Declaration
of Richard Cowley
IN THE UNITED STATES COURT
FOR THE DISTRICT OF THE DISTRICT OF COLUMBIA
COMES NOW Richard Cowley and declares as follows:
1. I have personal knowledge of the
matters stated herein and if called upon to testify could testify
competently thereto. In the course of the preparation of this
declaration, I read the declaration of Mr. Donald Black..
2. I grew up in the forests of
Lassen County CA in the community of Westwood. I was a member of the
Voluteer Fire Department of Westwood and I fought wildland fires
there. I have lived in and near forests all my life and experienced
and observed a lot of wildfires. My brother, Randy Cowley, is a
Ranger with the Plumas National Forest who is a qualified Equipment
Boss on fire fighting teams. We often discuss forestry and forest
fires and how to fight fires. Currently I reside at 816 10th
Street West, Columbia Falls, Montana. I am employed by FH Stoltze
Land and Lumber Company. Stoltze routinely trains employees for fire
fighting and safety. In 2003, I was a Red Card qualified
firefighter. I and my family are long time property owners in the
North Fork of the Flathead and I have observed and experienced
several fires there.
3.I own a cabin on Trail Creek, a
tributary of the Flathead River, which was threatened by the Wedge
Canyon Fire for nearly two months. The fire burned within about a
quarter mile of my property. Had a significant windstorm of the type
I have experienced in my time living in the area of the Flathead
National Forest arisen during the fire the fire would likely have
been pushed onto my property. My friend, Mr. Ed St. Onge, owns
property and resides near Tepee Lake. His property was burned in the
fire, but his residence and garage survived as a direct result of
the thinning and clearing he had done on his property and his
sprinker system. Because of my interest in my property and that of
friends, family, and neighbors, and the experience I have had as a
property owner in the Flathead National Forest area, I have
developed a keen interest in the way in forest fires are started and
grow, are discovered, and the ways in which they are started. I have
observed both forest fires and the manner in which they are fought
over the past forty years.
4. On July 18, 2003, I was up Trail
Creek tributary to the North Fork of the Flathead, working on my
cabin. There had been lightning storms and small fires in the area a
couple of days earlier, one right behind Ed St. Onge’ house that
was put out. I saw some smoke to the southwest shortly after 12:00
noon. I was unaware when I saw the smoke whether it was coming from
a fire that was already manned by firefighters; however, I was aware
of how dry conditions were and decided I should investigate to
determine whether it was a fire already being fought.
5. As I had no telephone, I went to
my father in law, Mr. Ron Holten, who had reported a fire on Towa
Ridge earlier. Mr. Holten and I then picked up my friend, Ed St.
Onge, on the Tepee Lake Road.
6. Currently, a person in the Tepee
Lake area wishing to view the head of Tepee Creek must drive
approximately two-and-a-half miles south to Whale Creek road and
then drive up the Hornet Lookout road up a couple of thousand feet
in elevation over the ridge. Previously, a person would have been
able to reach this vantage point much more quickly by driving a road
that existed alongside Tepee Creek. However, approximately 6 years
ago the Forest Service had dug up the road and bermed it off so no
vehicle could use the road, making the areas inaccessible to
vehicles for all purposes, including firefighting.
7. I, along with my father-in-law
and Ed St. Onge, reached the ridge just below Hornet Lookout about
1:00 pm. The Hornet Lookout road used to connect with the Tepee
Creek Road 907 but the Forest Service destroyed the road just before
the Tepee Creek connection, so no vehicles could get into Tepee
Creek. The Tepee Creek road used to extend about a mile and a half
west upstream from the Hornet Lookout road and Tepee Creek road
intersection, but that portion of the road, which had an excellent
helicopter landing area, was made unusable by the Forest Service at
the same time the Tepee Creek road was cut off.
8. We drove to a turnout on a spur
ridge where we could see the entire fire about a mile-and-a-half
from us. I observed a fire was burning just above the obliterated
road on the lower one-quarter of the slope and about a half-mile
above the intersection of the Hornet Lookout Road. If the roads had
been open and pumpers could have got in there, they could have
easily set up pumps in the creek and worked the bottom of the fire.
At the time I first observed the fire on July 18th, 2003,
I estimate the fire was about one-quarter of an acre in size.
9. The fire began spreading rapidly
uphill when it got into an area of heavy downed, dead timber and
began to put out huge amounts of flames and smoke. It was also
spreading downhill toward the blocked road.
