CONCERNS AND RESPONSES ABOUT THE QUINCY LIBRARY GROUP BILL

There were a number of "concerns" cited by the critics of the QLG bill. The reponse as it relates to each of the more common concerns are presented below.

Response to "Sound Bite" Concerns

SUMMARY OF COMMON CONCERNS

CONCERN #1: The Quincy Library Group bill doesn't protect over 200,000 acres of old-growth. RESPONSE

CONCERN #2:The QLG Bill will double or even triple logging on 2.5 million acres of National Forest! RESPONSE

CONCERN #3: The 40,000 to 60,000 acres of treatment will be in quarter mile wide clearcuts. RESPONSE

CONCERN #4:  The Lassen, Plumas and Tahoe forests already have the highest cuts in California and under this legislation the cut would increase by 50-100 MMBF! RESPONSE

CONCERN#5:  The Bill will "Override all environmental law such as National Forest Management Act, National Environmental Policy Act, and Endangered Species Act."RESPONSE

CONCERN #6:  Because of the large amount of road building necessary to implement the QLG program, FS specialists predict a significant increase in erosion and sedimentation. The increased sediment will result in additional costs to Pacific Gas and Electric which currently spends about 3 million per year dredging the reservoirs that catch that sediment. These costs will be passed on to rate payers. RESPONSE

CONCERN #7:  The Bill temporarily protects roadless areas on Plumas National Forest, however, on the Lassen National Forest there are a number of roadless areas that would be logged under S. 1028 and a large amount of rare Sierra Nevada Mixed Conifer Old-Growth would also be at risk. RESPONSE

CONCERN #8:  It is highly questionable whether the "fuelbreaks built under timber sales" proposed by the QLG and mandated by the Bill will work. The plan is to reduce forest canopy closure to 30-40 percent. This will let lots of light into the stands, stimulating the growth of brush and small trees. This will probably increase rather than decrease fire risk. Up to 60,000 acres of such fuelbreaks are mandated by the Bill each year. Most seasoned firefighters hate fuelbreaks because they almost never work, are poorly maintained and therefore typically increase fire intensity. RESPONSE

CONCERN #9:  The Pilot Project will "Increase the fire risk." RESPONSE

CONCERN #10:  The Forest Service says it will take an additional $83 million to implement the "pilot project".  Where will the money be found?  Unless there is a specific appropriation this increase in logging will require diverting funding from other forests-most likely other California National Forests. RESPONSE

CONCERN #11:  The Quincy Library Group "is an industry-picked group of 13 people who were granted $4.1 million by the Federal Government." RESPONSE

CONCERN #12:  The Quincy Library Group legislation undermines the National Environmental Policy Act and the National Forest Management Act. RESPONSE

CONCERN #1: The Quincy Library Group bill doesn't protect over 200,000 acres of old-growth.

RESPONSE: This is a concern expressed by Senator Boxer who in a letter to the Editor of the San Francisco Bay Guardian said "I am particularly disturbed that the bill does not include specific language to protect the most sensitive old-growth areas identified by the Sierra Nevada Ecosystem Report." This is also a "talking point" of the Sierra Nevada Forest proctection Campaign which states that the Quincy Library Group bill will "potentially impact 217,000 acres of late successional and old growth forests."

In fact, the Quincy Library Group bill protects most of the Rank 4 and 5 late-sucessional old-growth polygons identified by the Sierra Nevada Ecosystem Project (SNEP). The SNEP classified 164,910 acres of as providing high to very high contribution to late-successional forest function. The QLG bill results in protection of all but 11% of these polygons.

Additional analysis

More observations

CONCERN #2: The QLG Bill will double or even triple logging on 2.5 million acres of National Forest!

