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E-M:/ Hawk Timber Sale - Ottawa National Forest

Enviro-Mich message from Doug Cornett <drcornet@up.net>


Here's comments I just filed concerning the Hawk Timber Sale in the Ottawa
National Forest, in Michigan's western Upper Peninsula.  These comments
reflect problems common to timber sales across the Ottawa and the Upper

doug cornett 

Northwoods Wilderness Recovery, Inc.
P.O. Box 122
Marquette, MI 49855-0122

October 29, 1998

Jeff Larson,  District Ranger
Bessemer Ranger District
500 N. Moore St.
Bessemer, MI  49911-1096

Dear Mr. Larson:

I am writing to provide comment on the Environmental Assessment (EA) and
Biological Evaluation (BE) of the Hawk Timber Sale, located next to the
Presque Isle Wild and Scenic River corridor.

Below are Northwoods Wilderness Recovery's (NWR) concerns:

1.  The economic analysis of the Hawk Timber Sale is flawed.  The economic
analysis claims that the timber sale will provide a positive economic
return.  However, in 1996, the Ottawa lost over $967,000.  In the 1992-1994
General Accounting Office (GAO) economic analysis, the Ottawa was reported
to have lost over $6 million.  In the 1997 audit conducted by an accounting
firm commissioned by the Forest Service, a loss of $88 
million was reported for the entire National Forest system.  No breakdown
of individual forest losses has yet been released to the public for the
1997 study.

Since the Ottawa is not using any of the accounting methods that the GAO,
or the most recent 1997 Forest Service audit uses, then how can the
economic analyses be considered legitimate?  The Ottawa is obviously using
accounting methods that are bogus. Considering the losses reported by the
GAO, the Ottawa timber sale program must be losing at least $50,000 per
sale!  How can the Ottawa continue to use flawed accounting 
methods which show a profit, when in reality the Ottawa is losing millions
of dollars?

2.  The overharvest of northern hardwoods in M.A. 2.1 violates the Ottawa
Land Resource 
Management Plan.  Selection cutting of M.A. 2.1 forest wide exceeds the
planned average by 71%.  Over a ten year period, the Ottawa has cut 20,000
acres MORE than the plan has allowed for M.A. 2.1!  Likewise for thinning.
The Ottawa has thinned nearly 1500 acres more than was planned for the ten
years.  It appears that the Ottawa embraces the Forest Plan only when it
fits the timber cutting agenda!  Most of the Hawk timber sale is in M.A.
2.1 and is primarily selection cutting of hardwoods.  How can the Ottawa
continue to over cut hardwoods?

3.  Impacts to streams, wetlands and soils are not adequately addressed in
the EA.  Streams including Prospectors Creek, Monarch Creek and the Presque
Isle River will be negatively impacted by soil erosion and sedimentation
from logging and road-building.  Clearcutting and selection cutting, is
proposed near creeks and wetlands.  Additionally, vernal ponds and other
wet areas, found in the forest and NOT on the maps, will be 
negatively impacted.

Soils located in the timber sale area will also be negatively impacted.
Degradation will occur from compaction and rutting of the soils from heavy
logging equipment.  Trees will be harmed from heavy equipment that scrapes
tree bark and damages tree roots from rutting.  The Ottawa has not
effectively mitigated rutting and compaction by winter logging and other
restrictions, placed on some timber sales. 

The Forest Service tries to downplay these impacts by stating that
mitigation measures will take care of concerns.  The Forest Service claims
"past experience" with other nearby timber sales as adequate to address
erosion problems.  However, the Forest Service fails to provide any data,
and Northwoods Wilderness Recovery has documented chronic problems with
logging and resultant soil erosion and stream and wetland 
sedimentation.  These problems occur across the Ottawa, and concerns have
never seriously been addressed.

4.  Impacts to the soil and ground water due to oil and hydraulic fluid
spills and dumping are not addressed.

The Forest Service ignores this problem that is all too common to most
industrial timber sales in the Great Lakes region.  Significant volumes of
oil and hydraulic fluid are leaked and spilled in virtually all timber
sales.  The Forest Service response?  Silence.  Ignore it and it will go away!

