A Grassroots Look at the Quincy Library Group

April, 1994

Dear Quincy Library Group Members,

We are a group of grassroots environmental and conservation organizations local to the Sierra Nevada who are writing to you regarding the Quincy Library Group's "Community Stability Proposal". We understand that the Quincy Library Group is comprised of both timber industry representatives and local conservationists, and has recently been seeking broad support for the "Community Stability Proposal". This proposal addresses management of forest lands within the Lassen, Plumas, and parts of the Tahoe National Forest.

We share the QLG's interest in Our own communities, and in rural economies that are viable in the long term. Each of us have grappled with the apparent contradictions between Our desire to prevent ecological destruction on Our public lands and in the Sierra Nevada as a whole, and our need to work with our neighbors who may be economically impacted by changes in the industries that have been engaged in unsustainable logging practices. We respect the Quincy Library Group members' desire t6 work together.

As citizens of the Sierra Nevada, we are interested in and affected by management of Lassen, Plumas, and Tahoe National Forests. Some of us have commented in activities on these Forests, and been involved in planning. In addition, many of us have been approached by government officials or industry representatives and asked to be involved in a process similar to the Quincy Library Group, elsewhere in the Sierra. What happens inside the Quincy Library Group has a great impact on the rest of us working on similar issues throughout the Sierra Nevada. Others' perceptions of agreements that have been made by the QLG influence us all as we consider similar approaches in other regions of the Sierra. Some individuals seem to think that the Community Stability Proposal would be a “way out" of compliance with environmental laws. After conversations with Quincy Library Group members and specific requests for information, we recognize the falsehood of this perception of the QLG's intent. However, we remain concerned about the lack of specificity that the Proposal offers.

We hope that by communicating directly to the group with our questions, we will better understand the intent and the specifics of the Community Stability Proposal. The questions that follow are those that have arisen out of numerous conversations between grassroots groups, and out of interaction with other, non-local groups. Many of the questions are somewhat technical. We do not know if the QLG has addressed these questions yet as a group. If you have, we hope that it is possible for group members to provide written answers that will help to clarify some of our questions. It is likely that some of the many questions that follow will not have been addressed by the group; if this is the case, we hope that our questions will help to define some of the issues and concerns that we have when looking in from outside the QLG at the Proposal.

1. Does This Proposal Provide for Public Input, for Environmental Analysis that Will Allow Undesireable Impacts on Forest Ecosystems to Be Recognized, and for Avoiding Significant Environmental Impacts?

Environmental laws, such as the National Forest Management Act and the National Environmental Policy Act, require public participation in decisions, as well as detailed analysis of proposed plans and actions; and also set forth procedures for ensuring that information is gathered and that the public is informed. In addition, many specific provisions of the NFMA are intended to insure that Forest Service actions do no result in destruction of plant and animal communities, water quality, forest soils, and other, resources. It is widely recognized that the Forest Service has failed in some of the duties prescribed by these laws, such as information gathering and monitoring that provides information about the effectiveness of practices intended to avoid impacts to water quality and wildlife.

We have appealed Forest Plans and individual timber sales, and have worked long and hard with Forest Service officials, to ensure that forest ecosystems and unique areas we know and love would be cared for properly. The Forest Service is finally beginning to at least acknowledge the need to have basic information about forest ecosystems, such as where old-growth exists, before planning logging in sensitive and unique areas. Because information including sensitive species surveys and identification of old-growth has not been gathered consistently, the Forest Service is still some way off from a real understanding of the current condition of forest habitat, water quality, and basic ecosystem responses to management.

While the Quincy Library Group proposal states that Federal law will be followed, we have several questions regarding the ability of the group to ensure that this occurs. For example, the National Forest Management Act requires that the Forest Service maintain well distributed, viable populations of native vertebrate species on public lands; yet information regarding some species (such as the fisher) and availability of suitable habitat makes it difficult to determine whether or not this goal is being met at this time.

The National Forests that this proposal addresses include a large portion of the Sierra Nevada, and provide necessary connectivity with the Cascade range and forests to the north. The Mill and Deer Creek watersheds on the Lassen National Forest provide habitat to the remaining spring-run Chinook salmon in the Sacramento river watershed. The Lassen and affected portions of the Tahoe National Forest are the locations of some of the few recent wolverine sightings in the Sierra Nevada. The botanical resources on these forests are rich. The Plumas, Lassen, and Tahoe National Forests contain critically important old-growth forest that would be affected by logging under the Quincy Library Group Proposal.