RESPONSE:  A letter from Forest Service Deputy Chief Ronald Stewart to Senator Feinstein refutes this CONCERN. The Bill directs that 40,000 to 60,000 acres of defensible fuel profile zones (DFPZ) be created annually and that 0.57% (approximately 9,300 acres) of the group selection harvesting occur. The 3 forests involved are presently (Fiscal Year 1997) treating approximately 63,000 acres this fiscal year. The Plumas National Forest and Lassen National Forest plan of work for 1997 (Plan of Work for FY 97) provides for just over 21,000 acres of vegetation treatment on each forest. The estimated harvest associated with these treatments and the Sierraville Ranger District's is 191 MBF. Given that the proposed treatment acreage is approximately the same, two questions should be asked. First, why is the Bill necessary and second, if the acreage isn't that much greater, how could the cut double?

  The Bill is necessary to implement the DFPZ strategy at the appropriate pace and scale. The distribution of treatments on the Plumas and Lassen National Forests shows that the emphasis was on Fuel Reduction Zones (FRZ) at almost 17,000 (40%) during fiscal year 1997. Because several projects were presented as combination DFPZ and FRZ it is not possible to calculate the actual distribution of acres among treatment types.

  The QLG preference is to place the highest priority on DFPZs until the network is in place.  The FRZ treatments are important but, they don't contribute to the initial high priority of the fuelbreak strategy.

 Summary of Fiscal Year 1997
Treatments on the Plumas and Lassen N.F.

  One has to ask the obvious questions. Double the cut from what and when? What is the baseline used to make this claim? The source of the information is not provided by the critics. Factual information on timber harvest on the three forests is provided below with sources.

^1/  The information presented is for the entire Tahoe National Forest. The QLG area encompasses only the Sierraville
     Ranger District of the Tahoe NF, in addition to the Lassen and Plumas National Forests.
^2/  The respective Land and Resource Management Plans as summarized in "The California Spotted Owl: A
     Technical Assessment of Its Current Status. Page 265.
^3/  The California Spotted Owl Sierran Province Interim Guidelines Environmental Assessment, 1993,
     Chapter IV page 33.
^4/  Draft Environmental Impact Statement: Managing California Spotted Owl Habitat in the Sierra Nevada National
     Forests of California- A Ecosystem Approach. January 1995. Table 3.K.3, page 3-186.
^5/  The California Spotted Owl Revised Draft Environmental Impact Statement, August 1996 pg. 3-182.
^6/ Annual net Growth information is from the repective Land and Resource Management Plans.

Figure 1. Sales offered on the 3 forests took a sharp downturn beginning in 1991. The upward shift on the Tahoe National Forest in 1995 is attributable to the 44,000 acre Cottonwood fire salvage sale.

Figure 2. Actual sales for the 3 forest area began a steady decline in 1988 with a sharp downturn in 1991. The Plumas National Forest sales sold dropped significantly in both 1991 and 1992, then partially recovered in 1993 and declined again in 1994 and 1995. The upward shift on the Tahoe National Forest in 1995 is attributable to the 44,000 acre Cottonwood fire salvage sale.

Figure 3. Harvesting began a steady decline in 1988 for the three forest area. The Plumas National Forest sales sold dropped significantly in both 1991 and 1992, then partially recovered in 1993 and declined again in 1994 and 1995. The upward shift on the Tahoe National Forest in 1995 is attributable to the 44,000 acre Cottonwood fire salvage sale. Harvests have stabilized at roughly 33% of the 1987-88 levels for 1993-95. 

  The Quincy Library Group has preferred not to discuss annual volume harvested nor volume based targets. Instead they have preferred to focus on acres treated and have used the "Ballpark Objectives" as a rough guide to the level of activity necessary to address the accumulation of fuels.

  It appears that the claim that the QLG Bill will double that amount of logging is based on the modeling of Alternative "F" in the California Spotted Owl Environmental Impact Statement process. The Draft Environmental Impact Statement (DEIS) estimated that the allowable sale quantity for the Lassen, Plumas and Tahoe NF's would be 167 and the Revised DEIS estimated an allowable sale quantity of 379 million board feet. The RDEIS estimate is 75 percent of the Land and Resource Management Plan allowable sale quantity.

  The Revised Draft Environmental Impact Statement included the following statement about the modeling effort: "The QLG proposal, as originally presented, resulted in an infeasible solution when tested in the SPECTRUM linear program. In other words, the program was unable to solve for all the parameters simultaneously. Several parameters were modified until the program produced a feasible solution. The modified parameters were applied to the lands covered by the QLG proposal. The EIS team believes that modified proposal retains the fundamental concepts presented in the original proposal."

