POLICIES,GUIDELINES AND ENFORCEMENT
PROCEDURES AFFECTING PREVENTION,
CONTROL AND ABATEMENT OF AIR AND
WATER POLLUTION RESULTING FROM
FORESTRY PRACTICES ON THE FLATHEAD
NATIONAL FOREST. MONTANA.
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TABLE OF CONTENTS
Introduction i
I. FEDERAL AND STATE LEGISLATION, ORDERS AND GUIDELINES
DEALING WITH WATER AND AIR POLLUTION 1
A. Federal Legislation 1
Water Pollution Control Act Amendments of 1972 2
Clean Air Act 5
National Environmental Policy Act of 1969 6
Executive Order 11514 8
Revised Guidelines of Environmental Impact Statements 8
B. Guidelines and Policies of the State of Montana 11
Water Pollution Control 12
Air Quality 14
Montana Environmental Policy Act 17
The Department of Natural Resources and Conservation 19
The Fish and Game Department 20
Environmental Monitoring 23
State Agencies in Summary 24
II. POLICIES AND GUIDELINES OF THE U. S. FOREST SERVICE
REGARDING AIR AND WATER POLLUTION 27
A. Washington and Regional Office Policy Guidelines 27
The Environmental Quality Sequence • " 29
The Framework for the Future Sequence 32
The Forest Management Practices Sequence 34
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B. Policy Development on the Flathead National Forest 38
C. Analysis of the Adequacy of Forest Service Policy
and Its Relations to Federal and State Environmental
Policy 44
III. ACTIVITIES ON THE FLATHEAD NATIONAL FOREST AND THEIR
RELATION TO AIR AND WATER CONTROL POLICIES AND
GUIDELINES 50
A. Timber Operations Before 1971 51
The North Fork of the Flathead - A Case Study 62
B. Changes Since 1971 65
Inspection and Review of Previous Activities 66
1. North Fork of the Flathead 67 »
2. Lost Johnny Creek 70
3. Spotted Bear River 71
4. Bunker Creek 71
5. Puzzle Creek 72
Major Accomplishments Since 1971 74
Modification of Existing Timber Sales 78
The Puzzle Creek Sale - A Case Study 78
Cancellation Proposal 80
Specialist Review 84
IV. PRESENT PROCEDURES AND ACTIVITIES ON THE FLATHEAD
NATIONAL FOREST - A DESCRIPTION AND ANALYSIS 90
A. Long Range Planning 90
B. Level of Timber Harvest 106
Description of Present Situation 108
° How is the Annual Allowable Cut Determined? 109
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Is the Forest Service Justified in Proposing
a Reduction? 113
Weaknesses Relative to Calculation of the
Allowable Cut 117
Conclusions on the Subject of Allowable Cut 120
C. Air Quality 121
D. Review of Environmental Impact Statements on the
Revised Timber Management Plan and the 3 Year
Road Development Plan 123
Environmental Effects 124
E. The Specialists 128
Specialists Responsibilities 129
Problem Areas Noted by the Specialists 131
Specialists Needs 135
F. Lower Sullivan Creek Sale - A Case Study 136
G. Budgets and Budget Preparation 145
H. Enforcement 147
Regulation on Cancellation of Contracts 149
Regulation on Debarment of Bidders 151
A General Statement with Regard to Roads 152
I. Regional Inspection Report 156
V. EVALUATION OF INFORMATION NEEDED FOR PREVENTION AND
CONTROL OF NONPOINT POLLUTION 165
Baseline Data and Ecosystem Function 165
Applied Research 169
Management Personnel and Research Findings v 174
VI. RECOMMENDATIONS ' 176
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VII. SUMMARY lgo
Bibliography 198
Appendix A 207
Appendix B 230
Appendix C 240
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INTRODUCTION
In June of 1973 the Environmental Protection Agency entered into
a contract with the University of Montana to conduct "A Study of Policies,
Guidelines and Enforcement Procedures Affecting Prevention, Control and
Abatement of Air and Water Pollution Resulting from Forestry Practices
on the Flathead National Forest."
An initial purpose of this study was to help provide a basis for
the identification and control of nonpoint sources of pollution as stipulated
in the Water Pollution Control Act Amendments of 1972, 33 USC 1251.
The study was enlarged to consider provisions of the Clean Air Act PL
42 USC 1857, the Natural Environmental Policy Act of 1969, 42 USC 4321,
and related Executive Orders and supplementary orders published since
then in the Federal Register.
The Flathead National Forest was selected for study by the EPA and
by the Forest Service. The Flathead National Forest is located on the
western slope of the Continental Divide in northwestern Montana. The
majority of its 2,347,229 acres lies within Flathead and Lake Counties
with smaller areas extending into Lincoln County to the west and Missoula,
Powell and Lewis and Clark Counties to the south. Most of the national
forest is drained by the three forks of the Flathead River and an adjacent
tributary the Stillwater River. The Swan River drainage comprises the
remaining area and joins the Flathead River in Flathead Lake.
The Flathead National Forest covers most of the upper watershed
of the Flathead River draining into Flathead Lake. The only other major
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portion of the Flathead drainage is the western portion of Glacier National
Park. Some of the headwater area of the north fork of the Flathead River
is in Canada.
Most of the Flathead National Forest is quite rugged and steep,
particularly in the Mission Mountains, the Swan Range, and along the
Continental Divide. Elevations vary from 2,900 feet in the Flathead
Valley to about 8,500 feet in the higher mountain ranges. Most of the
land is in solid block ownership. The valley bottoms of the larger drainages
are in private ownership. In the Swan drainages an extensive area of
alternate sections belongs to the Burlington-Northern Company.
The forest provides a considerable flow of timber to the mills in
the Flathead Valley, a wide variety of high quality recreation varying from
intensive use in the valleys to the heavy but dispersed use of the Bob
Marshall Wilderness. It is an important producer of high quality water,
it provides excellent hunting and fishing, and is recognized as one of
the most scenic areas of the northern Rocky Mountain region. Its amenity
values enhance the lives of the residents, and a large rapidly increasing
number of people from throughout the nation and, in fact, the world.
The uses of the Flathead National Forest have varying effects on the
quality of the environment.
The Flathead National Forest is administered under the Multiple Use-
Sustained Yield Act, which is designed to provide a sustained flow of
multiple values and products for the continuing use and enjoyment of the
American people. In its operations it is, of course, subject to the
national laws requiring protection of environmental quality.
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In addition, the officials of the Forest Service have adopted policies
and guidelines to protect and enhance environmental quality. These policies
and guidelines are promulgated at the Washington level, and interpreted
at the regional office and forest supervisor levels, by documents which
supplement the national policies and guidelines. These policies and
guidelines and their interpretations are translated into direct action
through contracts and other agreements with forest users. The forest with
support and supervision of the regional office has direct responsibility
for enforcing the policies and guidelines during the operations on the
forest. The final test of the effectiveness of the policies and guidelines
on the national forests is in a review of what actually takes place in the
field.
The study was carried out by a group of faculty of the School of
Forestry of the University of Montana, from late June to November 1973, in
response to a request by the Environmental Protection Agency, who supported
it.
The team consisted of twelve faculty members:
Richard W. Behan, Associate Professor, Forest Policy and
Administration
Arnold W. Bolle, Professor, Administration, Economics and
Policy (Director of the Study)
Lee E. Eddleman, Associate Professor, Range Management and
Conservation
James L. Faurot, Associate Professor, Silviculture and
Engineering
Lawrence K. Forcier, Assistant Professor, Ecology and
Watershed Studies
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Thomas J. Nimlos, Professor, Forest Soils
W. Leslie Pengelly, Professor, Wildlife Biology
Nellie M. Stark, Associate Professor, Soils and Ecology
Robert W. Steele, Associate Professor, Forest Fire Science
" Robert F. Wambach, Dean, Economics and Forest Management
Earl E. Willard, Assistant Professor, Range Management and
Soils
The team worked in two groups, one focusing on policies, guidelines
and operations, the other on various aspects of forest science. Richard
Behan, Arnold Bolle, and Dean Robert Wambach, all with backgrounds in
policy, economics and management constituted the group studying the
policies, guidelines and operations. The scientific team was composed
of Larry Forcier and James Faurot in forest ecology and silviculture,
Nellie Stark and Tom Nimlos in forest soils, Lee Eddleman, Les Pengelly
and Earl Willard in forage and wildlife ecology, and Robert Steele,
forest fire science.
Dean Wambach, Eddleman, Stark and Nimlos contributed time to the
study. All of the other faculty were assigned time and funds to carry
on the study.
The study was given the full support of the Forest Service. Conferen-
ces and interviews were conducted with the regional forester, Steve Yurich
and his staff. Ed Corpe, Supervisor of the Flathead National Forest gave
his full support and made his staff and the district staffs available to
us. The cooperation was open and friendly throughout. The group worked
in teams and individually; visiting field operations, examining documents,
files and other materials in the Supervisor's and regional offices.
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The team also met with officials of State agencies in .Helena and
Missoula and was given full cooperation and needed documentation by them.
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1
I. FEDERAL AND STATE LEGISLATION, ORDERS AND GUIDELINES DEALING
WITH WATER AND AIR POLLUTION
A_^ Federal Legislation
The basic Federal Water Pollution Control Act was passed in 1956,
the Federal Air Pollution Control Act in 1965. Both Acts have been
amended and strengthened several times since then. The most comprehen-
sive of the Water Pollution Control Act Amendments are those of 1972,
of the Clean Air Act Amendments, those of 1970. These amendments
Fbucy
expanded the National Environmental Sentee! Act of 1969 (NEPA) and are
closely allied to subsequent Executive Orders and Guidelines printed in
the Federal Register.
This body of law represents the basis for the actions of Federal
agencies regarding environmental quality. NEPA declares "a national
policy which will encourage productive and enjoyable harmony between man
and his environment; promote efforts which will prevent or eliminate
damage to the environment." The Water Pollution Control Act states that
its objective "is to restore and maintain the chemical, physical and
biological integrity of the Nation's water." The Clean Air Act's purpose
is "to protect and enhance the quality of the Nation's air resources."
The Forest Service is a conservation agency of long standing and
operates largely on the basis of laws passed specifically for it,
particularly in the environmental area. It is to some extent a new
experience for the Forest Service to be subject to environmental laws
that are not specific for the Forest Service, as these are. These laws
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are declared "supplemental" to each agency's "existing authority"
and "a mandate to view the traditional policies in the light of
the Act's national environmental objectives." "Each agency...shall
comply unless existing law prohibits." The laws apply to agencies,
including the Forest Service, as they apply to any individual citizen.
But compliance is not enough for the Forest Service or any other
agency, the directive is clear that "the Federal GoveYnment...shall
provide leadership in the national effort to protect the quality
of our air, water and land resources..."
Water Pollution Control Act Amendments of 1972 PL 92-500
The Federal Water Pollution Control Act Amendments of 1972
charged the Administrator of the Environmental Protection Agency with
developing a program for the identification and control of nonpoint
pollution generated by silvicultural activities on forest lands. The Act
establishes a national goal to eliminate the discharge of pollutants
into all waters of the nation by 1985. For nonpoint sources including
forest lands a further goal is set. (Section 101 (a)(2)):
"it is the national goal that wherever attainable, an
interim goal of water quality which provides for the
protection and propagation of fish, shellfish, and wildlife
and for recreation in and on the water be achieved by 1983;"
In doing so existing state and federal programs will be used
(Sec 102 (a)). At the State level areawide waste treatment programs
will be the basis of pollution control (Set 201 (c)). The Administrator is
>,
authorized to "undertake technical, .legal, institutional, and economic
studies to serve as the basis for further evolution and development of
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nonpoint source control programs" (Sec 104). Special reference 1s
made to nonpolnt sources of pollution throughout the Act. Section 201
(c) specifies that waste treatment management plans shall "provide
control or treatment of all point and nonpoint sources of pollution."
Section 208 (b) (2) (F), calling for a planning process to be in effect
within one year, requires that "any plan prepared...shall include...
a process to (i) identify, if appropriate,...silviculturally related
nonpoint sources of pollution...and, (ii) set forth procedures and
methods (including land use requirement) to control to the extent
feasible such sources."
Section 304 (e) specifies "the Administrator...shall issue to appro-
priate Federal agencies...within one year of the effective date of this
subsection...information including (1) guidelines for identifying, and
evaluating the nature and extent of nonpoint sources of pollutants, and
(2) processes, procedures, and methods to control pollution resulting from...
silvicultural activities, including runoff from...forest lands."
Each State is required, by Section 305 (b) (1), to prepare a
report to the Administrator of EPA by January 1, 1975 (and annually
thereafter) "which shall include - a description of the nature and extent
on nonpoint sources of pollutants, and recommendations as to the programs
which must be undertaken to control each category of such sources,
including an estimate of the costs of implementing such program."
The legislative history of the 1972 Act amendments make clear the
intent to control nonpoint sources of pollution and specifically those
in runoff from forest lands in order to achieve the national goal
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specified in the Act.
The thrust of the Act is to require the development of a program
to identify and begin control of nonpoint sources of pollution within
the next two years and to develop a feasible system of controlling
nonpoint sources of pollution to meet the 1983 interim goals.
The Act calls for a coordinated program of existing federal and
state agencies working through a new arrangement: the areawide waste
treatment management planning. The "primary responsibility of States to
prevent, reduce and eliminate pollution" is recognized (Section 101 (b)).
In developing the programs the Administrator is directed to work "in
cooperation with other Federal agencies, State water pollution control
agencies, interstate agencies, and the municipalities and industries
involved" (Section 102 (a)). After such consultation the Administrator,
within 90 days after enactment, is to issue instructions for identifying
those areas which "have substantial water quality control problems,"
(Section 208 (a) (1)). Sixty days later each Governor is required to
identify these areas in his state and designate a "single representative
agency" to be in charge of planning, (Section 208 (a) (2)). Within one
year the designated organization is to have "in operation a continuing
areawide waste treatment management planning process," (Section 208 (b)
(D).
Each state is required to adopt water quality standards which may
be stricter but riot weaker than federal requirement, (Sec. 301). The
Administrator of EPA will develop the criteria for water quality "after
consultation with appropriate Federal and State agencies." Under Section
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309 the Administrator of EPA is empowered to bring civil action against
any person in violation of the Act. Under Section 402 the EPA has
authority to directly control point sources of pollution.<=Pedepa-l-
fae-i:l-i-t1:eT^re~recogni-zed-as--^-i-nt—sources. Executive Order 11752 \
published in the Federal Register Dec. 19, 1973, includes land in the
category of federal facilities. How this will operate and how State
.agencies may operate or cooperate in enforcement of the provisions of
this Act is not clear. However, provision is made for citizen suits
"against any person including the United States...who is alleged to be in
violation".
The Act provides for many opportunities for implementation of the
program in addition to control. In Section 104 the Administrator
of EPA is directed to "conduct and promote, in cooperation with Federal,
State and local agencies, training and demonstrations relating to the
causes, effects, extent, prevention, reduction and elimination of
pollution." In doing so, the Administrator is empowered to make grants or
enter into contracts with public and private institutions to carry on the
training. Courses can be developed to assist government officials and
industry personnel in ways to control pollution caused by runoff from
forested lands, for example.
Clean Air Amendments of 1970 PL 91-604
The Clean Air Act was first passed in 1965 and amended in 1966,
1967 and 1970. It recognizes the problem of air pollution, and its basic
purpose is to provide assistance to state and local governments which
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are given primary responsibility. The purposes are specified: "to
protect and enhance the quality of the Nation's air resources...to
initiate and accelerate...research...to provide technical and financial
assistance, and to encourage regional air pollution control programs.?
There is again a special admonition to Federal agencies:
"Each department, agency, and instrumentality of the executive,
legislative, and judicial branches of the Federal Government
(1) having jurisdiction over any property or facility, or
(2) engaged in any activity resulting, or which may result,
in the discharge of air pollutants, shall comply with the
Federal, State, interstate, and local requirements respecting
control and abatement of air pollution to the same extent
that any person is subject to such requirements."
The Federal Act provides standards and works through the States. States
are required to set standards which are required to be at least as strict as
.Federal standards. Enforcement is by the State with Federal oversight.
Section 309 of the Clean Air Act gives authority for the review of Environ-
mental Impact statements to the Environmental Protection Agency (EPA).
Executive Order 11602, July 1, 1971, providing for the administration
of the Clean Air Act with respect to Federal contracts, specifies that
"each agency empowered to enter into contracts for procurement or
services...shall undertake such activities in a manner that will result in
effective enforcement of the Clean Air Act."
The National Environmental Policy Act of 1969 (NEPA) (PL 91-190)
signed January 1, 1970 established the Council for Environmental Quality
(CEQ). The right of each person to enjoy a healthful environment as well as
his responsibility to contribute to the preservation and enhancement of
the environment was recognized. .
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All agencies of the Federal government were directed to:
(A) utilize a systematic, interdisciplinary approach which will
insure the integrated use of the natural and social sciences and
the environmental design arts in planning and in decision making
which may have an impact on man's environments
(B) identify and develop methods and procedures, in consultation
with the CEQ...which will insure that presently unquantifiable
environmental amenities and values may be given appropriate
consideration in decision making along with the economic and
technical considerations;
(C) include in every recommendation or report on proposals
for legislation and other major Federal actions significantly"
affecting the quality of the human environment, a detailed state-
ment by the responsible official on—•
(1) the environmental impact of the proposed action,
(ii) and adverse environmental effects which cannot be
avoided should the proposal be implemented,
(iii) alternatives to the proposed action,
(iv) the relationship between the short term uses of
man's environment and the maintenance and
enhancement of long-term productivity, and
(v) irreversible and irretrievable commitments of
resources which should be involved in the proposed
action should it be implemented.
This is the section which forms the basis for the environmental impact
statements now required of Federal agencies. These statements are to be
made available to other agencies, to the public, and, of course, the CEQ,
in advance of taking the proposed action.
There are other requirements to provide assistance to State agencies.
All Federal agencies are also directed to review their authority, admin-
istrative regulations, policies, procedures to determine any deficiencies or
inconsistencies with NEPA by July 1, 1971 and to make the changes needed to
comply. The agencies are also instructed to comply with all other environ-
mental laws (such as Water Pollution Control and Air Quality Acts and others).
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Executive Order 11514
In Executive Order 115H, March 5, 1970, Protection and Enhancement
of Environmental Quality, quoting his authority under NEPA, the President
ordered as follows:
Section 1. Policy. The Federal Government shall provide
leadership in protecting and enhancing the quality of the Nation's
environment to sustain and enrich human life. Federal agencies
shall initiate measures needed to direct their policies, plans and
programs so as to meet national environmental goals...
Section 2. Responsibilities of Federal Agencies.
(a) Monitor, evaluate, and control on a continuing basis their
agencies' activities so as to protect and enhance the quality of
the environment. Such activities shall include those directed to
controlling pollution and enhancing the environment and those
designed to accomplish other program objectives which may affect
the quality of the environment...
Revised Guidelines for Environmental Impact Statements - August 1_, 1973
In response to widespread comment that the CEQ should increase the
opportunity for public comment in the impact statement process and that
the CEQ should provide more detailed guidance on the responsibilities of
Federal agencies in the light of recent court decisions interpreting the
Act, the CEQ on August 1, 1973 published new guidelines for the preparation
of Environmental Impact Statements.
Referring both to NEPA and Executive Order 11514 the Guidelines
emphasize that "all Federal agencies, to the fullest extent possible,
direct their policies, plans and programs to protect and enhance environ-
mental quality." The environmental impact statement "requires agencies to
build into their decision making process, beginning at the earliest possible
point, an appropriate and careful consideration of the environmental aspects
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of the proposed action in order that adverse environmental effects may be
avoided or minimized and environmental quality previously lost may be
restored."
In identifying the actions affecting the environment, agencies are
o
directed to consider the "overall, cumulative impact." Individual actions
"may be localized in their impact, but if there is potential that the
environment may be significantly affected, the statement is to be prepared,
o
Proposed major actions, the environmental impact of which is likely to be
highly controversial, should be covered in all cases." "The Act also
.indicates that adverse significant effects include those that degrade the
quality of the environment, curtail the range of beneficial uses of the
environment, and serve short term, to the disadvantage of long-term,
environmental goals."
"In particular, agencies should keep in mind that...statements are to
serve as the means of assessing the environmental impact of proposed
agency actions, rather than as justification statements for decisions
already made."
As to content of the impact statements, the guidelines require the
following:
"(1) A description of the proposed action, a statement of its
purposes and a description of the environment affected, including
information, summary technical data, and maps and diagrams
where relevant^The interrelationships and cumulative environ-
mentalTiripact.. .shallTe presented.. .Agencies should also take
care tp_ identify, as appropriate, population and growth"
characteristics of^the affected area and any population
and growth assumptions.77" (emphasis added in all cases)
"(2) The relationship of the proposed action to land use
plans, policies and controls of the affected area. This
requires a discussion of how the proposed action may conform
or conflict with the objectives and specific terms of
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approved or proposed Federal, State and local land use plans,
policies and controls, if any, for the area including those
developed in response to the/Clean Air Act or the Federal
Water Pollution ControT"Act Amendments oTTSTzT""
"(3) The probable impact of the proposed action on the
environment.
(i) This requires agencies to assess the positive and
negative effects of the proposed action... Primary
attention should be given...to discussing those
factors most evidently impacted by the proposed action.
(ii) Secondary or indirect, as we!1 as primary or direct
consequences.TTshould be_ included".
e
"(4) A rigorous exploration and objective evaluation of the
environmental effects of all reasonable alternative actions."
"(5) Any adverse environmental effects which cannot be
avoided..."
"(6) The relationship between local short-term uses of man's
environment and the maintenance and enhancement of long-term
productivity..."
"(7) Any irreversible and irretrievable commitments of
resources...the extent to which the action irreversibly
curtails the range=of potential uses of the environment..."
In order to meet NEPA's precept to "utilize a systematic, interdisciplinary
approach" the Guidelines say:
"Agencies should attempt to have relevant disciplines
represented on their own staffs; where this is not feasible they
should make appropriate use of relevant Federal, State, and
local agencies or the professional services of universities and
putsideconsultants. The interdisciplinary approach should not
be limited to the preparation of the environmental impact
statement, but should also be used in the early planning stages
of the proposed action. Early application 'of such an approach
should help assure a systematic evaluation of reasonable
alternative courses of action and their potential social economic,
and environmental consequences."
Provision for review of draft environmental statements are made by Federal
and State agencies with jurisdiction by law or special expertise, by the EPA,
and by the public. Special emphasis is given to public participation. In
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discussing responsibilities of commenting entities the guidelines urge
commenters to "endeavor to make their comments as specific, substantive, and
factual as possible."
An area for specific comment is introduced:
"Agencies and members of the public should indicate in
their comments the nature of any monitoring of_ the envir-
onmental effects of_ the proposed project that appears
particularly appropriate.Such monitoring may be necessary
during the construction, startup, or operation phases of
the project. Agencies with special expertise with respect
to the environmental impacts involved are encouraged to
assist the sponsoring agency in the establishment and
operation of appropriate environmental monitoring."
