From Rick Brown,

							July 15, 1999

Sonny O’Neal
Wenatchee National Forest
215 Melody Lane
Wenatchee, WA 98801-5933

Dear Supervisor O’Neal,

The Lands Council and the Kettle Range Conservation Group appreciate the time and effort
that has gone into the scientific review of the Sand Project, as well as the discussion of
landscape management issues contained in the Wenatchee Dry Forest Strategy. The
Wenatchee can be commended for taking a new look at the restoration of dry forests, and
the Sand Project area in particular. This blind review has been educational and thought
provoking and helpful far beyond the Wenatchee Forest boundaries. Discussions we have
had with policy makers in Washington D.C. indicate a keen interest in the subject.

We believe a Supplemental EIS for the Sand Project needs to be issued to address the
significant new information presented by the Dry Forest Strategy and the science
assessment, and to address the gap in the range of alternatives of the FEIS. A new,
additional alternative needs to be developed in the SEIS that proposes fuels reduction
treatments through prescribed burning and, where necessary, manual pretreatments
without any commercial timber extraction or new "temporary" road construction. We believe
that ample arguments for the viability of this prescribed fire only alternative can be found in
the fire portion of the science assessment.

We are also interested in seeing the Dry Forest Strategy presented and discussed in the
public arena. At this point the Dry Forest Strategy is not a NEPA document, nor part of a
Forest Plan amendment, yet it changes the way the Forest looks at, and plans on managing
for the indefinite future. We believe that the draft version should be presented at public
meetings, comments taken, and a final form be submitted to the NEPA process.

The strategical objective of this prescribed fire only alternative should be authentic
ecosystem restoration through reintroduction of wildland and prescribed fire across the
landscape-including the portions excluded from timber extraction treatments in the FEIS.
This would offer a real alternative to the continuation of a wildland fire exclusion strategy in
the Sand project.

A Temporal View Of Landscape Restoration Is Needed
Dr. Paul Hessburg stated that the Forest does not take a long enough temporal view, either
in the Dry Forest Strategy (DFS) or the Sand Project. We agree that a long term look is
critical and would be helpful before the projects proceed.

That Sand project Alternative B is designed to move the system back towards historic
conditions is said repeatedly, indicating at least one of the blind reviewers thinks we are
trying to regain historic, pre-settlement conditions. Further clarification of what the intent of
the Dry Forest Strategy, and the Sand Project is trying to achieve is needed. Even the
thought of moving toward a historic condition must be made with caution, since we have yet
to establish, and agree on what that historic condition is.

Then there is the whole question of where the process and direction for "Returning the
forests to presettlement conditions." is going. Reviewer 2 said that if they were going to
follow that, they needed a NEPA process. We see that the Forest needs a NEPA process
either way---if you are going to adopt "returning the forest to presettlement conditions" you
need a NEPA process for that. If, as Bob Stoehr now says, and John Lemkuhl was firm on,
they are NOT returning the forest to presettlement conditions, the Forest need a
supplemental EIS because that was the basis for the Sand project.

We also note that much of the historic condition is stated in terms of tree stand
characteristics (silviculture), which other parameters such as wildlife, hydrologic functioning,
plant communities, climate, soils, etc. are not considered.

For example, Blind Reviewer 4 suggested that the Strategy in general inadequately
considers soils and their protection against compaction and erosion stemming from
management treatments. Both Reviewers 3 and 4 state that potential negative impacts of
suggested treatments are inadequately addressed in the DFS. This suggests that
hydrologic function, non woody plants, wildlife habitat needs, etc. are not fully analyzed.

Reviewer 3 suggested that the document “portrays dry forest vegetation and disturbance
dynamics as simple and homogenous, whereas in reality these forest are more diverse and
complex. ...the reviewer described the most obvious shortcoming of the Strategy as the
weak discussion of the multi-scale role that insects (and pathogens) play in influencing
disturbance and vegetation patterns. The Sand project also contains virtually none of the
insect and pathogen discussion that the Reviewer described is lacking in the Dry Forest
Strategy.

A supplemental EIS would be beneficial to answer the above questions.

A FIRE ONLY RESTORATION/RECOVERY ALTERNATIVE NEEDS TO BE FULLY
ANALYZED IN A SUPPLEMENTAL EIS, CONSIDERING NEW INFORMATION

The Wenatchee Forest took a brief look at a no commercial logging alternative for the Sand
Project, but did not rigorously explore this from either a biological or economical basis. It is
clear from the review that fuel levels are not too high that prescribed fire can be used solely.
This important new information calls for a supplemental EIS to fully analyze a burn-only
strategy - one that could restore all of the Sand Project area, not just the part in the
proposed timber sale.

