22 June 2009

Steve Ryberg District Ranger Evanston/Mt. View Ranger District
Uinta-Wasatch-Cache National Forest Evanston, WY

Dear Steve,
We are in receipt of the scoping proposal for the Blacks Fork Salvage Project and would like to provide these very brief comments.

Well, Steve, thanks for preparing an Environmental Impact Statement for this project. (At the same time, I was beginning to worry that you might retire before getting around to the East Fork timber harvesting proposal. Should have known better.)

Once again, instead of proposing a major timber sale within the forest plan’s Timber Growth and Yield Management Prescription (MP 5.2), the district continues timber harvesting on management prescriptions not intended for timber harvesting!

There is nothing more disingenuous, again, than this proposal to carry out extensive timber harvesting in management prescriptions that do not envision such massive timber harvesting proposals, salvage or not. The scoping proposal’s citation of Forest Plan Guideline 67 is duly reported and noted. But throughout the discussion and review of the forest plan preparation, Pam Gardiner, former Deputy Forest Supervisor, Tom Tidwell, former Forest Supervisor, and Melissa Blackwell, former Forest Planner, consistently assured us that harvesting outside of the timber management prescription (MP 5.2) was intended to be the exception, not the norm, not the rule. Now, either they outright misled us (Forest Service Chiefs don’t mislead, do they?)--and it is duly noted nothing was formally written--or deep changes have occurred, suggesting the need for a formal amendment to the forest plan, or contrary to the context and intent of the plan, timber harvesting outside of the management prescription focussing on timber management and yield has become the norm--the only--prescription in which timber harvesting has occurred. This was not the intent of these non-timber prescriptions.

We, again, anticipate you will dismiss this concern.

On the other hand, we are sure you will fully and honestly explore the issues surrounding properly functioning condition and “restoring vegetation, composition, structure and patterns within the historic range of variability” while noting how or/and why the present forest within the project area is not within the historic range of variability, why or why not and how the proposal will meet those conditions, and whether they will be met by a no action proposal.

These forests are defined by fire and natural disturbance regimes and clearly become dysfunctional when disturbed and managed by forest management techniques. Beetles are a natural component of the forest systems in this project area including high levels of beetle infestations and the resultant conifer mortality.

We are sure you will honestly discuss the impacts of 12 miles of proposed temporary roads by noting the roads will likely be accessible and on the ground for numerous decades while timber sales are made and harvested, making them far more than temporary.

We are sure you will be discussing the unique value of dead trees to ecosystem function and to so many forest critters from birds to wildlife to insects. At the same time we are sure you understand individual dead trees have little value and that the concern revolves around stands of dead trees, not randomly left clumps of dead trees.

We are sure you won’t try to convince us that timber harvesting mimics fire disturbance and that fire, while it has its place, it is not here because it is bad for some reason.

We are sure you will clearly note that timber harvesting undermines many ecosystem benefits, removes important biological legacies, and runs counter to inherent forest ecosystem health.

We are sure you will honestly and clearly note the impacts of additional forest fragmentation to terrestrial and avian wildlife species and that this fragmentation is not automatically mitigated by suspected migration routes somewhere nearby. We are sure, as well, that you will not fall prey and argue that displaced wildlife will automatically and easily find available and nearby habitat simply because there are other places that you have not yet harvested or roaded.

We are sure that you will recognize that goshawk and a host of other species survive perfectly well in natural forest settings and have no inherent need for timber harvesting or management schemes to survive.

We are sure you will recognize the values of unmanaged forests.

We are sure you will recognize the harvesting on the East Fork Blacks Fork and the mouth of the Middle Fork will significantly alter the sense of a primitive setting so important to the recreational users in the drainage as they wind up the road to the trailhead(s) and rustic trailhead campground.

We are sure you will recognize chasing pine beetles around the forest is a meaningless gesture. Interestingly, we discussed this with Dave Myers and Brian Ferebee at our recent UWCNF breakfast meeting (5/26/09) with both Dave and Brian agreeing such tactics are hopeless.

We are sure you will not overstate fuel loads in a forest system dependent upon and defined by fuel loads as the forest itself is a fire dependent and disturbance dependent forest. We are sure you will recognize there is no inherent risk associated with fuel loading in these forests since such a condition is inherent to these forest systems.

We are sure you will not summarily suggest aspen is an endangered species and that its survival at any particular spot is dependent upon logging rather than allowing natural disturbances to operate within the context of the forest system.
We are sure you will not offer summary conclusions that encroaching conifers are usurping small meadows “...leading to a loss of small ponds and streams, and a reduction in wildlife and fisheries habitat diversity.” At least you will not do this without a clear statement of how this is happening and an honest evaluation as to how many decades, maybe even centuries, this will take, and that allowing the inherent natural process typical to this kind of a forest system will assure such an event is imaginary!

We are sure you will consider the effects of climate change on fire behavior and pine beetle infestations and the negative impacts of timber harvesting in terms of exacerbating both the broad concerns of carbon cycling and the specific concerns of increasing the local heating/temperatures and decreasing local humidities and ground moisture.

We are sure you will consider an alternative that does not propose any harvesting south of the North Slope Road. This captures the concerns surrounding recreational values of these areas and dramatically minimizes the need for additional road construction. It assists in meeting all of the interests and concerns of your proverbial stakeholders. It has no effect on the concerns about Lyman Lake and minimizing fire potential around a campground and other facilities. It has no effect on the proposed aspen regeneration and burnings nor on willow regeneration burnings.

Maybe a field trip later this summer will help clarify these numerous issues.

Please keep us posted.

Sincerely,

Dick Carter