The Guidelines make it plain the NEPA applies to existing projects and
programs that were started before the Act was passed:
"Agencies have an obligation to reassess ongoing projects and
programs in order to avoid or minimize adverse environmental
effects. The section 102 (2) (C) procedure shall be applied
tp_ further federal actionsnTaving a significant effect on the
environment even though they arise from projects or programs
im'tiatecTprior to enactment of thelicT on January!, 1§70
...it is essential" that the environmentaT~impacts of proceeding
are reassessed pursuant to the Act's policies and procedures
and, if, the project or program is continued, that further
incremental actions be shaped so as to enhance and restore
environmental consequences. It is also important in further
action that account be_ taken o7 environmental consequences
not fully evaluated a_t the outset of the project or_ program."
B^_ Guidelines and Policies of the State of Montana Agencies to Effect
Control of Air and Water Pollution Resulting from Forestry Operations
The legislature and agencies of the State of Montana have established
laws and procedures and the means of controlling air and water pollution
in the State. Several agencies are also preparing new laws for the
legislature and regulations to more fully comply with Federal legislation
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and to strengthen the requirements and the power to control air and water
pollution. The Department of Health and Environmental Sciences (DH & ES)
has primary responsibility for air and water pollution control. The
Environmental Quality Council administers Montana's Environmental Policy
Act. The Department of Natural Resources and Conservation (DNR & C)
and the Fish and Game Department carry no direct authority but their
activities are so deeply involved in air and water quality that a descrip-
tion of their activities is included.
Water Pollution Control
The State government of Montana is taking the steps prescribed
under Section 208 of the Water Pollution Control Act Amendments of 1972.
The Governor has identified the areas in the state which "have substantial water
water quality control problems." He has designated the Department of
Health and Environmental Sciences (DH & ES) as the representative
agency in charge of planning. This agency has in operation a "continuing
areawide waste treatment planning process." The Water Quality Bureau
of the DH & ES has designated the Flathead drainage as water quality
limited through its continuing planning process.
The most recent amendments to the Montana Water Pollution Control
Act, effective November 5, 1973 include a provision on nonpoint pollution
sources (MAC 16-214(10)-SI4480 Water Quality Standards):
"Pollution resulting from storm drainage, storm sewer discharges,
and nonpoint sources, including irrigation practices, road
building, construction, logging practices, overgrazing and
other practices, are to be eliminated or minimized as ordered
by the Department."
This statement is preliminary to a program aimed at identifying and
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controlling these sources within the next two years.
Montana has passed legislation regarding both water and air
pollution. The administration of these acts is the responsibility of the
Department of Health and Environmental Science. Relationships between the
State and Federal government in regard to water and air pollution legisla-
tion are close and follow the general policies of the Federal government
vis-a-vis the states: "it is the policy of the Congress to recognize,
preserve and protect the primary responsibilities and rights of the States
to prevent, reduce and eliminate pollution and to plan the development and
use (including restoration, preservation, and enhancement) of land and water
resources..."
Montana's 1967 water pollution control act and later amendments seek
to keep the Montana laws in compliance with Federal requirements. The
State Water Pollution Control Council adopted the State's Water Quality
Standards which included water quality criteria, water use classifications
and policy statements in 1967. In 1971, The State Water Pollution Control
Act was revised and the functions of the Council were turned over to the
State Department of Health and Environmental Sciences. Further amendments
were enacted by the 1973 legislature.
In Section 2 (c)(2) of the 1973 amendment the law states that, "in
revising classification of standards or in adopting new classification or
standards the board may not so formulate standards of water purity or
classify any state water as to lower any water quality applicable to any
state water below the level applicable under the classifications and
standards adopted by the state water control council...of 1967." And
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Section 2 (c)(3) clearly states an antidegradatlon policy when 1t
says, "the board shall require that any state waters whose existing
quality is better than the established standards as of the date on
which such standards become effective be maintained at that high quality
unless it has been affirmatively demonstrated to the board that a
change is justifiable as a result of necessary economic or social develop-
ment and will not preclude present and anticipated use of such water."
It goes further in Section 2 (c)(4) to say that, "the board shall require
any industrial, public or private project or development, which would
constitute a new source of pollution or an increased source of pollution
to high quality waters, referred to in (3) immediately above, to provide
the degree of waste treatment necessary to maintain that existing high
water quality."
The DH & ES is carrying out a number of studies including the quality
of the inflow and outflow from Flathead Lake and is trying to identify
pollution sources from urban areas, agricultural areas, and forests. It is
cooperating closely with the Department of Natural Resources and the Fish
and Game Department. A biologist from the Fish and Game Department is
assigned to the DH & ES to assist in studies and pollution monitoring. In
cooperation with EPA it sponsored a study recently completed by John Tibbs
of the University of Montana.
Air Quality
The 1967 legislature passed the basic law entitled "The Clean Air Act
of Montana" which set policy, responsibilities for administration in the
DH & ES, created the Air Pollution Control Advisory Council and established
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its powers. The broad powers provided by the law, included making rules,
identification of sources, power to enforce, undertaking studies,
monitoring, and establishing standards.
The Board was also authorized to issue, suspend, revoke or renew
permits, make inspections and has the power to shut down violating
persons, or companies and issue penalities.
Municipalities and counties were authorized to establish local air
pollution control programs and to administer them.
The local laws can be more strict than state laws but not less. If,
however, the local program is not able or does not comply with set standards
the state reserves the right to reassert control.
Ambient air quality standards were established on May 27, 1967, and
recognized as only a beginning. "These standards are not intended to
represent the ultimate in air quality achievement." The plan was to
strengthen and improve them as research provided knowledge for sounder
standards. The goal for air quality was established as a compromise.
"The standards are designed to protect the health, welfare and comfort of
the public and to minimize economic losses."
Regulation 90-1010 revised January 9, 1970 stipulates "Open Burning
Restriction." Under Section A, Refuse Burning Restrictions, it states "NO
person shall cause, suffer, allow or permit an open fire except under the
conditions:
1. When such fire is set or permission for such fire is given in the
performance of the official duty of a public officer, and in the
opinion of the control officer is necessary:
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a. for the purpose of the elimination of a fire hazard which cannot
be abated by any other means.
b. for instruction in methods of fighting fires.
c. for the purpose of removing any hazardous material.
2. When such fire is set in the course of an essential agricultural
operation in the growing of crops or in the course of accepted
forestry practices provided no public nuisance is created and
provided a permit has been secured from the control officer.
3. When fires are set for the clearing of lands for new roads under
conditions stipulated in writing by the control officer and after
having applied for and received a permit for such open fire from
the control officer.
A study conducted by personnel of the DH & ES in the Flathead
Valley area November, 1968 to August, 1970 (following an earlier
base line study of the same area in 1963-64) observed that: "The air
quality in Flathead Valley has shown an alarming decline during the past
seven years." It concludes that the "most significant source of suspended
particulates and dirt fall is...from dusty paved and unpaved streets and
open burning." Among the recommendations made by the study team are:
(Regulation 90-005)
"1. That dust depressants be applied to all unpaved city streets.
2. That all open burning be stopped...
3. That an alternative method to slash disposal by burning be found."
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While regulation 90-010 makes an exception for the disposal of slash
by burning, State and Federal forestry agencies have expressed the feeling
that this exception is temporary and that the DH & ES may eventually
prohibit the burning of slash or other uses of fire in forestry.
The Forestry agencies are experimenting with mechanical means to
reduce slash in certain situations. They firmly believe, however, that
fire has a role in the forest ecosystem not only for reducing the danger
of wildfire and preparing seedbeds, but also for releasing certain soil
nutrients. The Fish and Game Department (F & G) wants burning continued
as a means of providing additional browse on game ranges.
At this time the forestry agencies have worked out an agreement with
the air quality officials of the DH & ES aimed at minimizing environmental
degradation from slash burning (see appendix).
The Montana Environmental Policy Act (MEPA) of 1971, established the
basic policies and guidelines for environmental protection in Montana.
Patterned after NEPA, it establishes the Environmental Quality Council and
staff and establishes the duties and procedures for the director and staff.
MEPA requires the preparation of environmental impact statements:
"Prior to any decisions concerning major action or
recommendations or proposed legislation that significantly
affects the environment, State agencies shall, in consul-
tation with other appropriate agencies and individuals,
both in the public and private sectors, assess in detail
the potential environmental impact in order that adverse
effects are avoided..."
.The revised guidelines for environmental impact statements were
adopted by the EQC on July 21, 1972.
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The act pronounces that "it is the continuing responsibility of the
State of Montana to use all practicable means, consistent with other
essential considerations of state policy, to improve and coordinate State
plans, functions, programs and resources..."
The Montana EQC has certain supervisory and coordinating responsibil-
ities over State agencies. It orders all State agencies to "review their
present statutory authority, administrative regulations, and current
policies and procedures for the purpose of determining whether there are
any deficiencies or inconsistencies therein which prohibit full compliance
with the purposes and provisions of this act..." However, it specifies
that statutory obligations shall be unimpaired by the act and that the
policies set forth in this act are supplementary to those set forth in
existing authorizations of all boards, commissions and agencies of the
State.
The MEPA was established by the legislature and the Montana EQC is
responsible to the legislative assembly, although the Governor is an
ex officio member of the Council. The Director has the responsibility to
gather information on environmental trends, review and appraise various
State programs and activities, recommend policies to the Governor and
legislature, conduct research and investigations, document and define
changes in the environment, provide material and aid in preparing
legislation, re.view and evaluate programs of other agencies and recommend
improvement, and provide annually to the Governor and legislature a
statement on the condition of the environmental quality of the State.
This report shall evaluate the condition of the environment, its adequacy
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in meeting the State's needs, the current and foreseeable trend 1n
environmental quality, the adequacy of the State's programs and recommen-
dations for needed remedies. In this way, the EQC has a general over-
sight responsibility for all environmental programs in the State.
The Department of Natural Resources and Conservation (DNR & C)
considers MEPA as the basic guideline for all its activities. The main
emphasis is on timber sales from State forest lands including those in
the Flathead area. An internal environmental statement is prepared on
all timber sales and an Environmental Impact Statement is prepared for
all sales determined as "major." The determination is made by the
Director of DNR & C. These statements are sent to the EQC, the Governor .
and interested people. If water questions are involved in the sale, soils
scientists, hydrologists and other specialists are available from their
own staff as well as from other divisions for preparation of
the impact statement. Fish and Game biologists are asked to participate
in statement preparation on all sales except minor ones. This process
slows down timber sale preparation and more lead time is needed but
the general reaction of department personnel is to welcome the process.
Excellent comments have been received from other agencies and from
the public. The individual timber sale plans define specific policy
and guidelines for each sale.
The DNR & C is cooperating with the Flathead County Planning Board
o
in Land Use planning. The Forest Service is also cooperating with the
Flathead County Planning Board and has made a significant contribution to
it. It finances one professional land planner who serves on the County
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Planning team. The arrangement is made under a cooperative agreement with
the State. The DNR & C is also working with the Pacific Northwest River
Basin Commission. The Flathead area has been selected as one of the
study areas by the Commission but the study has been underway for only
one year. The Geological Survey is now monitoring streams in the area
for water quantity, the DNR & C would' like to extend the monitoring
to include water quality. The DNR & C has also tried to interest the
Fish and Game Department and the DH & ES into a water quality monitoring
program but only a limited amount is being done.
Environmental Analysis Reports are prepared where forest roads are
built cooperatively with the Flathead National Forest or other groups such
as the Burlington Northern Company which is a large private landowner in
the area.
The Fish and Game Department's responsibilities in water quality stem
primarily from the Stream Preservation Act which applies to any projects
by any subdivision of State government which might alter a natural body of
water, physically. Its main concern is with road and highway construction,
it has no authority over irrigation diversions.
The department is involved in the State water pollution control act
because the criteria established are largely biological. While the DH & ES
has the responsibility under the act, the Fish and Game Department provides
it with a fisheries biologist. Personnel of the F & G Department throughout
the State serve as the ears and eyes for the DH & ES, reporting infractions
that they learn about in the course of their work.
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The department is also consulted by the State Forestry Division and by
Federal agencies and is invited to review timber harvest and road construc-
tion plans and environmental impact statements, for example, the plan for
Bunker Creek on the Flathead National Forest. This controversial sale is
being criticized by citizens and much of the criticism comes to the F & G
Department to act as intermediaries for the public in relations with the
V
Forest Service.
The F & G Department has been responding to many proposed management
plans on public lands. It has kept records of its comments in order to
see what the agencies accepted and what they rejected. A staff member
commented that the officials of the Flathead National Forest were the mpst
responsive Forest Service administrators in accepting the comments and
recommendations of the F & G Department.
In many of the mountain streams the critical wildlife is identified
as the Native Cutthroat Trout which has very specific water quality
requirements. The Fish and Game people, especially the fisheries biologists,
\
are capable of identifying sedimentation problems and their possible
extent. While the legal authority rests with the DH & ES, Fish and Game
officials act when they consider it necessary. Apparently this working
relationship causes no friction and is, in fact, a satisfactory
relationship to both agencies. There is no monitoring of stream sediment
content, identification now is by observation only. The impact of stream
sediment, such as its effect on invertebrates, trout, and other species is
not known.
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Fish and Game officials expressed unhappiness with the condition of -
the valleys of the North Fork as the result of past logging. They also
criticized road jcpns_truc_t1on_ into unroaded areas.
The Fish and Game Department advocates slash burning and would like
to see controlled burning in brush country. It expressed the belief that:
"burning is essential for improvement of wildlife habitat."
Relationships between F & G and EQC are close. EQC staff calls on the
F & G Department for review of highway plans and their possible effects on
stream channels as well as for review of impact statements affecting hydrau-
lics, game seasons, campgrounds, etc. F & G and EQC keep each other inform-
ed of their activities. On plant siting, the Bitterroot powerline and other
proposals, F & G was called in to help the DNR & C with the preparation of
impact statements. F & G in the past has formed the bulk of the critics in
State government. It has now changed status to that of co-authors with DNR &
C with EQC, and with DH & ES on impact statements, plans, etc.
F & G feels that it could close down a timber sale, either Federal
or State as well as roads on a timber sale under the Stream Preservation
Act. There is no question that it has the power to call for an alteration
in plans for roads or timber sales. But the effect would have to be a
physical alteration of the stream under the Act. However, as the eyes and
ears of the DH & ES it could invoke the State water pollution act.
It has not yet invoked the non-degradation clauses of the State law. In
fact, that clause has not yet been invoked by anyone but it does represent
the ultimate power in the hands of State agencies.
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In its unit planning activities the USFS leans on the F & G Department
for specialists. But specific knowledge is not available on many factors
such as the quantification of stream quality, and the effects on wildlife.
The department can help in identifying winter range but a great deal is
yet unknown of the relationships of forest harvest, and roads to the wild-
life and fish. At this time the F & G Department feels that its contribu*
tion to planning is of minor value. The process of participation with the
Forest Service shifts part of the responsibility to the F & G department
and meets certain coordinating requirements. The department feels that it
is sometimes used as a crutch for credibility. F & G data are not really
useful for planning but more for setting seasons and identifying winter
range.
Environmental Monitoring
In its second annual report issued in October 1973 the Montana
Environmental Quality Council reviewed the environmental activities and
accomplishments of Montana agencies and the legislature. It also listed new
programs proposed by agencies. Among these the Council recommends the
creation of an interagency environmental monitoring committee:
"This recommendation involves creation of an interagency
environmental monitoring committee that would standardize
and coordinate federal and state monitoring. In effect,
the committee would define parameters to be measured,
standardize methods of observation, coordinate programs,
provide data storage and dissemination systems, attempt to
eliminate duplication of effort and unwanted ommissions,
and coordinate with federal monitoring."
Such an action would be a big step toward the coordination of Federal
and State activities specified in the Federal Water Pollution Control Act
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Amendments of 1972 and would also provide for closer cooperation called
for in the National Environmental Protection Act of 1969 and the Clean
Air Act. It could also help to set the stage for working out control and
enforcement procedures, training programs, demonstrations and other
procedures needed to meet the environmental goals expressed in the Acts.
State Agencies TJT_ Summary
The State has relatively strong policies and laws protecting environ-
mental quality. It has developed workable guidelines and excellent
working relationships among the State agencies involved in environmental
protection. The coordination of activities among State agencies provides
a strength and effectiveness which is better in many ways than strict
departmental responsibility and authority.
V
The relationship between state and federal agencies, however, is not
well developed. Points of contact have occurred as past programs have
brought state and federal agencies together, but there is as yet no coordin-
ated approach such as will be required for "areawide waste treatment manage-
ment planning" under the Federal Water Pollution Control Act Amendments of
1972. Some cooperation in water quality studies exists. For example, the
DH & ES is making some water analyses for the Beaverhead and Gal latin
National Forests now, but this is not part of a deliberately planned
program.
Several state agencies have initiated monitoring programs around the
state including some in the Flathead River basin. These appear to be
largely uncoordinated with the monitoring being done by some federal
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agencies. However, the EQC has proposed a coordinated monitoring program
which could become a first step toward the coordination of state and
federal water quality programs into areawide waste treatment management
planning.
The Flathead River Basin has become the center of concern of a
number of state and federal agencies. While the focus is on Flathead
Lake, the concern is for the whole basin. With the example of Lake
Tahoe in mind state agencies and local residents realize that degradation
of water quality is already taking place and that prompt, major and
continuing action is necessary to restore lost quality and prevent further
deterioration. The efforts of every agency involved in the Flathead
Basin are needed in a continuing, cooperative program to identify, monitor
and control the sources of pollution throughout the basin.
Ihe.jtate_res.ou.r_ce-management -agencies are..in. need_ of. more knowledge
and data to identify and quantify the environmental effects of their
activities as well as those o^^r__activitjjes_ affecting the quality of air
and watery The present level of monitoring is not sufficiently advanced
to provide the data for identification and control of nonpoint sources of
pollution. The monitoring of the DH & ES has been directed toward point
sources of pollution. The F & G Department has been observing sedimenta-
tion from nonpoint sources and its effect on the fishery resource but it
has not been monitoring or quantifying the amounts or effects.
The Division of Forestry in the DNR & C has not been monitoring for
the effects of forestry activities on state lands. It does not have data
on the effects of its activities on water or air quality and it has
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developed no means of predicting the environmental effects of forestry
practices. While it prepares environmental statements on planned
activities, and while it observes the traditional precautions in road
construction and timber harvest it has not accumulated the quantified
data needed to provide precision in predicting environmental effects.
Its policies and guidelines are now in compliance with MEPA but do not
yet meet the requirements under the most recent revisions of the Water
Pollution Control Act regarding nonpoint pollution.
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II. POLICIES AND GUIDELINES OF THE U.S.FOREST SERVICE
REGARDING AIR AND WATER POLLUTION
A_._ Washington Office and Regional Office Policy Guidelines
Air and water pollution, from nonpoint sources of forest management
practices, are a direct consequence of the magnitude and character of
soil and vegetative disturbances occasioned by the management program.
For a given "magnitude" of management, pollution rises with decreased
care and concern for environmental quality; for a given "character" of
management, pollution rises with increasing quantities of timber cut,
roads constructed, and acres of slash burned.
The Forest Service has responded to Federal and State environmental
»
quality actions with three distinct and separate sequences of policy
development of its own.
One sequence we will call the "Environmental Quality Sequence." It
begins with the NEPA Policy, and it develops the Forest Service's
procedures for meeting the provisions of the law. This sequence deals
with the character of forest management.
So does another, that we will call the "Forest Management Practice
Sequence," but it also confronts the question, ultimately, of the magnitude
of management activities. This line of policy development is a direct
response to the political issue of forest management practices—notably
clearcutting--that surfaced in 1970 and was punctuated recently by Judge
Maxwell's decision that clearcutting, specifically on the Monongehela
National Forest is illegal. By no means, of course, is this sequence of
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policy development concluded, but It bears directly on air and water
pollution.
The third sequence also is concerned with the character of forest
management and the magnitude as well, but in a broadly generalized way.
We will call this sequence by the name of its seminal document, "The
Framework for the Future Sequence." It is a policy "charter" that came
from the Chief's office in February of 1970, apparently a consequence of
the public concern for environmental quality that produced, in the
legislative branch, the National Environmental Protection Act. The
"Framework for the Future" document outlines the broad objectives the
agency intends to pursue and is amplified by refinements at the regional
and forest levels.
These three sequences began and progressed independently of one
another; documents in one sequence related only to other documents in that
sequence, and there was no visible integration until two of the sequences
were deliberately joined. Nevertheless, there are at least some elements
that are common to all three sequences: the language is strongly influ-
enced by a concern for environmental quality; the autonomy of the National
Forest unit as an independent planning entity is either assumed or directed;
there is a strong "people orientation" in the sequence—forest management
is to be pursued to meet the needs of people; and a great deal of stress is
placed on inclusion: all the resources and values are to be considered in
virtually any activity—planning, project work, and budgeting. Finally,
perhaps, there is a common failing, too: "quality environment" is assumed
to be an identifiable and agreed-upon objective, but it is never well
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described or defined because the^ attempt to do so is never made.
The Environmental Quality Sequence
The Forest Service sees NEPA as a basic component of its legal
foundation. It sees three other laws, in particular, in a similar
light: the Wild and Scenic Rivers Act, P.L. 90-542, of October 2,
1968; the Wilderness Act, P.L. 88-577, of September 3, 1964; and the
Multiple Use Sustained Yield Act, P.L. 86-517, of June 12, 1960.
The first policy response the agency made to NEPA was "Emergency
Directive No. 1," issued July 13, 1971. It established a new title in the
Forest Service Manual, Title 1900—Environmental Planning and Management.
The emergency directive established Chapter 1940, Environmental Statements.
The chapter listed four main subheads as follows:
1941 ACTIONS REQUIRING ENVIRONMENTAL STATEMENTS
1942 ENVIRONMENTAL STATEMENT PREPARATION
1943 CONSULTATION AND REVIEW PROCESS FOR FOREST
SERVICE ENVIRONMENTAL STATEMENTS
1944 FOREST SERVICE REVIEW AND COMMENT ON OTHER
AGENCY STATEMENTS
On November 29, 1971, Region I issued an Emergency Directive elaborating
the Washington directive for local circumstances. Forest Supervisors were
to prepare Statements, and they would be processed through the Multiple Use
Group in the Regional Office. Ultimately, the statements would go to
Deputy Chief for Programs and Legislation. On November 9, 1971, the
Washington Office issued another Emergency Directive, this time under the
2100 title, Multiple Use Management.
The planning policy, standards, and procedure contained herein
are responsive to the Act of June 4, 1897, the National
Environmental Policy Act, the Multiple Use-Sustained Yield Act
and other national direction.
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A major effort has been made to merge the requirements of the
National Environmental Policy Act and the past practices that
have been developed for multiple use management. A basic
framework that facilitates this merger is provided in
Chapter 2130.
Thus the agency decided early to integrate environmental quality consid-
eration with its multiple use planning efforts. There is a question,
of how direct the relationship is between multiple use planning and the
management practices that show up in the woods; but the agency was
determined to take the NEPA seriously.
Emergency Directive No. 1, November 9, 1971, constituted a chapter
of the Forest Service Manual that listed procedures for Multiple Use
Planning. There were five subheadings:
2110 Planning Standards
2120 Planning Procedures
2130 Environmental Analysis
2140 Environmental Statements
2150 Coordinating Instructions
Chapter 2130 was to provide the basic framework for "the merger," and this
is the language that did it:
An environmental analysis and its documenting report will be
made for all resource uses and activities and plans concerning
or involving National Forest System lands. The analysis will
be the basis for reaching decisions or, making recommendations
on programs and activities. Programs and project plans and
their implementation will be developed and carried out 1n
accordance with the decisions reached in the environmental
analysis process and as documented in the Environmental
Analysis Report...