Cost is an important factor. As the acres to be burned increases, the cost will decrease per
acre and in the long run be far cheaper than a timber sale. Our conversations with other
fire ecologists indicate an economy of scale with landscape burning that was not captured
in the Sand EIS analysis. We also question the DFS characterization of small diameter
wood being salable - From DFS page 9: There is an expectation that small diameter green
sales will have higher values than those sales of similar sized burned material that were
sold after the 1994 fires. This is clearly not the case with the Asian economy and
dumping of BC wood on the market. Further analysis of the impact of small diameter
scales on the market, and the reality of implementing a strategy that is dependent on
market prices is needed in both the DFS and the Sand Project

      The differences between a logging project and a fire restoration project are
      significant and should be differentiated in the alternative analysis. Even the most
      severe fire doesn't build roads, doesn't compact soils, and doesn't remove all wood
      (especially the crucially important large snags and logs). The following quote is from
      "Creating a Forestry for the 21st Century: the science of ecosystem management"
      edited by Kathryn Kohm and Jerry Franklin, Island Press, 1997, p. 113.

      Recent research on forest ecosystems has clarified the importance of structural
      complexity to forest ecosystem functioning and the maintenance of biological
      diversity (Franklin 1993, Bormann and Likens 1979, Swank and Crossley 1988,
      Franklin et al. 1987, Maser et al. 1988, Harmon et al. 1986, Spies, Chapter 2).
      Important structural features include snags, woody debris on the forest floor, multiple
      canopy layers, varied sizes and conditions of live trees, and presence of canopy
      gaps. Research has also made clear the dramatic impacts that clearcutting and other
      management activities can have on biological diversity and ecosystem function; for
      example, in Sweden clearcutting is the major factor threatening endangered forest
      organisms (Berg et al. 1995).

      Investigation of the effects of natural disturbances on forest ecosystems and their
      subsequent recovery also have dramatically altered our understanding of these
      events (see Perry and Amaranthus, Chapter 3). Results from these studies
      emphasize the importance of biological legacies -- surviving organisms and
      organically derived structures, such as snags, logs, and soil organic layers to the
      rapid re-establishment of ecosystems that have high levels of structural, functional,
      and compositional diversity. Similar patterns of extensive legacies emerge from
      disturbances as diverse as wildfires (Christensen et al. 1989, Schullery 1989, Knight
      and Wallace 1989), hurricanes (Foster and Boose 1992, Walker et al. 1991) and
      other storm events (Peterson and Pickett 1995), and volcanic eruptions (Franklin et
      al. 1995, Franklin et al. 1985). These natural patterns contrast sharply with low levels
      of biological legacies associated with even-aged regeneration harvest practices,
       particularly clearcutting, even when treatments do not involve intensive site
       preparation (see, e.g., Keenan and Kimmins 1993)."

An important research paper that should be considered for the Sand "Ecosystem
Restoration" Project was recently written by Jack Cohen, research scientist at the Fire
Sciences Lab of the Forest Service's Rocky Mountain Research Station. This document has
been accepted for publication and is officially "In Press" for the Proceedings of the Fire
Economics Planning and Policy Bottom Lines Symposium in San Diego, California. The
paper and its findings have also been accepted by the supervisors of the Rocky Mountain
Research Station.

Cohen's research findings essentially eliminate arguments for increased logging, road-
building, or grazing as alleged means of protecting homes from wildfires. According to
Cohen, it is home ignitability factors, rather than wildland fuels, that is the principal cause of
home losses during wildland/urban interface fires. Current strategies for wildland fuel
reduction, such as the extensive commercial timber extraction planned in the Sand timber
sale, will be inefficient and ineffective for reducing home losses, for this large fuel reduction
on public lands does not effectively reduce home ignitability factors on private lands. The
Dry Forest Strategy and the Sand Project both should be updated to indicated that the
primary and ultimate responsibility for home wildfire protection lies with private
homeowners, not public land management agencies--or taxpayers.

The relationship to long term landscape restoration on public lands is clear. If homeowners
reduce home ignitability on their lands, then opportunities to use prescribed fire for the sake
of authentic ecosystem restoration may be greatly enhanced on our public lands, even in
the wildland/urban interface zone. The myth that commercial timber extraction will protect
rural communities from wildfire is simply not true, and the expectations and fear associated
with wildfire on public lands should be readdressed in the Dry Forest Strategy and a
supplemental EIS for the Sand Project.

Finally, the Wenatchee cannot continue to ignore implementation of the Federal Wildland
Fire Policy and resist development of a new fire management plan. For example, the
Medicine Bow-Routt National Forest is developing a Wildland Fire Use Program, as
required by the federal policy. The Wenatchee’s new fire management plan should
precede the landscape-scale projects proposed in Sand and other timber sales soon to
follow.

