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St. Vrain Fuel Reduction Project, Boulder County, Colorado Taylor Mountain Area (Unit 6) (Letter to the Forest Service) |
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Glenn Casamassa, Forest Supervisor
Dr. Mr. Casamassa: We are writing to address forest management issues on the Taylor Mountain Unit, St. Vrain Fuel Reduction Project in the Arapaho and Roosevelt National Forests (ARNF), Boulder County, Colorado.
INTRODUCTION AND SUMMARY According to a Forest Service report on old-growth ponderosa pines (Huckaby Et al. 2003, page 1), “Old trees were historically a major component of montane forests in the Colorado Front Range. They were an integral part of the ecosystem. Now they are relatively scarce.” The Forest Plan (Record of Decision, p. 31) states that ponderosa pine represents less than one percent of the old-growth forests found on the ARNF. Old-growth ponderosa pine forests are valued for their biological diversity and provide key habitat for many species of wildlife. The rarity and biodiversity of these forests speak to the necessity of managing them with the utmost care. Indeed, the ARNF Forest Plan (p. 5) has a goal of increasing the acreage of old-growth and late successional forest areas through its forest management efforts. The Environmental Assessment for the St. Vrain Fuel Reduction Project states that (EA, p. 2-8) “Treatments would be designed to maintain or develop old growth characteristics and help to ensure the presence of these stands into the future.”
ISSUE: Destruction of Old-Growth Ponderosa Pine Forest Stands on the Taylor Mountain Unit near Allenspark, CO A sign posted at the beginning of Forest Road 330 (which bisects the treatment area) states that “Where old-growth conditions exist, they will be retained and emphasized” and “Retention of large trees will be favored in inventoried old-growth areas.” In direct contradiction of the Environmental Assessment (EA) and other planning documents, a large percentage of the larger trees in the old-growth, developing old-growth and mature ponderosa pine stands on the Taylor Mountain Unit have been cut. As a result old-growth forest stands have been diminished or destroyed. Why is the Forest Servicecutting down large fire-resistant, open-grown ponderosa pines in areas with little or no ladder fuels when there is so much forest nearby with a high density of young trees that is creating a fire hazard and could start crown fires? The Boulder Ranger District is going against the general consensus among land managers, forest ecologists, and conservationists about what constitutes true forest restoration and fuels reduction. They are logging old-growth pines in the guise of fuel reduction. We are outraged at this breach of trust and the destruction of this rare element in our forest that the Forest Service says they are committed to protecting. There is no justification for cutting these old-growth ponderosa pine trees and rare forest stands.
RESPONSE: We call on the Boulder District to stop cutting old-growth ponderosa pine on the Taylor Mountain Project and in any other fuel reduction projects in the Arapaho and Roosevelt National Forests where this is an issue. The old practice of high-grading the forest (removing the largest, healthiest, and often genetically superior trees) cannot be allowed to become part of fuel reduction projects. A stop order for cutting old growth should be issued for the St. Vrain Fuel Reduction Project and any other projects in the ARNF that are removing old-growth ponderosa pine from our forests. It is imperative that we save all old-growth ponderosa pine stands and protect old-growth development areas. Instead of marking trees to be cut on this project, the Forest Service is using a method called “designation by prescription” which provides general guidelines for cutting trees and leaves the selection of individual trees to be cut to the contractor. The task orders that the contractor are obligated to follow on this project do not include any requirement for protection of old-growth and mature stands and in fact direct the cutting of large ponderosa pines in some instances. Task orders to contractors should include protection for old-growth forest stands. The Taylor Mountain project is part of a larger treatment area of about 2500 acres, which includes future projects near Allenspark, Meeker Park, Johnny Park, Raymond, and Riverside. These guidelines need to be in place as the Boulder District plans and implements the rest of the St. Vrain Fuel Reduction Project and other fuel reduction projects on the ARNF.