Objective: The environmental analysis and report system is
intended to provide, as an every day standard of doing business,
a working, planning, and decision making process that is
responsive to both the Multiple Use-Sustained Yield Act and the
National Environmental Policy Act...
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On March 8, 1972 the Regional Office Issued its supplementary instruction
to comply with the Washington Emergency Directive. Environmental analyses
and reports would be an integral part of the multiple use planning
system, and would serve a number of purposes (Ref. ED No. 1, 3/8/72,
p. 2130.2—1): they would show the consequences of a proposal, project,
or planning unit, in terms of irreversible and irretrievable commitments
of resources; they would provide a systematic means for meeting the
requirements of NEPA for submitting statements; and they would provide an
objective basis for evaluation of the project by interested publics.
This Regional Directive also specified that Environmental Analyses and
Reports would be prepared by Forest Supervisors and if subject to Regional
Forester approval submitted to the Area Studies Group in the Multiple
Use Coordination branch of the Regional Office for review.
In May of 1973 the Washington Office issued Title 8400--"Environmental
Statements." This was essentially a number-change, superceding the older
Title 1900 which had been entitled "Environmental Planning and Management."
The subheadings were the same, and the thrust of the title was the "how-to"
information on the preparation and submission of environmental statements.
The net of all this seems to be as follows: in all multiple use
planning activities, environmental analyses and reports will be made,
according to the policy guidelines in Title 2100 of the Forest Service
Manual. In those cases where an environmental statement is to be submitted
to CEQ, the procedures of Title 8400 will be followed.
There is, in this "Environmental Quality Sequence," however, neither
standards specified for air and water pollution control, nor reference to
such activities. There is a vague but palpable urge to consider
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environmental effect in planning activities, but no attempt made to
define pollutants, or even to identify them.
The Framework For The Future Sequence
This sequence of environmental policy development begins in February
of 1970 with a document entitled, "Framework for the Future." This
document is seen by field people as a landmark, and it lists a series of
"objectives" and subsumed "policies" to achieve them. These are the
"objectives":
Promote and achieve a pattern of natural resource uses that
will best meet the needs of people now and in the future.
Protect and improve the quality of air, water, soil and natural
beauty.
Help protect and improve the quality of open space environment
in urban and community areas.
Generate forestry opportunities to accelerate rural community
growth.
Encourage the growth and development of forestry based enter-
prises that readily respond to consumer's changing needs.
* /
Seek optimum forest land ownership patterns.
Improve the welfare of underprivileged members of society.
Involve the public in forestry policy and program formulation.
Encourage the development of forestry throughout the world.
Expand public understanding of environmental conservation.
Develop and make available a firm scientific base for the
advancement of forestry.
This was issued from the Washington Office, over the signatures of
Secretary Hardin and Chief Cliff. It was followed in March of 1972 with
a Regional refinement entitled, "Management Direction for Northern Region."
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This document was keyed directly to the "Framework," policy by policy and
objective by objective, and relied exclusively on such verb-forms as,
"encourage employees to participate," "become actively involved," make
resources available," "offer the use of skills," "expand plans," "provide
leadership," etc., etc. Both documents might be summarized this way;
"Do right things and do things right."
In November 1972 the Region issued a "Northern Region Program
Emphasis," another document in this sequence. "Program Emphasis" was
divided into three categories. The first was "Regain our Professional
Credibility With the Public," and these were.the items catalogued
thereunder:
Accelerate and Intensify Multiple Use Planning
Balance Programs Within the Region
Improve the Quality of Our Timber Harvest Activities
Improve the Quality of Our Road Programs
Provide Leadership in the Entire Environmental Field
Become Intimately Familiar with the New Wilderness
Area Program so we can Work Effectively with the
Public
The second category of emphasis was, "Raise Our Standards..."
and the third was, "Improve Trust and Confidence...Within Our Organiza-
tion..." At the end of this document is a listing of "High Priority Items
for FY 1974" and they include such things as, "maintain Commitment to High
Quality Environment" and "Restore Pride in Workmanship."
The "Framework for the Future Sequence" of policy development
extended ultimately to the Flathead National Forest; the policies and
objectives of the "Framework" document itself were incorporated directly
into the Forest draft multiple use plan, and presumably the Flathead
people took seriously the exhortations of the "program emphasis" paper to
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"regain credibility," to "raise standards," and to "improve trust and
confidence."
There is much in the "Framework for the Future Sequence" to provoke
skepticism. The agency simply cannot, for example, "provide leadership
in the entire environmental field" by proclaiming its desire to do so, no
matter how sincere and unanimous the proclamation.
And yet it was clear that the expressions of good intentions
produced palpable results among the people on the Flathead National
Forest. External observers, might choose to see the platitudes as a
smokescreen for conducting business as usual; but the Flathead people took
them seriously, as honest commitments from Washington and the Regional
Office to improve the environmental consequences of forest management.
The study will explore their behavior in more detail later.
The Forest Management Practices Sequence
This line of policy development is directed and specific. It probably
represents the policy area in which the greatest political and public
activities have taken place. The agency has hammered out a policy develop-
ment sequence here in direct interaction with the political processes.
This sequence began in the turbulent year of 1970, when forest management
practices constituted a hot, lively, and controversial public issue.
The initial and influential publication in this series was "National
Forest Management in a Quality Environment—Timber productivity" which
appeared March 26, 1971. It was the result of a Washington Office study
team composed of the following people:
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Homer Hixon, Director, Timber Management
T. B. Glazebrook, Director, Watershed Management
Carl Ostrom, Director, Timber Management Research
Donald D. Strode, Assistant Director, Wildlife Management
Edward H. Stone II, Landscape architect, Division of Recreation
The study relied upon, and reviewed, a number of prior studies: "Manage-
ment Practices on the Bitterroot National Forest," by a Task Force team
in Region I; "EvenAged Management on the Monongahela National Forest";
the August 1, 1970 report of the West Virginia Legislature; and "Report
on the Bitterroot National Forest," by a Select Committee of the Univeristy
of Montana.
This, in outline form, is what the "Timber Productivity" study had to
say:
A. Introduction
1. The National Forest System—a brief description of the
size and operation
2. The Nation's Wood Needs—for improved housing, and
the importance of timber harvesting to the national
economy
3. Actions Now Underway—broader, multidisciplinary,
public-involvement planning systems are being developed;
reorganization into multidiscipline-team management
instead of functional management; effort to incorporate
environmental concerns—for example, timber management
"needs to be 'designed' to enhance multiple use
rather than to be 'modified1 for that purpose in the
past."
B. Background
1. Harvesting practices—the standard definitions: clearcutting,
shelterwood, seed tree, selection, intermediate, and
salvage cuttings.
2. Regeneration and stand improvement: a plea here for more
money to reduce the backlog of needed work.
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C. Problem Situations and Responses (30 problems identified in
all)
1. Problems of aesthetics: sensitize the FS to aesthetics-
recognize areas where timber will not be harvested
because of the lack of suitable alternatives to clear-
cutting, and environmental impacts make clearcutting
unacceptable—
2. Problems of silvicultural practices and regeneration--
recognize and avoid problems of regeneration and final
harvest cuts—a finely detailed section here, referring
to specific timber types, e.g., problem 15: "to
carefully review environmental protection aspect of each
major type conversion project before such projects are
undertaken."
3. Problems of resource data, planning, and administration.
Problem 17: "To develop and put into effect an adequate
system to collect information on land-use capability and
suitability that will identify the land base available
for sustained yield timber production and will exclude
from the allowable cut base those areas that cannot be
harvested within acceptable environmental quality
standards by using foreseeable technology." (This
planned program would certainly have a significant
impact on pollution levels because it would alter the
magnitude of forest management activities: indeed, if it
was fully implemented it would determine the pollution-
component attributable to the magnitude of activities;
henceforth, only the character of those activities
would influence pollution loads.)
4. Problems of Road Systems—phasing out jammer logging to
reduce road-frequency.
5. Problems of research needs; problem 30--to accelerate
research in three program areas.
a. Understanding the forest as an environmental and
productive base.
b. Understanding human interactions with the forest
environment.
c. Development of timber-management practices that
enhance or have minimum impact on the environment
and are compatible with other forest uses.
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A condensed and popularized version of this paper was published in
May of 1971, entitled, "Timber Management for a Quality Environment."
In July, 1972, a derivative publication appeared, under the signature
of Chief McGuire. This was called, "National Forests in a Quality
Environment—Action Plan," and it was prepared by a Washington Office Task
Force in direct response to the 30 problems outlined in "Timber
Productivity." There appeared to be a great amount of field interaction
in preparing the paper, and in his covering memo, Chief McGuire quotes
verbatim from "Clearcutting on Federal Lands," the March, 1972, report
of the Senate Subcommittee on Public Lands. McGuire's quotes relate
largely to the "guidelines" in the Subcommittee report:
1. Allowable harvest levels—these should not be raised until
management practices justifying the raise are proven
effective and funded.
2. Harvesting limitations—clearcutting is not to be used on
unstable sites, where restocking is uncertain, where
aesthetic considerations dominate, and in situations where
only economy of operations is served.
3. Clearcutting should be used only where it is silviculturally
essential, where blocks can be kept small, and where "a
multidisciplinary review has first been made of the potential
environmental, biological, aesthetic, engineering, and
economic impacts on each sale area."
4. Timber sale contracts should contain requirements to avoid or
minimize environmental impacts of timber harvesting, even if
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such measures result in lower net returns to the Treasury.
The Chief, in his memo, responds to each of the Subcommittee Guide-
lines by outlining planned actions called for by the 30 problems in the
"Timber Productivity" paper. These planned actions, in turn, constitute
the bulk of the Action Plan, and take the form of suggested training pro-
grams, planning programs, and reissuing and/or modifying sections of the
Forest Service Manual and other directives. There are many followup reports
called for in the action plan, due in Washington January 31, 1973,
July 1, 1973, and January 31, 1974.
Region I responded to the Washington Office "Action Plan" by
issuing one of its own, entitled, "National Forest in a Quality Environ-
ment—Northern Region—Action Plan." This appeared November 11, 1972, sign-
ed by Regional Forester, Steve Yurich. This also derives directly from the
March 26, 1971 report, "National Forest Management in a Quality Environment--
Timber Productivity"; it lists the same 30 problems, the actions called for
both by the Washington Office Action Plan (including specifically the ones
that relate directly to the Subcommittee Guidelines), assigns responsibility
for completion to the various units, specifies completion dates, and calls
for progress reports on specified dates.
B^_ Policy Development On The Flathead National Forest
Three sequences of policy development in the Washington and Regional
Offices have been traced, all of which were responding to the environmental
concerns of the 1970's.
The "Environmental Quality Sequence" of policy development deals with
the mechanics of implementing NEPA, and it outlines the procedures for
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making environmental impact reports and statements. The "Framework for the
Future Sequence" relates to broad objectives and states firmly, although
vaguely, the agency's commitment to doing right things and doing things
right. And the "Forest Management Practices Sequence" deals almost exclu-
sively with clearcutting, allowable cut levels, and other matters dealing
with timber management.
It would be expected that the three lines of policy development would
converge on the Flathead National Forest, and to a degree they do.
The requisites of NEPA, absorbed by Washington directive into the
multiple use planning procedures, appear at the Forest level well
integrated in the planning process, which is also heavily influenced by
the "Framework for the Future Sequence." NEPA and the Chief's
"Framework for the Future1 document are highly visible in the Flathead's
multiple use planning-activities.
The end of the chain of the "Forest Management Practices Sequence,"
however, is less obvious. The Region prepared a document entitled,
"National Forests in a Quality Environment—Northern Region—Action Plan,"
outlining 30 tasks to be completed which would improve the environment
quality consequences of timber harvesting. It has been distributed to the
National Forests and to ranger districts. Last summer it was the basis of
supervisor inspection of at least two ranger districts on the Flathead
Forests to check compliance.
And those outcomes will indeed be significant at the Forest level.
Problem No. 2, for example, reads as follows:
To recognize those areas where timber will not be harvested
because there is no suitable alternative to clearcutting and
environmental impacts make clearcutting unacceptable.
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One of the actions called for to solve this problem is, "identifying such
areas on the ground," and the responsibility for its accomplishment is
assigned to the Regional Office Divisons of Timber Management and Soil
and Water Management, and to the Intermountain Forest and Range Experiment
Station. This job was scheduled for completion June 30, 1973. The
Flathead Forest, however, had not received an inventory from the Regional
Office of such sensitive areas. Problem No. 4 is particularly acute on
the Flathead:
To recognize those areas where the final harvest cut must be
discontinued or deferred because there is not assurance that
the area can be suitably restocked within 5 years after logging.
Such areas were observed in field inspections, particularly in the
spruce-salvage areas, some of which were twenty years old and had not
restocked. The action called for here is to "Identify the problem areas on
the ground and withdraw (these areas) from the allowable cut (standard)
base," and once again the responsibility was assigned to the RO Division of
Timber Management. This task was to be completed by December 31, 1973.
The process as prescribed could not operate satisfactorily because the
Regional Office was not able to provide the specific recommendations
needed. The Regional Office did develop the criteria which served as
guides and the specifics were worked out by the Flathead staff. They have
incorporated these into their planning process and into specific
recommendations in the field activities.
The silviculturist, for example, examines the soils, the timber stand
and land forms for a specific sale to decide whether or not clearcutting is
suitable or whether an alternative system is preferrable.
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The Land Use Plan identified the high area zone as a problem area
where there was no assurance of restocking in 5 years and withdrew if
from the allowable cut base. It has identified other areas where
regeneration is a problem and is negotiating with the Regional Office to
withdraw these from the allowable cut base. The other two sequences,
however—embodied in NEPA and the Chief's "Framework for the Future"--
are apparent on the Flathead in the multiple use planning activities.
It is through these planning efforts that policy developments continue
at the National Forest level, and the attitudes and opinions of the
planners are probably paramount in the policy outcomes.
The "Environmental Quality Sequence" and the "Framework for the
Future Sequence" have both been very influential in the thinking of the
Flathead personnel--the Supervisor and his top staff people. The two
sequences emphasize that more decisions will be made "closer to the
ground," and improving the quality of the physical environment will weigh
much more heavily in those decisions. Also improving the physical
environment will involve improving the character of forest management
activities, and it may also involve decreasing the magnitude of those
activities; e.g., "spot" scarification instead of complete scarification
of seed beds. Many of the suggestions in the policy sequences would create
a negative impact on the allowable annual cut, and the Flathead planners
understood the implications of these suggestions.
The Washington and Regional Office policies and guidelines are
translated to the Flathead National Forest in various ways. The planning
process makes these policies and guidelines specific for the Flathead.
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The plans of the Flathead are and will be the policy of the Flathead,
and those plans are intended to be interlocked into a hierarchy.
The fundamental process is multiple use planning. In this planning
process and through this planning staff the administrative requirements of
NEPA are met: environmental analysis reports and, if a project is of
sufficient importance to warrant one, environmental impact statements
are written with the multiple use plan as "constraint" and are reviewed by
the multiple use planning staff.
The multiple use plan—the document—currently in effect on the
Flathead is called the Flathead National Forest Basic Land Management Plan;
it was recommended by Supervisor Corpe on December 23, 1971, and approved
by Regional Forester Yurich November 1, 1972. A revision was approved in
February, 1974. This is the foundation of the hierarchy of plans on the
Flathead, and it contains four major sections, three of them unique
to the Flathead. The first is a description of forest zones that is virtually
identical to that for other national forests; but the "forest situation,"
the "forest basic assumptions," and the "forest coordinating requirements"
are unique to the Flathead.
The concept of forest zones is being discarded in the Land Use Plan
in favor of a system to identify discreet areas of land requiring special
management considerations. For example, the high area zone is distinguished
by biological limitations which may have some uniformity, Mh limitations on
the special zone, however, are cultural and the treatment of each may be
different. Whatever was not classified into other zones became the General
Forest Zone and it was unheterogeneous and had to be reclassified for
management purposes.
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The heart of the plan lies in the coordinating requirement (CR's).
These "CR's" were hammered out in hours of staff negotiations. The staff
including the rangers are strongly committed to them. In general, they are
policy statements for the resolution of decisiqn problems, and they were
designed to accord the promises of the policy sequences from the Washington
and Regional Offices. They will be examined in detail later in the report.
They assert that decisions will initiate on the Flathead and that environ-
mental quality will be the overriding criterion.
The plan, then, is a comprehensive policy statement. The biological
data that will eventually rationalize production goals will be generated
in the next level of the planning hierarchy. "Unit plans" will be
developed containing detailed biological analyses of various geographical
subdivisions of the Flathead. One of these unit plans for the Spotted
Bear River Unit, has been completed. Others are underway; they are
detailed identifications of "E.L.U.'s," ecological land units, and are
based on a system of "habitat typing." These will be examined in more
detail later.
The next step in the planning hierarchy is the preparation of
"functional plans," for the production of timber, recreation, water,
wildlife, and forage resources. Ultimately, these functional plans will
be built on biological data developed in the area plans, and one of these--
»
a timber management plan—is to be undertaken in the immediate future.
Finally, at the bottom of the planning hierarchy, are the project
plans—detailed prescriptions for timber sales, road construction projects,
wildlife habitat management projects, etc.
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The project plans are to be derived from the functional plans, which
will be constrained by biological parameters in the unit plans, and all
of them are to be guided by the multiple use plan: such is the nature
and scope of planning--!'.e., policy development—on the Flathead.
This is a description of the ideal, and the Flathead staff welcomes
the opportunity. They would be delighted to stop all activities on their
forest until their plans were in good order. But they are realists in at
least two ways: they know that production and management activities, based
on obsolescent plans and planning mechanisms, will and must continue; and
they know that planning is a process and not an event. They see none of
their plans as final, complete, and immortal. They are committed to the
process of planning as the prelude to management.
£. Analysis of_ Adequacy of Forest Service Policy and Its
Relationship to State and National Environmental Policy
The policy description in these pages leads to a single and conspic-
uous conclusion: the goal of the Forest Service is land management and
resource production control and abatement of pollution has been reviewed
as a constraint on these activities.
The agency has viewed NEPA as an alteration in its operational
environment. It has seen such legislation as constraints, rather than a
new set of objectives.
There is little question that the agency's management practices have
contributed to air and water pollution. With one exception Forest Service
policy fails to confront the necessity for pollution control.
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The single exception is in the form of several "interim handbooks,"
highly specialized documents written for and by Forest Service hydro!ogists.
The "Interim Handbook on Federal and State Laws, Executive Orders, and
Rules and Regulations Pertaining to Water Quality in Region 1," is a
compendium, without internal interpretation or subsequent policy refinement,
and it does not include the stringent 1972 amendments to the Water Pollution
Control Act. A document that explicitly spells out the Forest Service
responsibility is the "Interim Guide for Water Quality Surveys in Region
1." It is in the process of revision to accommodate the 1972 amendments,
but in restricting its emphasis to quality surveys, the document is a
long way from dealing with the character and magnitude of forestry operations
that determine pollution loads.
In respect to policy there is a need to distinguish cases. The
package of policy for "environmental quality" as a concern, for drawing
attention to the environment as a consideration, appears adequate. The
package of policy for air and water pollution control, on the other hand,
has not yet appeared.
The U. S. Forest Service is one of the oldest line agencies in the
Federal executive branch. It has been in business for about 70
years. This longevity provides a set of preconditions against which
policy changes must take place. Many of the preconditions are legislative.
Many are derived from intraagency policy. Many are assumptions
and behavior patterns of the several professions or "occupational
specialisms" represented in the Forest Service. Some may be considered
as the momentum of tradition.
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Such momentum is not to be taken lightly in a 70 year old agency. It
provides the Forest Service with an identifiable organizational self-image.
The Forest Service people interviewed saw themselves as pre-eminently
concerned with air and water quality -- the current way of saying
"conservation." The tradition of good husbandry of the land was strongly
felt, though rarely articulated. Concern for air and water quality was
taken as axiomatic. This concern was basic and fundamental .in the policy
and guideline documents inspected.
The Environmental Protection Agency, on the other hand, neither enjoys
nor is burdened by such preconditons of cumulative legislation, internal
policy, professional predisposition, nor long tradition. Instead, it is
driven by the zeal and enthusiasm of a sharply defined and strongly felt
mission: the unequivocal and pinpoint-focus on air and water quality.
The mission of the Environmental Protection Agency is the control
abatement and prevention of air and water pollution; but, that is not
the mission of the Forest Service. The distinction is important to
make, in order to understand the policy review undertaken. The Forest
Service sees its mission as something rather distinct from and substantial-
ly more complex than the prevention of pollution.
The Forest Service sees its significant base of legislative policy as
composed of four laws: the Multiple Use Sustained Yield Act of 1960; the
National Wilderness Preservation Act of 1964; the Wild and Scenic Rivers
Act of 1968; and the National Environmental Policy Act of 1969. On this
legislative basis, internal policy is built.
In 1971, apparently in direct response to NEPA, the Washington Office
issued a new title in the Forest Service Manual, Title 1900--Environmental
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Plarming and Management. In May of 1973 this was superseded by Title 8400,
Environmental Statements; the content of this section of the Manual outlines
the policies and procedures of complying with NEPA--when and under what
conditions environmental impact statements must be filed, how many copies to
prepare, where to route them, and the proper means of typing up a title
page. The title deals specifically with the mechanics of meeting the
requirements of the NEPA, not with air and water pollution.
Title 2100 in the Manual is entitled "Multiple Use Management," and
it dates from 1960 when the Multiple Use Sustained Yield Act was passed.
This title refined the legislation into agency procedures, but it is more
comprehensive than that. The title establishes a resource planning
procedure that the Forest Service is deeply committed to. The Multiple
Use Act called for no such planning activity. Title 2100 defines the shape
and substance of future resource management on the national forests. It
also promotes a view of management, a philosophy of planning, and set of
assumptions that go far beyond the simple mechanics of multiple use
land-zoning and implementation. In an "Emergency Directive" dated
November 1, 1971 Title 2100 is seen in its central and controlling role.
On that date NEPA was absorbed into multiple use planning activities. This
is the language from that Directive:
A major effort has been made to merge the requirements of
the National Environmental Policy Act and the past practices
that have been developed for multiple use management.
Thus NEPA was absorbed. The Forest Service has been in the conservation
business for a good many years and the agency believes that making some
adjustments in its planning and reporting procedures would adequately meet
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the requirements of the law.
The "Flathead National Forest Basic Land Manaqement Plan" approved
by the Regional Forester on November 11, 1972, is loaded with stated
concern for environmental quality, and the coordinating requirements, it
might fairly be said, are directed at little else.
"Unit plans" are to be developed on the basis of the basic multiple
use plan. One such plan has been completed—the one for the Spotted Bear
Planning Unit. This plan, too, is full of environmental quality language,
reflecting once again the spirit of NEPA.
According to FSM 2100, Environmental Analyses and Reports (EAR) will be
prepared for each project the Forest undertakes. The Flathead Forest does
so for each timber sale and road construction project. When the impact of
a project is judged to be "significant," based on the EAR, an Environmen-
tal Impact Statement (EIS) is prepared.
