The Forest Service on February 5, 2016, released the Final Environmental Impact Statement (FEIS) and Draft Record of Decision (ROD) for the Spruce Beetle Epidemic and Aspen Decline Management Response (SBEADMR) proposal, its heavy-handed reply to beetle outbreaks and Sudden Aspen Decline (SAD) on the GMUG National Forests. The agency is proposing to implement commercial and non-commercial timber management actions to address forest health issues on a massive scale.

At its heart, SBEADMR would “treat” 120,000 acres of National Forest land over the next eight to twelve years, amounting to seven percent of the spruce-fir and aspen forests on the GMUG.

Since SBEADMR’s inception in 2013, HCCA has expressed concerns with this proposal and worked with the Forest Service and diverse stakeholders to lessen its negative environmental impact and focus its timber treatment to areas where hazard tree removal is actually necessary and desired: near critical infrastructure and communities. However, as proposed by the Forest Service, SBEADMR’s purpose and need are unjustified, it’s geographic scope too large, its analysis too vague, and its adverse impacts too severe. HCCA remains committed to vegetation treatment that focuses on public safety and critical infrastructure instead of mass manipulation of forested landscapes that are ultimately counterproductive and unnecessary.

Purpose and Need – The purpose and need of the project is ostensibly to address safety, recovery and resiliency concerns on the National Forest. Unfortunately, analysis by HCCA reveals that SBEADMR would cause adverse impacts without providing much benefit. In fact, treatments would not likely reduce future beetle attacks, nor would they result in a significant reduction in the potential severity of wildland fires. The treatments could even increase the fire hazard. There is no reason to approve and implement the proposed treatments at the scale proposed by the Forest Service.

Geographic Scope – Based on anticipated implementation capacity, this project will treat up to 120,000 acres (up to 60,000 acres each of commercial and non-commercial treatments). The area considered in the FEIS preferred alternative encompasses approximately 207,600 acres in spruce, aspen, and spruce-aspen cover types throughout the GMUG National Forests.

Vague Analysis – Site-specific documentation of impacts is lacking. In response to public comments the Forest Service has incorporated a public notice and comment period for vegetation treatments during the course of SBEADMR implementation, but the treatments are still not subject to NEPA, and there is no assurance that comments will be considered.

Adverse Impacts – SBEADMR’s proposed action would lead to 178 miles of new road construction on the GMUG to access areas for logging and other treatments. While the Forest Service states that all new roads would be decommissioned within five years of project completion, current controversy on the Gunnison National Forest concerning decommissioning raises questions about this. Adverse impacts to wildlife, water quality and forest regeneration are likely for the life of the project and beyond. The Forest Service acknowledges that its proposed action is not the environmentally preferable alternative.

The deadline for filing an administrative objection to this proposal is March 21st. HCCA and our conservation partners are busy analyzing the FEIS, Draft ROD and associated documents, and will continue our efforts to secure a project that focuses on public safety. We are hopeful that the objection process will lead to positive resolution of our concerns.

If you have questions, please contact HCCA’s Public Lands Director Matt Reed at