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E-M:/ Western UP Forest Management Issue



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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Date: Tue, 21 Apr 1998 11:59:56 -0400
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From: "Henry W. Peters" <hwpeters@up.net>
To: "enviro- mich" <enviro-mich@great-lakes.net>
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Please post the following response to the Ottawa National Forest 
Supervisor Philys Greens' attempt to cloud the ALERT concerning the OLD 
M-64 Timber Sale, Trap Hills.  We are requesting the area to be place in 
the Presidents Roadless Area 18 Month Moratorium, at a minimum.

The below discussion by Doug Cornett of the Northwoods Wilderness 
Recovery helps to clarify the situation made unecessarily complex by the 
Forest Service.  This is a great example of how & why people have a hard 
time understanding that our Public Lands are in very serious trouble.

*I have added a footnote at the bottom of this message.

Thanks, 
Henry W. Peters, Citizen Public Lands 
"Your Lands, Our Planet" -------------------------------------->>>>> 

April 19, 1998

Readers:

The below posting is a reply to Ottawa National Forest Supervisor Phyllis 
Green's post (week of April 12) regarding the recent letter-writing 
campaign to include the Old M-64 Hardwoods timber sale and the Trap Hills 
in the President's Executive Order to protect Roadless Areas from further 
road-building.

I've broken Ms. Green's post into separate statements and responded to 
each, in an attempt to clarify our position for protecting the old M-64 
sale area and the Trap Hills from timber-cutting and road-building.

If you are interested in supporting this effort, we need to continue 
sending letters and making phone calls to Ms. Green.  

E-mail Doug Cornett at drcornet@up.net for more information.

If you are interested in visiting the area, or want to know more about 
the Ottawa's timber-cutting program, contact Northwoods Wilderness 
Recovery by E-mail or at P.O. Box 122, Marquette, MI 49855, ph. (906) 
225-1938.

Sincerely, Doug Cornett ------------------------------------------->>>>

GREEN'S INITIAL POST
>
>Forwarded by request to Enviro-Mich: 
>
>"Dear Ann, 
>Would appreciate your posting this on the EnviroWebsite.  I know it  
>probably does not represent your organization's views but would appreciate 
>your sharing with your readership in order to update them on the status of 
>the process and provide more information in regards to the area. 
>Thanks, Phyllis Green Forest Supervisor Ottawa National Forest" 
>
>"Several people sent me a copy of your latest updates on Trap Hills.  I am 
>always interested in understanding the perspectives of people who engage 
>and are concerned about public land management.  This time it was also 
>interesting to see how 1/2 of a conversation was interpreted.  Trap Hills 
>does not meet the  following 4 criteria for placing into the roads 
>moratorium: 1. roadless areas of 5,000 acres or more inventoried in RARE 
>II (Roadless Area Review and Evaluation) and other unroaded areas 
>regardless of size, identified in a forest plan; 2. unroaded areas greater 
>than 1,000 acres contiguous to Congressionally-designated Wildern ess or 
>contiguous to federally-administered components of the National Wild and 
>Scenic Rivers System that are classified as "Wild";  3. any National 
>Forest System area of low-density road development or 4. any other 
>National Forest System that retains its roadless characteristics which the 
>Regional Forester subsequently determines have such special and unique 
>ecological characteristics or social values that no road construction or 
>reconstruction should proceed." 
>
>" It has been characterized as being the last old growth stands on the 
>Ottawa.  Although the EA process placed 40% of the area into unmanaged old 
>growth very little of it has classic old growth characteristics.  Our 
>stand data indicates over 90% of the area originated after 1920.  Part of 
>the reason it is starting to regain structure is time and a variety of 
>treatments that have occurred from pre-commercial thins to harvest.  This 
>information does not necessarily alter people's interest in preserving the 
>area but it is more reflective of how the area has evolved.  The 9 
>criteria shared with you all in Murray's notes appear to be from the last 
>round of wilderness planning in Michigan.  They were not included in 
>Forest Service direction regarding the moratorium.  I do intend to review 
>the area and validate the locality of stands people are concerned about 
>that they feel are old growth.  At this point, the Regional Forester has 
>the authority to place areas into the moratorium and I have relayed your 
>criteria and concerns on to him. There are a number of issues that have 
>been raised in addition to old growth and we will be posting clarifying 
>material at our web site (www.fs.fed.us/r9/ottawa). We take our 
>stewardship seriously in regards to flora and fauna and the allocation of 
>land management strategies on the Ottawa National Forest was done 
>primarily through the Forest Plan process with a broad base of public 
>input.   The Wilderness Act of 1987  designated the current wilderness 
>acres. Land management strategies is definitely one of interaction with 
>the public about areas that they care about.  I appreciate hearing from 
>those of you who have written and look forward to more dialog on t his 
>area and its significance. 
>
>Phyllis Green, Forest Supervisor, Ottawa National Forest"
 
