The Ecology Center, Inc.
801 Sherwood Street, Suite B
Missoula, MT 59802
(406) 728-5733
(406) 728-9432 fax
ecocenter@wildrockies.org
October 6, 2000
Jon M. Hayes
Dept. of Natural Resources and Conservation
Southwestern Land Office
1401-27th Avenue
Missoula, MT 59804
re: Sula State Forest Restoration
Dear Mr. Hayes,
This letter supplements the September 20th comments submitted by the Ecology Center
regarding the Sula State Forest Salvage plan with the following comments. These
comments relate to issues discussed and areas viewed during the field trip of October 3.
We thank you for the opportunity to learn more about the project while on the field trip.
Public Comment
We request a thorough reply to each substantive comment that follows in this letter as well
as those that were included in the Ecology Center’s September 20th comment. We request
that all submitted comments be included in the EA as either reproductions of the
comments in entirety, excerpts of all substantive comments, or careful summary of each
substantive comment. We believe lumping together comments into vague generalizations
of concerns does not adequately meet the requirements for considering public concerns as
part of the MEPA process.
Time Frame and Process
We are concerned that the DNRC’s perceived need to log quickly will result in a failure to
adequately consider the environmental consequences of salvage logging. While we grant
that timber value may decline over time to some degree, we believe that the degree of
decline does not justify conducting the MEPA process in a rushed and seemingly insincere
manner.
We request a thorough explanation of the DNRC’s perceived need to rush through the
MEPA process. This explanation should include a thorough scientific discussion of the
pattern and schedule of any anticipated blue stain development on pine trees. Please
specifically address whether the expansion of blue staining is possible in winter conditions.
We also request that the DNRC describe the timber market situation that provides impetus
for the desire to sell salvage timber before the market becomes flooded with supply. If
oversupply is an issue, please explain the influence that the supply of salvaged timber from
state land will have on private timber suppliers.
We have very serious objections to the short-cutting of the MEPA process the DNRC is
using to expedite the salvage logging. We were told on the field trip that the process is:
1. 20-day public comment period based upon one-page scoping letter, ending September
20.
2. October 3 field trip, with comment period re-opened for unspecific period for field trip
participants.
3. October 16, DNRC takes proposal (whatever that is, no EIS or “Environmental Analysis”
will be ready) to Land Board for final approval.
4. “Environmental Analysis” and decision document distributed on November 15.
5. One week later, bids opened and sales awarded.
While we are glad that the DRNC has decided to not seek emergency exclusions for salvage
logging, we are concerned that the process used will still not allow for a meaningful and
adequate MEPA process that will lead to fully informed decisions. We are particularly
concerned that bringing the decision to the state land board on 10/16/2000, nearly a
month before the scheduled completion of the EA (11/15/2000), will not allow the land
board, the public, and even DNRC to be adequately informed of the impacts of the salvage
logging.
For most citizens, their only real opportunity for input is long past. And that opportunity
was based upon the limited information provided in a one-page scoping letter, plus what
information one might obtain by tracking down the appropriate DNRC employees to answer
questions. Obviously, lacking an opening in one’s schedule for field trip participation or
the time to finally reach busy DNRC employees, informed comments and public
participation would be impossible.
We are told that we should trust the professionals in the agencies. Unfortunately, our
experience in the realm of forestry on public lands leads us to have little trust in the
agencies. This has especially been the case when the normal public review process is
shortened, as also happened during the Salvage Rider days on federal public land in the
mid-1990s. An example directly experienced by the Ecology Center was the Studebaker
Fire Salvage on the Kootenai National Forest. This is documented in the website at:
http://www.wildrockies.org/teci/forestfraud. We urge you to examine that website and try
to tell us, with a straight face, to trust agencies that seek to short-cut the normal public
review process. We request that you to download each page of that website and print them
out in color to include them in the project record. We fully incorporate each of those pages
in these comments.
Presentation to the land board is proposed to occur in less than two weeks. Yet,
discussions that occurred on the field trip made it clear that the DNRC has not yet
considered project impacts to a degree that allows for understanding of the environmental
consequences of salvage logging. While some specialists may have begun initial fieldwork
and analysis of environmental consequences, it seems that little or no collaboration or
synthesis has yet occurred between specialists. Due to the intrinsic intertwinement of
ecosystem elements, such collaboration and synthesis is necessary to develop an adequate
understanding of the project’s ecological effects.
As the environmental analysis included in DNRC EAs are often minimally comprehensive
and detailed at best, we are extremely doubtful that the land board can be adequately
informed of environmental effects prior to the completion of the EA. What measures will
the DNCR take to ensure that the land board members are adequately informed and what
provisions will be allowed so that the public can ensure this?
