Literature Review For The RodeoChediski Fire

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					                Literature Review For The Rodeo/Chediski Fire
                       Salvage and Rehabilitation Project
On August 24, 2002 a scoping notice was mailed to 389 groups, organizations and
individuals who have asked to be kept informed of activities on the Apache-Sitgreaves
and Tonto National Forests associated with the Rodeo/Chediski Fire. Two organizations
sent letters with references to the Beschta report and other commentaries that the Forest
Service should consider during the analysis of environmental effects of the proposed
Rodeo/Chediski Fire Salvage and Rehabilitation Project.

Center For Biological Diversity letter dated September 25, 2002

The Center For Biological Diversity, (referred to as CBD), located in Tucson, Arizona, in
a letter signed by Brian Segee, dated September 25, 2002, referenced the Beschta report
and other literature concerning salvage logging found on page 6 of that letter. A table
was provided as follows:

              Study                                      Comments
Beschta et al (1995)              Advocates natural recovery
Intermountain West                Provides management recommendations
McIver and Starr (2000)           Forest Service literature review
Intermountain West                Acknowledges negative effects
Klock (1975)                      Ground based logging causes severe soil disturbance
Eastside Cascades                 and erosion
Bayles et al (1995)               Salvage logging creates high sediment levels.
Interior Columbia Basin           Advocates limiting human effects
Perry (1994)                      Senate testimony on hazards of salvage logging
Minshall et al (1994)             Letter to President from scientists against postfire
                                  logging
Sexton (1998)                     Negative effects of salvage logging and seeding on
                                  ponderosa pine and vegetation
Keene (1993)                      Salvage should be used to restore, conducted within
                                  other forest values
Maser (1996)                      Lists negative effects of salvage, fundamentally
                                  questions practice
Peters et al (1996)               Salvage logging does not reduce fire, damages soils,
                                  streams, and wildlife
Brown (1997)                      Ecological effects of salvage logging are primarily
                                  detrimental
Caton (1996)                      Nest abundance higher in unlogged area for 16 of 17
Northwestern Montana              cavity-nesting birds.
Hitchcox (1996)                   Cavity-nesting birds at significantly higher densities in
Northwestern Montana              unlogged areas
Sexton (1994)                     Salvage decreased forb and shrub biomass, species
                                  richness, increased exotics



                                          -1-
The Beschta Report

The Beschta Report, a commentary titled Wildfire and Salvage Logging:
Recommendations for Ecologically Sound Post-Fire Salvage Logging and Other Post-
Fire Treatments On Federal Lands in the West,” by Dr. Robert L. Beschta, et al., (1995)
has been highly touted by the environmental community as reasons why a wildfire should
not be salvage logged. CDB went to some length to point out that the findings in the
Beschta Report was intended to apply to all interior western forests, including
Southwestern Region National Forests. Contrary to what CBD has stated, references to
interior western forests are not found throughout the Report, instead the only references
to western ecosystems occurred in four places: 1) “Western ecosystems have evolved
with, and in response to, fire. While some have argued that fire is the major imminent
threat to the health of the region’s forest ecosystems, it must be recognized that there are
a number of threats to the integrity of ecosystems in the interior west.” 2) “Forests of the
interior west can be viewed as a sea of relatively recently altered ecosystems surrounding
a few “islands” of relative ecosystem integrity (Frissell 1993a),” found on page 4; 3)
“Western ecosystems evolved with and in response to fires,” found on page 4; and 4)
“Virtually all western landscapes, including forests, have been subjected to severe
disruption by human activities,” found on page 5. Most, if not all research papers have
conclusions that are in agreement with these four statements. However, application of
the recommendations contained in the Beschta Report to interior western forests ends
with those four statements.

A review of the literature cited in the Beschta Report discloses most are related
exclusively to ecosystems found in the Pacific Northwest. For instance, out of the sixteen
different literature citations, eight deal with habitat restoration or changes in habitat for
salmon species found in the Pacific Northwest. Two that dealt with fire effects were for
the Southern Canadian Rockies and the 1988 Yellowstone fires. Another discussed
wildlife habitats of the Blue Mountains of Oregon and Washington. Not one dealt
specifically with salvage logging following a catastrophic fire. None of the citations are
specific to the arid southwest ponderosa pine ecosystems found in the Rodeo/Chediski
burned area, most of which occur on gentle, rolling flat terrain and sedimentary soils.

The Beschta Report has been peer reviewed. Dr. George G. Ice, PhD, in his 1995
commentary, titled A Review of the Report, stated: “If I was to summarize the author’s
(Beschta et al.) positions, it recommends reverting to nature rather than working with
nature. Given the existing fuel loads in western watersheds and overlapping
environmental and social concerns, we believe an exclusively laissez faire approach to
wildfire is inappropriate.” Dr. Ice provided compelling reasons, both ecologically and
socially for rapid intervention on the post-fire landscape, contrary to the statements made
in the Beschta Report.

In his report, Dr. Ice states: “Hydrologic, water quality, and channel impacts from
wildfires are often greatest the first year following the fire. Dry ravel resulting from
combustion of the litter layer and soil-binding organics occurs during and immediately
following the fire (2). Hydrophobic soil conditions (which can increase surface runoff
and channel erosion) result from condensation of volatile organics and are greatest


                                            -2-
immediately following a wildfire (3). Exposed soil and surface erosion from wildfires is
greatest the first year as is the potential for mobilization of channel material. Amaranthus
found between 67 and 100 percent of surface erosion occurring within a few months (4).”