------------------------------------------->>>>

NORTHWOODS WILDERNESS RECOVERY'S RESPONSE

"Several people sent me a copy of your latest updates on Trap Hills.  I 
am always interested in understanding the perspectives of people who 
engage and are concerned about public land management.  This time it was 
also interesting to see how 1/2 of a conversation was interpreted.  Trap 
Hills does not meet the following 4 criteria for placing into the roads 
moratorium:

STATEMENT

1. roadless areas of 5,000 acres or more inventoried in RARE II (Roadless 
Area Review and Evaluation) and other unroaded areas regardless of size, 
identified in a forest plan;

RESPONSE

The Trap Hills wasn't included in RARE II.  However, the adjacent Norwich 
Plains was, although it was disqualified after the Forest Service divided 
the area in half with a road and proceeded with a timber sale.  The FS 
was certainly aware of what they were doing and how the timber sale would 
disqualify the Norwich Plains from wilderness designation.

Roads were also constructed in remote areas by the Ottawa in the early 
1970's, effectively "disqualifying" these areas from further wilderness 
consideration. The Old M-64 Hardwoods Timber Sale in the Trap Hills is 
one of these areas. Forest Road (FR) 326 was constructed sometime in the 
1970's and essentially divided the area.  Another road, F.R. 430, in the 
Cascade Creek semi-primitive area, was built during the same period, and 
will be used to cut more Trap Hills old-growth hardwoods in the Northeast 
Ridge Timber Sale.

The Act to Save America's Forests identifies the 30,000 + acre Trap Hills 
as a Special Area.  Biological surveys indicate that the area harbors 
numerous rare plant and animal species, and is indeed a biological 
"hot-spot."

STATEMENT

2. unroaded areas greater than 1,000 acres contiguous to Congressionally- 
designated Wilderness or contiguous to federally-administered components 
of the National Wild and Scenic Rivers System that are classified as 
"Wild"

RESPONSE

The Old M-64 timber sale is adjacent to the Cascade Falls semi-primitive 
area which is contiguous with the West Branch of the Ontonagon Wild & 
Scenic River corridor.  While the Old M-64 timber sale is separated from 
the Ontonagon River by the Cascade semi-primitive area and does not 
qualify strictly to the above guides, it is contiguous as a Wild Lands 
complex.  On November 30, 1997, LightHawk flew the Trap Hills and west 
branch of the Ontonagon River and videotaped the area.  This footage 
clearly demonstrates the intact nature of the Trap Hills and Ontonagon 
River corridor when comparing it to the surrounding area that has been 
heavily cut.

STATEMENT

3. any National Forest System area of low-density road development

RESPONSE

The Old M-64 timber sale area qualifies for this.  The only factor that 
disqualifies the area is erroneous claims by the Forest Service that the 
area is riddled with roads.

Old M-64, Forest Rd. 326 and the E&LS railroad are the only open roads 
and are approximately 10 miles in length for a 7 square mile area, or a 
road density of about 1.5 miles per square mile.  Old M-64 and the 
railroad are on the perimeter of the area and do not act to divide the 
land in question.  (If only the the roads within the perimeter are 
considered, the road density is 0.28 mi./sq.mi.)

Below is a discussion of road densities as presented in Northwoods 
Wilderness Recovery, et al's appeal of the timber sale.

The Forest Service claims that there currently is 4.45 miles of roads per 
square mile.  However, in the Forest Service "analysis," this includes 
logging roads and trails that have not been used in many years and are 
impassable to all but those on foot.

Forest Service states:

"...the on-the-ground transportation system is almost 31 miles...Many of 
these roads have pot holes, wet spots and minor rutting and are not 
passable by highway vehicle.  These old roads provide access to the area 
for hunters and other recreationists."