COLLABORATION The Forest Handbook (2005) states that “While the enabling legislation does not specifically mention collaboration in stewardship contracts, the Secretaries of Interior and Agriculture have directed the Forest Service and the Bureau of Land Management to involve states, counties, local communities, and interested stakeholders in a public process to provide input on implementation of stewardship contracting projects. Effort should be made to involve a diversity of local interests and engage key stakeholders in collaboration throughout the life of the project, from project design through implementation and monitoring.” Both during the original scoping for this project in 2005 and since the announcement that the project had finally received funding this summer, local residents have voiced their concern about protecting old-growth ponderosa pine, fearing that the project would leave too few large trees. The Boulder District response in the EA (p. 1-7) was that “Treatments intended for this project are not targeting large trees for removal; however, some large trees could be removed to create gaps in the tree canopies.” This past summer when the issue was raised again we were told by the Planning Team Leader that protection of old-growth ponderosa pine was one of the main objectives of the project. Walking through the treatment area, there is no escaping the conclusion that large trees are absolutely being targeted. If there is to be true collaboration, then all parties have to have trust in the process. Our trust has been badly shaken by the implementation of this project, since the public was told that old-growth stands would be protected, but instead the large trees within them are being cut, damaging or destroying the old-growth ecosystem. The Boulder Ranger District, among other Districts, has signed a 10-year Stewardship Contract for implementing fuel reduction projects and many more projects are in process or in the pipeline for the Front Range. Because this is only the first year of this contract, there is an excellent opportunity to improve communications and develop methods to insure that Forest Service objectives are met for all fuel reduction and forest restoration projects. We support fuels reduction in ponderosa pine forests when—and only when—implementation is in accordance with the Forest Plan, other project planning documents, and good forest restoration practices. This project is part of a long-term planning project that involves many land management agencies and other groups in the Colorado Front Range, including the Front Range Round Table, the Front Range Fuels Treatment Partnership, the Colorado Forest Restoration Institute at Colorado State University, and the Community Collaborative Implementation Project. Many people in Front Range communities are committed to a successful application of forest restoration principles and amelioration of hazardous fuel conditions in our forests. We are among them. We hope to work with you and others on a resolution of the issues addressed in this memo. A more detailed analysis of the problems with the implementation of the St. Vrain Fuel Reduction Project, Taylor Mountain Unit, is attached to this letter (see below). Sincerely,
Dianne Andrews COPIES TO: Rick D. Cables, Regional Forester, Golden, CO, rcables@fs.fed.us Christine M. Walsh, Boulder District Ranger, cwalsh@fs.fed.us Mark Martin, Boulder District, Planning Team Leader, mlmartin@fs.fed.us Kevin Zimlinghaus, Boulder District Silviculturist, kzimlinghaus@fs.fed.us, Deanna Williams, Boulder District Wildlife Specialist, deannawilliams@fs.fed.us Boulder County Commissioners, Cindy Domenico, Ben Pearlman, Will Toor, commissioners@bouldercounty.org, 303-441-3500 Kirk Cunningham, Conservation Co-Chair, Sierra Club, Boulder, CO, kirk.cunningham@rmc.sierraclub.org Kirby Hughes, CO Conservation Co-Chair, Sierra Club, Boulder, kirby.hughes@rmc.sierraclub.org Rocky Smith, Forest Watch Campaign, Colorado Wild, Denver, CO, rocky@coloradowild.org Suzanne Jones, Regional Director, The Wilderness Society, Denver, CO, suzanne_jones@tws.org Greg Aplet, Senior Forest Scientist, The Wilderness Society, Denver, CO, greg_aplet@tws.org Tim Sullivan, The Nature Conservancy, Forest Health Advisory Council, Boulder, CO, colorado@tnc.org Paige Lewis, The Nature Conservancy, Boulder, colorado@tnc.org Senator Mark Udall, http://markudall.senate.gov/contact Senator Michael Bennett, http://bennet.senate.gov/contact/ Congressman Jared Polis, http://polis.house.gov/Contact/ State Representative Claire Levy, claire.levy.house@state.co.us
COMMENTS ON IMPLEMENTATION OF THE ST. VRAIN FUEL REDUCTION PROJECT, TAYLOR MOUNTAIN UNIT, NOVEMBER 2010 Dianne Andrews and Tom Andrews
Background We are local residents of the project area and plant ecologists with experience as a former member of a Forest Ecosystem Management Team (City of Boulder Mountain Parks and Open Space) and a former Forest Service employee (regional Research Natural Area ecologist). For the last several years we have been hiking this area frequently, collecting data on its natural history for the Boulder County Nature Association Eco-stewardship Project, and teaching a class on forest ecology here. We came to appreciate this area for its beautiful ponderosa pine forests and high biological diversity. The forest is a mix of many forest types, including stands of ponderosa pine, ponderosa pine and Douglas-fir, aspen, mixed conifer (limber pine, lodgepole pine, and aspen mixed with ponderosa pine and Douglas-fir), and grassy openings dispersed among the trees. Ponderosa pine is the dominant species in most of the treatment area, with the exception of limited lodgepole pine stands and aspen stands. Due to fire suppression ponderosa pines are invading some of the meadows, but some of the ponderosa pine forest is quite open with many large trees and snags. We were somewhat surprised to learn this summer that the area was scheduled for a fuels reduction project when so many other areas nearby are more in need of treatment. We have been in the forest recently monitoring the results of the ongoing 400-acre project near Taylor Mountain, part of the St. Vrain Fuel Reduction Project. After reading the planning documents, talking with Forest Service personnel, and walking the treatment area with them before the project started, we were stunned by what we found during the first week of implementation. (See photographs at www.wildlandart.com/oldgrowth.html).