Dr. Ice goes on to state: “Aside from the environmental benefits of rapid intervention,
there are a suite of social benefits. Not the least of these is the potential to salvage
valuable timber. Although decay of timber varies, for some species this loss in value is
very rapid. Dales, in a report by Tesch, provides estimates of decay for five timber
species (8). The salvage period for average-sized trees ranges from 1 year to more than
ten years but there is economic loss beginning immediately after death of the trees.
“Wood-boring insects begin to mine sapwood and heartwood immediately after the fire
and cause lumber degrade” (8). This argues for rapid salvage of timber to avoid
additional losses of value.” He finished this section to state: “Contrary to the author’s
conclusions, there are opportunities to reduce the environmental and economic impacts
following wildfires but these must be done as soon as possible.”

Dr. Ice quotes from Roger J. Poff in his 1989 commentary entitled Compatibility of
Timber Salvage Operations with Watershed Values, “….salvage logging can improve
watershed condition by increasing ground cover, by removing a source of large, high
energy water droplets, and by breaking up hydrophobic soil layers. Salvage logging also
has the potential to generate funds for watershed improvement work, and the potential to
reduce the future risk of high-intensity fires by reducing fuel loading” (9). Dr. Ice’s
report is applicable to the conditions found on the ground within the Rodeo/Chediski
burn area.

CBD then states, “Moreover, the findings of the Beschta report have been directly
acknowledged and adopted within the Southwest,” and pointed out that, “The Mexican
spotted owl recovery team, at page 88 of the spotted owl recovery plan, states that “the
recovery team advocates the general philosophy of Beschta et al. (1995) for use of
salvage logging.” CBD has failed to recognize that the recovery plan was just that,
written by the US Fish and Wildlife Service, and the direction provided to Southwestern
forests outlined in the Record of Decision for Amendment of Forest Plans, and signed by
Regional Forester Charles W. Cartwright, Jr., on June 5, 1996, does not incorporate nor
adopt the general philosophy of Beschta et al. concerning salvage logging. Specifically,
the Forest Plan Amendments (Appendix B, Forest Plan Amendments and Forest Plan
Corrections), for the Apache-Sitgreaves and Tonto National Forests in relation to the
Mexican spotted owl recovery plan do not mention salvage logging or adopting the
general philosophy of the Beschta Report, pages 21-27 and 80-81 respectfully. Instead,
the Regional Forester provided standards and guidelines as developed in Alternative G,
which was the selected alternative to be implemented. This direction is applicable to the
Rodeo/Chediski burn area.

In an August 17, 1995, letter to the Regional Forester of Region 6, Richard Everett,
Science Team Leader provided an in-depth review (known as the Everett Report) of the
statements made in the Beschta Report. In the summary it is stated:




                                           -3-
       “The custodial approach recommended by the Beschta document appears less
       desirable than active management on at least two points: soil protection and fuels
       reduction. By their own admission current systems are altered in structure and
       process, and fire effects are increasingly beyond those experienced historically.
       As a result fire effects in dry forest types are no longer an historically-similar
       phenomena in which species previously existed. Extended fire-free intervals have
       increased tree density while at the same time reducing remnant shrubby and
       herbaceous plants and their seed reserves. Combined loss of the forest floor from
       increased burn intensity and reduced post-fire plant response increases hazard of
       erosion and loss of surface soils. There is a need for active management to
       conserve post-fire soil resources that takes precedence over the protection of the
       current native plant community.”

The Everett Report concludes the summary by stating, “As stated in the review, the
immediate reduction of fire hazard is not the issue, it is the long-term fire hazard which is
of concern. The extended timeframe until fire hazard increases (20+ years) provides
opportunities to reduce fuels with minimal adverse impacts to resources. The decline in
economic benefits from salvage logging over time because of wood decay should be
considered and weighed against potential economic costs associated with loss of soils,
water and fish resources.” Indeed, the Forest Service has reviewed the Beschta Report
and found it either lacking or not applicable to other areas, specifically to arid ponderosa
pine ecosystems found in the Rodeo/Chediski burn area.

CBD, at page 5 of their letter, has twisted the Everett Report findings by quoting a couple
of sentences out of a paragraph and then drawing conclusions contrary to the rest of the
paragraph. First, CBD states, “The Everett Report concurred with several key aspects of
the Beschta report including its conclusion that there is no data supporting the notion that
post-fire salvage logging reduced the risk of reburn. For example, page 4 of the Everett
report states that “there is no support in the scientific literature that the probability of
reburn is greater in post-fire tree retention areas than in salvage logged sites, “and that the
Beschta report is “…correct that the intense reburn concept is not reported in the
literature.”

The paragraph in its entirety follows from page 4 of the Everett report:

       “There is no support in the scientific literature that the probability for reburn is
       greater in post-fire tree retention areas than in salvage logged sites. The real
       question is not whether there is a greater probability for reburn, but if reburns
       occur will they be of greater intensity and more destructive to resources. The
       authors are correct that the intense reburn concept is not reported in the literature.
       It took time since fire suppression started (early 1900s) for forest tree density and
       cover to increase, and it took time for random ignitions to burn these altered sites
       (Entiat fire 1970, 107,000 acres, Dinkleman fire 1989, 52,000 acres, Tyee fire
       1994, 140,000 acres). It is taking more time for burned snags to fall and burned
       forests to again increase in tree cover and fuels continuity (Martin et al. 1976).




