Sales Position Statement

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					    Position Statement on Commercial Timber Sales in the Mt. Baker-
                Snoqualmie and Olympic National Forests1
                            November 2005
This document is a position statement regarding commercial timber sales, most of which are
characterized as commercial thins2 in the Mt. Baker-Snoqualmie (MBS) and Olympic National
(ONF) Forests. This document should not be applied to other national forests. It is important for
management and conservation purposes to recognize the high variability of forest types and
conditions within the large region covered by the Northwest Forest Plan (NWFP).

We recognize that for each of these national forests, the NWFP specifies a commercial timber
sale target, defined as the PSQ (probable sale quantity) and currently set for 10 million board feet
(mmbf) for the ONF and 7 mmbf for the MBS. We expect sales chargeable to these PSQs to be
carried out from Matrix and Adaptive Management Areas (AMAs) since the NWFP requires far
higher standards in Late Successional Reserves (LSRs). Because we have accepted the Plan as a
compromise among ecological, social and economic concerns, we3 accept annual average timber
sale volumes up to, but not exceeding, these PSQ levels. However, we want to make it perfectly
clear that this acceptance is only for timber targets and not for claimed ecological purposes of the
timber sales. We remain unconvinced that these commercial sales will "accelerate" old-growth
conditions, or old-growth like conditions, often claimed as one of the major purposes of many of
these commercial sales, and often cited as one of the objectives of forest "restoration" activities.
We have not seen any scientific research presenting convincing evidence that thinning will
"accelerate" the achievement of old-growth conditions.

We also stress the well-documented fact that commercial thinning as currently implemented
damages the forest through consequences such as: road-building, loss of biomass, linear trails of
soil disturbance and compaction due to yarding, reduced snag creation, homogenization of types

  Representatives of the Olympic Forest Coalition (OFCO), Alpine Lakes Protection Society (ALPS),
Pilchuck Audubon Society (PAS) and North Cascades Conservation Council (NCCC) under the
guidance of Forest Ecologist Dr. Linda Winter wrote this position statement. All Boards have
approved this position. The Olympic Park Associates’ Board has also signed on to this position
  We define "commercial," applied to any thin or other form of partial cut, to imply that logs are removed
from the target area and sold. This implies the construction or reconstruction of an infrastructure of roads,
skid trails, and cable corridors. Conversely, "noncommercial" implies that no material (tree boles) are
removed from site and sold. Traditionally, noncommercial cuts have occurred in younger forested areas--
between 20 and 40 years, say--whereas commercial cuts have occurred in forested areas more than 50
years of age.
 Except for Pilchuck Audubon Society. PAS has a no-commercial logging position, and so does not
accept any PSQ. However, PAS does evaluate commercial timber sales whenever they occur, and agrees
with all other positions we take in this document.

and spatial arrangements of live and dead plants, development of overly dense and unnaturally
homogeneous understories, and unintended developmental pathways and structures. Collectively
we have spent many hours examining the results of recent and older commercial thins on these
forests. We have seen much ecological damage from these thins. We will resist efforts to
increase the timber targets beyond the PSQs set by the NWFP, but for those PSQs we will
continue to push for ways to meet the timber target that minimize damage and/or that include
alternatives to thinning. Further, we will continue to carefully examine and probably contest
"restoration" as the purpose of a commercial timber sale until research on these forests proves

The current forested landscapes of both the Olympic and MBS national forests are drastically
degraded and fragmented due to decades of heavy logging and road building activities.
Commercial timber sales, when they exist, should be designed and implemented to minimize
further degradation and fragmentation and include aggressive road decommissionings. This
document does not address ways to help heal the forested landscape, or “restoration” as it is
commonly called, but is limited to presenting the following checklist of sale properties that we
examine when evaluating commercial timber sales, and our positions regarding these sale
properties. Our objective in evaluating these sales is to advocate actions that will help minimize
the ecological damage done by them. This list is by no means exhaustive. Rather, it presents
some of our key positions concerning commercial timber sales:

Checklist of sale properties we evaluate, and our positions regarding these properties.

• Forest Service land allocations in the sale area:
       Our positions for land allocations that are common to both forests, and that might
       be in the sale area:
        -Late Successional Reserves (LSRs): The Northwest Forest Plan states that silvicultural
       activities should NOT take place in LSRs unless such activities are in forests less than 80
       years if age, and these activities are beneficial to the creation and maintenance of late-
       successional forest. We require that the decision that the activities are beneficial to the
       creation and maintenance of late-successional forest must be based on broadly accepted
       science that is relevant to the place of the activity.

       -Adaptive Management Areas (AMAs) and Matrix: The purpose and function of
       Adaptive Management Areas are different for the ONF and the MBS and attention should
       be paid to those differences. The ONF has no Matrix land nor do the AMAs contain
       LSRs. On the other hand, the MBS does have Matrix lands and their two AMAs contain
       lands primarily in LSRs. Given that, on the ONF we recommend that commercial sales
       in AMAs should be part of a plan for testing innovative approaches to integrating
       ecological, economic and other social and community objectives. On the MBS, we
       believe commercial thinning sales should occur only in Matrix lands; we encourage
       innovative approaches as stated above.

       -Riparian Reserves: We advocate no commercial thinning of riparian reserves, however
       we may support very limited silvicultural activities depending on the details of the sale

          proposal. For example, we may support dropping a few trees to add large woody debris
          into a stream.

