To: SEPA Center
PO Box 47015
Olympia, WA 98504-7015
FAX: 360-902-1759
Subject: File No. 01-111301
Libby South Fire Kill Timber Sale No. 73406 Forest Practices Application No. 3007254

Dear Sirs, Mmes:

These comments are submitted on behalf of over 800 members of the Kettle Range Conservation Group, whose mission for over 25 years is to defend wilderness, protect biodiversity, and restore ecosystems of the Columbia River Basin. Our members live and recreate near the area in question, and we all benefit from having the area remain in a natural state. Our members have personally visited the area in question many times, and some of us live close enough to the area to be concerned by DNR activities.

We do not concur with the DNR Agency Determination of Non-Significance for many reasons. Many of our reasons were already submitted to you during comments sent by myself during the scoping period for both Gamble Mill and Libby South sales, but the most important point of these comments appear to have been ignored.

This proposal ignores long-term costs to productivity and benefits to the trust. This proposal will result in a net loss to the trust. By definition, salvage is not included in the long-term plans for the DNR. The DNR has no mandate to sell timber below cost, yet this proposal does just that, by releasing the proposal in a hasty, careless manner, that will lower long-term benefits to the cost.

This sale should be dropped, and in addition, the trust should be held responsible for damages to nearby landowners for soil losses, spread of noxious weeds from DNR lands onto adjacent private lands, and in maintening vehicles in a dangerous fashion that caused the fire.

Nearby landowners are frightened that the poor condition of the DNR fleet trucks will cause more fires. This proposal is a direct result of a fire that began with poor maintenance and equipment, coupled with driving through weed patches, and highly flammable European forage grasses.

I am familiar with the area’s ecology from my long association as a botanist with the Forest Service. Botanists have gradually watched as cheatgrass has replaced native species in the west over the last 50 years. Cheatgrass and the other grasses listed above are favored by disturbances such as fire and soil destruction. By clearcutting this area, the DNR is adding multiple insults to the ecosystem, which has yet to recover from the fire. Washington has some of the last strongholds of intact ecosystems in remote areas such as this, but this action marks the beginning of the end for such native ecosystems.

The area where the fire began is dominated by cheatgrass, diffuse knapweed and pubescent wheatgrass, three species that are known to increase the rate and severity of fire. The truck that started the fire must have been driving through these fuels for them to have ignited, and in fact I confirmed this on a visit to the ignition area. The DNR has allowed these weeds to proliferate through poor management, and this proposal will result in the further increase of Noxious weeds in the area. The cost to control Noxious weeds in this area alone would lower the value of the sale below the returns, not to mention repairing damaged fences, or poorly upkept roads. We doubt that the DNR has a plan that will help control these weeds, therefore we feel that the DNR is hiding the fact that this is a below-cost timber sale, by transferring the costs of weed management to other departments and to the public at large.

The SEPA checklist appears to have been prepared by someone with no familiarity with the area. It is an insult to local communities that outsiders with little knowledge of ecosystems profess to “manage” this area for the long-term benefit to the trust, which should be representative of people at large.

Western gray squirrels occur in the Libby South sale area at a much higher frequency than the DNR checklist would indicate. This year alone, western gray squirrels were observed in the sale are or close by by Aileen Jeffries, Don Johnson, Peter Morrison, Lindsey Swope, Ray Robertson and the WDFW.

A discussions of gray squirrels with Mary Linders of WDFW, indicated that state threatened gray squirrels live mainly in the drier parts of the ecosystem because they feed on the nuts of trees that are adapted to that climate; nuts from the ponderosa pine and oaks are among its favorite foods. They also can be seen in the lowlands of the wetter zones feeding on fungi.

The DNR is not allowed to cut a squirrel nest tree, yet this proposal offers no assurance of this, in fact it is likely. The DNR is proposing to clearcut 400 acres of the remaining habitat for squirrels surviving in this area.

Populations of the western gray squirrel are declining in Washington state, and have been recommended by biologists studying them for upgrading to state-endangered. According to Bayrakçi, 1999,
 

“… throughout much of its range, western gray squirrels are an oak-obligate species. The current distribution of western gray squirrels in Washington is restricted to three populations which are located in the Puget Trough (southern Pierce and northern Thurston Counties), Yakima and Klickitat Counties, and Okanogan County. … Research in Okanogan and Chelan Counties has been restricted to limited foot surveys by the Washington Department of Fish and Wildlife. More research is necessary to determine the potential threats facing this population of western gray squirrels. … Evidence of long-term population declines and ongoing risks threatening at least two of three Washington populations of western gray squirrels supports the need to reevaluate the legal status of the squirrel. Our data on the Puget Trough population and the Washington State populations partially justifies the recommendation that the western gray squirrel be upgraded to state-endangered.”

