MT Fire Suppression Committee: Please focus on common ground

By Matthew Koehler, Unfiltered 4-21-08

Dear Montana Fire Suppression Committee:

In anticipation of the Fire Suppression Committee meeting and field trip in the Bitterroot Valley April 28-29 (http://leg.mt.gov/css/committees/interim/2007_2008/fire_suppression/default.asp) attached you will find a two page document with some photos from logging done in Sept 2007 as part of the Middle East Fork "Healthy Forest Restoration Act" logging project on the Bitterroot National Forest (see: http://www.wildwestinstitute.org/pdf/MEF_logging.pdf ). More perspectives on the MEF HFRA project from UM Forestry Professors, local East Fork residents and others are below.

Also, it's important to point out that in response to the harmful parts of the Bitterroot National Forest's Middle East Fork Hazardous Fuels Reduction project, in November of 2004 local conservation groups, together with some Bitterroot Valley residents and former Forest Service employees, collaboratively created an alternative that was intended to provide far superior wildfire protection to the East Fork community, protect old-growth forests and elk and bighorn sheep winter grounds and implement bona-fide restoration activities within the East Fork area. This alternative was called the Community Protection and Local Economy Alternative and it was submitted it to the Forest Service in December 2004 during the official scoping process for this project.

This Community Protection and Local Economy Alternative included 1,600 acres of fuel reduction work on Forest Service land, including 600 acres of strategic fuel reduction within a quarter mile Community Protection Zone around structures within the project area and an additional 1,000 acres of fuel reduction work outside of that zone but still within the Wildland-Urban Interface. According to the Forest Service, this plan would have generated $1 million in labor income and provide 45 local jobs in the Bitterroot Valley.

Unfortunately, some in the logging industry knowingly misled the public when they characterized this alternative as "no action on the forest except for a small amount of work done around houses and raking needles from under decks." How in the world local conservation organizations supporting and encouraging fuel reduction on 1,600 acres of Forest Service land that would generate $1 million in local labor income and provide 45 jobs is portrayed as "no action" and just "raking needles from under decks" is a real mystery to me.

While some in the logging industry - and even some members of this Committee - may continue to falsely portray the conservation community's position on issues related to fuel reduction, fire suppression and restoration, the truth of the matter is that a lot of common ground has been reached and I don't know of any conservation group that doesn't support the solutions and pro-active measures to fuel reduction and fire suppression as outlined so well by Dr. Thomas H. Deluca, Dr. Cathy Whitlock and Dr. Paul Alaback in their letter to this committee on February 1, 2008 (see: http://www.wildwestinstitute.org/pdf/deluca_etal_fire_supp_comm_pdf).

I would like to ask that the Committee focus on these vast areas of common ground and agreement, rather than entertaining, for example, a perspective that calls for the National Environmental Policy Act and the public appeals process to be suspended at a time when the truth of the matter is that much of this agreed-upon, bona-fide fuel reduction work isn't going forward because of the dismal lumber markets and the lack of bids the agency (both Forest Service and State DNRC) is getting for fuel reduction and logging projects. However, seeing the lack of balance contained within the agenda for the upcoming meeting I'm not sure the Committee is ready to seriously focus on common ground and agreement.

Thank you for your time and as always, I'm more than happy to speak with any of you about these issues.

Sincerely,

Matthew Koehler
Executive Director
WildWest Institute

Perspectives on the Middle East Fork HFRA project from the official project file.

"When you lay out expected receipts and costs, this would bring into focus that costs will far exceed receipts. It would be clear that timber sales would not fund your healthy forest goal….You say that selling timber, even at a loss, provides you with funds to partly offset the cost of doing Healthy Forest work on lands adjacent to the logged area. I don't think this is true on the Bitterroot or other Region 1 Forests…. I can't see how you can fund any part of the off-sale acres you desire to treat under the Healthy Forest Act."
- Bob Wolfe to Supervisor Dave Bull specifically about the Middle East Fork HFRA project (Sept. 29, 2005), Mr. Wolfe worked for the Congressional Research Service and was widely considered Congress' Forest Service budget expert. He died a few months after this email was sent to Mr. Bull.