10. We continually observed the area
during the time described in this declaration. It was not until
approximately 3:00 p.m. on July 18th that a scout
helicopter showed up and landed on the heli-spot on the closed road.
At approximately 3:30 p.m. a heavy helicopter came and made a couple
of drops on the fire, but the fire was burning so intense the drops
didn’t have any effect. A retardant plane subsequently arrived and
made a drop which had no effect on the fire.
11. After the ineffectual drops
described above, a small Forest Service pumper truck with Danielle
Burke, with whom I am familiar, and two young men came by and said
they were going to go down and work on the fire. They appeared to be
unaware that the road had been obliterated. We informed them that
the road was not intact and they drove on down what remained of the
road. Approximately twenty minutes later a similar small pumper
truck from Glacier Park came past us and went down to join the
Forest Service Crew sitting on the Hornet Lookout road later
followed by a TV news person came who took some video and statements
from us. I do not remember what station the news person represented.
12. A few minutes after the arrival
of the news person, Don Kopple of the Montana Department of Natural
Resources with whom I am familiar, drove up and joined us at the
vantage point, around 4:30 p.m. Based on my dealings with the people
in the pumper trucks described above, it appeared to me that they
not been informed of the current impassible road situation.
13. At the point where the
above-described people had arrived, the fire had expanded to
approximately 40 or 50 acres in my judgment, burning to top of ridge
between Tepee and Trail Creek. Mr. Kopple in my presence immediately
got on the radio and called for bulldozers. At this point, I
believed that all kinds of men and equipment would be headed for the
fire, so we headed back down by 5:00 p.m. At no point in our return
trip did we meet anyone going to the fire, not even a pickup. In
light of what I knew, I believed the absence of persons heading to
fight the fire was strange and inconsistent with my experience of
such fires and the response to them.
14. In light of my experience
regarding fires and firefighting and my observations of the
particular fire described above, I find Mr. Donald Black’s
statements in his declaration that the lack of vehicle access was
not a factor in this fire getting away and about a "strong
initial attack" to be absurd. I found nothing in his
declaration that explains how an inability to get people and
equipment to a fire as fast as possible can fail to have a negative
impact on the ability to extinguish or control a fire. It is my
experience that roads serve at least five purposes when it comes to
fires. First, they provide access to areas in order that fuel
reduction programs can be undertaken and fuels management can be
accomplished at minimal cost and with minimal environmental damage.
In fact, it is my experience based on personal observation that more
damage to the environment in terms of air pollution, erosion, and
injury to plants and animals, among other things, is done by
reopening or creating roads when a fire occurs, and then closing
them again after a fire is extinguished, than would occur if roads
were left intact and properly maintained. Second, they provide a
means by which fires are more readily discovered and reported at an
early stage. Third, they provide fire/fuel breaks to minimize the
spread of a fire before it is discovered and attacked. Fourth they
provide a means for reaching and attacking fires before they can
grow too large and to contain larger fires by providing alternative
attack opportunities when wind, other weather, or other factors
render an existing attack strategy useless or dangerous. Fifth, they
save lives by giving people trapped in or near fire areas, more
direct routes and more alternative routes for escape.
15. In my experience, fires such as
the one at issue in this declaration and to which Mr. Black directed
his declaration are more often discovered and reported by persons
who actually were in the area of the fire. Had the access to the
Tepee and Trail Creek areas not been disrupted by destruction of
roads into the area, there is a high probability in my judgment
based on my years of experience that someone would have discovered
the fire much earlier than actually occurred.
16. It is also my judgment based on
my personal experience and information, reflected even in common
sense, that getting to a fire and extinguishing it while it is small
is infinitely preferable to waiting until the fire grows. Based on
my experience I judge that, had vehicle access been available, and
had the Forest Service sent some experienced people and equipment
right away when the potential of this fire was reported, it could
have been effectively contained the night of July 18 and morning of
July 19.
17. Down Tepee Creek to the east
there are bare rocky spur ridges that could have been successfully
used to contain the fire if pumps, heavy equipment and ground crews
had been able to get in to them on July 18 and 19 and stop the fire
from spreading across Tepee Creek. Although I observed the area
closely, I saw no effort to even begin to open access to the fire
until Sunday, July 20, 2003, when "cats" were finally
started up Antley Creek and when Road 907 began to be opened.