                                             -4-
       Because of the time tables involved the field testing of the intense reburn concept
       started in the recent past and will continue into the future.”

The next paragraph clarifies this situation further where Dr. Everett states:

       “A precise evaluation of the effects of salvage logging and total tree retention on
       reburn fire intensity has not been accomplished. What is in the literature is that
       when dead and live tree biomass increase so does flame length, and fireline
       intensity (Rothermal 1983). Temperatures and duration of heat increase with
       added forest fuels (Ottmar and Vihnanek, 1990). Mass fires with extremely
       violent behavior occur when excessive fuels are ignited (Project Flambeau,
       Countryman 1969).”

CBD then went on to twist the findings of the Everett even further by stating, at page 5,
“At page 5, the Everett report states that current research suggests that salvage logged
areas may have elevated fire hazard over unlogged sites, and at page 6 concludes that
“the urge to remove woody biomass is not based on reducing short-term fire hazard, but
on the capture of economic values and reduction of long-term fire hazard.”

The Everett report, at page 5, states something entirely different. This specific paragraph
is quoted as follows:

       “Future fire hazard is complex with or without wood removal. Current research
       (Fire Science Team, in progress) suggests that salvage logged areas may have
       elevated fire hazard over tree retention sites the first 20 + years, but retention sites
       would have elevated fire hazard from then into the future. Snag longevity models
       for ponderosa pine, Douglas-fir and grand fir following fire indicate a significant
       pulse of log biomass from burned snags 6 to 9 inches in diameter occurs after
       approximately 20 years. Standing snags present a much reduced fire hazard than
       logs, thus there is reduced fire hazard until snags fall.”

CBD continues this tactic on page 6 of the Everett report. This paragraph actually states
in its entirety:
         “The urgency to remove woody biomass is not based on reducing short-term fire
         hazard, but on the capture of economic values and reduction of long-term fire
         hazard. The urgency comes from removing wood before it decays, becomes less
         economically feasible to extract, and makes further reductions in fuel loading
         more expensive to the American taxpayer.”

The Everett Report, contrary to CBD’s statements, is particularly relevant to conditions
found in the Rodeo/Chediski burn area.

McIver and Starr (2000) Intermountain West

CBD cites McIver and Starr as a Forest Service review; acknowledges negative effects.
The correct title of this publication is Environmental Effects of Postfire Logging:



                                            -5-
Literature Review and Annotated Bibliography, and is a detailed listing of known
scientific literature on logging after wildfire, with a focus on environmental effects of
logging and removal of large woody structure. The authors provide detailed reviews of
129 references, which included information that varied from subjective opinion to
replicated and controlled scientific studies. The findings of this report are summarized in
two tables. “Table 1 – Perceived effects of postfire logging,” displays both positive and
negative effects instead of only negative effects as CBD portrays. Many of the studies
and references provided in McIver and Starr’s report are directly applicable to the
Rodeo/Chediski burn area.

“Table 2 – Results of scientific studies that investigated logging effects and structural
changes for postwildfire logging,” lists scientific studies conducted primarily in the
northwest, includes studies from Australia and Israel and one un-replicated experiment
conducted in the ponderosa pine vegetation type of the Prescott National Forest in
Arizona during 1973-1974. This report, conducted by John G. Blake (1982) and titled,
Influence of fire and logging on nonbreeding bird communities of ponderosa pine forests
was conducted in the arid southwest. One of his conclusions was, “For birds, burning
explains more of the variation in abundance and species composition than does logging.”
It should be noted that the Beschta Report does not appear in this table because it is
classified as a commentary.

Klock (1975) Eastside Cascades

CBD cites G. O. Klock’s report as “Ground based logging causes severe soil disturbance
and erosion.” The correct title of this 1975 report is, Impact of fire postfire salvage
logging systems on soils and vegetation and was conducted on the east slope of the
Cascade Mountains of central Washington on the Entiat National Forest in pine and
Douglas-fir. Here CBD again has totally misrepresented the conclusions drawn in this
report. This un-replicated experiment studied cable and tractor skidding, skyline and
helicopter systems and tractor skidding on snow. The conclusions drawn were:
“Helicopter and tractor-on-snow logging preserved the most vegetation cover; logging by
skyline and tractor on bare ground were intermediate; cable skidding preserved the least.”
The report cites information on soil disturbance and logging in several other studies and
states, “advanced systems are better than traditional ones.” All systems, both advanced
and traditional, are being considered for application within the Rodeo/Chediski burn area.

Bayles et al (1995) Interior Columbia Basin

CBD cites Bayles’s report as “Salvage logging creates high sediment levels, advocates
limiting human effects. This two-page commentary, titled Forest Health and salvage
logging: What’s the connection? is an unpublished report developed in the interior
Columbia Basin and addresses sediment caused from salvage logging and road building
activities. Four conclusions were drawn: (1) “No evidence that salvage logging improves
watersheds…, and a great deal of evidence that it does harm;” (2) “Dead trees serve a
necessary function and are important to ecosystem recovery;” (3) “Thinning and
underburning can be beneficial in some instances, but fuel reduction cannot be done on a



                                           -6-
large enough scale;” and (4) “Limiting human effects will best help ecosystems.” It is
not clear from what basis CBD could state; “salvage logging creates high sediment
levels,” as that was not one of the conclusions drawn by this author. This commentary
was based on conditions found in the Columbia Basin and not those found within the
Rodeo/Chediski burn area.

