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Kelsey Beaver DEIS YVFC

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Kelsey Beaver DEIS YVFC Powered By Docstoc
					October 19, 2001

Mike Balboni, District Ranger
Three Rivers Ranger District
1437 Hwy 2
Troy, MT 59935

Dear Mike Balboni:

Please accept and consider my enclosed comments on the Kelsey Beaver DEIS on behalf
of the Yaak Valley Forest Council.

First of all I should list some issues that we are happy to see occur with this project. We
appreciate that Three Rivers responded to our letters regarding Roderick Butte by adding
an alternative that precludes logging in the viewshed (though we’re disappointed that
Three Rivers feels the need to lobby for comments that reflect their position as well as
give an incomplete analysis of fire hazard).

Phil Fortier and myself greatly appreciate the assistance of some of the ID team members
during the comment period in providing maps and information we requested.

We’re glad to see that, with the exception of proposed unit 80, the unroaded area at the
upper end of Beaver Creek will be left alone and allowed to recover naturally. I also
appreciate the decision to stay out of the Mount Henry Roadless Area, as well as deciding
on no permanent road construction.

We’re also pleased that Three Rivers chose not to request an emergency exemption for
salvage harvest—though I think that if this project would have been developed on a
smaller size and scale it could have been much farther along at a much lower cost.

We’re disappointed and concerned that this project was developed solely on the basis of
efficiency and economics. From documenting the fire areas over the past few months it’s
obvious that this project was designed to locate harvest opportunities in suitable
timberland and then the project—ie. restoration work, stated purpose and need, fire
severity levels, prescriptions, etc., were developed around that initial timber assessment.
An undeniable fact of last year’s fires is that they were slow burning ground fires for the
most part; this is mainly because of weather factors but also because many unlogged
areas in the Yaak Valley are still in a healthy fire history and are not outside the range of
historic fuel levels. Last years fires were a continuation of healthy fire history in many
areas of the project. This is particularly apparent in areas like the southwest-facing units
north of Vinal Creek where there was and still is a low level of fuel loading. The Kelsey
Beaver DEIS fails at giving an honest and straightforward look at the natural processes of
fire on the landscape and at identifying areas that meet “the desired condition.”

It is a shame that the Kootenai National Forest fails to recognize and accurately portray
the positive ecological benefits from last year’s fires. It’s amazing to see the incredible
use of the fire areas already by elk in units such as 68 in the Turner Creek drainage and
the grouping of units north of Vinal Creek—these ground fires have rejuvenated the soils
while the tree mortality is low enough to still provide shade and moisture requirements
for maintaining soil productivity and hiding cover for big game. Yet areas such as the
grouping of units north of Vinal Creek were falsely mapped as overwhelmingly fire
severity level 1. While the Kelsey Beaver DEIS talks about the need for fuels reduction,
it’s obvious to anyone who visits a number of sites that areas with lots of small diameter
fire-killed trees (such as the portion of unit 15 in the Kelsey fire that was recently
dropped), are being left alone while areas with lower fuel levels, and larger diameter trees
that are more fire-resistant, are being targeted. Why can’t the Kootenai National Forest
look at areas like unit 52 and realize that the natural processes at work don’t need any
manipulation and focus instead on others areas where opportunities may exist?

Alternatives:
We feel a reasonable range of alternatives that cover a full range of options, from the
most efficient and economical to the most environmentally sound, were not presented in
the Kelsey Beaver DEIS. We appreciate an alternative which precludes logging in the
Roderick Butte viewshed and also the statement from Mike Giesey that the proposed
action was developed solely on the basis of what the ID team felt needed to be done, not
inflated and then reduced to satisfy the public. However, with the exception of the two
units on Roderick Butte that are eliminated or reduced in alternative C the two action
alternatives are the same. As stated in my scoping comments on April 12, 2001 YVFC
members want to see a more balanced approach in forest management that accomplishes
several objectives, including employment of local, independent loggers in Lincoln
County, protecting wildlife habitat and corridor areas & minimize stream flow increases
and soil erosion. As I will explain further in my comments we feel the two action
alternatives will accomplish none of these objectives and the no-action alternative will
not help employ local, independent workers.

