Environmentalist Community Appropriations Language Offer
April 30, 1997
QLG provides the following comments and insights to the Environmentalist Community proposal to provide Appropriations language in lieu of legislation
H.R. 858 calls for a five-year plan, an essential element of the QLG proposal. The reason for the five-year period is to provide an opportunity to prove or disprove this "experiment" while also providing adequate time to implement LMP revision/amendment processes that allow for the public participation we are all advocating. A single year is an insufficient amount of time to conduct NEPA, plan projects, contract, implement, monitor and evaluate the environmental and economic value of the program.
QLG also questions the likelihood that Democrats will secure funding from a Republican controlled Congress to fund a program that national environmental organizations do not support.
The QLG legislation calls for 40,000-60,000 acres of fuelbreaks annually, which provides the beginning of a 32-year program that will ultimately reduce fuels and the likelihood of huge catastrophic fire. The pace of the shaded fuel break construction program seems large to some, but the QLG area forests contain 1.564 million acres (areas available for group selection) of forested, already-roaded and harvested lands, much of which used to have average fire return intervals of 7-15 years. The pace advocated by the QLG would not fully restart the natural fuels treatment rotation, but at least would get these lands closer to the historic fire periodicity and able to sustain natural fire intensities and amounts.
At 30,000 acres annually, the long-term fuel reduction effort will take 64 years, with the initial fuelbreaks in place in 8-10 years. At this rate, the first fuelbreaks will be overgrown before the last ones are built.
The QLG proposal, employing unit area control at an estimated 9,300 acres of group selection, provides for an average of 175-200 year rotation, and annual aerial disturbance of 0.57% of the landbase-- these are all figures that are consistent with the amenity/environmentalist alternatives in the Land Management Plans. The proposed 1,000 acres of group selection provides for a 1,600 year rotation, for which there appears to be no scientific basis.
The QLG bill calls for making the 50,000 acres of fuelbreaks plus the 9,300 acres of group selection a priority. While the current legislation does not definitively spell this out as a requirement, the Forest Service will be pushed to complete these acres target, thus leaving little room for "additive" vegetation mangement programming.
Much of the SNEP area is already excluded from management in the QLG proposal. We would note that the SNEP ALSE chapter authors explicitly stated that the ALSE maps were not valid at small scales and that prohibitions on all mechanical treatments were not advocated by the SNEP authors. Additionally, the QLG wonders where is the NEPA compliance to make this decision? Would it not be better and more appropriately addressed in H.R. 858?
An explanation of why this must be an element of discussion/negotiation would be helpful. Furthermore, QLG again raises the issue of the likelihood of achieving appropriations language given the Republican majority in Congress.
QLG does not believe that there were any "areas of agreement' (other than perhaps threads of the philosophical) reached on April 8. One concern is that any areas of agreement that may have been perceived do not include the scope of thinning or group selection.