"... there has been a consistent, deliberate removal of information that accurately portrayed the conditions of the soils and the prescriptions and mitigations needed to address those degraded soil conditions. Therefore, I can not support the DEIS in terms of assuring we are meeting the SQS. I can no longer say the proposed actions are legal regarding NFMA and other pertinent laws and FS policies. I am very disappointed that all my hard work has been erroneously reinterpreted, rewritten and changed far from what I wrote and intended by the editor(s) who weren't even on the ground doing soils investigations in this project area!"
- Ken McBride to Supervisor Dave Bull (May 5, 2005). McBride was the Bitterroot NF's soil scientist for 16 years before retiring in the fall of 2005. McBride was the BNF's soil scientist for the Middle East Fork project.

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Text of Official Middle East Fork HFRA Objection received on October 14, 2005 from Robert S. Francis, E. Fork Rd., Sula, MT

"I wish to object to the planned 'preferred' Alternative #2 that would 'treat' 6,472 acres instead of Alternative 3 that would impact 1,064 acres. I object on a personal and a general basis.

On a personal level my objection is based on the fact that my ranch house is next to Forest Service road #5778. The logging truck traffic resulting from Alternative #2 will make that structure uninhabitable. This observation is based on a small project set up by Sula Ranger Hollingshead last year. Her total lack of courtesy and consideration resulted in logging trucks roaring by our house at 3 am. I have no hope that attitude will change.

On a general level I object to the premise that logging, etc outside the 400 meter zone protecting property is useful. There is no evidence it helps stops wildfires. In fact, there is ample evidence that logging increases the intensity of fires due to the drying effect on the understory and the piles of tinder-dry trash, slash, et at logging sites.

On a general level I object to the premise that logging will affect the Douglas-fir bark beetle epidemic. There is ample historical data that shows this is a normal, cyclical process. It is natures way of thinning. Logging does not cure it. To use this infestation as an excuse to 'get the cut out' is, at best, intellectually dishonest. This course of action makes sense only if one accepts the attitude that our national forest is a tree farm - not an ecosystem. I do not share that attitude.

I object to Alternative #2 on an economic basis - as a taxpayer. Logging is a notorious money-loser. The value placed on the product is much too low. If my corporation conducted business the way you folks do, we would have gone out of business years ago.

Finally, I object to the heavy-handed methods used to ram Alternative #2 down my throat. Under the guise of getting 'community support' you have used scare tactics, and have hand-picked certain people for 'testimonials' that support the plan you wee going to use - no matter what.

I have one last request - please give me at least 3 months warming before the log trucks start rolling along road #5778, so I can move out."

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Text of Official Middle East Fork HFRA Objection received on October 24, 2005 from Jed and Jessica Fitzpatrick, Sula, MT

"My wife, daughter and I live on the eastern edge of the project's boundary and feel that Alternative 2, the proposed alternative, will negatively affect this area. Treating nearly 6000 acres through the prescribed methods will greatly increase the spread of noxious weeds, disturb fragile soil systems, greatly increase sediment (26 tons) into the Bitterroot River, while not reducing the urban fire threat or the pine beetle infestations.

We support Alternative 3 for this project because it focuses on urban interface, rather than backcountry logging. Alternative 3 would resolve the questionable aspects of the project proposed."

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Text of Official Middle East Fork HFRA Objection received on October 14, 2005 from Stephen F. Siebert, Professor, Department of Forest Management, University of Montana College of Forestry and Conservation, Missoula, MT

"I am writing to express my opposition to the Middle East Fork Hazardous Fuel Reduction project in terms of both substance and process. While I do not have official standing to file an objection, I submit this statement for the record. I visited several forest stands that will be impacted by the proposed project this past summer, attended the field trip that Forest Supervisor Dave Bull organized for College of Forestry and Conservation faculty members, attended the public meeting in Hamilton, and was a panel discussant at the Missoula public meeting.

On the faculty field trip and at the public meetings, numerous questions and concerns were raised with regard to Bitterroot national Forest assumptions about fire regimes and behavior, potential to control bark beetle infestation, noxious weed invasions, elk forage cover relationships, soil compaction, stream sedimentation, and fisheries. In my opinion, these concerns have not be adequately addressed.

Give the inherent uncertainty and unpredictability of management actions in a project of this scale, a case could be made to pursue the proposed alternative as a learning exercise. This would necessitate documenting, monitoring and assessing impacts through rigorous, replicated, randomized studies with adequate controls. However, as proposed, the project will not serve this function either.

Based on the failure of the Forest Service to address substantive concerns about the proposed alternative and the dismal decision-making process (particularly the selective inclusion of the public and ejection of some members of the public from the public announcement meeting), the Bitterroot National Forest Sula District has achieved 'catastrophic success.' The American public and the US Forest Service deserve better."

