Road Maintenance:

Over the past decade there has been a dramatic decline in the federal timber sale program. Coinciding with the reduction of sale offerings there has been a drop off in road maintenance. Historically, road maintenance has been funded through the timber sale program.  Road projects were developed and completed as part of sale contracts. The lack of maintenance has resulted in a number of problems with the transportation system.  Some of the problems include, increased sediment inputs into streams from roads, culvert failures, restricted access, loss of surface material, road prism failures and general decline in the road drainage system.

Part 212 – Travel Management, subpart A 212.2(c) requires the forest service to develop, fund and maintain an annual “program of work for the transportation system”. The proposed alternatives will have a direct impact on local revenue to the community which should be considered. However the TMDEIS doe not have a comprehensive discussion on this subject.

The maintenance work generated from the various alternatives has the potential to impact local contractors. Due to the current economic downturn, it is important to know which alternatives will provide the greatest opportunity for local contractors.  Which alternative will provide the best revenue stream for the community? TuCARE would like to request the forest service include a one-year program of work and a five-year forecast of work for each alternative.           

Wildfire frequency and Fire suppression:

Increasing fire frequency in recent years has become the focal point in many land management decisions.  It is a widely held belief that wildfire potential will continue to play a major role in future land management decisions across the region. Furthermore, the current decline in infrastructure has the potential to exacerbate this situation by delaying critical forest treatments.  The changes being considered in the proposed alternatives have the potential to impact fire frequency and suppression, yet the TMDEIS does not discuss the matter.

This leaves a number of questions unanswered. Such as, which alternatives increase the probability of ignition from recreation sources? Will changes in road classification lead to slower response times, resulting in larger fires and higher suppression costs? 

TuCARE would like to request the forest service conduct further analysis to determine the potential wildfire risks associated with the various alternatives.           

Hunting and Fishing Recreation:

One of the greatest attributes of our National Forest System is access for hunting wild game. All across America there is a family heritage of hunting and fishing on our nation’s public lands.  Local and valley residents have been traveling to the Stanislaus National Forest for many years to access hunting and fishing opportunities offered on the forest. Most trips to the forest take place early in trout season or late fall during deer season. Restrictions imposed by the wet weather closure provision and the expanded winter closure period will discourage sportsman and could lead to a decline in visitor days from this user group and subsequent loss of revenue to the community.

TuCARE requests the forest service drop the wet weather closure from the proposed alternatives.  In lieu of the wet weather closure and the extended winter closure period we would like to see impacts mitigated through road maintenance projects such as surface replacement, road reconstruction, road drainage improvement.  

Wet Weather closure:

As written all native surface roads, regardless of elevation, will be subject to closure for a 72-hour period after 1 inch of rainfall beyond September. This unfairly singles out hunters by limiting access during peak deer hunting conditions.  A number of other hunting seasons will be shortened and/or interrupted.  For example, spring turkey season runs from the last Saturday in March extending for 37 consecutive days.  April is commonly a wet period.  The wet weather closure will make it next to impossible to plan a trip during turkey season.  Access during bear, quail, small game and fishing seasons are all impacted by this provision.

Expanded Winter Closure Periods:

As written all roads between 3,000 and 5,000 feet will be closed from November 30th to April 1st. Above 5,000 feet roads will be closed from November 30th to May 15th.  The closure period for roads above 5,000 feet is completely unacceptable. The last weekend of April is the opening of trout season.  Under this plan there would be no access for fishing, camping, or fish planting until the middle of May. The expanded winter closures will also have considerable impacts to hunting seasons similar to those mentioned above. Below are the dates and duration for the hunting seasons listed in the fish and game regulations. We have also taken time to provide the figures 1 and 2 showing the impacts to the various seasons. 

California Department of Fish and Game Regulations:

1. 361.Archery Season:

361. (a)(4)(A)(2), The archery season in Zones D-3, D-4, and D-5 shall open on the third Saturday in August and extend for 23 days.

361. (a)(4)(B)(2), The archery season in zones D-6 through D-10 shall open on the third Saturday in August and extend for 23 days.

361. Deer Season:

361. (4)(3)(B), The season for zones for D-3 through D-5 shall open on the fourth Saturday in September and extend for 37 consecutive days.

361. (4)(5)(B), The season in Zone D-6 shall open on the third Saturday in September and extend for 44 consecutive days.

361. (c) Special Hunts

360. (c)(13) G-37 (Anderson Flat Buck Hunt). 

360. (c)(13)(B) The season for additional hunt G-37 (Anderson Flat Buck Hunt) shall open on the fourth Saturday in November and extend for nine consecu­tive days.

360. (C) (37) J-15 (Anderson Flat Apprentice Buck Hunt).

360. (C) (37) (B) The season for additional hunt J-15 (Anderson Flat Apprentice Buck Hunt) shall open on the fourth Saturday in November and extend for nine consecutive days. 

365. Bear

360(b), the bear season shall open on the opening day of the general deer season as described in subsections 360(a) and (b) and extend until the last Sunday in December in the areas described in subsections 365(a)(1), (2), (3) (4) and (5) above.                                                                                                                                                                                                                                                                                                                                                                                                   

Parking allowed off National Forest Transportation System Roads:

The preferred alternative and alternatives 3, 4, & 5 currently have a provision limiting parking off NFTS roads to one car length. This provision does not appear to be justified in the analysis and is overly restrictive.  The Travel Management Rule states 212.51 Designation of roads, trails, and areas.

