At the behest of the logging industry, the San Juan National Forest on March 17 published a Draft Environmental Impact Statement (EIS) rationalizing the largest timber sale ever in southwest Colorado.  Statewide, the Forest Service is proposing to “salvage” log trees within areas of almost every large forest fire of summer 2002 despite overwhelming scientific research demonstrating the likelihood of significant impacts – post-fire salvage logging may be especially harmful as watersheds, soils, vegetation, and wildlife are in a vulnerable condition following fire.  The Missionary Ridge timber salvage sale proposes an outrageous 20 million board feet (MMBF) of logging – 6 MMBF of aspen and 13.8 MMBF of spruce, fir, and ponderosa pine on over 4,000 acres, as well as the reconstruction or maintenance of between 55 and 90 miles of roads.  This logging, in clearcuts of over a square mile, equates to 4,000 logging truck loads within a mere 3 – 6 months (visualize loaded logging trucks stretching from Durango to Bayfield, and back!).  The proposed logging would provide a spike in timber supply requiring the timber industry to hire additional personnel and increase mill and timber transport capacity, engendering demand for unsustainable logging levels following completion of the salvage logging.

According to the Draft EIS, the project meets Bush’s euphemistically titled “Healthy Forest Initiative ”. Yet the timber sale has little to nothing to do with healthy forests, but rather is designed solely to “maximize the output of timber”.  Other secondary timber sale rationale, including reducing threat of future fires in the burned area, are unsupported by the body of scientific research.  A Forest Service study commissioned to refute growing scientific consensus on the impacts of post-fire salvage logging conceded that there was “little to no evidence” that post-fire salvage removal of trees limits the intensity of future fires.  Yet the timber sale has little to nothing to do with healthy forests, but rather is designed solely to “maximize the output of timber”.  Other secondary timber sale rationale, including reducing threat of future fires in the burned area, are unsupported by the body of scientific research.  A Forest Service study commissioned to refute growing scientific consensus on the impacts of post-fire salvage logging conceded that there was “little to no evidence” that post-fire salvage removal of trees limits the intensity of future fires.

Water Quality Impacts Understated

Durango, Bayfield, and Ignacio all rely on the burned area for their water supply.  While the fire itself is bringing water quality impacts, the Draft EIS uses a completely flawed analysis to conclude that logging will not further harm water supplies and recreation opportunities:

• The erosion analysis ignores the presence, much less the reconstruction and maintenance, of 55 to 90 miles of roads, as well as 5 miles of “temporary” road construction, despite consensus among a half dozen scientific studies that show roads are, by orders of magnitude, the major contributor to erosion, sedimentation, and water quality impacts.  It also uses assumptions erroneously derived from scientific studies or simply entirely without basis.
• While the Draft EIS predicts that 60% of the 110+ logging units will increase erosion, the 40% that supposedly reduce erosion are based on practices (such as cross-slope skid trails and the lop and scatter of logging debris) never demonstrated to be effective  or simply unnecessary (such as the breakdown of water repellent burned soils when they are breaking down naturally anyway).
• The Forest Service’s preferred alternative proposes to log on 479 acres of debris flow hazard areas despite the recommendations of the consultants hired to predict erosion. 
• The preferred alternative proposes logging on at least 1,221 acres, or 30% of logging acreage, of moderate-severe, high, or severe erosion hazard areas, ignoring the Best Management Practices that the Forest Service promises will minimize impacts.
• With another salvage timber sale in NW Colorado, the Forest Service surreptitiously decided to label trails as roads for the purpose of hauling logs on them.  With Missionary Ridge, a roads assessment – critical to determine the maintenance, reconstruction, or even construction needs of current or temporary roads – is being conducted “concurrent with the EIS”.  In other words, the Forest Service doesn’t even know what condition roads are in, nor can the public provide input on this most critical component of erosion.

Scientific Research and Other Impacts Ignored

The Forest Service is failing to heed lessons learned elsewhere.  Following extensive salvage logging in the 1990s, researchers recommend that salvage logging by any method be prohibited on sensitive sites , including “…in severely burned areas, on erosive sites, on fragile soils, in roadless areas, in riparian areas, on steep slopes, or any site where accelerated erosion is possible, [and] in watersheds with existing serious sedimentation problems.”  In a response to these recommendations, Forest Service researchers found no support for claims that post-fire logging results in no more environmental damage than logging of live trees.  The Missionary Ridge Draft EIS ignores these conclusions altogether, ignoring the most prominent research altogether.  Practically every single logging unit proposed on Missionary Ridge violates principles suggested by well respected researchers in the well known Beschta Report and other scientific studies.  For instance, over 80% of the logging units are on severely burned areas, and many are on erosive sites as determined even with the flawed Draft EIS.