18. Notwithstanding Mr. Black’s
unsupported statements in his declarations that road access was not
a factor in the Wedge Canyon Fire escape and that there was a strong
initial attack, it is clear from my observations and my experience
that the lack of road access was a factor and that the initial
attack was, at best, a token air attack. Air drops are useless on a
crowning fire as I witnessed. In my experience, rapid access by
competent ground crews and equipment is essential for successful
attack and control of a fire under conditions we had in 2003 and
will continue to have in the future. Other than the token air drops
there was no initial attack.
19.. I have heard and read numerous
news accounts stating that the fleets of firefighting tanker planes
have been grounded as unsafe. If this is true, in my judgment based
on my observations and experience, road access becomes even more
important, since even the alleged "strong attack" would
not be possible.
20. Under the fire conditions that
existed, and the lightning we had, in the 2003 fire season in the
Flathead National Forest, I cannot understand why the Forest Service
did not have someone on Hornet lookout watching for fires, extra air
patrols or something to detect the fire earlier.
21. Furthermore, the statistics
cited in Mr. Black’s declaration regarding the total number of
strikes, fires, and the like, for the 2003 season does not support
his conclusions as I am personally aware that, at the time of the
July 18, 2003 fire, there were no other large fires burning and,
therefore, their ability to attack the July 18th fire
could not have been impaired because significant resources were
being dedicated elsewhere in the Forest. All the events I observed
on this fire support an unstated Forest Service policy to let the
fire burn, wait for the fire to come to the valley bottom, to set up
elaborate sprinkler systems, construct instant fuel breaks, and the
like, to attempt to guide or "herd" the fire around
private property.
22. In addition, though, as I
declared above, Mr. Kopple in my presence requested bulldozers at
5:00 p.m. on July 18, by my observation, none showed up to fight the
fire until July 19, 2003 and even then were not put to work opening
any access until Sunday, June 20, 2003, during which time the fire
continued to grow.
23. Even then, rather than
continuing with a plan to open access up Antley Creek to get forces
on the ridge to beginning a direct flanking attack of the fire, that
plan was abandoned apparently to ensure there would be no equipment
use in the Thompson-Seton Roadless Area, and Antley Creek access was
not opened until after the fire had burned across the private land
and river into Glacier Park and down into Trail Creek.
24. I have personally observed the
Forest Service tear out culverts, destroy vehicular access, and fill
roads, which themselves act as fire/fuel breaks, and firelines with
flammable debris. It is my judgment, based on my experience, that my
property and that of others are now at more risk that before than
before the fire described above because the potential Antley Creek
access is completly lost and fuels are connected for a reburn when
all the snags fall in the roadless area. Unless the Forest Service
does a fuel break to the west of my property to the Canadian line, a
fire start to the west in the Antley-Thoma-Trail Creek area will
threaten me again. This is all the more true in that no timber sales
in the North Fork area have occurred, except for fire-killed trees,
since 1996. There has consequently been a buildup of fuels that,
together with the above-described conduct, increases the risk to my
property.
25. The Forest Service failed to
inform me about the threat posed to me when the fire burned north
across Trail Creek. If we had the winds that normally happen around
Sept. 1, my property, as well as many others up in the Moose City
area would have been destroyed and my life at risk, and the fire
would have been in Canada. The Canadians did construct a fireline
about 200 feet wide just across the border in anticipation of that
event. It is my opinion based on my experience living in the
Flathead National Forest area that it was just luck that this did
not happen in 2003.
I declare that the foregoing is true and correct to the best of
my knowledge and recollection under penalty of perjury of the laws
of the United States.
___________________________________
Richard Cowley
TOP
Declaration
of Gary Hall
IN THE UNITED STATES COURT
FOR THE DISTRICT OF THE DISTRICT OF COLUMBIA
COMES NOW Gary Hall and declares as follows:
1. I have personal knowledge of the
matters alleged herein and could testify competently thereto if
called at trial.
2. I live 6 miles west of Olney off
of Forest Road 2873 surrounded by National Forest land. My address
is Box 133, Olney, MT 59927. I have lived here since 1976. Before
that I lived for two years in Bigfork, MT. I have served on the
board of Montanans For Multiple Use for 5 years and I am the current
Vice–President.
