QLG letterhead

Mr. Kent Connaughton
USDA Forest Service
Pacific Southwest Region
801 I Street
Sacramento, California 95814

Dear Mr. Connaughton,

These are comments by the Quincy Library Group (QLG) on the Sierra Nevada Framework for Conservation and Collaboration (aleferred to here as "Sierra Nevada Conservation Framework", or "SNCF"). In particular, this letter comes in response to the two questions posed under SNCF's Task 3. These remarks and suggestions were developed jointly by roughly a dozen QLG members.

We are pleased to be taking part in this innoative and courageous public collaboration process for the Sierra Nevada's forests, communities, water and wildlife. QLG members have participated in many of the information meetings and workshops already scheduled. There weresee QLG members present at today's workshop in DAvis. A copy of our first comments on Sierra Nevada conservation planning are included his letter as Attachment 1. We will undoubtedly offer extensive comments on the proposed action and alternatives when they are made available.

Background and Context

The Quincy Library Group has been seeking U.S. Forest Service action on revising and amending the Land and Resource Management Plans ("LRMPs," or "Forest Plans") of the Lassen, Plumas, and Tahoe National Forests since 1993. In August of that year, QLG submitted a 3-page proposal outlining landbase reallocations, silvicultural system changes, and new emphases on fire and fuels management, watershed restoration, and monitoring. The proposal was based upon alternatives already studied in the LRMPs' Environmental Impact Statements (EISs), and upon the 1992 CASPO Report and other emerging scientific work.

When QLG submitted its proposal to the Forest Service, it was widely acknowledged that Forest Plan changes were needed because of significantly changed circumstances (i.e., the "forest health" problems of widespread tree mortality and wildfire hazard during and after a multi-year drought), significant new information (e.g., that the SOHA management strategy was a "prescription for extinction" of spotted owls, the CASPO Technical Assessment, and watershed condition information newly collected), and significantly reduced Forest Service budgets. Any one of those three categories of change are sufficient to trigger LRMP amendment or revision, according to the national forest planning regulations at 36 CFR 219.10(e) through (g).

Members of the QLG were disappointed when it became clear that the group's proposal would be formally considered only within the larger Cal Owl EIS process, particularly when the Cal Owl ID team altered our landbase, silvicultural, and fuels management proposals to "fit" the linear programming model being used to estimate outputs and effects. The ID team also effectively added a "poison pill" to the QLG alternative by its selection of management schemes and land allocations for the non-QLG-area Forests.

Nevertheless, we took every opportunity to participate in the Cal Owl EIS process. The Quincy Library Group's comments on the draft EIS and related correspondence are part of the Forest Service's public record. We hereby request that those submissions be considered "incorporated by reference" into this current incarnation of forest planning, because they contain a large number of documents that provide background socio-economic, silvicultural, and fuels management information for the northern Sierra Nevada national forests. We also would refer any interested party to the QLG's website on the Internet for position papers, archival information, monitoring plans and results, other pertinent information. The website URL is www.qlg.org.

Quincy Library Group Legislation and Its Relation to the Sierra Nevada Conservation Framework

As you know, QLG is attempting to get Congressional direction to the Lassen, Plumas, and Tahoe National Forests separately from the Regional Forester's Sierra Nevada forest planning processes. The Quincy Library Group Forest Recovery and Economic Stability Act of 1997 (the "QLG bill" or the "pilot project") is expected to become law in early October, 1998. On that assumption the 300 days provided for completion of the pilot project Environmental Impact Statement (EIS) would expire about the end of July, 1999. Since the Sierra Nevada Conservation Framework (SNCF) EIS is also scheduled to be completed that month, and since the management activities required by the QLG bill involve issues that are (or should be) well represented in the SNCF, QLG strongly suggests that the Forest Service should take full advantage of all opportunities for efficient cross-reference between the two processes.

The specific management activities required by the QLG bill include (1) fuelbreak construction on 40 to 60 thousand acres per year, (2) group selection and individual tree selection prescriptions on the landbase available for such activity, (3) a program of riparian management including wide protection zones and riparian restoration projects, (4) reports to Congress, which implies the need for much improved implementation and effectiveness monitoring by the Forest Service and other parties, and (5) reference to a landbase map that protects large roadless and sensitive areas as well as previously designated wilderness areas. The pilot project will take place on the Lassen and Plumas National Forests and the Sierraville Ranger District of the Tahoe NF (the "QLG area").