A draft EIS has recently been issued on the Flathead for an interim
revision of the timber management plan for the forest. Again, NEPA is
respected in the planning process.
The documents and written guidelines relating to environmental quality,
and the requirements of NEPA, are numerous. They relate almost exclusively,
however, to the planning process, and only distantly if at all to Forest
Service operations; and "policy" is accounted for only partially in
documents and written guidelines.
"Policy" might also be construed to be what administrators dp_, in
addition to what administrators say.
The Flathead National Forest is doing three things. The administra-
tors are (1) planning, and in so doing are invoking the language and the
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spirt of NEPA.
They are also (2) cutting down trees and (3) building roads. The
language and spirit of NEPA are conspicuous in these activities only
by the frequently stated concern for "environmental quality" in Environ-
mental Analysis Reports. The objective pursued is not air and water
pollution control. The objective is forest land management.
In summary, the policy reviewed showed this: In written policy, a
great concern is evident for "environmental quality," though the term is
never defined in tangible terms. For air and water pollution control,
there is as yet little written policy.
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III. ACTIVITIES ON THE FLATHEAD NATIONAL FOREST AND THEIR RELATION TO
AIR AND WATER POLLUTION CONTROL POLICIES AND GUIDELINES
The response of the Forest Service staff on the Flathead National
Forest to the policies and guidelines from the Washington and regional
offices has been direct and significant. The environmental concerns
expressed have been taken to heart and converted to action on the ground.
A new spirit pervades the staff. Their new, planned environmental
approach to forest management is a considerable break with the past.
They have come a long way but there is still more to be done in
order to meet the goals and criteria established by the Water Pollution
Control Amendments of 1972 and the new NEPA Guidelines. These will be
discussed in detail later. First what the Flathead staff have done in
field operations since 1971 will be reviewed. It is significant and needs
to be thoroughly understood so that the appropriate steps can be recommend-
ed to meet the new program requirements.
Perhaps the best way to understand the progress is to review the
process of change which has been initiated in 1971 and follow it through to
the present. The present operation will then be analyzed to identify
program needs to meet the new requirements and from that analysis draw
recommendations.
Operations in the two decades before 1971 will be reviewed to more
fully appreciate what has been done since then. The history of forest
harvest on the Flathead N.F. has set patterns which are very difficult to
change.
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A^ Timber Operations on the Flathead N.F. Before 1971
Timber was the first major industry in the Flathead Valley. It
started with the construction of the Great Northern Railroad which was
completed in 1891; The industry began to export to national markets on
the newly completed railroad. Building materials were shipped to settlers
moving into the western great plains. Eastern Montana, western Dakotas
and the adjacent Canadian provinces were teeming with new settlers and
they provided a ready market for Flathead timber during the first two
decades of 1900. Timber was also shipped to Butte for use in the mines.
The supply of timber came mostly from the lower valleys: the Stillwater,
Whitefish and Swan Valleys as well as the broad Flathead Valley itself.
The timbering came almost to a standstill during the depression periods
when markets disappeared and by that time the supply in the valley bottoms
had largely been exhausted. The great boom period for the Flathead
Timber industry has come since World War II. The sale of timber from the
national forest had increased slowly from the depression period when
almost no timber was sold until 3 to 4 million feet were sold annually.
There was doubt that the annual allowable cut of 40 million board feet
would ever be sold.
The war period brought a quick increase in production to 31 million
feet in 1944. Production declined in 1946 and might have dropped further,
but in 1947 work began on Hungry Horse Dam on the south fork of the
Flathead. Timber on the reservoir site was offered for sale at prices
which attracted local as well as distant companies. One of the latter
moved in from Minnesota and set up a mill at Columbia Falls. Eighty-five
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TIMBER VOLUMES CUT & SOLD - FLATHEAD NATIONAL FOREST
Data from U.S. Forest Service, Missoula, Montana 12/28/73
(in thousand board feet) (MBF)
Fiscal Year
1973
1972
1971
' 1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
1959
1958
1957
1956
1955
1954
1953
1952
1951
1950
1949
Calendar Year
1948
1947
1946
1945
1944
1943
Cut MBF
Sold MBF
118,364
156,425
149,060
145,855
167,780
156,161
138,572
167,644
145,533
135,147
146,305
126,697
108,879
98,707
88,490
92,423
79,989
93,689
102,537
72,812
65,658
38,688
19,080
13,148
Not available
32,407
54,239
32,834
20,613
22,668
15,175
120,248
131,921
153,818
231 ,680
150,527
147,497
141,702
138,406
134,198
135,053
146,135
137,115
131,123
144,421
112,001
90,145
55,304
39,536
129,717
83,424
82,648
23,986
72,785
17,558
Annual
Allowable
Cut
(AAC)MBF
156,000
156,000
194,500
194,500
137,500
137,500
137
137
137
137
500
500
500
500
137,500
137,500
137,500
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
40,000
Cut in I
of AAC
76
100
77
75
122
114
101
122
106
98
106
92
79
247
221
231
• 200
234
256
182
164
97
48
33
81
136
82
52
57
38
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million feet of timber were sold in 1947 and 24 million the following
year. This timber entered the market during 1947 to 1949. There was
another reduction in 1950, but by this time the post-war building boom
was well underway and demand for Flathead lumber spurted to an all time
high. Total cut for the valley reached 200 million feet and from the
national forest it reached 102 million feet in 1955. The spruce salvage
program came as a boost to the industry just when it was declining after
the Hungry Horse project. This stage seemed to have put it into orbit.
Spruce had not been a high demand item. After a small flurry of
demand during World War I interest in spruce had died. Spruce on a low
market was commanding only limited prices, now it was pushed as a new
product competing with white pine. It also made a desirable material for
"decking" and "knotty pine" paneling. At the first sale for dead spruce on
the North Fork of the Flathead River the sale was limited to a few large oper-
ators because of the size of the operation and the expense of development.
The spruce salvage program was a response to a natural catastrophe, but was
possible because the means had been developed to harvest timber on steep
slopes and the market was high enough to accept the timber at a profitable
price. In 1949 hurricane winds struck this part of Montana and in this
national forest completely leveled considerable areas of timber and
uprooted many other trees throughout the area. Most of the damage
occurred in spruce stands at higher elevations. The spruce beetle attacked
the down and dying trees, rapidly building up in numbers and by 1952 the
attack reached epidemic proportions and had spread into green timber.
Millions of board feet of spruce timber were killed and a salvage program
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was launched. It was estimated that more than 2.5 billion board feet of
spruce timber were killed in Montana and Idaho. Removal of spruce timber
soon after mortality is urgent because the wood deteriorates rapidly and
is suitable for lumber for only about two years after it dies. The
beetle epidemic declined by 1957. The salvage program brought prompt
government action. Roads were built into the high country to salvage the
spruce, a system of clearcutting was developed, there was an expansion in
Forest Service activities aimed at the salvage of the dead spruce, the
industry expanded and there was a considerable immigration of new
industries into the area.
The movement of timber harvesting into the steep lands and high
country would have proceeded slowly under normal conditions. The combin-
ation of the spruce beetle epidemic, the post-war building boom which
occurred during the 1950's, development of technology which permitted
access to steep lands by harvesting equipment, the development of mill
technology to handle the species all combined to bring a quick development
of the forests of the high country.
As a crash program whose purpose was primarily the salvage of the
tremendous volume of timber, road and harvesting systems developed
very rapidly and the effect on the environment was severe. There were few
environmental controls at this time except for the basic policies in
existence. While the spruce salvage program at first was considered a
temporary crash program, it set the basis for a new level of harvest in the
Flathead National Forest which has continued to expand since that time.
The area that was considered operable has increased and continued to
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increase until it included virtually all the available forest land in the
Flathead National Forest. All species of trees became marketable, the
minimum diameter has continued to decrease and so the allowable cuts and
the amount harvested has continued to grow. The allowable cut was
increased to 64 million in the 50's and during the spruce salvage
program was exceeded every year. As it became plain that this level of
harvest would continue, the forest was re-analyzed and a proposal for
"Full Use and Development of Montana's Timber Resources" was submitted to
Congress by Montana Senators and Congressmen in 1959. It explained that
Montana timber had gotten into the national market in the 1950's and
Montana's national forests had now become important in providing for the
national timber supply. It proposed that Montana's primary manufacture
of timber could be increased three-fold with an eight-fold increase in
secondary manufacture as the basis for a greatly expanded economy. A
program was described as one "designed to fully develop Montana's
resources for the long time benefit of the nation." It included shifting
of additional manufacturing plants to Montana, expansion of transportation
needs, including roads and highways, a program of reforestation, greater
staffing for timber sales and considerable emphasis on the use of
national forest for timber production. It also called for the expansion
of recreation development and for water management. "Forest development
plans should recognize the needs for assuring timeliness, quantity and
quality of waterflow."
Montana was selected as a model for other western states. Although
the program mentioned that production in western Montana in 1957 was
at 830 million feet on an estimated sustained yield of 780 million feet
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it explained that by readjustment in^species taken, by taking smaller
size and lower quality of logs, and the extension of a road system to
permit greater salvage, the allowable cut could be increased to 855 million
feet in addition to a possible harvest of 1,234 thousand cords of pulp
wood. The allowable cut for the Flathead National Forest was increased
to 137.5 million board feet annually in 1961. The annual cut figures
in Figure 1 (page 52 A) show that this allowable cut was frequently exceeded.
During the 1960's the demand for Flathead timber continued although
the price dropped. The appropriations to the Forest Service were tied
heavily to timber production. Earlier requests for increased appropria-
tions on7 the spruce salvage program and during the period of the 1960's
following the program for Montana which then became a national program and
increased the allocations for the Forest Service showed that the increased
allocation to the Forest Service was more than repaid by the income from
the timber sold. The pattern was established of tying increases in
appropriations to timber production. Timber production became the main
activity of the Flathead National Forest and other national forests. There
were other forces at work and the requirements for road construction for
harvesting and other forest activities were strengthened.
The Multiple Use and Sustained Yield Act was passed in 1960 requiring
the consideration of all uses of the national forests. The Wilderness Act
was passed in 1964. Wilderness regulations had, of course, been in effect
long before this, and the Bob Marshall Wilderness had been established in
1933: one of the first in the United States. The Wild Rivers Act was
passed in 1968. Air and water pollution control acts had been passed
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durlng the 1960's. Citizen interest in recreation, water, wildlife and
aesthetics continued to increase, but the primary interest in timber
production was maintained.
The scientific basis for the management of the forests was based
largely on the traditional forestry knowledge of timber production. A
multiple use plan was developed for the forest and for the districts which
were then the working circle within the forest. The multiple use plans
and the timber sales contracts included provisions for concerns over
runoff, erosion, stream sedimentation, and other environmental facts. The
specific provisions in the timber contracts in the 1960's are not very
much different from those in the present (post-1971) contracts.
Enforcement tended to be lax. While cases of erosion, particularly
on roads, were observed they were accepted as part of the operation. If
roads were built too close to streams or if harvesting had to be carried
on across streams, they were done whether it was necessity or convenience.
It didn't make too much difference. Although the regulations became
stricter during the 1960's than they had been in the 1950's, where only
minimal restrictions existed, the pattern of lax enforcement had developed.
In the 1960's the price of timber was lower and there was a tendency to
disregard restrictions which might cause an economic pinch on the
operator.
Getting timber from the Flathead National Forest and other National
Forests in the Rocky Mountain region onto the national market was
considered a major accomplishment of the 1950's. This was touch and go
economically and any restrictions which reduced timber availability or
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raised operating costs were regarded as a threat. The accepted goal of
forest management was to replace the old residual timber with young, fast
growing, healthy stands would look like an "orchard." Removing the
residual forest,, therefore, had a deeper and more important purpose than
the production of timber alone and depended on the continuing availability
of an expanding market. Economic return to the government, or stipulations
for environmental considerations in road construction, timber harvest
and so on could not be allowed to seriously interfere with the primary
goal. While stricter controls were written into multiple use plans and
contracts, they were only minimally observed and not at all if they
appeared to offer any hardship to the operator.
During the 1960's, when the demand for timber was down, it appeared
critical to continue to rel^x controls in order to avoid a collapse of the
market for Rocky Mountain timber. In a way this was a public subsidy to
maintain the timber industry. Mills had been attracted into the area and
mills already there had been encouraged to expand on the basis of a
continuing and increasing volume of cheap public timber. Cheap, partly by
laxness in supervision and enforcement and partly by the consequent
accumulation of social costs in environmental degradation.
With the overwhelming emphasis on timber, the timber management
division from the regional office and the supervisor's office tended to
have a great deal of influence on the decision process. The field staff
were largely carrying out orders from higher ups. There was a general
acceptance that strict enforcement was not necessary. The forest
received instructions in terms of blanket recommendations. Clearcutting
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became the general recommendation for the harvest of virtually all species.
Harvesting equipment was designed and accommodated best to clearcutting.
It was the easiest and least expensive to lay out and to supervise.
Road construction became a primary activity of the national forests
and a considerable increase in engineering staff occurred and, looking back,
many of the roads are considered to be over-engineered, designed mainly to
accommodate equipment at higher speeds and greater efficiency, and so the
design of both the harvest systems and of the roads tended to clash more
and more with the natural environment. Decision-making became broad and
general rather than specific to the site or situation. The natural
features of limitations tended to be ignored. The system was thrust on
the land rather than being fitted to it, but it was efficient in terms
of manpower, in terms of machinery and in terms of maximum short
term production and profit. The Forest Service as well as the industry
and the community adjusted to it and became linked with it. The pressure
for increasing the cut continued and in 1969 a new management plan was
developed establishing the allowable cut at 194 million feet. A good
share of the increase was based on the expansion of commercial thinnings
into second growth stands. The change also represented a shift in the
period of liquidation of old growth timber to 32 years.
The Flathead Forest like most other forests in Region 1 has a high
percentage (43 percent) of its forested area in mature, high risk saw
timber stands. The mortality is high in such stands, the loss is
estimated at about 18 million board feet a year. A main goal of management
is to harvest these old stands and regenerate them with vigorous, fast
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growing, new stands. As far as production of timber from the forest was
concerned, the objective was to maintain an even flow of volume in
converting from the old stands to the younger stands. The purpose in
expanding the commercial thinning of these young stands is to increase
their rate of growth and shorten the conversion period for the old
growth timber. Of course, the problem is that this will greatly expand
the area of timber harvested each year and also extend the road program.
Provision was made that if the proposed commercial thinning program
of 2,000 acres annually didn't materialize within four years the conversion
period would be lengthened to thirty-four years and the allowable cut
reduced. The plan estimated that 3,270 additional miles of access roads
would be needed for effective management of the Flathead National Forest.
As of 1967 there were about 1900 miles of road completed. The total
acreage of forest harvested and exposed to the elements is not known, but
it has been in excess of 2,000 acres per year for the last 20 years. Not
all of the harvesting has been clearcutting. Some of it has been in
various stages of intermediate cut and a reasonable amount of it has been
overstory removal.
The accepted method generally was to clearcut the old growth timber;
to burn the slash, either broadcast or in piles; and to expose the mineral
soil in order to provide the best seed bed recommended by silviculture!
research. Disturbance of the soil is necessary in order to remove the
competition of grass, and underbrush and to reduce the depth of duff so
that seedlings can survive during periods of scarce moisture. This
conformed with the general idea of removing the old natural forest and
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replacing it with a more desirable "managed" forest. To quote from the
1969 Timber Management Plan, "Current Flathead management is directed
toward regenerating desirable species naturally. A stand of mixed species
adapted to the site is the objective. This is mainly accomplished by
cutting practices which create conditons that are desirable for naturally
regenerating the species. Occasionally certain areas need to be planted or
aerial seeded to get the desired results. This is still far from optimum
management, but combined with precommercial and commercial thinning, tree
growth and species composition should improve which should in turn produce
a more desirable forest. Some genetic improvement, fertilization, and
irrigation may also become part of intensive management." And then again,
"Visually the desired forest would approach the appearance of a well
managed orchard."
In general it was believed that the soils on the Flathead Forest
were relatively stable, that roads if properly laid out and taken care
of would not cause too much damage. Some of them had indeed washed out,
but they had been replaced. The runoff and siltation from cutover lands
and particularly those that had been heavily scarified ware recognized
but not considered serious. Since there were no standards established
for control of sedimentation, runoff, etc., general guidelines seemed
to be sufficient. While effects were recognized, it was considered that
they were not highly important, that they tended to heal over after a
time, that the effects were temporary and could be tolerated as a
necessary concommitant of timber harvest. At that time, at least, they
were not considered to be illegal. The protest from the public was largely
over visual impacts on the environment, especially clearcutting, and
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extension of roads and timber harvest into previously unroaded areas such
as Bunker Creek. There was also some complaint from fisheries biologists
and fishermen regarding the streams where road construction had interrupted
the run of the native Cutthroat and Dolly Varden trout and also that
siltation in some cases was reducing the spawning gravel beds. There was
also complaint over projections for extending roads into undeveloped areas,
particularly such areas as the Middle Fork of the Flathead River and some
of the high country areas like Jewel Basin.
A Case Study - North Fork of the Flathead River
The Forest Service had been estimating the timber volumes and allowable
cut in the North Fork drainage since the establishment of the national
forest. In 1916 the annual allowable cut for the drainage was estimated
at 25 million board feet. No timber was harvested because it was
inaccessible physically and could not have been brought to the market
at a profit. Periodic forest fires through the area reduced the estimated
annual allowable cut to 16.7 million in 1926. Still no timber was
harvested. In 1946 the annual allowable cut was reduced further to
14 million board feet, because of continued loss by fires especially in the
low country. The spruce salvage program started in 1953 and the annual
cut jumped from about zero to almost 50 million board feet in 1955 and
started to taper off after that. The allowable cut was increased to about
28 million feet in 1959.
It was during the spruce harvest program that the roads were
constructed into the valley seeking the easiest and cheapest route. The
access road was extended up the main valley and roads were pushed into the
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tributary valleys. They were poorly laid out and minimally constructed,
but they established the pattern for harvest of the area. The dead
and infected spruce was clearcut, largely conforming to the pattern of
infection. Succeeding harvest followed the original pattern and a number
of valleys were very heavily cut: Coal Creek, Hay Creek and- others.
Concern developed because siltation and bank erosion were occurring
in a number of the streams and inspections pointed out that these side
drainages were approaching the point of hydrologic imbalance. The problem
could not be settled by foresters, hydrologists, soils scientists and
others, because there was no basis, no hydrologic data, no quantitative
data on siltation or nutrient loss or any other of basic biological and
physical knowledge that needed to be obtained. The exact condition is not
determinable.
The North Fork drainages were the center of the spruce beetle
infection and were heavily cut in the spruce salvage program. Harvest was
shifted to other areas during the early 1960's to permit the North Fork
drainages time to recover. In 1968 to 1970 heavy cutting was again carried
out in many of the tributary valleys of the North Fork. This cutting was
near or contiguous to earlier clearcuts. The 1969 Timber Management plan
called for a rate of harvesting the old growth timber which would remove
all of it within 32 years. The conversion period was based on the
estimated period required for the younger forests to reach harvestable age.
The conversion rate was, it needs to be emphasized, based primarily
on the considerations for maintaining the output of timber. It was not
based on considerations for the environment. Only recently have such
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concerns been expressed. In the next portion, we will review the
inspections and comments of the Forest Service personnel after 1971 when
they reviewed the North Fork in the post-NEPA period. In the 1969 plan,
however, it was assumed that the heavy clearcutting in the North Fork was
not causing undue sedimentation, erosion and hyrologic effects; or that
the amount caused was, somehow, acceptable. While some effects were
noticed, they were considered transitory and would soon heal. The argument
for the rate of timber harvest was based on ample data on volumes and
growth rates while the considerations for erosion, sedimentation, stream
channel effects and so on were based on observation, not quantified data.
The level of harvest now hinges on the 32 year conversion period for
old growth timber proposed in the 1969 Timber Management Plan, There is
pressure particularly on the part of industry to hold to that conversion
period or in fact perhaps even reduce it in light of the recent report of
the Presidents' Panel on Timber and the Environment (PAPTE). The
argument advanced is that since available knowledge does not prove that
harm would be done by an accelerated rate of cut, that cutting should
proceed on the shorter conversion period. Inspection reports by hydrolo-
gists and others express considerable concern over the condition of a
number of the side drainages on the North Fork. A forest hydrologist
believes that 32 years is far too short and conservatively estimates a
far longer conversion period from the standpoint of the protection
of the watershed, but again he admits that he does not have data to prove
this. The Forest in its proposed 1973 timber management revision proposes
a fifty year conversion period as a reasonable compromise, but again the
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data. are not there to prove or disprove this position. The reasonable
approach where danger is forseen, is that a cautious approach be taken in
the light of lack of knowledge and that every effort be made to seek this
knowledge as soon as possible. The glaring need is quantitative data,
quantitative knowledge based on experience'which can be used as a much
sounder basis for prediction of the anticipated results. Meanwhile the
North Fork is a source of embarrassment to the Forest Service. Different
hydrologists see things differently. Some see severe damage, some see
insignificant damage to the watershed. There is unhappiness in the Forest
Service now over the type of forest management which led to the present
condition of the North Fork. Damage is now recognized and admitted, but it
is not quantified.
The lessons to be drawn from the North Fork are really not available
because of lack of quantified data, and whether or not it conforms to the
requirements of the 1972 amendments to the Water Pollution Control Act is
not known. The provision that past damage should be repaired applies here
and until effects are quantified the extent of repair will not be realized.
The North Fork is a lesson but one that cannot now be fully identified
and the practices that have been instituted as a result of the lesson
which appears to have been learned can also not be evaluated at this
time. And because it cannot be evaluated it may not be defensible from
any standpoint.
EL_ Changes Since 1971
In June 1971, a new Supervisor was appointed to the Flathead National
Forest. In the two and one-half years since then a new organization and
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program were established. There has developed a sense of responsibility
and accountability in the staff, brought together into a hard working
team. They have gone a long way toward instituting a program for "the
protection and enhancement of the environment."
The staff was asked to delineate what it considered its major
accomplishments. They are listed briefly here and will be discussed
in greater detail later after a look at recent inspection reports of
past forest activities:
1. Development of the Coordinating Requirements for the Flathead
National Forest and a decision that no timber would be sold
without land use plans.
2. Reorganization of the staff to a program basis, as opposed
to a functional basis, and identifying responsibility and
accountability.
3. Expansion of resource specialists to include staff in soils,
hydrology, fisheries, wildlife, geology and more
silviculturists.
4. Revision of the timber management plan and a reduction of the
annual allowable cut in 1972.
5. Cracking down on enforcement of contract provisions and
establishing authority to do so.
Inspection and Review of Previous Activities
Starting in 1971 and continuing to the present time the Forest Service
has sent inspection teams from the Regional Office and the Forest into the
field to review previous activities in order to provide an understanding of
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what had occurred and to recommend changes in operations to meet the require-
ments for "environmental protection and enhancement."
These documents constitute the evidence that the Forest Service itself
recognized environmental degradation from past practices and the need for
change in its operations.
In all cases the judgments are made on the basis of observation by
people with training and experience in substantive areas: They are not
based on quantitative data derived from measurements. The conditions can
be pinpointed but they cannot be evaluated in quantitative terms.
