Utah Environmental Congress
Thousand Lakes Mountain Logging Proposal
March 17, 2000
Marvin R. Turner, Loa District Ranger Dear Ranger Turner,
The Utah Environmental Congress (UEC) appreciates this opportunity to comment on the proposal to log a portion of Thousand Lakes Mountain. We ask to be kept on the mailing list to receive additional information regarding this project as it moves through the NEPA process.
Roadless Areas: First, the demonstration area located between two existing RARE II roadless areas and just off a road running between them. The vast majority of this area will fall within a roadless area once validation is completed. According to the Region 4 Desk Guide mentioned above "Roadless area boundaries should generally be established 33" from the centerline of the constraining road, edge of development, facility or other feature which would disqualify an area as roadless." (Emphasis added).
Given the requirement to place the boundary 33' from the centerline and the fact that no other developments or facilities exist on either your map or were found by the UEC during its 1999 roadless area survey on the Fishlake National Forest, it is difficult to see how the Forest Service could justify excluding the demonstration area from the roadless area.
In addition to the demonstration area, by far most of the other logging units would also be within roadless areas under the guidelines spelled out in the Region 4 Draft Desk Guide. Based on these facts, the UEC calls on the Forest Service to reconsider its proposal to log these areas. If the Forest Service is unwilling to consider dropping the proposal, it must prepare an EIS because logging within roadless areas constitutes an irretrievable commitment of resources and a significant impact to the human environment as defined by NEPA.
Logging as beetle control: Has the Fishlake monitored beetle activity in other parts of the Forest and compared the level of activity previous to timber sales to beetle activity after timber sales? Is there a statistically significant change in beetle activity after a sale, and if so for how long?
Can the Fishlake National Forest demonstrate that logging to prevent the spread of beetles does not result in the removal of many trees that genetically may be strong enough to resist the "epidemic"? On the Cedar City Ranger District the Dixie National Forest now reports younger trees that were previously left largely alone by beetles are being attacked. This may be an indication that tree removal may has the effect of both weakening the genetic strength of the stands being treated, and forcing beetles to adapt to a forest environment with few older and weaker trees left standing.
Economics: In addition, the Forest Service must analyze the burden to the American taxpayer associated with the sale of this timber. If the Forest Service cannot demonstrate the sale will generate revenue for the treasury, the sale should not move ahead. Any analysis of costs associated with this sale should attempt to take into account the cost of mitigation, monitoring and possible costs associated with the recovery of any management indicator species (MIS) or threatened, endangered, proposed and sensitive (TEPS) species that may be affected by the action.
Wildlife: The Fishlake National Forest should not simply rely on an analysis of the habitat needs of the wildlife in question or an overview of their natural habits. Any analysis completed for this project should include surveys of the various species done within the area to both accurately determine the condition of the population as well as their actual presence. Simply stating adequate habitat does or does not exist is not sufficient.
Conclusion: The EIS should include a detailed analysis of the impacts to wildlife within the project area, including all MIS and TEPS species. The EIS should also document the past effectiveness of using logging to control the spread of beetles, and a detailed economic analysis showing the benefits of the sale to a few small local industries are not outweighed by the environmental and economic benefits of letting the forest ecosystem function naturally.
Thank you again for this opportunity to comment. We look forward to reviewing your analysis of the impacts of this project.
Sincerely,
Craig Axford
P.O. Box 129
Loa, UT 84747
The proposed action would result in a two part logging operation consisting of a demonstration project and a larger logging operation to be implemented after completion of the demonstration project. The UEC is troubled by the fact that both of these parts of the proposed action will enter roadless areas based on the criteria established within the draft Region 4 Desk Guide on Roadless Area Inventory and Evaluation.
The UEC calls on the Fishlake National Forest to document the effectiveness of logging as a beetle control tool. The scoping letter states that the purpose of the proposal is in large part to "minimize the risk of spruce beetle infestation and subsequent loss of the overstory component."
The scoping letter lists as a "secondary purpose" an effort "to provide forest products to resource dependent communities and industries in the local and regional area." We ask the Forest Service to include in its analysis detailed documentation showing exactly how many jobs and industries are dependent on forest products and industries. This analysis should compare the amount of jobs and revenue generated through recreation, clean watersheds and stable soils to that created through logging. In addition, the Forest Service should analyze trends in the rural Utah and western economies. This analysis must show that the benefits received through clean water, air, and an otherwise healthy forest environment are outweighed by the benefits of logging if economics are to be used as a partial justification for this action.
The analysis prepared for this project must include a detailed analysis of the impacts of the proposal to all MIS and TEPS species contained within and surrounding the project area. This should include the endangered Mexican spotted owl, northern goshawk and three-toed woodpecker among others.
Because of excessive entry into roadless areas the UEC calls on the Forest Service to abandon its proposal to log Thousand Lakes Mountain. In the event the Fishlake National Forest decides to move ahead with this proposal it must develop and EIS.
Program Director, UEC