2
We feel that it is unreasonable for the DNRC to ask the land board to make a decision
based upon incomplete information and trusting that the EA will be adequately developed.
We feel that this decision making strategy undermines the intent of land board approval.
Pre-decision Activities
The DNRC’s initial activities to prepare for salvage logging seemingly suggest that the
DNRC does not intend to consider the environmental effects findings of the EA to any
meaningful degree. For example, the field trip clearly revealed that the DNRC has begun to
mark the 1 to 2 snags per acre that will remain after logging without having the EA confirm
that this snag retention rate is adequate to meet the needs of wildlife in the area. The
resource and time commitment that the DNRC has already committed to the project as
currently proposed will clearly lead the DNRC to resist any project changes suggested by
public concern or EA findings.
Forest Health Perspective
Comments made my DNRC officials on the field trip strengthened our convictions that the
DNRC’s apparent philosophy that humans can and should interfere with natural processes
is severely misguided. The forests have evolved to include fire as a natural mechanism for
regeneration and renewal. The overall sentiment of the field trip appeared to be that the
forest was undergoing a forest health crisis and that rapid action was necessary to salvage
what value remained following a catastrophe. The drastic extent and intensity of the post-
fire salvage logging proposed indicates that the sentiment of the DNRC is to appeal to the
public perspective of “catastrophic” fire to enable a massive logging project that grants little
or no consideration to maintaining the integrity of the forest by allowing natural processes
to occur.
The forest is currently in a fragile post-fire state. Rather than proposing heavy logging, the
DNRC should be acknowledging the forest’s fragile state and responding accordingly. This
acknowledgement should include leaving more trees that can serve as snag habitat
because of the loss of structural complexity in areas outside the salvage area due to fire.
Tree Mortality
During the field trip, we were told by Tony Liane that no “green trees” would be logged, that
only “dead trees” would be cut. Participants quickly pointed out that such assurances,
while sounding simple, were practically impossible to administer accurately. This is
because of the delay between the fire event and the time when a tree can be definitely
determined to be dead. It was stated that trees suffering fatal injuries from a fire may look
green and thus alive for a long time, therefore the decision to log some green trees would be
based on the degree of scorching of the exposed root. It was also acknowledged that live
trees will have the appearance of being dead because of discoloration or burning of the
needles, yet will grow new needles the spring following the fire.
It was also stated that the decision would be based upon whether green needles were left in
the crown. The subjectivity—and therefore inaccuracy—of this method is also obvious.
Accurate determination of tree mortality is made even more difficult by the DNRC’s
insistence to expedite the logging to preserve economic value of the trees. Obviously, the
sooner logging begins, the less accurate will be mortality determinations.
More troubling to us is the insistence by one of the DNRC foresters that bigger trees are
less likely to survive than smaller ones, due to their higher vulnerability to crown loss.
This contradicts research showing that larger diameter trees, especially fire resistant trees
3
such as ponderosa pine, withstand proportionately greater stem and crown damage than
smaller trees (McCulley 1950, Lynch 1959, Hare 1965, Martin 1965, Bevins 1980, Wyant et
al. 1986, Harrington and Hawksworth 1988).
Harrington and Hawksworth, as well as Wyant and others, determined that a ponderosa
pine’s chances of surviving fire increased proportionately in larger diameter tree classes.
Thus, a 30 inch diameter, healthy tree with 75% scorch was found to have a 65% chance of
living (Harrington and Hawksworth 1988).
The trees in the areas we visited on the field trip showed a lot of scorch on the trunks, but
the crowns were generally discolored (turning brown or grayish) but unburned. As stated
above, research shows that larger ponderosa pine and Douglas-fir (which together by far
were the majority of tree species in the areas visited) have more resistance to this visible
scorch of the trunk due to the thickness of the bark. From our tour, it seems that most of
the trees in the burned areas were similarly damaged, i.e. the trunks were scorched to
some degree and the crowns showed signs of stress but were not consumed by the fire.
Other areas looked quite black from a distance, and viewed up close the crowns of the trees
in those areas did look as if they had been consumed by flames. The DNRC, however, did
not seem to make any distinctions between the areas burned with different intensities in
the crowns. This suggests a fallacy in considering the amount of “green” in the
crown, rather than considering the degree of actual crown scorch.