  Another source of information on the potential for increased harvest is the Congressional Budget Office cost estimate developed for H.R. 858. The CBO estimated volume harvest is approximately 62 million board feet per year which represents an increase of only about 33 percent over the 1995 harvest volume.

  A further consideration is that recent harvest levels have no basis in growth or sustainable harvesting. Since 1991 the harvest levels have been constrained by budgets.

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CONCERN #3: The 40,000 to 60,000 acres of treatment will be in quarter mile wide clearcuts.

RESPONSE:  There is no clearcutting associated with the bill. The bill does provide for single tree selection and group selection harvesting along with the thinning from below associated with the Defensible Fuel Profile Zone network. Group selection has been characterized by some as clear cuts, however group size is only large enough (0.25 to 2 acres) to provide sufficient sun light to the shade intolerant pine species. The Technical Coordinators of the California Spotted Owl Assessment identified group selection cuttings or modifications thereof as "possibly having promise for production and long-term maintenance of owl habitat because it can provide a multi-aged mosaic of small even-aged groups or aggregations" (Verner et. al. 1992, page 271). Groups would range in size from about 2 acres down to a quarter-acre, or possibly less. Openings would be sufficiently large to permit regeneration of shade-intolerant as well as shade tolerant tree species.

Verner, Jared; McKelvey, Kevin S.; Noon, Barry R.; Gutierrez, R. J.; Gould, Gordon I., Jr.; Beck, Thomas W.; Technical Coordinators. 1992. The California spotted owl: a technical assessment of its current status. Gen. Tech. Rep. PSW-GTR-133. Albany, CA: pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture

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CONCERN #4:  The Lassen, Plumas and Tahoe forests already have the highest cuts in California and under this legislation the cut would increase by 50-100 MMBF!

RESPONSE: The claim means very little without knowing about the acreage involved. The Lassen and Plumas National Forests have nearly twice the acreage classified as capable, available and suitable for timber management then the other National Forests of the Sierra Nevada. Given this fact it is reasonable to expect that these forests would have the highest harvest. Comparing the ratio of harvest to total acres the Lassen and the Plumas harvest levels are very conservative.

  As one might guess, with the largest land base it follows that the allowable sale quantity (ASQ) would be among the largest. This is true whether one uses the Land and Resource Management Plan ASQ or that of the Revised Draft EIS for the California Spotted Owl.

^1/  The respective Land and Resource Management Plans as summarized in "The California Spotted Owl: A
     Technical Assessment of Its Current Status. Page 265.
^2/  The California Spotted Owl Sierran Province Interim Guidelines Environmental Assessment, 1993. Appendix D page      2 and Chapter IV, page 32.
^3/  Revised Draft Environmental Impact Statement, Managing California Spotted Owl Habitat in the Sierra Nevada
     National Forests of California: An Ecosystem Approach. page 3-182 & 3-195.
^4/  The ASQ is based on the assumption that "Fiscal year 1994 volumes better reflect the alternatives effects" and that
     a similar situation will occur when a longer-term strategy decision is made.
^5/ Estimated Sum of Green sales and salvage.

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CONCERN#5:  The Bill will "Override all environmental law such as National Forest Management Act, National Environmental Policy Act, and Endangered Species Act."

RESPONSE: It was always the intent of the QLG that all environmental laws would be followed.  Specific language to this effect was not included in HR 858 because it was not deemed necessary to say that all laws would be followed. The bill now very specifically states "Nothing in this section exempts the pilot project from any Federal environmental law".

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CONCERN #6: The Forest Service estimates the additional logging and the more than 100 miles of requisite new road construction will increase the level of watershed disturbance on the affected public forests by up to 300% over current management. Because of the large amount of road building necessary to implement the QLG program, FS specialists predict a significant increase in erosion and sedimentation. The increased sediment will result in additional costs to Pacific Gas and Electric which currently spends about 3 million per year dredging the reservoirs that catch that sediment. These costs will be passed on to rate payers.

