South Manti Timber Salvage DEIS comments
July 19, 1999
Don Fullmer, EMBC
Manti La Sal National Forest Dear Don:
The Utah Environmental Congress (UEC) appreciates the opportunity to comment on the South Manti Timber Salvage DEIS. We also appreciate the extended comment period and the field trip provided by your office.
The UEC does not support any of the action alternatives considered in the DEIS. The volume of the sale, the cumulative effects related to land stability, soils, wildlife, and roadless areas, the economic loss to tax payers, and the inability of the Forest Service to demonstrate a substantive purpose and need for the sale -–makes this a project the UEC cannot support.
Purpose and Need Potential for Wildfire In the section on Land Stability, the DEIS states "Late snowstorms, rapid snowmelt, and high runoff volumes in 1983 and 1984 caused flooding, severe erosion, and saturation of surface materials" (3-7). It would appear the analysis area is generally wet and moist and susceptible to flodding. In the Water Quantity section the DEIS states "The project area has some of the highest water yield rates on the Wasatch Plateau. These yields are related to the higher precipitation at high elevations (3-11). Again, the inference is made as to how wet the area is in general. The Fuels/Fire section states "There has been an average of one ignition per year over the past 27 years within the project area. Typically, due to direct suppression and/or wet conditions, these fires rarely reach more than one acre in size (the largest fire in the past 27 years in the project area is 1 acre)" (3-26). This statement clearly demonstrates the 'wet conditions' of the area and documents only one, one-acre size fire in 27 years. The Fuel Moisture section states "Fuel moisture in the spruce/fir type is typically higher…. This higher fuel moisture content results in a lower risk to fire starts…. The fuel moisture levels in these openings will be higher due to less transpiration from dead trees, thereby making more soil moisture available" (3-27).
The section on Dead and Down Fuel Loads further states "This size of material…results in a relatively low rate of spread for ground fires. Because of the predominantly cold, moist conditions in subalpine forests, even those stands having relatively heavy fuel loads may not experience fires for many decades" (3-27). According to Bradley (1992) Engelmann spruce is the second most resistant species to fire within the project area (3-27). On page 4-31 the DEIS states "Although fire hazards are not usually considered to be a major concern in these forest types, except during periods of drought and high wind conditions (Bradley, Noste, and Fischer, 1992), fire is a natural part of the ecosystem." Page 4-41 states "Younger trees are more susceptible to fire than the older trees." And "It is anticipated that it would take longer for stands to naturally open and experience localized drying effects, than it would for treated stands in the action alternatives."
The Forest Service's own documentation demonstrates that wildfire is clearly not a major concern in this project area, however logging will increase the chance of wildfire. Page 4-42 of the DEIS states "It is expected that fuel moisture levels would decline due to opening of the canopy through salvage harvest. Temperature gradients and wind would increase the process of drying the dead, downed fuels more than other areas. Risk of potential wildfire starts and spread rates due to drier fuels would be increased in these more heavily infested areas." The S. Manti Timber Salvage will not meet the Purpose and Need for reducing the chances of wildfire – indeed it will increase the chances. Furthermore, if the Forest was logging at a sustainable rate, it would not need to 'facilitate rapid reestablishment' of Engelmann spruce, which we will discuss later on in these comments. Lastly, the Forest will not recover any economic value for this salvage sale. This project, like all the others on the Manti La Sal National Forest is a below-cost timber sale estimated to lose $4 million. "The present net value of all sales appraised deficit" (4-76). The S. Manti Timber Salvage fails to meet any of the purported reasons given for the Purpose and Need of this project.
Sustainable Ecosystem Forest Management The Forest continues to plan beetle salvage sales and is quickly approaching the logging of 100 MMBF of Engelmann spruce forest type off of approximately 15,000 acres, including the proposed S. Tent sale. According to the DEIS "A Forest Service Entomologist estimates that 30,000 acres of spruce-fir forest have been affected by the spruce beetle infestation to date across the Forest (Anhold, 1998) (3-17). The Ferron and San Pete Districts alone have or will log about 50% of the diseased stands. This level of logging does not consider the Forest Service modelling prediction that the beetle-cause spruce mortality would leave approximately 34% of the stands as multi-storied (3,542 acres) (4-39). It also fails to consider the Schmid and Frye (1977) report that states average fall rates in areas similar to this project [S. Manti] to be between 0.7 and 1.5% per year with about 84% of the trees still standing after about 25 years (4-40). In addition, this level of logging clearly violates Forest Plan direction.