ISSUE ONE. DESTRUCTION OF OLD-GROWTH PONDEROSA PINE FOREST STANDS AND OLD-GROWTH DEVELOPMENT AREAS
The Importance of Old-Growth Ponderosa Pine Forests and Restoration Forestry Old-growth ponderosa pine is a scarce resource throughout the western U.S., including Colorado. As Noss and others (undated) state, in a report on endangered ecosystems of the U.S., ponderosa pine ecosystems of the Intermountain West “have become some of the most imperiled major forest types. Selective logging of the best trees and fire suppression have been responsible for most of the degradation.” These forests are important not only because only a small fraction of the original acreage of this type remains, but also because of the biodiversity they support. According to a Forest Service report on old-growth ponderosa pines (Huckaby et al. 2003, p. 1), “Old trees were historically a major component of montane forests in the Colorado Front Range. They were an integral part of the ecosystem. Now they are relatively scarce.” The ARNF Forest Plan states that on the forest as a whole “Old growth is currently about 12 percent (108,900 acres) of major forest types. Two thirds of this acreage is spruce-fir, one third is lodgepole pine and only one percent is Douglas-fir and ponderosa pine. The current amount of Douglas-fir and ponderosa pine old growth is extremely low.” ARNF ROD at 31 Old-growth ponderosa pine forests provide key habitat for many species of wildlife. The rarity and biodiversity of these forests speak to the necessity of managing them with the utmost care. Indeed, the ARNF Forest Plan (p. 5) has a goal of increasing the acreage of old-growth and late successional forest areas through its forest management efforts. And the Environmental Assessment for the St. Vrain Fuel Reduction Project (EA, p. 2-8) states that “Treatments would be designed to maintain or develop old growth characteristics and help to ensure the presence of these stands into the future.” Conifer forests that depend on frequent fire, like ponderosa pine, “have declined not only from logging but also from increases in tree density and from invasion by fire-sensitive species after fire suppression. These kinds of change can cause the loss of a distinct ecosystem as surely as if the forest were clear-cut” (Noss Et al., undated). Restoration forestry (Noss and Cooperrider, p. 216) attempts to restore forests to a more natural condition by: · Managing the landscape for older forests by preserving existing old growth and other late-successional stands · Allowing many second-growth stands to mature · Placing managed stands on longer rotations · Retaining structural diversity, including snags and down logs, in managed stands
A report about increasing the area of old-growth ponderosa pine forests in Oregon (Henjum and others 1994) states that: To attain this goal, existing second-growth pine and isolated old-growth individuals must provide the cornerstones around which to rebuild the landscape. Any logging of remaining pine, except for thinning in overstocked stands, moves the landscape further from NRV [Natural Range of Variability]. (Even thinning may better be left to natural processes if it threatens other resident biotic components.)”
Definition of Ponderosa Pine Old-Growth for Arapaho and Roosevelt National Forests Old-growth ponderosa pine is characterized in the Forest Plan for the ARNF (Appendix B, p. 11-12) as sites dominated by: · The presence of large live trees (18”+ dbh), including 15 or more trees per acre 12”+ dbh (diameter at breast height (dbh) is measured at 4.5 feet from the base of the tree). [The official old-growth descriptions for the Rocky Mountain Region says 10 trees per acre at least 16” dbh for ponderosa pine old growth (Mehl 1992)]. · Presence of large snags (14”+ dbh), including 2 or more snags/acre 12”+ dbh · Presence of large fallen trees (14”+ diameter), including 3 or more per acre 12”+ diameter · Presence of multi-storied canopy · Overhead canopy closure over 20% Old-growth ponderosa pine stands in the Taylor Mountain treatment area exhibited many of these qualities before treatment began.
STATEMENTS FROM USFS PLANNING DOCUMENTS ABOUT OLD-GROWTH FORESTS: The Forest Plan for the Arapaho and Roosevelt National Forests (ARNF) and the Environmental Assessment (EA) for the St. Vrain Fuel Reduction Project (which includes the Taylor Mountain Area) state over and over again a commitment to protect old-growth ponderosa pine, as outlined below.
1. Old-Growth Retention and Enhancement The EA for the project tiers to the North St. Vrain Landscape Assessment (2003), which indicates management priority for old growth: “The intent in the ponderosa pine matrix would be less homogeneous in tree age and size, less density, and larger trees and snags across the landscape.” The Environmental Assessment contains the following passages related to old-growth ponderosa pine: “The Desired Future Condition for St. Vrain Project Area as defined in the National Forest Plan and the Healthy Forest Restoration Act, would exhibit the following characteristics related to vegetation condition and potential hazards of wildfire: · Forest health is enhanced and forest fuels and fire hazards are reduced resulting from active vegetation management. · Old-growth recruitment and retention is emphasized.” EA at 1-5
The EA states that as a result of treatment, “The percentage of old growth and their associated structures would increase across the landscape . . . Management is allowed in developing old growth areas as long as the treatment objective supports old growth development.” EA at 3-42
“Additionally, the proposed action would not foreclose future options for the long-term maintenance of old forest structural elements . . . .” EA at 1-7 “All old-growth ponderosa pine in treatment units will be maintained or enhanced as a result of the Proposed Action.” “Treatments would be designed to maintain or develop old growth characteristics and help to ensure the presence of these stands into the future.” EA at 2-8.
