A Newsletter by and about the Quilcene Ancient Forest Coalition, March 1998

CALENDAR

Apr. 4 - Saturday - 10 a.m./3 p.m. - Jefferson County Fairgrounds - "Festival of the Trees" - Workshops, music, food, plant vendors, evening dance -- sponsored by Jefferson Land Trust

The Forest Service has extended the comment period for the Interim Roadbuilding Moratorium to March 30. See last month's newsletter for details about the moratorium.

The agency is also accepting comments until March 30 on the overall road system and a long-term transportation policy.

"The Forest Service transportation system is a long-term, high-level financial commitment and we simply cannot afford to maintain all the roads we have," said Deputy Chief Bob Joslin. The Forest Service says that only 40% of the roads are maintained to standard and cites over 40,000 miles of unneeded or environmentally harmful roads that should be decommissioned.

If you weren't able to send in comments before, remember to ask Chief Dombeck to apply to all National Forests, including those currently exempt from the Moratorium, the authority given to Regional Foresters to include roadless areas with "unique ecological or social values" in the Interim Moratorium.

Some members of Congress are planning to actively oppose any moratorium on Forest Service roadbuilding. They are even threatening another one of those infamous "riders" to overturn such a policy, or at least retaliation by cutting the Forest Service budget.

The Forest Service needs public support for, and encouragement to practice, environmentally responsible forest and road management. Congress should be working on finding them additional funding to accomplish this, rather than going down the same old tired road, so to speak.

Western Ancient Forest Campaign reports that Agriculture Committee Chairman Bob Smith (R-OR) has released a revised version of his forest health bill, H.R. 2515. Ironically, Smith has systematically erased every reference to "forest health" in the bill.

The revised "this-is-not-a-forest-health" bill claims to prohibit "recovery projects" in old growth, roadless areas and riparian areas where such activities are prohibited by Forest Plans. But this change is meaningless because the Forest Plans lack protection for these critical areas, and it is precisely this lack of protection driving many resource conflicts on the National Forests. For example, the Northwest's Late-Successional Reserves do not prohibit salvage logging, so recovery projects would be allowed to proceed. Riparian reserves are also being routinely logged by the agency, as allowed under the Northwest Forest Plan.

ForestWater Alliance reports that the bill, H.R. 2515 could come to a vote in the House of Representatives as early as March 23.

FWA has suggested a sample letter supplied by Earthjustice (formerly Sierra Club) Legal Defense Fund that you can send to your Representative to ask for his/her opposition to the bill. The letter explains many points, contains all the arguments you need to oppose the bill, and can be tailored to your needs.

In addition, you can call 1-800/522-6721 during office hours in D.C., ask for your Representative's office, and leave a message that you don't want him/her to support H.R. 2515.

The Honorable Norm Dicks (for example)
U.S. House of Representatives
Washington, DC 20515

RE: H.R. 2515

Dear Representative Dicks:

As a voting resident of your district and a citizen concerned about the fate of our National Forests, I want to draw your attention to a recent proposal to increase logging on our National Forests.

Last fall, Rep. Bob Smith introduced H.R. 2515, misnamed the "Forest Protection and Recovery Act." Like most of its predecessors, H.R. 2515 contains several mechanisms that, taken together, seek to increase logging by private timber companies of more, bigger, and green trees in our National Forests. These mechanisms include financial incentives for logging; a new, politically-charged scientific committee; and shortened time frames for meaningful evaluation of logging activities through conservation laws. All of this is at the expense of wildlife, water quality, and recreational opportunities on our National Forests. These and other concerns about H.R. 2515 are detailed below:

First, H.R. 2515 uses pseudo-science to justify increased commercial logging in the name of "forest recovery." The bill is based on insupportable claims of a national forest health "crisis." There is no scientific consensus that such a "crisis" exists. More specifically, there is a significant difference between the national "forest health crisis" often claimed by the proponents of the timber industry, and the existence of forest health problems within some stands on particular National Forests. In either case, the Forest Service already has all the authority needed to undertake specific "forest health" treatments. In fact, the agency already has granted itself considerable flexibility under the National Environmental Policy Act (NEPA) to bypass environmental analyses for projects that might be construed as benefitting "forest health." For example, categorical exclusions from NEPA are already provided for projects involving up to 1 million board feet of salvage, 250,000 board feet of green trees, and 200,000 board feet of thinning. Further, there also exist broad categorical exclusions for thinning, brush control and prescribed burning for timber stand and/or wildlife habitat improvement. These types of non-commercial activities can adequately address particular forest health problems on particular forests.