Aspen is already sprouting in burn areas that should again become beautiful forest in 15 to 20 years.  The Draft EIS acknowledges that clearcut logging will facilitate access for cattle, elk, and deer that prefer aspen sprouts above all other forage, yet ignores the potential consequence of turning logged areas into permanent clearcuts.  Burned areas, contrary to notions promoted by the timber industry, provide critical habitat for many wildlife species.  Geographically and temporally spaced burned forest is critical for the three toed woodpecker for instance, yet logging and fire suppression to preserve forests for their timber have driven this rare species onto the sensitive species list – a step shy of the endangered species list.

Local Economic Impacts Belittled in Favor of the Timber Industry

The Forest Service concludes that benefits to the timber industry outweigh impacts to Durango’s recreation and tourism based local economy.  Yet according to the Draft EIS, roads may be closed and camping opportunities eliminated.  The Draft EIS concludes that hunter numbers – a backbone of the economy in the fall – will be reduced by more than the 50%, yet given the Forest Service’s underestimation of impacts and  logging truck numbers, this may well be all 7,500 or so hunters expected .  The Draft EIS even suggests that the Vallecito area roads will be closed for the summer and fall altogether.  The Draft EIS meanwhile fails to perform any actual analysis of visual quality impacts at all.  Can La Plata County’s tourism and recreation based economy handle another summer of destroyed business?

The Draft EIS concludes that 3,000 logging trucks would be required to haul the timber, yet their own data shows that 4,000 would be needed.  The Forest Service incorrectly states that “only” 10 logging trucks / day (20 round trips) would be needed.  Over 6 months, the logging would require 22 trips / day.  If timber industry demands  that logging occur by early summer are factored, 66 trips / day (132 round trips) would be needed.  The Draft EIS’s conclusion of only a 2% increase in traffic on the East Animas Road is clearly meant to mollify mountain bikers, road bikers, hikers, and business owners that may be impacted by tremendous increases in dangerous logging truck traffic.  Meanwhile, logging trucks are expected on CR 501 by Bayfield high school in the morning and afternoon when students are going to and from school.

Write your letter to the Forest Service by May 5, 2003:

David Dallison, Timber Program Leader, EIS Coordinator
USDA Forest Service
15 Burnett Court
Durango, CO 81301

Make some or all of the following points.  The Forest Service:

• must quit underestimating impacts to Durango’s recreation and tourism based economy in favor of short-term benefits for the timber industry,
• must acknowledge tremendous scientific consensus, as outlined in the Beschta report and other studies, and then drastically reduce the scope of logging proposed,
• should enjoin logging in any inventoried Roadless Areas, as well as any currently unroaded areas that have not yet been identified by the Forest Service,
• must acknowledge limited, if not non-existent, justification for salvage logging based on the hypothesis of preventing re-burn of already burned areas,
• should incorporate significant control areas to assess the impacts of proposed logging,
• should guarantee adequate funding for long-term monitoring to ensure effectiveness of mitigation and no unintended consequences,

• should assess the efficacy (or more likely lack thereof) of outrageously expensive fire suppression efforts.

If the choice is between rushing a shoddy, incomplete, and erroneous assessment of likely impacts from the proposed logging, or performing no logging at all (as stated by the Forest Service), then the Forest Service should choose the no logging alternative.

Please also write letters to the Durango, Bayfield, and Ignacio City Councils, as well as the Durango Herald:

Durango City Council 949 E. 2nd Ave. Durango, CO 81301	Ignacio Town Council 540 Goddard Ave. Ignacio, CO 81137
Bayfield Town Council 11 W. Mill Bayfield, CO 81122	Durango Herald letters@durangoherald.com 1275 Main Avenue Durango, CO 81301

Colorado Wild itself submitted or signed on to other groups' detailed comments on most of these projects, for instance, with scoping comment on the Million Fire . We cited considerable literature indicating that this fire salvage project will provide no benefit, and will likely cause considerable problems, especially soil erosion.  Colorado Wild also drafted and submitted comments to Regional Forester Rick Cables regarding the above post-burn salvage logging sales proposed statewide.  Our letter outlined how the body of scientific research strongly suggests significant, negative environmental impacts from post-burn salvage logging.  In sum, our letter called for the Regional Forester to instruct each National Forest considering salvage logging proposals to:

• avoid logging in any inventoried Roadless Areas, as well as any currently unroaded areas,
• incorporate all the recommendations by Beschta, MacIver and Starr, and wait for the recommendations to be made by the Forest Service’s Hayman fire study team,
• acknowledge limited, if not non-existent, justification for salvage logging based on a re-burn hypothesis or limitation of insect infestations,
• incorporate significant control areas to assess the impacts of salvage logging operations, and assess the efficacy of fire suppression efforts,
• consider and assess and select a Forest Restoration and Community Protection Alternative, and
• vastly reduce the scope of proposed logging to that which the current Colorado timber industry can accommodate without any increase in mill and timber transport capacity or personnel.

 
Many groups, including the Land and Water Fund of the Rockies, Center for Native Ecosystems, White River Conservation Project, Colorado Environmental Coalition, The Wilderness Society, and American Lands Alliance signed on to our letter.  The letters were cc’d to Congressmen Scott McInnis, Tom Tancredo, and Mark Udall.