Perry (1994)

CBD cites this August 29, 1994 testimony before the Senate Hearing on Forest Health as
“Senate testimony on hazards of salvage logging.” CBD has misrepresented David
Perry’s testimony as the actual conclusion reads, “Salvage decisions must strike balance
between benefits and hazards of down wood.” This testimony discussed three categories
of (forest) health problems: disturbance vulnerability, habitat loss, and soil degradation
and recommended that managers reintroduce fire (into the ecosystem); fuel reduction and
thinning should be applied judiciously; avoid building new roads and thin from below.
This testimony is applicable to the Rodeo/Chediski burn area.

Minshall et al (1994)

CBD cites this two page commentary, on file with Pacific Rivers Council, Eugene,
Oregon, from five scientists against logging after wildfires as: “Letter to President from
scientists against postfire logging.” CBD has provided yet another commentary out of
the Pacific Northwest with little to do with salvage logging in the arid southwest and
specific conditions found within the Rodeo/Chediski burn area.

Sexton (1998)

CBD erroneously cites this 28 page unpublished manuscript (actually dated 1994 instead
of 1998) titled Ecological effects of post-wildfire salvage-logging on vegetation diversity,
biomass, and growth and survival of Pinus ponderosa and Purshia tridentate as,
“Negative effects of salvage logging and seeding on ponderosa pine and vegetation.”
This was a replicated experiment conducted 1993-1994 in central Oregon on the
Chiloquin Ranger District where wildfire areas were compared with salvaged areas and
not salvaged areas. CBD somehow overlooks the reported results that salvage increases
graminoids and pine seedlings grew 17 percent higher on salvaged sites. This particular
study did report that salvage decreased canopy cover (13.5-5.3 percent); salvage lowered
forb and shrub biomass in the first 2 years; salvage reduced species richness (23-20 in
1993; 22-16 in 1994); and salvage increased exotic species. Short-term changes in
canopy cover, forb and shrub biomass, species richness and chance of introduction of
exotic species are being considered in the EIS being developed for rehabilitation of the
Rodeo/Chediski burn area.

Keene (1993)

CBD cites this three-page commentary titled Salvage logging: health or hoax as,
“Salvage should be used to restore, conducted within other forest values.” The actual



                                            -7-
conclusion drawn from this report is, “Salvage should be conducted within full context of
other forest values.” Other conclusions read as follows: “Salvage is a tool, to be used
only to restore, not to do further damage;” “Defines salvage as “rescue,” save, or heal;”
and “National Forest Management Act regards salvage in separate light from green tree
harvesting—this is bad.” The rehabilitation treatments being proposed for the
Rodeo/Chediski burn area will consider these conclusions during development of project
design features.

Maser (1996)

CBD cites this 1996 commentary titled Salvage logging: the loss of ecological reason
and moral restraint as, “Lists negative effects of salvage, fundamentally questions
practice.” This commentary concludes by listing seven negative consequences of
salvage, questions the practice of salvage per se, and salvage is economical, not
ecological. The rehabilitation treatments being proposed for the Rodeo/Chediski burn
area will consider these conclusions during development of project design features.

Peters et al (1996)

CBD cites this 1996 commentary titled, Managing for forest ecosystem health: a
reassessment of the “forest health crisis, as “Salvage logging does not reduce fire risk,
damages soils, streams, and wildlife.” This 36 page commentary put together by the
Washington DC Defenders of Wildlife and in cooperation with Northwest Ecosystem
Alliance, Bellingham, WA; and Klamath Forest Alliance, Etna, CA concludes “Salvage
logging results in damage to soils, streams, and wildlife habitat and impairs a forest’s
ability to recover;” “Logging may exacerbate disease;” Salvage may not reduce fire risk,
because risk depends more on weather than fuel;” and “Thinning and prescribed fire can
benefit forests but pose risks also.” The conditions found in this burn area are different
than those found in the Pacific Northwest, however, the rehabilitation treatments being
proposed for the Rodeo/Chediski burn area will consider these conclusions during
development of project design features.

Brown (1997)

CBD cites this 1997 commentary titled, Post-fire salvage, published in the Natural
Resource News, La Grande, OR as “Ecological effects of salvage logging are primarily
detrimental.” This commentary concluded that, “A careful weighing of economic
benefits versus ecological risks must be done before deciding to salvage harvest” and that
“Ecological effects of salvage harvests are predominantly detrimental.” The conditions
found within the Rodeo/Chediski burn area are different than those found in Oregon,
however, the rehabilitation treatments being proposed will consider these conclusions
during development of project design features.




                                           -8-
Catron (1996) Northwestern Montana

CBD cites this 1996 Ph.D. dissertation titled Effects of fire and salvage logging on the
cavity-nesting bird community in northwestern Montana as “Nest abundance higher in
unlogged areas for 16 of 17 cavity-nesting birds.” Other results of this study were listed
as follows: “In logged sites, most birds nested only in partial cuts; Tree-forager
abundance higher in partial cut; flicker and mountain bluebird more abundant in clearcut;
Flathead National Forest and Glacier National Park very different in tree diameters and
species; Nests in the Flathead National Forest were found in sites with tree diameters
significantly higher than average; tree diameter difference between nest sites and average
was less in Glacier National Park; and Stands around partial cuts had higher diameter
basal area and height, compared to clearcuts.” This interesting study, conducted in
northwestern Montana in mixed conifer vegetation, is not relevant to the arid conditions
found on the Rodeo-Chediski Fire in ponderosa pine and pinyon-juniper vegetation types.