It appears that the DNRC is utilizing the science on this subject in a very illogical manner,
and we fear it is so that logging more of the bigger trees can be justified. The DNRC does
not seem to know enough about available predictive models. Better yet, DNRC should take
a much more conservative approach to making tree mortality assumptions because you
simply don’t know enough to make accurate predictions of tree mortality, a problem
exacerbated because the project is on such a fast track.
We are attaching to these comments a Missoulian article about the Payette National
Forest’s difficulties with accurately estimating tree mortality, and a Forest Service memo
regarding the accuracy of their mortality predictions.
In a related matter, it is even more troubling to us who gets to make the call on whether a
tree is alive or dead. We were told that, beyond the DNRC marking one or two trees per
acre for retention, contract language will outline the process of tree mortality
determination. In other words, it will be up to the loggers to decide, on the ground, how to
apply the guidance. So at least two steps removed from what is inexact science, at best,
you will have people making the cutting decisions who are extremely biased toward logging
the biggest trees.
Loggers are not paid to make the right decisions in managing the forest—that’s the DNRC’s
job. Loggers are paid to cut down trees for the economic advantage of the companies, and
that’s what you must expect they’ll do.
In a side conversation, Jeff Juel asked how the DNRC would be able to monitor this
situation, and was told that DNRC employees would only be able to visit a site once a day
at most. This means that evidence of bad judgment or timber theft by loggers would be lost
once a tree is cut. One would be unable to tell if a stump without paint was from a live tree
or dead tree once the log was moved or de-limbed. The public would likewise be put in a
position of being unable to monitor correct implementation regarding tree mortality. In
deciding on the use of contract language to specify trees to be cut, DNRC should consider
4
the results of its previous experiences with administering fire salvage timber sales that use
similar contract language for determining tree survival.
In sum, we believe it would be irresponsible on the part of DNRC to assume that contract
language will adequately govern tree mortality determinations so soon after the fire, and it
would be extremely reckless to essentially turn loose the loggers without adequate
accountability measures.
Old Growth
The DNRC must carefully detail its plan “to remove some of the dead trees” from old growth
areas. If the DNRC’s forest manipulating practices have allowed natural processes to
proceed unchecked anywhere in the state forest, such retention of natural processes would
certainly occur in old growth areas. Old growth forests, even or particularly those
undergoing a process of fire induced regeneration, represent an essential resource for
wildlife and ecosystem services. The DNRC’s proposed manipulation and disruption of 800
of the 1200 acres of Sula’s old growth forest will represent an egregious detriment to
wildlife and ecosystem services.
We are gravely concerned because the proposal does not treat old growth any differently
than the rest of the forest. We know that old growth often tends to burn less intensively
than previously logged areas, since past logging means the fire resistance of a forest has
been reduced. Despite the fact that old growth—even old growth affected by fire—has far
greater value to wildlife and for water quality, DNRC has not even considered an alternative
that recognizes such values. Old growth should be the last areas examined for logging, so
that more accurate tree mortality determinations can be made and the impacts to these—
the most ecologically important areas—can be both fully analyzed and minimized.
The DNRC is already facing litigation about its vague, ever-changing definition of old
growth, so it is extremely important that the DNRC delineate the remaining old growth in
the Sula Forest, using scientifically acceptable criteria such as those used by the Bitterroot
National Forest and the Northern Region of the U.S. Forest Service.
Snags
The project proposal to retain 1 to 2 large snags per acre seems inadequate to provide for
habitat needs of forest species given the large area of proposed logging and the loss of
structural complexity due to fire in forests adjacent to the cutting units. We request that
you review the science used to develop this snag retention rate. We request that the DNRC
consider how fire effects the need for and benefits of snags.
SMZs
The DNRC said it is considering logging in burned riparian areas (the Streamside
Management Zone or “SMZ”). The SMZ law requires that, when logging is contemplated in
SMZs, the value the trees have for shading or screening the stream and riparian area must
be considered. Especially in burned areas where the shading function of trees already has
been severely reduced, it makes absolutely no sense to log SMZs because even dead trees
provide some badly needed shade.
Grazing Restrictions
We are pleased that the project will include grazing restrictions. Due to the large potential
detriment of grazing on the fire sensitized ecosystem, we support complete grazing
exclusion for an extended time period. The DNRC is reacting under an apparent
“emergency” situation because of the fire, yet we were dismayed to see cattle still foraging
5
in what was termed the Sula South area. Continued cattle grazing on soils and vegetation
affected by a fire does not impress us as responsible stewardship.