What can be accomplished by fire alone matches the Dry Forest Strategy exactly:
        1. Management Objectives for Protecting, Maintaining, or Enhancing Forest
        Health on Dry Forests
                  (1) Reduce stand density
                  (2) Alter species composition
                  (3) Reduce fuel loads to conditions consistent with native fire regimes
                  (4) Maintain tree density consistent with native fire regimes
                  (5) Reforest created openings
                 (6) Maintain desired fuel levels consistent with native fire regimes
                 (7) Maintain Native Grass and Shrub Communities
A logging project will remove some of the ability to maintain native species diversity, due to
compaction, roads, exposed soils, noxious weeds, changes in hydrology and weather
dynamic, and maintaining natural fire regimes. A supplemental EIS could address these
differences.

THE SAND PROJECT NEEDS FURTHER WATERSHED ANALYSIS

Watershed Analysis in the Sand Project does not meet the analysis recommended in the
Dry Forest Strategy. While floods are certainly a natural event, the timing and intensity can
be cumulatively affected by human management. After 100 years of logging, building,
roading, grazing and farming downstream our systems are not as resilient, aquatic or
socially (cities downstream). As per the Dry Forest Strategy, the Forest should perform the
NEPA cumulative effects analysis on the Sand Project to show what added impacts from
management will have. In the blind review the Watershed reviewer stated that old models
and old references were used, but were adequate as was the analysis. However, NEPA is
clear that up to date information must be used and scientific models must be accurate and
include recent information.

There are a number of watershed management issues that are pertinent to discussion of
dry forest management and should be a part of the site specific project analysis. These
issues are complicated by: (a) the changes in vegetation that have occurred historically
over large portions of the watersheds due to reduction in fire frequency and increase in fire
intensity; (b) changes in soils by repeated stand entries and historic grazing impacts; and
(c) resulting cumulative changes to the watershed as a whole affecting the water regime.
It is well understood that these "dry forest" watersheds have been altered. In addition to the
changes in stand structure and composition previously discussed, other alterations are
present; roads, cattle driveways, soil compacton from logging and grazing, and settlements
below the forests.
Many of the dry forest watershed are unglaciated with sandstone parent material in a lower
elevation drier climatic regime. A common landsystem description is that these systems are
"flashy" meaning they have high per unit area spike peak flow volumes with low baseflow.
The classic cumulative effects analysis is therefore complicated by a changing vegetative
structure and a more subtle change in soil condition from historic conditions. It is not just a
matter of evaluating a proposed stand entry given historic entries and a road system. The
background structure of the watershed on which the proposed impacts will be
superimposed is very dynamic. Specifically the water balance has presumably changed
given the fact that these are moisture limited environments and vegetation has increased
significantly. Certain assumptions as to the nature of the soil profiles current ability to
handle water, and cycle nutrients and organic matter, may not be valid when put in a
systems framework.
The analytical approach might be divided into two major steps: modeling a water balance,
water yield, sediment, and mass failure frequency regime pre- vegetative and soil horizon
impacts of the past hundred plus years, what could be termed a pre-management scenario;
and secondly, superimposing over this modified environment effects of a highly mitigated
understory removal treatment. The following topic areas should be discussed in cumulative
effects analysis:

1) Site specific water balance analysis at a first order system level with effects routed
   through third and fourth order watershed systems;
2) Site specific flood analysis at a first order system level with effects routed through third
   and fourth order watershed systems;
3) Water balance changes applied over an entire fourth order system and specific to
   aspect, elevation and vegetation zonation;
4) Comparison of historic and current soil profile properties, trend of watershed condition,
   and both in relation to the proposed action.
5) Sediment regime given both long and short term changes in soils, applied over the first
   order and cumulated to the fourth order scale, both historically and from current
   management;
6) Sustainability of watershed functions including hill slope routing of water and sediment,
   riparian interactions with aquatic and stream channel environments, and stream channel
   geomorphology.
7) Effects of historic, current and proposed road systems;
8) Comparison of watershed system response with and without the proposed action and
   with a major wildfire event;
9) Connectivity of all the above to localized site productivity, riparian zone function and
   condition, stream channels, and resident anadromous fish species as the most
   restrictive beneficial use of the aquatic system.

The above analysis should include a clear documentation of approach used and key logic
assumptions. The analysis should contribute to both the formulation and evaluation of
alternatives to the proposed action, and should influence the selection of the preferred
alternative.

Thank you for the opportunity to provide further input into the restoration of the
Wenatchee’s dry forests, we hope you will carefully consider our comments and we look
forward to a supplemental EIS for the Sand Project.


Sincerely,

Mike Petersen, for The Lands Council
Elizabeth Allen, for Kettle Range Conservation Group