Visuals:
Our opinions on the viewshed of Roderick Butte have been well stated in comments and
on field trips. Roderick Butte is one of the few mountainsides in the Yaak Valley where
the viewshed is still in a natural state and we feel should remain that way (see photo 1-1).
We’re concerned that the ID team has chosen to focus their discussion of Roderick Butte
on theories of fire hazard rather than the stated major issue, which is visuals. While we
can understand soliciting comments from specific residents in the south fork area with a
mailing in our opinion following that up with phone calls to discuss the project and offer
to send comment sheets has crossed the line into lobbying for your position, which is the
proposed alternative. Your bias is clearly evident by the fact that the phone caller is a
person entailed in fuels, not visuals. If Three Rivers feels they need to begin calling local
residents in order to receive comments then they should be calling at least everyone in the
Upper Yaak since visuals impacts everyone there on a regular basis.

Fire severity/mortality:
The fire severity ratings are extremely misleading and vague, particularly the medium
intensity range which goes from 20% -70%. The way the Kootenai National Forest
assesses fires gives no clue as to the effects of last years fires. For instance, basing
mortality levels on the percentage of the total number of trees killed instead of basing it
on overstory trees killed or basal area reduced by fire is extremely misleading. Countless
areas, including units 6, 7, 9, 10, 11, 12, 13, 35, 52, 54, 60, 62, 75 and portions of units
16, 22, 24, 38, 45, 68, 80, & 81 burned in what looks more like a prescribed burn than a
high severity fire that is claimed in the DEIS (see photo 1-2). The units listed are all sites
we’ve visited; there are countless more units we haven’t seen that I’m sure would fit in
the same category.

In order to get a second opinion on mortality levels in the proposed units we hired an
ecologist, Michael Jacobs, to work with us on determining mortality levels. He based his
work on Forest Service research by Reinhardt and Ryan (1989) and Lowell et al. (1992).
By surveying tree species, tree diameter, bole char and crown scorch in 1/5 acre plots we
were able to predict mortality levels in the units surveyed, as well as break down
mortality levels in size class (undestory, mid-story and overstory). Based on this
information we also calculated basal area reduced by the fires. We sampled seven units of
various forest types in order to have a diverse representation of fire areas.

Basal area reduced by fire is critical when estimating whether hiding cover and
movement corridors will be maintained or lost in fire areas, as well in predicting future
peak flows. The Kootenai National Forest’s method of determining fire severity simply
by the total number of trees killed is woefully inadequate and does nothing to help other
agencies such as EPA, Montana Department of Fish, Wildlife & Parks & USFWS to
comment accurately on this proposal in regards to peak flow, big game security,
endangered species, etc.

For instance, from plots surveyed on unit 52, around 70% mortality could be expected of
the total trees, yet only 13% of the overstory >40ft. tall trees are expected to die and only
11% of the basal area reduced by fire (see photo 1-3).

I have enclosed our report prepared by Michael Jacobs concerning mortality levels in
units 3, 7, 13, 24, 62 & 75. I also previously submitted Mike’s report on unit 52 and
incorporate both of these reports in our comments on Kelsey Beaver DEIS.

The statement in Kelsey Beaver DEIS that only fire-killed trees will be harvested does
not match with the fact that the prescriptions for the Kelsey Beaver units are species-
designation based. There is a blanket assumption by the Kootenai National forest that all
trees other than larch died and as our survey data shows this is simply not true. This is
particularly true in the case of Douglas-fir, which seems to have been singled out by
region one as this decades undesirable species in the Northern U.S. Rockies. While it
certainly may be true that during drought years more mortality will be expected, it
wouldn’t be to the extent that every tree other than larch has or will die from the fires in
the proposed units.
Fuels:
Fire intensity and spread depends on many factors, including weather, slope, aspect, fuels
and the arrangements of fuels. The Kelsey Beaver DEIS focuses on only one aspect of
fire—fuels—which makes the effects analysis in the Kelsey Beaver DEIS (chapter three)
biased and slanted towards logging as a solution to minimizing future fires.