Soils
The post-fire sensitivity of soils to erosion should compel careful consideration of logging
technique on steep or unstable slopes. Discussions during the field trip gave the
impression that logging would occur without special high-slope precautions at slope angles
up to 35 degrees. Given the tenuous post-fire stability of the slope, an angle of 35 degrees
appears to be too high for initiation of special techniques. We request that the EA
thoroughly discuss post-fire stability issues and disclose the rationale for determining 35
degrees as the cutoff for high-slope methods.
The soil compaction anticipated to occur as a result of logging activities must be thoroughly
analyzed.
Regeneration
We are concerned that grass seeding and reforestation measures may prevent natural post-
fire successional patterns that are essential to the post-fire regeneration of the forest. The
“immediate tree planting” of 900 acres and potential planting of up to 7,650 acres must be
carefully detailed in the environmental analyses and should be discussed in reference to
the potential natural forest post-fire regeneration. Potential impacts of logging related
disturbance on natural regeneration must be thoroughly analyzed.
The field trip fact sheet suggests that “natural regeneration will be surveyed in summer
2001.” While we believe that monitoring of natural regeneration is an essential component
of projects for which planting is proposed, we are concerned that making planting decisions
this early may not provide sufficient time for more desirable natural regeneration to occur.
Roads
The impacts of the 1 to 2 miles of new roads should be thoroughly analyzed. These new
roads, even and particularly if being created as small segments, will have a significant
impact on the fragile post-fire soils. Slopes that would normally be considered stable may
be unstable in their post-fire state. We request that the analysis of the ecological impacts
of road building consider the particular needs of the post fire ecosystem. Given the large
potential for erosion of post-fire soils, closure and stabilization of additional miles of road
should be considered.
We are also concerned that eight culverts need to be replaced. As fire is a natural
component of ecosystem process, road construction must accommodate for overland flow
increase associated with this natural facet ecosystem process.
The fact sheet DNRC provided to field trip participants implies that many roads in the
burned area do not meet Best Management Practices standards. And during our trip least
two road segments were pointed out as being out of compliance with BMP standards. The
DNRC admitted that it relied heavily upon timber sales to fund efforts to bring roads up to
BMP standards, and that without them the work often fails to get done in a timely manner
because of limited funding sources outside of timber sales. We are seriously concerned
about the ongoing resource damage from roads that won’t be brought up to BMP standards
as a part of the project.
It is also clear that the DNRC will not consider the costs it will later incur to finally bring all
roads in the Sula State Forest into compliance with BMP standards in this timber sale
6
analysis. The fire affected practically every acre of the Sula Forest. Since the impacts of
the fire mean that there may not be any substantial timber sales in the Sula Forest for
several decades following this proposed sale, we strongly question why the DNRC is not
even thinking about how all roads will be maintained or brought up to BMP standards in
the future. We also wonder about the legality of ignoring these ongoing out-of-compliance
conditions in the Sula Forest.
Some segments of roads we traveled on the field trip were wet, muddy, and badly rutted.
The DNRC must consider the possibility that the expedited logging might exacerbate such
problems. We question whether the DNRC will have the will to shut down logging activities
in wet weather, given the emergency mentality DNRC exhibits concerning loss of wood
value.
The third stop of the field trip featured a discussion of road obliteration along Lyman
Creek. The extremely close proximity of the old road was a good argument for its
obliteration, as proposed. However, we noticed that segments of the road leading to this
site were also closely encroaching on the creek. There was no rationale provided for not
considering the obliteration/relocation of this and all other roads in the Sula Forest that
are built along streams.
Economics
The proposed logging project, as we understand it, raises serious economic concerns. We
wonder how the DNRC will be able to sell all the timber it plans to, given the currently
depressed market. Low bids will raise the incentive to highgrade the burned areas of the
biggest trees—whether or not they are actually dead.
We have not seen any substantial economic analyses, despite the fact that the State Forest
is to be managed to maximize return to the trust.
Given the properties of the resources at hand (i.e. forest ecosystems), the DNRC policy of
conducting a non-discounted economic analysis that fails to include future activities on a
project by project analysis is utterly inadequate. The loss of value of ecosystem services
(e.g. purification of water and air and temperature regulation), loss of recreation potential,
degradation of the intrinsic worth of forest ecosystems, and loss of board feet of timber
must be considered in order for an economic analysis to be meaningful. Current receipts
from timber sales should be discounted with reasonable estimates of future increases in
the value of the resource (i.e. the increased worth of trees when logging on private, state,
and federal land increases tree scarcity).
At the very least, the economic analysis should incorporate the future road maintenance or
obliteration costs of constructed or maintained roads associated with each project.
