QLG Appeal of the SNFPA Decision page 43

Timber Management.

The FEIS fails to provide a range of timber producing alternatives that meets the ever-increasing demands of Californians and the citizens of the United States. The FEIS and the ROD violate: NFMA 219.1(a) and 219.4(a)(1) Maximize net public benefits; 219.1(b)(10) Systematic interdisciplinary approach; 219.1(b)(13) Sensitive to economic efficiency; 219.1(b)(14) Responsive to changing social and economic demands; 219.4(a)(2) Reflect production capabilities; 1500.2(f) Quality of human environment; 1502.9(b) Reveal and respond to any responsible opposing view; 1502.24 Insure professional integrity; APA Sec 706(2)(A) Arbitrary and capricious or not in accordance with law.

California currently imports approximately 76% of the 8 billion board feet of wood products consumed annually by its residents. The FEIS shrugs off this fact with the inconsequential comment, "Imported logs and lumber from Canada and South America have been meeting the demands for wood products" [Volume 2, Chapter 3 page 29]. Consequences of importing this volume of wood instead of properly managing and harvesting readily available timber resources within California national forests have at least these significant adverse consequences:

(1) Loss of primary jobs and local economic opportunities in logging, timber processing and lumber milling.

(2) Loss of secondary economic opportunities in support industries and services.

(3) Loss of economic viability in rural communities dependent or partly dependent on logging, timber processing and lumber milling.

(4) Loss of electric generating capacity due to reduced fuel for biomass-fired plants.

(5) Increased direct Federal costs to conduct the required fuel reduction and forest health work entirely through service contracts.

(6) Loss of tax revenue due to the adverse economic effects.

(7) Increase federal costs for direct county roads and schools payments that could be largely or completely handled out of forest reserve revenues that are generated from gross timber receipts.

(8) Increased costs and reduced national economic security due to balance-of-trade deficits.

(9) Increased hazards to society related to:

a. Delay in implementing fuel reduction and/or curtailment of fuel reduction program, with consequent increase in local wildfire hazards and loss of critical watersheds and wildlife habitats.

b. Greatly increased health hazard due to smoke and air pollution from wildfire or prescribed burning of material that could be mechanically removed and processed with 97 percent reduction of pollutants.

c. Irresponsible transfer of troublesome environmental effects to exporting nations where timber and milling operations are less efficient and well regulated.


QLG Appeal of the SNFPA Decision page 44

The Forest Service is required by law to provide a high level of sustainable timber yield [16 U.S.C. 531 and implementing regulations]. The FEIS and ROD don't even pretend to comply with this law. Through the elimination of available and suitable lands for timber management, the application of restrictive standards and guidelines, and the expansion of time consuming and costly Limited Operating Periods, the timber and biomass yields of the preferred alternative are merely a fraction of the levels specified in pre-existing forest plans. After decimating the pre-existing programs and invalidating all assumptions on which they were based, the FEIS and ROD fail to provide the new determinations of timber land allocation, projected growth and yield, and allowable sale quantity required by NFMA and its implementing regulations.

Failure to consider the full range of timber yield outputs that are feasible and legally attained is a prominent example of how the FEIS fails to include the legally required full range of alternatives. The alternatives actually range from near–zero to a low-level yield, excluding a maximum timber alternative or even an alternative producing historic timber levels.

The FEIS fails to consider an alternative that develops and maintains the appropriate forest cover with species of trees, degrees of stocking, rate of growth, and structure of stands designed to secure maximum sustained yield benefits. The selected alternative fails to control, maintain, or restore vegetative species diversity consistent with maximum multiple use sustained yield benefits.

The FEIS fails to analyze and display the suitability of lands for resource management. Existing forest plan designations of capable, available, and suitable land are rendered meaningless by the Decision, and the FEIS does not include replacements for these required designations.

The FEIS fails to consider and examine changed conditions that have occurred since the release of the Draft EIS. California is experiencing an energy crisis in which forest biomass can play a critical role. Although not sufficient to eliminate the immediate energy crisis, 29 biomass facilities currently operate at less than peak capacity due to insufficient availability of biomass material, and making available the full capacity of these facilities could often tip the balance between reliable electric supply and rolling blackouts. Moreover, 13 biomass facilities are closed, several of which could reopen if there were a long-term prospect that biomass material would be available. Selecting Alternative 4 in the FEIS could double the availability of biomass material over the level allowed by the ROD, which would be sufficient to fuel three 30-megawatt power plants.

Finally, and perhaps most important for the long term sustainability of the communities, forests and the health and safety of the affected citizens and wildlife, the Forest Service, in adopting this FEIS and ROD, has failed to recognize that sustaining a viable industrial infrastructure is not just an economic and social issue any more, it has become a vital ecological necessity. Without a healthy and competitive industry with a capacity to remove and process the increasing volume of excess biomass that now threatens our national forests, there is no hope to accomplish the necessary fuel reductions and silvicultural treatments that will make our national forests truly safe and sustainable. And without the offsetting revenues from an economically viable timber component in the fuel reduction program, there is little hope of obtaining the continued appropriations that would be needed to pay for fuel reduction at the scale and pace specified in the national Cohesive Strategy and other policy statements. Far from being "sensitive to economic efficiency" [NFMA 219.1(b)(13)], the FEIS and ROD generate the highest costs while implementing the least effective and productive methods of fuel reduction in the alternatives considered.