Review of the Flathead National Forest's Mortality Guidelines

Contact: Cameron Naficy, Native Forest Network
406.542.7343, cameron@wildrockies.org

Summary
Under the direction of the current Flathead National Forest (FNF) Supervisor, Cathy Barbouletos, the FNF has pursued aggressive post fire logging policies that have resulted in logging projects in each major fire area since 2001. The FNF largely bases these projects on the premise that logging dead and dying trees is not as damaging as logging green trees, that burned old growth forests are not important for old growth dependent species and that burned forests, once logged, provide suitable habitat for the diversity of wildlife species that utilize native, unlogged burned forest.

The FNF’s post fire logging projects use a set of mortality guidelines to attempt to predict which trees may die as a result of the fire and could, according to their logic, then be logged. We submitted a Freedom of Information Act (FOIA) request to the FNF in January of 2005 asking for information they used to develop their mortality guidelines.

We found that, with virtually no review of the accuracy or validity of this assumption, the FNF has authorized logging of all thin barked tree species such as spruce, subalpine fir, grand fir, western red cedar, and white pine that were even slightly scorched by fire. For thicker barked species such as Douglas fir and western larch, the FNF has largely based its mortality guidelines on the potential risk of beetle infestation following the fire rather than direct tree mortality due to the fire. No field data was provided in the FNF’s documents used to draft these guidelines that verified the FNF’s assumptions of tree morality in thin barked species.

To assess the potential risk of beetle infestation, the FNF began monitoring bark beetle infestations (which primarily affect only Douglas fir) in areas burned by the Moose Fire of 2001. They focused surveys mainly on high risk beetle areas, finding very low levels of beetle infestation in 2002 and an increase in activity in 2003. They halted monitoring efforts in 2004 to pursue logging projects in the Moose Fire area and in the areas affected by the 2003 Robert, Wedge, Beta, Doe, Blackfoot, and Ball fires. In the short time the FNF pursued field checking of the beetle attacks they found that even in stands with high beetle risk at the time of highest infestation, an average of 50% of the trees that survived the fire also survived the beetle attacks. Despite this finding, and the fact that beetle epidemics are an erratic and highly unpredictable natural phenomena, the FNF has adopted logging prescriptions that would leave only 6 trees per acre left standing on the landscape.

These projects are in grizzly bear core habitat, are the primary habitat for fire dependent species, and contain some bull trout streams. What the documents that the Native Forest Network received from the FNF show is that the FNF has cut its monitoring efforts short to pursue large logging projects, have neglected to verify or assess the accuracy of the guidelines they have drafted, and are using highly unpredictable phenomena (i.e. beetle outbreaks) to justify their industrial logging projects.

Findings

On 01/10/05, NFN sent a FOIA request to the Flathead National Forest including the following:

In response, on 2/17/05, the FNF provided a set of documents which the Native Forest Network has gleaned for relevant information and summarized below. We received no documents that addressed direct tree mortality due to fire except one that only partially addressed it (see comments from H-81). All of the documents focused mainly on beetle infestations, primarily infestations of Douglas fir bark beetle, to a lesser extent spruce beetle, and one article that mentioned flatheaded fir borer as a potential mortality agent in western larch. From the documents it appears that the FNF began field checking of the Moose Fire in 2002, continued in 2003 and largely abandoned monitoring efforts in 2004 due to "new priorities" associated with the Robert/Wedge and Westside Reservoir projects. The Robert and Wedge Fires were surveyed for Douglas fir beetle and spruce beetle infestations in 2004. The Westside Reservoir project was never surveyed.

