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Back Comments on the Babione Vegetation Project - January 26, 2007
January 26, 2007 Re: Babione Vegetation Project Dear David: Please accept these comments from the Wyoming Wilderness Association on the Bighorn National Forest’s proposal to log the Babione area of the Forest. These comments will be sent via email and a hard copy will be sent via US Mail within 30 working days from the Dec 19th date. The Wyoming Wilderness Association (WWA) was re-established in 2003 as an educational 501(c)(3) tax-exempt organization whose mission is to work to protect our public wild lands because present generations are responsible for ensuring the future of wild places for people and wildlife, including the Bighorn National Forest. WWA has the following concerns: This proposed action would allow timber harvest in about 1,633 acres. This is a huge area that would fragment and disrupt any kind of recreation activity as well as harm the wildlife use in the area. WWA is pleased that the Babione inventoried roadless area has been removed from the proposed action, but to pretend that “treating” 1600 acres is going to provide better diversity for vegetation is dishonest. The goal of reducing wildlife risk is also based in misinformation. Cutting down a forest is not the answer to preventing fires in our national forests. Studies are showing that thinning forests without also burning accumulated brush and deadwood may actually increase forest fire damage rather than reduce it, researchers at the Forest Service reported in two recent studies. Studies of fires in 2002 in Colorado and Oregon raise questions about the effectiveness of thinning forests without burning debris. The findings cast doubt on how effective some of the thinning done under President Bush's Healthy Forests Initiative will be at preventing fires if the forests are not also burned. The studies show that in forests that have been thinned but not treated with prescribed burning, tree mortality are much greater than in forests that have had thinning and burning and those that have been left alone. Another study, on Blacks Mountain Experimental Forest in Northern California, had similar findings. The studies, combined with other recent research showing that climate change is reducing snowpack and making the fire season longer and more intense, have prompted researchers to urge the Forest Service to use prescribed fire more. Ronald H. Wakimoto, a professor of forestry at the University of Montana who studies fire. "We need fire on the ground. The only thing that stops fires is previous fire or prescribed fire." A study of a 500,000-acre wildfire in Oregon in 2002, called the Biscuit fire, showed that the mortality rate of trees in forests that had neither thinning nor prescribed burns was a little more than half. The study, published in late 2005 in The Canadian Journal of Forest Research, found that 80 to 100 percent of the trees in forests that had only been thinned died in the blaze, while 5 percent of the trees died in forests that had been thinned and burned. A 2003 study of another large blaze, the Hayman fire in Colorado in 2002, published as a case study by the Forest Service, showed that fires killed 50 percent of the trees in a natural, unthinned forest but killed 90 percent in a thinned forest, because the fire on the ground was hotter. When thick stands of small trees are cleared and space is created between larger trees, it causes a mat of litter several inches thick, including pine needles, slash from thinning and other debris, to dry out. New growth of shrubs and grasses, stimulated by thinning, also adds to the fuel load. When a fire gets started, it burns hotter and moves faster than when it was slowed by thicker growth. "The forest floor is hotter, drier and windier," Dr. Wakimoto said. "When we thin, we're not getting the shade, and the vegetation doesn't slow the winds.” He said thinning near urban areas was particularly worrisome. "If they don't treat the fuels on the ground, the fire will get to the homes faster," he said. Thinning may create room to fight fires, he said, but it creates a false sense of security because serious fires can still happen. Thinning is often done to prevent crown fires, which move through treetops, but unless crowns are 20 feet apart, which is usually not the case, surface fires can still create crown fires. The most efficient way to decrease these fire risks is with prescribed fire, which can be difficult in areas with houses. So-called activity fuels, the debris left by thinning, were a big part of the problem in the Biscuit fire. "Thinning needs to be done completely," said Crystal L. Raymond, a researcher at the College of Forest Resources at the University of Washington, "including activity fuels, which can be done with prescribed burning." Forests around the West have adapted to frequent fires, which were set by lightning and for centuries by American Indians. But regular, minor fires have been thwarted because of increasing numbers of homes in grasslands and forests. When a fire does start, it feeds on accumulated fuel and is more damaging than smaller, recurring fires would have been. Federal officials say they understand the role of prescribed burns but have not used them widely. "It's an issue of sequence," said Mark E. Rey, under secretary for natural resources and the environment at the Agriculture Department. "We'll follow the thinning with prescribed burns." There is no mention in the Babione Project proposal for