"... Alternative 2 designates roads needed for harvest and would allow 
other roads not needed to be obliterated by revegetating.  This process 
would reduce the road density in the project area by 46% and brings the 
road density of the project area within Forest Plan guidelines.  To 
inhibit ATV/ORV traffic, roads cleared for logging would be block [sic] 
by berms, gates or other means. This will reduce the ATV use and help 
maintain the nonmotorized character of the project area."

Forest Service downplays Alternative 1 (no-action) and deceptively claim 
that overgrown roads are currently "open:"   AGAIN, THEY state:

"Long term effects of alternative 1 include the continued narrowing of 
roads as brush and other vegetation encroaches.  Sporadic public use of 
road beds as ATV trails would continue to keep these corridors open, more 
as paths than as roads...This use would also detract from the 
non-motorized character of the area..."

"Road densities would eventually be reduced as they gradually grow over 
with vegetation.  Actions to close these roads would have to be 
accomplished as separate projects."

However, Forest Service ADMITS that roads opened up for logging will be 
widened and the road corridor will be reclaimed by vegetation at a slower 
rate than the no-action alternative.

THE EA FOR THE SALE SAYS:

"Long term effects of alternative 2...After harvest activities are 
complete these roads would gradually narrow, however this would occur at 
a slower rate than in alternative 1 because the roads have been cleared 
of brush and widened. Roads except FR 326, would be closed in such a way 
to prevent ATV use. Closed roads would also provide hiking opportunities 
for the public."

Currently, the "open" roads (outside Old M-64, FR 326 and the railroad) 
see very infrequent use by ATV's and are used primarily by wildlife and 
humans on foot.  How can Forest Service honestly reduce the road density 
by opening over 14 miles of road and then "closing" them?  The current 
condition of these roads provide a closed forest canopy.  Alternative 2 
will open this canopy and create at least 28 miles of edge, effectively 
dividing the project area and fragmenting much of the interior forest.

STATEMENT

4. any other National Forest System that retains its roadless 
characteristics which the Regional Forester subsequently determines have 
such special and unique ecological characteristics or social values that 
no road construction or reconstruction should proceed."

RESPONSE

This condition allows for discretion to be exercised when chosing an area 
for the Executive Order.  In other words, if an area does not strictly 
follow 1 - 3, it can still be chosen.  This follows a statement made by 
Mike Dombeck when first appointed as Chief of the Forest Service.  Soon 
after taking office Mr. Dombeck claimed that "[the Forest Service will] 
stay out of old growth, unroaded lands and sensitive areas."

In NWR, et al's appeal we state:

"Many species of Michigan state-listed, Federally-listed and candidate, 
Region 9 sensitive species and species that may be new-to-science are 
known to occur in and/or near the Old M-64 Hardwoods Vegetation 
Management Project. Peregrine Falcon (Falco peregrinus), Northern Goshawk 
(Accipiter gentilis), Red-shouldered Hawk (Buteo lineatus), Wood Turtle 
(Clemmys insculpta), Fairy Bells (Disporum (Prosartes) hookerii), Male 
Fern (Dryopteris filix-mas), Prairie Buttercup (Ranunculus rhomboideus) 
and Moonworts (Botrychium spp.) are known from the immediate project 
area."

"Suitable habitat exists within and/or near the project area for other 
regionally sensitive, state-listed, federally-listed and federal 
candidate species, including Eastern Timber Wolf (Canis lupus lyacon), 
Cerulean Warbler (Dendroica cerulea), American Bittern (Botaurus 
lentiginosus), Northern Reed Grass (Calamagrostis lacustris) and 
Laurentian Fragile Fern (Cystopteris laurentiana)."

"The nearby Ontonagon River supports a disjunct Southern Swamp Hardwoods 
ecosystem that is unusual at this latitude.  Species components of this 
ecosystem include Silver Maple, Bur Oak, Slippery Elm and possibly 
Butternut, a Federal ESA candidate species.  Bur Oak occurs in the 
project area and is a good indicator of rare habitats."

