Christine Walsh
Boulder Ranger District
2140 Yarmouth Ave.
Boulder, CO 80301
cwalsh@fs.fed.us 

Glen Casamassa
Arapaho-Roosevelt National Forest
2150 Centre Ave. Bldg E
Ft. Collins, CO 80526-8119
gcasamassa@fs.fed.us      

December 7, 2010

Dear Ms. Walsh and Mr. Casamassa,

I am writing to express concern about implementation of the St. Vrain Fuel Reduction Project in the Taylor Mountain area east of Allenspark. I visited the area in late November with some local residents. While in what we believe was unit 6e (changed to units 1 and 2 in the Task Orders for the units in question), what we saw was alarming:  a majority of the large trees had been cut in a stand of ponderosa pine old growth or developing old growth. The stand was not especially dense, as it had some openings and moderate crown spacing between clumps of mature trees. There was little ladder fuel, in the form of smaller trees and tall shrubs immediately adjacent to larger trees, that could have carried fire into the crowns of the larger trees. Where there was ladder fuel, it had not been cut

As you know, mature ponderosa pine have thick bark, which makes them resistant to low intensity fires. Thus relatively few of them would need to be removed to reduce any fire threat to the subdivision which is adjacent to the units on their south side. Many of the trees cut were several hundred yards from the subdivision, all of which is downhill from the cutting units. Cutting trees well away from homes does not provide much additional fire protection for the structures.

The stands in question are likely old growth ponderosa pine.  The Regional description for Front Range ponderosa pine old growth is found in Mehl, 1992. The characteristics listed there are mostly met in the Taylor Mountain units. Clearly, these stands have more than 10 trees with a diameter at breast height (dbh) of at least 16 inches, with a variation in tree diameter. Tree ages for the larger trees likely exceed 200 years, and there is evidence of decadence. It is also clear that at lest some of the trees in the upper canopy are growing slowly, as evidenced by their flat-topped crowns.

Even if the stands in unit 6e/1 and 2 in the project area are not considered to be old growth, they are almost certainly developing old growth. In any case, due to their rarity (see below), they should be protected.

Cutting the large trees in the old growth stand contradicts direction at multiple levels. The environmental assessment (EA) for the project states that a desired future condition for the project is that “[o]ld growth recruitment and retention is emphasized”. EA at 1-4. Forest Plan direction for the St. Vrain Geographic Area, in which the project is located, also emphasizes old growth recruitment and retention. Plan at 97.

The EA also states 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.

More than “some” large trees were cut, as it appeared a majority of the trees 15 inches dbh and over  had been cut, a great deal more than would be needed to reduce fuel or create gaps in the canopy. As stated above, there were already many gaps in the canopy prior to cutting. It is clear that large trees were targeted for removal, as they were the great majority of trees that were removed.

The implementation of the Taylor Mountain units also violates the following Forest Plan direction:

Retain all existing Douglas-fir and ponderosa pine old growth and increase amounts in the future.  . . .

Within existing ponderosa pine and Douglas-fir old-growth stands that are known or discovered, either exclude vegetation treatments or reduce fire hazards using prescribed fire or mechanical means if sites are at risk from fire (e.g. removal of encroaching Douglas-fir regeneration in ponderosa pine old growth sites).

Plan at 32.

This is reinforced by the following from the project 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.  . . .

Larger trees would generally not be removed except when providing a gap or space between the crowns of residual trees and groups of trees.  . . . 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. . . .

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, 2-7.

There were scattered Douglas-fir trees in the units we visited, but very few had been cut. There were small, scattered areas with ladder fuel of Douglas-fir and ponderosa pine, but very little of it had been cut.

It is our understanding that implementation of the Taylor Mountain units is part of a project funded under the Collaborative Forest Landscape Restoration Program (CFLRP). As such, it must comply with legal requirements, including the following

 (b) Eligibility Criteria- To be eligible for nomination . . . ., a collaborative forest landscape restoration proposal shall—

  (1) be based on a landscape restoration strategy that-- . . .

      (D) fully maintains, or contributes toward the restoration of, the structure and composition of old growth stands according to the pre-fire suppression old growth conditions characteristic of the forest type, taking into account the contribution of the stand to landscape fire adaptation and watershed health and retaining the large trees contributing to old growth structure;

     (E) would carry out any forest restoration treatments that reduce hazardous fuels by--

         (i) focusing on small diameter trees, thinning, strategic fuel breaks, and fire use to modify fire behavior, as measured by the projected reduction of uncharacteristically severe wildfire effects for the forest type (such as adverse soil impacts, tree mortality or other impacts); and

        (ii) maximizing the retention of large trees, as appropriate for the forest type, to the extent that the trees promote fire-resilient stands; . . .