3. I have read the Declarations of
Mr. Black, Ms. Barbouletos, and Mr. Hammer submitted in opposition
to the motion of Plaintiffs in the above-captioned matter. I have
read the reports and other documents relied on by Mr. Hammer in his
declaration as well as the Opening Brief of plaintiffs in this
action. I have found their assertions to be factually incorrect.
4. For example, apparently
responding to Plaintiffs’ Opening Brief and the discussion of the
Forest Service’s improper reliance on a preliminary study for
enacting Amendment 19, Mr. Hammer states in his declaration that a
"Final Report" (Mace, R. D. and J. S. Waller. 1997. Final
Report: Grizzly bear ecology in the Swan Mountains, Montana. Montana
Department of Fish, Wildlife and Parks. Helena, Montana) fully
supports the road density standards and closure requirements of
Amendment 19. However, this study is contradictory and often
misleading and Mr. Hammer’s characterization of its contents
misleading at best. Nowhere in the Final Report is there a
recommendation for road obliteration. Rather the report, at p. __,
recommends flexibility in road management emphasizing seasonal
closures and short term openings for public access.
5. Similarly, although Mr. Hammer
claims that culvert removal is necessary for water quality, a
Flathead Forest Service study, Table 3-15 from the Spotted Beetle EA
pp 3-86, reveals that culvert removal may deliver more sediment than
it prevents. Forest road engineers generally agree that if roads are
upgraded to the latest Best Management Practices, which include
properly sized culverts and waterbars among other things, the
sediment delivery of roads is minimal.
6. Mr. Hammer’s statement that
fires are more often caused by people who use forest roads is just
not true. Even Mr. Black is forced to admit that over 70 percent of
all fires are lightning caused (Black Declaration, ¶ 9).
7. Mr. Black’s statements that
road closures do not affect fire fighting effectiveness contradicts
statements in Amendment 19 (pp. 40) and other fire fighting experts
as well as the dictates of common sense.
8. Supervisor Barbouletos’
contention that we do not need this injunction but could appeal FS
decisions is false on its face because we have, in fact, done the
very thing she suggests to no avail because we were always told that
the amended forest plan required road closures and obliterations to
meet Amendment 19 standards. Her claim that the injunction would
hamper current management activities is frivolous because if and to
the extent that claim is true the same reasoning would apply to
management activities whether or not the request for injunction is
granted.
9. In support of his belief that
closed and obliterated roads are good for grizzly bears, Keith
Hammer quotes the Final Report on page three in his second
declaration, paragraph 5, as follows:
"During the period 1988-94,
eight marked grizzly bears in the study area were killed by
humans. These deaths were directly influenced by road access,
development of grizzly bear habitat, and conditioning of grizzly
bears to unnatural food sources near roads."
This statement is misleading. In
fact, the Final Report discloses that of the 19 man-caused
mortalities in or near the study area only two occurred in the
core/multiple-use area. Five of these deaths occurred far from roads
in the Bob Marshall Wilderness and 12 occurred in the "rural
areas" on the western edge of the study area. The rural areas
are those areas close to human habitation near Bigfork, Echo Lake
and the Swan Valley. The road closures and obliterations of
Amendment 19 do not occur in the wilderness or in the "rural
areas". Therefore road access in multiple use areas is not a
factor in survival. Instead, acclimation to or avoidance of human
habitation rather than "strict road access programs" may
be the key to grizzly survival as the report points out on pages 73
and 121.
10. The "Final Report"
states on page 33 that "…no strong relationships were
observed for closed road density and bear density."
Therefore, closed roads do not need to be obliterated. Source: Mace,
R. D. and J. S. Waller. 1997. Final Report: Grizzly bear ecology in
the Swan Mountains, Montana. Montana Department of Fish, Wildlife
and Parks. Helena, MT. Pages 109-110 and 121.
11. A 1997 study by Kasworm and
Wakkinnen in the Selkirks and Cabinet/Yaak mountains concludes that
barriered roads were ignored by the bears.
"Examination of influences
of road type on bears did not produce a statistically
significant result, but appeared to indicate that barriered
roads have less influence on bear distribution than gated roads.
Results comparing total road calculations with and without
barriered roads showed no statistical relationship. We suggest
that if barriers on roads are effective, these roads may be
removed from total road density calculations."
Again we conclude that roads that
are closed need not be obliterated.