Hitchcox (1996) Northwestern Montana

CBD cites this M. S. thesis titled “Abundance and nesting success of cavity-nesting birds
in unlogged and salvage-logged burned forest in northwestern Montana as “Cavity-
nesting birds at significantly higher densities in unlogged areas.” This study, conducted
from 1993-1995 in northwest Montana in mixed conifer, lists the following results:
“Most nests were secondary;” “Eighteen species nested in unlogged areas; 8 in logged
areas;” “Mean nest density was higher in unlogged areas for all species;” “Black-backed
woodpecker, three-toed woodpecker, red-naped sapsucker, and Williamson’s sapsucker
present only in unlogged areas;” “Nest abundance higher each year postfire;” “Unlogged
plots had higher density tall and large-diameter trees, more live trees, and more trees with
bark;” “Unlogged plots were less severely burned;” “Logged plots had higher proportions
of snags;” “Logged areas appeared to have had lower tree densities before fire;” and
“Most species of birds selected larger than average trees for nesting in both logged and
unlogged plots.”

What CBD has quoted as “Cavity-nesting birds at significantly higher densities in
unlogged areas” was taken from the abstract of this study. The actual quote should have
read as follows: “Unlogged areas had more cavity-nesting bird species nesting at
significantly higher densities compared to salvage-logged areas.” Most of the cavity-
nesting bird species listed in this study are not found in the southwest and in particular,
within the Rodeo-Chediski burn area.

Sexton (1994) Oregon

CBD cites this 28 page unpublished manuscript titled Ecological effects of post-wildfire
salvage-logging on vegetation diversity, biomass, and growth and survival of Pinus
ponderosa and Purshia tridentate as, “Salvage decreased forb and shrub biomass, species
richness, increased exotics.” This was a replicated experiment conducted 1993-1994 in
central Oregon, Chiloquin Ranger District where wildfire areas were compared with



                                            -9-
salvaged areas and not salvaged areas. CBD somehow overlooks the reported results that
salvage increases graminoids and pine seedlings grew 17 percent higher on salvaged
sites. This particular study did report that salvage decreased canopy cover (13.5-5.3
percent); salvage lowered forb and shrub biomass in the first 2 years; salvage reduced
species richness (23-20 in 1993; 22-16 in 1994); and salvage increased exotic species.
Short-term changes in canopy cover; forb and shrub biomass, species richness and chance
of introduction of exotic species are being considered in the EIS being developed for
rehabilitation of the Rodeo/Chediski burn area.

At page 7 in their September 25, 2002 letter, CBD states that Sexton concludes that
“salvage logging resulted in a significant decrease in understory biomass, species
richness, species diversity, and growth and survival of P. ponderosa and P. tridentate,”
and that “salvage-logging reduced species richness, species diversity, and altered species
composition.” This exact quote could not be found in the Sexton document.

The abstract of this study, which was quantified on the Lone Pine Fire area on the
Winema National Forest in the Klamath Basin, Oregon, states however:
       “Biomass of the understory was significantly lower in salvage-logged areas
       compared to areas that were not logged following fire. In 1993, the understory of
       salvage-logged sites produced 38.2% (322 kg/ha vs. 843 kg/ha) of the
       aboveground biomass produced on nonsalvaged sites. In 1994, salvage-logged
       sites produced only 27.3% (402 kg/ha vs. 1468 kg/ha) of the biomass produced
       on nonsalvaged sites.”

The abstract fails to qualify this statement since most salvage logging occurs on severely
burned sites which sterilizes soils, soils become water-repellent for up to four years after
fire and considerable soil nutrients (especially nitrogen) are lost with fire. Short-term
changes are being considered in the EIS being developed for rehabilitation of the
Rodeo/Chediski burn area.

While this report has discussed the references cited by CBD, it is important to display the
references they failed to cite that were developed here in the southwest and are relevant
to the Rodeo/Chediski burn area. For example, within the same publication that they
used to develop their list of references from, Environmental Effects of Postfire Logging:
Literature Review and Annotated Bibliography, they overlooked the scientific
unreplicated experiment that is described by John G. Blake that was conducted on the
Prescott National Forest of salvage logging that occurred in 1973-1974 in a document
titled Influence of fire and logging on nonbreeding bird communities of ponderosa pine
forests which was published in the Journal of Wildlife Management. This study
concluded with the following results: “For birds, burning explains more of the variation
in abundance and species composition than does logging;” “Openess” was a very
important variable; for example, for seedeaters and flycatchers;” “Use of unburned
clearcut sites and the burned sites suggests that openness of habitat was more important
than the type of alteration.”




                                           - 10 -
Another study described in the same document listed above, titled Wildfire effects on a
ponderosa pine ecosystem: an Arizona case study, conducted by Campbell, R. E. et al. in
1977, where a severe wildfire killed about 50 percent of the sawtimber trees. This fire
was salvaged logged and the study concludes with the following results: “Runoff,
sediments, and soluble salts increased considerably immediately after the fire;” “Soils
became water-repellent for at least 4 years after fire;” Deer use increased after fire, but
numbers of rodents decreased;” “Considerable soil nutrients (especially nitrogen) were
lost with fire;” “The ecosystem is flexible and does recover;” and “Ninety percent of the
pulpwood and 50 percent of the sawtimber were lost in severe fire; losses were less for
moderate fire.” Conditions described in this study are explicitly applicable to the
Rodeo/Chediski burn area as this study was conducted in north-central Arizona.

