Scoping Letter to DNR about Salvage Sales in the 2001 fires

The following comments are excerpted from comments submitted by Kettle Range Conservation Group on Oct 17, 2001, in commenting to the DNR salvage proposals

1. The Okanogan economy is not dependent on timber

Geraldine Gillespie Columbiana Magazine (columbiana@televar.com) compiled a factsheet and analysis of Okanogan County's history of economic development titled, respectively, "Socio-Economic Fact Sheet" and "Socio-Economics of Okanogan County: A Brief Profile of Bureau of Economic Analysis (BEA) Statistics".

The study uncovered many important historical events. Okanogan County has experienced continual in-migration since the early 1970s, part of the rural living renaissance that is taking place in high quality rural landscapes around the United States (NIIP, 1999, "Personal Income..."; Johnson, 1995, 8). Rapid population growth during the 1990s alone added 5000 new residents, nearly doubled personal income, and generated approximately 4500 new jobs (NIIP, 1999).

In 30 years, Okanogan's population has increased 150%; while its personal income has grown by 700% (NIIP, 1999, "Personal Income..."). Nearly half of Okanogan County's annual personal income, $300 million (1997) is from transfer payments, interest and dividends (NIIP, 1999). However, 85% of Okanogan County personal income in 1997 was generated from trade, finance, real estate, services, government, and transfers and dividends (NIIP, 1999).

There are 7000 jobs in natural resources (agriculture, timber and mining) that comprise 30% of Okanogan's total 23,000 jobs. The number of extraction related jobs has remained constant for 30 years, while Okanogan has added 10,000 new jobs in that time period (NIIP, 1999, "Employment...").

Okanogan County has been classified a Recreation county, one of only 17 recreation counties among 100 counties in the interior Columbia River Basin (Quigley, 1997). Recreation counties are so classed because they are attracting migrants who are looking for a relaxed and aesthetically pleasing place to live (Gomoll, 1997). Recreation counties are the fastest growing counties in the United States (Johnson, 1999), and in the interior Columbia Basin (Quigley, 1997, 24).

Quality-of-life driven population growth is expected to be the primary driver of the basin's economy in the future (Gomoll, 1997, 2). The majority of new residents purchase homesites in the unincorporated areas of the county, which experienced a growth rate of 19% during the 1990s (Nelson, 1999, 2-4).

The conclusion was that Okanogan County's post-pioneer economy is based on the amenities of its natural environment, and the home and business development resulting from thirty years of continuous in-migration to the county.

2. Forests are already suffering from a century of exploitive timber extraction mandated by beltway bureaucrats. An example is the damage caused by the 1990s "timber rider", or recissions bill, which required the US Forest Service to sell billions of board feet of timber off national forests in two years, while suspending all environmental laws and judicial processes. The Rider was written by Senator Slade Gorton of Washington, a timber industry hack who admitted taking $34,000 in campaign donations from the timber industry. The timber rider was a hoax on the American public passed by the swell of new of Republicans that entered Congress in 1996, because it resulted in deficit spending with a net loss to the treasury. An example was the Thunder Mountain salvage timber sale in Okanogan County that cost taxpayers over $400,000 while generating approximately $30,000, even though a higher bid by Northwest Ecosystem Alliance would have paid not to log the trees.

Another disastrous timber rider was the infamous Section 318 or "Hatfield Rider in the 1990 Interior Appropriations Act, which specified unsustainable levels of clearcutting on Forest Service and BLM lands in Washington and Oregon. Section 318 clearcuts continue to raze forests in the Region. Okanogan County is familiar with such sales from the infamous Black Pine Lake clearcut which appeared one day in the Twisp River drainage, and generated hundreds of indignant letters from throughout the Region condemning the Forest Service for desecrating a sacred place.

Salvage programs often originate at high levels in government, rather than with local planning authorities. This is a recipe for poor planning. According to the Center for Public Integrity, at least 150 state legislators in 34 states have financial connections to timber interests. More than 27% of those legislators sit on committees that regulate the timber industry. See the full report at www.public-i.org (or call Leah at 202-466-1300 ext. 137).

3. Because they are defined as "emergencies", salvage sales lack sound planning that will recognize the value of intact ecosystems when evaluating the impacts. Instead, political posturing by the timber industry will couch such programs in terms of "Jobs vs. the Environment", deflecting attention away from the real problems with degraded environments that result from poorly planned sales on public lands.