5.  Impacts by ATV's and ORV's, through increased road densities and use,
is not adequately addressed in the EA.  Negative environmental impacts from
over use and irresponsible use of ORV's and ATV's, is being experienced
across the Ottawa.  For example, the Finger Lakes area, in the Watersmeet
RD just north of Phelps, WI, is experiencing extreme impacts of ORV and ATV
overuse of new logging roads and skid trails.  The Trap Hills, in the
Bergland RD is just beginning to have ATV's access the most remote lands,
via the North Country and Gogebic Ridge Hiking Trails, and problems have
been exacerbated by new logging road construction.

The Forest Service maintains that the road density will be decreased with
the proposed action.  This absurd assumption is made in light of the fact
that the exact opposite, an increase in road density, will actually occur.
Roads that the Forest Service claim to be presently "open" are actually
overgrown and unused.  The proposed action will open these roads and build
new roads!!  A decrease???

ATV and ORV use will increase!  The Ottawa admits this, but does not count
ATV's and ORV's as vehicles. Hence, by blocking roads from "street
vehicles" the Ottawa undermines both NEPA and NFMA by refusing to claim
ATV/ORV trails as the true roads that they are!  This practice is blatantly
illegal and prevents the Forest Service from taking any meaningful steps to
reduce road density.

6.  Impacts to threatened, endangered, special concern and rare plants and
animals, and their habitats, are not adequately addressed in the EA.
Numerous threatened, endangered, special concern and rare plants and
animals have a potential to exist in the timber sale area and negative
impacts to their habitats will occur.  Animal species include Four-toed
Salamander, Wood Turtle, Eastern Timber Wolf, Canada Lynx, Cougar, 
Pine Marten, Moose, Northern Goshawk, Red-shouldered Hawk, Boreal Owl,
Cerulean Warbler, and others.  Plant species include Ginseng, Fairy Bells,
Braun's Holly Fern, Holly Fern and Butternut.  Few if any surveys have
occurred for these species.  Most of these species are not even mentioned
in the Hawk EA and BE.

7.  The use of "boiler-plate" Environmental Assessments (EA) and Biological
Evaluations (BE) is a violation of the NEPA.  Boiler plates for all of the
current timber sales in the Ottawa were created several years ago and are
used over and over again.  Boiler plates are NOT sufficient to meet the
intent of NEPA and NFMA, especially ones that are as scientifically flawed
as the plant and goshawk boiler plates.  The Environmental Analysis is
required to use the best scientific information available, obtained by
original research, within the project area.  The Ottawa has failed to
conduct ANY analyses sufficient to meet the intent of Federal law.
However, boiler plates are used in the Hawk EA and BE to justify the
proposed action.

8.  The cumulative effects analysis is flawed.  Use of boiler-plate
"analysis" is not sufficient to address cumulative effects.  The Ottawa has
failed to take this requirement seriously and failed to assess cumulative
effects properly through detailed spatial analysis.  Cumulative effects
results from the incremental impact of the action when added to other past,
present and reasonably foreseeable future actions regardless of what agency
(Federal or non-Federal) or person undertakes such actions.  Cumulative
impacts result from individually minor but collectively significant actions
taking place over a period of time.  Numerous timber sales have occurred in
surrounding lands, federal and private, over the past ten years, and a
detailed cumulative effects analysis should be conducted.  The Forest
Service has failed to do this.

9.  The Ottawa fails to examine an adequate number of alternatives.  The
Hawk Timber Sale only presents one alternative.  With the presence of an
active Northern Goshawk nest, several alternatives should be considered,
including smaller volume cuts.


Northwoods Wilderness Recovery, Inc. recommends that the Ottawa National
Forest withdraw the Hawk Timber Sale and remove the project from the list
of any future timber sales.  The Presque Isle Wild and Scenic River
certainly will be negatively impacted by ANY timber cutting that occurs in
its periphery.  Most economic impacts to the local area will be negative,
especially when considering tourism and recreation.  The Hawk Timber Sale
will negatively impact the US Treasury and add to the "below-cost"
condition of National Forests that currently sell timber.  Hawk will
contribute to the global problem of paper overuse by adding to the current
glut of cheap pulpwood.  Threatened, endangered and rare plants and animals
will be negatively impacted.

Numerous Federal laws may be violated including the National Forest
Management Act, National Environmental Policy Act, Endangered Species Act,
Clean Water Act, President Nixon's Executive Order to ban ORV and ATV from
federal lands, and others.  In addition, state laws may be violated
including the Michigan Endangered Species Act and the Soil Erosion and
Sedimentation Control Act.

Thank you for the opportunity to comment on this timber sale.  I look
forward to your response.


Douglas R. Cornett

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