From H-49: Moose Fire Project Summary of 2002 Douglas-fir Beetle Monitoring
p.1 Survey Method
" On average, about 83% of the total area was covered during the survey, ranging from 50-100% within individual units. Lower sampling percentages typically resulted from avoiding portions of units with very few or no beetle susceptible DF, or those portions of unit on excessively steep, hazardous slopes."

p.2 Interpretation related to Moose Post-Fire project
"An additional 3500 acres within the fire area were not surveyed in 2002—areas that were not proposed for any kind of beetle management treatments in the proposed action due to their low risk to beetles and their location in areas where other resource or management emphases dominated. About 83% of these acres were rated low risk to beetle infestation, with most of the rest rated moderate risk. They are scattered throughout the Moose Fire area, primarily within the Inventoried Roadless Areas (about 1300 acres), riparian habitat conservation areas, and areas that the Flathead Forest Plan has classified as unsuitable for timber management."

POINT: Surveys were skewed to focus on areas with high beetle hazrard.

p. 1 (2nd to last paragraph) – "Very few of the trees that still had green crowns have been attacked, even though they may have been underburned or partially scorched and stressed by the fire. Nearly all trees attacked were fire-killed, most often with completely blackened boles and crowns consumed, or with 100% scorch (red needles)."

From H-48: Summary of Doug Fir Beetle monitoring in stands within and surrounding the 2001 Moose fire, Summer 2003.

In areas that were identified as high or moderate hazard for Doug fir beetle (about 1200 acres of the 3700 surveyed in 2002) they say: "Estimates of the proportion of remaining live trees infested with DFB within the survey unit ranged from about 25%-95%, with most areas around 50%.
POINT: Even in the moderate-high hazard areas only 50% of the fire affected trees were killed by beetles two years after the fire. The mortality guidelines used by the Flathead would take much more than 50% of the fire affected trees.

From H-80: Summary of Douglas-fir Beetle monitoring in the 2001 Moose Fire area, Summer 2004.

p.1
"Monitoring of Douglas-fir beetle populations within the Moose Fire area was conducted in the summer of 2004, though at a much reduced level than that done in 2002 and 2003. This was due to changes in project priorities and funding, mainly initiated by the Robert, Wedge Canyon, and Westside Reservoir fires that burned that summer and fall."

From H-79: Summary of Doug fir spruce beetle monitoring within the 2003 Robert and Wedge Canyon Fire areas Summer 2004

p.1
"In comparison with the intensity of beetle activity found the first year after the Moose Fire, the level of infestation in Robert and Wedge fire areas appears to be higher, with greater proportions of Douglas-fir infested, and higher intensities of infestation on individual trees. Also, more trees with green crowns are being attacked this first year, though beetles still seem to be favoring the fire killed, charred and dead trees."

p.2
"Most of the beetle susceptible spruce stands in the Robert and Wedge fire areas were burned to the degree they no longer provide suitable habitat for spruce beetle."

"Extensive field review of spruce beetle hazard areas was not completed in 2004 due to other priorities, one being to monitor Douglas-fir beetle activity in the fire areas."

From H-81: Observations of Post-fire Conditions and Tree Survival in the 2001 Moose Fire and 2003 Fires on the Three Forks Zone, November 2004

p. 2 Relationship to tree survival
"Surveys and field observations in the Moose Fire area from 2002 through 2004 indicate that many of the areas that burned at low or moderate vegetation burn severity have experienced delayed tree mortality, and there appears to be far fewer "green trees" across the landscape. Most of these areas have not been intensively surveyed, so precise estimates of numbers of fire-surviving trees that died are not available. However, it is assumed that the fire injuries on the trees in these areas caused either direct or indirect (insect attack) mortality."

POINT: These statements are made on observational postulations, not field based surveys. No surveys were done in the Westside Reservoir project area. See 2002, 2003, and 2004 surveys of the Moose Fire and 2004 survey of the Robert and Wedge fires for details on surveys done in those areas, or read notes from above.

p. 3, last sentence
"As compared to the Moose Fire, all these fires (Robert/Wedge and Westside Reservoir Complex) had substantially less acreage of low severity/unburned area."

