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The Devastation Framework
Richard Kunstman


The following report describes the efforts of the Forest Service's Region 5 to secure public approval for the revision of the 2001 Sierra Nevada Forest Plan Amendment (also known as the"Conservation Framework"). The Framework, which was acclaimed as a landmark plan for scientific forest management, limited the size of trees that could be logged to 20 inches diameter at breast height (DBH). The revision permits logging of larger trees -- 20 to 30 inches DBH -- to accommodate the wishes of the timber industry.

Region 5 is working hard to gain public approval for this unpopular decision, which has been criticized by Forest Service scientists as well as nationally recognized members of the Union of Concerned Scientists. To impress the public, Region 5 has published a slick brochure titled"Forests with a Future," that panders to the public's fear of wildfire and distorts the efficacy of the proposed revision. This report includes some of the text and graphics from the brochure to expose the distortions that create false impressions of security and ecological improvements.


Forest1990s - The Northern Spotted Owl dispute in the Pacific Northwest Forests (Region 5) lead to the report on the California Spotted Owl (CASPO) that laid the groundwork for the"Interim Guidelines" for Region 5 forest management.

During the 1990s there were confrontations, appeals, and lawsuits between Non-Governmental-Organizations (NGOs) and the Forest Service relating to the management of the national forests of the Sierra Nevada (Region 5). In an effort to avoid the"Train-Wreck" situation -- that occurred on the forests of the Pacific Northwest (Region 6) as a result of the 1991 court Decision on the Northern Spotted Owl 2 -- the Pacific Southwest Research Station undertook a study of the California Spotted Owl. In 1992, the CASPO technical report on the owl's status was published. CASPO 11 recommended"Interim Guidelines" for management of forests to preserve the options for the owl's viability. In 1993, Region 5 adopted the interim guidelines until a final Management Plan could be developed, that would assure the survival of the owl as a species. The guidelines prohibited logging of trees larger than 30 inches diameter at breast height (DBH) and required retention of 40 percent of the basal area in the largest trees in any"cut unit."

For those unfamiliar with the term,"Basal Area" (BA) is the surface area of all the stumps that would remain if all the trees in an acre were cut off at breast height.

1993 - The timber industry reacts to the adoption of the Interim Guidelines.

Adoption of the Interim Guidelines was greeted with dismay by the timber industry that wanted to continue logging the old-growth forests that comprise the owl's habitat. In a typical exaggeration, Bill Dennison - an industry spokesperson - stated:"This will cause the loss of 10,000 jobs and bring the California economy to a grinding halt." Never mind that the expected reduction in timber output from the national forests was about 30 percent and the previous annual output from the Sierra Nevada national forests was approximately 1.5 billion board feet. A generous estimate of national forest component of employment in the industry at that time was 4 jobs per million board feet annually, or a total of 6,000 jobs that would be reduced by 30 percent (about 1,800 jobs). The California economy survived.

The CASPO report became the basis for many appeals that were filed on national forest projects. The agency's reviewing officers upheld the vast majority of these appeals. Some of those that were denied became the subjects of litigation and in most cases the courts found for the plaintiffs.

1995 - Under threat of litigation, the region released a Draft Management Plan and Environmental Impact Statement in January 1995. Several iterations of the plan finally lead to adoption of the Conservation Framework in January 2001.

Responding to the threat of litigation to compel preparation of the management plan envisioned by the Interim Guidelines, Region 5 published a Draft Management Plan and Environmental Impact Statement (DEIS) in January 1995.7 Comments on this plan argued that the DEIS failed to disclose the uncertainties in the outcomes predicted by the models used to develop the prescriptions embodied in the plan. In August 1996, the Region published a Revised plan (RDEIS) 8 that was severely criticized for its failure to incorporate the science published in the June 1996 Report to Congress by the Sierra Nevada Ecosystem Project (SNEP)"The Status of the Sierra Nevada." 3 This report was the result of a three-year study of the entire ecosystem by more than 100 scientists from federal agencies, academia, and recognized experts in the various disciplines.

1997 - To forestall possible litigation, the administration convenes a Federal Advisory Committee to review the RDEIS for scientific adequacy.

Anticipating the potential for prolonged litigation, the Administration in 1997 convened a committee of independent scientists under the Federal Advisory Committee Act (FACA) to review the RDEIS for scientific adequacy. The report by this committee - issued in late 1997 - scathingly criticized the RDEIS as failing to assure the viability of the California Spotted Owl and also a failure as"An Ecosystem Approach" - the subtitle used for the RDEIS.