Wildlife Within the project area there are 93 miles of road and trails with 2.4 miles per square mile (3-30). This high road density increases elk vulnerability during the hunting season. The S. Manti sale is proposing additional road construction which will further impact cover through sheer destruction, decrease security, increase access, and will actually increase road densities if funding is not available for the proposed closures, which is likely. "Road and trail reclamation would occur as funds become available" (2-10). The mitigation to lessen increased vulnerability simply does not meet Forest Plan RNG direction for production of forage and cover. Furthermore, the DEIS states that the availability of undisturbed habitat would be continually affected during harvest operations (4-46) over the next six years, and adequate security cover would not be provided for 30-50 years (4-46). The Forest is also planning another prescribed burn that will have immediate effects to the cover and forage ratios for the next 3-5 years, further limiting cover (4-57). Current cover forage ratios are 40/60 which is a limited cover ratio. With implementation of the action alternatives, cover will be further reduced to 27 – 32 %.
Furthermore, the amount of past, proposed and future projects will impact three-toed woodpeckers considering the entire project area and vicinity is prime habitat and beetles are their prime prey. Currently, 25% of this habitat has been logged (3-34), and the S. Manti sale will log an additional 18 –29% (4-55). In addition, 37% of its snag habitat will be logged (4-50). Seventeen percent of the area contains suitable goshawk habitat, and two nest territories with multiple nests are within the project area (3-33). A primary prey species of the goshawk is snowshoe hare (also primary prey for lynx) which is supported in the project area and requires dense forest habitat Black bears are known to exist and den in the project area as well. Flammulated owls nest in the project area. It is clear the area is widely used by a variety of wildlife species, and provides some level of cover and security for their needs. The S. Manti project will open up the area destroying the dense vegetation required by these species.
Page 4-37 of the DEIS states the threatened Heliotrope milkvetch and its critical habitat exists within the project area, but are located outside of the proposed treatment units and therefore there will be no effects to this species. The UEC requests the FEIS clearly state exactly how this species and its habitat will be protected?
The UEC strongly disagrees with the DEIS statement that "All action alternatives would comply with Forestwide direction to provide habitat needs, as appropriate, for MIS; maintain or improve habitat capability; maintaining appropriate forage to cover ratios; and maintaining at least 50% of current habitat (4-98). None of the action alternatives will meet these Forest Plan directives and therefore violate the Forest Plan.
Watershed Health and Restoration/ Land Stability Pages 3-12 and 3-13 of the DEIS state: "Total sediment production includes input from mass movements, channel erosion, and surface erosion. Channel erosion is a common feature in many of the streams within the project area. There have been some hydrologic events, such as the floods of 1983 and 1984, that have caused severe channel adjustments. These flood events in combination with the landslide activity during the same time period, especially west of Skyline Drive (FDR #50150), have caused stream channels to move out of equilibrium. Many stream reaches have over-steepened banks, bank erosion, and constant channel adjustment which causes in-channel erosion, a major source of sediment. The modeled results provide an estimate of background sediment yield levels of 64 tons/mile square to 976 tons/mile square depending upon the drainage. These estimates only address sediment from overload flow and do not consider sediment from mass movements or in-stream channel erosion." Page 3-15 states "Extensive soil movement and channel adjustment was observed by the Forest Fisheries biologist in response to high runoff in the Upper Muddy drainage in 1995 (Dufour, 1995). High fall flows caused substantial channel down cutting and some lateral adjustment in the lower portion of the same drainage near the Forest Boundary (Dufour, 1995)."
In addition, page 3-6 states "The project area contains numerous landslides." Figure 3-5 in the DEIS shows that 37% of the project area is in the "unstable" class and 27% more is in the "moderately unstable" class. Therefore, 64% of the project area is unstable to some significant degree. "The project area contains many existing and ancient landslides. The effects of land instability are common to the area" (4-6). "Activities that have the greatest potential to decrease land stability include new and temporary road construction, road reconstruction, and staging area development for equipment" (4-7). All action alternatives proposed in the S. Manti sale will reconstruct 15 miles of road, build 1 mile of Forest Road Development, and 8 miles of temporary roads (4-60). Furthermore, page 4-61 states "Some reconstruction would have the same ground-disturbing effects as localized new construction due to the need for realignment, specifically access into treatment unit F3." In addition, as many as 30 helicopter landing sites could be developed. According to the DEIS, these roads and helicopter pads in unstable and moderately unstable areas could induce localized landslides especially on steep slopes and wet areas fed by springs (4-7). Currently, development of a network of roads in areas mapped as unstable and moderately unstable within and adjacent to the project area has increased the potential for landslides (4-8).