Given the right conditions, as we saw in the year 2000, fires will burn in any habitat or
forest type. However, the one forest condition that is most resilient with regards to fire is
forest ecosystems with large, fire-resistant trees. Morgan, Neuenschwander & Swetnam
(2000) state, “…it is very important to leave the large trees in the forest…these trees are
the “insurance” for the future—they are critical to ecosystem resilience.” They go on to
say, “If there are few tree crowns (low bulk density) near the ground and there is little
vertical continuity between the crowns of the small and big trees, forests can often
withstand surface fires even in dry, windy conditions.” This is exactly what happened in
many areas of last year’s fires (see photo 1-4). Units 6,7,9,10,11,12,13,35,52, 60, 62, 75
and significant portions of units 16,22,24,38,45,54,58, 59, 67 & 68 all fit this description,
and I’m sure there are more units that we didn’t document that would fit this description.
Our contention is that these areas are “the desired condition”, with little fuel loading
problems, few fire-killed merchantable trees and soils that have been rejuvenated by fire.

While the Kelsey Beaver DEIS continually throws out the threat of a reburn more intense
than what occurred in 2000, there is absolutely no scientific studies or literature to
support the theory. Beschta et. al. (1995) state “…we are aware of no evidence
supporting the contention that leaving large dead wood material significantly increases
the probability of reburn.” There are reports to the contrary however. "Timber harvest,
through its effects on forest structure, local microclimate, and fuels accumulation, has
increased fire severity more than any other recent human activity." (Sierra Nevada
Ecosystem Project, 1996). Also, "Logged areas generally showed a strong association
with increased rate of spread and flame length, thereby suggesting that tree harvesting
could affect the potential fire behavior within landscapes. In general, rate of spread and
flame length were positively correlated with the proportion of area logged in the sample
watersheds. "(Historical and Current Forest Landscapes in Eastern Oregon and
Washington)

 Even on an anecdotal basis when looking at last year’s fires the Kelsey Beaver DEIS
does not give an objective look at fire behavior. The “Influence of Regeneration Harvest
on Fire Severity map” (M-15) is both inaccurate in showing fire severity levels in pre
1990 harvests and selectively skewed by not including 1990 harvests. The large
lodgepole pine regeneration units from the 1970’s that were pre-commercially thinned in
the Upper Beaver drainage, just to the south of units 38, 39 and 45, listed as low fire
severity in reality burned with over 70% mortality (see photo 2-1). This is also confirmed
by the fact that these units are listed in the proposed replanting of harvest units map (M-
6). Additionally, it is our contention from surveying mortality levels in the proposed units
that mapping of fire severity levels in unlogged areas is inaccurate and misleading, which
makes this map even more suspect. It is also listed in the DEIS that 1725 acres of past
regeneration harvests will be replanted (1-8). On page 3-23, table 3-7 shows 921 acres of
regeneration harvest in the 1990’s and 3183 acres of past regeneration harvest total in the
fire areas. Going by this table we can assume that over 50% of past regeneration units
burned at a high enough severity to require replanting.

The stated reasoning on why recent regeneration harvests burned with high rates of
mortality, “…the trees were too small to withstand the heat from the surrounding burning
stands…” (3-48) is ludicrous. Fires burn through clearcut harvests just as easily as they
burn through grasslands, shrublands etc. In fact, in the project area they probably burned
more intensely and with a faster rate of spread because of the steep slopes. I even
watched and photographed part of the Upper Beaver fire creeping downhill and into the
prevailing winds through a recent clearcut—despite the fact that there were low fuel
levels on the ground (see photo 2-2).