The Regional Forester Lynn Sprague, then convened a committee of scientists from the various branches of the Pacific Southwest Research Laboratories to review the SNEP report and identify which portions were applicable to forest management. After completing their reviews on the various applicable disciplines, the reports were submitted to independent experts in academia for peer review and the resulting Scientific Consistency Review was published in July, 1998. 9

Conservation Framework

The Region 5 office then prepared a new plan -"The Conservation Framework" -- based on the Scientific Consistency Review, proposals from various NGOs, and industrial interests. In April, 2000 the new Regional Forester, Bradley Powell, published the Framework DEIS, which analyzed eight Alternatives. Including the required"No Action" Alternative, which would continue management practices under the CASPO interim Guidelines, these Alternatives spanned the range from the absurd"No Commercial Logging" to the theological"We Must Cut the Forest Down to Prevent it From Burning Up." Following the 90-day comment period, the planning team made alterations in some of the Alternatives and added a"Modified Alternative 8" -- which became the"Preferred Alternative - and published the final EIS in January, 2001.10

At the same time, Forester Powell issued his"Record of Decision" adopting Modified Alternative 8 and Chief Forester Dr. Jack Ward Thomas approved the decision. The Framework was acclaimed broadly as a landmark plan for scientific forest management. Emphasis was directed to protection of communities -- with aggressive fuel reduction treatments in a 1/4 mile"Defense Zone" and less intensive treatments in a 1-1/4 mile"Threat Zone." Outside these protective zones, logging was limited to trees less than 20 inches DBH. The Framework also emphasized the use of Prescribed Fire -- as a means of reducing the excessive fuel loads that lead to catastrophic wildfires - and to restore the ecological functions of natural fire.

From Conservation to Devastation

Later in 2001, Chief Forester Thomas resigned. The new Chief, Dale Bosworth, reassigned Regional Forester Powell and replaced him with the current Forester Jack Blackwell, who - under pressure from the timber industry -- immediately began gathering information to justify logging of trees up to 30 inches DBH. A committee of scientists was convened to perform a"Meta-Analysis" on all the California Spotted Owl data. The committee report showed that - for some of the 41 models examined - the experimentally determined value for"Lambda," within the 95 percent confidence intervals, could be greater than 1.0 - a significant increase from the experimentally measured values.

"Lambda" is the statistical value that describes the reproductive success of a species. A value of 1.0 means that the population is stable - individuals that are lost by death, disease, or natural disasters, are replaced by new individuals. A value greater than 1.0 implies that the population is increasing toward a new stability level. A value less than 1.0 indicates that the population is headed toward extinction.

Of course the 95 percent confidence intervals also imply that the true value of Lambda could be significantly smaller than the experimentally determined value. The committee report did not discuss forest management prescriptions, recommending only that future data gathering protocols be uniform among the various forests.

In 2003, Regional Forester Blackwell published the"Supplementary DEIS" with revised logging prescriptions, that permitted cutting of trees up to 29.9 inches DBH. A portion of the report on"An Investigation into the Bush Administration's Misuse of Science" 6 by 60 scientists (20 Nobel Laureates) of the Union of Concerned Scientists commented:

In an incident involving the management of national forests, the Bush administration created a five-person"review team" made up of predominantly nonscientists who proceeded to overrule a $12 million science-based plan for managing old-growth forest habitat and reducing the risk of fire in 11 national forests. This so-called Sierra Nevada Framework, which was adopted by the Clinton administration in 2001 after nine years of research by more than 100 scientists from the Forest Service and academia, had been viewed by the experts who reviewed it as an exemplary use of credible science in forest policy.