Our statement above, indicates that the area where the Old M-64 timber 
sale is located is "special," due to the many rare species and habitats 
found here. The Appellants did not make unfounded claims.  Our statement 
comes from over 5 years of our own field work, and research of Forest 
Service and Michigan Natural Features Inventory records and data bases. 
We also consulted with botanists and wildlife biologists who have 
conducted research in the same area.

STATEMENT

"It has been characterized as being the last old growth stands on the 
Ottawa. Although the EA process placed 40% of the area into unmanaged old 
growth very little of it has classic old growth characteristics.  Our 
stand data indicates over 90% of the area originated after 1920.

RESPONSE

Most of the stands are second-growth but have not been cut since the 
1920's. A few uncut stands, ranging from 20 to 30 acres in size, are 
found in the area.

When looking at the stands being "MANAGED" (read -->> CUT), then we see 
that many of the stands contained in the Old M-64 sale DO have old-growth 
characteristics.   Big trees, a necessary component of old-growth, are, 
unfortunately, also needed to "pepper" money-losing pulpwood sales with 
money-making saw timber.  And nearly all of these stands are open for 
cutting.

(In essence, old-growth saw logs subsidize loggers to cut small diameter 
hardwood trees that go to the paper mill.)

Many of the stands placed in the "unmanaged old-growth" category indeed 
DO NOT have old-growth characteristics.  The Old M-64 timber sale is a 
great example of the FS old-growth "shell game."  In the Old M-64 timber 
sale area the rock escarpment and a small lake have been called 
"old-growth."  This comprises much of the designated "old-growth."

Obviously, rock and water are not good areas to be called "old-growth." 
In fact, at least half of the areas Northwoods Wilderness Recovery has 
examined (in both state and national forests) for proposed "old-growth" 
never have the potential to be called "old-growth" in our childrens or 
our lifetimes.  We've seen clearcuts, tag alder, bogs, swamps, lakes, 
rivers, rocks, logging roads, openings and numerous other sites that 
never have the potential to grow ANY trees (let alone BIG trees), 
designated as "old-growth."

Forest Service own records of the timber sale show that old-growth 
concerns were voiced by citizens who have visited the area.  Also, FS 
plant survey notes state that stands in the eastern portion of the sale 
are "largely undisturbed" and "mature."

STATEMENT

Part of the reason it is starting to regain structure is time and a 
variety of treatments that have occurred from pre-commercial thins to 
harvest.  This information does not necessarily alter people's interest 
in preserving the area but it is more reflective of how the area has 
evolved.

RESPONSE

Most of the area HAS NOT seen timber cutting since the 1920's.  The 
stands that have regained structure similar to old growth are stands that 
have been left alone (give it time).  The stands on the edge of the area 
are the ones that have been cut, these stands DO NOT have the structure 
approaching old growth, as do the uncut stands.  Most of these stands are 
"dog-hair" thickets with little or no forest structure and absent of 
nearly all old-growth characteristics (this constitutes the 'variety of 
"treatments"').

STATEMENT

The 9 criteria shared with you all in Murray's notes appear to be from 
the last round of wilderness planning in Michigan.  They were not 
included in Forest Service direction regarding the moratorium.

RESPONSE

These criteria, while developed for RARE II, are general in nature and 
could be used as guides when chosing Roadless Areas for the Executive 
Order.

The following are the eight criteria for roadless areas in the Eastern 
U.S (RARE II):

1.  The land is regaining a natural, untrammeled appearance.

2.  Improvements existing in the area are being affected by the forces of 
nature rather than humans and are disappearing or muted.

3.  The area has existing or attainable National Forest System ownership 
patterns, both surface and subsurface, that could ensure perpetuation of 
identified wilderness values.

4.  The location of the area is conducive to the perpetuation of 
wilderness values.

5.  The area contains nor more than a half mile of improved road for each 
1,000 acres, and the roads are under Forest Service jurisdiction.

6.  No more than 15 percent of the area is non-native, planted vegetation.

7.  Twenty percent or less of the area has been harvested within the past 
ten years

8.  The area contains only a few dwellings on private lands and the 
location of these dwellings and their access needs insulate effects on 
the natural condition of Federal lands.

The Old M-64 hardwoods timber sale area meets all these conditions.

STATEMENT

I do intend to review the area and validate the locality of stands people 
are concerned about that they feel are old growth.  At this point, the 
Regional Forester has the authority to place areas into the moratorium 
and I have relayed your criteria and concerns on to him.