Another factor that is not discussed in the DEIS is the impacts of pre-commercially
thinning regeneration units. These units which had fine fuels on the ground, combined
with hotter air temperatures and increased wind effect because of the openings, burned
both hot and fast and helped create larger fires in unlogged forests (see photo 2-3). Please
address this in the FEIS.

With regards to the Roderick Butte fire, while fuel loads may increase fire severity 20-30
years down the road it’s our contention that clearcutting that large an area will increase
the risk of fire spread for the next 10-15 years by increasing wind effect and air
temperatures close to the soils. A perfect example of this is where the 2000 fires burned
through the 94 fire area. It would be my estimate from looking at the Fire History map
(M-14) that out of the 762 acres of fire last year that reburned in the 94 fires at least 90%
of that area burned through the Upper Fowler fire salvage area (see photo 2-4). Once the
fire went through the salvaged area and up onto the ridge—where you would expect the
fire to become more intense—it burned itself out in unlogged areas that burned in 94.

Soils:
The Kootenai National Forest does not adequately analyze or monitor the effects of
salvage logging on soils. From personal observations it’s very apparent that past
regeneration units that burned, and particularly the Fowler Creek salvage area from 94
that reburned, have a much lower rate of vegetative regrowth this year compared to
unlogged areas that burned. Photos 3-1 & 3-2 show vegetative regrowth on two similar
areas as far as slope and aspect, yet the area that hasn’t been logged is drastically more
vegetated than the logged site. I’ve seen this in countless areas this summer. The Kelsey
Beaver DEIS provides no research or studies into the impacts of salvage logging on soils.

Watersheds & Fisheries:
Because of inaccurate fire severity level mapping in the project, we disagree with the
assumption that there will be no direct impacts to watersheds and fisheries as a result of
timber harvest. Particularly in southwest-facing units such as those north of Vinal Creek,
where in unit 52 our surveys show a predicted mortality level of only 13% of the
overstory trees, the impacts of harvesting on peak flows will be measurable. While I am
glad to see some units such as 53 and 53a dropped or reduced and am glad to see that all
larch will be left in some units, we feel that any units where the majority of the overstory
trees survived on steep south-facing slopes should be left alone in order to reduce the
effects of peak flows.

The DEIS states that some streams are predicted to be above peak flow standards yet
does not state which streams and exactly what the peak flow standards are. Please address
this in the FEIS.

We disagree with the assumption that the no action alternative could result in additional
negative impacts to the water and fisheries resource (3-74). Fires are an important and
necessary cycle in fisheries and watershed health. According to a position paper by the
Western Montana Level 1 Bull Trout Team (Reducing Fire Risks to Save Fish—A
Question of Identifying Risks, 2001), of which Kootenai National Forest fisheries
biologist John Carlson is a contributor, “In the short-term, fires trigger other processes,
such as erosion and woody debris recruitment, which are critical in the formation of
young, biologically rich stream systems.” The position paper further states, “…we
believe, in most cases, proposed projects that involve large-scale thinning, construction of
large fuel breaks, or salvage logging as tools to reduce fuel loadings with the intent of
reducing negative effects to watersheds and the aquatic ecosystems are largely
unsubstantiated.”

Kelsey Creek is listed in the Kootenai National Forests Fires Assessment 2000 book as
being in a red zone; condition 3, where extreme caution must be taken with regards to
any management activities. It seems in light of this that the grouping of units including
15, 15a and 16 as well as 24, 25 & 26 are excessive.

We’re glad to see that 3.3 miles of road decommissioning will take place in the Kelsey
drainage prior to or in conjunction with the Kelsey Beaver project. However, road 6065E
in Kelsey Creek, which is not included in the road restoration work, has a culvert towards
the end of road that is extremely undersized and the road has partially washed out in the
past (see photo 2-5). The stream drainage was also severely burned. This culvert should
be pulled this year if at all possible since the risk of a blowout is high. The unit past the
culvert, 20, is mainly lodgepole not impacted by the fire but diseased and is not worth the
risk of waiting until after harvest takes place to do the work.