The Bush administration's proposed changes to the plan include harvesting more of the largest trees, which may double or triple harvest levels over the first 10 years of the plan. Other changes call for relaxing restrictions on cattle grazing in some areas where the original plan significantly reduced grazing due to the potentially critical impact on sensitive species.
Forest Service officials justified these changes in part by stating that the original plan relies too much on prescribed burning and would fail to"effectively protect the general forest areas from fire." Contrary to Forest Service claims that their recommendations are based on"new information and findings," the proposed revisions appear to lack any scientific basis. In fact, a scientific review panel put together by the Forest Service found that the revisions failed to consider key scientific information regarding fire, impacts on forest health, and endangered species.
In response to the outcry by the scientific and environmental communities, the anticipated appeals, and the probable litigation challenging the basis for the revision, the Region embarked on a PR campaign - hoping to win in the court of public opinion what it is likely to lose in the court of law. $90,000 was paid to a San Francisco PR company for advice on procedure and another $23,000 was spent on publication of a brochure, entitled"FORESTS WITH A FUTURE," that attempts to persuade the reader that the Revised Framework will result in reduced catastrophic wildfires, increased old-growth forest, and improved wildlife habitat.


Figure 1 shows the pictures associated with the three brochure inserts. These are obviously an effort to generate fear -- an emotional response -- and create the impression that implementation of the revision allowing 30 inch DBH trees to be logged will avert the fearful consequences. No credible explanation is provided to support this implication -"trust us."

acres of forest destroyed by catastrophic fire

Notice that the graph begins to depart from the linear increase in the mid 1990s when timber harvests were declining. Although the text of the brochure states"We need future forests more like past forests," the projection for"Annual Acres Burned" only achieves a 30 percent reduction toward the 1950 level by 2050.

annual catastrophic fires

Figure 3 shows - in addition to the expected reduction in annual catastrophic fires - the predicted increase in annual acres burned, as the accompanying text claims:"If nothing new is done" (dashed red line).

Here again, the obvious purpose of the text is to generate the emotional response -- fear of catastrophic wildfires. However, these disastrous predictions rely on the caveat that the"status quo" will be maintained. The Conservation Framework (which is a new approach to forest management) proposed the same fuel reduction strategies as the Supplemental DEIS, but did not permit logging of trees in the 20 to 30 inch diameter class. Logging of these large, fire-resistant trees does not contribute to fuel reduction as demonstrated by the following excerpt from the April, 1999 analysis by the General Accounting Office in the report"A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats." 4

The agency relies on timber production to fund many of its programs and activities, and all three of its budget allocation criteria for timber activities relate solely to the volume of timber produced or offered. As a result, as forest officials told us, they tend to (1) focus on areas with high-value commercial timber rather than on areas with high fire hazards or (2) include more large, commercially valuable trees in a timber sale than are necessary to reduce the accumulated fuels. Similarly, an interagency team that reviewed the implementation of the Emergency Salvage Timber Sale Program observed that some Forest Service personnel focused more on harvesting timber than on protecting forested ecosystems. This tendency of some agency personnel was further documented in a 1999 report by the Department of Agriculture's Office of Inspector General.

Old Growth Trees and Wildlife

Figures 4 and 5 show respectively, the increases in Old Growth Trees and Wildlife Habitat that are predicted to occur as a result of implementation of the"Forests with a Future Campaign." However, this"Campaign is not scheduled to begin until the year 2004. Notice that around 1990, the dramatic declines in Old Growth Trees and Wildlife habitat pass through a minimum and begin an increasing trend. This reversal correlates in time (following adoption of the CASPO Interim Guidelines) with the period when activists began successfully challenging destructive timber sales, and the courts issued injunctions compelling the Forest Service to comply with the laws and their own standards and guidelines.

catastrophic wildfire and ecologically-beneficial

Figure 6 is probably the most blatantly deceptive illustration in the Campaign Brochure. The left hand picture shows a catastrophic wildfire that results when"fuel ladders" are intact. The right hand picture shows a well-behaved, ecologically-beneficial, cleansing fire that is expected when the"fuel ladders" are removed. This latter fire is typical of those that burned prior to Euro-contact. They killed most of the susceptible seedlings, that could become fuel ladders if they survived, and spared the large, fire-adapted trees.

The logging frenzy, which altered the natural forest structures and microclimates, also left enormous amounts of surface fuel accumulations. These, combined with the misguided fire suppression policy, resulted in the excessive undergrowth that characterizes the forests today.

Only an unrealistic fanatic would argue that these fuel ladder trees should not be removed. This is a matter of common sense supported by the best available science. However, the Forests with a Future Campaign differs from the Conservation Framework's vegetation management prescriptions only in that it permits the logging of the larger (20 to 30 inch) trees.