CBD also fails to mention several commentaries and other studies described in this same
document that supports salvage logging as a tool to rehabilitate burned areas. It is
unfortunate that within this same document a reader may find one of the most
comprehensive discussions of the general effects of wildfire, studies that examine the
environmental effects of postfire logging and structural changes available in the
literatures. CBD totally ignored the conclusions drawn, starting at page 19 through 22, of
which many discuss positive effects of salvage logging.

In their September 25th letter, they state at page 3, “It is essential that the Forest Service
directly, fully and honestly address the body of scientific research and literature
addressing the environmental effects of post-fire salvage logging.” Sadly, CBD has
failed on all points to observe their own admonition. Instead, they have resorted to
distorting conclusions developed by respected scientists such as was done in their
discussion (at page 5) concerning the Everett Report.

Forest Conservation Council letter dated September 6, 2002

The Forest Conservation Council (hereafter referred to as FCC), located in Santa Fe, New
Mexico, in a letter dated September 6, 2002 that responded to the scoping request for the
Rodeo/Chediski Fire Salvage and Rehabilitation Project, also referenced several
documents that the Forest Service should consider during development of the
environmental documents supporting this project. Calling their references as “the best
available science,” they, like CBD have totally ignored other conclusions from respected
scientists that support salvage logging and fuels reduction projects following a wildfire.
Their references are addressed in the order presented in the following discussions.

Klock 1975

See page six of this report for discussions of the applicability of the conclusions drawn in
G. O. Klock’s report to the Rodeo/Chediski burn area.




                                             - 11 -
Marston and Haire 1990

FCC has referenced this report, titled Runoff and soil loss following the 1988 Yellowstone
fires in connection with the Beschta Report, at page 2 of their September 6, 2002 letter.
While this scientific unreplicated experiment was conducted in the Yellowstone National
Park in 1988-1989, and has different vegetation and soil conditions found on the
Rodeo/Chediski burn area, the results are quite different than the discussions and
conclusions found in the Beschta Report. The results of this study were: “Sites logged
before burning showed greatest erosion, probably because higher fuel loads caused high-
intensity fire;” “Water-repellent soil was common and produced more erosion;” “Rate of
runoff did not differ between glacial till and volcanic terrain;” “Litter density was key to
controlling soil loss;” and “Postfire logging had little effect on runoff, soil loss, litter, or
organic matter compared to wildfire only.”

While this report did not focus on the efficiency of the project design features
incorporated into the treatments, they certainly must have been effective for the authors
to arrive at this latter result. Project design features (mitigation measures) being
incorporated into rehabilitation efforts for the Rodeo/Chediski burn area are anticipated
to produce the same results.

Minshall et al., 1994

See page seven of this report for discussions of the applicability of this commentary to
the Rodeo/Chediski burn area.

Beschta et al., 1995

See pages two and three of this report for discussions of the applicability of the Beschta
Report and its recommendations to the Rodeo/Chediski burn area. Other scientists such
as Dr. George Ice and Richard Everett do not share the same opinion of the Beschta
Report as being the “best available science.” FCC has referenced this document a
number of time throughout their September 6, 2002 letter, totally ignoring science that
describes the Beschta Report as an improper approach to rehabilitation of a severe burn
such as experienced in the Rodeo/Chediski burn area. Many of the conclusions drawn in
the Beschta Report are not applicable to this burn.

McIver and Starr, PNW-GTR-486, 2000

See pages five and six and related discussions on pages 9-11 of this report for
applicability of this excellent and thorough review of the scientific information available
concerning discussions of the general effects of wildfire, studies that examine the
environmental effects of postfire logging and structural changes available in the
literatures. FCC has totally ignored the conclusions drawn, starting at page 19 through 22
of this important study, of which many discuss positive effects of salvage logging.




                                             - 12 -
Stickney, 1990

FCC failed to include this reference in their literature cited section, therefore it is not
considered in this report.

Lyon, 1976

FCC has made reference to Jack L. Lyon’s research completed on the Sleeping Child
Burn in Montana, titled Vegetal Development on the Sleeping Child Burn, 1961-1973.
This wildfire occurred in primarily lodgepole pine and mixed conifers in Montana and is
not applicable to ponderosa pine in the arid southwest that is predominate in the
Rodeo/Chediski burn area.

Cohen, Preventing Disaster, Home Ignitability in the Wildland-Urban Interface,
2000

FCC has made reference to Jack D. Cohen’s 2000 study titled Preventing Disaster, Home
Ignitability in the Wildland-Urban Interface, which utilized the Structure Ignition
Assessment Model. At the time of these experiments, the model had not been developed
to assess the potential for structure ignitions from flame exposure and firebrands, at page
17, Journal of Forestry. The burns were conducted in jack pine and black spruce that
burn very differently than ponderosa pine under the conditions that prevailed during the
Rodeo/Chediski wildfire. Other scientists have reached conclusions that contradict Mr.
Cohen’s results (Brown, James K., 1980), (Agee and others, 2000), and (van
Wagtendonk, 2000).