The UEC is concerned about the population of Colorado River cutthroat trout planned to be introduced into Little Horse Creek sometime in 1999, or later (3-15). The success of the introduction would appear to be in danger due to the unknown current sediment rates, the current impacts and potential impacts from the S. Manti Timber Salvage. The water yield model used in this analysis predicts an average annual increase of 4.7 inches of water for the areas infected with beetles (4-12). The increased flows in seven streams will likely cause channel alterations (bed and bank erosion), and seven streams will have increased flows of more than 10%, including Little Horse Creek (4-12). Sediment loads in streams from surface erosion could be increased in Little Horse Creek subwatershed by about 11% in the worst case analyzed (4-15).
Harvest activity in the watersheds would increase sediment yield, impact channel morphology and affect aquatic habitat (4-24). Dependent on the action alternative chosen, between 14 and 18 riparian road crossings and 2 road alignments would occur within riparian areas. Increased erosion would result in temporary filling of pools in some areas and possible sedimentation of spawning gravels, causing some fish displacement and loss of productivity (4-25).
The DEIS states that downstream from the project area, there are four Colorado River fish species which are listed as 'endangered'. The UEC requests the FEIS state how far downstream do these species exist and what are the possible impacts to them from the S. Manti project?
It is patently clear that the project area is on unstable soils; sediment loads from mass wasting and soil erosion are unknown; direct impacts to fish species is therefore unknown; road construction will exacerbate the sedimentation, as well as erosion problems in the project area; watersheds have already been impacted from past landslides; water yield will be dramatically increased; and logging and road building activities will be occurring on steep, unstable soils. The UEC is at a loss to explain how the Forest can possibly claim that all alternatives would be consistent with Forest Plan direction for land stability including: "avoid, where practical, unstable areas, moderately unstable areas, slopes greater than 40%, and active landslides" (4-95). The S. Manti project will violate all of these directives. We note here that some slopes proposed for logging are 130 to 75% (3-10)! Page 4-96 of the DEIS states that all alternatives would comply with Forestwide direction to improve or maintain water quality. The S. Manti analysis cannot guarantee this when sedimentation analyses haven't been conducted, therefore baseline data is not available, and the DEIS concedes the project will impact the watersheds further.
Road Construction Roadless Areas Due to the Roads Moratorium, which UEC supports, the Forest decided to enter the five roadless areas using helicopters. This adds dramatically to the cost of the sale – and coupled with the significant impacts to this delicate area, it is a ridiculous project to proceed with. The UEC is particularly concerned about proposed units F1 and F3 in the Duck Creek drainage. The UEC took 13 people on a field trip to many of the proposed units, and hiked through unit F3. We were hard pressed to find more than 20-30% dead trees in this unit – hardly the 90% dead the Forest claims exist. Furthermore, the road stated for reconstruction has been put to bed for a long time. Our surveyors had difficulty finding where the road went after the first ¼ mile. This road would have to be fully reconstructed through a riparian area to access this unit. The UEC recommends dropping this unit completely. I videotaped the unit as well as the road to document the current situation, which is vastly different from what the Forest claims. This area is particularly important to goshawks, black beer, elk and should be considered roadless for all practical purposes. The UEC will document the current cherry stem and recommend this area be added to the Big Bear Canyon Roadless Area.
The UEC is interested in working with others in Utah's environmental community to develop a forest wilderness proposal for qualified roadless areas. The DEIS states "Harvest and associated road work could remove future opportunities to designate affected portions of inventoried roadless areas, or the whole inventoried roadless area, as roadless and eligible for recommendation as wilderness (4-80). The UEC encourages the Forest to stay completely out of all roadless areas.
Economics Helicopter Logging Bleich, V.C., R.T. Bowyer, A.W. Pauli, M.C. Nicholson, and R.W. Anthes. 1994. Mountain sheep ovis canadensis and helicopter surveys: Ramifications for the conservation of large mammals. Biol. Conservation 70:1-7. Cote, S.D. 1996. Mountain goat responses to helicopter disturbance. Wildl. Soc. Bull. 24:681-685. Conclusion The UEC is disappointed that a project of this nature was even considered, much less evaluated in a $70,000 EIS. A project as foolhardy as this should have never made it to the EIS level
of evaluation. We sincerely hope the Manti La Sal National Forest will wise up and stop planning destructive timber sales that further denude our public lands at public expense. The UEC
and its members are very concerned about this project. Please keep us on the mailing list and if this project proceeds, send us a copy of the FEIS.