1. The North Fork of the Flathead River. An inspection team
from the regional office which reviewed the Flathead National
Forest August 6-10, 1972, reported the following: (emphasis added)
The National Forest lands in the North Fork of the Flathead
River Basin were heavily cut during the spruce bettle
infestation beginning in the early 1950's and also during
recent years. During 1968-70, extensive cutting occurred on
Many tributaries of the North Fork. Recent cutting has been
near or contiguous to former sales.
Aerial view of the North Fork drainages leaves the impression
that developed HraTinages have been overcut and ""TuTrtT" Concern
has been candidly expressed outside the Service as well as
within the Service as to how sales can be repeated so frequently
in the same drainage without causing soil damage and irreparable
damage to stream channels, water quality, water yield, and
stream habitat. The question of excessive siltation, scoured
streambeds, timber removal on creek banks, skidding along and
across streams, the miles of clearcuts along drainage courses,
removal of 65_ percent~oT~tTie" total volume or^ 15 percent of the
acreage are all quality management considerations affecting
soil and water.
The increased rate of waterflow and extended duration of peak
volumes for each stream are discussion subject materials within
the Service as well as outside the Service.
The Forest has inventory information that timber stocking on
most of the clearcut areas is sufficient. There are some areas
in which the stocking is not sufficient. Cutting areas in the
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North Fork generally have a dense brush cover. The Forest is
attempting to get accelerated reproduction in some of those
areas where stocking is not sufficient by vertical dozer
scarification. The Forest hydrologist indicated there were some
calculated risks involved. With average weather conditions and
proper execution of predetermined specifications, it was
believed the operation could assist in getting reproduction
without accelerated soil erosion.
There is a concern that in the properly stocked clearcut areas,
the reproduction has been slow in coming and growth has not been
sufficient for the length of time involved. This is an important
factor since hydrologically this influence in relation to tree
height, snowmelt, infiltration rates, water yield, water quality,
and a good mix of resource management is of prime importance in
the management of watersheds in the North Fork.
The North Fork drainages which have been developed in the
past show a_ preponderance of evidence of the viola'tTons of the
former RegTonal Multiple Use Guides ancTftanger District Multiple
Use Plan decisions'. ^Hjgh area, stream influence, and travel
influence zone definitions and coordinating requirements and
basic dec'isions~h"ave in the past been violated"?
The Forest is developing a sensitive awareness of this and
has taken positive steps to assure soil and water protection by
the establishment of marginal areas. This is a hold action until
such time that skidding systems or other systems of logging can
be developed which will assure reasonable protection of the land
and its water.
The shifting of allowable programmed timber harvesting is also
being accomplished.
A number of reports by various specialists in the Supervisor's office
refer to the North Fork. A report made on July 26, 1973, mentioned that
there was
"serious soil erosion and stream siltation on Whale Creek
near the confluence of Inuya Creek that starts in a high burn in
a basin at the head of the Inuya Creek. Large charges of water
surged down carrying rubble into the culvert at the Whale Creek
road. The culvert is plugged, water washes silt into Whale
Creek."
The recommendation was to remove the culvert and establish a new one.
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Another report on August 3, 1972, says that erosion and siltation
is mostly from roads: washouts, bank cuttings, slides, etc.; resulting
mostly from poor location and lack of drainage maintenance. It is recom-
mended that new culverts, additional culverts, relocations and maintenance
be instituted. Improper road drainage is noted as the main cause. Reveg-
etation of cuts, fills and fertilization are prescribed in order to get the
vegetation started. Inadequate erosion measures and control of temporary
roads and skid trails were noted( The pictures shown here>/ere taken by
Forest Service people and loaned to us.
In a report of November, 1972, on the Coal Creek Timber Sale the new
silvicultural objective was given as "the improvement of aesthetics by the
removal of overmature and decadent trees using small clear cuttings."
Erosion control was rated at "3 in a classification of 1 to 5." No
erosion was anticipated if proper control measures were used. "Non-specific"
skid trails and other roads should be obliterated or cross ditched and
grass seeded. The sale called for removal of all materials to a 3 inch
top. The environmental statement discusses stream-side protection. It
mentions that "there will be minimal soil erosion from ground disturbance
and that this is unavoidable and inevitable." (The new provisions are
expected to greatly reduce erosion over previous practices, but, it appears,
that it cannot be eliminated.)
A report of July, 1972, mentions that the Fall Creek drainage in the
North Fork "is drastically overcut and should be deleted from any future
logging plans for at least 10 years."
A report in July, 1972, remarks that on Whale Creek in the North Fork,
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"there is continual deterioration of the channel and it is best to
discontinue timber harvest in this watershed for 25 to 50 years."
On May 19, 1972, in a review of Packer's1 Bulletin, "Terrain and
Cover Effects on_ Snow Melts in_ a_ Western White Pine Forest," it is
recommended by a Flathead hydro!ogist that "A working knowledge of snow
pack reaction to management is an essential tool on the Flathead."
He explains that:
Snow melt is primarily dependent upon direct radiation to
the snow pack and by heating from convection and conduction
resulting in snow mass warming. Delayed melt usually results
in an increased melt rate. An increase in melt rates results
in sharper peak flows and subsequent channel damage. This is
especially critical jn_ poor channel condition areas such as~the
North Fork. By cTear c u 111ng low energy and horizontal slopes
at intermediate and high elevations snow melt has been delayed
and rates have been increased. As a result channel damage from
increased peaks has occurred. Conversely clearcuts on high
energy slopes result in earlier melt and some degree of desyn-
chronization with peak flows from low energy slopes. As Packer
points out, snow melt rates are lowest where canopy densities
range from 25 to 45 percent at intermediate to high elevations.
In the tributaries of the North Fork it would seem that there
is sufficient evidence to suggest that future timber harvest
should be directed to this end. This is old hat, but I will
repeat it again.Partial cutting in the low energy slopes and
small clearcuts on high energy slopes. The situation is probably
beyond the point where this type of management will have
significant affect, but it may help" in stabiTTzing the situation.
The Regional office inspection team mentioned other drainages in the
Flathead Forest:
2. Lost Johnny Creek. This creek drains directly into the
Hungry Horse Reservoir. Timber cutting operations have progressed
up the drainage and currently are located in the upper Johnny Creek.
1 Paul Packer of the Forest Service Intermountain Forest and Range
Experiment Station
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The active timber sale in this area is being modified to assure
quality management and protection of the soil and water resources
that are located in the high area zone. Roads are being closed to
protect the basic resources. However, there is evidence of
irreversible soil and water impacts in the Lost Johnny Creek
drainage.Soi1 has been forced into stream channels, roads have been
washed out, and coordinating requirements of the former Regional
MultipleTDse Guides violated.
The District Ranger and his assistant do exhibit an awareness of
the soil and water problems involved.
3. Spotted Bear River. The lower Spotted Bear River drainage is
being developed. The initial thrust of road building and timber
harvest operations have started and progressed to the Beaver Creek
Campground; 7.1 miles of additional road are being constructed and
completed into the Spotted Bear drainage proper and the lower portion
of the Whitcomb Creek drainage (comrnonly called the Dean Ridge Road).
The developed portion of the lower Spotted Bear River drainage
has in the past been a topic of discussion for the public as well as
for the previous Regional Forester and staff. Violation of the
Region's initial Regional Multiple Use Guides and Ranger District
multiple use plan decisions have left some irretrievable impacts.
Some difficulty is being experienced at the present time in connection
with recent road construction operations in this drainage. The soil
and water impacts because of road width and road location problems
where the road divides near the mouth of Whitcomb Creek, the large
slump because of "cutting the toe of the slope" on the initial
Whitcomb Creek section, and the existing and potential problems
generated in a small slump after crossing Whitcomb Creek are items
which demand a^ Forest look at what land ethic and quality management
really is in the eyes and mTnd o£ an^ engineer, soil scientists, ~
hydrolocjTst, forester, and District Ranger.
4. Bunker Creek. Bunker Creek is being developed. This
drainage also has a long history of public concern and controversy.
Development in the drainage has also caused some diverse thinking
and opinions within the Service over the past 15 years. A timber sale
of 31 million board feet was sold with some 15 cutting units
involved - basically to clearcut. In 1970, the new District Ranger
became concerned as to the impact of the timber harvesting systems,
particularly clearcutting, removing 31 million board feet of timber in
this sensitive and high water-producing basin.
Through established administrative procedures of District
Ranger, Forest Supervisor, Regional Forester, and Comptroller General
of the United States, the Bunker Creek timber sale contract has been
modified as to total volume, harvesting systems, and area to be cut
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over. One of the prime purposes of the modification has been to
protect soil, water, and wildlife from unnecessary impacts of logging
and road construction.
In traveling to and within the Bunker Creek sale, it was observed
that the roads appeared to be, in some instances, wider than
necessary. Excessive road clearing was causing additional debris to
enter creek channels." We observed current road locations which hacr
been made and partial construction completed in the creek" bottom.
Corrections had been made as soon as detectedTTiowever, degradation
of the soil and water resources had already occurred. Soil was
Being forcedTnto Bunker Creek.
Cat skidding in one of the lower units had been completed. This
was one of the best cat skidding jobs ever observed in this Region in
relation to the minor impacts to existing soil and water conditions.
There inherently exists a general and intensified road
drainage and general soil and water problem in the Bunker Creek
operation which is characteristic of this and other high
water-producing basins. Irretrievable decisions and resulting
irretrievable project impacts on soil and water can easily be made.
Early spring season road construction had caused some water and
soil problems. Good road location, construction, and proper
drainage are of prime importance in preventing irretrievable
impacts.
The Flathead has taken positive action in road closure
accomplishment in Bunker Creek. The information we received as to
future Forest plans and objectives of the road closure program
appeared to be logical. This action is long overdue. The reduction
in loss of soil, better drainage continuity, and improvement in water
quality are products of this endeavor. Protection of the grizzly
bear in the Bunker Creek drainage could be another. General wildlife
protection, when needed, could be enhanced.
5. Puzzle Creek. The Flathead Forest has begun construction of
a road from U.S. Highway No. 2, up Skyland Creek through Skyland-
Dodge Creek saddle, past the old Challenge Guard Station to the
headwaters of Morrison Creek, lower Puzzle Creek and upper Twenty-
Five Mile Creek areas. The original plan was to continue construction
of this road down Morrison Creek to the mouth of Morrison Creek, to
the old Shaefer Ranger Station and onward to the Spotted Bear River
via Dean Ridge. Public sentiment has caused a reappraisal of this
proposal.
Several timber sales have been made in the process of constructing
this road system to its present termini in the Morrison Creek area.
Some of these sales are also located in the high water-producing basins
where soils are sensitive. Portions of the area are extremely moist
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and boggy. Ranger District personnel became concerned about the
damage being done to soil and water in logging and road building
operations in the Puzzle Creek sale. The result has been a
modification of timber sale contracts with the objective of completing
current and agreed upon commitments and at this point, curtailing
further operations until such time that logging systems can be
developed which will not leave irretrievable damage to soil and water
as well as other resources.
There could be a question as to the extent of damaging impacts on
the areas logged and roaded in Sky!and, Dodge, Puzzle, and Morrison
Creek. This area also appears to have been "hurt." Soil is moving
into the creeks and the quality of water has been affected. Roads
_^_i__ be of greater~width _.
drainage Ts~ a problem.fine road was constructed through two snow
appeared to be of greater width Wan needed or desired, and roac
drainage Ts" a_ £n
avalanche paths.
Stream influence zone and travel influence zone coordinating
requirements of the past Regional Multiple Use Guides have been
flagrantly vioTated.
Dozer pi 1ing on a small burned area and on a clearcut area
appeared to be greatly excessive. The areas, in fact, looked like
plowed fields. The depth of the disturbance appeared to be such
that the future capability of the soi1 for regeneration of any kind
is_ seriously questioned. TFTs needs to be considered inTield
quality management training sessions.
Some further effects are discussed by staff specialists.
On July 7, 1972, the Gregg Creek Timber Sales, a report by the
fisheries biologist, Soil Scientist and hydrologist:
"We looked at the effects of clear cutting in the Gregg Creek
watershed Talley Lake Ranger District. There was ample evidence of
overland flow in the clearcut areas. Generally overland flow does
not occur in undisturbed forested areas. Gully and sheet erosion
were a result of water flowing over scarified soil. Much of the silt
from the eroded area was found in Gregg Creek. Water which had
flowed through debris piles exhibited a turbid appearance. Several
shallow ponds which had formed below debris piles contained a
considerable amount of green filamentous algae. The algae is a fresh
water algae commonly found in the warmer water where there is
sufficient nitrogen and phosphorus. Water samples were taken below
the debris pile and at a point in the mainstream approximately
one-quater mile downstream. The downstream sample showed more
dissolved oxygen and a slightly cooler temperature. Ranger Kline
called our attention to this area and suggested there has been
watershed damage due to logging. Onsite damage is obvious, but
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downstream effect is probably negligible. The area might serve,
however, as an in service educational area to show possible physical
and chemical changes in the water source."
This information is based on the observation of specialists with some
sampling, but no monitoring has been developed. The interesting thing is
that this is a documentation of onsite damage and an implication that
harvesting will always have some effect.
Major Accomplishments Since 1971
In listing what he considered his major accomplishments, the Forest
Supervisor discussed each point as follows:
1. During the development of the Coordinating Requirements for the
Flathead National Forest the decision was made that no timber would
be sold without land use plans. The spirit and intent of the Coordinating
Requirements became the most significant policy for the Flathead National
Forest. The CR's were approved by the Regional Office in November, 1971.
The Land Use Plan became the basis for timber harvest.
2. Reorganization of Flathead Forest was authorized by the Chief of
the Forest Service. Two forests in each region were permitted to
experiment with reorganization. The Flathead changed from the former
functional basis (i.e., timber, water,wildlife, recreation) to a program
basis. The new organization gives greater protection from outside
pressures which usually represent interest groups. Since there is no
specific staff in the special interest area, the pressure points are
largely eliminated and problems are treated in the perspective of the
program for the whole forest. There is now greater accountability.
Rangers have more responsibility for the decisions on their own districts
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and are held accountable for their decisions. Ranger staffs have been
strengthened by transfers from the supervisor and regional offices. The
reorganization had the potential to weaken construction supervision so
this activity was held in the Supervisor's office. However, Construction
Supervision personnel report to the district ranger when working on a
district.
3. The timber management plan was revised in 1972 and the annual
allowable cut was reduced from 186 to 156 million board feet. The
environmental impact statement on the revised plan is under review. The
programmed sell depends on manpower available and was set at 107 million
board feet for FY 1974. The revised plan has been challenged by industry
and was the basis for the Oils report in 1972. Timber Management
Planning and Land Use Planning are complementary and the new Timber
Management Plan will be used to advance the Land Use Planning activities.
The figure resulting will become the basis for the annual allowable cut.
The allowable cut will be discussed in detail later.
4. Enforcement of contract provisions has been intensified. A
key problem has been overloaded log trucks which cause damage to bridges,
road surfaces, structures and culverts. This has been a persistent and
pernicious problem. Enforcement in the past penalized only the truck
driver. Flathead Forest officials are now taking enforcement action
against the timber sale contractor. Timber sales have been closed
1 A Study of Forest Management Practices on the Flathead National
Forest, Montana. R. E. Oils et al. for the Kalispell Chamber of
Commerce (Mimeo) October 1972.
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down for the first time and the regional office supported the action.
Now that the right to cancel sales for overloads has been established,
Flathead forest officials feel that they have the authority to close
down sales for violation of environmental stipulations. The contract
can now be used to enforce compliance. There has been strong reaction
to such enforcement procedures by industry. Announcement of new USDA
regulations on Cancellation of Contracts was published in the Federal
Register on April 23, 1973. Mith this new regulation Flathead forestry
officials feel that enforcement can become even more effective.
5. The specialists were added during the reorganization. The staff
of the Flathead find that the hydrologist, soils scientists, geologist
and silviculturists have been a great help and it is recognized that
more help is needed. The half-time services of a fisheries and a big
game biologist are also available. Individual districts are approaching
the time when they will need a silviculturist and an engineer and
possibly other specialists on a full time basis. It is not the job of
the specialists to determine specific action but to analyze and point
out consequences and alternatives. The ranger (with the advice of
specialists) makes the decision and is accountable for the decision. If
the ranger ignores the advice of the specialists, the Supervisor's Office
acts as mediator.
Accomplishments of the Flathead National Forest staff are recognized
in the Regional Office inspection report of August, 1972:
Its People
The Flathead Forest received a new supervisor in June 1971. The
Flathead people we traveled with during this inspection left us with
the impression that they are a dedicated, forthright group with a
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new look and perception being developed as to balanced water and
soil management. The turnaround which has occurred on the Flathead
in connection with soil and water management and other resource
management problems is one, which when compared to that found on
the Forest 5 years ago, is an indication of positive progress. The
recognition of past damage to soil and water through past poor
management practices appears to be an accepted fact with a
considerable number of Flathead people. The sophisticated planning
procedures, public involvement, complete change in organization
format, approach to Forest problems, modification of timber cutting
systems, modification of going timber sales, and establishment of
marginal areas for timber harvesting, all attest to the support for
some protection of soil and water in the high area basins which the
Flathead Forest now finds itself working when constructing roads
and harvesting timber crops. These are areas of delicate soil and
water complexes with high water-producing capacity.
Its Quality Management
There is accountability for responsibility on the Flathead Forest.
The first which has been observed in this Region since 1954. Flathead
people appear to be striving for quality results for managing the
soil and water resources. There is evidence of a people's trend on
the Flathead to move from a sawdust or single-use oriented management
to high quality management mix, including a proper mix of soil and
water with other resources. The mix of values by priorities appears
to be the beginning theme of unit land management. The Flathead
desires through its skilled people, its organization, and management
to apply the proper mixes of its skills in getting proper soil and
water management and overall quality management. Planning how to
emphasize soil and water values is in progress. The implementation of
these plans in project work to enhance these values needs wholehearted
and progressive Forest Supervisor and overall Forest support. The
strengthening of people's awareness of solid and water values and
the interrelationships with other resource values in exercising
control over all project work and especially in road construction and
logging operations is beginning to be recognized and in evidence on
current operations. Rapid progress is in evidence in some areas and
on some projects while on others there is a need to move forward.
The people of the Flathead have the obligation to maintain and
sustain a reasonable supply of commercial products from Flathead
National Forest acres and at the same time protect the basic soil
and water resources in their value relationship to other resources.
The continued development of a mutual Forest understanding of quality
management and a basic land ethic should assure improvement of
water quality and yield and leave the soil in the high water-producing
basins where it belongs.
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Modification of Existing Timber Sales
In 1971 the Forest Service decided that the environmental restrictions
of the National Environmental Policy Act had to be imposed on sales that
were already in existence. The first such revision was worked out on
the Bunker Creek sale on the South Fork of the Flathead River. This was a
test case. The Office of Comptroller of the U.S. Department of Agriculture
supported the change and a revision was worked out in a mutually
satisfactory way with the timber sale purchaser. On November 16, 1971
the Chief of the Division of Timber Management in the Missoula Regional
Office solicited immediate knowledge on other sales which needed
modification. Among others the Flathead Forest recommended modification
of the Puzzle Creek sale.
There is usually an elapsed time of several years from the time
timber layout starts until harvesting is complete. The Puzzle Creek sale
was laid out in 1967 to 1969 and the contract let in 1969. Harvest was
started, but was still far from complete when the environmental requirements
were imposed. In order to show how this was done the Puzzle Creek sale
was selected as a case study.
A Case Study - The Puzzle Creek Sale
The sale area and some of the natural hazards are described in
the timber sale contract: "The Puzzle Creek Drainage begins on the west
side of the mountain chain that forms the Continental Divide and terminates
at its confluence with Morrison Creek which flows into the middle fork
of the Flathead River. The drainage area covers approximately 2800 acreas.
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Elevation ranges from 5600 to almost 8000 feet. Puzzle Creek, which
is a third order drainage, is an upper tributary to Morrison Creek which
has a total drainage area of approximately 24 square miles.
"Mean annual precipitation in Puzzle Creek ranges from 45 to 65 inches
with more than half of the area in the 55 inch zone. Total estimated water
falling as precipitation in the drainage is 12,955 acre feet per year.
Approximately 55 percent of the mean annual precipitation is available for
runoff as either surface or ground water. This means that there are
approximately 7,000 acre feet available as runoff.
"The area is generally characterized by numerous first order drainages
that are deeply entrenched with 30 to 50 percent side slopes. There is
evidence of considerable ground water movement throughout the watershed.
Peat bogs can be found on some of the poorly drained areas. Soils in the
area consist of a loess cap of about 12 to 18 inches and has higher permeabil-
ity than does the residual clay soil below it. Consequently, water entering
the surface at a rapid rate cannot be absorbed by the clay soils. The
result is a free water movement between the loess-clay interface. Distur-
bance on a hillside such as this usually results in mass failures."
Shortly after the sale started the Forest Service became concerned,
halted the sale and initiated an investigation of the area. A review of what
happened is discussed in a document entitled, "Cancellation Proposal Puzzle
Creek Timber Sale Flathead National Forest."
Following this report from the Flathead National Forest a group of
regional specialists visited the site in June 1973 and made an in-depth
technical review of the problems.
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CANCELLATION PROPOSAL
PUZZLE CREEK TIMBER SALE
FLATHEAD NATIONAL FOREST
Synopsis
The Puzzle Creek Timber sale was contracted by the Flathead Forest to the
Stoltze Land and Lumber Company of Kali spell, Montana, in December of 1969.
The principal contract items were the sale of 12,410 MBM of sawlogs and
construction of 6.15 miles of main road.
Logging and road construction started in August of 1970, and continued
sporadically until July of 1971. At that time the District Ranger ,
administering the sale requested that operations be stopped to allow a
re-evaluation of adverse environmental impacts which were occurring.
A first evaluation of the area by resource specialists in July of 1971
indicated there were complex soil-water interrelationships in the sale
area needing much more consideration than given previously. This initiated
sale modification proposals by the Forest Service to the purchaser. All
proposals were rejected by the purchaser. During this period intensive
resource evaluations were made which indicated the need for review of all
of the possible resource impacts of the sale. A team made up of a Soils
Scientist, Hydrologist, Geologist, Fisheries Biologist, and a Silvicultur-
ist subsequently made the review of July of 1972.
The conclusions drawn from the investigation were that, as originally sold,
the sale would cause irreparable damage to soil and water resources. In
addition, regeneration of the cut-over areas would not be possible in
the time frame required by Forest Service policy. The fisheries resource
would be damaged, and accelerated wind-throw of spruce and subalpine
fir would be probable in the remaining stands with serious accompanying
spruce bark beetle buildup. These risks of substantial wind-throw and
a bark beetle epidemic in this area with so many critical resource problems,
make any decision to continue the sale, as advertised or modified, subject.
to a great deal of uncertainty and a high degree of risk. The very wet
sites, along with high incidence of past wind-throw evident in the area, are
solid indications of wind-throw problems if the stands are opened up.
The District Ranger, based on the conclusions of the specialists and his
professional judgment as tempered by service-wide, Regional, and Forest
Management Direction, has recommended cancellation of the sale. In his
judgment the consequences of continuing of the sale as designed or
re-designed are unacceptable, legally (Multiple Use Act), policy-wise
(re-generation requirements), and administratively (Management Direction by
the Regional Forester and Forest Supervisor).
