P.O. Box 1749, Quincy CA 95971

December 11, 2001

Pete Stine
PSW Forest Service
Room 262
801 I Street
Sacramento, CA 95814

Subject: Revised Draft of the QLG Administrative Study Plan, dated 13 September 2001.

Dear Peter,

Our comments are based primarily on the answer to one question: Would this aspect of the proposed study be compatible with the HFQLG Act and the Pilot Project, or would it be in conflict with them?

The short answer is this: We find enough serious conflict on key issues that we believe implementation of the Administrative Study as specified in the SNFPA ROD and proposed in the draft plan would not be legal under the Act and would seriously interfere with successful implementation of the Pilot Project. Furthermore, we do not see how changing the draft plan could satisfy the requirements stated in the draft study plan for the experimental design and at the same time bring the Administrative Study into conformity with Pilot Project requirements specified in the Act.

As the study plan stands now, we believe the proposal regarding fuel reduction effectiveness is redundant, and the proposal for implementation of group selection silviculture cannot be reconciled with the Act and the Pilot Project. Our main reasons for reaching those conclusions are these:

1. The first principal issue the Administrative Study proposes to address is whether specific combinations of Defensible Fuel Profile Zones (DFPZs) and subsequent area treatments would be effective in reducing the extent and severity of wildland fires. It is not necessary to go beyond the monitoring plan already included in the HFQLG Pilot Project to make that determination for the area covered by the Administrative Study, and if greater scientific rigor is required to address this and related issues in a wider context, it is already being provided in the Fire and Fire Surrogates (FFS) study now underway at national scale under PSW direction. We understand that when at least one national forest in the HFQLG area was earlier asked to participate in the FFS study, the invitation was refused. We don't understand how it was a bad idea about a year ago to participate in the FFS study, but all of a sudden this year it's a good idea to spend time and money on duplicating work that will already be done by Pilot Project monitoring or the FFS study.

2. The Act requires “Group selection on an average acreage of .57 percent of the pilot project area land each year of the pilot project.” That rate of harvest is based on an average rotation age of 175 years, with harvests spread as evenly as is practicable over the rotation period. The draft plan proposes to do something quite different from that provision of the Act. It proposes no group selection on about 32% of the treatment unit acreage identified as suitable, 5.7 percent group selection on about 30% of the suitable acreage, and 11.4% on about 37% of the available acreage. This is a weighted average of 6.0% of the entire 185,000 acres that is estimated to be available in the eleven treatment units. As we understand it, the SNFPA decision prohibits implementation of group selection on the remainder of the HFQLG Pilot Project area, except that the relatively few acres already under contract can proceed to completion. This amount and distribution of group selection acreage is not at all compatible with the requirements set out in the HFQLG Act.

Regarding the group selection planned for the Administrative Study, it is proposed to do that 6 percent within 3 years, an average rate of 2 percent per year, which is 3.5 times the intensity of group selection specified in the Act. Furthermore, on over 1/3 of the available acreage it is proposed to treat 11.4% in three years, which is 6.7 times the intensity specified in the Act. Of course we understand that not all the work initiated within 3 years would be complete within 3 years, due to startup delays and some uncertainty as to when contracted harvests would actually take place. However, those uncertainties would accompany any group selection program, and they do not change the fact that the Act calls for an average implementation rate of 0.57 percent of the available acreage per year, and the study plan calls for something quite different.

The SNFPA ROD says the intent of the Administrative Study is to “...examine the relationship between management-caused changes in vegetation and their effects on spotted owl habitat and spotted owl population dynamics.” The four treatment units proposed for the most intense group selection average 17,250 acres apiece, said to be large enough that at least10 pairs of owls are likely to reside in each unit. If group selection harvest is done at a rate 6.7 times what the Act calls for, the resulting disturbance to owls can hardly be called a fair test of the effects of the group selection proposed by QLG and specified in the Act. The study plan test has a foregone result built into it, a result that would almost certainly have a devastating adverse effect on the credibility of the HFQLG Pilot Project.