Source: Wayne. Kasworm and Wayne
Wakkinen ,. 1997. "GRIZZLY BEAR AND ROAD DENSITY RELATIONSHIPS
IN THE SELKIRK AND CABINET - YAAK RECOVERY ZONES", page 26.
12. Hammer maintains that culvert
removal, which renders the road impassable, is necessary for
maintaining high water quality. In paragraphs 10, 11, and 12 he uses
his own unscientific writings and the personal communications of two
individuals to support his contention that culvert removal is
necessary. While these personal observations may be interesting they
do not rise to the level of expert testimony. However the Flathead
National Forest has disclosed in the Spotted Beetle EA that culvert
removal does release a significant amount of sediment to the stream.
Table 3-15 from the Spotted Beetle EA pp 3-86.
The removal of 44 culverts, which
were required for A19 compliance in the Spotted Beetle project, will
result in the release of 127.6 tons of sediments, if they were all
in the moderate range AND they were all "Best Case". This
is 11 times the amount of sediment delivered by one culvert failure
of the same type. Culvert failures are very rare. It is extremely
unlikely that 11 culvert failures would occur in a drainage in the
course of 50 years or more. Most importantly, 11 failures in one
watershed over the course of five years, which is the typical time
span for a culvert removal project, is out of the question. Recent
testimony by Flathead Forest Officials at a public hearing in
Bigfork, MT on June 7 disclosed that there had been only 3 to 5
culvert failures on the entire Flathead Forest in the last five
years,
4.4 x 44 = 193.6 tons for culvert
removal > 11 x 17.2 = 189.2 tons or 11 culvert failures.
The above analysis does not take
into account the additional sediment delivery that occurs during the
next 2 or 3 spring runoff events or until the new stream channel
stabilizes. In some cases this would be more, maybe several times
more, sediment delivered to the stream than culvert removal itself.
Since these obliteration projects have always been associated with
other management projects, they only affect one or two watersheds
per project. This causes a massive spike in sediment for the
downstream watershed that lasts for the duration of the project and
beyond. Actual photographs of the erosion that occurred at these
stream crossings after culvert removal may be seen at www.mtmultipleuse.org/road_destruction.htm
Source: "Spotted Beetle
Resource Management Project Environmental Assessment". Flathead
National Forest. September, 2001
13. In paragraph 13, Mr. Hammer
overstates the total road mileage on the Flathead and understates
the miles of road that have been and will be required to be
obliterated by Amendment 19. In fact, even Defendants Barbouletos
and the United States Forest Service have contradicted this
assertion. According to a fact sheet handed out by Flathead Forest
Road engineer, Ken Meckel, at a public forest planning meeting in
Whitefish on May 10, 2004, there are 3469 miles of road on the FNF
in 2004. Of that total, only 1,542 miles are open seasonally or all
year. Ms. Barbouletos and Flathead National Forest NEPA official
Terry Chute told reporter Jim Mann of the Daily Interlake, a local
newspaper, that the final total of obliterated roads is estimated to
be 920 miles. Mr. Hammer’s figures are 4000 and 366 respectively
and he does not mention that the majority of all roads are closed
year long and therefore do not affect the grizzly as the two leading
studies regarding the relationship between grizzlies and roads which
we quote above, make clear.. Source: Mann, Jim. 02/08/04. "Forest
Backs Off On Road Closures", The Daily Interlake.
14. Mr. Hammer, in paragraph 18 of
his declaration, states that the economy in Northwest Montana has
diversified. This is somewhat true of Flathead County but not of
other counties in the area. Lincoln County has been particularly
hard hit and is listed as a county at risk. Hammer states that
logging now plays a smaller role in the economy, which is also true
in the Flathead. He does not mention that this is directly due to
the reduction in federal timber sales caused by Amendment 19. We can
expect that a similar amendment recently implemented on the Kootenai
NF in Lincoln County will have the same effects. I have addressed
the economic issue in a separate statement which Mr. Hammer does not
directly confront nor explain why his figures, which are not
official county figures, are the more accurate.
15. Mr. Hammer’s statement in
paragraph 19 that, "Most forest fires are started by people
along or near roads. ", directly contradicts the
statement of Donald Black in his declaration. Black says in
paragraph 9 of his declaration on page 4 that, "Lightning
caused fires (in an average year, approximately 70% of all fires)….",
occur at higher elevations where there are fewer roads. Roads and
people are not the problem. On the contrary, they are the solution.