Conversations with several DNRC officials related to this issue provided no rational for the
DNRC’s failure to incorporate future costs associated with each project except for the
administrative difficulties of doing so. Given that any private timber company would not
conduct an economic analysis without considering future costs for fear of making an
economically undesirable decision, the DNRC’s historic failure to do so is completely
unacceptable. We hope that that the Sula Salvage logging EA may consider future costs.
The DNRC should recognize the economic and ecological incentives to do much more to
assure the retention of all live trees. Live trees will provide a free source of seeds for forest
regeneration for years to come. Trees that have survived the fire are also the ones with the
most desirable genetic traits to pass on to the next generation, maximizing productivity and
7
therefore revenue to the trust. Live trees would also provide cover for the small seedlings of
the regenerating forest. These are economic values that are hard to measure, nevertheless
their values can be assigned dollar estimates.
Logging Pattern
The proposed pattern of logging as revealed by the “potential harvesting areas” map
supplied during the field trip appears to have disturbing implications for forest
fragmentation. In the western and northern areas of the northern cutting units, the project
proposes to leave small forest fragments lingering among a sea of functional clearcuts
representing salvage logging areas. The map reveals no attempts to preserve wildlife travel
corridors between salvage logged areas. The influence of the proposed logging activity on
forest fragmentation and the influence on wildlife of such fragmentation must be carefully
analyzed.
The DNRC must realize that burned areas are still a vital part of a functioning forest
ecosystem that provides for essential needs of many species. The burned forest cannot be
envisioned as an ecological wasteland, the disturbance of which will not influence
ecosystem function.
Watershed and fisheries
We fear that the expedited process to recover economic value poses a significant risk to
water quality and fisheries. A project of this scale necessitates a comprehensive watershed
analysis, integrating the information on monitoring of past project impacts, instream and
riparian conditions, fish species’ presence and population trends, and the fact that water
yield is already increased above normal because of the fire and from past clearcutting. A
proper watershed analysis would is also important given the fact that you have obviously
damaged streams from roads and livestock grazing.
Synthesis
Despite all the good points brought up during the field trip, we observed that DNRC
officials made no commitment to change any specific aspect of the proposal. Everything we
heard indicated that the decision to log, and also when and how to log, was already made.
As we understand the proposal, here is the likely scenario: Loggers will cut the trees they
see as being the most merchantable, due to the marginal timber market. This means they
will log the biggest trees, regardless of their being alive or dead (since the DNRC will be
unable to adequately monitor). The risk posed by later reburn that some claim exists with
remaining dead trees will not be substantially reduced, because the biggest, most fire
resistant tree trunks will be the only wood taken out of the forest. The future economic
value of the Forest will be compromised.
Please send us with a map of all the old growth in the project area, telling us the types of
old growth and the criteria used to designate each area.
Please send us with a copy of all scientific information the DNRC is using to provide
guidance in the process of writing contract language dealing with the designation of a tree
being considered dead and therefore included for logging. Also please send us a copy of the
language that will be used in the contract, dealing with this subject.
Please send us a discussion of the rational basis for the anticipated bid prices assumed to
be received for the timber.
8
Sincerely,
Jeff Juel Lauren Buckley
Literature cited:
Bevins, C.D. 1980. Estimating survival and salvage potential of fire-scarred Douglas-fir.
USFS Res. Note INT-287, 8 p. Intermt. Forest and Range Exp. Stn., Ogden, Utah.
Hare, R.C. 1965. Contribution of bark to fire resistance of southern trees. Journal of
Forestry 63:248-251.
Harrington, M.G., and Hawksworth, F.G. 1988. Interactions of fire and dwarf mistletoe on
mortality of Southwestern ponderosa pine. Effects of fire in management of Southwestern
forests, pp. 234-240, USFS Gen. Tech. Rept. RM-191, Ft. Collins, Colorado.
Lynch, D.W. 1959. Effects of a wildfire on mortality and growth of young ponderosa pine
trees. USFS, Intermt. Forest and Range Exp. Stn. Res. Note 66, 8 p. Ogden, Utah.
Martin, R.E. 1965. A basic approach to fire injury of tree stems. Proc. Tall Timbers Fire
Ecol. Conf. 2:151-162.
McCulley, R.D. Management of natural slash pine stands in the flatwoods of South
Georgia and North Florida. U.S. Dep. Agric. Circ. 845, 57 p.
Wyant, J.G, Omi, P.N., Laven, R.D. Fire induced tree mortality in a Colorado ponderosa
pine/douglas fir stand. Forest Science 32(1): 49-59.
9