This proposal will result in a trend to upgrading the listing for the gray squirrel, which is probably illegal.

According to Harvey (1999), in well-studied California populations. “In winter, [squirrels] make brood nests in tree and snag cavities, often enlarging an abandoned woodpecker cavity. They also build nests on branches of oak, fir, or pine trees. Nests are lined with shredded bark, grass, moss, and lichen”. “… squirrels are dependent upon mature stands of mixed conifer and oak habitats. … [Squirrels r]equire large trees, mast, and snags.” “Numbers have been reduced by removal of snags, duff, slash, or oak trees.”

The DNR proposal goes a long way toward helping to extirpate gray squirrels. In a population already at the extreme of viability, in an area where thousands of acres of available food source have just been lost to fire, the DNR now proposes to further reduce their numbers by removing their habitat and co-dependent species such as large wood and pileated woodpecker habitat. We note that the SEPA checklist, erroneously assumes that there are no pileated woodpeckers using the area, when everyone else knows this is one of the best areas to see pileated woodpeckers, as well as other rare, keystone species such as white-headed woodpeckers and Lewis’ woodpeckers.

In addition, the SEPA checklist erred in not listing spotted owl habitat. Along with WDFW biologist Lynda Hofmann, we surveyed this area and obtained reliable spotted owls reports for this area. In addition, a known nest pair occupies the burn area, and may be dispersing into this area.

Following are some additional considerations offered during scoping that were not heeded in preparing this sale.

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.  Dr. James Agee's (Agee, J.K. 1997. Severe fire weather: Too hot to handle? Northwest Science 71: 153-156.) 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. Clearcutting 400 acres of pine and Douglas fir will be devastating to the ecosystem as well as long-term trust benefits. Already, the entrance to this piece of DNR land is a disgraceful display of noxious weeds, with a dominant cover of diffuse knapweed, cheat grass, hound’s tongue, flannel mullein, and bull thistle. Land that should be supporting healthy stands of pine and fir, and rich wildlife have declined to the point where trees won’t even grow because of the damage to the shrub-steppe of the ecosystem. Where bitterbrush and arrowleaf balsamroot should be growing, there is a monoclone of cheatgrass, quackgrass, intermediate wheatgrass and pubescent wheatgrass.

Salvage timber harvest increases 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.”  (M.H. Huff and others, 1995.  U.S. Forest Service).

The report 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”. (Interior Columbia Basin Project, 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).

Salvage logging degrades forest health.   The available evidence indicates that salvage 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.”  (David Greenwald, statement in An evaluation of the Long Draw Salvage Timber Sale Using Fire Behavior and Effects Models, 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).

Salvage logging is unsustainable, by definition. Because of the poor analysis that accompanies fast track logging, the environmental affects are worse than timber sales that have been thoroughly analyzed. Increased effects include:
· Damage to soil integrity through increased erosion, compaction, and loss of litter layer (Harvey et al. 1994, Meurisse & Geist 1994).
· Increase sediment contribution to streams from roads is often much greater than that from all other land management activities combined, including log skidding and yarding." (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.
· Increased mortality of residual trees due to pathogens and mechanical damage to boles and roots (Hagle & Schmitz 1993, Filip 1994)
· Creation of sediment that may eventually be delivered to streams (Beschta 1978, Grant & Wolff 1991)
· Increased levels of fine fuels and near-term fire hazard (Fahnestock 1968, Weatherspoon 1996, Wilson & Dell 1971, Huff et al. 1995)
· Reduced habitat quality for sensitive species associated with cool, moist microsites or closed canopy forests (FEMAT 1993, Thomas et al. 1993)

We apologize for having to point these facts to you so bluntly, but frankly we feel that the DNR is abrogating its responsibility in the preparation of this and other salvage sales.

Sincerely yours,

George Wooten
Field Representative

cc: Steve Meacham (FAX: 509-684-7484)

References:

Bayrakçi, R.T. 1999. A reevaluation of the status of the western gray squirrel (Sciurus griseus) in Washington State, emphasizing the Puget Trough population. M.S. Thesis. The Evergreen State College, Olympia, WA.

T. Harvey, 1999. Western Gray Squirrel. California Department of Fish and Game, 1999. California's Wildlife, Sacramento, CA (http://www.sibr.com/mammals/M077.html).