• Roads: We advocate no new roads, and a program to aggressively and dramatically shrink the
system of existing roads. Additionally, our position is that commercial thinning sales should
NOT occur in roadless areas 1,000 acres or greater (not just Rare II inventoried roadless areas,
but rather, all roadless areas of this size), or less than 1,000 acres if adjacent to a congressionally
designated conservation unit, even if helicopter logging is proposed.

• Characteristics of forest in sale area: Our position is that commercial thinning sales should be
done only in young (generally less than about 50 years old) forests. Such areas are common on
the landscape, generally already have roads, and generally have already been subjected to
human-caused disturbance. Commercial sales should NOT take place in forests that have
naturally regenerated following disturbances, or in railroad-logged forests. Additionally, we
would like to see criteria from these Forests for how they prioritize where commercial sales are
the least likely to produce ecological damage at multiple scales.

• Logging and yarding prescriptions: We evaluate whether the prescriptions are designed to
minimize ecological damage and to retain variability in the presence and spatial arrangement of
live and dead plants. As one example, we recommend that leave trees have variable spacing, and
that there are some areas that are not logged (skips), and other areas (not linear strips) that will
have few live trees retained (gaps). Some especially ecologically valuable structures, such as
snags, and portions of the forest should be marked for retention. The density of the thinning is
also very important to the future of the cut area. These national forests have generally thinned
too heavily. We recommend following guidelines presented in the MBS Forest-wide LSR
Assessment, pg. 68-73.4 The prescriptions should additionally account for various effects
associated with silvicultural activities, such as soil compaction, erosion, treatment of logging
residues, blowdown problems, biomass removal (these forests run on biomass), and damage
done by roads. Are aquatic systems adequately considered and integrated in the prescriptions?

• Purpose stated for sale: We advocate that sale objectives are based on scientific findings that
are relevant to a particular place. We do not accept fire control as a stated purpose for thinning
on these forests, and until proven otherwise, we do not accept “restoration” or “acceleration” of
late-successional conditions as a purpose for commercial thinning here.

• Implementation and effectiveness monitoring: We advocate that the sale includes concrete and
funded plans for implementation and effectiveness monitoring.

• Beyond the scale of the individual timber sale: We evaluate whether there are issues beyond
the boundaries of the individual timber sale that should be taken into account, such as
connectivity, wildlife movement corridors, hydrology etc.

• Alternatives to thinning as a method for obtaining timber volume. Natural landscapes are
dynamic and highly variable. Thinning should not be automatically assumed to be the

    Contact the Mt. Baker-Snoqualmie National Forest for a copy of this document.

appropriate prescription for every timber sale. An alternative approach, for example, would be
for some sales, or parts of thinning sales, to be planned as small creative openings. Such an
approach would allow establishment of shade-intolerant species, while generating more volume
from fewer acres, and with far less roading, than thinning. We evaluate the appropriateness of
such options and see them as experiments, which would require a research hypothesis and an
effectiveness-monitoring component.

General considerations regarding commercial timber sales.

• There is a need for place-specific and scientifically credible information concerning the short
and long-term effects of thinning in the moist forests of western Washington. Claims that the
development of old-growth characteristics can be speeded up by thinning are, at best, highly
speculative. We strongly advocate that the Forest Service conduct a consistent, rigorous
scientific program of research and monitoring to obtain such information. Adaptive Management
Areas (AMAs) that do not include LSR management direction, and Matrix are the only place for
such research. We will only support a small-scale, long-term, cautious approach. LSRs are not
the place for experiments and for scientifically unproven approaches.

• Climate change predictions must be taken into account. Researchers at the Climate Impacts
Group at UW and at the Pacific Northwest Research Station of the USFS predict that although
precipitation levels may not change, winters and summers will be warmer, with more frequent
and severe storm events. Although it may be difficult at this time to decide what changes to tree
species should be factored into timber sale planning, it is clear that the addition of even more
roads to the forest system puts the aquatic ecosystem at risk. This will affect human property and


The following papers provide more detailed information and citations about some issues covered
in the Position Statement on Commercial Timber Sales in the Mt. Baker-Snoqualmie and
Olympic National Forests. This is not intended as an exhaustive list.


Franklin, Jerry F., D.A. Perry, R.F. Noss, D. Montgomery, and C. Frissell. 2000. Simplified
forest management to achieve watershed and forest health: a critique. Seattle, WA: National
Wildlife Federation. 46 p.

Although this report was written to specifically critique a particular type of forest management, it
is an excellent general reference for things to watch for when evaluating sales and management
plans as to whether they are ecosystem based. This report also has an extensive list of additional

useful references.


Halpern, C.B., and D. McKenzie. 2001. Disturbance and post-harvest ground conditions in a
structural retention experiment. Forest Ecology and Management 154:215-225.

This paper is useful for references on ground disturbance and production of slash during logging
and yarding operations.


Noss, Reed. The Ecological Effects of Roads.

This is an excellent review of ecological effects of roads


Noss, Reed and Adam Switalski. The Evolution of Road Science.

This is good for references on ecological effects of roads.


Spies, Thomas A., John Cissel, Jerry, F. Franklin, Frederick Swanson, Nathan Poage, Robert
Pabst, John Tappeiner, Linda Winter, 2002. Summary of Workshop on Development of Old-
Growth Douglas-fir Forests along the Pacific Coast of North America: A Regional Perspective.
November 7-9, 2001. H. J. Andrews Experimental Forest, Blue River, Oregon. 11/15/2002


USDA Pacific Northwest Research Station. 2003. New Findings about Old-Growth Forests.
Science Update Issue 4.



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