(b) Motor vehicle use for dispersed camping or big game retrieval. “In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a specified distance of certain designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal.”

TuCARE would like to propose parking up 150′ from the traveled surface of a system road for the retrieval of big game and access to dispersed camping.

TuCARE is committed to the “Wise Use” of our natural resources. It is our intention to provide comments that will reflect wise use and reasonable solutions to problems shared by us all.

Western Institute for Study of the Environment W.I.S.E.

TO OFFSET GREENHOUSE GAS DAMAGE CAUSED FROM CALIFORNIA WILDFIRES DURING 2001-2007, STATE’S 14 MILLION CARS WOULD NEED TO BE LOCKED IN GARAGES FOR 3½ YEARS, STUDY FINDS

A raging wildfire can burn out of control for a long period of time, but eventually it will be extinguished. However, the effects of that wildfire can linger for years and be a prime contributor to global warming. A study by Dr. Thomas M. Bonnicksen, Professor Emeritus of Forest Science at Texas A&M University, released today found that California’s increasing wildfire crisis is causing more destruction and undoing much of the progress California is making to fight global warming.

Dr. Bonnicksen, who holds a Ph.D. in forestry from the University of California, Berkeley, and has studied California forests for more than 30 years, is author of America’s Ancient Forests: from the Ice Age to the Age of Discovery (John Wiley, 2000).

This report, entitled “Impacts of California Wildfires on Climate and Forests,” chronicles how the wildfires that scorched California from 2001 to 2007 seriously degraded the forests in the state and contributed to global warming. The report notes that political and economic obstacles to managing and restoring forests contribute to causing the wildfire crisis.

Emissions from the last seven years of wildfires documented in this study are equivalent to adding an estimated 50 million more cars onto California’s highways for one year, each spewing tons of greenhouse gases. To offset this damage, all 14 million cars in California would have to be locked in garages for 3½ years to make up for the global warming impact of these wildfires.

From 2001 to 2007, fires burned more than 4 million California acres and released an estimated 277 million tons of greenhouse gases into the atmosphere, resulting from combustion and the post-fire decay of dead trees. That is an average of 68 tons per acre.

This study and previous studies use a new computer model, the Forest Carbon and Emissions Model (FCEM), to estimate greenhouse gas emissions from wildfires and insect infestations, and opportunities to recover these emissions and prevent future losses.

“Our most important question is: Can we recover from our mistake of letting forests become unnaturally overcrowded with trees and vulnerable to catastrophic wildfires?” said Dr. Bonnicksen, “the answer is yes, if we care about restoring our forests and fighting global warming.”

There are many other harmful effects of these wildfires as well, including killing wildlife, polluting the air and water, and stripping soil from hillsides. Ironically, the greenhouse gases they emit are wiping out much of what is being achieved to reduce emissions from fossil fuels to battle global warming.

“While California’s actions to reduce global warming are significant, reducing the number and severity of wildfires may be the single most important action we can take in the short-term to lower greenhouse gas emissions and really fight global warming,” Bonnicksen said.

Some public forests in California have more than 1,000 trees per acre when 40 to 60 trees per acre would be natural. These dense forests contain small trees that can carry fire into the canopy, and heavy concentrations of woody debris lying on the ground intensify the flames, which helps increase the size and severity of forest fires. Reducing the number of all sizes of trees per acre by thinning is effective in helping prevent crown fires in forests.

Yet that is only part of the wildfire tragedy.

During the seven years covered by this study, California wildfires deforested about 882,759 acres of public and private land. Only an estimated 120,755 acres were replanted. That means about 762,004 acres of forest was converted permanently to brush because no live trees remain standing to provide seed for a new forest. That is an average loss of 109,000 acres of forests each year, or the equivalent of nearly four times the area of San Francisco.

California’s forests are dwindling due to permanent deforestation from wildfire. In addition, the estimated 134 million tons of carbon dioxide (CO2) released by fires and the decay of dead trees from forests that were permanently converted to brush from 2001 to 2007 will continue to worsen global warming.

Harvesting dead trees to prevent them from releasing CO2 from decay, storing the carbon they contain in long-lasting wood products, and using the money from the sale of the wood to replant a young forest that absorbs CO2 through photosynthesis, is the only way to restore deforested areas and recover this greenhouse gas from the atmosphere, Dr. Bonnicksen said. He added that this is done routinely on private industrial forestland but rarely on public forestland. Therefore, he said, it is critical to expedite and increase the harvesting of fire-killed trees and replanting of young trees on public forests destroyed by wildfire.

The immensity of greenhouse gas emissions from California’s wildfires and the permanent loss of huge areas of forest are a warning.

The report emphasizes that every effort must be made to reduce the amount of fuel in public and private forests to prevent catastrophic wildfires. That means managing forests to make them healthy, productive, and resistant to crown fires.

Major constraints to managing and thinning private forests are government regulations and the high cost of Timber Harvest Plans (THPs). Solving this problem by streamlining regulations and reducing THP costs on private forests, and expediting environmental reviews for thinning and timber harvesting on public forests, could dramatically reduce wildfires and greenhouse gas emissions.

***

Data used in this report come from a variety of government and other sources. They include the U.S. Forest Service Pacific Southwest Region Ecosystem Planning Staff, U.S. Forest Service Region 5 Silviculturalist, California Department of Forestry and Fire Protection (CAL FIRE), and the National Interagency Fire Center (NIFC).