4. Salvage logging perpetuates conditions of poor forest health. The Libby South Burn in the Methow Valley, Washington encompassed a large roadless area surrounded by high-grade logging units dating from decades ago. High-grading is a form of logging which takes the best trees and leaves the rest. These old logging units have grown up in a suppressed condition, with large amounts of brush and dense, spindly crowns which act as "ladder fuels" to spread the fire into the crowns of the trees. In contrast, areas near the center of the roadless area which have never experienced logging often experienced light underburns or no fire at all. An example of these poor forest health conditions are illustrated by an old fireline that straddles the main ridge that burned. The old fireline was choked with brush and small trees which burned extremely hot, completely consuming the fine material, and leaving only a fine residue of ash. Away from the fireline, old logging units experienced scorching which killed the trees and blackened the stumps, while leaving some brown needles and leaves remaining on the plants. Away from the old roads, the uncut areas frequently remained completely green.

The supposed benefits of thinning forests is counteracted by elevated drying out of open canopies. Agee (1997) found that research demonstrated that reducing groundfuels is the most effective treatment to prevent crownfires, while thinning tree canopies results in hotter, drier, windier conditions on the ground surface.

5. The County Payments Bill signed on October 30, 2000 by President Clinton decoupled county timber payments from forest profits, so counties no longer accrue direct benefits for increased logging. Under the new law, a county receives "timber" payments from the general Treasury, regardless of whether a single tree is cut on the National Forests. Payments are based on the counties' all time-high revenue-sharing payments, so that counties and schools no longer have a direct a stake in promoting higher logging levels.

However there still remains 15% of discretionary funding upon which to base conflicts. This is because activities that would benefit ecological restoration under Title II of the bill can be co-opted by the counties under Title III. Title II would give a local 15-member Resource Advisory Committee (RAC) the use of a portion (15-20%) of the guaranteed payments for federal land management projects. Title III allows counties to opt out of Title II projects and keep the 15-20% of the project funds under county control. Many counties will obviously favor Title III provisions since the county gets to control the disposition of funds instead of funding the RACs. The language in the final Bill ameliorates this to a small extent by allowing counties to "mix and match" Title II and III funds. Counties can fund both Title III projects and divert funds into Title II projects without adequate ecological protections.

To provide perspective, Douglass County in Oregon will receive $20.9 million in County Payments per year and will have to divert around $3.1 million to Title III projects, Title II projects or the Treasury. For example, under the "mix and match" scenario Douglass County can provide $600,000 for Title III projects, and $2.5 million for Title II projects. This kind of funding is significant because the $2.5 million can be used for commercial timber sales.

The bill also requires that 50% of Title II projects must be for road maintenance, decommissioning and obliteration or stream and watershed restoration. Unfortunately, this provision is vague and lacks adequate monitoring provisions to assure that 50% of all projects nationally are indeed going toward these restoration efforts.

6. The conflict over salvage logging is really about saving virgin timber from becoming developed with additional roads. The impact of roads is more severe than any other man-made disturbance, and has resulted in fragmentation of forests and a decline of forest health and resource values throughout the world. While it is true that roads can be of help in fighting fires, it is more important to note that that roads are what makes timber sales profitable, since on federal lands, the taxpayers pay for the roads, while timber companies receive the profits. Natural processes evolved in the absence of roads and logging, which have no natural counterpart. The current Roadless Area Rule approved by the Clinton administration allows logging and thinning in roadless areas anyway, but in roadless areas, healthy forests can be maintained more efficiently by natural thinning processes, including fire, insects, soil suitability and mycorrhizal relationships.

7. Environmentalists place the highest priority on protecting homes and communities from wildfire, rather than on conducting salvage sales in remote roadless areas. According to a report by Jack Cohen, Reducing the Wildland Fire Threat to Homes: Where and How Much?, available at the Rocky Mountain Research Station, 801-625-5291), the most effective protective measures for homes should be located within 10 meters of homes, and the biggest threat is from brush fires, not trees. Only a small minority of fires in the US occur in forests, most are in non-forests.

Cohen states, "the threat of life and property losses during wildland fires is a significant issue for Federal, State, and local fire and planning agencies who must consider residential development within and adjacent to wildlands". According to past Forest Service Chief Mike Dombeck, 87% of areas at high risk for catastrophic fire on National Forest lands are in roaded areas, while only 13% in roadless areas.