To our knowledge there are no bighorn sheep in the QLG area, and our urban interfaces are generally not so extensive or dangerous as on the mid-Sierran national forests, but every other issue that was (or should have been) included in the SNSR is also present in the QLG area. Many of the major issues -- e.g., old-growth forest, spotted owl, aquatic and riparian resources, and fire and fuels issues-- have been addressed in an integrated, interdisciplinary manner that also encourages scientifically valid adaptive management. Because of the extensive contributions from the scienfific community to the substance of our solutions, we believe the QLG proposal represents one locally appropriate resolution of the high priority conservation issues. Thus, it is our belief that implementation of the QLG bill can serve not only as the pilot project originally envisioned by QLG and the Congress, but also as a full-scale demonstration of SNCF implementation. Even if the legislation fails to pass in this session fo Congreess, we would request that the Quincy Library Gropup forest management proposal be analyzed as an alternative in the SNCF EIS.

Therefore, to answer Task 3's second "pre-NEPA" question first, the changes that QLG would suggest for management direction on the Sierra Nevada national forests include the following for the Lassen, Plumas, and Tahoe National Forests:

(1) the timber management and vegetation management programs should be focused on a strategically planned and implemented program of landscape-scale forest fuel reductions, conducted at a pace and pattern appropriate to the problem;

(2) a program of group and single tree selection management designed to produce habitat conditions ranging from early seral to those associated with 200 year old stands;

(3) short-term reallocation of the landbase maps to protect large roadless and sensitive areas as well as previously designated wilderness areas, and to focus management actions on restoring healthy forest conditions to lands already roaded and logged;

(4) a program of riparian resource management that includes wide protection zones, riparian restoration projects, and that restores hydrological and ecological functions; and

(5) monitoring and evaluation programs sufficient to be scientifically sound and to enable the Forest Service to engage in adaptive management in the truest sense of the term.

Thos familiar with the QLG Proposal of 1993 will recognize these as generalized descriptions of the QLG elements. How those elements would be applied to the local national forests' lands is laid out in both the QLG Cal Owl DEIS comments and also the QLG legislation.

Issues in the SNCF that are directly addressed by the QLG pilot project.

Cultural, Demographic, and Socioeconomic Changes. The SNCF must assess the current socioeconomic, cultural, and demographic situation of each affected area, and state how these would change as a result of the land management actions proposed for that area.

A major change in the culture of forest-related communities has been the recognition that hostile confrontation is a lose-lose game. The Quincy Library Group has demonstrated more than five years of progress toward establishing a win-win game. This foundation of community-based, consensus-driven, cooperative effort to address forest health and community stability issues is an asset that the SNCF should utilize and build upon. QLG has focused on local manifestations of the major issues identified in the Sierra Nevada Science review. However, the original Quincy Library Group Community Stability Proposal of 1993 was intended to suggest short-term measures that would address the most immediate threats while long-term solutions to a wide range of forest health issues were being developed and implemented. Therefore, full participation in the SNCF effort to address forest health and community stability issues in a more comprehensive framework is fully consistent with QLG‚s long term goals.

One aspect of the SNSR's review of demographic and socio-economic information was problematic to our reviewers was its seemingly monolithic view of the timber industry and of timber-related businesses. Some dramatic shifts in logging and milling technologies have occurred over the last decade within the northern Sierra, and these changes have altered what is marketable via Forest Service timber sales. Two major mills in the QLG area have retooled or added new equipment to utilize trees less than half the size that was considered merchanable when the original Forest Plans were adopted. The use of feller bunchers, cut-to-length, and chippers in logging operations has altered the type and amount of environmetnal impacts resulting.