We believe it is essential that the Proposal be designed such that other legally required environmental protections are not compromised. For example, we believe that project compliance with the Regional Forester's interim decision regarding the California spotted owl is necessary.

In addition to questions regarding the landscape itself, we also have questions regarding wider public participation in the development of direction for public lands. We believe that answers to the following questions will benefit all concerned by helping to identify potential conflicts with federal law.

A. Concern About Maintaining Biological Diversity and Healthy Forests On Public Lands: Compliance With The National Forest Management Act (36 CFR Part-t 219; see for example 219.19, 219.26, 219.27 (g))

National Forest lands are vitally important to the maintenance of native ecosystems in the Sierra Nevada. Minimally disturbed forest is a valuable protector of water quality, and a reservoir of information about native plant and animal communities. We are particularly concerned about logging that may be planned in old-growth forest that lies outside of the proposed set-aside areas. The descriptions of logging provided are vague, but appear to be likely to result in negative impacts to sensitive species habitat, such as spotted owl and fisher habitat. The following are some questions that we believe should be answered prior to logging in old-growth habitat; habitat that may or may not be available in sufficient quantities to ensure viability of species.

1. The proposal states, "Old Growth: It is our opinion that (as long as the above practices and policies are successfully implemented) the remainder of the forest landbase should remain available for timber management" (Quincy Library Group Community Stability Proposal, November 1993, pg. 3). What information is available to support this opinion?

a. To the best of the group's knowledge, where and how much potential late successional forest exists outside of the set aside areas? To what degree is the existing landscape fragmented?

b. How many acres, and in what spatial configuration are the deferred areas? How much of these areas are old-growth forest? Were the quantity or the design of set aside areas based on scientific information or principles (e.g., landscape ecology, population biology, conservation biology)? It would be helpful if documents or literature were referenced.

c. How will species viability be insured, and what information will be utilized in attempting to design agency actions so that impacts to sensitive species are avoided?

d To what degree has the QLG addressed impacts of soil disturbance and road construction associated with logging in old-growth and late successional forest habitats? In addition to the obvious impacts of logging on the trees and forest structure, have impacts on soil processes, plants, and other less visible aspects of forest ecosystems been assessed? Have sensitive and unstable soils been identified?

While some of these questions are difficult to answer at this time, your answers will help us to understand the thinking behind the contention that group selection logging within late successional and old-growth forest on the three National Forests will not be problematic.

2. How will Sensitive lands be identified outside of the existing- set aside areas?

Other than by setting aside forests identified for protection in conservation-oriented Forest Plan Alternatives, the QLG Proposal does not specify if other sensitive areas will be set aside, or how sensitive areas will be identified. Those alternatives were developed often over five years ago, and may not reflect information available today. There exist areas in which timber management is likely to be somewhat controversial due to the sensitive nature of the resources affected. Examples of such areas include Botanical Special Interest Areas proposed in the Plumas National Forest LRMP, which have yet to be formally adopted. Another example is the Perazzo project in the Tahoe National Forest, which has met with opposition from local environmental groups that do not sit on the QLG steering committee.

Have groups, individuals, or relevant resource professionals familiar with the three Forests been queried as to potentially sensitive areas outside of the agreed upon set asides? Will this process include the rest of the public?

3. Will the Group Selection logging mentioned in the proposal be conducted according to the recommendations of the of the document entitled: "The California Spotted Owl: A Technical Assessment of its Status"?

These recommendations represent the best available information at this time as to the habitat requirements and potential threats to the California spotted owl. These recommendations were also made policy by Regional Forester Ronald Stewart in January of 1993. Is it the intention of the Quincy Library Group for logging to be conducted in a manner that conforms to prescriptions given within these recommendations?

B. Will Evaluation of Environmental Impacts and Discussion Relating to Potential Impacts Be Conducted in a Manner that Complies With the Requirements of the National Environmental Policy Act?

Because of the significance of the resources involved, and their importance to the maintenance of the Sierra's ecosystems in the long term, we need to be reassured that that the proposal be subject to detailed analysis and be available for full public and agency comment, as required by NEPA.

1. Does the QLG Proposal address fire danger and fire ecology in a specific and biologically credible manner?

a. Has analysis of the location of priority areas for fuels reduction outlined in the CASPO report been completed?

b. Have specific prescriptions for fuels reduction been identified? If so, what are they? On what size trees will prescriptions focus? What sort of slash treatment will be recommended? Will the prescription result in marketable timber sales?

c. Has the group discussed the ability of logging to result in meaningful reduction in fuel levels across the landscape while still providing an economically valuable product, and maintaining wildlife habitat Are there perceived conflicts between prescriptions that would best "fire-proof' stands, and those that will provide economically viable timber sales?

d. To what degree does the group expect or intend to encourage the use of prescribed burning to "fire-proof” forests? The effects of low intensity fire that is thought to have been a regular part of Sierran forest ecosystems, and the effects of logging are quite different in many ways. To what degree has the group discussed this issue?

2. NEPA ensures the credibility of scientific discussions, and requires that impacts be fully evaluated. How will this analysis be completed?

a. Does the QLG intend that this proposal receive full NEPA analysis?

b. The Proposal is intended as a short term proposal. Will the timing of NEPA documentation for this proposal be completed prior to the completion of the Region 5 CASPO EIS that is currently underway? If not, perhaps the CASPO EIS would be an appropriate forum for NEPA analysis.

c. Does the group have any agreement that ensures monitoring will occur? Does monitoring depend on USFS funding? If monitoring cannot be funded, what aspects of the Proposal does the QLG intend to be implemented?

In the Sierra Nevada, effectiveness and implementation monitoring that is required by Forest Plans has often gone unfunded and unaccomplished. The QLG has publicly emphasized the importance of monitoring, but the Proposal fails to specify any means for making certain that monitoring occurs.

C. Public Participation and Decision-making on public lands

1. To what degree does the group intend to encourage and allow public participation in decisions made by the QLG regarding the use of public lands?

a. How does the Quincy Library Group plan to solicit broader public comment on the Community Stability Proposal? Will a NEPA document be available for public comment and participation?

b. Are maps or legal descriptions of land to be set aside available to the public?

c. Many of the people participating in the QLG are located near the Plumas National Forest and Quincy. Are the Lassen and Tahoe National Forests well enough represented at the table, by people from all "sides" of the issue? Given that Quincy is quite far from many locations on the Tahoe and Lassen National Forests, can the QLG adequately serve as a community forum for the broad area that the Proposal covers?

The Quincy Library Group has taken on a very large task. The group is now challenged to find ways of expanding access to information and discussion that have been available to QLG members. Many interested groups elsewhere have little knowledge of the QLG and the Community Stability Proposal. How does the group intend to involve outside parties, and to make sure that interested parties who live outside of Quincy are able to participate in public lands planning?

II. Will the Proposal Foster Community Stability In the Long Term?

As conservationists and citizens of the Sierra Nevada, we have concerns about the long term economic environment of the Sierra. Mills have become fewer as timber supplies diminish, and as larger companies merge and expand their influence. While our primary focus is on the environmental aspects of the QLG's proposal, we are aware of the degree to which the market influences resource management decisions. We are also residents of local communities, who are concerned about the economy of the Sierra Nevada in the long term. We hope that the group will consider the questions below, and that these questions help to formulate the important discussions needed to identify both short and long term goals for the economies of our communities.

We recognize the potential that the QLG proposal may give mills local to the Proposal a market advantage over other mills in the Sierra. The "working circle" concept has the potential to impact competition in the market. In addition, the QLG's request for a congressionally designated "sustained yield unit" has raised concerns in light of the history of this designation. This designation has the potential to result in control over public resources by a few, large companies, at the expense of the environment. For example, the Shelton sustained yield unit in the Olympic National Forest has been highly 'controversial for related reasons.

Sierra Pacific Industries, while fairly local to the affected region, is one of the largest single private landowners in the Sierra Nevada and purchases timber from well outside the local Forests. S.P.I. has also acquired many other mills and landholdings in the Sierra Nevada. There is a potential that further acquisition may also allow S.P.I. to have a dominant influence over the future of the area's resource economy, and over our local economies.

We are concerned about the assumption that community stability can be secured by attempting to insure that a few local mills continue to receive a timber supply that was considered "adequate" in the past decade. Today's mills exist as a result of decisions made in the economic and political environments of past decades. Given the existing scale of these mills, an "adequate timber supply" as defined by the mill's capacity may require ecologically unsustainable levels of timber harvest.