Trees in the 20 to 30 inch size class would be between 65 and 95 years old and would range in height from 85 to 140 feet. The base of their crowns would be a minimum of 30 feet above ground level. Additionally, at this age the bark of many trees is fire-resistant. Fire scientists report that a hot ground fire -- that bakes the needles in the over-story -- is necessary for a crown fire to persist. Theoretical analysis - using the Forest Service's Farsite modeling software - shows that crown fires will not occur when"ladder trees" are removed and surface fuels are consumed by"underburning." (SNEP, vol. II, Chapter 43) These theoretical results have also been empirically confirmed by post-wildfire observations. Nevertheless, the Supplementary DEIS proposes to log about 183,000 trees in the 20 to 30 inch size range each year for five decades.

Consider carefully the trees that remain in figure 6 after the"fuel ladder" trees have been removed. Assuming the largest tree is 40 inches DBH, this tree would be about 140 years old. Now consider the size of the largest"fuel ladder" tree proposed for removal. This tree is about 1/4 the size of the largest tree (10 inches DBH) - not the 20 to 30 inch DBH that the Supplementary DEIS proposes to remove. Notice also, that the remaining intermediate tree - retained in the right hand picture - is less than ½ the size of the large tree, with its crown base well above the anticipated flame length.


In 1991, the Sacramento Bee published a 5-part series of articles by journalist Tom Knudsen entitled"Sierra In Peril." 5 Knudsen described the various damages to the Sierra Nevada ecosystem that resulted from unrestrained clear-cut logging and poorly managed livestock grazing. His observations were confirmed with rigorous science in the 1996 SNEP report. The outgrowth of these observations and science was a scientifically sound management plan"The Sierra Nevada Forest Plan Amendment."

Once again, the Sierra is in Peril. The revisions in the"Supplementary Forest Plan Amendment" reinstitute the practice of logging large, old-growth trees - reaffirming the Forest Service's mindset that maximizing fiber production is the primary objective.

It's clear that there is no need to remove the larger trees in order to reduce the risk for high-severity, catastrophic wildfires. The analysis of the information, shown in the Region 5's own brochure, as well as a large body of solid science, confirms this. The corollary conclusion is that the only reason for logging the larger trees is to accommodate the desires of the timber industry, because the"ladder fuel" trees -- and trees in the less than 20 inch size class -- are considered"sub-merchantable," i.e., not attractive to a potential timber sale purchaser.


1. Agee, James K., Fire Ecology of Pacific Northwest Forests, Island Press, 1718 Connecticut Avenue, NW, Washington, DC, 20009, 1993.

2. Dwyer, William L., Memorandum Decision and Injunction, Seattle Audubon Society, et al., Plaintiffs, v. John L. Evans, et al., Defendants, United States District Court Western District of Washington at Seattle, Docket No. C89-160WD, May 23, 1991.

3. Erman, Don C.,, Status of the Sierra Nevada, Centers for Water and Wildlands Resources, University of California, Davis, Wildlands Resources Center Report No. 39, June 1996. (SNEP).

4. General Accounting Office, A Cohesive Strategy is Needed to address Catastrophic Wildfire Threats, April 1999.

5. Knudsen, Tom, Sierra in Peril, Sacramento Bee, 5-part series, 1991.

6. Union of Concerned Scientists, An Investigation into the Bush Administration's Misuse of Science: Scientific Integrity in Policymaking, February 2004.

7. USDA-Forest Service, 1995, Draft Environmental Impact Statement, Managing California Spotted Owl Habitat in the Sierra Nevada National Forests of California: An Ecosystem Approach.

8. USDA-Forest Service, 1996, Revised Draft Environmental Impact Statement, Managing California Spotted Owl Habitat in the Sierra Nevada National Forests of California: An Ecosystem Approach.

9. USDA-FS/PSW, SIERRA NEVADA SCIENCE REVIEW, Report of the Science Review Team charged to synthesize new information of rangewide urgency to the national forests of the Sierra Nevada, July 24, 1998.

10. USDA - Forest Service, Sierra Nevada Forest Plan Amendment, Final Environmental Impact Statement, January 2001.

11. Verner, J., K.S. McKelvey, B.R. Noon, R.J. Gutierrez, G.I. Gould, and T.W. Beck, 1992, The California Spotted Owl: A Technical Assessment of Its Current Status (CASPO), USDA-Forest Service, Pacific Southwest Research Station, Gen. Tech. Rep. PSW-GTR-133, Berkeley, CA, 1992.