When confronted with the Ranger's conclusion, the purchaser's authorized
representative stated that his Company would sue the Government for
damages if a unilateral attempt at cancellation was made.
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Backqround Data
Sale Statistics:
The sale area is 3,200 acres.
Total proposed cutting area is 835 acres.
(All clearcutting)
Total Volume sold 12^.4 MMBM
Road Construction 6.15 miles of specified roads with a total
cost allowance of $68,315.
Contract Items Completed:
One cutting unit has been completed and another is substantially
completed.
Total volume removed from the cutting units and road clearing is
2,655.28 MBM.
Road construction consists of approximately 5.7 miles complete
or substantially complete. Other specified roads have been
pioneered and spur roads have been constructed.
Volume Available tp_ the Purchaser;
Unit 2 containing 880 M is roaded and available to be logged.
In our opinion it is environmentally sound to do so.
Modification Proposals tp_ Purchaser:
1. September 23, 1971. The purchaser was approached with the
following proposal:
Reduce contract timber volume from 12.4 MM to 7.3 MM.
Reduce total acreage cutover from 835 to 593 acres.
Reduce clearcut acres from 835 to 295.
Reduce road mileage 0.3 miles and reduce standard for
for 0.25 mi. of road to spur standard.
Adjust stumpage rates accordingly.
The purchaser rejected the proposal stating that the original
contract volume must be met as a prerequisite to bilateral
modification.
2. June 5, 1972. (After intensive resource investigations)
The District Ranger proposed a revised volume to be removed
by conventional method (tractor and jammer) of 6,380 MM. An
additional 880 MBM could be removed by cable yarder with a
1,000 ft. skid capability.
The purchaser rejected the proposal for the same reason as
he rejected Proposal #1.
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3. Additional attempts to reach agreement on bilateral
modification were made in meetings with the company on November
7 & 17, 1972. At these meetings the purchaser agreed to accept
(in principle) a modification proposal providing agreement
could be reached concerning volume, logging costs and the actual
unit boundaries marked on the ground.
In addition, the purchaser explored the feasibility of
helicopter logging. He felt that if stumpage prices were
reduced to minimum and the sale was logged as originally sold,
it would be feasible to remove about half the remaining volume
by helicopter.
4. Subsequent re-evaluation of the specialists report, F.S. policies,
and the preparation of a draft Environmental Analysis Report
resulted in the Ranger recommending unilateral cancellation.
5. On March 27, 1973, the purchaser was advised that on the basis of
the Environmental Analysis Report completed in January 1973, the
District Ranger would recommend unilateral cancellation.
6. On May 18, 1973, a meeting was held with the purchaser to explore
the possibility of logging areas under the present contract, that
could be logged without undue environmental impact. This would
include Unit #2 and some risk material along the main road.
Approximately 1 to 1.5 MMBM could be removed in this manner. The
purchaser was reluctant to make a commitment until after checking
with his legal representatives in case this would jeopardize
future court action. He stated he would have a position in about
two weeks and would advise us.
He also indicated that the company was committed to other logging
operations this season. As a result, it would be questionable
whether they would have a logger free to work on the Puzzle Creek
Sale.
Summary
The intensive resource evaluations conducted by a multidiscipline team
examined the environmental consequences of fulfillment of the contract.
The Ranger, using the specialist information, evaluated alternatives for
completing the contract. This included logging as originally contracted..,
a partial cut throughout the sale area, a long-term sale cutting only high
risk trees, and modifying logging systems to mitigate the newly recognized
environmental impacts both with and without the use of helicopters. He
also examined the alternative of unilaterally cancelling the contract.
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Analysis to date reduces the acceptable alternatives to one:
1. Unilaterally cancel the contract. The basis would be the
service-wide policy on timber sales adopted as outlined in
"National Forests in a Quality Environment Action Plan".
Problem #4, page 11 of this publication states; "To recognize
those areas where the final harvest cut must be discontinued
or deferred because there is not assurance that the area can
be suitably restocked within five years after logging". Any
partial cutting on the wet spruce sites involve unacceptable
risks of heavy wind-throw and associated insect problems.
This policy also includes direction to Forest Supervisors to identify
problem areas on the ground and incorporate in timber management and
multiple-use plans. It also gives direction to modify, where appropriate
existing timber sales contracts containing such areas to prevent harvest
cuts in those stands where satisfactory regeneration cannot be expected
within five years.
In viewing this direction and the other Puzzle Creek Sale resource
protection problems, the only other course of action is "timber mining".
This would enable us to fulfill the contract and protect most values.
Unilateral cancellation would adversely affect the profit the purchaser
has expected from the contract. The apparent possible profit loss is
about $202,800. This figure was obtained by calculating the profit that
could be expected by harvesting and processing the remainder of the
original contract timber volume. The actual loss to the purchaser, if any,
is not known. Royce Satterlee, purchaser's representative, stated that
losses to the company would be in excess of $300,000.00.
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SPECIALIST REVIEW
PUZZLE CREEK TIMBER SALE
Introduction
In late June 1973, E. M. Richlen, H. J. McKirdy, F. W. Pond, and J. E.
Eggleston were requested to review the "Environmental Analysis Report, A
Proposal - Cancel Puzzle Creek Timber Sale Contract" and to discuss this
proposal with Timber Management. The memorandum concerning this meeting
is under file designation "1930 - Environmental Analysis" dated July 2,
1973.
On August 3, 1973, Rich!en, McKirdy, and Eggleston were requested to review
the Puzzle Creek Sale Area on August 6-7 to examine the situation on the
ground, and to evaluate another modification of cutting units and road
locations as proposed by Radtke. We briefly discussed our findings with
Dave Minister in his office on August 7. This report is the result of the
August 6-7 field trip. Forest personnel involved with this review were
Delk, Martinson, Casey, Ostheller, and Hook.
Discussion
During the review of the Puzzle Creek Timber Sale Area, we looked at several
"different areas" of land. These areas are discussed, more or less,
individually.
The spur road from Road 2848 into cutting unit No. 2 exhibits many
characteristics common to Land Unit A. Slumps have occurred along the banks
of Puzzle Creek under natural conditions, as well as along the road. Any
removal of vegetation from or above this land unit will adversely affect an
already precarious situation. The soils of this unit are almost completely
saturated during the entire snow-free period and are supersaturated during
the snowmelt period. Any vegetation removal will increase the amount of
water by an estimated 15-20 unit area inches. This increase will aggravate
both the slumps on the road and on the creek bank. This effect will take
place just by removal of vegetation through timber harvesting - by any
means - and is independent of those effects that would be caused by road
construction.
We also walked over the upper spur road in timber sale Unit 2 and portions
of the two lower spur roads. We were under the impression that only one
spur road was to be built in timber sale Unit 2 when in actuality four
spur roads were built (the uppermost was a very short abandoned spur road).
The two lower spur roads were less than 150 yards apart and portions were in
very clayey soils. Runoff from these soils will contribute high amounts of
clays which will greatly increase turbidity in adjacent stream. Logging
equipment, depending on soil moisture, will either compact the soil or
create a muddy quagmire. In either case a lowering of productivity can be
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expected along with high stream turbidity. The bulldozer operator
constructing the roads was somewhat embarrassed by closeness of the lower
two roads and said he just built roads where they were flagged. The
logging team working on the upper spur road indicated the area between the
two major snowslides (total clear-cut area) was to be tractor logged. We
were also under the impression (environmental statement) that this logging
unit was to be cable skidded.
The review team walked the proposed new road location through cutting
Unit 7 and to the termination of the road in Unit 8. In Unit 7 the road
crossed several high mass failure areas and a logging landing appeared to
be located on a high mass failure area. Briefly discussed was the
possibility of making a log road (corduroying) across unstable soil areas.
This type of road construction can cause serious compaction in the
underlying soil materials (see discussion on slope hydrology.)
A good stream crossing had been located on Puzzle Creek between Timber Sale
Units 7 and 8. The road location beyond the stream crossing to Unit 8
contained both stable and highly unstable soils (high mass failure areas).
The proposed road in Unit 8 was located in dominantly unstable soils (very
high mass failure). Besides having a very high mass failure potential, the
proposed road will have a very adverse effect on the slope hydrology.
"SLOPE HYDROLOGY" is not too well understood, often misinterpreted, or
overlooked, and ft is difficult to discuss the hazards and impacts in a
few brief remarks. Some of the more dominant factors involved in slope
hydrology evaluations are climatic conditons, land surface configuration,
hydrologic events and the controlling soil characteristics. Depending on
the specific situation, any of the above dependents can be a dominant
factor. For example, soil infiltration, percolation, and transmission
rates, among other soil characteristics, affect subsurface moisture
movements. Although a number and variety of management impacts can be
developed, the following discussion will be confined to those involving
roads. The effects of slope hydrology can briefly be described in several
ways. One of the effects occurs when the road is constructed through the
land surface as is the present road (2848). The road cut will intercept a
portion of the subsurface flow, forcing it to the surface where it must be
transported in ditches or culverts. This will accelerate the flows from the
area and will increase the volume of water during the peak flow period.
This surface water also carries increased suspended sediments to the
streams. Part of the increased sediment will come from the tributary
stream channel presently in equilibrium but due to increased water
directly related to the road, start to degrade as a result of the increased
water. Besides producing higher peak flows, lower dry season flows will
occur.
Another similar slope hydrology effect results from turnpike road
construction wherein the compaction and weight of the road materials
compacts the underlying soil. This restricts subsurface flows, causing
hydrostatic pressure to build, producing "blowouts", "slumps", or soft spots
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(boils) in the road. Water problems are similar to those described in
previous paragraphs.
Still another slope hydrology effect of more subtle consequences relates
to the vegetation - its productivity and habitat type. In areas where
the slope hydrology is adversely affected, the soils above the road will
increase in wetness (supersaturation) and drier areas below the road due
to the sharp decrease in subsurface moisture movement. The long-term
effect would be a potential change in habitat types above the road and
below the road.
The effects of slope hydrology is best exemplified in main road 2848
through Land Unit A. The soils in Land Unit A are dominantly clay loams
which compact easily under optimum soil/moisture conditions. This
compaction can also cause the subsurface water to surface due to the
reduction in permeability and transmissibility. This situation was
exemplified by one culvert in road 2848 where nearly twice as much water
was coming out of and around the lower end of the culvert than is flowing
into the culvert from the ditch (upper end of culvert).
The addition of water resulting from road interception and transported
through culverts and stream channels or vegetative manipulation resulting
in higher peak flow volumes (example - spur road to Unit 2 and vegetative
removal above the spur road) will accelerate the aggravation of the streams
of Puzzle Creek.
The results of roads built higher up the slopes in Land Unit D (cutting
Units 5,6,or 7), would be similar to those mentioned, except that the
hydrostatic pressures would be greater on the steeper slopes, and the
resistance to blowouts would be less.
A water yield increase from cutting Unit 8 would cause very undesirable
results in two different locations. Tree removal here will also increase
the available water by 15-20 inches as noted earlier. A portion of Unit 8
(that portion where the proposed road was located) lies on slopes of about
40-50 percent. At the base of these steep slopes, where they meet the
Puzzle Creek terrace, are located many bogs, seeps, peat deposits, and
springs. Any increased yield on the slopes above these wet areas will
increase the hydrostatic pressure on them, and make them more susceptible
to "blowouts" or slumping. If slumps do occur, they would be right on the
banks of Puzzle Creek. A significant increase in the amount of sediment
introduced into Puzzle Creek would occur immediately, and would continue
to occur for a long period of time.
Some of the water from this proposed cutting unit will follow the dip
slope of the underlying limestone beds and emerge in the vicinity of the
large slump located below the lower end of the Morrison Creek Road. This
slump does show some evidence of movement by water from within the slump
itself, as well as continual sloughing from undercutting by Morrison Creek.
Since deep percolation and lateral movement of water in this situation is a
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slow process, the Impact of increased yields on cutting Unit 8 may not be
manifest for three to five years.
We also walked up into Land Units D and E in the vicinity of cutting Units
5 and 6. This included the proposed road to Unit 5; the deeply incised
"V" channels, and the alluvial fans at the terminal end of these "V"
channels. The land area above the "V" streams acts like a "Tin Roof"
wherein most of the precipitation runs off through the "V" notched stream
channels to the stream braided alluvial fan. In the natural situation,
water from Land Units C and E normally deposits its sediment on the
alluvial fans at the mouth of Unit E. These fans are natural sediment
deposit areas, built up over the years. Surface waterflow over the fans
is through several defined channels that are continually shifting as more
sediment is deposited. If a road is constructed across Unit E (the
deep-cut stream channels) a significant increase in sediment production
will occur. If a road is constructed across the alluvial fans, a
significant increase in sediment delivery to the stream (Puzzle Creek)
will occur because the water will tend to be collected and channelized.
The greater flows will carry more sediment directly to the stream. The
higher up on the fans the road occurs, the more sediment will be carried
directly to the stream. Flow rates will also be speeded up, as discussed
earlier. (See discussion on slope hydrology.) A direct increase in
either the sediment load or the flow rates of Puzzle Creek will be
extremely deleterious because the creek is already at capacity for both
aspects. An increase in either will cause additional damage to the
fisheries and to the streambanks and channel.
If a road is constructed across these fans, the onsite water management
objective should be to keen the water dispersed rather than collecting and
channelizing it in culverts and ditches.
Puzzle Creek and a short portion of Morrison Creek channels were walked to
determine condition and stability. That portion of Puzzle Creek above the
spur road to cutting Unit 2 is in relatively good condition compared
to the rest of the channels. The lower portion of Puzzle Creek is full of
debris from the 1964 flood and from recent avalanches. Fresh sediment
deposits are found behind many of the debris jams, and currently active
bank cutting was noticed in several places. The portion of Morrison Creek
from the bridge on Road 2848 to the junction with Puzzle Creek is also in
relatively good condition.
The lower portion of Puzzle Creek could be enhanced by removal of certain
debris. This should not be done without due fisheries and hydraulic
considerations, nor should it be considered a tradeoff for logging which
could affect the stream in other locations.
The stability of the stream channels and banks presents a different
picture. The entire bank system of Puzzle Creek is laced with mass failure
areas. Most frequently, the slumps occur on the east bank of the creek.
These slumps are associated with the subsurface flow as it emerges at or
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near the creek level. The slumps are aggravated by the continual under-
cutting of them. Any additional water entering the slump area, either
surface or subsurface, will keep them active. Likewise, an increase in
the peak flows would cause additional undercutting of the slumps. The
slumps have contributed much fine material to the streams system, most of
which have settled on the stream bottom. These fines, if much more
extensive, could result in the depletion of salmonid reproduction in this
stream.
Morrison Creek, above its junction with Puzzle Creek is, again, relatively
stable. Some sloughs do occur, but they are due primarily to bank
undercutting, rather than by slumping. One critical slump was noted on
the north bank of Morrison Creek about 200 yards below its junction with
Puzzle Creek. A slump has developed on this bank, immediately adjacent to
the stream, which also lies directly below cutting Unit 3 which was
clearcut in 1970-71. The increased yields as a result of this cutting may
be directly responsible for this slump.
It was also noted that many small tributary streams are located throughout
these reaches of Puzzle and Morrison Creeks. Protection of these small
streams must also be considered in order to protect the overall spawning
of the Dolly Varden.
Conclusions and Recommendations
Our review has led us to the following conclusions and recommendations.
1. The scientific soils, hydrology, and fishery data in the
environmental statement has been carefully developed.
2. The soil-hydrology map is of sufficient detail to support their
conclusions.
3. Any team or individual planning on review or even visiting the
area should read and study the scientific data found in the
environmental analysis report before going to the area.
4. Although reference is made to slope hydrology throughout the
report, it needs to be more fully developed and strongly emphasized
as it is critical to the management of this watershed.
5. We recommend the present road 2848 not be extended through timber
sale Units 7 and 8. Both areas contain highly unstable soils
and irreparable damage to Puzzle Creek and Morrison Creek in the
form of increased sedimentation, erosion of streambanks, etc.
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6. Me recommend timber sale Unit 8 not be cut. The increased
runoff will contribute sediment and cause additional streambank
erosion. Deep percolation of water to the underlying limestone
bedrock may aggravate the slumping problem in Morrison Creek.
We also believe other silvicultural problems will develop.
Unstable land areas near the toe of sale Unit 8 has high potential
for slumping, adding high amounts of sediment to Puzzle Creek.
7. We recommend a spur road not be built to timber sale areas 5 and 6.
A spur road across the slope will create severe slope hydrology
problems affecting the areas stability, water yield and vegetative
composition.
8. If feasible from a silvicultural standpoint, we recommend timber
sale Unit 5 be helicopter logged, removing the older overstory.
A team consisting of a silviculturist, fishery biologist,
hydrologist, and soil scientist should evaluate timber harvest
practices in relation to sediment yield, increased water yield,
slope hydrology impacts, soil productivity impacts and the
silvicultural impacts.
9. We recommend the spur road across the avalanche paths to, and in,
timber sale Unit 2 be examined and management practices such as
erosion control he instituted immediately after harvest and before
winter sets in.
The Puzzle Creek modification proposal is still under consideration. The
final decision wilf come soon. It is of particular interest because it
shows the steps in accomplishing the change. This was a difficult
undertaking, but it helped develop the process of review by specialists of
the conditions which could contribute to environmental degradation. In the
process the specialists and the staff of the Flathead National Forest
gained a considerable amount of experience. From this they have developed
their present system where the review is made in advance of the sale and
the sale is designed to meet environmental requirements from the beginning.
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IV. PRESENT PROCEDURES AND ACTIVITIES ON THE
FLATHEAD N.F. A DESCRIPTION AND ANALYSIS
A_._ Long Range Planning
Since 1971, there has been a great deal of change in the way the
Flathead National Forest goes about its business of managing resources.
There has been a change in the language from Washington and the Regional
Office. This was a rhetorical change, full of the spirit of NEPA that
0
focused so much attention on environmental quality. There has been a
change in the organization of the Supervisor's staff that has induced
a spirit of unity and mutual dependence among the units and the personnel
on the Flathead; this was a structural change. There has been a procedural
change too, occasioned by the rhetorical and structural changes that
have occurred. The procedural change is a renewed emphasis on resource
planning as the means for ensuring environmental quality.
The Flathead personnel now see resource planning as the most important
thing they do. There is a shared conviction that resource management
must be a consequence of sound resource planning, and that the planning
must come first. The Forest is spending a considerable amount of its
time and energy in resource planning, and is defending that activity
jealously, against a number of other claims on its time and resources.
Two elements of the Flathead organization—one tangible, the other
not—combine to make the resource planning and management activities
work well and smoothly.
The intangible element is the disappearance of the autonomy of the
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Ranger District. There are still separate ranger stations, and rangers,
and districts, for that matter, but the units do not see themselves as
distinct entities. Rather, the entire Flathead Forest is viewed as the
operating unit. The Tally Lake ranger is concerned about the Swan Lake
District as well as his own. The Rangers, the Supervisor, and the
Supervisor's staff constitute a management team, and they all view them-
selves as team members planning for and managing the Flathead National
Forest, not budget-antagonists at the District level. The Districts are
subdivisions of spatial convenience, not independent management units. A
more concrete expression of this unity is the timber management plan now in
force on the Flathead. When the old plan was revised in 1969, the separate
working circle boundaries, which coincided with ranger district boundaries,
were eliminated, and the current plan relates instead to the Flathead
Working Circle—the entire forest.
The tangible element of Flathead organization is the elimination
of functionalized specialties on the supervisor's staff. No longer
is there a separate staff position for timber, for wildlife, for watershed
management, etc. Instead the organization is subdivided into "operations"
and "planning" and this format seems to be extremely effective in
fostering the sense of management and planning unity for the entire
forest. It spawned the "management team" image, and that has blurred the
independent identity of the ranger districts; the result is a laudable
singularity of purpose and spirit on the Flathead.
The Flathead is proud of its planning format and its planning process,
and has reason to be, though some comments are offered on what are thought
to be flaws in both.
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The multiple use plan is seen pre-eminently as the basic land
management document, fundamental to all others, and there has been a great
deal of deliberation and resources invested in it. The Forest Service
has been in the planning business for a long time, but since the
passage of the Multiple Use Sustained Yield Act in 1960, multiple use
planning has assumed dominance among all planning activities. Since
NEPA in 1970, multiple use planning and management have been the official
vehicles for the Forest Service's concerns and responsibilities in
environmental quality. The agency made a deliberate decision to incorporate
environmental quality concerns, and environmental reporting procedures
(i.e., impact statements, etc.), directly into its multiple use planning
processes, and to utilize its multiple use planning resources and staff to
accommodate the new responsibilities.
The current multiple use plan for the Forest is called "Flathead National
Forest Basic Land Management Plan, 1." It was recommended for approval by
Forest Supervisor on December 23, 1971 and approved by the Regional
Forester on November 1, 1972. It is important to keep in mind that the
planning on the Flathead is not intended to produce static, once-and-for-
all answers, but rather to exhibit a process or an approach to land
management. The planners see the world this \^ay and it is more accurate
to describe the Flathead as a planning forest than as a planned one.
This is a philosophy of dynamic planning, and there appeared to be
almost complete consensus about it among the Flathead people. They also
agreed on two other major patterns of thought and behavior.
. One was the necessity of public involvement in the planning process.
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The other was a management rationale that can be described as "localized
decisions based on land productivity."
Two elements in the policy-streams from the Washington and Regional
offices made a great deal of sense to the Flathead people. One was the
repeated emphasis on decentralizing decisions: more and more decisions
were to be made "on the ground," and the basis for those decisions was
to be "quality management." This meant, to the Flathead people, that
management decisions would be constrained by land productivity. Since no
one knew better, or could better learn, the limits of land productivity
than the local managers, "localized decisions based on land productivity"
appealed very strongly as a management rationale.
Some of the procedures in the current Flathead multiple use plan
date to the early ones established soon after the Multiple Use Act
was enacted—the zoning features, in particular--and others are much more
contemporary--the public involvement features.
In July of 1971 the forest personnel held eight "listening sessions"
at communities throughout the Flathead Valley, deliberately seeking public
comment and expressions of value that could be incorporated into the
multiple use planning process. Thus the Flathead looked outward early
in its planning activities. It kept meticulous records of the listening
sessions, and ultimately published a report entitled, Flathead National
Forest Listening Sessions, Northern Region, July, 1971.
In the introduction to that report, the Flathead outlined the rationale
of its planning approach. The multiple use plan, the report said, would be
the one on which,
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...all other Forest plans, uses, and activities are based.
This basic document involves essentially three component parts:
0 (1) an inventory of the land to produce resources and uses; (2)
an inventory of existing resources and uses; and (3) recognition
of peoples' thoughts and ideas.
The report also made clear the intent of the public meetings: "These
'Listening Sessions' are a part of component number three."
Paraphrasing the intentions listed above, three planning elements can
be identified as follows:
1. an inventory of productivity
2. an inventory of existing outputs (a reflection of
current demands)
3. suggestions for marginal adjustment—and expressions
of non-market demand
Element No. 1, the inventory of productivity is the most significant
and crucial. With that information the Flathead Forest can take the policy
initiative, making the independent and professional decisions on management
and production that will meet the requirements of environmental integrity
promised by the policy streams from the Washington and Regional Offices.