2. Inventoried Old Growth According to the EA, “The primary emphasis for treatments in Inventoried Old Growth units are to enhance and maintain old growth characteristics such as large trees, large down woody material, snags, and both vertical and horizontal forest structure.” EA at 2.6 The EA also states that “Trees to be removed would generally be smaller in size and from below the canopy to reduce the existence of ladder fuels capable of delivering fire to the tops of trees. Larger trees may be removed to create the gaps in the canopy, between individual trees and groups.” EA at 2-6
3. Old-Growth Development Areas “Within the mature forest structure stage is a portion inventoried as relatively close to becoming old growth, and termed “developing” old growth. The remainder of the mature forest stage is not considered close to becoming old growth.” ARNF FEIS at 205 The EA states that “old growth development areas are estimated to become old growth stands within the next century in the absence of a stand-replacing event.” EA at 3-41. “The primary emphasis for treatments in Old Growth Development Areas is to enhance old growth characteristics such as large trees, large down material, snags, and both vertical and horizontal forest structure in ponderosa pine stands. Stands would be treated to promote a future stand with all age and size classes of trees (i.e. seedlings, sapling/pole, mature). Treatments would be designed to develop old growth characteristics more rapidly and help to ensure the presence of these stands into the future. Generally, smaller diameter trees and competing species would be cut to remove them from competition, promote a healthier stand and reduce the potential for a crown fire event.” EA at 2-6 and 2-7
4. Retaining Larger Trees “Larger trees would generally not be removed except when providing a gap or space between the crowns of residual trees and groups of trees.” EA at 2-8
5. Thinning Smaller Trees “Trees to be removed would generally be smaller in size and from below the canopy to reduce the existence of ladder fuel capable of delivering fire to the tops of trees. Larger trees may be removed to create the gaps in the canopy, between individual trees and groups.” EA at 2-6 “The Proposed Action should also enhance these stands by removing smaller trees that compete with old-growth for water and nutrients.” “Fuel reduction treatments would target reducing ladder fuels, increasing the height between the ground and live branches of individual trees, and increasing the spacing between the crowns of trees.” EA Abstract, page 1 “Thinning would occur where overcrowded trees are causing significant fuel buildup, and where there is the potential for increased wildfire intensity and tree mortality.” EA 1-7 The EA states that the principal goals of the St. Vrain Fuel Reduction Project are “to maintain or enhance vegetation structure and to minimize the potential for sustained crown fire or crown fire initiation.”
Loss of Old-growth Ponderosa Pine during Project Implementation on the Taylor Mountain Unit
Contrary to the above objectives stated in Forest Service planning documents, this is what we have observed on site: 1. Old-growth recruitment and retention is not being emphasized on this project. Old-growth ponderosa pine is not being maintained or enhanced as a result of this project. 2. Larger trees are not being promoted across the landscape. Retention of large trees is not being favored even in inventoried old-growth areas. We have found that even in areas with trees smaller than 18” in diameter, the largest pines have been targeted, thus removing the very trees that would become old growth. 3. Smaller trees are not being thinned. Trees being logged are generally not smaller in size and from below the canopy to reduce the existence of ladder fuels capable of delivery fire to the tops of trees. Thinning is not helping to ensure the presence of old growth stands in the future. 4. Spacing between the tree crowns is occurring, but often at the expense of the many of the largest trees in the forest, and in some areas where thinning is unnecessary due to the openness of the forest. In one area, nearly all the largest ponderosa pine trees have been logged. In summary, many of the trees that have been logged were growing in the open or in small groups of trees, and most of them were healthy and in good reproductive condition, as shown by their full canopies and the large number of pine cones still clinging to their branches. Measurement of cut logs and tree stumps shows the contractors are repeatedly cutting many of the largest ponderosa pine trees in a stand, sometimes leaving smaller trees with poor form behind and decimating the old-growth forest stands. In the areas we have surveyed so far dozens of large ponderosa pines, from 18” up to 30” dbh, have already been cut. (Our measurements at the bottom of the cut bole differ negligibly from diameter at breast height.) The large trees that have been cut are considered to be the most fire-resistant trees in the forest. According to a 2004 report on the health of Colorado ponderosa pine forests (Lewis and others 2004) describes thinning from below as: “. . . the most common treatment used to reduce wildfire risk in ponderosa pine forests. This technique involves removing only small to mid-sized trees while leaving larger trees that are more resistant to fire. Thinning from below reduces both ladder and canopy fuels and lessens the chance that surface fires will climb into forest crowns and result in unnaturally intense or large wildfires.” Why is the Forest Service cutting down large fire-resistant open-grown ponderosa pines in areas where there is little ladder fuel when there is so much forest with a high density of young trees throughout the ARNF that is creating a fire hazard and could start crown fires? There is no justification for cutting these old-growth ponderosa pine trees and rare forest stands. Both during the original scoping for this project in 2005 and since the announcement that the project had finally received funding this summer, local residents have voiced their concern about protecting old-growth ponderosa pine, fearing that the project would leave too few large trees. The Boulder District response in the EA was that “Treatments intended for this project are not targeting large trees for removal; however, some large trees could be removed to create gaps in the tree canopies.” EA at 1-7. This summer when the issue was raised again we were told by the Planning Team Leader that protection of old-growth ponderosa pine was one of the main objectives of the project. Prior to implementation of this project, we visited other areas nearby that had been treated for fuel reduction near Bunce School Road and Gold Lake. In both of these areas we found that trees in old-growth stands trees had been logged and we expressed our concern to the District Planning Team Leader.