Sincerely,
Denise Boggs, Executive Director
599 West Price River Drive
Price, UT 84501
The P & N for this timber sale is threefold: 1) reduce potential for large and intense wildfires 2) facilitate rapid reestablishment of Engelmann spruce; and 3) recover some of the economic value of dead and dying trees (DEIS – S2). We fail to comprehend how these three goals fit with the Forest Service's Natural Resource Agenda that focuses on four key emphasis areas: watershed health and restoration, sustainable forest ecosystem management, improved management of the National Forest road system, and improved recreation opportunities and experiences (S1). The South Manti Timber Salvage will denude watershed health, is an unsustainable level of harvest, will build more roads that will fragment the forest and for which no funds will be available to maintain (over $1 billion backlog in road maintenance funds), and will lower recreation opportunities and experiences. We will address each of the issues separately under individual subject headings, but note here that the Purpose and Need of this project violates national Forest Service direction, and fail to understand the Forest's claim that "This project embraces the Agenda's goals (1-5).
The UEC does not believe the S. Manti analysis area is in any significant danger of wildfire. The area elevation is between 8 –11,000 feet (3-5); snowpack remains until late June (3-11); early snowdrifts can inhibit or restrict access and may be found beyond July 1st, and early snows can close people out prior to October 31st (3-37); the area experiences 8 – 12 inches of rain between May and September (3-4); and Engelmann spruce is known to be resistant to fire in general (3-27).
The S. Manti Timber Salvage will log between 20 – 40 MMBF of timber off about 6,500 acres depending on the action alternative chosen. According to the DEIS, several other timber sales have been logged or sold in the area. The 1992 Timber Canyon sale logged 2.9 MMBF off 330 acres; the Twelvemile Timber Sale logged 2.4 MMBF off 205 acres in 1993; and the six timber sales sold in the 1996 South Manti Timber Salvage Sales will log approximately 20 MMBF off 2,045 acres (3-20). All of these sales were dead or dying Engelmann spruce totally approximately 9,110 acres. Based on a 1960 timber survey, the project area included 11,490 acres of Engelmann spruce-subalpine fir forest cover (3-21), and the DEIS states that at least 11,275 acres of spruce have experienced extensive mortality (4-27). It is clear the Forest is planning to cut the entire Engelmann spruce component in a 10-year period (1992-2002). In addition, "Other planned, current, or reasonably forseeable actions include harvesting in other unmanaged areas in the next 10+ years (4-57). Salvage, or not, these sales are not being logged at a sustainable rate in accordance with ecosystem management objectives. Other smaller sales have also occurred in the area and the South Tent salvage sale is currently being planned for the same reasons (beetle-killed Engelmann Spruce and is estimated to be 40 MMBF). [Although this proposed sale was discussed on the field trip, it is not mentioned in the cumulative effects section of the DEIS. ]
About 22% (5,335) acres of the project area is allocated specifically to provide for wood fiber production and utilization, and another 78% (19,112 acres) is allocated to allow for wood utilization consistent with meeting other resource value requirements. That 'other resource value' is the production of forage and cover for livestock and wildlife (3-2). The combined salvage sales, including the S. Manti Timber Salvage are not consistent with meeting the production goals of forage and cover for wildlife. The MIS for hiding and foraging habitat, as well as road densities, are elk and deer (2-4). Deer populations are below herd objectives (3-29).
Hiding/security cover is the primary habitat provided by the stands of trees within the project area (3-30). Recent wildlife surveys (1998) have found deer and elk occupying these habitats (3-30). Even prior to the spruce beetle infestation, the amount of cover in the project area was limiting during the general elk hunt (3-30). The S. Manti Timber Salvage will only exacerbate the problem of limited cover in the project area. In addition, the DEIS states that forage is not a limiting factor in the project area (3-30, 4-46) and "the adverse effect of reduced cover (increased vulnerability) is not counter balanced from an increase in forage" (3-30). The S. Manti sale will clearly violate the Range Forage Production Management Unit (RNG) (Forest Plan III-64).
The S. Manti project area includes 4 watersheds including 17 lakes, reservoirs, and ponds, representing 22% of the lakes within the Forest boundary and all waters are designated as high quality (3-11). The DEIS states "This analysis did not directly measure or predict sediment volumes from historic or current mass movements" (3-12). This is a major flaw in the document that must be corrected in the FEIS. Page 4-96 of the DEIS states "The only water quality parameter that would be affected by the action alternatives is sediment." How can the Forest claim that "All alternatives would comply with Forestwide direction to improve or maintain water quality" (4-96) without this basic information? The UEC believes water quality and quantity will be severely impacted by the S. Manti Timber Salvage project based on the following information found in the DEIS.