prescribed fires following thinning areas, but should be. Thinning has been controversial, even when accompanied by prescribed burns, since the Healthy Forests Restoration Act was signed into law in 2003. A 1996 federal study, the Sierra Nevada Ecosystem Project, was conducted by a team led by Dr. Don C. Erman, emeritus professor of ecology at the University of California, Davis. Dr. Erman said thinning could be effective only if it was repeated as often as every two years, which would be prohibitively expensive. "It's a treadmill you have to be on all the time," he said. Prescribed fire may extend the period between thinnings, he said, but not by much. Prescribed fire can also be controversial, though for a different reason. A 2000 blaze in New Mexico called the Cerro Grande fire that started as a prescribed fire burned more than 40,000 acres and 400 houses near Los Alamos. Thus, prescribed fires must be carefully controlled but should be recognized as the most effective tool for achieving the goal of defending private cabins and developments. A report by the Office of the Inspector General at the Agriculture Department issued in March was critical of the Forest Service's management of the Healthy Forests Initiative, saying the program had no consistent analytical process to determine which areas were most at risk and did not set priorities for projects. WWA recommends the project area involve only the smallest acreage necessary to reduce fuel loads and increase firefighter and public safety. Astonishingly, the project area totals 8,311 acres with more than 1,600 acres to be cut. WWA recommends that the large clear cut areas (Units 03, 04 & 05, 16, 17 20, 21, 25) be drastically reduced to 40 acre units, remove all of the large areas within the elk security cover (03, 04, 05, 16, 17, 20, 25), which would prevent any further fragmentation of this significant elk habitat area will not be a temporary reduction of elk use but a generational disturbance with any hope of return of the elk. Fragmentation of habitat is the number one cause of loss of elk habitat. WWA has not seen a project that promotes fragmentation and cumulative impacts to elk as this project. Slope angles and soil stability must be thoroughly analyzed as to whether trees may be cut and removed without negative impacts to the watershed and nearby environs. Project area land and lands nearby are also commonly utilized by the public for the outstanding recreational opportunities they provide, including camping, hunting, fishing and general outdoor-related experiences. As the project area lies within a 5.4 prescription, which includes high quality wildlife habitat and escape cover, big game hunting opportunities, and dispersed recreation activities must not be negatively impacted. The project area has varied wildlife, such as big game animals, raptors, songbirds and forest carnivores, and must be thoroughly analyzed to keep negative impacts to a minimum. There is little analysis of wildlife, except for elk, which the Bighorn NF is ignoring by logging the security cover areas. The analysis should also include red squirrel Red breasted nuthatch, Brewer’s sparrow and trout. Any impacts to populations of other rare species such as goshawks, 3-toed woodpeckers, songbirds, voles, amphibians must be considered and protected. WWA urges that the BNF use appropriate caution in order not to adversely affect these renowned resources and that the BNF comply with all laws during the analysis of such actions and during any implementation of actions arising from lawful decisions. In determining the scope of this project, USFS must consider “connected actions,” “cumulative actions,” and “similar actions.” 40 C.F.R. § 1508.25. Connected actions are actions that are “closely related” to the Babione vegetation project. WWA has concerns regarding two stated objectives under this project’s Purpose and Goals; to “bring the vegetation distribution closer to the desired condition, improve wildlife habitat, reduce wildfire hazard, sustainably produce timber and other forest products and to manage motorized travel.” 1. Bringing the vegetation distribution closer to “desired condition” is vague and unknowable. Cutting 1600 acres in a 4 mile radius can only wreak havoc and destruction. The area will not regenerate in mandated 5 years. It is unacceptable to display this as the “desired condition.” 2. 87% of the area to be cut will be in elk security habitat. Security habitat is defined as hiding 80% of an elk at 200 yards. By implementing these huge clear cuts of 254 acres, 164 acres, 210 acres, 175 acres etc, will not improve elk security cover, but will also disturb nesting goshawks, owls, wood peckers, squirrels and other wildlife that are left out of the analysis. 3. It has been noted above that thinning will not succeed to reduce fire without including a prescribed fire regime into the plan. Clear cuts are not the answer to reducing fires. The proposed large clear cuts will devastate the landscape, destroy the recreation experience and run off the wildlife. 4. The Bighorn cannot sustainably produce timber and other forest products. It takes 120 years to grow an 8” marketable tree on the Bighorns. The climate is too high, dry and harsh to maintain, let alone sustain a timber industry. Please keep WWA informed on developments concerning this proposed project and on others affecting wildlands and wildlife in the Bighorn National Forest. Sincerely,
Liz Howell, Director
Wyoming Wilderness
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