Second, H.R. 2515 is flawed from the start because it is premised on a pseudo-scientific forest health report, misnamed the "Forest Health Report on the United States," commissioned by Rep. Charles Taylor (R-NC) and written by the "Forest Health" panel led by Dr. Chad Oliver. With little or no peer review, this report was prepared by foresters and silviculturalists without involvement from biologists, hydrologists, ecologists, and other scientists necessary for an adequate examination of forest ecosystem health issues. Worse still, H.R. 2515 incorporates this same fundamental flaw in the composition of its own scientific advisory committee.

Third, the bill approaches forest health issues from a decidedly silvicultural perspective: i.e. that the best way to make forests healthy is to cut them down. Once again, there is little scientific support for the proposition that more logging will make forests healthier. Indeed, one of the lessons of the Salvage Rider should be that logging is not a solution to forest health problems. As you recall, the Salvage Rider -- or "Clearcut Rider" -- used similar claims of a "forest health crisis" to justify suspending all environmental laws in order to increase logging on every National Forest in the country.

Fourth, H.R. 2515 is eerily reminiscent of a bill introduced in the 104th Congress by Idaho Senator Larry Craig (S. 391). Like the old Craig bill, H.R. 2515 attempts to give the Secretaries of Agriculture and Interior broad discretion to designate "recovery areas" and authorize "recovery projects" of an unlimited size, number and duration.

Fifth, H.R. 2515 seeks to give government agencies broad discretion to short-cut environmental laws and limit meaningful citizen participation in forest management decision-making. For example, it requires the agencies to make final decisions regarding the designation of forest health areas and authorization of forest health projects within 120 days. This deliberate truncating of the time frames established for public participation under the National Environmental Policy Act appears intended to create a de facto exclusion of both meaningful public participation and critical scientific analysis about the potential effects of proposed recovery projects. By short-circuiting environmental laws, this bill attempts to create unnecessary exceptions from safeguards that protect water quality, wildlife, and recreational opportunities.

Last but not least, H.R. 2515 traps the Forest Service in a vicious cycle of financial incentive to cut down healthy forests. The vast majority of activities most likely to address such problems -- such as prescribed burning and pre-commercial thinning -- cost money for the government and do not make a profit for the timber industry. Forest activities that generate net revenues usually include commercial logging of green trees. Thus the industry is pushing for a commercial logging-oriented solution to an alleged forest health "crisis." H.R. 2515 contains an off-budget fund that is meant to operate, after an initial government appropriation, on revenues generated by "forest health" activities. Since the only "forest health" activities that can consistently generate revenues for the fund are those that log healthy, green trees, the Forest Service will have a powerful incentive to allow cutting of healthy forests in order to raise money for forest health improvement projects!

The Quilcene District is accepting comments until April 10 on the proposed Easter Salvage Timber Sale in the Tunnel Creek portion of the Big Quilcene key watershed, which supplies water to Port Townsend.

The preferred alternative consists of 10 acres within the Late-Successional Reserve, estimated at 347,000 board feet. Helicopter removal, in this unroaded area, is planned to minimize soil disturbance Nearby plantation thinning is also planned.

For a copy of the Environmental Assessment, and its four alternatives, or for more info, inquire from, and/or send comments to: Steve Ricketts, Quilcene RD, P.O. Box 280, Quilcene, WA 98376; 360/765-2200.

Call 360/385-6271 for information about these issues.

QUAFCO News March 1998