Proposal for Additional Logging in Coyote Hollow
March 6, 2000
District Ranger
Dear Ranger Schulkoski,
The Utah Environmental Congress (UEC) appreciates this opportunity to comment on the proposed additional logging in the Coyote Hollow project area. The UEC
asks to be kept on the mailing list to receive additional analysis or a decision notice regarding this proposal.
Supplemental EIS Required: The Dixie National Forest is proposing to essentially double the amount of timber to be logged in the Coyote Hollow area from that approved under the original EIS
and decision notice signed in 1993. The Supplemental Information Report sent to the public states "It is estimated that the trees being killed by the bark beetle will
increase the harvestable volume by 4-6 million board feet." The action approved in 1993 authorized the cutting of approximately 6.6 million board feet. Any move to
increase that by 4-6 million additional board feet is clearly a "substantial change" as defined by both NEPA and the CEQ.
In addition, impacts to wildlife habitat, wildlife populations, and soil conditions may be increased substantially over those impacts considered within the original EIS.
The Forest Service is proposing to add more than 2,500 acres to the amount of land directly impacted by the action and essentially doubling the amount of timber to
be removed. Impacts once considered minimal are likely to be greatly enhanced by the expansion of the project to the levels outlined in the Supplemental Information
Report.
Inadequate monitoring of MIS and TES species: The Supplemental Information Report offers no information with regards to the endangered Mexican spotted owl or the sensitive three toed woodpecker. In
addition, two TEPS plant species located by Forest Service staff along a fenceline in the Coyote Hollow area, the Aquarius paintbrush and Little penstemon are not
mentioned.
A review of monitoring data received under a Freedom of Information Act (FOIA) request submitted by the UEC shows no surveys have been conducted to
determine the presence of Mexican spotted owls on the Dixie in spite of the fact that significant habitat exists and the Dixie National Forest lies well within this bird’s
historic range. A review of the same monitoring data shows no evidence of three toed woodpecker surveys with only a summary of woodpecker habitat and range
conditions across Region 4 provided.
The National Forest Management Act (NFMA), Section 219.19 reads "Fish and wildlife habitat shall be managed to maintain viable populations of existing native
and desired nonnative vertebrate species in the planning area." NFMA goes on to state "Population trends of the management indicator species will be monitored
and relationships to habitat changes determined." (Emphasis added). There is absolutely no evidence these requirements have been met with regards to the species
listed above. The fact that endangered species monitoring is not taking place is especially troubling.
The recovery plan prepared for the Mexican spotted owl documents the impacts logging can have on this species. Research sited within the plan showed "In general,
owls foraged more than or as expected in unlogged forests, and less than or as expected in selectively logged forests." (Page 27, Recovery Plan for the Mexican
Spotted Owl). The recovery plan concluded "Clearly, recent forest management practices and those detailed in existing Forest Plans are not beneficial to Mexican
spotted owls. Reliance on traditional forest management and silvicultural techniques may no longer be possible, not only with respect to the conservation of the
Mexican spotted owl but also with respect to maintaining other ecosystem attributes." (Page 71).
Spruce bark beetle threat: The inappropriate disposal of slash and other debris created by logging activities has been shown to contribute to the spread of spruce beetles. Did the Forest
Service require Kaibab Industries to remove through burning or other means slash piles when they announced they were going out of business? These piles may have
contained bark beetles or allowed bark beetles to become established within the project area. We are troubled by the possibility that past logging may have
contributed to this outbreak. It seems unlikely that it is simply a coincidence that such a heavily logged area should suddenly begin to develop a bark beetle problem
when the Forest Service consistently argues such logging operations are a means of controlling these outbreaks.
We remind the Dixie National Forest of its admission in the August 15, 1999 Salt Lake Tribune that logging has failed to control the outbreak of beetles in the
Cedar City Ranger District. If anything, the problem there has gotten worse as the Forest Service continued to log in vain in an effort to control these beetles.
The UEC raises two concerns with regard to using logging to control spruce beetles. First, the Forest Service may be inadvertently removing trees strong enough to
withstand a beetle attack by cutting down all trees above a certain dbh thus reducing the genetic strength of the timber stands the Dixie National Forest is attempting
to protect. Second, by removing all older trees above a certain dbh the Dixie National Forest may also be causing the beetles themselves to adapt in ways that
enable them to attack younger trees more effectively. In the same article sited above the Dixie National Forest mentions its frustration with the fact that beetles were
attacking younger trees below 12 inches dbh and that "The spruce trees’ natural defense mechanism-drowning the beetles in sap-has failed for most…"
The possibility that the Dixie National Forest may be contributing to the very epidemic it is trying to control by returning again and again to traditional silvicultural
methods needs to be examined.
Conclusion: In addition, we would like to see the Forest Service start backing up its claims that logging aids in beetle infestation control with solid science. It seems to us the more
you log the more beetle problems you have down the road. What scientific evidence or past monitoring is the Forest Service using to support its claims that
operations such as this will aid in your efforts to control beetles?
We urge the Dixie National Forest to make no decision regarding the expansion of the Coyote Hollow project until these issues are addressed in an adequate
analysis. Thank you again for this opportunity to comment. The UEC looks forward to reviewing any documents published regarding this action in the future.
Sincerely,
Craig Axford
In a memorandum entitled Guidance Regarding NEPA Regulations published by the Council on Environmental Quality (CEQ) it states "A supplemental EIS is
required when an agency makes substantial changes in the proposed action relevant to environmental concerns…"
While the UEC does not have a copy of the FEIS prepared for this sale, the Supplemental Information Report indicates there are and were some serious gaps in the
analysis of the impacts of this project with regards to management indicator species (MIS) and threatened, endangered, proposed and sensitive species (TEPS).
The Supplemental Information Report provides a brief history of the Coyote Hollow timber sale stating that the original contract went to Kaibab Industries. This
company was able to log approximately 4.2 million board feet of timber prior to going out of business in 1996. The fact that they were unable to complete their
contract raises some serious questions with regards to this sale.
Because the proposed action represents a significant change from the FEIS and decision notice signed in 1993 the Forest Service must prepare either a detailed
supplement to the FEIS or a new EIS to examine the impacts of the proposed action. That document should analyze the issues raised above including possible
impacts to MIS and TEPS species.
Program Director, UEC