We’re glad to see that roads in the Upper Yodkin drainage will be decommissioned. I
also feel that the spaghetti roads in Upper Beaver, 6711A, 6711B, 6714 etc., should be
considered for decommissioning.

 The problem with road restoration work is it often doesn’t get completed after harvest
work. I’m extremely concerned that the West Fork Basin Road, listed for
decommissioning in the Basin Creek Salvage project, won’t be done this year even
though the funds are available to complete the work. There are numerous culverts and
seeps in the area coming off the northeast slope of Mount Henry that are delivering
sediment directly to Basin Creek via ditch routing. The culverts are also at high risk of
plugging up during peak flows and blowing out the road. It is frustrating to see the
culvert work already done in areas like road 746B this summer in anticipation of
increased peak flows as a result of the salvage logging when past work that is needed gets
past by simply because land managers don’t feel it’s a high priority. Another area that is
an extreme problem is old logging roads in the North Fork of Meadow Creek. One
culvert there has plugged and the road blew out sometime in the past. Right now water
has washed out the road about 6’ deep, 8’ wide, 100’ long and will only get worse every
year. From what I heard this area was listed for restoration work in the Meadow Creek
EA in 1996 and yet nothing has ever been done about it. Negligence like this makes it
hard to believe the Kelsey Beaver DEIS when it states that peak flows and water quality
problems will be improved by management activities.

We are also concerned about the negative effects on water quality, surface and subsurface
flows in units 2 & 3 in the Roderick Butte fire and units 38 and 45 in the Upper Yodkin
Creek drainage. In regards to units 2 & 3, road 472F has severe drainage problems as a
result of subsurface flows that emerge out of a cutslope on the road and has no adequate
drainage (see photo 2-6). This road should also be considered for decommissioning.

I agree with riparian planting in streamsides that burned extremely hot but don’t see the
need in doing any work in Vinal and Beaver Creeks. These areas were low intensity
ground fires and are in relatively level slopes with plenty of remaining cover and
vegetation. It seems that whenever possible allowing natural processes to take place
should be preferred.

Wildlife Habitat:
The Kelsey Beaver DEIS does not analyze possible negative impacts to wildlife since the
fire severity levels are incorrect. Hiding cover is still available in many of the proposed
units that are over 40 acres, including units 51 & 52 in winter range and units 38 & 45 in
summer range. The FEIS needs to reevaluate factors such as elk security and movement
corridors since the mortality levels are lower than stated in the DEIS.

I am also concerned about noxious weeds in winter range areas. Last summer I saw
yellow hawkweed in units 51, 52 & 54 as well as the regeneration unit adjacent to the
proposed units. The hawkweed is off the road and in the units so I doubt that spraying the
road system would help. The infestation will only increase with the proposed temporary
road and associated skid trails that will be used in the units.

In regards to units 38 & 45, we feel that this area is prime lynx denning habitat with its
proximity to sapling sized regeneration units and its elevation range of 5000 to 5600 feet.

We are also concerned about units 38 & 45 since they are in higher elevation corridor
areas located between Zulu and Mount Henry IRA’s that can be used by grizzly bears,
elk, lynx and other wildlife for safe travel. Also, the corridor movement map in the
project file incorrectly identifies the past regeneration units to the south of units 38 and
45 as providing cover. These units burned with high mortality. The female grizzly
Maggie has been radio-collared in the area this past summer as well as close to where
units 22 & 24 are planned in the Kelsey fire. These units should be dropped to allow
more grizzly bear security.
Another area that provides some level of security for grizzly bears is Roderick Butte.
Local residents and Three Rivers employees saw signs of a female grizzly and cub in the
area last spring and early summer this year. It seems highly probable that Roderick Butte
and the ridgeline running towards the Roderick IRA is used as a corridor area for bears
and other wildlife.