POINT: This, I think, will be one of the major factual hinges of their argument--high mortality was seen in the Moose fire and the other fires all burned more intensely so they will likely show higher post fire mortality as well.

p. 5 Relationship to tree survival
"Fire intolerant trees, such as spruce, subalpine fir and lodgepole pine, are usually killed even under low soil or vegetation burn severity, and no exceptions to this were found on the 2003 fires."

POINT: What monitoring was done to confirm this? These statements were not even addressed in the surveys provided with this FOIA.

p. 5
"Continuing high populations of Douglas-fir beetles in the region, and on this forest, as well as surveys in the Moose Fire area and in the Robert and Wedge fire areas in 2004 indicate that this future mortality is certain to occur in remaining live Douglas–fir trees."

POINT: This is a blanket statement of absolute certainty based on studies that found much less than certain results. Infestation may be certain, but again the degree of mortality remains unassessed.

p. 5
"High mortality is expected on remaining live Douglas-fir trees within the 2003 fire areas, and could reach up to 80 or 90% of the remaining larger diameter trees (i.e. > 16" dbh)."

POINT: Again, this is unfounded speculation which predicts up to 80-90% mortality of large trees (16" dbh and above).

"Because of the nature of how these fires burned, if Douglas fir was underburned, even at relatively ‘low’ intensities, it is expected that there has been some, if not significant, root damage to the Douglas-fir. Bark beetle infestation is expected to occur at high levels. The guidelines are designed to be pro-active in the management of the beetle population, removing trees that are currently or expected to be infested with beetles within the next few years. Our best and most reasonable options to manage beetle populations are to reduce the habitat available and to a lesser degree directly reduce population levels through removal of infested trees. These options are balanced with other resource and social concerns."

Below are the other studies the FNF provided the Native Forest Network with in response to our FOIA that are not specific to the Flathead or the Robert Wedge and Westside Reservoir projects and that they based their mortality guidelines on.

From H-101: Bulaon, Beverly February 2003. Report 03-2, Douglas Fir Beetle Surveys of 2000 Fires.

p.5 – Heavy mortality in buffer zones.
"The majority of fires (7 out of 13) had 40 percent to 50 percent of the fire-damaged Douglas-fir attacked by bark beetles in 2001 and 2002. Ten of the thirteen fires had 30 percent to 50 percent attacked. There are only five fires with slightly over 50 percent fire-damaged trees remaining."
POINT: 54% (7/13) of the 2000 fires had 50%-60% of Douglas fir uninfested by beetles by 2002. 77% (10/13) of the 2000 fires had 50%-70% of the Douglas fir uninfested by beetles by 2002.
p. 5 (and in other places throughout) – "Much of the mortality in 2001 and 2002 was large diameter Douglas-fir. Douglas-fir beetle consistently selected the largest fire-injured trees in all surveyed areas."

POINT: The Flathead FS is removing most of the burned living trees that are most likely to survive the beetle infestation, the middle sized (often commercial) trees that survived the fire and would be selectively avoided by the beetles. These trees would be the most likely to regenerate the stand. Keep in mind though that smaller and medium size classes are still infested by beetles, usually only when larger diameters have been already infested and beetle populations are still high.

From H-48: The role of bark beetle populations in delayed tree mortality following wildland fires

p.1
Higher % crown scorch are attacked preferentially one and two years after fire
Basal girdling also affected beetle attack

"DBH was the most significant factor explaining mass-attacks both one and two years following the fires. Although crown scorch affected the number of Douglas-fir beetle brood sampled prior to winter, adult emergence from trees the following spring showed no relationship to fire-caused tree injury."

"Douglas-fir beetles were responsible for an additional 11% tree mortality in those trees that might have survived the fires the first year, and additional 27% the second year. Beetle-caused tree mortality was greatest in the larger diameter classes."

p.3
"For both fires combined, 70% of the Douglas-fir trees greater than or equal to 14 inches DBH are still alive…"