8. Salvage logging during times of low stumpage value that exist now will result in competition between state and private interests, effectively putting private timber lots out of business, while benefiting large industrial outfits. By favoring government-subsidized logging, some private timber sales will become unprofitable. This will force some small woodlot owners toward bankruptcy, along with any benefits that would result from sound ecosystem management of forests. While the bottom line of industry is the dollar, badly needed restoration on private lands would may not be affordable during a timber glut.

9. National forests are far more valuable for their recreation, wildlife and water quality than for timber, minerals and cattle grazing. The National Forests are worth an estimated $234 billion and generate 2.9 million jobs from recreation, fish and wildlife, water quality and wild areas, according to an economic consulting firm that prepared the report for the Sierra Club, which opposes commercial logging in national forests. By comparison, the nation's 192 million acres of federal forests generate $23 billion and 407,000 jobs from timber, mining, grazing and other uses, according to the firm, ECONorthwest.

10. Government logging suffers from poor monitoring of pre- and post-sale treatments. According to an article by John Cushman in the New York Times, Friday, February 5, 1999, "Audit Faults Forest Service on Logging Damage in U.S. Forests", federal auditors found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.

After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that "immediate corrective action is needed."

The report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out.

The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, past chief of the Forest Service, that the review had found "numerous serious deficiencies." Agency officials generally agreed with the report's conclusions and recommendations.

The problems not only cause lasting harm to publicly owned natural resources, the report emphasized, but also cost the taxpayers money because many timber sales are canceled for environmental reasons, and the Government must then pay penalties to the timber companies for breach of contract.

11. Timber harvest may increase fire risk. Managers who prefer unsound timber harvest activities over well-planned ecosystem management deserve some of the responsibility for extent and severity of forest fires.

The Sierra Nevada Ecosystem Project summary found that, "more than any other human activity, logging has increased the risk and severity of fires by removing the cooling shade of trees and leaving flammable debris." (Status of the Sierra Nevada, Vol. 1., Assessment of Summaries and Management Strategies, pg. 62. Sierra Nevada Ecosystem Project). The report cites that, "As a by-product of clearcutting, thinning, and other tree-removal activities activity fuels create both short- and long-term fire hazards to ecosystems...Even though these hazards (with logging slash) diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon." (Huff et. a., 1995).

The report in the Interior Columbia Basin Project goes on: "Fires in unroaded areas are not as severe as in roaded areas because of less surface fuel… Many of the fires in the unroaded areas produce a forest structure that is consistent with the fire regime, while the fires in the roaded areas commonly produce a forest structure that is not in sync with the fire regime. Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands". (Hann et al. 1997).

According to the Interior Columbia Basin Assessment, "fires in unroaded areas are not as severe as in roaded areas because of less surface fuel… Many of the fires in the unroaded areas produce a forest structure that is consistent with the fire regime, while the fires in the roaded areas commonly produce a forest structure that is not in sync with the fire regime. Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands" (Hann et al. 1997).

Timber harvest that removes dead and dying material from sites can inhibit the recruitment of downed woody material as time progresses. Timber harvest is associated with reduced structural complexity and reduced age and size class diversity that can lower wildlife abundance and diversity.

"Timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity." Sierra Nevada Ecosystem Project Report (1996).

"As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems...Even though these hazards (with logging slash) diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon." (M.H. Huff and others, 1995. U.S. Forest Service).

In eastern Oregon and Washington, Lehmkuhl et al. (1995) and Huff et al. (1995) reported a positive correlation between fuel loadings, predicted flame lengths and logging. They attributed the increased fire hazard in managed areas to slash fuels generated as a by-product of tree removal activities (including thinning), and to the creation of dense, early-successional stands via logging that have a high fire potential. (DellaSalla and Frost 2000).

12. Logging may degrade forest health. The available evidence indicates that logging can result in numerous adverse environmental impacts, including:

"It is my opinion based on reading the literature and on this modeling exercise that…salvage logging does little to nothing to increase the long-term resilience of these forests to stand destroying fires or insect outbreaks." (Greenwald, 1996).

Repeated intermediate harvests, partial harvesting, or uneven-age management, such as economic selection cutting or sanitation/salvage cutting could increase both the frequency and severity of root diseases in stands. Even one harvest entry in stands has been found to greatly increase the frequency of root disease compared with stands that have not had tree harvest entries. Studies have shown a doubling of root disease frequency in stands on the Lolo National Forest in Montana with at least one harvest entry compared to those with no history of tree harvest. (Fish Bate Timber Sale analysis file, page 152).

Roadless area logging may cause: