Initial Review of the Middle East Fork Record of Decision

What follows is a quick initial review of the Bitterroot National Forest's Record of Decision (ROD) for the Middle East Fork Healthy Forest Restoration Act project. The Forest Service annouced their decision on March 30, 2006. The review was compiled by the Native Forest Network. You can find more information about this project by contacting the Native Forest Network at 406.542.7343.

• This decision still includes 2,893 acres of industrial logging in some of the best remaining pockets of unlogged, mature forests in the East Fork of the Bitterroot. Generally, these logging units are deeper in the forest, far from homes and the East Fork community. These forests also provide critical habitat for the huge elk, bighorn sheep and mule deer herds found up the East Fork. As we review the ROD, we'll certainly be reviewing what the Forest Service's decision calls for in these special areas.

• On initial review it appears as if we could support about 2,600 acres of fuel reduction work that's part of this decision, including 2,194 acres of slashing and prescribed fire and 487 acres of pre-commercial thinning. We want to make sure the public knows that we do support effective, bona-fide fuel reduction work to help protect the East Fork Community from future wildfires.

• The Forest Service is claiming that all treatments in old-growth habitat have been dropped. This is not true. Much of this is due to nomenclature and the Forest Service's bureaucratic designation of areas, not because all logging units in forests that are comprised of unlogged, old-growth forests have been dropped.

• The Forest Service has changed 10 units that were considered "old-growth habitat" in the Draft and Final EIS and in the Record of Decision now claims that these units no longer constitute "old-growth habitat" because trees have been killed by beetles. We would certainly argue that "old-growth habitat" is much more than just the trees and that dead and dying trees are as much a part of "old-growth habitat" as living trees.

- From ROD Attachment E, p. E-1, referencing FEIS p. 2-52:  The following units no longer have old growth habitat and so therefore would not be included in this mitigation. 60, 62, 66, 326, 504a, 504b, 804, 814, 815, 817. These changes are the result of changed conditions due to mortality caused by the Douglas-fir bark beetle which was determined through field verification in 2005.

• The Forest Service fully acknowledges that large, green, live trees will be cut down as part of this project.

From ROD (p 23): "As described in Section 8.2, page 31, some large live trees will be removed to meet project objectives (less than 2% of the commercial harvest), and incidentally when necessary for skyline corridors, landings and other operational needs."

Notice the key "and incidentally when necessary for..." part of that sentence. We've seen a 500 year old green ponderosa pine tree right in the middle of a helicopter landing pad, temporary roads going right through nice stands of big green trees and you can bet skyline corridors will be put in places where it just so happens that large, green trees happen to be living. This is pretty standard on most logging projects I'm familiar with over the past decade.

So, even though the Forest Service might say "less than 2%" of the logging will be "large live trees" it will be well above that figure. But let's just assume that "only" two percent of the commercial harvest of 11 million board feet comes from large live trees. There are 5,000 board feet per log truck meaning that 2,200 log trucks full of trees will come out of this "healthy forest fuel reduction" project.

Two percent of 2,200 log trucks means that 44 log trucks that come out of the East Fork will contain large, green trees (ie what most people would consider "old-growth trees".) If as much as 5% of the volume comes from large green trees we'd be looking at 110 log trucks of these types of trees. When's the last time anyone saw 44 to 110 log trucks of big, green trees driving down the road?

We would invite the public to visit some of these areas (as we have done over the past 18-months) and see for themselves just how beautiful these remaining pockets of unlogged, mature forests up the East Fork are. While the Forest Service might not consider them "old-growth" in a bureaucratic sense, they are clearly "old-growth" in every sense of the definition and provide critical habitat for elk, bighorn sheep, mule deer, pine martins, goshawk, bear, coyote and a host of woodpeckers and other critters.

• Of the approximately, 1,500 acres that were deferred/dropped from this record of decision:
- 100 acres were deferred for old growth
- 417 acres were deferred for soils review
- 1017 acres were deferred because soil conditions are already above the legal limit for soil damage

It's important to note that for the past 18-months conservation groups and PhD scientists have repeatedly pointed out to BNF officials concerns with this project regarding old-growth and soil issues. The BNF never once admitted any problems with this project in regards to old-growth and soils. In fact, they outright rejected all our official HFRA Objection points on these issues. Yet today, they have essentially dropped 1,500 acres from this decision due to old-growth and soil issues, which is in fact an admission that our concerns about old-growth and soil resources were valid.

• The Forest Service still appears to be hiding behind the "Collaboration Cloak." It's important to point out that the official HFRA collaborative process for this project was limited to one meeting, held on September 28, 2004. This is not what most people would consider a "collaborative process," especially since BNF officials showed up at that meeting with their logging units already presented on a map and their minds made up.

The BNF is using other meetings, going back as far as meetings that were held in 2000 while the Bitterroot fires were burning and meetings regarding the Bitterroot Community Wildfire Protection Plan, and essentially wrapping these into the "collaborative" process for this HFRA project. This is disingenuous at best. Furthermore, Jed Fitzpatrick, who lives in the East Fork within the project area, attended a March 2004 meeting that the BNF has been using to bolster their "collaboration" claim, and told the Ravalli Republic, ""They didn't say we're going to log this much acreage in the Middle East Fork," Fitzpatrick said. Rather, the meeting focused on things the agency could do to benefit the local community, he said. He remembered talking about things like back-country access for horses, fishing access and more toilets. "There was no way this plan (alternative 2) was birthed from that."

The BNF's notion of a collaborative HFRA process for this project is certainly much different than the process the Lolo NF has used for the proposed DeBaugen HFRA project. During that collaborative process (the project is in scoping) to date 6 official HFRA collaborative meetings and 2 official HFRA field trips have been held. Again, this compares with one official HFRA meeting on the Bitterroot and zero official HFRA field trips.

• Since NFN's FOIA request revealed that as of October 20, 2005 the BNF spent $208,363 marking trees and unit boundaries for this project BEFORE the decision was made, how much taxpayer money did the BNF waste by marking trees and unit boundaries and then dropping about 1,500 acres (about 25%) from the decision. Does that mean that 25% of taxpayer money (about $50,000) was wasted due to the BNF marking trees/units prior to their decision?

Again, you can learn more information about this project by contacting the Native Forest Network at 406.542.7343.