In regards to road density and BMU’s, we are very concerned about two Bear Analysis
Areas: 4-11-4 and 4-16-10. Proposed activities will increase open road densities to 1.11
and 1.63mi/sq.mi. respectively in these two BAA’s. If I read the maps correctly these two
areas are in the Roderick Butte and Yodkin (6062 road system) and Beaver Creek
drainages. Please consider ways to reduce the road densities here, including no activities
in Roderick Butte that would entail using road 472F and dropping units such as 38,
39,43,44 & 45 in the Upper Yodkin and Beaver drainages. This would reduce road
density and at the same time maintain security areas for grizzly bears in the two areas. If
this still doesn’t meet the guidelines of ORD .75mi/sq.mi. along road 6062 please
consider winter logging along this road system in the lower elevation areas.

Somewhere I believed I read that USFWS recommends a minimum of 55% of each BMU
should be core areas. BMU’s 16 & 17 are far below that currently. It seems critical, not
just for core area but for watershed quality in the Basin drainage, that the roadwork
identified in the Basin Creek Salvage EA is completed. It should also be noted that in the
Gold Boulder Sullivan project under development in the Rexford District core area in
BMU 16 is identified as increasing—despite opening roads for activities—with the
assumption that road work in the Basin drainage is completed. Also, looking at the BMU
map there are several small areas in BMU 11 identified as core—from looking at the map
they seem far too small to provide adequate core area. Please address this in the FEIS.

From documenting activities in the Gold Boulder Sullivan area I’m skeptical that Rexford
Ranger District will effectively earth-berm roads in order to meet core area requirements
for BMU 17. Please list in the FEIS exactly what roads Rexford will berm and when that
will happen.

Again, it is our contention as a result of our monitoring report on fire severity/mortality
levels that hiding cover and corridor movement is still available in some of the proposed
units. Please address this in the FEIS.

Cumulative Effects:
Biodiversity in the Kelsey Beaver project area is suffering from the cumulative effects of
forty years of clearcuts & roadbuilding—not from the effects of wildfires. Every chapter
on every resource in the DEIS lists fire as a risk to something: fisheries, old growth,
wildlife habitat etc., yet the land, the watershed, the forests, the wildlife have been shaped
and formed by the natural process of fires for thousands of years. Old growth forests need
fire for stand decadence, snag recruitment, multi-storied forests—everything that makes
an old growth forest what it is depends on fire—yet the Kelsey Beaver DEIS states, “A
high severity reburn resulting from high fuel concentrations could burn or reburn MA 13
and further reduce MA 13 and/or old growth acres.” (3-128). Whoever wrote that should
take a plane ride over the project area and then tell everyone what exactly is reducing
mature forests.

Roderick Butte:
We are concerned that alternative B will drastically impact visual qualities with the
proposed clearcuts of 133 acres as well as negatively impact grizzly bears. With the
increased mortality of grizzly bears in the past two years it has become even more
apparent how important it is to maintain what little core security and corridor areas there
are in Yaak. We feel Roderick Butte is a critical area for the grizzly bear and that the
proposed clearcuts would drastically reduce the amount of area the bear can use. While
the tree mortality levels are high in the area it’s obvious when looking at past fire and
past fire salvage areas that some amount of security is still available in unlogged fire
areas.

I haven’t fully discussed this with our supporters who have commented on the
importance of keeping Roderick Butte in a natural state but perhaps we can support some
opportunities for helicopter harvest in key areas for fuels reduction and for creating
firebreaks without heavily altering the visuals of the landscape. I think this would need to
be done with a landing established off of Long Meadows Road; this way road 472F
would be kept closed for grizzly bear concerns as well as water drainage problems. I
would also again request that the district look at decommissioning and recontouring road
472F at a point where water drainage problems begin. With the wetness of the soils
helicopter harvesting would also help negate any potential soil compaction problems.

