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.
Sincerely,
/s/
Neil G. Dion