Faulty Science and Fatal Flaws in the DSEIS Framework Revisions

I. Are we burning up more old growth than we are growing?

Response: Forest Service characterizes Sierra Nevada fire loss as 68,000 acres/year of old forest “lost” annually. DSEIS suggests, “at this rate we will burn up old forest faster than it can be replaced.” (DSEIS Summary p.3)

It is misleading to characterize the total amount of acres burned as “lost” (suggesting that all fire is lethal fire). On DSEIS p.163 Figure 4.2.4b (see below) lethal or stand replacing fire is displayed as approximately 15 thousand acres/year to the third decade.

Second, on p. 181 the DSEIS shows in Table 4.3.2.2a. Projected Old Growth Late Seral Stage increasing significantly region-wide, under all alternatives from 1.5 million to 2.5 million acres over the first 30-year period. This growth rate directly contradicts the summary statement on p.3 regarding the loss of old growth due to stand-replacing fire.

II. Forest Service claims not enough land will be treated to protect communities?

Response: Currently the 2001 Framework Plan identifies 319,204 acres in the “defense zone” nearest communities. The Framework Plan provides increased flexibility near communities by allowing increased cutting of large trees and relaxing standards in place over the last 10 years under the CASPO Guidelines.

The Sierra Nevada Framework focus is consistent with the National Fire Plan and the California Fire Plan. The Forest Service has presented no hard evidence that the Framework is economically unfeasible. Instead, the Forest Service, under Regional Forester Jack Blackwell, has resisted active implementation.

Forest Service line officers are presenting a biased opinion of the new change in direction just as they did in 1993 when the CASPO Guidelines were introduced. Don Yasuda, Wildlife Biologist Eldorado National Forest 2/21/03 in an e-mail to District Ranger and Review Team Member Sam Wilbanks states, “you might make sure it is clear that a lot of the concern expressed by the Rangers was the same type of concern expressed by the Range and Recreation communities and was based heavily on the unknown. It is pretty easy to look at any complex set of rules and imagine a picture in your mind of how it couldn’t work. This is usually the tact that people take…we fixate on what doesn’t work…The point is that a lot of concern from Rangers collectively seems to be based upon the hypothetical rather than through IDTs (project planning teams) trying to work on a piece of new ground and apply the ROD from scratch. I keep thinking how we all thought the Interim Guidelines would never work and yet we now wish we could just go back to them because they are so simple!!” (emphasis added)

The intention to thwart successful implementation is clear in a recent comment made by Tahoe National Forest Supervisor, Steve Eubanks at a meeting with a team of scientists on August 7, 2003, “We looked at several areas and didn’t spend time on planning because it wasn’t worthwhile to implement it. We can’t show you where it didn’t work because we didn’t go very far in planning these areas.”

III. Will the DSEIS Revisions lead to a sound fire strategy?

Response: Sierra Nevada wildfires fires are driven by surface and ladder fuel accumulations. The DSEIS focus on harvesting large trees, 20”-30” diameter, flies in the face of the best available science.

Sierra Nevada Ecosystem Project Report (1996) Volume II, Chapter 43, p. 1164 suggested, “fuels treatment scenarios that did not treat surface fuels, such as biomassing only the over-story or piling and burning did not appreciably change fire behavior.”

The Framework FEIS Volume 2, Chapter 3, part 3.5-page 282 suggests treatments that remove overstory trees “could produce faster windspeeds in the understory as a result of the sparser canopy.” Increased wind speed, drying surface fuels, and increases in understory brush growth from increased sunlight, all exacerbate surface fuel conditions and increase fire risk.

Treatments that remove large fire-resistant trees are NOT fuels reduction but are part of their new logging objective. The Framework’s focus of treating surface fuels, ladder fuels and under-story thinning of trees up to 20” (30” in defense zone) has been shown to be the best approach to fire restoration and it has the added benefit of maintaining suitable wildlife habitat for at-risk species.