Without productivity information, management decisions can only be
random—or issued off-site from distant headquarters offices. Scientific,
biological productivity data are the only defensible alternative
to managing the Flathead by political dictate—to growing timber by fiat,
for example. The acquisition of productivity data will be the ultimate
test of the validity of the multiple use planning process.
The criterion that will be applied to the evaluation of the resource
planning of the Flathead is: How well does the planning effort identify
and, ultimately, quantify, the productivity of lands administered by the
Flathead National Forest?
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After the eight listening sessions had been conducted, the staff
assembled the transcripts of the meeting, read through them, and prepared
the sizeable document summarizing them. In a section entitled "General
Evaluation" the following is found:
The most common criticism was against the practice of
clearcutting. Even those who spoke in support of the
practice felt it should be used with much more discretion
and concern for other values. Most people said they
wanted better multiple use balance on the Forest. Many
felt the Forest Service is preoccupied with timber
management.
...Another point expressed by a large number of
participants was that we have too many roads.
Thus, the concern for environmental integrity and quality management in the
policy streams from Washington was echoed at the local level, and the
Flathead people took cognizance of it as they proceeded with their multiple
use planning.
On the 8th of October, 1971, the "Flathead Forest Multiple Use
Plan Part I" was submitted to the Regional Office for approval. It contained
a 23 page appendix that compared the specifics of the plan with the policy
streams contained in the Washington office document Framework for the
Future document and the Regional directive, Management Direction for
Northern Region. The congruence was total and complete, but this version
of the Flathead plan was not approved. It was resubmitted December 21,
1971, and approved by.the Regional Forester November 1, 1972; the major
difference in the two versions was the deletion in the final version
of the appendix material comparing the plan, the Framework paper, and
the Management Direction. The document was renamed Basic Land Management
Plan, 1, and the "1" referred to the first of a two-phase planning effort.
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The first phase was the general, overall plan for the management of the
Flathead; and the second would consist of detailed management prescriptions
for sub-units of the Forest.
The philosophy of "dynamic planning," public participation, and
localized decisions based on productivity, was made explicit in the
Preface:
Both Part I and Part II of the Plan integrate three basic
components: (1) The ability of the land to produce on a
long-term basis; (2) Inventory of existing resources and
uses; and (3) Recognition of peoples needs and demands.
This is a recapitulation of the planning elements proposed in the
"Listening Sessions" paper: productivity, existing outputs, and
provisions for changes. However, the ability of the land to produce is
not^ specified here, except in very broad terms. For example:
The (general forest) Zone offers the best opportunity to
raise timber; it provides almost all winter range for deer
and elk available on the Forest; it provides year-round
habitat for all but the subalpine animals found in this
region; it provides almost all of the domestic stock grazing
opportunities found in the Forest; it provides the largest
and most influential acreage for water runoff and storage;
it provides almost all spawning streams; it provides many
streams for domestic water supplies...special uses...insects,
disease, wildfire threats...recreation opportunities.
This example passes, in Part I, as an inventory of "the ability of
the land to produce on a long-term basis," and is not sufficient as a
data-base on which to make management decisions. Part I is designed to
do something additional:
Part I is an analysis of the Flathead's situation—its lands
to its users, the local communities, and region. The
Forest's land zoning descriptions, situation statements, and
assumptions about the future have resulted in Forest
management direction statements called Coordinating
Requirements. These requirements set guidelines for resolving
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resource conflicts, giving direction, helping 1n decisions, or
setting priorities.
It is apparent from this statement that Part I has very little to do with
the sequence of productivity--needs--changes, or with independent
management decisions on output quantities. Part I will not and cannot tell
the Flathead people what can be done, in a biological sense of land
productivity.
Part I is simply the latest in a series of planning documents
that stretch back thirteen years to the Multiple Use Act of 1.960; the
Forest Service at that time, saw multiple use primarily in terms of land
use zoning—on the bases of physiographic features—and in terms of
ameliorating land use conflicts. There was no attempt to make a
scientific inventory of the biological productivity of forested properties--
to indicate what could be produced, nor any attempt to assess the market
and non-market demands to indicate what should be produced.
With respect to many earlier multiple use plans, there are only
marginal changes in this one. It describes the features of the various
zones, the water influence zone, and the special zones. Only in the
widest definition of the term can these descriptions be considered
statements of "the ability of the land to produce on a long-term basis."
That much is unchanged from earlier plans.
The next section is both new and intelligent: it is entitled the
"Forest Situation," and it is candidly written. The section describes the
status, in turn, of "agricultural crops and forage," "game and sport fish,"
"recreation," "water," "energy fuel minerals," "non-fuel minerals,"
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"wilderness," and "timber." The situations cannot be categorized as
easily as the resources can—each was analyzed with discrimination and
care--but the most significant information, relative to pollution
abatement and environmental quality is found under the discussion of
water:
The importance of water on the Flathead cannot be overstressed
yet management practices and development have not always
protected the water resource. Resource plans of al-1 types refer
to "good watershed management," but lacking was a clear
definition as to what was meant by this. Definite watershed
management standards, guidance, or water resource objectives
were not clearly identified.
District multiple use plans developed in the '60's clearly
stated that water quality and quantity should be maintained.
The many uses of water were recognized, and water was thought
to be important enough to receive special attention and
management. However, water was subordinated by other resource
activities and uses, and was considered a separate resource
entity rather than part of the total environment. Water was
considered on a project-by-project basis rather than an
environmental or area-planning basis. Consequently, until
recently little thought was given to long-range effects of
management of the water resource both on-site and downstream.
Timber Management activities have been first priority on
much of the Flathead for the last 20 to 30 years. Most of the
timber harvesting was accomplished through clear-cutting.
Clear-cutting and the related road systems have had a
tremendous impact on water quality, quantity, and timing of
runoff. On-site damage was considered tolerable in many cases,
but accumulative effects which caused downstream damage in
several cases were not recognized.
In summary...Plans have not recognized water as related to
climate, topography, vegetation, and soils. As a result, the
importance of water as part of the environment has been
misunderstood. Downstream damage, as well as on-site damage,
was accepted as the price to be paid for progress.
Admissions of that sort call for a degree of administrative courage.
The Flathead plan-writers were admitting miscalculations and misunder-
standings as a prelude to substantive improvement. This was a candid and
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honest appraisal of problems to be solved, of practices to be improved,
of planning and management activities to be changed. The Flathead is
taking at face value the admonitions of the policy streams to act with
authority and accountability to do a better job of managing the
physical environment.
The next section of the Basic Land Management Plan is entitled "Basic
Assumptions" and under four categories one general "assumption" is made.
The categories are "Land," "Resources and Uses," "Management," and "People,"
and the common assumption is "more." This is a typical statement: "The
public will demand increased utilization of resources from our limited
resource base." All trends are seen as sloping sharply upward—and no
new trends or impacts are identified. The Forest was attempting to a
isolate and identify the assumptions it was making in writing its multiple
use plan. If the zoning descriptions were rough and ready statements of
productivity, the "basic assumptions" could be thought of as rough and
ready statements of demands being made of and on the Forest.
The next section of the Plan is viewed by the Flathead officials as its
core: this section contains the "Flathead Forest Coordinating Requirements,"
some 86 statements of intentions, constraints on resource uses, and
management decisions. The coordinating requirements are a vestige of
earlier multiple use planning philosophy, in which zoning and conflict-
resolution were the objectives. In those earlier plans, they were the
mechanism of use-harmonizing within each of the zones. Indeed, four of
the five categories of the present plan's coordinating requirements are
zone categories. Coordinating requirements are listed for the high area
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zone, the general forest zone, the special zones, and jointly for the water
and travel influence zones. The other category is listed as "General
(All Zones)," and it contains 53 of the total of 86 coordinating requirements,
Multiple use planning must go far beyond land zoning and conflict
resolution, and indeed the Flathead Basic Land Management Plan, in its
section on coordinating requirements, attempts to do so. Only about
one-third of the requirements are keyed directly to the land use zones. The
other two-thirds are statements wholly in the genre of the Framework for the
Future or Management Direction for Northern Region. Here are some
examples:
I,D,1: Get involved and participate in outside activities.
I,A,6: Transportation planning will be done in conjunction
with basic land management planning.
I,E,9: Base access needs on specific land management
purposes.
I,K,1: Formulate plans and programs based on interrelationships
among our various objectives and policies,
multi-objectives. Express interrelationships, mix or
balance among the multi-objectives; production of goods
and services, local and regional economic development,
and quality of environment whenever possible.
The generic resemblance of these requirements to those in the Framework
and Management Direction papers is not coincidental. In the earlier
version of the Plan a 23 page appendix compared the three documents
statement for statement, and the compatability was conspicuous. It might
be said that the Coordinating Requirements are the final link in the
policy chain: from Washington to the Flathead Forest the agency promises
to do right things and to do things right.
The Flathead officials were both proud of and committed to the
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coordinating requirements they had written. They meant the "CR's" to
be strong, binding, and unequivocal, and a number of inspection reports
were reviewed 1n which managers were severely criticized for violating
them. And a number of the "CR's" do appear to have substance:
111,3: Until we know more about the effects of roads and
timber harvest on high elevation-low timber producing
areas, allowable cut adjustments will be made as these
areas are identified.
111,11: Avoid or modify harvesting in drainages involving
unacceptable watershed degradation, either existing
or anticipated, based on hydrologic analysis.
111,12: Revised Timber Management Plan on basis of known
hydrologic and wildlife limitations, as well as changes
in the land base and marginal areas.
I,F,1: Revised allowable cut timber volume excluding
contributions from wilderness candidate study areas.
Determine future timber harvest in other roadless
areas through land management planning.
And at least two of the "CR's" seem to have been written in direct response
to the general evaluation of the "Listening Sessions." The complaints
therein centered on clearcutting and road frequency, and the CR's deal with
those complaints as follows:
111,1: Do not clear-cut where alternative cutting methods are
feasible unless clear-cutting must be done to achieve
management objectives set forth in the Multiple-Use
Plan.
I,E,11: Re-evaluate present transportation systems with the
objective of closing roads that are not continuously
needed for the purpose for which they were constructed.
(This, presumably, is a result of the expressed
complaint about road frequency.)
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The "CR's," viewed comprehensively, seem to be a compendium of
caveats, vague constraints, aspirations to virtue, and evidence that the
Flathead planners were familiar with the Framework and Management
Direction pamphlets. There is not much to be found in them that is
extraordinary, exciting, or even very unusual: they might apply with
equal facility to any National Forest. If one reads carefully, however,
one senses a certain continuity. The CR's do contain the conviction that
independent production decisions would be made locally, and they would be
made on the basis of land productivity.
The "CR's" do not lead to the kind of productivity information
the managers will ultimately need. Part I of the Basic Land Management
Plan was not designed to do that. The "area plans" that would comprise
Part II are to do it, and the final section of Part I scheduled that phase
of the planning activity.
The Planning Unit boundaries were delineated by a forest multiple-use
task force consisting of the forest planning officer and representatives
and/or rangers from the various districts. Once the boundaries were
established, a "planning level" was determined for each unit; Level I
planning would involve much new inventory information, Level III would rely
on existing data, and Level II was intermediate. Finally, the planning
unit priorities were agreed upon, and four units were ranked in order for
Level I planning: the Spotted Bear River unit; the Lake Five unit; the
Tally Lake unit; and the Stoner Creek unit.
Clearly, an enormous responsibility was attached to unit planning;
through years of controversy and conflict about forest management
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practices; through hours and days of Congressional hearings; through
comprehensive studies both within and without the Forest Service; through
policy studies and declarations constituting hundreds of pages and
thousands of man hours, the Forest Service had come to recognize a
problem and to formulate its solution: management decisions would be made
independently at the Forest and District level, on the basis of land
productivity, and in unit planning that information would be secured.
The highest priority plan for the Forest—the Spotted Bear River Plan-
was released on February 27, 1974. It promised to "integrate three basic
components: (1) The ability of the land to produce on a long-term basis:
(2) Inventory of existing resources and uses; and (3) Recognition of
people's needs and demands." The plan's success in meeting this central
objective is not obvious, particularly as it doesn't even attempt to
address the second and third "basic components."
The plan bears no direct boundary relationships to the zones in Part I
nor to the "CR's". There is no market-analysis contained in it, nor analyses
of non-market demands made of the unit. And there is no explicit concern
for air and water pollution.
Planning is time consuming and demands up to 50 percent or more of
the time of most of the specialists at the Forest level. The effectiveness
of the planning process can be questioned, but, based on the comments
of the specialists, one can assume that they are qualitatively better
than they were several years ago in terms of knowing how to plan and
in attempting to reduce degradation of non-timber resources. While the
specialists often expressed the need for more information, particularly
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specific quantitative information, they did have confidence that the
planning process would provide guidelines for the Districts that would
improve the quality of management on the Forest. As will be noted in the
Lower Sullivan Creek case study, (Page 104) if a District is already
committed to a given procedure on a project area, the specialists seem
inclined to work with the constraints of that previous commitment.
Because of the limited data available it might be useful to accelerate
data gathering even though it might mean temporarily slowing the planning
process at the Forest level. Much needed data probably can be obtained with
a concentrated effort so that planning could become more meaningful.
Effective planning is dependent upon trained decision-making experts as a
part of the planning team. Also, it is essential in the process itself
that the team include a skillful integrator to effectively determine and
consider the environmental information that must be gathered on any
intended management unit.
For both air and water quality, it is important that planning be
by hydrologic units or drainages as stated in the clearcutting memorandum
of March 23, 1973 from the Regional Forester to Forest Supervisors.
Planning by drainage areas with adequate information on the effects of any
manipulation on small basins, should prevent concomitant management
practices on several units resulting in changes which exceed (1) threshold
levels of stability for the major forest area or (2) environmental quality
standards previously established. Prediction of changes within larger
basins would be possible by using lower order (e.g., second order)
watersheds as detailed planning units. Watershed planning should allow for
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management units encompassing several or parts of several of these small
watersheds. Despite some problems in adopting the hierarchical watershed
approach to multiple use planning, their usefullness both in predicting
and determining changes in water and air quality seems clear and has been
advocated at the regional levels (Marks, 1971).
In summary, the efficacy of the planning effort itself must be
questioned. Although identifying potentially hazardous areas and
stratifying land uses in the forest areas in some detail is significant,
the degree of time investment in this particular process, given the results
presently obtained, may be too great. It seems that the planning process
is running ahead of the data.
Once again the error here is one of execution, not concept. The
planning goal of the Flathead is above reproach, namely: to
determine, through resource planning, both what the land can produce
and what the social needs and wants are, expressed in both market and
non-market terms, and then make local independent production and management
decisions accordingly.
The Flathead officials appear committed to the right things—planned
1 Problems which must be addressed before such a system can be developed
include (1) the non-existence of a widely accepted description of
a first order watershed (R. J. Shreve, personal communication); (2)
the existence of adventitious watersheds and portions of higher-ordered
drainages which are not accounted for by included lowered-ordered
basins; (3) the need to use different scales when considering different
resources; e.g., wildlife versus water (J. L. Lyon, personal communi-
cation); and f4) the possibility of over-emphasizing the biophysical
aspects of the resources to the detriment of social and economic
values with over-enthusiastic adoption of such a procedure (E. Corpe,
personal communication).
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management and quality management. They face both constraints and
reality, and the conflict is sizeable between their aspirations and their
possibilities. For example, Coordinating Requirement I,A,2 states this:
"Determine future land uses through area planning rather than through
special resource planning." That statement has been approved by the
Supervisor and the Regional Forester, and yet timber management planning
occupies a sizeable amount of time on the Flathead. The forest expects to
spend 18 months and almost $200,000 writing a new timber management plan,
in seeming contradiction to the CR above. The Supervisor and his staff
might better spend that money on area planning, and indeed intend to
integrate the timber planning effort directly with their long range
planning activities. The Flathead can spend the timber management
planning funds wisely, since the allowable cut figure-determines the
magnitude of timber harvest activities, and that is presently the single
most significant determinant of air and water pollution.
B^. Level of_ Timber Harvest
It is quite clear that some air and water pollution is occurring on
the Flathead National Forest. The amount and significance remains largely
undetermined at this point. But one thing is obvious, most of the
pollution results from timber operations and road building (and most of the
roads are built to facilitate timber harvesting). Thus, leaving aside the
issue of how serious the pollution might be, the fact remains that there is
a strong positive correlation between the level of timber production and
the amount of pollution. Not all timber operations cause pollution, but
most pollution is caused by timber-related operations. Furthermore, most
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other incidents of environmental degradation (e.g. damage to fisheries and
wildlife habitat, aesthetic deterioration, spring floods, etc.) are
likewise associated with timber-related operations.
It follows then that the amount of timber cut each year is a matter of
vital interest to anyone concerned with the quality of the natural
environment on the Flathead National Forest. The higher the level of
annual harvest, the greater is the potential for environmental damage.
Also, a high level of cutting increases the risk of serious (or even
catastrophic) environmental damage; it tends to divert managerial attention
and resources from non-timber activities; it diminishes the land use options
available in the future; and if the level of cut cannot be sustained it can
cause serious social and economic disruptions at some .time in the future.
The degree and seriousness of the impact of high cutting levels is not
known in a quantitative or specific sense; but the burden of proof is on
those who advocate the higher cutting levels. The thrust and spirit of the
new environmental laws clearly requires evidence that damage will not occur
before an action is undertaken—rather than allowing an activity to
proceed in the absence of proof that environmental damage will result.
However, it would be naive and unrealistic to argue that the cutting
level should be drastically reduced (or eliminated) in the interest of
protecting the environment. Our society needs wood products, and the
economy of the Flathead Valley is heavily dependent on the wood products
industry. Furthermore, with proper supervision and the use of the proper
equipment and methods, a substantial amount of timber can be harvested
without causing serious pollution or other environmental damage. And, with
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adequate investments and good management it should be possible to increase
the level of cutting over time without compromising the environment.
So what is needed is a compromise; a cutting level that will provide a
reasonable supply of timber to our wood-using industries and to the
consumers of wood products, but that will also prevent serious damage to
the natural environment. The question becomes: How do we arrive at this
compromise cutting level?
Description of_ the Present Situation
The Flathead Forest is presently operating under a Timber Management
Plan approved in 1969. This Plan originally set the annual allowable cut
at 194.6 million board feet. In 1970 this was reduced to 181.6 million
feet because of the moratorium on cutting in the Middle Fork of the
Flathead River, (an area being studied for potential classification as a
Wild River). Over the past several years the actual harvest on the
Flathead has averaged about 151 million board feet per year.
In 1972 the Flathead Forest Supervisor decided to propose a modification
of the 1969 plan. Based on a new reclassification of the land,
consideration of new environmental constraints, and the use of a new
method for calculating the annual allowable cut (now called the programmed
allowable cut), the Forest proposed a reduction in the level of allowable
cut to 119.4 million board feet (plus a small portion of 26.9 MMBF that
might be available from marginal land). This is a proposed reduction of
34-percent. Furthermore, the 119.4 MMBF figure includes the expected yield
from 7 to 9 inch logs which was not included in the 1969 plan. Much of the
reduction (26.9 MMBF) is due to the reclassification of 203,780 acres of
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land from "industrial" to "marginal". The timber on these "marginal" lands
is not considered available with today's markets and with existing logging
technology. Another change that required a reduction in allowable cut was
the addition of 73,600 acres to the "high area zone" (i.e. from 261,000
acres to 334,700 acres). Land in this classification is considered
non-commercial and it is excluded from the timber growing base when the
allowable cut is calculated. Certain "roadless" or undeveloped areas were
also temporarily removed from the timber growing base, pending studies that
would determine whether they should be developed or permanently designated
as Wilderness. Also accounting for part of the reduction in allowable cut
was the decision to extend from 32 to 50 years the period of time allowed
for liquidation of mature timber.
proposal to reduce the allowable cut
was met with some dismay by the timber interests. The controversy that
ensued is still being pursued. The outcome is vitally important because of
the intimate correlation between the amount of cutting and the potential
amount of pollution.
How i_s_ the Annual Allowable Cut Determined?
It might seem, at first thought, that allowable cut (annual yield) is
a rather simple concept, and its calculation would be a rather straight-
forward process. One would simply determine the acreage of land available
for timber production, inventory the standing volume, estimate future
growth, and then schedule the annual cut to achieve the predetermined
goals of a forest. In practice, however, the process becomes complex
and frustrating. Goals are usually vague and often conflicting; adequate
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information is usually lacking (on such things as growth, environmental
impacts, responses to cultural treatments, etc.); economic and technological
factors are variable; social and legal contraints are changeable; and even
the definition of a forest is in question (in terms of species, tree size,
location, extent and density of the stand, etc.).
The Forest Service has evolved a logical, though very subjective,
system. They start by dividing the land base into two categories; timber
growing land (942,339 acres on the Flathead National Forest) and land not
available for timber production (1,423,027 acres on the Flathead). The
latter category includes non-forest (roads, rocks, water, etc.), dedicated
Wilderness areas, non-commercial forests (e.g. a'lpine or high elevation
forests), and land set aside for special studies (e.g. wild and scenic
rivers, roadless areas, etc.).
The timber growing land base is then further stratified into three
additional categories:
1. Standard (692,319 acres on the Flathead)--land where timber
can be grown and harvested with existing markets and logging
technology.
2. Marginal (203,780 acres on the Flathead)--land where timber
cannot be economically harvested with existing technology
without causing unacceptable damage to other resource values.
3. Special (46,240 acres on the Flathead)--land where production
and harvest of timber must be somewhat curtailed in order to
protect special recreational or scenic values (e.g. roadsides
and water influence zones).
An allowable cut is then calculated for each of these categories;
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usually stratified further by species, size class, cutting method, etc.
Actually, two kinds of allowable cut figures are determined for each
category:
1. The Potential Annual Allowable Cut—the biologically possible
allowable cut, considering land capabilities and assuming
optimum Management.
2. The Programmed Annual Allowable Harvest—that portion of the
potential annual allowable cut which will be offered for sale
each year during the planning period; usually lower than the
potential because of inadequate funding, manpower, technology,
and the need for protecting other resource values.
On the Flathead National Forest the actual calculations which determine
the allowable cut are performed by computer, using the Timber RAM model
devised by the Pacific Southwest Forest Experiment Station.
The Timber RAM model has been thoroughly Described and evaluated
elsewhere. It is essentially a linear programming model that determines
the best cutting schedule for achieving specified objectives. It optimizes
an "objective function" under a set of designated constraints. For example,
it can be used to determine the cutting schedule that will (1) maximize
the volume yield during the first decade of a planning period, (2) maximize
the present net worth of the forest property, or (3) minimize the cost of
managing the forest property. Region I of the Forest Service usually
1 Navon, D. I. 1971. Timber RAM...a long-range planning method for
commericial timber lands under multiple-use management. Pac. SW For.
Exp. Station, USDAFS paper, PSW-70.
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uses an objective function that maximizes the volume production (i.e. the
cut) over the full plannning period (usually 1 1/2 rotations).
The constraints that limit the cut (or which influence the cutting
schedule) can be classified into three categories:
1. Biological constraints—such as total standing volume, age
class distribution, projected growth rates, soil and
hydrologic conditions, etc.
2. Technical constraints—such as harvest methods, silvicultural
treatments, rotation length, utilization standards,
regeneration period, rate of reading for accessibility, etc.
