Draft SNFPA Management Review and Recommendations

Community Impacts

New Information and Understanding Gained from Review

An assumption of the SNFPA planning effort was that timber harvest would be applied only in support of, and constrained by, the need to find solutions to the five problem areas.^[57] Modified Alternative 8 limits vegetation treatments to those designed for fire hazard reduction, maintenance activities, or for public health and safety.^[58] This means that on the Sierra Nevada national forests, providing forest products to meet the needs of people is no longer an objective. This is a large and important decision that is only documented in a few areas of the FEIS, and no discussion of the rationale for this decision was found in the administrative record by the Team. With the exception of the Big Valley Sustained Yield Unit, there is no long-term sustained yield or suitable acres for programmed timber yield on approximately 11.5 million acres on the 11 national forests.

In the Chief's appeal decision it was acknowledged that the discussion of timber management issues in the FEIS was confusing and difficult to follow. The Chief found no violation of regulation, and none is alleged here.

The decision to provide outputs of commercial forest products only coincidentally, while meeting minimal fuels objectives, may be the most important and far reaching decision made in the SNFPA. This is because one of the original purposes of establishing national forests was to "furnish a continuous supply of timber for the use and necessities of citizens of the United States."^[59] Removing the objective to provide timber within the concept of sustainability is a significant deviation from past policy.

Currently project planning and development is difficult because of the restricted and narrow scope of objectives a manager can consider. This puts a "burden of proof" on project planners during project analysis and documentation and when they are faced with appeals and challenges. They must prove that any removal of trees meets, but does not exceed, the objective of reducing hazardous fuels. This greatly complicates planning to the point of forcing justification on nearly a tree-by-tree basis of any vegetative removal.

Many cases exist where harvesting some trees larger than those strictly required to meet the stated stand level fuels objectives would allow the project to go forward as a timber sale. This might mean the project would generate moderate revenue or break even, instead of using a service contract. The small difference in trees removed in many instances would not result in a measurable difference in environmental effects.

Eliminating any vegetation management objective other than those adopted by the ROD, precludes projects that include even a minor objective for timber production or even other restoration objectives such as improving forest health, or promoting regeneration of shade intolerant species.

Although the Team did no rigorous analysis, we believe that allowing the inclusion of timber production as a secondary or tertiary objective does not in itself necessarily create adverse environmental effects. It is the way that an objective is approached during project design that influences environmental effect. For example, a project with a purely fuels objective that eliminates 100 percent of surface fuel, and spaces trees widely to eliminate crown fire risk, would likely have a larger adverse impact on the environment than a light thinning from below of a young stand with the sole objective of increasing growth and yield of timber.

Some people feel that if there is an objective for providing commercial forest products from national forest lands, that local managers will be forced to provide commodity outputs at the expense of ecosystem health and integrity. The Team believes that current law, policy, and agency culture provide the necessary framework to responsibly manage national forests to produce an ecologically sustainable flow of wood products. Managers must be held accountable for doing a quality job of land management within existing law, policy, and direction.

⁵⁷ FEIS Vol. 2, Chapter 3, Part 5.1, page 337
⁵⁸ FEIS Volume 1, Chapter 2, page 165
⁵⁹ Organic Administration Act, 16 USC 475

USDA Forest Service · Pacific Southwest Region