Multi-aged Forests The EA also states that “In some stands there would be the promotion of a future stand with all age and size classes of trees (i.e. seedlings, sapling/pole, mature). Treatments would be designed to maintain or develop old growth characteristics and help to ensure the presence of these stands into the future. Generally, the smaller diameter trees and competing species (i.e. Douglas-fir) would be cut to promote a healthier stand, reduce ladder fuels, and reduce the potential for a crown fire event.” EA at 2-8. The goal of maintaining or restoring a multi-aged forest, with representation across many age classes, should never be used as an excuse for cutting the largest trees in a stand. The largest trees are the most difficult to obtain and retain, while smaller trees often can be produced via vegetation treatments.
Forest Structure and Wildfire Hazard Reduction One of the principal goals of the St. Vrain Fuel Reduction Project is “to minimize the potential for sustained crown fire or crown fire initiation.” According to the EA, “Comparisons of current forest conditions in the St. Vrain Fuel Reduction Project Area against the desired future conditions outlined in the 1997 Plan indicate a need to implement projects that will reduce and alter fuel conditions. A survey of the area shows that existing conditions left untreated increase the potential for a crown fire – the most dangerous and destructive class of wildland fire. Therefore, vegetative treatments designed to reduce the potential for crown fire should be considered.” EA 1-4. “. . . the potential for crown fire initiation and spread should be drastically reduced within treated stands and immediately surrounding treated stands.” EA 3-46 and 3-47 Kaufmann and others (2006), in a report on Historical Fire Regimes in Ponderosa Pine Forests of the Colorado Front Range, and Recommendations for Ecological Restoration and Fuels Management, describe the difficulty of using vegetation management to reduce fire hazard in higher elevation ponderosa pine forests:
“ . . . Effective reduction in fire risk at these higher elevations could potentially require more forest removal (and prevention of regeneration) than is either economically feasible or socially acceptable. Thus, we should not lead the public to believe that we can effectively or cheaply prevent all high-severity fires, either by fuels treatments or by suppression efforts.” (p. 14)
They also point out that thinning can potentially increase the danger of crown fires: There is abundant evidence that logging (e.g., removal of larger trees or thinning of smaller ones) and associated soil disturbances may enhance establishment of new ponderosa pine seedlings. Thus, depending on initial stand structure, thinning could potentially result in a new stand structure in which surface fires are actually more likely to become crown fires. (p. 14) Even in areas of the Taylor Mountain Unit with open grown ponderosa pine stands and meadows (units 6f and 6g) that “are not expected to exhibit crown fire behaviors” many of the largest trees have been logged. Attempts to reduce wildfire hazard should not be used as a justification for cutting the largest trees in forest stands and may have unintended consequences. Monitoring is essential for increasing our understanding of the impacts of these fuel reduction projects on wildfire.
Bark Beetles During a pre-treatment field trip to the Taylor Mountain unit with local residents of the area and Boulder District staff, we discussed the fuel reduction effort with the District silviculturist and found that he was actually in favor of targeting large trees for removal. He remarked that bark beetles were going to kill them anyway. Cutting down old growth trees to “save” them from a potential bark beetle attack is a spurious argument. There is no way of knowing if or when bark beetles will strike above the endemic level, or which ponderosa pines or how many will be attacked. So far, bark beetles have killed only a few ponderosa pine trees in the Taylor Mountain area. Even if some large trees are killed by beetles they would still continue to play an important role in the ecosystem by providing cavities and perches for nesting birds and small mammals.
