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F.S. Misleads Public on Lawsuits and Losses

A detailed report explaining misinterpretations of the Forest Service report on Biscuit post-fire salvage volume reductions by Greg Nagle (Ph.D.) and Rich Fairbanks[1][1]
Biscuit Logging
Biscuit Logging
On March 16, 2005 Oregon Senator Gordon Smith's office issued a press release stating that a recent US Forest Service report [2][2] had documented how legal delays during Biscuit fire salvage resulted in the loss of up to $140 million in commercial value in fire killed timber. The press release stated that lawsuits were a primary factor in timber loss since they delayed harvest with resulting volume losses due to decay.



An accurate reading of the Forest report instead reveals the serious difficulties the Forest Service faced in executing a massive Biscuit salvage program with limited staff, and clearly describes the inevitable problems the Forest Service will again face if pending legislation expediting rapid post-fire salvage logging is passed.



In planning for Biscuit after years of severe staff cutbacks and minimal field capabilities, instead of using more labor intensive field surveys to give them realistic and timely estimates of harvest volumes, the Forest Service relied on extremely inaccurate data on the acreage available for harvest generated by computers based on erroneously analyzed satellite data. This resulted in extreme overestimates of the volume of timber available for harvest and accounts for 80% of the acreage reductions in areas released for immediate harvest in June 2004[3][3]. In contrast to this loss in volume, the Forest Service report attributes only 20% of the later acreage reductions to decay.



A careful reading of the report reveals that in 2004-05, 10,757 acres were released for harvest in roaded matrix and Late Successional Reserve lands with only 3657 acres harvested. According to the text of the Forest Service report , loss of projected harvest due to decay accounted for only 1350 acres or 20% of the 7100 acres in harvest reductions while 5750 acres, or 80% were due to other factors that had nothing to do with delays and decay but to mistaken assumptions on available harvest volumes. When these initial planning mistakes were corrected during later field work the acreage dropped.



To quote directly from sections of the Forest Service document:



The magnitude of the analysis area and the timeframe for EIS completion required an unavoidable initial reliance on available remote sensing data and interpretive applications. Acreage estimations from this remote sensing analysis were continually refined as actual field data became available. Differences between computer interpretations of remote imaging results immediately after the fire and actual conditions visually evident two to three years later drove the largest acreage and volume reductions. ( Pg 4)



Following release of the RODs, additional adjustments were made as more detailed field information was obtained. During sale layout and continuing even during sale operations, adjustments were made to ensure legality and economic viability. The most significant was change that related to the number of riparian areas to protect since more riparian channels became evident after the fire than were known and mapped prior to the fire. ( Pg 5).





The largest such acreage reduction concerned meeting the legal requirements for management within Late Successional Reserves (LSR), and the protection of riparian corridors, archeological sites, botanical sites, and geologically unstable sites. ( Pg 5)



Where remote imaging indicated fire-killed trees existed in amounts and acreages consistent with LSR standard and guideline requirements for salvage, field reviews very often found that it did not. Between the DEIS and the FEIS approximately 7,600 acres ultimately were dropped for this reason to meet legal requirements. More such adjustments were found during actual sale layout and implementation. (pg 5)





Assumptions of Economic losses



The calculations of massive revenue losses cited by Senator Smith's office assumes that all 8174 acres of roadless area salvage proposed in the FEIS would have been legally available for harvest but as explained above, over half of the roaded acres previously released for harvest were dropped from the cut due to various reasons having nothing to do with decay due to delays in harvest.



Proponents of expedited salvage claim that prompt harvest will gain better prices. They use the average prices paid for Biscuit roadside hazard tree sales ( $292/mbf) and the logs piled during fire suppression ($396/mbf) as an indication of the kind of revenues that can be gained if salvage is rapidly expedited. However, these hazard sales were all immediately next to roads where harvest costs were very minimal compared to more typical salvage units requiring helicopters and expensive long reach cable yarding.



Another key weakness in the Forest Service report and statements by Senator Smith's office is that they used "pond" value of $500/ thousand board feet (mbf), the price the mill pays to the timber purchaser for delivery at the mill, as an estimate for economic losses to the Forest Service. In fact, the Forest Service only receives the "stumpage value" paid by the timber purchaser. In the FEIS the FS had estimated that they could have received at most $333/ mbf in stumpage value.