We need those roads that remain in the higher elevations to fight
those lightning caused fires. If it is true, as Mr. Hammer states in
paragraph 19, that wildland fires are twice as likely to occur
outside of inventoried roadless areas, then we should eliminate
roadless areas because there is much more than twice as much
National Forest land outside of those areas than inside. Therefore,
it would seem that roadless areas burn at a higher rate per acre
than the roaded lands. In Oct, 1999 Region 1 of the Forest Service
published a chart disclosing the numbers and status of inventoried
roadless on Region 1 forests. 495,430 acres are presently managed as
inventoried roadless on the Flathead National Forest out of a total
of 2,353,049 acres.
16. In his Declaration Donald Black
states in paragraphs 10 and 11 that road closures do not increase
the risk of loss of life or property or reduce the ability of
firefighters to control fires. However, Amendment 19 itself
discloses the increased fire risk due to restricted road access. The
Amended EA for A19 says on page 40:
"Management actions that
change roaded access, may affect …initial attack fire
suppression success and have significant effects on large-fire
suppression capability. Delayed response time for initial attack
and reinforcement for emerging fires is the critical limiting
factor for fire starts. Extended response time due to reduced
surface access (Note:
caused by closed and obliterated roads)
increases escaped fire possibility. The cost of suppression
increases due to needs for aviation support and fire fighter
support in more remote areas."
and
"Vegetation
to treat insect and disease mortality, blow down and undesirable
tree species compositions are restricted to varying degrees in
each alternative. Fire history suggests that those alternatives
with the least vegetative management would have the most
potential for large fires…. When a wildfire begins under the
right weather and fuel conditions in these types, wildlife
security habitat could be adversely impacted."
and
"In general, decreases in
access can result in larger fires due to delays in getting
firefighters to the site."
Mr. Black refers to the various
aircraft that are used to respond to wildfires. He fails to mention
that the large bombers that were so effective in previous years have
been grounded and will not be available for this year and beyond.
However, even if those bombers were available, we still must fight
wildfires on the ground. In a letter to the Billings Gazette, Chief
of National Forests, Dale Bosworth wrote, "Contrary to
widespread belief, fires are stopped on the ground -- not from the
air. Firefighters on the ground need roads.
Source: Firefighters can
do jobs without large air tankers (Guest Opinion). June
6, 2004. Kathleen Clarke, Bureau of Land Management
Director, and Dale Bosworth, U.S. Forest Service Chief.
Billings Gazette, Billings, Montana
17. In paragraph 5 her Declaration,
Cathy Barbouletos states that, "An injunction is unnecessary
because Plaintiffs have the opportunity to appeal and challenge any
particular proposed action to close or obliterate a road in
accordance with NEPA and Forest Service regulations." Plaintiffs
have done that repeatedly. The latest examples would be our comments
and appeals of the Spotted Beetle and Moose Fire projects. In every
case, we are told that the Forest Plan requires that roads be closed
and obliterated. The forest managers claim to have no choice but
implement the strict standards of Amendment 19. They have tried to
have it both ways; claiming in Amendment 19 that the amendment was
not site specific and would not have a significant impact on the
environment, in other words compel road closures, and then during
site-specific analysis they insist that Amendment 19 compels them to
close roads. In short we have tried to get relief through the NEPA
process from the harm Amendment 19 is causing but our arguments are
consistently trumped by the claim that the forest plan as amended
must be complied with. Furthermore, there is no appeal process which
enables the Plaintiffs to challenge the cumulative effect of
amendment after amendment.
18. In paragraph 7 of her
declaration, Ms. Barbouletos expresses concern that projects
designed under a forest plan rolled back to 1994 (assuming our
request for injunction is granted) might not be consistent with the
new forest plan scheduled to come out in 2006. Therefore she would
hesitate to proceed with any new projects. If that is her fear, then
she should not proceed with new projects anyway because projects
conceived under the amended plan may not be consistent either. In
either case, injunction or no injunction, there will be a need to
reassess projects and update them after 2006.
CONCLUSION
As an inholder, in the Flathead
National Forest, as an outdoors recreationist and as an officer of
Montanans For Multiple Use charged by our members to protect their
access to forest lands, I am directly and vitally affected by
Flathead National Forest policies which include but are not limited
to closure and obliteration of roads and all of the other actions or
lack of action stated in my original declaration. Therefore, I
respectfully request that you grant this injunction.
GARY HALL
