Forest Service 

Wednesday, August 11, 2004

Comments and Requested Improvements for the Draft Land Management Plan and Draft Environmental Impact Statement For the Southern California National Forests

While some portions of the Management Plan and DEIS are well done, important portions contradict standard ecological science, ecological fire science and grazing science. Other parts do not reflect or incorporate standard ecological science, ecological fire science or fail to adapt for the dramatically different ecosystem of Northern Los Padres.

As experts in forest ecology, central California fire ecology, imperiled species protection, grazing and environmental impacts in general for the Northern Los Padres National Forest we recommend --
 

• Rejecting all six Alternatives as each of them has at least one outrageously enormous (and easily avoidable) environmental impact, 
• Prepare and Analyze a Reasonable Alternative using portions of the adequate available segments of other Alternatives. It would resemble Alternative 6 - but without any prescribed burning. 
• Emphasizing imperiled species protection and restoration and ecological health (as Alt 6 implies doing),
• Eliminating all prescribed burning (which is almost unquestioned in all these documents and is contrary to that portion of Alternative 6) since the need is only an opinion - not a scientific claim (e.g. testable; using a unit of measure), and the solution has no scientific support,
• Removing all Grazing (as Alt 6 provides),
• Prohibition of all lead bullets because of their cumulative damage to condor restoration,
• The FS obtain and provide maps of all imperiled species habitat - so we all know which areas to avoid.

We have limited our comments to only a few of the myriad errors in these documents in hopes these documents will be revised using the best available ecological science, standard ecological fire science and grazing science and are adapted for the dramatically different ecosystem of Northern Los Padres.
 

Part One

The adaptive management plan graphic on page five is well-done.

Vision, page three

We greatly appreciate that you recognize the world importance of our forests as biodiversity hotspots. We also appreciate your providing account of the number of federally listed imperiled animals and plants. We request that you add to this all the species listed by California as imperiled.

We hope you recognize that the Northern Los Padres National Forest is highly distinct from the other forests in this plan in that it is not one most urban influenced forests in the national Forest service system. While fire may be a fact of life in Southern California, the Northern Los Padres National Forest is clearly not in Southern California. It is most commonly referred to as located in Central California. 

Ecosystems, geology and climate are often dramatically different in Southern California. For example the Northern Los Padres National Forest hosts the southernmost extent of the native Redwood Forest, the southernmost ranges of the imperiled marbled murrelet, the Northern spotted owl and the Southern Sea otter. 

Vision, page four

What are "desired non-native plant, fish and animal species?" We are uncomfortable with this comment and its potential to undermine protection of native imperiled plant, Fish and animal species.

Vision, page five

We disagree that "Wildland fire may be the biggest challenge facing Forest managers..."

While not as dramatic and fear inducing as a wildland fire, the extinction of species depending on our national forests for their homes, has a direct cause-and-effect relationship which humans ability to exist on this planet. "Prescribed burning" can directly increase extinction risk to imperiled species.

We feel it of paramount importance to recall that a recent fire in the Northern Los Padres National Forest resulted in more than 70 miles of bulldozed roads in a wilderness! A wilderness where all mechanical equipment is prohibited. While we strongly support the use of fire stopping equipment when it endangers occupied residences, we are outraged at the 70 miles of destruction of wilderness, its forest, its fragile ecosystem and its soils.

As USGS ecologist Jon Keeley has shown, winds (e.g. Santa Ana) are a magnitude more important for wildland fire severity in S. California than any other reason. This completely undermines any rationale for prescribed burning.

Vision, page six

* Please add " law enforcement" to the Fire management challenges list just as you have included it under the urbanization management challenges list. Humans are now the primary cause of wildland fires.

As an expert in Monterey pine forest ecosystem fire ecology, I can state with confidence that fire is a highly complex subject, nowhere near as absolute or black-and-white as your document asserts. 

While fire may be a fact of life in Southern California, the Northern Los Padres National Forest is in a very different climatic region. Some experts are surprised to learn that there is no analogous Santa Ana hot wind phenomena in this area. 

In addition --

"This foggy California coast, by a significant amount, experiences among the world's lowest onshore thunderstorm frequency, at less than 5 per year (McKnight). Similarly, it has among the world's lowest onshore lightning incidence outside the polar regions (Burton) and among the lowest lightning frequency in the lower 48 states. (Diels et al) at less than one flash per 8 square kilometers per year (Boccippio et al.). That low rate of measured flashes includes the high frequency of flashes induced by the 5,000 ft. Big Sur mountain range." - Native Monterey Pine Forest Natural Fire Scarcity Systematically Underestimated and Misrepresented, D.J. 
Dilworth, 2004 

1) unsupported by any evidence in the document, and

2) an unscientific claim since no units of measure are provided, let alone any actual measurements to support these un-scientific opinions.

Bullet six:
While "allowing fire to play a more natural role" maybe indeed a laudable goal, that is a dramatically different topic from "use of fire" - presumably meaning intentional human set forest burning - which is anything but a natural role.

There are literally no studies showing that prescribed burning can mimic the effects of natural fire with out causing significant other environmental damage.

We strongly support "allowing fire to play a more natural role", but 
We fiercely oppose intentional human set forest burning - which is anything but a natural role.

Wildlife and Plants
* Please add " law enforcement" to the Wildlife and Plants management challenges list just as you have included it under the urbanization management challenges list.

Please reconcile the numbers on page six and the numbers on page three for imperiled species (62 versus 31 plus 29).

The first management challenge is inadequately and ambiguously worded. Please change the bullet point to read "The primary goal is to reverse the trend of human demands forcing species towards extinction." 

Vision
Please change the first sentence so that it reads "... ensuring short and long-term ecosystem health..."

We find no justification for any "flow of goods" from the Southern California forests.
Please remove the words "goods and".

 Strategic Goals

Please add as goal number one --

"Goal 1: Protect and Restore Imperiled Species Habitats"

"Outcome: Provide sufficient species and habitat protection that all currently listed imperiled species are removed from ESA listing, with assent from environmental public interest groups, due to their long term stable and biodiverse populations."

Assent from environmental public interest groups is vital since and federal agencies have to be sued regularly or to uphold the minimum protections of the Endangered Species Act.

Resource Management
The use of mostly non-imperiled species is, at best, far removed and at worst irrelevant from daily direct impacts on ecosystems. Ignoring the immediate and direct impacts on imperiled species is gross mismanagement.

Please add to Table1.1 --

West Coast Steelhead (Oncorhynchus mykiss, or O. mykiss), and
the California Red-Legged Frog (Rana aurora draytonii). 

These are imperiled species which can give direct and immediate indicators of ecosystem health. Because of their differing ecosystem needs these two species together give a multi-dimensional picture of  watershed health.

"Restoration" of Forest Health

We feel it is of paramount importance to recall that a recent fire in the Northern Los Padres National Forest resulted in more than 70 miles of roads bulldozed in a wilderness! ; a wilderness where all mechanical equipment is prohibited ! While we strongly support the use of fire stopping equipment when it endangers occupied residences, we are outraged at the 70 miles of destruction of wilderness, its forest, its fragile ecosystem and its soils.
 

* We strongly support "allowing fire to play a more natural role", but 

* We fiercely oppose intentional human-set forest burning - which is anything but a natural role.

Strategy page 13
10,000 acres needed annually for Prescribed Burns.

This is so far past outrageous it is beyond words. It contradicts standard ecological science and ecological fire science. 

NEED is Anti-scientific
Just to give you a hint of the top of this anti-scientific iceberg - answer this simple question - 

* What unit of measure do you use for overstocked forest, or brush or understory accumulation?

Having read some 150 journal articles on forest fire ecology, I can state that only one actually measured and described understory biomass in an amount. I will be surprised if your documents relied on any such  solid science on this matter.

SOLUTION is Anti-scientific

* What real on-the-ground studies (not theoretical papers) do you rely upon to show that prescribed burning produces the same ecological results as natural fires?

Hint: There are none.

---------------
Alternatives

Alt 1 fails because --
It uses extensive prescribed burning and fails to protect and restore imperiled species.

Alt 2 fails because --
It uses extensive prescribed burning and fails to protect and restore imperiled species, it retains all active grazing and converts some road to motorized roads.

Alt 3 fails because --
It uses extensive prescribed burning and fails to protect and restore imperiled species, it retains all active grazing.

Alt 4 fails because --
It uses extensive prescribed burning and fails to protect and restore imperiled species, it retains all active grazing and it develops and OHV road system.

Alt 5 fails because --
It uses extensive prescribed burning and fails to protect and restore imperiled species, it retains all active grazing and it develops extensive OHV road system.

Alt 6 fails because --
It uses even more extensive prescribed burning.

The only alternatives presented are unacceptable. We are allowed to have more alternatives than merely "do you want to be hung, poisoned or shot?"

* We insist that a pro-environmental alternative be analyzed. It would resemble Alternative 6 - but without any prescribed burning. 
 

Northern Los Padres - Composite Alternative Needed

Because the Northern Los Padres National Forest is so highly distinct from the other forests in this plan, as recognized on page 3-30, we feel strongly a special Alternative can and should be assembled from the adequate available segments of other Alternatives.
 

• We urge the complete cessation of grazing in the Northern Los Padres Forest.

Grazing has severely degraded, destroyed or at least permanently altered entire ecosystems on hundreds of millions of acres of Western Public and private lands. "No other human activity in the West is as responsible for the decline or loss of species as is livestock production."

* GRAZING'S DIRECT IMPACTS include: Trampling from Grazing, Soil Compaction from Grazing, Grazing caused Vegetation Biomass loss, Grazing caused Riparian Vascular Plant Cover Loss;

* SOIL IMPACTS FROM GRAZING include: Grazing caused Litter (Soil cover or "Duff") Loss, Decreased Infiltration from grazing, Increased Water Runoff from Grazing, Doubled Water Erosion from Grazing, Wind Erosion from Vegetation Cover loss from Grazing;

* STREAM IMPACTS FROM GRAZING include: Sedimentation Doubling, Grazing caused Streamflow Timing & Flow change, Flash floods increase from plant cover loss from grazing, Stream Temperature Increases from Grazing, Animal Waste Harm to Waterbodies;

* WILDLIFE IMPACTS FROM GRAZING include: Endangered & Sensitive Species Harm from Grazing, Raptor prey species habitat reduced by Grazing, Wildlife Deaths due to Grazing Fences, Wildlife Deaths due to Utility Lines, Grazing caused Trout Biomass loss, Fish kills from Cattle Wading;

* VEGETATION IMPACTS FROM GRAZING include: Riparian Willow cover loss from Grazing;

* GRAZING ECOSYSTEM IMPACTS include: Grazing Induced Desertification, Grazing caused Biotic Productivity loss from Sediment increase, Riparian environment Shade Loss from Grazing, Bird diversity loss caused by vegetation diversity loss from Grazing, Hydraulic Conductivity loss from Grazing, Grazing harming nesting success, Soil Temperature increase from grazing, Fecal coliform increase from grazing, Sedimentation increase from overgrazing affecting stream hydrology, Cryptosporidium increase from grazing.

Grazing Elimination Alternative

Eliminating grazing would reduce impacts from: 

Direct Impacts including Trampling, Soil Compaction, Vegetation Biomass loss, Riparian Vascular Plant Cover Loss;

Soil Impacts including: Litter (Soil cover or "Duff") Loss, Decreased Infiltration, Increased Water Runoff, Doubled Water Erosion, Wind Erosion from Vegetation Cover loss;

Stream Impacts including: Sedimentation Doubling, Streamflow Timing & Flow change, Flash floods increase from plant cover loss, Stream Temperature Increases, Animal Waste Harm to Waterbodies;

Wildlife Impacts including: Endangered & Sensitive Species Harm, Raptor prey species habitat reduction, Wildlife Deaths due to Grazing Fences, Wildlife Deaths due to Utility Lines, Grazing caused Trout Biomass loss, Fish kills from Cattle Wading;

Vegetation Impacts including: Riparian Willow cover loss;

Grazing Ecosystem Impacts including: Grazing Induced Desertification, Biotic Productivity loss from Sediment increase, Riparian environment Shade Loss, Bird diversity loss caused by vegetation diversity loss from Grazing, Hydraulic Conductivity loss, Grazing harming nesting success, Soil Temperature increase from grazing, Fecal coliform increase from grazing, Sedimentation increase from overgrazing affecting stream hydrology, Cryptosporidium increase from grazing.

This Alternative does not require any non-off-the shelf technology.
 
 

* Please revise the Plan, the DEIS and recirculate them with these improvements.

If this is not done, prior to the Final adoption we will fill the record with substantial evidence of all the statements made in this letter.
 

With all due respect,
 

David Dilworth, Executive Director