While some of these industrial changes are occurring elsewhere in the Sierra, they do not appear to be happening to the same extent as in the northern Sierra. For example, the Lassen National Forest FY95 and FY96 timber sales programs were more than half biomass by volume, while the Sequoia's sales during those years were less than 5% biomass. If new regional direction wre to emphasize forest thinnings "from below" and fuel removals, the northern Sierra Nevada's communities would contain the workforce and the industrial infrastructure necessary to implament such direction; but it is doubtful that the southern Sierra Nevada would have similar capacity. it isn't clear from the SNSR or from prior EISs that the Forest Service recognizes these differences and how they affect the overall socia-economic qualities of different places within the Sierra Nevada.

Fire and Fuels. QLG believes that large high-intensity wildfire is the symptom, but fuel is the fundamental problem, and failure to address the fuels problem at adequate scale and pace would eventually doom all other attempts to restore forest health and community stability. There is no sane choice except to reduce the huge overload of fuel that our forests now contain. The pressing questions are How much? How fast? What methods? and How do we pay for it? The Sierra Nevada Science Review‚s summary statements on science and current management direction refer only to fire, fire management direction, and fire suppression. This omission of fuel in the summary, and the general short-changing of fuel management in the full SNSR and SNCF documents, is an all-too-typical indication of Forest Service attitudes and practices that must be drastically changed, not reinforced. The fuels problem requires an urgent and fully integrated response from the entire Forest Service, including particularly the timber management organization, not just from fire management and other resource specialists.

In addition to lengthy chapters in both the SNEP Report and the CASPO Technical Assessment that address fire and fuels management considerations for Sierran mixed conifer forests, there is a large and growing body of literature on silvicultural thinnings and their effects on forest fire behaviors and intensities, long-term site productivity, etc. One good overview now being finalized is contained in Part I of "Biomass Technologies to Address Forest Health Concerns in the West" by R. Neil Sampson and Megan S. Smith, as well as others listed in the attachment at the end of this letter.

Regarding size, pace, methods, and finance of fuel reduction, QLG believes: (1) It is necessary in the long run to reduce fuel over the whole forest that is available for vegetation management, for direct protection of life and property, and to provide the best possible indirect protection of wilderness and other reserved or special management areas by establishing fuel regimes in the surrounding landscape that would greatly reduce the probability of fire moving into or out of those areas; (2) The pace of fuel reduction should be such as to permit a complete cycle through the treated land in no more than 30 years; (3) All methods should be considered, and the method for each project should be chosen for its ability to achieve the strategic goals of size, pace, effectiveness, and financial capability; and (4) Financial capability is unlikely to be adequate unless every possible opportunity for cost-effective procedures and commercial use of the removed material is taken advantage of.

The strategy that QLG recommends to meet all four of these requirements is an initial period (5 years) of fuel reduction in a network of wide fuelbreaks, followed by a transition to area-wide treatments. Fuel treatments should combine reduction of ground fuel and fire ladders, as well as thinning of canopy trees where needed, in order to limit the ability of the resultant fuel regime to carry crown fire or high intensity ground-based fire. Each fuelbreak should contain a road (an existing road wherever possible), in order to provide for rapid access and safe retreat. In most places in the QLG area we believe that thinning the canopy to an appropriate closure and crown bulk density will necessitate the removal of sufficient mid-size trees to support viable timber and multi-product sales that can largely or completely support the accompanying reduction of smaller fuel components. Appropriate limits on the maximum diameter of trees that can be removed during thinning or timber harvest should be established in the SNCF EIS.

Prescribed fire. The QLG emphasis on fuel reduction by mechanical methods has sometimes been interpreted as opposition to the use of prescribed fire. That is not the case. QLG favors the use of any and all appropriate methods for establishing and maintaining desired fuel regimes throughout the forest. However, in terms of the four strategic considerations listed above, QLG believes that the use of prescribed fire just for routine fuel reduction will increasingly be seen as inappropriate in all but a few exceptional cases. On one hand there are short burn windows, declining fire management resources, increasing risks, and particularly air pollution concerns among our smoke-sensitive and senior citizens. On the other hand there are needs for periodic burning to achieve goals other than fuel reduction, such as pathogen control and seed germination, which probably can‚t be provided by any means other than management-ignited prescribed fire or wildfire of acceptable intensity. In other words, prescribed fire has become and will continue to be a very valuable resource in limited supply. Therefore priority must be given to using it for essential purposes that cannot be achieved by other methods, and this clearly means its use for fuel reduction will more likely decline than increase. Given that prescribed fire is already short of meeting the total need for fuel reduction by a factor of 6 to 10, depending on which expert you consult, it is appropriate that fuel reduction strategies should emphasize mechanical removal of excess fuel, not depend on prescribed fire.