ISSUE 2. PROBLEMS WITH “DESIGNATION BY PRESCRIPTION” Instead of marking trees to be cut, the Forest Service is using a method called “designation by prescription” which provides general guidelines for cutting trees and leaves to the contractor the selection of individual trees to be cut. The task orders that the contractor is obligated to follow on this project do not include any requirement for protection of old-growth and mature stands and in fact direct the cutting of large ponderosa pines in some instances (see below). The USFS Renewable Resources Handbook in Forest Handbook (2005) (sec. 60.1), “allows for the use of designation of trees by description and designation of trees by prescription. These methods must be used in a manner that ensures that the amount of material removed is verifiable and accountable.” The method used on this project is Designation by Prescription, which is supposed to be used for noncommercial material or for low value commercial material removed from the forest. Selection of trees to be cut is made by the contractor, following prescriptions spelled out in the Task Order for the project. How does removing many, if not most, of the largest trees in the forest qualify as “noncommercial” value? Not only are these the most important trees in the forest ecologically, they are also the most valuable economically. In Designation by Description, which can be used for commercial and noncommercial material removed from the forest, the selection of trees to be cut, or left, is not left to the discretion of contractor, but is designated by description by Forest Service personnel. Why wasn’t this type of designation used for this project?
The Taylor Mountain Task Order (TMTO), which the Boulder District wrote to provide direction to the contractor, differs substantially from the objectives outlined in the EA for the St Vrain Fuels Reduction Project. These differences are outlined below. To more fully show the serious discrepancy between implementation and the original guidelines for this project, it is useful to examine some of the statements in the original the Forest Plan and the Task Order. The Forest Plan for the ARNF provides overall direction for future management activities on National Forest System land. Under Management Emphasis Goals and Objectives this document states: “In ponderosa pine and Douglas-fir forests, manage existing old growth and mature forests to retain and encourage old-growth qualities.” Plan at 4.
In the Forestwide Direction, Operational Goals, Standards, and Guidelines: “Retain all existing Douglas-fir and ponderosa pine old growth and increase the amounts in the future.” Plan at 32.
The Forest Plan is also specific for the North St. Vrain Geographic Area when it specifies under Goals and Desired Conditions: “Emphasize old-growth recruitment and retention.” Plan at 97.
The specific prescription from the TMTO for Unit 1 (which is similar to the language for Unit 2) contains the following selection criteria (page 4): 2. Species preference of healthy leave trees: limber pine, aspen, Douglas-fir, Engelmann spruce, ponderosa pine, and lodgepole pine. 3. Identify healthy Douglas-fir and limber pine trees (>40% live crown). Cut ponderosa pine whose crowns over top the healthy tree. 4. Identify areas with ponderosa pine regeneration/saplings and remove overstory tree regardless of size if regeneration/sapling tree(s) is located beneath or within 5’ of the overstory crown.
The EA divided Unit 6 (Taylor Mountain area) into 8 separate subunits, including subunit 6e, which is 53 acres of inventoried old-growth ponderosa pine. The TMTO only divides Unit 6 into two units and makes no mention of the existence of old growth or any provisions for protecting the large ponderosa pine trees that occur in the inventoried old growth area. In summary, 1. The TMTO actually incorporates specific language that gives species preference for leave trees to Douglas-fir over ponderosa pine, which is contrary to good forest management practices in these stands. 2. The TMTO specifies that ponderosa pines that overtop healthy Douglas-firs and limber pines should be cut. This directive alone could lead to the destruction of old-growth and developing old-growth ponderosa pine. 3. The TMTO specifies that overstory trees regardless of size are to be removed where there are regeneration/sapling trees beneath or within 5’ of the overstory crown. This is another misguided prescription for cutting large trees in the project area. Even if the logging contractor had crafted this language in the TMTO, it could not have been more explicit in directing the contractor to maximize the number of large trees to cut and thus maximize the amount and value of marketable timber. The net result has been that this supposed fire reduction project is being implemented as if it was a normal timber sale designed to maximize contractor profits and to neglect the original purposes of fire reduction and especially old-growth retention. As implemented, much of this project represents an egregious example of forest high-grading.
Task Orders to Contractors Should Include Protection for Old-Growth Forest Stands Last summer one of the first issues we raised when we called the Forest Service to inquire about this fuel reduction project had to do with diameter limits on the size of trees that could be cut. The response was that there were no limits in place. But we were told by the Planning Team Leader that protection of old-growth ponderosa pine was one of the main objectives of the project, as confirmed in the planning documents, so we were expecting that most of the old-growth ponderosa pine would remain, with only a large tree here or there removed under special circumstances. Since the opposite has occurred—a large percentage of the larger ponderosa pines have been cut and only a few have been left—we are requesting that very specific guidelines for protection of old growth stands be included in the Task Orders that the contractors follow. Unless these stands and trees are identified and marked, or unless there is a specific prohibition against cutting the largest trees in a stand (or any trees over a certain dbh), how can they be protected? As Huckaby and others (2003) write, “unless the old trees are explicitly identified and protected, forest restoration activities could inadvertently damage or destroy many old trees.” Currently, the task orders are so broad and so at odds with planning documents that requirements and goals in the legal documents cannot be met. Specific guidelines are needed for all projects on the ARNF for forest restorations, wildfire hazard reduction, and fuel reduction, including the protection of old-growth forests and associated wildlife. The Taylor Mountain project is part of a larger treatment area of about 2500 acres, which includes future projects near Allenspark, Meeker Park, Johnny Park, Raymond, and Riverside. These guidelines need to be in place as the Boulder District plans and implements the rest of the St. Vrain Fuel Reduction Project.