As mentioned in previous comments, the UEC is opposed to any new road construction on the Forest. This includes reconstruction and temporary roads as well. The Manti La Sal Forest has been "cut to ribbons" by roads, to quote a local in the area. The Forest Service admits it does not have the needed funding to maintain the roads that currently exist, not the funding to enforce road closures. At the national level, the Forest Service is backlogged approximately $8 billion for road maintenance. There is simply no excuse to build more roads, further fragmenting the forest, causing irretrievable resource damage, and then not properly maintained. In addition, it should be clear to any logical person that roads should not be built on unstable land, erosive soils and steep slopes. The cost of road construction further contributes to this deficit sale.
The UEC does not and will not support the entry into roadless areas for logging purposes regardless of the logging method. These areas provide the best wildlife refugia remaining on the forest. It is clear from the DEIS that wildlife habitat propagation has not been considered an important resource on the Manti La Sal National Forest. Indeed, every logging proposal further encroaches on and fragments the remaining wildlife habitat and every NEPA document claims there will be no long-term impacts to any species. The UEC challenges the Forest to show us even one document (EA, EIS, BE, BA) that outright states significant impacts will occur that jeopardize viable populations of native wildlife species. It is nonsensical to believe that the amount of logging being conducted on the Manti La Sal National Forest is not having deleterious impacts to wildlife in general. The BA for this project states "The total effects from the proposal relative to all present, past and forseeable effects should not have harmful impacts upon the local threatened and endangered species provided all the planned designed features for the rpoject are implemented. However, as future human actions increase, additional uses from all aspectes like mining, recreation, grazing, fire suppression, etc. over space and time, the existing habitat will probably become less effective for those species Federally listed" (J-11). How many future human actions must occur before this determination is made? The UEC suggests that time has come and passed and impacts are occurring now.
The S. Manti Timber Salvage is estimated to lost $4 million according to the DEIS (4-76) in large part due to the use of helicopters, but even without it would still be a deficit sale. Despite the DEIS' promises of jobs and local income, it is doubtful any local loggers would be able to afford to bid on any of the sales. A call to Satterwhite Log Homes confirmed they would not bid on helicopter sales.
The DEIS failed to consider the noise impacts of helicopter logging on wildlife species such as deer, elk and black bear which are all present in the S. Manti project area. This issue needs to be substantively addressed in the FEIS. While the following abstracts deal with Mountain sheep and goats, they are also pertinent to other large mammals.
Abstract: Author's Abstract: Mountain sheep Ovis canadensis respond dramatically to helicopter disturbance. Significantly more animals abandoned sampling blocks and moved farther during helicopter surveys than on nonsurvey days throughout the year. Likewise, mountain sheep changed the vegetation type they occurred in more often than before helicopter surveys: however, this difference was only significant during spring. Mountain sheep did not habituate or become sensitized to repeated helicopter overflights: time since capture was not related to their movements. The negative influence of the helicopter was extreme and may override variables that might otherwise be correlated with movement patterns of mountain sheep: this outcome also may hold for other ungulates. Further, sampling with helicopters may result in the violation of fundamental assumptions of population estimators routinely employed in conservation efforts for large mammals. the consequences of disturbing mountain sheep, such as altering use of habitat, increasing susceptibility to predation, or increasing nutritional stress, need additional study. These factors all have ramifications for the conservation of mountain sheep, and other large mammals disturbed by helicopter sampling.
Abstract: Mountain goat (Oreamnos americamus) responses to helicopter traffic were investigated at Caw Ridge (Alberta) from June to August 1995. A population of 109 marked
individuals inhabited the ridge during the study. As measured by their overt responses, mountain goats were disturbed by 58% of the flights and were more adversely affected when
helicopters flew within 500m. Eighty-five percent of flights within 500m caused the goats to move> 100m; 9% of the flights > 1,500 m away caused the goats to move similar distances.
Helicopter visibility and height above ground, number of goats in the group, group type (bachelor or nursery), and behavior of groups just prior to helicopter flights did not appear to
influence reactions of goats to helicopters. Helicopter flights caused the disintegration of social groups on five occasions and resulted in one case of severe injury to an adult female.
Based on these observations, restrictions of helicopter flights within 2 km of alpine areas and cliffs that support mountain goat populations is recommended.
In summation, the South Manti Timber Salvage should be withdrawn from further consideration for the following reasons:
