October 16, 1995

To: Quincy Library Group
Fr: Steve Evans
Re: Barkley Salvage Sale

Although not a signatory to the Quincy Library Group (QLG) proposal, I have always supported efforts of the group to come to a consensus on how our public forest lands should be managed. More than a decade ago, I helped the Friends of Plumas Wilderness develop the conservation alternative for the Plumas Forest plan and was the primary designer of a similar alternative for the Lassen Forest plan. The conservation alternatives for both forests were later revised and updated with my input and became the land base used by the QLG to identify those "sensitive" areas which would not be subject to timber harvest for five years.

To my dismay, the Forest Service is soliciting bids on a timber sale in a "sensitive" area which is off-limits to logging in the QLG proposal. The Barkley sale is located in the Polk Springs roadless area on the Lassen National Forest. The roadless area encompasses a portion of Deer Creek which includes critical spawning and holding habitat for the de facto endangered spring run Chinook salmon and winter steelhead. The sale would result in the construction of approximately two miles of road and logging of 2.5 mmbf of timber in the roadless area.

I and many other people and organizations have submitted extensive comments concerning the potential impacts of the Barkley sale on these sensitive resources. Unfortunately, our ability to seek full administrative and legal relief concerning this sale has be effectively foreclosed by Congress which exempted so called "salvage" sales from most of nation's environmental laws. The Forest Service is now scheduled to review bids for this sale on October 18.

There are several compelling reasons why the Barkley Sale should not proceed, including:

1. The Barkley Sale violates the Quincy Library Group land base which is off-limits to timber harvesting for five years. The argument will be made that the QLG proposal does not expressly prohibit salvage logging in response to a catastrophic fire. Nevertheless, the QLG proposal plainly exempts sensitive areas such as roadless areas from logging for five years. In addition, most of the catastrophic impact of the 40,000 acre Barkley fire occurred on private land, not on public land. The vast majority of public lands burned in the Barkley fire were part of an oak, grassland and chaparral ecosystem which requires periodic fires in order to remain healthy. The Forest Service identified only 265 acres of burned timber lands in the Barkley Sale area and initially proposed salvage logging only 200 acres. More recently, the acreage slated for salvage decreased to 176 acres. The situation on public lands is not a catastrophe requiring some kind of emergency exemption from the QLG proposal.

2. The Barkley Sale violates basic scientific principles for the management of watersheds which support "at risk" stocks of anadromous fish. Before he became Chief of the Forest Service, Jack Ward Thomas helped develop an Aquatic Conservation Strategy to address the need to better manage watersheds which support endangered salmon and steelhead. A basic premise of the strategy is that roadless areas in anadromous watersheds act as critical refugia and provide high quality water for endangered fish. The strategy prohibits the construction of roads in roadless areas and requires extensive watershed analysis prior to any major action which could impact fisheries and water quality. A much more politicized and weaker version of the strategy was adopted in the PACFISH standards used by the Forest Service in developing the Barkley Sale. PACFISH fails to protect roadless areas and does not require extensive watershed analysis prior to road building or logging in roadless areas.

3. The Barkley Sale violates federal environmental law, including the Endangered Species Act. Acting in good faith, conservationists delayed submitting a petition to list the spring run Chinook salmon as an endangered species, while we work with government agencies, land owners, anglers and other interest groups in taking steps to protect the species. If we acted when our petition was drafted, the spring run would undoubtedly been listed and the Barkley Sale would have probably never been proposed. Now, our good faith is essentially being trampled by the Forest Service and a Congress which appears intent on fanning the flames of conflict rather than encouraging mutually agreeable solutions. Given these compelling reasons, I urge the QLG to join conservationists in demanding that the Forest Service drop the Barkley Sale. Having been denied administrative and legal relief, we may have no choice but to argue this issue in the "court" of public opinion. This scenario will undoubtedly increase the level of rhetoric, raise questions concerning feasibility of the QLG proposal, shed light on private timber land management practices adjacent to the sale, and generally make it more difficult for us all to work together in the future. This can be avoided if the Forest Service can be convinced to drop the sale.

I plan on attending the QLG meeting on Thursday, October 19. If you would like to discuss this issue beforehand, please call me at (916) 442-3155 or at home.

Thank you for your consideration.