Final Environmental Impact Statement Rio de los Pinos Vegetation ...

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Colorado Wild Page 4 In sum, it is highly unlikely that the proposed logging could take place without considerably adverse effects on watersheds and soils. Thus at a bare minimum, units 4 and 5 must be dropped, and logging reduced in the other proposed units. II. LOGGING IS NOT NEEDED IN THE PROJECT AREA. Even if logging could be done without damaging soils and watersheds, there is no need to log in the area. A. REFORESTATION WOULD OCCUR WITHOUT LOGGING BUT MIGHT NOT OCCUR VERY WELL AFTER LOGGING. Part of the need for the project is said to be reforesting areas “severely impacted by spruce beetle”. DEIS at 1-4. There is already a fairly dense understory of trees throughout the area. DEIS at 3-38. 2 In other words, the future forest is already there. As spruce trees die from bark beetle attack and shed their needles, the understory will be released and grow faster, forming a new forest. Logging, however, would destroy much of this understory. Felling and skidding would break or uproot many seedlings. Larger trees in the understory could be damaged during operations. Indeed, some regeneration would be deliberately destroyed to reach trees targeted for removal. See DEIS at 3-64, which says that fir trees and trees less than eight inches in diameter “will be removed to access larger diameter standing trees“. Not entering the area would protect existing regeneration. By the time a sizable number of the dead standing spruce begin to fall, probably 50 years or so from now, the currently small trees will be large enough to resist much of the damage they might otherwise receive from falling trees. The down spruce will quickly begin to deteriorate in the wet soils, which would by then be shaded considerably by the new forest. The rotting logs might provide a good seedbed for regeneration then. See DEIS at 3-31. Attempts at reforestation after logging, particularly in the proposed patch cuts, will have a high failure rate. Englemann spruce is difficult to regenerate because it needs shade in the early years to prevent desiccation and death from too high a dose of ultraviolet radiation. Previous clearcuts in and near the project area have not regenerated, or have only partially regenerated. See DEIS Appendix D. We do not believe that retention of light logging slash would increase regeneration success. In spite of what is stated, we do no see how such material would “protect[ seedlings] from excessive sunlight, extremes of temperature, desiccation, and grazing animals” DEIS at 3-11. Logs with a pretty good diameter (at least several inches) would be needed to provide shade and other protection for seedlings. A substantial amount of such material would be needed to protect existing and any future regeneration. Such an amount would probably not a constitute a “light” accumulation of slash. Regeneration after logging would require planting. Intuitively, planting would be most needed in the patch cuts, as these would be clearcuts, meaning there would be no shade from standing trees 2 The Table on this page shows more than 1000 less than eight inches in diameter in all proposed logging units. Page 3-63 states that there are an average of 750 seedlings per acre. Printed on recycled paper with at least 30% post-consumer content.
Colorado Wild Page 5 to help provide areas capable of regeneration. Page 3-10 shows 74 acres of anticipated planting, all in units 3-5, with the large majority in unit 5. But DEIS p. 2-3 shows 74 acres of patch cuts, almost all of it in units 1-3. In other words, the units with the most patch cutting are least likely to need planting, except for unit 3. This does not make sense. If planting is needed in non-patch cut areas, regeneration throughout the project area would be even more difficult because regeneration failures in patch cut areas are more likely, and the overall success of regeneration via planting is thus far from assured. B. LOGGING IS NOT NEEDED TO REDUCE THE FUTURE THREAT OF FIRE. A need for the project is said to be to reduce fuel build up. DEIS at 1-4. However, fires are rare in wet, high-elevation areas like the project area. See DEIS at 3-89, 3-90. Also, once spruce trees attacked by bark beetles die and lose their needles, there is very little opportunity for a crown fire to spread because there is no way for fire to jump between standing dead trees. See DEIS at 3-88. Spruce there were sound when killed by beetles (i. e., have no root or heart rot) are likely to remain standing for decades. When they do fall to the ground, they will begin to decay quickly, as soils are wet in the area, and snow covers the area for the majority of the year. See DEIS at 3- 91, which notes that slash quickly becomes part of the duff layer; i. e., former woody debris soon decomposes. As discussed above in subsection A, existing regeneration would by then be sufficient to shade much of the ground, preventing it from thoroughly drying out except during extended drought periods. Finally, there is little private land in the immediate vicinity, so fuel reduction effort in the project area is not needed to protect human habitation. C. DEMAND FOR TIMBER IS LOW, THUS THE SALE MAY NOT SELL OR BE IMPLEMENTED IN A TIMELY MANNER. Currently, the demand for timber is quite low, due to the recessed state of the economy. Housing starts are very low, so demand for dimension lumber, which would be the most likely product from the project area, is especially low. Also, there is probably only one mill that could handle the large volume proposed for offering from the project area. That mill, Intermountain, in Montrose, may not be able to take on another large sale like Rio de los Pinos. Alternatively, it might have to forgo implementing other sales to harvest the wood in Rio de los Pinos. We do not see how offering the large proposed volumes under the action alternatives (8 to 13.1 million board feet) would allow the small mills in the San Luis Valley to compete for resources, as suggested at DEIS p. 3-87. These mills could simply not handle the large sales that would be offered from the project area. Thus it may not be possible to get timber from the project area on the market before decay eliminates any wood product value, as is the intent of the proposed action. DEIS at 3-11. Printed on recycled paper with at least 30% post-consumer content.
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Final Environmental Impact Statement Rio de los Pinos Vegetation ...

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