ISSUE 3. WILDLIFE SPECIES DEPENDENT ON OLD-GROWTH PONDEROSA PINE FORESTS COULD BE SIGNIFICANTLY AFFECTED BY LOSS OF HABITAT IN THE TREATMENT AREA Old-growth ponderosa pine forests support high levels of biological diversity. With the exception of riparian habitats, ponderosa pine forests support the highest diversity of birds in Colorado (Kingery, 1998, p. 27). Mammal diversity is also high (Armstrong, 2008, p.16-20). Certainly there is no question that the logging of so many mature and old-growth ponderosa pines on the Taylor Mountain Unit will impact wildlife species dependent on late successional and old-growth forests. The only question is how serious the impact will be. The ARNF Forest Plan (p. 17) outlines the following goals for protecting sensitive wildlife species: “Restore, protect, and enhance habitats for species . . . appearing on the regional sensitive species list to contribute to their stabilization and full recovery.” The North St. Vrain Landscape Assessment (2003) states that “Old Growth Retention areas are intended to serve as habitat for late successional related species, with natural ecological processes allowed to function to the extent possible.” Mature ponderosa pines in good reproductive condition are an important part of the forest food web, providing seed for many species of birds and small mammals. Some species are almost totally dependent on ponderosa pine seeds during part or all the year. Many of these seed eaters are, in turn, important prey for predators like hawks, owls, and coyotes. The logging of these large trees, which are the major seed producers in the forest and provide food, as well as nesting areas, for many species, will probably have a significant negative impact on wildlife in the Taylor Mountain Unit. Many wildlife species have been designated by the ARNF as Sensitive Species, Management Indicator Species, and species dependent on old-growth ponderosa pine forests, as listed below. Sensitive species occurring in the Taylor Mountain Unit are Northern Goshawk, Olive-sided Flycatcher, and possibly Flammulated Owl. Management Indicator Species. Since not all species can be monitored directly, Management Indicator Species are selected that are characteristic of the Management Indicator Communities (in this case old-growth ponderosa pine). Species are chosen that will reflect changing conditions within each community type. Management Indicator Species for the St. Vrain Fuels Reduction Project that occur in the Taylor Mountain Unit include elk, mule deer, Hairy Woodpecker, Pygmy Nuthatch, Warbling Vireo, Wilson’s Warbler, and Mountain Bluebird. Species known to be dependent on late successional and old-growth ponderosa pine forests in the Taylor Mountain Unit include Pygmy Nuthatches, Red Crossbills, Western Bluebirds, Williamson’s Sapsuckers, Flammulated Owls, and Northern Goshawks, as well as Abert’s squirrels. According to the EA (p. 3), “the overall goal of retaining and enhancing old-growth forest characteristics within treatment units will have a beneficial effect to [wildlife] over the long term.” Does the ARNF have the resources to track changes in populations dependent on old-growth ponderosa pine? How will we know the impacts of treatment unless we support effective monitoring programs?
ISSUE 4. COMMUNICATION WITH THE PUBLIC When so many years pass between the initial scoping for the project (2005 in this case) and implementation of the project, we request that the District office give the public notice well before implementation of the project begins (which was, in this case, in June) when boundary units for the project were being marked. The only notice we are aware of was published in the Allenspark Wind in October. Many members of the community may have been unable to participate in the original scoping and/or may have moved to the area since 2005, so it would be helpful to have a summary of each project posted on the ARNF website and perhaps published in local newspapers and newsletters. Members of the public should have access to documents that explain what is actually going to happen on the ground during implementation of the project. Task Orders to the contractors should be translated into language that is easily understandable by non-foresters and should be correlated with all aspects of “desired future conditions” so implementation can be evaluated against the goals of the project. On Stewardship Contracts, forest personnel must “Calculate on a monthly basis the value of forest products removed against the value of services rendered to determine the amount of revenues and expenses. Submit a monthly report to the Albuquerque Service Center’s Receivables and Collections Branch of the cumulative balances for both the value of services rendered and the value of forest products removed.” These monthly reports should be posted on your website.
ISSUE 5. COLLABORATION The Forest Handbook (2005) states that “While the enabling legislation does not specifically mention collaboration in stewardship contracts, the Secretaries of Interior and Agriculture have directed the Forest Service and the Bureau of Land Management to involve states, counties, local communities, and interested stakeholders in a public process to provide input on implementation of stewardship contracting projects. Effort should be made to involve a diversity of local interests and engage key stakeholders in collaboration throughout the life of the project, from project design through implementation and monitoring.” If there is to be true collaboration, then all parties have trust in the process. Our trust has been badly shaken by the implementation of this project, since the public was led to believe that old-growth stands would be protected, but instead the large trees within them are being cut, damaging or destroying the old-growth forest ecosystem. The Boulder Ranger District, among other Districts, has signed a 10-year Stewardship Contract for implementing fuel reduction projects and many more projects are in process or in the pipeline for the Front Range. Because this is only the first year of this contract, there is an excellent opportunity to improve communications and develop better methods to insure that objectives are met for all fuel reduction and forest restoration projects.
