest Service to take action, and
the Flathead National Forest prescribes this condition in suitable
management areas even on areas already burned.
What should have been done was to evaluate the
burned areas in terms of projecting the fuel loading to be generated
by the existing burned stands within 2 decades if no treatment was
done. Then, especially in the areas suitable for timber
management, a salvage objective should be established to reduce the
future fuel contributed by existing stands to well below 25 tons
/acre where standing merchantable trees can be economically
salvaged. Leaving
case hardened sound snags just to meet an ill-conceived rule
doesn’t provide significant feeding
or nesting habitat for cavity nesting birds it only reduces
potential revenues and increases future fire severity and costs.
The decayed, broken, and defective wood that does provide
good habitat will be left in all salvage areas in any case.
Potential salvage areas should be evaluated on a landscape
scale to evaluate effectiveness of fuel reduction balanced against
the need to leave valuable wood for bird snags.
There is no scientific data that shows that large standing
and down dead wood was ever uniformly or continuously distributed
over the landscape. It
is well within the natural range of variability to have some areas
that don’t have the “ideal” number of large snags and fuel
reduction areas should be well below the ideal snag and dead wood
habitat. Not only are
there thousands of acres with excess snags and down wood adjacent to
potential harvest areas, there is nearly always plenty of those
components left when salvaging merchantable wood.
Even stumps of harvested trees provide excellent feeding
habitat and speed the decomposition process to replace decayed wood
burned by the fire and thus provides immediate benefits to all
wildlife (including bears) that forage on organisms in decayed wood.
Salvage
Issue: With
no specific data provided on what and where the salvage
opportunities actually were, no information on the map as to
previously regenerated areas in relation to proposed salvage,
it is difficult to make informed comment on the adequacy of
the salvage proposal. From
the data summaries provided at the collaboration meetings that did
not summarize any of the data by suitable/unsuitable, we can
piece together an estimate that approximately 26,145 acres of burn
contained merchantable timber stands.
About 18,000 acres were suitable timberlands where 7,500
acres had been previously regenerated.
A proposal that appears to leave more than half of all the
merchantable timber in the suitable management areas and all but a
small fraction of the merchantable timber in unsuitable management
areas to fall down and fuel future fires is inadequate in responding
to the purpose of the project.
Roadless
Areas: Inventoried
roadless areas were by law evaluated in the existing Forest Plan and
portions of those inventoried areas recommended for wilderness
classification and other portions allocated to continued roadless
management with small portions recommended for sustained yield
timber management. There
is no good reason why roadless logging methods (the logging
helicopters will be right there) couldn’t be used in the
unsuitable roadless management areas to salvage high value stands
and especially where salvage would provide strategic fuel breaks
ideally providing connectivity to fuel breaks in suitable areas for
the future. A
roadless salvage operation would actually benefit restoration by
getting some wood (unmerchantable tops) down on the ground in
severely burned areas to retard overland flow, provide sediment
traps, and enhance regeneration of desired species.
Logging
Systems: There
appears to be an excessive amount of helicopter logging.
The use of helicopters at least gets wood to the mill, but
there is a huge tradeoff in income to the US Treasury, potential KV
collections that could make significant contributions to other
restoration costs, and to counties.
The more area that is helicopter logged, the less opportunity
for local loggers and local wages and income.
There is lots of opportunities to extend existing roads with
temporary roads, roads built of snow in the winter, and more use of
light on the land mechanical harvesters and forwarders to reach more
area from existing roads and new temporary roads.
Please look for those opportunities not only to change
proposed helicopter to ground system but provide for more areas than
the initial proposal in the Decision document so that additional
areas can be salvaged.
Access
Management: Montanans
For Multiple Use current lawsuit explains why we believe the
continued implementation of Amendment 19 is illegal, not in the
public interest, and contrary to good resource stewardship and
common sense. Nevertheless
the Flathead National Forest evidently believes destruction of the
transportation system in suitable timberlands is the right thing to
do because we know of no efforts being made by the FNF to suspend
A-19 for emergency projects such as this one or pending the outcome
of the bear population recovery study.
Perhaps
you believe we should commend you for proposing less than the
draconian “worst case scenario of A-19” depicted for the areas.
We cannot accept any additional decommissioning because it is
just plain wrong. In
addition “the moving window” analysis seems to be moving to
ridicules levels. For
example, as part of the 1996 Wedge Canyon Timber sale decision, 36
miles of road were destroyed and
18 miles closed year long, including the western segment of
road 907 which would have provided immediate access to the start of
the Wedge Canyon fire and is very likely the reason the fire escaped
containment and eventual control. Six more miles of road 907 was
closed with tank trap berms that not even a 4x4 pumper truck could
negotiate. Allegedly
at that time the decision brought that area into compliance with
grizzly standards and objectives of Amendment 19.
Why is it that now almost all the rest of the road would have
to be “decommissioned” to meet A-19?
It is obvious that the “rules” for determining grizzly
road density must have change dramatically in the last 5-6 years
with no public notice or process for changing standards.
Recreation:
Recreation was addressed in several of the collaborative
groups. Although the
proposed action did not directly address recreation, the access
restrictions proposed certainly affect recreation.
For example, two miles or more of Road 9805 are apparently
proposed for closure from the trail to Hornet Lookout down to Teepee
Creek road 907. This
blocks access to Teepee Creek for most folks.
Instead, Road 907and road 9805 should be seasonally open to
provide a recreational route during the summer.
Driving for pleasure and fishing are recreational pursuits
that are in the most demand on
National Forests. There
should be some high quality scenic drive loops, and Teepee Creek
certainly provides that opportunity.
Burned areas provide significant opportunities
for snowmobiling in the winter because areas are cleared of brush
and trees by the burn and salvage activities.
There needs to be at least an open route in the Teepee area
and there will be several opportunities for high quality
snowmobiling and OHV riding in the Robert Fire area.
Motorized access is woefully inadequate in both burn areas.
Areas and trails must be made available, at least on a seasonal
basis in both fire areas.
Implementation/local
employment: There
was a lot of discussion and agreement in the collaborative groups
regarding opportunities for local employment in the salvage and
restoration activities. As
mentioned in our comments on logging systems above there surely must
be numerous opportunities for selling salvage units as separate
small sales that local contractors are capable of
bidding and harvesting in a timely manner.
Partially burned areas where only a portion of
the trees are killed or severely damaged
would be especially suited to smaller independent local
contractors. Some
of the larger areas proposed for helicopter such as the area between
Depuy Cr. And McGinnis Creek could perhaps be offered under the
Stewardship contracting authority to give the bidder the opportunity
to propose mutually agreeable workable alternatives for salvaging
the area.
Montanans For Multiple Use is willing to
invest additional time collaborating with you and project specialist
on site specific proposals.
Sincerely,
Fred D. Hodgeboom, President
Montanans For Multiple Use