Cohen, Reducing the Wildfire Fire Threat to Homes: Where and How Much, 1999

FCC has made reference to Jack D. Cohen’s 1999 paper titled, “Reducing the Wildland
Fire Threat to Homes: Where and How Much?, which concludes as follows:
       “Specific to the W-UI fire loss problem, home ignitability ultimately implies the
       necessity for a change in the relationship between homeowners and the fire
       services. Instead of all pre-suppression and fire protection responsibilities reading
       with fire agencies, homeowners should take the principal responsibility for
       assuring adequately low home ignitability. The fire services become a
       community partner providing homeowners with technical assistance as well as
       fire response in a strategy of assisted and managed community self-sufficiency
       (Cohen and Saveland 1997). For success, this perspective must be shared and
       implemented equally by homeowners and the fire services.”

Mr. Cohen’s observation applies to the Rodeo/Chediski WUI situation where he
discusses the publics expectations of fire services to protect them from wildfire:
“Contrary to these expectations for fire protection, the fire services have neither the
resources for effectively protecting highly ignitable homes during severe W-UI fires, nor
the authority to reduce home ignitability.”




                                             - 13 -
Cohen, Why Los Alamos Burned, 2000

FCC has made reference to Jack Cohen’s 2000 paper titled Why Los Alamos Burned in
connection with the above two references by the same author. Other scientists have
reached conclusions that contradict Mr. Cohen’s results (Finney, 1999), (Agee and
others, 2000), and (van Wagtendonk, 2000).

Arno et al. 1995

FCC has made reference to S. F. Scott; J. H. and M. G. Hartwell’s 1995 research paper
titled Age-class structure of old growth ponderosa pine/Douglas fir stands and its
relationship to fire history, where it is stated that “Even ponderosa pine forests have been
found to have originated in stand replacing fire events.” Most research scientists have
reached conclusions similar to this. This conclusion is applicable to the Rodeo/Chediski
burn area.

Schmoldt, Daniel L., et al.

FCC has made reference to Daniel L Schmoldt, et al. 1999 research paper titled Assessing
the Effects of Fire Disturbance on Ecosystems: A Scientific Agenda for Research and
Management, where it is stated that “Drought and other climatic factors are the primary
causes of large-scale fires, which occur regardless of fuel conditions.” Both the Rodeo
and Chediski wildfires were human caused, during a prolonged drought, at a time of the
year when the southwest experiences its worst burning conditions of the year. These two
fires burned together in fuels that are considered to be outside the range of natural
variability to become the largest wildfire in Arizona’s history. Future fuel conditions are
predicted to range from over 40 tons/acre to as high as 90 tons/acre across the landscape
of the Rodeo/Chediski burn area, with many stands having as high as 3,000 stems per
acre of small diameter trees that served as ladder fuels (Fuels Specialist Technical Report,
Les Buchanan, Project Record).

FCC had other references listed in their “Literature Cited” section, however there was no
direct reference to them in their September 6, 2002 letter. Therefore they were not
addressed in this report.

Conclusions Reached As A Result of This Review

It should be noted that both the Center for Biological Diversity and Forest Conservation
Council referenced “the best available science” that should be considered in the
environmental analysis being conducted on the Rodeo/Chediski burn area. If their
references were not negative toward salvage logging, quite often the scientist’s
conclusions were misconstrued and twisted to appear so. Both organizations have failed
to reference scientific evidence that does support postfire salvage. There are many, for
instance: Maloney, P. et al. 1995; Simon and others, 1994; Poff, R. J. 1988; and Amman,
Gene D.; Ryan, Kevin C. 1991. These scientists did studies in the same ecosystems that
both organizations have provided references with negative conclusions concerning



                                           - 14 -
salvage logging, and ignored science that displays positive results. This approach speaks
plainly of their agenda toward conservation of our nation’s natural resources.



Jimmy E Hibbetts
Rodeo/Chediski ID Team Leader

November 15, 2002




                                          - 15 -
Literature Cited:

Agee, J., B. Bahro, M. Finney, P. Omi, D. Sapsis, C. Skinner, J. Van Wagtendonk,
       and C. P. Weatherspoon. 1999. The use of shaded fuel breaks in landscape fire
       management. Forest Ecology and Management 127(2000): 55-66.

Amman, Gene D.; Ryan, Kevin C. 1991. Insect infestation of fire-injured trees in the
    greater Yellowstone area. Res. Note INT-398. Ogden, UT: U. S. Department of
    Agriculture, Forest Service, Intermountain Research Station. 9p.

Arno, S. F., Scott, J. H. and M. G. Hartwell. 1995. Age-class structure of old growth
      ponderosa pine/Douglas fir stands and its relationship to fire history. Res. Pap.
      INT-RP-481. Ogden, UT: U.S. Department of Agriculture, Forest Service,
      Intermountain Research Station, 25 p.

Bayles, David; Minshall, G. Wayne; Frissell, Christopher. 1995. Forest health and
       salvage logging; What’s the connection; 2p. Unpublished report. On file with:
       Interior Columbia Basin Project, U.S. Department of Agriculture, Forest Service,
       Pacific Northwest Research Station, 1401 Gekeler Lane, La Grande, OR 97850.

Beschta, R. L.; Frissell, CA; 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.

Blake, John G. 1982. Influence of fire and logging on nonbreeding bird communities of
       ponderosa pine forests. Journal of Wildlife Management. 46(2): 404-415.

