February 13, 1997

Ms. Linda Blun
Quincy Library Group
P. O. Box 1749
Quincy, CA 95971

Dear Linda:

I have been traveling for the past three days and am only now back in the office. Your faxed revision of the QLG bill reached me in Seattle late on Monday, and I have only been able to read it through once. I appreciate your efforts to coordinate this process but frankly, am quite disappointed that so few change were made to incorporate the issues Mike Jackson said at our last meeting would be included in this draft. My intent is to prepare by the 19th, some specific bill language for inclusion in the next draft. (I will be on vacation from 2-14 through 2-17 and will not get to this again until the 18th).

Overall, the legislation remains vague about some key points and creates some alarming uncertainty. For example, language is need to stipulate that all logging will be done under the CASPO system, without the use of either adaptive management exemption.

Also, The Wilderness Society (TWS) cannot support certain provisions of the 1993 QLG agreement which is incorporated into the bill by direct reference. Specifically, the ambiguous clause that would allow some land currently unavailable for logging to become available establishes a precedent that undermines the NFMA. I understand that the QLG's intent is to relax the visual constraints, and that may be appropriate under the group selection system, but the place to reallocate lands is in the forest plan amendments, not by condoning a vague statement that has no process associated with it. I made this point at our meeting last month and three years ago, and it still remains problematic for TWS. Language is need that specifies that all logging conducted pursuant to the legislation shall take place on lands that are capable, available, and suitable, until such time that a forest plan amendment reallocates lands.

Similarly, the 1993 QLG proposal specifically calls for stewardship contracts, a sustained yield unit and a working circle, none of which the Wilderness Society supports. Prior conversations with QLG members indicate that the group is not advocating these three ideas at this time but the legislation is noticeably silent. Because the bill directly references the 1993 QLG agreement, language is needed that expressly precludes endorsement for stewardship contracting, working circle, and sustained yield unit. If not, some could argue that Congress had in fact, authorized them in the QLG bill.

Several concerns remain with the "strategic system of defensible, shaded fuelbreaks consistent with the Quincy Library Group proposal of 1993,..." I acknowledge the change by the addition of a range from 40,000 - 60,000 acres. However the fuel zone concept is experimental. No field data exist demonstrating that a fuel zone will bring a crown fire to the ground. Anecdotal information is mixed at best. But, we are not opposed to a carefully constructed experiment on a much more limited basis, like one Ranger District. In addition, the 1993 QLG proposal is silent on the fuel zone idea. It was added later in various forms (some of which we have seen) and, in my non-legal opinion, would therefore not be covered by the bill's reference to the 1993 agreement, creating more uncertainty.

In addition, the bill-creates no process to develop the "strategy" behind the system. As you are will aware, the so-called, "Technical Fuels Report" prepared by the forests in the area purports to present a fuel treatment strategy, and goes so far as to put lines on a map identifying "general forest fuel reduction zones." Alas, no where is this report is any explanation whatsoever as to how the forests decided that these "general forest" areas need fuels treatment. One discredulous environmentalist once described these zones as suspiciously similar to the forests' green sale program. Language is needed that describes a process by which the public can participate in the design of the fuel break system. Without such language, the public is being asked to trust a general, shifting, vague concept without any input, and the land could be subjected to the program proposed in the Technical Fuels Report.

Another major uncertainty is the amount of logging that could take place. While we agree that all logging should be performed by the CASPO rules, the bill provides no assurance to the public, or direction to the Forest Service, that the cumulative levels of logging done for the fuel zone construction and pursuant to the group selection program be sustainable. Currently, The forests in the QLG areas cutting a great amount of timber. In fact, last year, according to the Regions Cut and Sold reports, the Plumas and the Lassen cut 25% of all the timber cut on California's national forests. The current ASQ for the Lassen, as amended by CASPO, is 47.1 mmbf. Last year, the Lassen reported cutting 95 mmbf. We believe that it is unwise to encourage this forest to expand their logging programs. We can not support limitless logging and feel strongly that some type of limit must be imposed, regardless of the silvicultural method. The public has a right to know what level it is condoning. Language is needed that specifies that 1) the forest management program established by the bill is the entire logging program for the forests (so they don't add their own timber program to the QLG's). and 2) that the total volume logged not exceed the allowable sales quantity for each forest as established by the forest plans as amended by CASPO.

TWS remains concerned about the Catastrophe Area exemption. One unresolved serious issue concerns the four areas proposed for Wilderness designation in the Lassen forest plan. Currently, the Forest Service must manage them as Wilderness until such time as Congress acts. If the bill was enacted as currently drafted, these 20,000 acres of wilderness would be subject to logging and road building, activities precluded by the current status.

The above are some of the concerns that we still have with the legislation. The Wilderness Society is sincere about working collaboratively to produce an acceptable piece of legislation, but in its current form, we can not support the bill. I will send you some suggested language by the 19th, and thank you for your sincere efforts to work this out.

Very truly yours,

Louis Blumberg
Assistant Regional Director

03/09/97 09:54:19 PM