3. The Study Plan is based on a rigid grid-based procedure for selecting group locations. The result is said to be that “...vegetation is removed proportional to occurrence on the landscape...” This is not what QLG recommended in the Community Stability Proposal, nor does it conform to group selection as described by any silviculturist we know. The group selection system we envisioned when HFQLG was created is classic group selection as described in any textbook on silviculture and as practiced in places like the Blodgett Experimental Forest. The Act requires a demonstration of the effectiveness of group selection, by which it means real group selection, not something else designed for a different purpose.

When this point was brought up in an email exchange between a QLG member and Mike Landrum, the group selection team leader, Mike's reply was that the team discussed the issue intensively and decided on the grid system as an experimental necessity, but that “In a more perfect world, I too would rather focus group selection on trees and stands rather than mechanized map locations.” We don't expect a “more perfect world,” only a credible implementation of group selection silviculture that conforms to the clear mandate of the Act.

4. Once the center points of groups are determined by the grid system, then the Study Plan rigidly specifies particular sizes, shapes, dimensions, and orientations for the groups themselves. This would result in group boundaries cutting across stands and clumps of trees at arbitrary positions and angles, a practice that is once again completely at odds with anybody's usual selection and marking criteria for group selection silviculture.

5. The Study Plan specifies a distribution of group sizes that is not based on sound silvicultural criteria but came entirely from post-fire examination of one part of the recent Storrie fire. The specified distribution is 30% of the groups at 0.5 acre, 40% at 1.0 acre, 20% at 1.5 acres, and 10% at 2.0 acres. This is said to emulate the opening sizes observed after the fire.

First, group selection is a silvicultural system, intended by QLG and the HFQLG Act to demonstrate the effectiveness of this particular system for promoting regeneration and growth of trees, not emulate openings created by a recent fire. No evidence is cited that the distribution of opening sizes proposed in the study plan would be best suited for silviculture or any other purpose.

Second, even if a “natural” range of sizes were to be the goal, it is unlikely to be achieved by emulating the Storrie post-fire forest structure, because (1) the pre-fire forest structure in that area is not likely to be “natural,” (2) there is no evidence that it is representative of the whole forest, and (3) the Storrie fire was not a “natural” event that would necessarily produce a “natural” post-fire forest.

The group selection proposed by QLG, as described in the HFQLG FEIS, called for a range of group sizes up to a maximum of 2 acres. Since the HFQLG Act requires the Secretary to “...use the most cost-effective means available,” the intent was to select groups according to the available stand structures, giving preference to the largest available groups within the 2-acre limit, if those groups also met other selection criteria, because larger groups are more effective in regenerating desired shade-intolerant species, and are much more cost-effective, particularly when some trees in a group must be left because of dbh limits. Also, QLG agrees with findings at the Blodgett Experimental Forest and elsewhere, that openings should, if possible, have a long dimension at least twice the site potential tree height. This almost always favors 2-acre openings instead of 1/2 acre openings. Small openings are less efficient to operate in, require more disturbance per acre for access, and are more likely to generate collateral damage to un-harvested trees in the harvest groups and adjacent stands.

6. A fundamental problem with the Administrative Study is that it was inserted into the SNFPA ROD at the last minute, without any foundation at all in the SNFPA FEIS, in a desperate attempt to avoid implementing the management actions required by the HFQLG Act, but substitute a scientific experiment instead. As a result, the hurriedly proposed experiment is not well founded in questions originating with scientists, and the Pilot Project is compromised by an overlay of management activities other than those specified in the HFQLG Act. If the Administrative Study is implemented as directed by the Regional Forester and specified in the draft study plan, the result is unlikely to be good science, and it will certainly not be proper implementation of the Act.

Our conclusions about group selection are (1) that the so-called “group selection” proposed in the draft Administrative Study Plan is not “group,” because the criteria would not produce groups that any competent silviculturist would find reasonable, and (2) it is not “selection” because locations are determined by a rigid grid system that would never be employed by a competent silviculturist to select harvest groups.

Because of the conflicts identified above, we must oppose implementation of this Administrative Study as currently directed by the Regional Forester and proposed in the Draft Study Plan.


signed by Mike Yost and George Terhune
for the QLG P2C2 Committee