Brown, James K. 1980. Influence of harvesting and residues on fuels and fire
     management. In: Proceedings, Environmental consequences of timber harvesting
     in Rocky Mountain coniferous forests; 1979 September 11-13; Missoula, MT.
     Gen. Tech. Rep. INT-90. Ogden, UT: U. S. Department of Agriculture, Forest
     Service, Intermountain Forest and Range Experiment Station: 417-432.

Brown, Rick. 1977. Post-fire salvage. Natural Resource News. La Grande, OR: Blue
     Mountains Natural Resources Institute; 7(3): 4.

Campbell, R. E.; Baker, M. B., Jr.; Ffolliott, P. F. [and others]. 1977. Wildfire
     effects on a ponderosa pine ecosystem: an Arizona case study. Res. Pap. RM-
     191. Fort Collins, CO: U. S. Department of Agriculture, Forest Service, Rocky
     Mountain Forest and Range Experiment Station. 12 p.

Caton, Elaine Lisa. 1996. Effects of fire and salvage logging on the cavity-nesting bird
       community in northwestern Montana. Missoula, MT: University of Montana.
       115 p. Ph.D. dissertation.




                                          - 16 -
Cohen, Jack D. 1999. Preventing Disaster, Home Ignitability in the Wildland-Urban
      Interface. Journal of Forestry, March 2000.

Cohen, Jack D. 1999. Reducing the Wildland Fire Threat to Homes: Where and How
      Much?, USDA Forest Service Gen. Tech. Rep. PSW-GTR-173.

Cohen, Jack D. 2000. Why Los Alamos Burned, USDA Forest Service, 1999

Everett, Richard. 1995. Letter dated August 17, 1995 to John Lowe, Regional Forester,
       R-6, Review of the Beschta document. 8p. On file with: U. S. Department of
       Agriculture, Forest Service, Pacific Northwest Research Station, 1133 N. Western
       Ave., Wenatchee, WA 98801.

Hitchcox, Susan M. 1996. Abundance and nesting success of cavity-nesting birds in
      unlogged and salvage-logged burned forest in northwestern Montana. Missoula,
      MT: University of Montana. 89 p. M.S. thesis.

Ice, G. G., Megahan, W. F., McGreer, D. J., Belt, G.H., 1995. A Review of the
        Report, “Wildfire and Salvage Logging: Recommendations for Ecologically
        Sound Post-Fire Salvage Logging and Other Post-fire Treatments on Federal
        Lands in the West,” 10 p., [on file at the National Council of the Paper Industry
        for Air and Stream Improvement, Inc., P.O. Box 458, Corvallis, OR 97339].

Keene, Roy. 1993. Salvage logging: health or hoax. Inner Voice. [Place of publication
      unknown]: Association of Forest Service Employees for Environmental Ethics;
      (March/April): [3 p.].

Klock, Glen O. 1975. Impact of five postfire salvage logging systems on soils and
       vegetation. Journal of Soil and Water Conservation. 30(2): 78-81.

Lyon, L. Jack. 1977. Attrition of lodgepole pine snags on the Sleeping Child burn,
      Montana. Res. Note INT-219. Ogden, UT: U.S. Department of Agriculture,
      Forest Service, Intermountain Forest and Range Experiment Station. 4 p.

Maloney, P. Cavan: Thornton, John L.; Lesch, Ellen. 1995. Executive summary:
      summary of watershed monitoring within the Foothills fire salvage logging area
      1992-1995. Boise, ID: U.S. Department of Agriculture, Forest service, Boise
      National Forest. 13 p.

Maser, Chris. 1996. Salvage logging: the loss of ecological reason and moral restraint.
      International Journal of Ecoforestry. 12: 176-178.

Minshall, G. Wayne; Meyer, Judy L.; Stanford, Jack A. [and others]. 1994. Letter
      dated September 19 to President Clinton on fire and salvage logging. 2 p. On file
      with: Pacific Rivers Council, P.O. Box 10798, Eugene, OR 97440




                                           - 17 -
Perry, David A. 1994. Testimony, August 29, Senate Hearing on Forest Health: Boise,
       ID. Corvallis, Or: Department of Forest Science, Oregon State University. 6p.

Peters, Robert L.; Frost, Evan; Pace, Felice. 1996. Managing for forest ecosystem
       health: a reassessment of the “forest health crisis.” Washington, DC: Defenders of
       Wildlife. 36 p. In cooperation with: Northwest Ecosystem Alliance, Bellingham,
       WA; Klamath Forest Alliance, Etna, CA.

Poff, R. J. 1988. Compatibility of Timber Salvage Operations with Watershed Values.
       p. 137-140, in Proceedings of the Symposium on Fire and Watershed
       Management, Berg, N.H. [/ed,], USDA Forest Service Gen. Tech. Rep. PSW-
       109 (October 1988).

Sexton, Timothy O. 1994. Ecological effects of post-wildfire salvage-logging in
      vegetation diversity, biomass, and growth and survival of Pinus ponderosa and
      Purshia tridentate. Corvallis, Or: Oregon State University, Department of
      Rangeland Resources. 28 p. Unpublished manuscript. On file with: Department
      of Rangeland resources, Strand Agriculture Hall, Oregon State University,
      Corvallis, OR 97331.

Simon, Jerry; Christy, Stephen; Vessels, Joseph. 1994. Clover-Mist fire recovery: a
      forest management response. Journal of Forestry, November: 41-44.

van Wagtendonk, J. W. 1983. Prescribed fire effects on understory mortality.
     Proceedings of the Fire and Forest Meteorology Conference 1983 pp. 136-138.




                                         - 18 -