CONCLUSION The result of the Taylor Mountain Fuel Reduction Project is not the retention of old-growth ponderosa pine, but its destruction. We are disheartened and angry at the destruction of this rare element in our forest that the Forest Service says they are committed to protecting. Many large ponderosa pines that could have lived hundreds of additional years, providing shelter and nourishment for many forest inhabitants, have been removed from the forest. It is imperative that we save all remnants of old-growth and developing old-growth ponderosa pine, as well as the largest trees in younger ponderosa pine stands. We call on the Boulder District to stop cutting old-growth ponderosa pine on the Taylor Mountain Unit and in other fuel reduction projects in the Arapaho and Roosevelt National Forests. We support fuels reduction in ponderosa pine forests when—and only when—implementation is in accordance with the Forest Plan, the project planning documents, and good forest restoration practices. This project is part of a long-term planning project that involves many land management agencies and other groups in the Colorado Front Range, including the Front Range Round Table, the Front Range Fuels Treatment Partnership, the Colorado Forest Restoration Institute at Colorado State University, and the Community Collaborative Implementation Project. Many people in Front Range communities are committed to a successful application of forest restoration principles and amelioration of hazardous fuel conditions in our forests. We are among them. We hope to work with you and others on a resolution of the issues addressed in this memo.
REFERENCES Arapaho and Roosevelt Nationals Forests. 1997 Revision of the Land and Resource Management. U.S. Department of Agriculture, Forest Service, Rocky Mountain Region. Armstrong, D.M. 2008. Rocky Mountain Mammals. Third Edition. University Press of Colorado, Boulder, CO. Barnes, B. V., Et al. 1998. Forest Ecology. Fourth Edition. John Wiley and Sons, New York, NY. Boulder Ranger District, Arapaho and Roosevelt National Forests. North St. Vrain Landscape Assessment. Boulder, CO, September 2004. Forest Service Handbook. 2005. Renewable Resources Handbook. Chapter 60, Stewardship Contracting. U. S. Forest Service. National Headquarters, Washington, D. C. Graham, R. T., S. McCaffrey, and T. B. Jain, technical editors. 2004. Science basis for changing forest structure to modify wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. Henjum, M. G. Et al. 1994. Interim protection for late-successional forests, fisheries, and watersheds: National Forests east of the Cascade crest, Oregon and Washington. Wildlands Society, Bethesda, Maryland. Huckaby, Laurie S., Et al. 2003. Identification and Ecology of Old Ponderosa Pine Trees in the Colorado Front Range. Gen. Tech, Rep. RMRS-GTR-110. Fort Collins, CO: U. S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. http://www.fs.fed.us/rm/pubs/rmrs_gtr110.html Kaufmann, Merrill R., Thomas T. Veblen, and William H. Romme. 2006. Historical Fire Regimes in Ponderosa Pine Forests of the Colorado Front Range, and Recommendations for Ecological Restoration and Fuels Management , Front Range Fuels Treatment Partnership Roundtable, findings of the Ecology Workgroup. www.frftp.org/roundtable/pipo.pdf Kaufmann, M. R., W. H. Moir, and W. W. Covington. 1992. Old-Growth Forests: What Do We Know About Their Ecology And Management In The Southwest And Rocky Mountain Regions? In Old-Growth Forests in the Southwest and Rocky Mountain Regions: Proceedings of a Workshop, M. R. Kaufmann, Et al., technical coordinators. Rocky Mountain Forest and Range Experiment Station, Forest Service, USDA, Fort Collins, Colorado. Kingery, H.E., editor. 1998. Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership and Colorado Division of Wildlife. Distributed by Colorado Wildlife Heritage Foundation, Denver, Colorado. Lewis, P., M. R. Kaufmann, L. S. Huckaby and D. Leatherman. 2004 Report on the Health of Colorado’s Forests. Colorado State Forest Service and Colorado Department of Natural Resources, Division of Forestry. Colorado State University Publications, Fort Collins, CO. Noss, R. F., E. T. LaRoe III, and J. M. Scott. Undated. Endangered Ecosystems of the United States: A Preliminary Assessment of Loss and Degradation. National Biological Service. http://biology.usgs.gov/pubs/ecosys.htm U.S. Forest Service, Boulder Ranger District. 2005. Environmental Assessment for St. Vrain Fuel Reduction Project , Arapaho and Roosevelt National Forests http://www.fs.fed.us/r2/arnf/ |
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