Last month, the Forest Service released its long-awaited Spruce Beetle Sudden Aspen Decline Management Response (SBEADMR) draft Environmental Impact Statement (EIS). From the beginning, HCCA has pointed out the need to focus on public safety. Removing hazard trees so infrastructure, structures, and communities are protected must be the top priority. These activities must also occur where it truly counts – which is within close proximity to such features – not miles in the backcountry.

We need a proposal from the Forest Service that identifies these top priority areas to insure those are addressed first and foremost. SBEADMR is proposed to last for an 8-12 year period and treat up to 120,000 acres of our National Forest lands – all only a single formal environmental analysis process―the process undergoing right now. The Forest Service is proposing that public involvement would occur through an “adaptive management” approach. For HCCA, this does not cure the need and requirement to disclose and analyze impacts as the project is implemented and seriously hamstrings analysis of impacts due to the lack of site-specific impacts being  provided. As the proposal currently stands, the public and the agency is left guessing about what the impacts may be, among other things.

What little we do know is concerning, particularly in light of the Forest Service’s approach to evade any later formal environmental analysis. SBEADMR proposes to annually treat 6,000 acres commercially and 6,000 acres non-commercially throughout the life of the project. This triples the current amount of acres treated forest-wide. Additionally, each action alternative proposes miles of new temporary and designed roads. In fact, two of the three action alternatives propose 60 miles of new designed roads and 260 miles of temporary roads. Because we already have an unsustainable amount of roads on the forest, both ecologically and fiscally, this is an alarming amount of new designed roads, especially as there is a possibility these would remain on the road system. Roads fragment habitat, contribute to the spread and increase of invasive weeds, and increase sedimentation in our mountain streams―more roads is the last thing we need on our forested lands.

Comments are most helpful when they provide specific points.
As promised, here is a robust list of issues to assist you in drafting your comments.

HCCA is concerned that:

SBEADMR would not reduce fire risk or additional spruce beetle attacks, we need to focus treatments where it will defend our communities, not in the backcountry. Public safety should be the single and top priority in the SBEADMR.

  • Spruce-fir forests don’t burn often and there is no evidence that fire-suppression has resulted in the fire regime or current forests being outside the historic range of variability. Drought controls whether spruce-fir forests burn- not fuels. This – calls into question goals of thinning the forest.
  • Reducing risk of additional spruce bark beetle through treatments would likely be ineffective because an insignificant amount of spruce would be treated. Previously treated areas can be attacked by spruce bark beetles.
  • The proposed cuts in aspen are not needed because aspen is reproducing well on much of the GMUG NF, and future fires will regenerate more aspen.
  • Proposed cuts in aspen are unnecessary. Aspen is reproducing well on much of the GMUG NF and future fires will regenerate more aspen. Activities should exclude areas where natural regeneration is well-established, including areas where species may be mixed with less “merchantable” species. Mixed conifer forests are the most resilient to disease.
  • The Forest Service should provide better analysis regarding the impacts clear-cutting on spruce regeneration. Spruce is a shade-tolerant species. Large open areas after a treatment are likely to become unsuitable for spruce and generally planting this species has low success rates. Well-established natural regeneration must be protected.
  • Public safety must be the top priority.
  • The Forest Service must ensure limited resources are used wisely to protect our communities. Research shows that a maximum of a 132 foot buffer is sufficient to protect structures from a fire. Thus, the Forest Service should adopt a quarter-milebuffer standard. This would allow firefighters room to stage.

The Forest Service must disclose and analyze site-specific and cumulative impacts.

  • Additional site-specific information is needed regarding size, location, and scale of individual projects that may be proposed under the SBEADMR (including the proposed location of roads).
  • Without site-specific information, the public and ultimate decisionmaker cannot assess the incremental cumulative impacts this proposal would have when added to past, present, and reasonably foreseeable actions on the forest and surrounding lands.

The proposal needs to represent a reasonable range of alternatives, with different proposed amount of acres to be treated.

Proposed cuts would damage, destroy, and fragment important wildlife habitat.

  • The proposed cuts would damage, destroy, and fragment habitat for the threatened lynx and other species like marten, boreal owl, and purple martin.

New designed roads should not be used as part of this project as the existing road system is unsustainable and having negative impacts on our forest ecosystems.

  • The Forest Service must use existing roads to the greatest extent possible. New roads should not be part of this project given the current unsustainable road system on our forest already.

You can submit comments 3 ways:
1.
 E-mail Scott Williams, scottwilliams@fs.fed.us 760-382-7371

2. Fill out the form found at http:www.fs.usda.gov/goto/SBEADMR_comments

3. Send hardcopy to:
Scott Armentrout, Forest Supervisor
Attn: SBEADMR
2250 Highway 50
Delta, CO  81416