In an April 23, 2004 request to the Regional Forester for an Emergency Situation Determination on the Biscuit, the Forest Service used a projected sale income of $250/ mbf to justify protection from appeals in order to accelerate logging. This emergency exemption was granted on June 3, 2004.



The 220 Biscuit sale units that were initially offered were concentrated for the most part along main ridge-top roads, adjacent to old clearcuts. The accessibility of these units was relatively easy and bid prices could have been expected to be much better than prices for remote roadless area sales with longer helicopter distances.





Despite the inflated revenue assumptions based on income of $250/mbf that was used to obtain an emergency exemption, with so much of the ground needing expensive helicopter logging the Forest Service had to ask for very low minimum bid prices.



The 12 Biscuit sales sold for $15 to $304 per mbf at an average price of $74.58 per mbf.



Out of the 12 sales, nine had only one bidder with 8 of these sold at or just above the minimum acceptable bid price





Forest Service estimates of volume losses to decay are likely inflated



Trees grow much larger in riparian areas, than in upland areas in the Biscuit fire area. Many upland areas are dominated more by smaller trees than by larger. Decay in these smaller trees was advanced by 2005 when these areas finally became available for harvest. There resulted then, a significant number of acres dropped where merchantable timber was no longer available in amounts to be economically viable, after protection buffers were established for riparian zones. Approximately 1,350 acres were dropped for this reason. ( Pg 5)





Forest Service estimates for acreage losses due to decay, particularly in the small diameter class are very questionable.



The FEIS stated that two years after the fire, the time of most of the sales, only 11% of the volume would be lost to decay.



The Biscuit FEIS stated that in the 9-21 inch size class, 65% of the stems were unmerchantable hardwoods and of the remaining 35% that were conifers, 58% were too small to sell. This means that only 15% of all the timber in that 9-21 inch size class was ever possible for harvest.



The real issue about the acres that were dropped due to this purported decay in smaller trees was that after factoring in the volume removed from riparian buffers, and costs of helicopter logging, it simply was not worth it to go after smaller trees with helicopters regardless of the extent of decay while other units with such smaller diameter trees were still logged with cable yarding. In the Steed sale area immediately west of Game Lake Peak, many salvage units were principally stocked with such smaller sized trees. These units had no riparian buffers and were logged with less expensive cable yarding. The upper slopes of Fiddler unit 8, the largest unit in that sale area, was also stocked with many smaller trees which were profitably cable yarded.



Reasons for delay



It is not generally understood by the public that an entire logging season was lost due to interference by the Bush administration during the planning process for the Biscuit. A three-month delay in producing the Final Environmental Impact Statement, which pushed back Biscuit logging an entire operating season, was the result of Forest Service changes that resulted in the inflated timber volumes projected for harvest. The Forest Service during scoping initially proposed a much more modest proposal, but agency planners were pressured into adding two other alternatives calling for much higher harvest levels. This additional analysis pushed the completion of the plan back three months into October, thereby foregoing an operating season.











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[1][1] Rich Fairbanks is the retired USFS interdisciplinary team leader for the Biscuit planning effort, now employed by the Wilderness Society. Greg Nagle is an independent researcher with a Ph.D. in Forest Science and a former research biologist for the USFS Pacific Northwest Research Station. Between November 2004 and October 2005 Nagle did a field examination of 90 Biscuit post-fire salvage logging units encompassing about 60% of the total Biscuit sale area of 3658 acres. Contact at:  gnagle2000@yahoo.com. Cornell University, Department of Natural Resources, Ithaca NY, 14853.

[2][2] The Forest Service report was titled "Responses to Questions Asked by the House and Senate Committees on Appropriations Concerning the Biscuit Fire in Southern Oregon."

[3][3] In order to reduce field time and expenses on Biscuit , the Siskiyou tried to do sale unit boundary marking with helicopter paint drops and were actually going to have the logging companies mark the legally mandated no-cut 174 foot riparian buffers and choose wildlife leave trees. After being ordered by a judge to do these with their own personnel , the Siskiyou had to bring in a crew from Montana to mark wildlife trees and unit boundaries.

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