We are concerned that by banking on the survival of a few large mills, local community members may be helping to reduce economic diversity and fair market competition that is the foundation of our capitalist system. Could it hinder the ability of the timber market to respond to change in a flexible way? Will this help or hurt the economy of the Sierra in the long term?

Reductions especially in supply of very large old trees are inevitable. For example, on the Eldorado National Forest, the largest percentage reduction of old-growth forest is thought to have occurred in the past decade, in which 22% of the Forest's remaining old-growth was removed. An 80's level supply of trees that are several hundred yea old is not sustainable, and is not renewable at current rates of timber harvest.

We believe that community Stability should not be based on assumptions that this timber supply, which was "adequate" to the mills of the 1980's, win continue to be available. How does the Community Stability Proposal address changes in economics of mill operation in relation to supply?

A. The proposal states: "In order to provide an adequate timber supply for community stability and to maintain a relatively continuous forest cover a management system using group selection ...and/or individual tree selection... must be implemented immediately". On what information is this statement based?

1. What is an "adequate timber supply"? How much volume is needed to keep the mills open, and can the Forests provide it in an ecologically sound manner?

a. How was group selection determined to be necessary to providing an "adequate timber supply"?

b. Is there emphasis on a multi-product orientation at the mill level, such that products of CASPO fuels reduction efforts comprise some large part of the "adequate timber supply"?

c. How does this group propose to address supply fluctuations in the long term (that is, after the proposed five year period)?

2. How Will Community stability be protected if the timber supply is not "adequate"'?

a. If the mills close despite the QLG's efforts, are there any agreements that would provide community stability?

b. Has "community stability" been defined sufficiently? How has the relative stability of the community been assessed, and what specifically does the group wish to achieve? What historical information has been used to determine whether increasing supply of raw material to large, local, factory employers in the short term is an effective way of maintaining "community stability"?

c. Has the QLG addressed economic diversity for the community? Are there proposals for developing economic diversity in the timber-dependent communities represented by the Quincy Library Group? Does the group intend to work towards greater independence from the few large mills that make their towns "timber dependent”?

d. Large timber companies are conspicuous members of the QLG. Are other small mills and timber operators involved in the QLG? What about labor representatives? Could the agreement benefit some of these groups more and others, less?

B. Could the Proposal, and specifically the "Sustained Yield Unit" and "Working. Circle" aspects of the Proposal, create undesirable market conditions?

1. The QLG proposal states: "In order to adequately assure community stability ... stewardship contracts must be expanded, and a 'sustained yield unit' as authorized by Congress must be established."

a. Why "must" a "Sustained Yield Unit” be established? What specifically would this allow that is not allowed under existing Forest Service policy, environmental law, and other laws? Specifically, how will a sustained yield unit result in community stability and/or timber supply adequacy?

b. What impact on the timber market will expansion of "Stewardship Contracts" cause? Will Such an expansion restrict the ability of mills other than SPI and Collins Pine, and specifically mills with less private land holdings, to purchase timber from public lands?

2. Could the proposal encourage monopolies and reduce competition in the market, to the detriment of the industry and consumer?

a. Will the proposal adversely impact small mills and small logging companies within the working circle, and/or throughout the Sierra Nevada?

b. Will the proposal, directly or indirectly, reduce competitiveness in the market? Under the proposal, will competitive bidding for public timber occur? What limits are intended by the group with regards to who can purchase timber from the National Forests? Will the "Sustained Yield Unit" limit competitive bidding for public timber?

C. Could the QLG Proposal, and specifically the "working circle" and "sustained yield unit" result in ecological damage, or in exemption from environmental laws?

a. Will either of these proposals result in or be accompanied by requests for exemption from federal environmental laws?

b. Will these proposals increase the ability of one or two companies to exert a dominant influence on the management of public lands?

Conclusion

Your proposal is a bold attempt to move the current polarization of efforts in the Sierra into a rational and community solution to ongoing resource extraction issues. We are very interested in developing solutions and respect your pioneering efforts to do so. We hope that these questions will help to clarify some aspects of the Community Stability Proposal, as well as to provide us with information. We also hope by writing this letter to establish better communication with members of the Quincy Library Group. Thank you very much for reading this letter and considering our concerns.

We look forward to hearing from you.

Sincerely,

Sunday, January ,(, /),( 0(:,(:,( AM