Old-Forest Ecosystems - Forest Conditions of Structurally Complex Forest Types. This issue has recently been discussed in terms of Late Successional / Old Growth (LSOG) ranking, and attempts have been made to map such areas and define Areas of Late Successional Emphasis (ALSEs) that should be managed primarily to preserve and expand forest structure of high ranked LSOG. In the QLG area about 11 percent of the mapped high ranked (LSOG 4 and 5) areas are already protected in designated wilderness reserves. The QLG landbase designations that are integral parts of the QLG bill and pilot project would bring this total up to about 50 percent of high ranked LSOG that would be directly protected in wilderness and in areas defined as off-base or deferred from road building and timber management. However, existing definitions of LSOG do not readily translate into management prescriptions, and the Sierra Nevada Ecosystem Project (SNEP) reports based on LSOG mapping give clear warnings not to use those maps at the scale of individual projects, because they are not sufficiently accurate or reliable. There is a great need for clear definition of the "old growth" forest type, and to ground truth the mapping of that type.

The QLG believes it is not sufficient just to protect old growth wherever its remnants can be found. It is necessary also to provide for long-term renewal of structurally complex forest types, which must include significant components of high ranking LSOG. Of the possible silvicultural practices that might generate and sustain this long-term renewal, QLG believes that group selection in combination with individual tree selection is the method most likely to be successful. These and other methods are starting to appear in the scientific literature as "restoration forestry." The SNSR didn't seem to scratch the surface of recent publicaitons which bring together ecological, conservatioin biology, fire science, and silvicultural issues. Unfortunately, silviculture does not appear as a significant issue in either the SNSR or the SNCF to date. QLG intends to make sure that long-term silvicultural practice is a major issue to be dealt with in both the SNCF EIS and the QLG Pilot Project EIS. It is second only to fuels as an issue requiring urgent attention, because success in addressing most other forest health and wildlife issues depends in large part on restoring, establishing, and sustaining a mosaic of stands with appropriate spatial, size class, and species distributions.

Old-Forest Ecosystems - California Spotted Owls. Attempting to deal with spotted owls as a separate issue has demonstrably failed. Current population studies, to the extent they exist at all, are either inconclusive or show reproduction rates not sufficient to sustain long-term populations in either managed or reserve areas. Success in dealing with the owl issue has correctly been said to depend largely on reducing the probability of high intensity wildfire and increasing the amount of habitat. While looking forward primarily to resolution of the fuels and silvicultural issues as the necessary long-term solution for owls (and other wildlife mentioned in the SNSR and SNCF), QLG supports (and the QLG bill requires) continued protection of the Protected Activity Centers (PACs) and Spotted Owl Habitat Areas (SOHAs), according to the original concepts in The California Spotted Owl: A Technical Assessment of its Current Status (the CASPO report) and the California Spotted Owl Sierran Province Interim Guidelines Environmental Assessment (the interim guidelines).

Old-Forest Ecosystems - Forest Carnivores. As noted above, the issue is primarily habitat, with a special requirement for large, relatively well connected areas of high ranking LSOG. QLG believes these requirements are best met with the combination of landbase usage, fire protection through fuel reduction, and silvicultural methods specified in the QLG bill.

Aquatic, Riparian, and Meadow Ecosystems - Frogs and Toads. As noted earlier, the QLG bill requires a program of riparian management. This is expected to be an extension of the riparian restoration program already being conducted in much of the QLG area under the direction of the Feather River Coordinated Resource Management Group (the CRM) which is managed by Plumas Corp and is participated in by PG&E, other local and regional private and government entities, as well as the U.S. Forest Service. As noted in the SNSR, the decline of frog and toad populations is not well understood, but it seems certain that both fish stocking programs and habitat degradation play major roles. If the science team did not already consider "An Evaluation of Habitat Management Practices for the California Red Legged Frog" by Catherine Peterson, 1997, that paper should be reviewed. As with owls and carnivores, habitat improvement is probably our best chance for reversing the adverse population trends among frogs and toads, and the QLG bill provides not only direct enhancement of aquatic habitat, but improved fire protection and silvicultural management of the upland watersheds that have great impact on the quality of riparian habitat.

