Neil G. Dion
Blairsden, CA 96103 -9741

July 16, 1993

Mike De Lasaux
U.C. Cooperative Extension
208 Fairgrounds Road
Quincy, CA 95971

Re: “Quincy Library Group -- Community Stability Proposal"

Dear Mr. De Lasaux.

     On July 10, 1993 I attended the Quincy town meeting which was convened in order to explain and discuss the "Quincy Library Group" (QLG) proposal to establish new rules and regulations governing forest management on the Plumas and Lassen national forests and the Sierraville District of the Tahoe National Forest. As a member of Friends of Plumas Wilderness I entered that meeting opposed to the proposal as I understood it and find myself now even more adamantly opposed to it.
     The reason the QLG gives for this proposal is at once nebulous and disingenuous. Their recent summary of the proposal states, for example, that "A common belief of the participants is that present USFS management is inadequate to meet the objectives of any of the participants." While this statement may accurately represent the general opinions of some disparate factions within the Northern Sierra community, it does not speak for all interested and effected parties. Moreover, it evades the true, underlying specific statement which is, "A common belief of the participants is that current USFS management incorporating CASPO Report recommendations and guidelines is not beneficial to the short-term economic well-being of the timber industry and timber workers."
     The proposal is, in essence, a forest management outline designed to circumvent the recommendations of some of the most substantive aspects of the California Spotted Owl (CASPO) Report and to ignore great portions of the science contained therein. More specifically, the proposal ignores the following substantive CASPO recommendations:

* retention of trees 30 inches diameter at breast height (d.b.h.) or greater on all areas of the forest not otherwise protected
* minimum basal area retention on "Selected" and "Other" timber strata
* 40 percent or greater canopy cover in Selected Timber Strata
* snags and downed woody material retention on Selected and other timber strata
* limitations on the number of entries into non-protected, commercial logging areas prior to implementation of a long-term strategy for managing the California Spotted Owl

     In my opinion it is entirely inappropriate for any Sierran forest management proposal to actively ignore major portions of the CASPO Report and its far-reaching and relatively comprehensive science. While the QLG does promote CASPO-recommended fire an fuels management and protected activity center (PAC) sites, virtually every other recommendation contained in the CASPO Report is ignored. My initial primary concerns relative to the QLG proposal are outlined below.

     1.) The QLG proposal would, in general, continue the inappropriate management of Sierran national forests that has resulted in the environmentally fractured landscape we see today. Except for in PACs and other protected areas, the QLG proposal would allow small clear-cuts ("group selection") in hopes of mimicking natural forest processes, and "pick and pluck" (select cutting) which would remove exactly those trees CASPO recommends saving. The net result would be that the vast the majority of the forest landscape would be available for timber cutting based on a 200-year rotation. (Some sites would be on less than a 200-year rotation.) Moreover, a substantial number of PACs would become islands in a large, young “forest."

     The QLG proposal states that "all CASPO identified PACs will be deferred from logging during the life of this interim management plan," yet it fails to recognize that PACs are merely one management tool of many which CASPO recommends. Ignoring the other far-reaching recommendations defined in Chapter 5 of the CASPO Report and as defined under "Other Forested Public Lands" (pages 21-25, CASPO Report) is shortsighted at best. Furthermore, the QLG proposal would provide for no replacement stands for the PACs outside protected areas and would severely limit or destroy large areas of suitable foraging habitat for the spotted owl.
     The QLG proposal, in effect, "picks and plucks" CASPO recommendations to suit the political and economic goals of its authors and fails to take a comprehensive, scientifically up-to-date- view of forest management.

     2.) It is incomprehensible that anyone seriously interested in the preservation and continuance of a diversified and healthy Sierra-wide ecosystem would agree to abandon primary, substantive directives of CASPO the way the QLG proposal does. The directives contained in the CASPO Report are designed so as to provide a scientific basis for observation, study and analysis of the viability of the spotted owl, which is merely an indicator species. CASPO also, therefore, provides for de facto observation, study and analysis of what is or is not a healthy, bio-diverse forest environment. Without following CASPO directives, no scientific analysis can provide accurate results. For example, CASPO scientists have provided the Forest Service with what they deem to be the minimum environment for a successful evaluation of owl viability over time. Taking away any of the primary requirements, e.g. trees 30 inches in diameter or greater, would result in highly unreliable analyses.
     Moreover, CASPO recommendations are expertly designed to prevent the spotted owl, or other sensitive species, from being listed as threatened or endangered. Any large-scale plan to circumvent its recommendations, therefore, may well have disastrous effects.
     To go forward with the Library Group proposal would be to establish large-scale forest management based on poor, unsubstantiated and untested science. Such experimentation should take place on the smallest scale possible, not on a scale equivalent to more than 38 percent of the land area of all Sierran National Forests. Moreover, both the greatest concentration of Sierran California Spotted Owls and the location where the California and Northern spotted owls meet are in the proposed area.

     3.) While the Library Group proposal may be beneficial to short-term community and timber industry financial stability, it will result in a further degraded forest landscape with less bio-diversity and less viable populations of sensitive species.

     During the five-year period of the QLG plan, all areas on the timber base could be susceptible to old-growth liquidation. The question, then, is what will be the result if further -scientific studies reveals current CASPO recommendations to be appropriate and for all California forests? The result will be that on the Plumas, Lassen and Sierraville Ranger District of the Tahoe, significant portions of what would otherwise be suitable and desirable forest habitat according to CASPO will have been destroyed. Indeed, CASPO itself states, "Management of the (Sierra) forests during this interim should not foreclose options for whatever long-term management scenario, may be adopted for the owl at the end of the interim period." (page 5)
     At the end of the QLG-proposed five-year experiment period, the communities and companies which this plan hopes to protect may well be back to square one in terms of economic stability, but with less viable populations of sensitive species. A worst-case scenario, is that due to the QLG proposal to continue large-scale application of poor and inadequate forest management, some sensitive species may become threatened or endangered thereby further negatively impacting community stability.

     The only appropriate course of action for any Sierran national forest to take is to follow the recommendations of the CASPO Report. The only prudent course of action Sierran communities should take is to proactively seek out Federal funds to help our communities to adapt to societies changing environmental sensibilities. That is to say, rather than focus on how to maintain the status quo as the QLG plan essentially does, let us work to obtain the necessary funds to restore and protect our forests in all their bio-diversity, to provide jobs and training to any and all displaced workers so they can obtain Employment and enjoy prosperous lives, and to provide for truly sustainable timber cutting.
     Putting off the inevitable by employing poor forest management is not the way to a more secure future, either for the forest environment or for our communities. It is ironic indeed, that just now when we have the tools to rectify historically inadequate forest management techniques it is being proposed that we abandon those tools in order to obtain short-term and likely short-lived economic "stability."
     I urge everyone to take a very close look at the QLG proposal and compare its management direction with the management direction of the CASPO Report. For the long-term prosperity of our communities and the health of our forests, I know you will find that CASPO recommendations represent the best science and best direction for forest management.

     This letter is being distributed to some members of Friends of Plumas Wilderness, some members of the Quincy Liibrary Group, U.S. Forest Service local and regional officials, technical coordinators of the California Spotted Owl Report, the national Resources, Defense Council, the Wilderness Society, Friends of the River, county supervisors and other interested parties.
     Please note that this document is an initial response to the QLG proposal and as such is not exhaustive in scope or content. I intend to keep a keen eye on developments relative to the QLG proposal and will do my utmost to ensure that all substantive CASPO recommendations are adhered to.



Neil G. Dion