As stated in previous comments and field trips we would also like the Three Rivers
Ranger District to consider establishing portions of Roderick Butte as a Research Natural
Area. The area can be utilized in studying fire ecology in a wet, northeast aspect and the
resulting regrowth in areas that burned with varying intensities. In particular I’m
interested in seeing how white pine in the area responds to fire. From what I saw,
especially along the top ridgeline, the white pine in the area looked like it was fairly
resistant to blister rust and it would be worth looking at how the seedlings respond to fire
and how healthy these trees are as they grow. The Yaak Valley Forest Council would also
be interested in helping find ways to fund monitoring projects in the area as well.

Small Sales Alternative:
We request that Three Rivers Ranger District come out with a revised EIS on Kelsey
Beaver due to the inaccurate and misleading fire severity mapping and because a
reasonable range of alternatives was not presented in the DEIS. A small sale alternative
would provide more incentives to small, independent loggers in Lincoln County while at
the same time more effectively treat high fuels areas near roads by better utilizing smaller
diameter fire-killed trees. A small sales alternative should also address other concerns
such as openings over 40 acres, wildlife movement corridors, open road density in certain
BAA’s, etc.
Please develop an alternative that would focus salvage operations along roadsides in
lower elevation areas that doesn’t entail opening as many roads as the proposed action.
The focus should be on reducing fuels in the fire area while at the same time creating
firebreaks along roads that are near the private land interface. Also consider fuels
reduction of small diameter lodgepole and cedar along main roads in the project areas
that were not impacted by fire. These wood products could be sold as post n’ pole
material or other value added products to mills such as the cedar mill in Troy. In order to
reduce confusion and conflicts between contractors we advise that you look at
consolidating sales and bids based on road systems. For further recommendations on a
small sales alternative please review my scoping comments dated April 12, 2001.

Thank you for considering and listening to our concerns.

Sincerely,



Randy Beacham
Yaak Valley Forest Council

cc: Dale Bosworth, USFS Chief
Brad Powell, Region 1 Forester
Bob Castaneda, KNF Supervisor
Jerry Brown, MDFWP
Wayne Kasworm, USFWS



Literature Cited:

   Lowell, E.C., Willits, S.A., and R.L. Krahmer. 1992. Deterioration of fire-killed and
   fire-damaged timber in the Western United States. General Technical Report PNW-
   GTR-292. Portland Oregon. USDA Forest Service. Pacific NW Forest and Range
   Experimentation. 27p

   Reinhardt, E.D. and K.C. Ryan. 1989. Estimating tree mortality resulting from
   prescribed fire. In: Symposium Proceedings, Prescribed fire in the intermountain
   region. (Eds. D.M. Baumgartner, D.W. Breuer, B.A. Zamora, L.F. Neuenschwander
   and and R.H. Wakimoto). Washington State University, Pullman, WA. 41-44

   Morgan, P., Neuenschwander L.F., Swetnam, T.W. 2000. Testimony: To the
   Subcommittee on Forests and Forest Health, Committee on Resources, U.S. House of
   Representatives.

   Beschta, R.L., Frissell, C.A., Gresswell, R., Hauer, R., Karr, J.R., Minshall, G.W.,
   Perry, D.A., Rhodes, J.J., 1995. Wildfire and salvage logging: recommendations for
ecologically sound post-fire salvage logging and other post-fire treatments on Federal
lands in the West. Corvallis, OR: Oregon State University.

Sierra Nevada Ecosystem Report. 1996. Final Report to Congress

Historical and Current Forest Landscapes in Eastern Oregon and Washington. Part II:
Linking Vegetation Characteristics to Potential Fire Behavior and Related Smoke
Production.

Brassfield, R., Brammer, J., Carlson, J., Christensen, J., Phillips, S., Riggers, B.,
Walch, L., Walker K. 2001 Reducing Fire Risks to Save Fish—A Question of
Identifying Risk. A Position Paper by the Western Montana Level 1 Bull Trout Team.

				
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