QUINCY LIBRARY GROUP
P.O. Box 1749, Quincy CA 95971
November 29, 2002
Mr. Jack Blackwell
Pacific Southwest Region
USDA, Forest Service
1323 Club Drive
Vallejo, CA 94592
Subject: HFQLG Administrative Study
We are encouraged by information recently made available in the owl scientists' meeting notes, Danny Lee's presentation in a session following the recent QLG meeting, the Cosumnes River Demonstration Project, our Cone Fire field trip, and various conversations with Forest Service people on these subjects and others. It appears that much-needed corrections to the SNFPA Decision will be made, which should permit construction of the specified DFPZ network by the most cost-effective means available, as required by the HFQLG Act.
Unfortunately, the anticipated corrections would still leave us with one very significant impediment to full implementation of the Act as intended by Congress. The plan for the Administrative Study impedes full implementation of the Act in at least three crucial ways: (1) the designation of large areas where excess cost and deficient effectiveness will be imposed on DFPZ construction; (2) the initiation of group selection at artificial rates of implementation on larger contiguous areas than would be normal practice; and (3) the delay imposed by yet one more EIS to justify the Administrative Study's deviations from the underlying direction given by the HFQLG ROD as supplemented by subsequently adopted owl guidelines in a new SNFPA Decision. This delay would not be just to process a new EIS, it would almost certainly include a separate round of appeals and probably additional litigation as well.
The Administrative Study is not consistent with the intent or any requirement of the Act. The stated purpose of the Act is to demonstrate the effects of the specified management activities, not to conduct experimental research. That part of the Act that might be said to contemplate study of the results places strict limits on the expenditure of HFQLG funds for the scientific evaluation of Pilot Project results. The Study is thus inconsistent with the Act in at least two major ways:
(1) In order to provide the spread of effects called for in available drafts of the proposed administrative study plan, DFPZs would be constructed that are either significantly less than adequately effective or more than necessarily disruptive -- possibly some of both. For the same reason of providing spread, two versions of group selection would be implemented, neither one of which is in accordance with the demonstration of normal group selection that is required by the Act.
(2) The additional costs of this Study imposed on the Pilot Project exceed the study limits specified in the Act. We believe that some questionable costs have already been paid out of HFQLG-designated funds; but even if no such direct expenditures have been made to date, the additional costs and delays accumulated over the life of the Pilot Project as a result of conducting the Study will in effect use up large amounts of HFQLG funding intended for other purposes. The cost of an additional EIS is only the start.
While scientific study of Pilot Project effects would be valuable if done in separate studies for good scientific reasons, the last-second imposition of this HFQLG Administrative Study gives no assurance that a truly valid scientific question is being studied, and there is even less assurance that any such question could be adequately addressed by the means proposed. Any scientific studies properly done must have sufficient separation from the Pilot Project demonstrations to assure that the intentions of the Act are not compromised, and all funds designated for HFQLG implementation must be spent entirely for that purpose and within limits imposed by the Act.
Significant amounts have already been spent on initial surveys, planning, and preparation for a new EIS on the Study. At least the cost of the surveys need not be a waste, because those baseline data would provide very useful information for various kinds of monitoring and research, as well as the monitoring required by the Act. Additionally, the survey work can be used immediately to inform the design of the Group Selection, Individual Tree Selection, and DFPZ construction projects already authorized or mapped in the HFQLG EIS.
Our most vital long term need is, of course, correction of the original SNFPA ROD. But it will be bitterly ironic and a hollow victory for HFQLG if that correction immediately turns loose all the rest of the Sierra Nevada to start cost-effective fuel reduction while the HFQLG area remains saddled with the need to do an additional EIS and fight new appeals and lawsuits over a Study that was arbitrarily imposed by the original ROD for a purpose that was anything but scientific, was never persuasive, and is now only an enduring embarrassment.
Please correct the entire SNFPA ROD by also removing every reference to the Administrative Study.
Co-Chair, Pilot Project Consultation Committee
of the Quincy Library Group