RESPONSE: This claim is apparently based upon the Revised California Spotted Owl Draft Environmental Impact Statement that was withdrawn from public release in August of 1996. It is interesting to note the original California Spotted Owl Draft Environmental Impact Statement stated that Alternative "F", the Quincy Library Group proposal "would result in minimal new road construction" (page 3-143). The same EIS also stated that the Equivalent Roaded Acres for Alternative "F" would be lower than that of the existing Forest Land and Resource Management Plans (page 3-143).

  The withdrawn Revised California Spotted Owl Draft Environmental Impact Statement said that "the alternatives [including the "QLG alternative, F"] would not directly affect the management of forest roads. Road management would continue to be guided by standards and guidelines in the Land and Resource Management Plans and pertinent laws and regulations." "New road projections are an estimate of the road construction needs to complete a fully developed transportation system that meets short- and long-term goals and objectives of the forest LRMPs and the alternative. Actual road construction will vary by year, depending on program levels. Road construction and reconstruction needs, locations, density, mitigation, and consequences will be addressed in site-specific analysis at the project level".

  There is no "plan" to build new roads for fuelbreaks, because that is one issue that needs to be decided in the project EIS required by S-1028. The National Forests in the QLG area are already intensively roaded, so it will be difficult to find any "necessity" for new roads. One major effect of the S-1028 will be to remove hundreds of thousands of acres from the area currently available for roadbuilding, and designate them "off base" or "deferred" areas. For at least the term of the QLG Bill, no road building or timber management activity would be permitted in those areas. The QLG fuelbreak strategy is not dependent on any quantumfold increase in road building.

  The Pacific Gas and Electric Company is a founding signatory member in the Feather River Coordinated Resources Management Group (FRCRM) established in 1985. The FRCRM has been actively working on watershed restoration and is one of the earliest and more prominent CRM groups in California. The P.G. & E. does not spend "about 3 million per year dredging the reservoirs" in the Feather River watershed. P.G. & E. has not dredged any reservoirs in the Feather River watershed in the past 10 years.

  However, there is significant erosion and sedimentation in the Feather River. The erosion and sedimentation is attributable to more than a century of resource impacts that include timber harvesting, road construction, mining, grazing and large scale fires. Since 1985, over $4.1 million has been invested in more than 30 watershed restoration studies, assessments and projects.

  If you would like to know more about the FRCRM and its activities you may request several Fact Sheets that describe the organization, its accomplishments since 1985 and several restoration projects from Plumas Corporation (email, telephone- 916.283-3739).

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CONCERN #7:  The Bill temporarily protects roadless areas on Plumas National Forest, however, on the Lassen National Forest there are a number of roadless areas that would be logged under S. 1028 and a large amount of rare Sierra Nevada Mixed Conifer Old-Growth would also be at risk.

RESPONSE: The areas referred to are presently available for logging and so are the 494 thousand acres that are identified by the QLG bill as "offbase or deferred"!  While it would be unlikely that the Forest Service would propose a treatment in any roadless area, if this were to occur it would be reviewed under a project specific Environmental Analysis as required by the National Environmental Policy Act. If the Lassen National Forest were to propose activity in any roadless areas referenced, the Quincy Library Group and any other interested party would consider the proposed treatment and make appropriate recommendations through the normal NEPA channels.

What the critics forget to mention is that the Quincy Library Group proposal protects 494 thousand acres (21% of the entire forest area) that are presently available for timber management. These are areas that were reviewed under the Roadless Area Review and Evaluation program and left as available for timber management. Those areas that remain roadless are considered "offbase" or "deferred" under the QLG's Community Stability Proposal and the Bill.

While the critics don't specify the areas being referenced, it is likely that these areas are Late Successional Old-Growth (LS/OG) identified during the Sierra Nevada Ecosystem Project. A recent analysis of these areas by the Lassen National Forest found that several thousand acres are identified as LS/OG class 4 or 5 that were not included in the QLG "offbase" or "deferred" areas. This is new information in that the QLG proposal was developed in 1993 using the best available information while the SNEP project was completed in August of 1996. Additional analysis by Lassen National Forest staff found that of the several thousand acres of LS/OG not protected by the QLG proposal, some overlaps with proposed DFPZ locations. This is one reason that the QLG has been requesting a EIS for the fuelbreak strategy since the Technical Fuels Report was released.

