March 1,1999

Kathleen Reich, Environmental Staff
Office of Senator Dianne Feinstein
U.S. Senate Office Hart-331
Washington, DC 20510

Dear Kathleen,

I am writing you to clarify any confusion that may exist regarding the in-person communication we had about minutes from the Quincy Library Group adaptive management CASPO exemption discussions at a meeting attended by Erin Noel, an attorney for the Sierra Nevada Forest Protection Campaign, in Quincy on January 28th.

I attended the QLG/Forest Service meeting in Quincy February 26th where we discussed this issue in an open and civil forum. I would like to reiterate the following points:

Ms. Noel's notes accurately described what she felt to be an important topic of the meeting. Monitoring CASPO exemptions is important to the interests of the Sierra Nevada Forest Protection Campaign.

QLG members felt they should be able to discuss issues in an open meeting and not-receive a "lightning bolt" from Washington, DC regarding the topics of discussion. I explained the "Campaign" is very concerned about proper-implementation of the Herger-Feinstein QLG Pilot under existing law and guidelines. It Is my job to order up a "lightning bolt" if I thought there might be adaptive management exemptions of any sizable scale proposed for a project of this intensity and duration. The discussion (in Erin's notes) regarding flexible limits on canopy closure/basal area/basal area-derived diameter limits was very alarming.

We discussed adaptive management and my experience of seeing the CASPO guidelines "decaying" over time with bolder and bolder adaptive management-projects pushing the limits of what was intended in the CASPO direction for the Region.

It is the Campaign's contention that adaptive management prescriptions of a scale not described in CASPO, or planning non-CASPO project actions without evoking adaptive management would violate Herger-Feinstein and existing Federal laws. Although QLG members are always free to discuss what they wish, in the real world, it is logical that we would respond to such a discussion with alarm.

I believe some confusion occurred during my last trip to Washington regarding the notes from this Jan 28th QLG meeting. I assumed that point 1(a) of Erin's notes (implementing CASPO in large units and averaging canopy closure/basal area across large units) inferred exemption from the 30" diameter retention rule.

Erin informed me that exempting the 30" rule was not a part of the QLG discussion. I inferred that large unit averaging certainly implies exemptions to snag, down log, and tree retention standards. I incorrectly interpreted item I (a) of her notes.

The main point of Erin's report was the discussion of "averaging across large units" and "flexible cuffing limits. In a time of seriously declining California spotted owl populations across the Sierra Nevada, including the Lassen National Forest, it is highly inappropriate for QLG or the Forest Service to be thinking of prescriptions that dramatically increase forest fragmentation. They should be concerned about what the Sierra Nevada Science Review states regarding sufficient suitable habitat within home ranges of existing owl pairs, and the larger watersheds as a whole, to maintain viability, rather than looking for exceptions to the habitat protection guidelines.

In conclusion, I had an engaging and mutually respectful meeting with the QLG members and Forest Service last week. I understand their desire for a clear and speedy implementation of the Act. I believe they better understand our concerns about CASPO exemptions and fragmentation effects on the California spotted owl population. We (Forest Service/SNFPC/QLG) are meeting in Sacramento March 4th to continue to work on these issues.

If you have any further questions please call 530/622-8718



Craig Thomas
Sierra Nevada Forest Protection Campaign

Cc: Ann Kennedy, Natural Resources and Environment, USDA
Erin Noel, Attorney Sierra Nevada Forest Protection Campaign
Linda Blum, Consultant Quincy Library Group


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