IV. Is fire destroying significant spotted owl habitat?

Response: The DSEIS p.185, states, “the risks to losing PACs (spotted owl nests) to high severity fire is uncertain.” In fact, the rate of loss is approximately 0.2 percent of the PACs/SOHAs in the Sierra Nevada over the past 8 years. This is not a significant loss rate. This is validated by Figure 4.4.2.2.a (above) and the increasing levels of old forest (spotted owl habitat) under all alternatives.

V. Will the Forest Service revised plan protect old growth?

Response: The Framework Plan contains 4.2 million acres of old forest emphasis areas centered around the 1996 SNEP old growth locations. The old growth reserves have specific management objectives to protect old growth structure (trees, snags, logs) and are managed with the re-introduction of prescribed fire and limited small tree (<12” diameter) harvesting.

The revised plan proposes to raise the logging limit to 30”, thereby allowing the logging of old growth trees across all national forests. This “one-size-fits-all” cutting prescription also seriously degrades the understory portion of these important forests, impacting imperiled species like the California spotted owl and the Pacific fisher that live and hunt in the old growth forest understory.

VI. Do the Framework Revisions protect the California spotted owl?

Response: The tripling of logging across the Sierra Nevada and the cutting of trees up to 30” plus the additions of 43,000 acres of small clear cuts under the reactivated Quincy logging plan, when added to a possible 3.2 million acres of “forest health” harvesting, when combined will likely cause the spotted owl to be listed under the Endangered Species Act.

The DSEIS says as much on p. 193, “Alternative S2 tends to disrupt the continuity of habitat conditions (i.e. habitat structure and distribution) over the 20-year time period.”

Twenty years is the approximately the life span of the existing population. While the Framework maintains structural diversity within treated stands, alternative S2 “provides for very limited structural diversity within treated stands.” “The increases in fragmentation and patchiness are likely to isolate populations and limit the opportunity for interactions across (National Forest System) lands.”

VII. Is it scientifically sound to rely on long-term 130-modeling projections?

Response: There is a significant amount of variation or error potential in relying upon long-term modeling projections for a variety of important issues in the DSEIS.

The Framework EIS rejected the use of these long-term projections as risky, and unreliable for decision-making based upon the input from scientists and old growth and wildlife specialists in the Forest Service (2001 FEIS Volume 2, Chapter 3, part 3.2—page 129-130; FEIS Vol. 3, Chapter 3, part 4.4, page 87).

“…USFS forest inventory information has continued to serve as the basis for much of the spatial planning and modeling exercises and policy analyses underlying the EIS. These are applications for which the data were never intended. The uncertainty in any projections of stand structure and composition, fire behavior, or species habitat based upon this information is extremely high.” –Science Consistency Report by Frank Davis, UC Fire Modeler, in: Framework Administrative Record 2001. (Emphasis added).

“ Tree growth models are the worst for modeling; poor inventory currently; inventory collected for timber strata; we don’t know the strata for species; big trees in strata are not correct for species & implies incorrect projection. I say uncertainty for long projections 100-200 can not be trusted, maybe only 10-20 years. Also, these are modeled only for harvest systems that are not relevant today.” –Kevin McKelvey, Forest Service owl scientist and modeler, June 21-23, 1999 meeting with Framework Science Team, Spotted Owl Scientists and US F&WS regarding EIS Alternatives and Spotted Owl Modeling. In: Framework Administrative Record 2001. (Emphasis added).

[The Forest Service Modeler] “…is making the same errors in his large tree projections that he did in the previous EIS attempt. That is, he provides no confidence intervals around his projections and the details of his modeling assumptions are not made explicit. For example, when I look at the projection of the # of large trees in the mixed conifer type there is no uncertainty estimates associated with any of these trajectories. My guess would be that the uncertainty is so large that it is impossible to discriminate among the alternatives in terms of this metric. In addition, all projections would have greater uncertainty the more distant they are into the future—his graphs do not show this and therefore are misleading to the public.”—Dr. Barry Noon, Dept. of Fishery and Wildlife Biology, Colorado State University. In: Framework Administrative Record ID #1504 (Emphasis added).