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Text of Official Middle East Fork HFRA Objection received on October 24, 2005 from Diana L. Six, PhD, Associate Professor of Forest Entomology/Pathology, Director, UM Mentoring Program for Women in Science, Dept. of Ecosystem and Conservation Sciences, University of Montana College of Forestry and Conservation, Missoula, MT 59812

"The Middle East Fork Hazardous Fuel Reduction Project has substantial problems in its design and its ability to meet its stated objectives. I will restrict my comments to planned work outside of the urban interface zone as that work is clearly needed, meets objectives, and is not in contention. In contrast to the community protection zone, much of the additional work that is planned, especially in the higher elevations, is not likely to meet objectives and may even work counter to them. This area is primarily composed of mixed fire intensity stands which do not behave the same as low elevation low intensity high frequency fire adapted stands and thus cannot be assumed to respond the same ways to thinning treatments. By opening these stands they become drier and windier and can burn hotter (per comments by fire expert Ron Wakimoto and others). Furthermore, as planned, these are spacing treatments not restoration treatments that truly attempt to restore historic stand structure and function (see Franklin et al, ...). The lack of application and use of current knowledge in the ecological sciences and ecosystem management principles in this project is as disturbing as the apparent poor understanding of when and where to properly apply certain types of treatments.

My expertise lies in insects and disease of forests and in genetics and I will confine the majority of my remaining comments to these topics. Thinning of stands to reduce tree susceptibility to bark beetles can be a very effective preventative strategy when applied properly and at the correct time. While the efficacy of thinning in Douglas-fir remains to be tested it is likely to be effective in many situations. Thinning works by releasing trees in overdense stands from competition. This release means that trees have higher levels of resources of which some then be made available to produce defensive compounds. While Douglas-fir does not use pitch to defend itself against beetles as do pines, it has other defenses that are resource dependant. The effects of thinning, however, are not immediate. Typically, trees in thinned stands become more susceptible immediately after thinning due to changes in stand conditions including increased light and wind to which they are not accustomed. After a lag period of one or more years, trees then often exhibit an increase in their defensive capabilities and become more resistant. Therefore, immediately after thinning, trees become more susceptible-if thinning is done in a stand with high levels of beetle activity this can increase, not decrease, mortality. Such treatments, therefore, are most appropriate and effective as preventative treatments applied before beetles become active in considerable numbers in an area.

In epidemic situations, such as the areas affected by the project, thinning is ineffective and may exacerbate mortality in remaining trees. Such efforts and expense would be better placed into areas on the Bitterroot Forest where beetles are not yet active but where conditions would support increases in their populations and where the treatments can do some good and are appropriate. This project will not reduce beetle populations or mortality due to the small amount of area being treated relative to the size of the infestation and thinning in these areas is not likely to help save the remaining live trees.

Another concern with the project is the source of stock to be used for replanting at some of the sites. It is now well known, and has been for some time, that replanting with trees not native (same species) to the site can be devastating to the long term health and function of a forest. Forest geneticists have recommended that replanting should be done using seed sources from the site as this assures replacement of dead trees with site-adapted trees and less of a potential for losses in genetic diversity if seed is properly collected. The genetic diversity present in a stand is ultimately tied to how well a forest is able to deal with changes in the environment that occur in the short and long term. Unfortunately in the past, and still in many places currently, the value of maintaining genetic diversity is not understood. Nor is the fact that trees are site-adapted to more than just temperature, elevation, precipitation and soils at a site. We now know that more than optimal site conditions for tree growth are important in maintaining a healthy forest. The genetics of trees at particular sites have resulted from millennia of adaptation to conditions that go well beyond temperature, precipitation and soils and include susceptibility to many diseases and insects, ability to survive prolonged drought, and other disturbances. Problems related to the genetics of offsite trees often do not show up until decades after planting. By that time, the trees have produced pollen that has spread throughout the forest and their alleles have been incorporated into the genomes of the "native" trees potentially polluting and diluting the genetic pool and affecting adaptive traits that evolved there. Once this happens it cannot be reversed.

I hope the Forest will reconsider the non-community zone portion of this project and in the future base more of their management on ecological principles and the best available science. Management is clearly need in many places but should always strive to use the best information available to ensure the greatest likelihood of doing good."

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