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CONCERN #8:  It is highly questionable whether the "fuelbreaks built under timber sales" proposed by the QLG and mandated by the Bill will work. The plan is to reduce forest canopy closure to 30-40 percent. This will let lots of light into the stands, stimulating the growth of brush and small trees. This will probably increase rather than decrease fire risk. Up to 60,000 acres of such fuelbreaks are mandated by the Bill each year. Most seasoned firefighters hate fuelbreaks because they almost never work, are poorly maintained and therefore typically increase fire intensity.

RESPONSE: These remarks are drawn from Dr. Timothy Ingalsbee's report commissioned by the Western Ancient Forest Campaign. See Dr. Menke's review of and the QLG's response to Dr. Ingalsbee's report.

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CONCERN #9:  The Pilot Project will "Increase the fire risk."

RESPONSE: This statement is also drawn from Dr. Ingalsbee's report. See Dr. Menke's review of and the QLG's response to Dr. Ingalsbee's report.

  In a recent article in the Journal of Forestry, Drs. K. Norman Johnson, John Sessions, Jerry Franklin and John Gabriel said that "building fuelbreaks could reduce the size of wildfires and increase safety for firefighters as a first step toward limiting the extent of high-severity fires. Without an agressive fuel-reduction program to complement the fuelbreak system, however, much of the forest would remain susceptible to high-severity fire." [Editor's note: see QLG Fuel Strategy paper] Computer simulations by the authors suggested" that more than two thirds of the pine and mixed conifer forests have at least a 10 percent chance of fire (one burn) under extreme weather in the next 50 years, and almost a fifth have at least a 30 percent chance of fire (three or more burns) with out fuelbreaks. Adding fuelbreaks somewhat reduces the overall all probability that thise forests will burn in extreme weather."

K. Norman Johnson, John Sessions, Jerry Franklin and John Gabriel. Integrating Wildfire into Strategic Planning for Sierra Nevada Forests. Journal of Forestry. January 1998. Vol96:1.

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CONCERN #10:  The Forest Service says it will take an additional $83 million to implement the "pilot project".  Where will the money be found?  Unless there is a specific appropriation this increase in logging will require diverting funding from other forests-most likely other California National Forests.

RESPONSE:  This statement is drawn from the Congressional Budget Office (CBO) report. Somehow the critics overlook key parts of that report, which explain that revenues will offset the costs in large part or perhaps completely. The critics failed to mention that the CBO report stated that "Implementing the bill's provisions could lead to a significant increase in offsetting receipts from future timber harvests in the affected forests".

CONCERN #11:  The Quincy Library Group "is an industry-picked group of 13 people who were granted $4.1 million by the Federal Government."

RESPONSE:  First, everyone who participates is there of their own free will. The industry didn't pick anyone. If you show up for the regular public meetings and want to work, you will be drafted into membership (presently with about 40 on the steering committee, not 13), and nobody has ever been turned down. Domination by any one faction is not possible, because decisions are by consensus. It isn't easy to reach agreement when everybody has a veto, but we manage to make it work by persuasion, not coercion.

Second, QLG has never received any federal money. The QLG is responsible for having an additional $5.7 million allocated to the 3 forests, but the QLG hasn't touched a penny of it. The QLG doesn't even have a bank account and it is not chartered.

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CONCERN #12:  The Quincy Library Group legislation undermines the National Environmental Policy Act and the National Forest Management Act.

RESPONSE:  See QLG member Linda Blum's response to several email messages and telephone calls from environmental activists regarding this criticism.

EPILOGUE

The QLG bill includes most of those things that the environmental community has most wanted: preserving roadless areas, protecting ancient forests and key watersheds, better protection of streams and rivers, and the use of credible scientific information in forest planning.

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