 Omnibus Public Land Management Act, P. L. 111-11, Title IV, section 4003.

 In spite of all of the above, the Forest Service has not protected old growth stands in the Taylor Mountain area. In fact, the Task Orders for the area even favor cutting larger ponderosa pine:

 The “designation by prescription” for both cutting units includes the following selection criteria:

Species preference of healthy leave trees:  limber pine, aspen, Douglas-fir, Engelmann spruce, ponderosa pine, and lodgepole pine.

Identify healthy Douglas-fir and limber pine trees (>40% live crown).  Cut ponderosa pine whose crowns over top the healthy tree.

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.

Task Order at 4.[1]  If implemented as designed per the EA, the Taylor Mountain units would likely have complied with all of the applicable direction described above. As actually implemented, they most clearly do NOT comply. Why did the Forest Service write the above prescriptions, in direct contradiction to direction found in the Forest Plan, project NEPA documentation, and law?!

The fact that insects could kill the large trees in the future is no excuse for cutting them now.  It is possible that mountain pine beetles (MPB) will attack and kill some or most of the large diameter ponderosa pine trees in the Taylor Mountain area. But this is far from a certainty. And even if a high level of future mortality was assured, it would be no excuse for cutting the trees now. There is no reason to prematurely terminate or damage the functioning of the old growth ecosystem here. Even if the trees were killed, they would continue to play a role in the ecosystem, as snags and future down dead material (coarse woody debris), which has many functions, including slow decay into new soil. Logging, on the other hand, removes biomass from the ecosystem. Finally, cutting some of the ponderosa pines prior to MPB attack is not likely to save the remainder if MPB build to a high population level.

Ponderosa pine old growth stands are rare on the Front Range. In addition to violating Forest Plan, project, and legal direction, the cutting of ponderosa pine old growth or developing old growth is very troubling because it is so rare on the Front Range. The Final Environmental Impact Statement (FEIS) for the Forest Plan shows that there is only 1300 acres of ponderosa pine old growth on the Arapaho-Roosevelt National Forest, which is less than one percent of this timber type and is “possibly below the [range of natural variability]”. FEIS at 207. There is another 300 acres of developing old growth in this timber type, with a note that a more complete inventory would likely show additional ponderosa pine within 100 years of becoming old growth. Id.

In the project area, only about 3000 acres of the ponderosa pine type, out of 24,911, are in the mature stage (structural stage (SS) 4), with none listed in the old growth (SS 5) category. EA at 3-40. However, EA p, 3-42 shows 1133 acres of inventoried old growth, 1349 aces of old growth retention, and 8100 acres of developing old growth.[2]

Note also that only six acres in the mature stage (SS 4) are in the high closure category (SS 4C – 70+ percent canopy closure) and only 402 acres of the pole stage (SS 3C) are in this category. EA at 40. In other words, the mature ponderosa pine stands in the project area are not especially dense.

How can the public be assured that the 10-year contract will be implemented without damaging forest resources? The above indicates that something has gone wrong in implementation of the St. Vrain project. That alone, especially given that rare old growth is being damaged, is troubling enough. But it is even more alarming because the project is part of the huge 10-year contract the Forest Service recently signed, under which many thousands of acre of fuel reduction projects along the Front Range would be implemented with funding under the CFLRP. How will the remaining areas to be treated under this contract be implemented?

Work must stop immediately in at least the St. Vrain Project area, until there are assurances that old growth will be protected.  We request that the Forest Service order that all marking and cutting of trees in at least the St. Vrain area cease until procedures are in place to ensure that old growth and other resources are protected, and that Forest Plan, project, and legal direction will be faithfully implemented. Task orders for any further work in the Taylor Mountain units must be rewritten to include very clear protection for old growth stands and the largest trees in mature stands. Large trees in such stands must not be cut except where absolutely necessary to achieve fire risk reduction in areas closest to occupied private land.

We are happy to assist the Forest Service in assuring proper implementation and monitoring of treatment units in the St. Vrain area and other areas covered by the 10-year contract.

Sincerely,

Rocky Smith
Colorado Wild
1030 Pearl #9
Denver, CO 80203
303 839-5900
rocky@coloradowild.org

dc: Mark Martin   mlmartin@fs.fed.us
      Kevin Zimlinghaus    kzimlinghaus@fs.fed.us

REFERENCE

Mehl, Mel S., 1992.  Old-Growth Descriptions For the Major Cover Types in the Rocky Mountain Region.  IN:  Old-Growth Forests in the Southwest and Rocky Mountain Regions – Proceedings of a Workshop, March 9-13, 1992. Rocky Mountain Forest and Range Experiment Station, General Technical Report RM-213.