Aquatic, Riparian, and Meadow Ecosystems - Willow Flycatcher. Our comments regarding frogs and toads would apply here as well. In addition, we would call attention to the SNCF finding that current management direction is being developed on a project by project basis. QLG believes that these issues are closely interwoven at landscape scale, and therefore that "project by project" attempts to deal with a declining wildlife population are doomed to eventual failure. Habitat restoration work must be done according to a strategic plan that operates at ecosystem scale and adequate pace, not just project by project.

Lower Westside Conifer/Hardwood Zone. Compared with the mid and high elevation mixed conifer and pine zones, the lower westside conifer and hardwood zone is a relatively small part of the QLG area. Specific direction for each forest type, to be developed in the pilot project EIS, is expected to implement the general requirement to establish defensible fuel breaks, initiate group and individual tree selection, and conduct riparian restoration projects.

Roads. The landbase usage specified in the QLG bill would put most roadless areas in the QLG area either off-base of deferred from road building. The "available" landbase in the QLG area is already adequately roaded to support the fuelbreak network and silvicultural management specified in the QLG bill, and improved maintenance and repair of existing roads is the main problem to address. Since implementation of group selection is expected to be occur in relatively long cutting cycles (say 15 to 20 years between entries to any given area of several thousand acres) any new access requirements are expected to be met with temporary roads and skid trails that would be closed between management entries. This provides for a more strategic view of road usage, with short term needs for opening roads largely avoided.

Priority Considerations for Implementation.

Adaptive Management and Monitoring. The SNSR clearly and appropriately identifies monitoring as a very weak link in the Forest Service adaptive management loop. While QLG agrees with that observation, unfortunately there is another link that is equally weak. The adaptive management loop isn‚t just planning, monitoring, and feedback, it must include implementation as an essential link. The SNCF gives no attention to the issue of implementation at ecosystem scale. Without at least one example of implementing the plan and monitoring its effects at ecosystem scale, we will have neither a true adaptive management loop nor a valid monitoring program. As noted in our earlier comment, for several reasons the QLG area and the QLG pilot project would provide the most efficient demonstration of SNCF implementation at ecosystem scale. Not only does the QLG bill require progress reports (implementation monitoring) and a science-based assessment at the end of the project (effectiveness monitoring), the development of a comprehensive monitoring plan has already been developed in the QLG area with "Forest Health Pilot" funding secured in previous years by QLG.

Effects of California Spotted Owl (CASPO) Interim Management. As noted earlier and reinforced by the SNSR summary on this issue, attempting to deal with the spotted owls as a separate issue has demonstrably failed. While no formal studies address the problem, QLG believes the best chance for owls is to maintain the PACs and SOHAs in the QLG area while implementing the fuels, silviculture, and riparian management practices specified in the QLG bill.

For a variety of reasons we believe that it is pretty much impossible to determine the effects of CASPO interim management per se. All of the national forests in the Sierra Nevada were slow to develop and offer CASPO-prescription sales, with the Stanislaus releasing its first CASPO sale in September 1996, 3-1/2 years after the interim guidelines went into effect. Timber management activities during the CASPO interim period have concentrated more on salvage, hazard tree removal, and in northeastern California on eastside pine (i.e., outside of spotted owl range) timber sales.

For those timber removals within the range of the California spotted owl and implementing the CASPO guidelines, it is impossible to determine effects on owls because there has been virtually no post-project monitoring. Furthermore, so much no-CASPO management was also occurring that no conclusions can reasonably be drawn about environemtnal impacts of CASO interim management.

Reinvestment and Funding for Ecosystem Management. This is a major concern of QLG, because the best plan in the world is useless if you can't finance its implementation. To whatever extent that the gvegetation management part of ecosystem management must rely upon market mechanisms (including private sector), the Forest Service should consider market requirements and capacities.

