THE WILDERNESS SOCIETY

SIERRA CLUB

NATURAL RESOURCES DEFENSE COUNCIL

March 31, 1994

Quincy Library Group
c/o Michael Jackson
P.O. Drawer 207
Quincy, CA 95971

Dear Mike Jackson and the Quincy Library Group:

   We are writing regarding the proposal put forward by the Quincy Library Group (QLG) for management of the Lassen National Forest, Plumas National Forest, and the Sierraville District on the Tahoe National Forest in the northern Sierra Nevada. We understand that the QLG is a continuing discussion among some timber industry officials, community members, county government officials, and some local environmental activists in an attempt to address forest management issues in the region. According to various reports, the details of the proposal may have changed since this summer.

   In general, we support collaborative approaches to addressing forest management problems and would like to support such an approach in the northern Sierra Nevada. However, we have concerns about the QLG process as described in your written material and substantial questions remain unanswered regarding the specifics of the proposal. Until such questions are answered, it is difficult to assess the merits and impacts of the proposal. In this letter we outline some of these questions, and request that you respond in writing to them. This information will be helpful to us in developing a position on the proposal.

1) The QLG propsal intends to be "consistent with all existing laws." Does this include the National Environmental Policy Act (NEPA), the National Forest Management Act (NFMA), and the recent Region 5 policy for the California spotted owl (CASPO)?

• Would the OLG proposal be reviewed and considered within the owl EIS process, or does the QLG envision an alternate means outside of NEPA to achieve their management and funding objectives? Would all activities undertaken as part of the QLG proposal be subject to public review as provided in NEPA?

• Does the proposal seek to comply with environmental protections provided by the Regional Forester's interim decision relating to the California spotted owl (CASPO), or does it seek to suspend some of the more restrictive provisions in the interim policy, including the prohibition on logging big trees? During the time period when an EIS is being prepared on the California spotted owl in Region 5, does the QLG seek to replace the existing CASPO policy with another policy altogether?

• Would management under the OLG proposal meet the species viability requirements in NFMA? If so, how does the proposal demonstrate that its suggested landbase and silvicultural practices are likely to meet these viability objectives?

2) According to the written materials, The Quincy Library Group strategy is intended to apply to "the broadest landscape possible" and proposes to "expand the existing landbase available for timber production beyond that currently 'zoned' for timber production but that environmental effects upon this expanded landbase will be greatly reduced."

• What areas currently outside of the landbase would be included for logging? Why are these areas presently outside of the landbase? What would be the impacts of opening these areas to uneven-aged logging? What is the total acreage logged and timber volume produced under the OLG proposal?

• Does the administrative study provision in the Region 5 interim policy provide an adequate landbase to achieve the OLG goals in the interim? If not, why not?

• What is the basis for the QLG conclusion that environmental impacts would be greatly reduced as a result of expanding the landbase for timber production? Does the QLG believe that such a landbase expansion be implemented without an assessment of impacts in an EIS process?

3) The QLG has asked for Forest Service appropriations "to meet the immediate needs of the OLG proposal."

• What, specifically, are these needs? Can they be met through the existing Forest Service budget and land management process? If not, why not?

4) The QLG concludes that "stewardship contracts should be expanded, and a sustained yield' unit as authorized by Congress must be established."

Given these significant questions, it is impossible for us to adequately evaluate the QLG proposal at this time. We look forward to your response and hope that we will be able to extend support to our efforts.

Sincerely,

cc Jack Ward Thomas
  Ronald Stewart

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