Percent of target log-volume goal sold by USDA Forest Service, Eldorado National Forest, 2008…74

Percent of target log-volume goal achieved by USDA Forest Service, statewide 2008…54

Average annual log-volume delivered from Stanislaus National Forest, 1980-1990…132 mmbf

Average annual log-volume delivered from Stanislaus National Forest, 1998 – 2008…17 mmbf

Log-volume delivered from Stanislaus National Forest, 2008…12 mmbf

Average annual log-volume delivered from Eldorado National Forest, 1980-1990…147 mmbf

Average annual log-volume delivered from Eldorado National Forest, 1998 – 2008…45 mmbf

Log-volume delivered from Eldorado National Forest, 2008…24 mmbf

Percent of planned forest thinning blocked due to litigation, Stanislaus National Forest, 2008…41

Percent of annual Forest Service wood volume blocked by litigation, statewide…33

Approximate percent of forest thinning in the Sierra Nevada that would be blocked by the most recent lawsuit against the USDA Forest Service…95

Estimated percent of USDA Forest Service resources spent on planning, administrative appeals or litigation…40

Volume of wood on California’s national forestlands currently blocked by litigation…400 mmbf

Number of average-size sawmills that could operate for a year on 400 mmbf…5

Percentage of wood used in California that is imported…75

Percent decrease in timber harvest on federal lands since 1990…90

Percent of California sawmills closed since 1990…70

Potential direct jobs created by returning harvest to half of 1990 levels…3,000

Tree mortality, Stanislaus National Forest, 2008…38

Increase in acres burned by severe wildfire in California in 2007 and 2008 respectively, over previous five-year average…300, 315

Cost per acre to taxpayers to reduce fuel loads in the Sierra Nevada, with local sawmills…$500-$2,500

Cost per acre to taxpayers to reduce fuel loads in the Sierra Nevada, without local sawmills…$1,000-$5,000

Potential cost per acre to reduce fuel loads through public-private partnerships…$0

Millions of acres of productive national forestland at serious risk of catastrophic wildfire…7

Percent reduction possible, in severe wildfire through increased forest management…50-60

Taxpayer costs to fight wildfire, 2008…$1.4 billion

Data sources: U.S. Forest Service, Calif. Dept of Forestry and Fire Protection, California Board of Equalization or analysis of Forest Service data by California Forestry Association

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.

On Wednesday, August 26th, the fire danger was so high that several timber operators cutting on the Stanislaus National Forest were required to stop work at 1:00 pm for fear their equipment might spark a fire. On the same day, one ridge over, the Yosemite Park Service purposely set a fire near a small community. The 91 acres that was supposed to burn was spared, at the expense of 7,200 other acres. Sixteen million dollars later, the “prescribed” wildfire was contained. In an admission that defies logic, common sense, science, and a desire to keep his job…when asked if he would do it all over again, Dave Uberuaga, the Acting Superintendent of Yosemite National Park said, “Yes.” This gave real meaning to the “Acting” part of his job title.

On August 6th, the Sierra Forest Legacy took stock of the timber situation in California and decided it was a perfect time to deliver the final blow. It came in the form of a lawsuit to further restrict Forest Service timber sales. The Legacy group argues that it will suffer irreparable harm if the Forest Service goes ahead with its program of forest thinning. This is all on the heels of new research released by Dr. Tom Bonnicksen, Professor Emeritus of Forest Science at Texas A&M University, which documents findings indicating that all of California’s 14 million cars would have to be garaged for over 3 1/2 years to offset the emissions released by California’s wildfires between 2001 and 2007.

And finally, yours truly just finished writing a 128 page Timber Harvest Plan costing thousands of dollars so that Columbia College could harvest one acre of trees averaging 8 inches in diameter to accommodate their new Science and Natural Resources building. CAL FIRE rejected the timber plan twice because it did not adequately address the impact the one acre tree removal job would have on climate change, specifically greenhouse gas effects (I am not making this up). In the end, the whole thing gave me more gas than the one acre of trees could ever have absorbed!

So, what to do…how can we ever recover from the hole in which we find ourselves?

Well, first pull out a penny or a $100 bill, or anything in between, and read across the top, and never forget that message. Secondly, most of us are not “in the hole”, but are instead watching our misguided fellow Americans dig. That’s not so bad, but when they try and pull us down with them…well…we get angry. That’s where we are right now. The grassroots (or “astroturf” as Speaker Pelosi calls us) are getting angry. Fortunately, our chance to take action is only a November away.

In the meantime, TuCARE will fight back for all of us. TuCARE is one of two interveners in the Sierra Forest Legacy lawsuit against the Forest Service. An October 1st hearing is scheduled. We will be there. TuCARE is doing any good reporter’s job by trying to get access to the actual weather data at the fire line when the Yosemite prescribed fire was started. We will not rest until the truth is known.

TuCARE supports both existing and new home improvement stores. We want to help stock their shelves. We will continue to stay in the forefront of the effort to restart our sawmills. TuCARE is uniting with valley farmers to educate the public and politicians with a simple message…healthy forests = clean and abundant water. TuCARE believes that a 128 page timber harvest plan for 1 acre of small trees is 126 pages too long. We are working toward common sense reforms in our current “analysis paralysis” regulatory systems.

In the meantime…don’t give up—keep the faith—pledge allegiance—read the penny.