QLG has addressed the issue of reinvestment, market adjustments, and agency funding very energetically and directly. very energetically and directly. In part because of QLG support for fuel reduction and fuelbreak construction, there are now several sawmills in the QLG area that can efficiently make lumber from logs too small to be considered merchantable by conventional standards, and QLG membership includes strong participation by several industrial users of wood chips for power generation. Compared with all other national forests in California, national forests in the QLG area already yield a higher percentage of their harvest in utilized biomass (please see Attachment 2).

As part of an intense effort to increase the removal of hazardous biomass through commercial sales, QLG has cosponsored a study of the feasibility of manufacturing ethanol from wood chips in the QLG area. Two pilot plants are currently being considered, one of which has received a Strategic Energy research grant in support of its ethanol project from the California Energy Commission. But perhaps the most important potential for reinvestment is the water yield from the Feather River drainage, which dominates the QLG area.

In Attachment 3 we list several reports and publicatinos which we recommend for your consideration in an analysis of funding sources for ecosystem management.

Issues of concern to QLG that are not addressed adequately in the SNSR or SNCF.

Water. As the SNSR says, the yield of highest monetary value coming off these forests is water. In contrast, we note the absence of "water" as a major issue of concern in the SNSR and SNCF lists. It is not adequate to consider water just for its effect on vegetation and wildlife in the forests. In our area (and we believe in several other Sierra Nevada national forests) there is an urgent need to consider management effects on the quality, quantity, and timing of water runoff. QLG is an active participant, along with northern California counties and other local agencies, in promoting the concept that water users have an identifiable and quantifiable interest in maintaining the health of their upland watersheds.

During the SNCF process the Forest Service should give very high priority to analyzing the economic value of water as a potential source of re-investment in the health of upland watersheds and riparian areas. Historically the Forest Service has not exercised its full power to influence that reinvestment, but, given the situation outlined in the "Reinvestment and Funding" section of the SNSR, it is necessary to reconsider that history and develop a more productive plan for Forest Service participation in water supply issues, and to take a more active role in seeking reinvestment through the FERC and CAL-FED processes.

Forest Health. The national forests of the northern Sierra Nevada have experience two "salvage emergencies" delcared by Congress in the 1990s. These wre years when the factors of drought, bark beetle outbreaks, stand stocking levels and species compositions all combined to prduce extensive tree mortality. The situations were so dire that normal porcedures and planning requirements wee suspended, including citizen appeals (twice) and lawsuits (once).

How can it be that forest health is not now considered a high priority issue? While substantial thinning and fuel reduction work has occurred in the last few years within the QLG area, there are numrous areas yet to be treated. And as mentinoed above, the QLG-area forests are far ahead of other Sierran forests in the amuont of thinnings and biomass treatments being performed. Forest inventories, fuels assessments, pest and pathogen assessments, and the USFS/FRAP change detection study of the Sierra Nevada should be included in geopgrahically coded data bases for assessing and planning actions to prevent future fores health emergencies.

Issues involving the SNCF process.

Desired Future Condition. A vital issue that should have been addressed at the very beginning of the "pre-NEPA" process is to define Desired Future Conditions, because those definitions must underlie all other discussions of management direction.

Need to refer to management action, not just direction. The SNCF has been based on a comparison of the "Science Review" with a "Summary of Existing Management Direction." In QLG‚s view this is not the comparison of most importance. An evaluation of where we are, as a basis for deciding where we should consider going, should be based on existing management actions, not just on existing management direction. Don‚t just tell us what you promised to do, tell us what you‚ve actually done. To stop short of that is about the same as to claim that monitoring and evaluating forest management can be done in the office looking at plans instead of in the forest looking at trees.

Forest Plan review and revision. Another issue that will become more important as the SNCF process unfolds is to define and explain exactly how this regional amending of the individual Forest Land and Resource Management Plans (LRMPs) will affect and be affected by the general statutory requirement for periodic review and revision or amendment of those LRMPs. Are these amendments intended to fulfill those requirements? If not, what is the schedule for making those other revisions and amendments?

Sincerely, etc.

Sunday, January ,(, /),( 0(:,(:,( AM