RESPONSE

I hope that the Ottawa Supervisor Phyllis Green is sincere about visiting 
the area and listening to our concerns.  I am somewhat skeptical at this 
point. I have 3 concerns regarding Ms. Green's posting, 1) the claim that 
the Old M-64 sale and the Trap Hills area do not meet the criteria for 
the Executive Order, 2) that the issue centers around just the location 
of a few old-growth stands, and 3) the Forest Service avoids rare and 
endangered species issues, which are major concerns of people who want to 
protect the area from logging.

STATEMENT

There are a number of issues that have been raised in addition to old 
growth and we will be posting clarifying material at our web site

www.fs.fed.us/r9/ottawa

RESPONSE

I suggest those reading this to visit the Ottawa web site.  It's 
interesting to note that you have to really dig to find out that the 
Ottawa's major (taxpayer- funded) activity is logging.  The majority of 
the site is devoted to recreation. Yet recreation receives very little 
funding, and what funding is received is usually from timber sale 
receipts.

Here's an example:

"Mountain bike trails travel through a variety of management areas across 
the forest. These areas are managed for a wide range of multiple use 
activities including recreation, threatened and endangered species, fish 
and wildlife, water quality, and wood products."

Timber-cutting is not mentioned any where else on the web site until the 
National Environmental Policy Act (NEPA) page is reached.  Then you have 
to look at the individual "projects" before the term "timber cutting"or 
"logging" can be found.

Since logging is considered by the Forest Service to be benign or even 
beneficial, then why does the Forest Service attempt to hide this from 
the public?

STATEMENT

We take our stewardship seriously in regards to flora and fauna and the 
allocation of land management strategies on the Ottawa National Forest 
was done primarily through the Forest Plan process with a broad base of 
public input.

RESPONSE

The Plan is seriously outdated and flawed.  The Ottawa relies heavily on 
the Plan which is biased toward timber-cutting.  The Ottawa claims "broad 
base of public support" which is not really a true representation of the 
circumstances.

Over 12 years after the Forest Plan was approved, things have changed 
dramatically.  The public is demanding more recreation that can not be 
accomodated by the current "allottment" of wilderness and wild and scenic 
rivers.

STATEMENT

The Wilderness Act of 1987 designated the current wilderness acres.  Land 
management strategies is definitely one of interaction with the public 
about areas that they care about.

I appreciate hearing from those of you who have written and look forward 
to more dialog on this area and its significance. Phyllis Green, Forest 
Supervisor, Ottawa National Forest

RESPONSE

Northwoods Wilderness Recovery and others have worked for over 6 years to 
"dialog" and "interact" with the Ottawa.  We've made very little 
progress. Each attempt to provide meaningful input has been attacked by 
the Forest Service as being "unscientific" and persons with different 
views are labelled "non-cooperators."

As a result of this lack of interaction, and overwhelming public response 
for other values besides timber-cutting to be prioritized, and a feeling 
that agencies just aren't doing that job, there is a growing national 
movement to end all logging in our National Forests. The Ottawa should 
begin to interact in good faith with those who represent forest 
protection efforts, and listen to the majority of Americans who want to 
put an end to corporate welfare.

Please write Ottawa Forest Supervisor Phyllis Green and Forest Service 
Chief Mike Dombeck and urge them to protect this area.

Phyllis Green Forest Supervisor Ottawa National Forest E 6248 US 2 
Ironwood, MI 49938 (906) 932-1330

Mike Dombeck, Chief USDA Forest Service MAIL STOP 1104 P. O. Box 96090 
Washington, DC 20090-6090

Comments also may be sent to the Chief via the Internet to: 
roads/wo@fs.fed.us. 

*Henry Peters footnote here:

I would only add here, that if most of our original ancient old growth 
FORESTS have been cut & destroyed... as it has, we had better start 
making serious consideration of the POTENTIAL for similar growth to 
re-occur.  

My guess is that the cumulative effect of such massive FOREST removal 
(i.e., pre-European settlement), means that even INDICATORS for POTENTIAL 
for OLD GROWTH take on HUGELY greater significances...!!!  

This is to say, we better stop splitting hairs about "old growth"... and 
when in doubt, undoubtably... fall on the side of PROTECTION.  H.P.



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