3. Policy constraints—such as "even-flow" requirements, conversion
period (i.e. liquidation of old growth), rate of progress
towards a regulated forest, assumptions about future intensity
of management, tradeoffs between timber and other resource
values, etc.
The calculation processspfoceeds as follows: (1) a single objective
is designated, (2) all of the pertinent constraints are identified and
specified, and (3) the computer (using the RAM program) finds the
cutting schedule that best meets the objective without violating any of the
constraints.
The system appears reasonable and rational. However, because of
inadequate data, shallow technical judgements, and arbitrary policy
assumptions the results (i.e. the calculated allowable cuts) are
subjective and indefensible. The planner or analyst can almost literally
get any answer he wants. This is not necessarily bad, but it is a fact
that must be acknowledged.
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it should also be pointed out that the most influential factors in
the process are all under the control of the forest manager or planner.
Thus, even on the basis of much better biological and technical data,
the cutting level could still be greatly influenced by adjustments in
policy or assumptions about-the future.
Is_ the Forest Service Justified rr\_ Proposing a_ Reduction jm_ the
Allowable Cut?
The Forest Service is required by law to provide for the sustained
yield of all forest resources in perpetuity, without impairment of the
productivity of the land or degradation of the natural environment.
This is, by design and intent, a conservative policy. Therefore, the
proposed reduction appears prudent and wise. To attempt to justify
a higher allowable cut by arguing that timber is more important than
the other resources, or on the grounds that markets, technology, or
management intensity may improve in the future, would be to subvert the
laws that were established to guide the management of the National Forests
Some specific reasons in support of a conservative policy are as follows:
1. Knowledge about the forest ecosystem, about the impacts of
cultural treatments, and about the economic implications of
forest policies and practices is rudimentary at best and in
some cases almost completely lacking. Until such time as
these inadequacies are overcome it would seem prudent to be
conservative when making important management decisions.
2. Many professional foresters on the Flathead were convinced
that the present cutting level was too high. One ranger
estimated that he had enough timber for only five more years;
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another said he could continue his present cut for only
10 more years. A specialist in the Supervisor's Office esti-
mated that the present cutting level could only be maintained
for about 30 years, and then it would have to be reduced
substantially. Several of the technical specialists told
us that they were confident that if they had better data
in their area of responsibility it would suggest that the
allowable cut should be reduced. This evidence is subjective
but it is meaningful because it is consistent and it comes
from knowledgeable people who have an intimate association
with the Flathead Forest.
3. There is reason to suspect that many of the non-timber
resources are not being managed on a sustained-yield basis.
In response to a direct question concerning the sustained
flow of their resource, most non-timber specialists responded
either that sustained yield was not being practiced or that
they had no basis for making a judgement. Until all other
resources are put under sustained yield management, as required
by law, the timber resource should be managed conservatively
to prevent the foreclosure of future options.
4. A review of NEPA and subsequent environmental laws leads to
the conclusion that the Forest Service must regard environmen-
tal quality as an objective (goal), not simply a constraint
on the achievement of other goals. In other words, the
Forest Service must actively work to maintain and enhance
air and water quality, just as it works to maintain or improve
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the yield of other products and services from the Forest.
Prevention of pollution is in every sense a coequal goal
with the harvest of timber. Thus, it is no longer sufficient
to say that unless potential environmental damage can be
proven, a forest practice may be undertaken. The burden
of proof has shifted. Now the practice should not be undertak-
en until it can be proven that environmental damage will
not result. This new national policy suggests that the
annual allowable cut should be as conservative as possible
until we more fully comprehend the environmental impacts
associated with timber cutting.
5. Most of the arguments for increasing the allowable cut are
misleading. For instance, it seems unwise to increase the
cut in anticipation of more intensive management in the
future. There is no reason to believe that Congress will
appropriate the necessary funds, or that they would be allocat-
ed to the Flathead even if they were appropriated. Furthermore
the anticipated growth responses to more intensive management
are by no means proven or assured. It also seems unwise to
put much faith in improved utilization, or higher prices,
or new technology that will permit the harvest of timber
in "marginal" areas. These things may develop, and if they
do, the cut should be adjusted accordingly; but in the meantime
the allowable cut should be kept at a conservative level. As a
matter of fact there are some reservations about the ability of
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the Forest to maintain even the reduced level of cut. The
proposed allowable cut of 114.6 million board feet includes
trees as small as 7 inches in d.b.h.; it presupposes that
8200 acres of precommerical thinning will be conducted each
year; and it includes an annual harvest of 4.2 million board
feet on "marginal" land. Considering the historical and
current performance on the Forest, one must be very optimistic
indeed to assume that these practices will be accomplished
as planned.
6. The 50 year conversion period (for cutting the remaining
old growth timber) is much more practical and reasonable
than the 32 year period associated with the earlier and higher
allowable cut. It permits a more gentle, gradual treatment
of the land, which in turn provides a buffer against unexpected
but potential damage to watersheds. It allows more time
for the development of better scientific and technical knowledge,
which will assure maximum protection for the environment
and other resources when the timber ultimately is cut.
It prolongs the consumption period for this unique resource
(old growth timber), for the benefit of a future generation.
It helps to provide an easier and quicker transition to
a regulated forest condition. And, finally, it avoids the
need for an accelerated reading program, with all of the
environmental dangers and problems that are inherent in
such a program. It should also be noted that the Forest
officials consider it impractical and unfeasible to gain
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access to all of the old growth timber in less than 50 years;
based on projections of past and present reading accomplishments,
These reasons, while partly subjective, appear to support the Forest
Service position to reduce the allowable cut. While there is agreement
with the reduced allowable cut, it is not necessary to reduce the cut to
that level in one fell swoop.
Weaknesses Relative tp_ the Calculation of_ the Allowable Cut
The Flathead National Forest appears to have arrived at a reasonable
allowable cut. This conclusion is based on extensive interviews, obser-
vations, and analyses. However, their process could hardly be called
objective and the results are certainly open to question. Questions
regarding the process are illustrated by the following points:
1. Growth projections(which are extremely important in the
calculation of allowable cut) are inadequate. For example,
it appears that growth on all regenerated stands was projected
to be 516 board feet per acre per year...apparently disregard-
ing the effects of site quality, stocking levels, insects,
etc. This is unrealistic, and possibly misleading. As
another example, in 1969 the Flathead estimated growth in
immature sawtimber stands at 231 board feet per acre per
year. In 1972 they reduced this to 160 board feet, without
any explanation and apparently without any empirical justifica-
ti on.
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2. The Forest Service concern with even-flow seems inconsistent.
In calculating the allowable cut it insists on a rigorous
adherence to a policy of even flow, permitting only a one-
percent drop in the allowable cut at the end of each decade.
This is done in the interest of maintaining community and
industrial stability. But at the present time they are
promoting an abrupt reduction of major proportions, i.e.
34%. To most observers it would appear to be an inconsistency
in policy.
3. Information concerning the impacts of forest practices on
the environment is lacking, and efforts to gain such information
are minimal. The Forest has added technical specialists to
its staff and these people seem competent, dedicated, and
hard-working; but they are spread too thin, they are seriously
underfinanced, and they have little opportunity to attend
professional meetings, consult with scientific colleagues,
or otherwise expand the level of their technical competence.
4. The initial classification of land on the Forest is a vitally
important step in determining the allowable cut, but the
public seems to have little understanding regarding the process,
methods, or procedures for doing this job. What are the
operating criteria? Who did the classification? What level
of accuracy or precision was required? Were field checks
conducted? Full disclosure on this issue, would be to the
benefit of the Forest Service and the public.
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5. The allowable cut is based, in part, on the inventory of
standing volume in the forest. The allowable cut designates
how much of this standing volume may be harvested each year.
The magnitude of the cut is measured in terms of the scaled
volume of the actual logs removed from the forest. The
discrepancy between standing volume and scaled volume can
be quite large. According to U. S. Forest Service Research
Paper INT-77 (1970) the actual volume removed (measured
in cubic feet) is only 86% of the standing volume. Thus,
to achieve a harvest of 1,000,000 board feet we must deplete
our standing inventory by 1,164,000 board feet. Or, to put
it another way, by using scaled volume to measure harvest
after the allowable cut was based on standing volume, the
Forest would be overcutting by 16.4%.
6. The Forest apparently made no economic analyses at all in
determining the optimum allowable cut; no cost studies,
no economic impact studies, no evaluation of investment
alternatives, no cost/benefit analyses, etc. Economics is a
vital part of the allowable cut and should not be ignored.
7. Inviting public review of a full blown management plan,
with its designated allowable cut, is both difficult and largely
ineffectual. The public can have no meaningful input at this
point. It would be much more productive to involve the
public (in the form of special interest groups) in the formulation
of underlying policies, such as even-flow, conversion period,
rate of roading, land classification criteria, etc. With
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general agreement or understanding on these issues, the
calculation of allowable cuts and timber planning in general
becomes a more rational processes.
Conclusions on_ the Subject of_ Allowable Cut:
Based on an extensive review of all available documents relating to
the timber inventory and timber planning on the Flathead, and on field
observations and interviews with dozens of knowledgeable people, the
following conclusions were reached:
-- some drainages and some planning units on the Forest have been
overcut in the past.
-- the allowable cut established in 1969 was too high; or at least
it must be considered too high today in light of the many new
constraints on the level of timber harvest.
-- proposed level of cut, 119.4 million board feet per year,
seems reasonable or at least acceptable; but it may still
be on the high side if it is assumed that the present level of
management will peri sit.
-- the Flathead is basically a very productive Forest and with
increased levels of capital investment and good management
it should be able to produce timber at a much higher rate.
— the opinions stated above are intentionally cautious, and
conservative to compensate for the lack at knowledge about
potential environmental impacts. More knowledge (e.g. a good
watershed monitoring system) would almost surely obviate the
need for conservatism and might well lead to a recommendation
for an increase in the level of the programmed allowable cut
in the future.
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C_. Air Quality
The Forest Service in recent years has prepared written policies
regarding dispersal of smoke from slash burning.Title 5100 (Fire Control)
of the Manual includes instructions on Prescribed Burning plans (5153.13).
Region 1 Supplement No. 48 provides that in order to insure "minimum
impact on air quality...employ the principles contained in...'Principles
of Smoke Dispersion from Prescribed Fires in the Northern Rocky Mountain
Forests,1 by W. R. Beaufait and Owen Cramer." (see appendix)
The Flathead contributed to the development of the Regional system
and has set directions of its own for prescribed burning, fuel management
planning and treatment guides.
The staff of the Flathead forest is concerned with air pollution in
several ways. Slash burning is carried out under the present inter-
agency agreement described earlier. Many burning areas are near smoke
sensitive areas such as Glacier Park, the Flathead Valley itself, and
outlying areas such as the Bob Marshall Wilderness Area. Several methods
of slash burning are being utilized: hand pile and burn, dozer pile and
burn and broadcast burn. About 6500 to 7000acres are burned on the
Flathead Forest each year. About 1200 acres are broadcast burned, about
5300 acreas are dozer piled and about 500 acres are handpiled. Dozer
piling has been emphasized in order to meet the requirements of the
inter-agency agreement. In some areas where it is determined that the
accumulated slash is not a serious fire hazard burning is not used. Dozer
piling is used in areas that are not too steep and where scarification is
needed for seedbed preparation.
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Some steps have been taken to develop alternative methods of slash
disposal as recommended by the State Department of Health and Environmental
Sciences. Several places were observed where the timber sale required
removing all trees to a three-inch top. In addition trees were skidded full
length to a landing, topped and delimbed there. The amount of slash left by
this process was considerably reduced. The accumulated slash is then
either piled and burned or burned in an "air curtain destructor".
. In another operation a slash cutting machine, called a Tomahawk, was
run over the slash to chop it up and incorporate some of it into the
soil. In some areas this machine reduced the slash on the site and
burning was not necessary. This method had the further advantage of
preparing a seedbed for the next crop of trees. It partially scarified
the site but also left the soils protected with the broken down slash.
This process is still in the experimental stage but for some sites, at
least, appeared to offer a viable alternative to slash burning and for
site scarification as well.
Main haul logging roads in many areas have been given an oil coating
to reduce or eliminate air pollution from dust. Before oil treatment the
dust pollution problem was serious and complained about especially in
recreation areas. Another problem of water pollution from the oil has
appeared. Fisheries biologists have complained of oil pollution in some
of the trout streams. Two of the oiling trucks accidentally overturned in
streams. In addition run-off and road maintenance have allowed some of
the oil to get into streams. The Flathead staff are well aware of these
problems and are seeking ways to avoid a recurrence.
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At this time it seems that the standards of the burning agreements
are being met in most cases. Weather changes and fires that continue to
burn after their expected life have caused some problems. Given time,
alternative processes for slash reduction may well take care of a
considerable amount of the slash disposal. A new problem of slash
disposal in partial cuts and in areas being thinned commercially or
precommercially is requiring some new measures. They are recognized as
posing additional fire hazard due to increase in fuel accumulation.
It appears that for some time into the future there will need to be
burning of accumulated slash to reduce the danger from wild fire and to
restore fire to the forest at least in part of its natural role.
D_. A_ Review of_ the Environmental Impact Statements on_ the Revised Timber
Management Plan and on_ the Three-Year Projected Road Development Plan
During the past year the staff of the Flathead Forest prepared
draft environmental impact statements in connection with their timber
management plan. The draft for the revised timber management plan was
circulated for comment and preparation of the final statement is about
complete. The final statement for the three year road program has been
issued. The draft was circulated earlier and many comments were received
which are attached to the final report.
These two statements are reviewed here to describe where the Flathead
Forest is now in environmentally sound management. The discussion of
environmental effect is reviewed first and followed by the discussion of
the level of timber harvest.
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Environmental Effects
In keeping with the Forest's approach to long range planning the
environmental Impact statements were very broad and general. The statements
are meant to give "broad direction" only. These are meant to be followed
by an environmental analysis for each operation one to two years before the
contract is let. In addition the impact statement promises that if the
analysis shows that there will be a major environmental impact, "an
environmental impact statement may be prepared prior to advertisement."
Environmental impacts are mentioned broadly in various categories.
Impacts on water are recognized as: increase in yield and temperature,
accelerated runoff, surface erosion, siltation of streambeds, degradation
of channels. Primary impacts are from road construction. "Significant
increase in stream siltation often results during soil disturbance phases
of road construction." This, in turn, reduces fish habitat. "Transitory
impacts on air quality," are also recognized from slash burning. "Once
the old growth stands have been harvested this problem will largely be
resolved" when "replaced with healthy, vigorous trees."
The prescriptions for mitigation of environmental damage are also quite
broad. They include: lengthening the conversion period of old growth,
leaving unharvested "filter strips" along streams, greater care in road con-
struction and provision for drainage protection, review by specialists before
construction, avoiding construction when soils are wet, avoiding areas
subject to mass failure, "defer logging if present techniques cannot
protect soil," modify site preparation, and road design all give broad,
general but unspecific precautions for which no criteria are set. The Forest
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Coordinating Requirements are referred to as the basic document influencing
timber harvest and road construction.
Favorable environmental impacts emphasize the economic benefits of
timber manufacture, the material, for housing needs and some additional
access for recreation. Favorable effects on water include: increased water
yield although it "must be regulated to avoid the run-off capacity of the
individual drainages"; and increased water temperature because it creates
"conditions favorable to increased plant growth." However, "precautions
must be taken to avoid increasing water temperatures to the point that
they become detrimental to desired fisheries. The value of the water
produced on the Flathead Forest is said to be $5,000,000.
The principle favorable impact on air mentioned is that "the production
of oxygen will increase" as the over-mature stands are replaced with
healthy young stands. Danger from wildfire as well as the need for slash
burning will be reduced.
A large share of the adverse effects listed are visual impacts because
they have been the main topic of public criticism in the past. The only
irreversible or irretrievable commitment of resources listed is the loss
of the "pure, natural character" and its possible reclassification as
wilderness. But these effects will be minimized in keeping with the
Regional Forester's Management Direction of March 1972: "timber harvest
areas will be designed to produce a natural-appearing landscape. Timber
programs should be designed to contribute to other resource enhancement,
such as wildlife and recreation."
In discussing the relationship between short-term and long-term
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effects the statement says: "The potential long-term productivity of the
Flathead National Forest depends on maintaining the inherent soil
capabilities without impairment of productivity, maintaining the high
quality of the air and of the surface and ground water resource." It
promises that "road construction will be implemented so as to maintain
long-term soil productivity...though 700 acres will be seriously affected."
"Road construction will be controlled to insure that the guality of the air
meets or exceeds current State and Federal standards. There will be short
term lowering of air quality due to construction." "The quality of water
will remain high...Every effort will be used to insure water quality
continues to meet or exceed current State and Federal standards."
Comments from Federal and State agency representatives emphasize
what they called the inadequacy of the statements, that they were too
general, gave no specific information and, in fact, provided no measure
for judging the environmental effects. "Studies should be cited to
indicate the magnitude of increased soil/water run-off, water chemistry
changes, and water temperature modifications." "The total effects of an
increased and improved transoortation system deserve complete and detailed
evaluation." "Other economic considerations should be evaluated as well as
the timber resource." "Monitoring water quality before, during and after
projects is important to determine the effects and to prevent serious
long-term problems. Methods and plans for monitoring should be discussed
in the final statement. Because several factors affect sedimentation
potential from roads (steepness of slopes, soil types, vegetation types
and condition, size and location of roads in relationship to streams),
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these factors and associated alternatives should be evaluated." "The
entire impact statements are fraught with unsubstantiated comments designed
to provide an after-the-fact justification of the forest's timber harvest
goals."
The Forest Service replies pointed out that "detailed comments could
not be answered due to the broad nature of the Statement...details will be
provided in land use allocation statements and proposed project statements."
Industry favored the statement although one man suggested the need for
supporting data. The Chamber of Commerce generally considered environmental
concerns and provisions as expensive frills. Citizen groups generally
responded that the statement was too general for comment.
Both environmental impact statements, one on timber, the other on
roads, were broad and general with the promise that more detailed statements
would be prepared when specific work would be undertaken if environmental
degredation were threatened. There is a serious lack of guidelines for these
specific projects. There exists no body of knowledge to provide such
guidelines. Research has provided only a few results which might be
applicable. There are no benchmark areas established to measure change
in the area. There has been no monitoring of past experience to provide
data. The information is not available to prepare specific environmental
statements on the projects which might later be undertaken under the umbrel-
las offered by these two impact statements. The solution to this problem
is to develop the knowledge as rapidly and as soundly as possible.
Although the statements emphasized the fact that they were meant to
give only broad guidelines and that specific information would be provided
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in each individual contract, there should be at least general guidelines
based on specific data. The promise that specific information will be
provided later cannot be fulfilled because the specific knowledge needed is
not presently available and little attempt is being made to make the
knowledge available.
The lack of knowledge is perhans most conspicuous in the range of
alternatives proposed. With more accurate knowledge a continuum of cause
and effect relationships could be shown and the development of alternatives
could document the consequences of the alternatives. The alternatives
given show one or two irrational alternatives by which to compare the
desired alternative. However, there is no proof presented that the
alternative selected is necessarily in the rational range for decision or
that there may not very well be a better one available.
l_. The Specialists
The addition of specialists to the supervisor's staff is generally
regarded by the Flathead Forest staff as one of the most necessary
and effective steps toward environmental management. The study team
spent time with specialists, examined the work and reports of the specialists
and discussed their problems with them. Observation was made of how they
worked, what they provided, how they felt about what they were doing, and
what improvements and changes they thought necessary.
The specialist staff available to the Flathead N.F. includes a soil
scientist, a hydrologist, two silviculturists, a landscape architect, a
transportation engineer, (all full time) an engineering geologist, a
fisheries biologist, and a wildlife biologist (shared with another forest).
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The disciplinary diversity of the small specialist staff on the Flathead
is impressive, particularly when the importance of having specialists at
the Forest level was not recognized until recently. Other Forests
(e.g. Bitterroot and Kaniksu) in the Region have and are developing
similar teams.
No one on the Forest feels that there are enough specialists
available. They cannot spend time on inventory or monitoring, and they
can seldom go back and inspect past activities unless serious problems
develop. In addition to the staff on the Forest some help is available
from the regional office, and from the Fish and Game Department, the
Soil Conservation Service and others. Comparing present activities with
the past, it is obvious that acquiring and using scientific information
is a big step toward more responsible environmental management of the
Flathead National Forest.
Specialist's Responsibilities
While mo£t of the specialist's time is assigned to development of the
long range plan, they do work on specific problems on the districts.
The ultimate intent is to have them examine these problems in a
multi-disciplinary analysis prior to activity. At present, most major
project (i.e. road construction and timber sale) investigation is limited
to those which forebode possible problems to the District staff based on
their previous experiences. According to the specialists, on-ground
examinations are made on perhaps 10 per cent of the Forest's projects,
with this percentage varying by District. These on-ground examinations
themselves vary in their thoroughness and are influenced by the number of
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specialists involved, the time that the specialist or specialist team
invest in the analysis, and the amount of data available for a qiven area.
It was apparent that, by necessity, some ground level examinations were not
thorough. However, besides examining projects on the ground, the specialist
team utilizes aerial reconnaissance (particularly, photographs), existing
bedrock information and topographic maps to predict potential problem
areas on an extensive basis. The specialists were confident that the
extensive analyses are very useful in partially alleviating the development
of new problem areas and that in this way they do have the opportunity to
at least call attention to potential environmental problems.
Without exception the specialist recognized that the Flathead is
in the timber cutting business. They also recognized the official
commitment of the Flathead to multiple use but only in relationship to
0
the principal goal of meeting the timber harvest goals. All of the
specialists seemed to have accepted the situation as the framework within
which they had to work.
They did believe, however, that within these limitations they were
effective in the decision process. They pointed to instances where their
work had modified road and harvest plans. In one case they felt that
their recommendations had stopped a sale. They felt that they had strong
backing and were expected to make strong and factual recommendations. The
supervisor and his staff confirmed this and felt that they had made it
plain to all the Forest staff as well as the specialists that this freedom
on the part of the specialists was most important and had to be encouraged.
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Problem Areas Noted By_ The Specialists
i
!
The specialists feel that most of the environmental problems relating
to timbering activities are caused by roads. Those caused by timber
harvesting itself seem less in degree and extent. The most serious
problem is mass failure caused by soil instability, slope hydrology or a
combination of both. Next in importance is sedimentation. Another
problem is channel degradation brought about by increased streamflow as a
result of timber cutting. Effects of sediments and organic matter in
streams and their effects on fish migration and spawning are of special
concern to the fisheries biologist. Also of concern is increased water
temperatures in streams where the timber has been cut, or from run-off
from exposed areas. Of particular importance to the wildlife biologist
are the effects of roads and harvest on animal movements and populations.
Another problem is productivity. Establishment of regeneration,
particularly spruce in high elevations, and unexplained slow rates of
growth of young trees are of special concern.
All these problems are interrelated and interconnected and the
communication and cooperation of all the specialists is basic to problem
identification and analysis.
They agree that the worst erosion comes from slumps and slides
caused by roads and from bank cutting on streams and rivers as the result
of increased flow. However, they recognize that there is also a
considerable amount of natural sedimentation from normal snowmelt and
rain, especially the spring run-off. There are also occasional serious
floods such as that in the spring of 1964 which gutted every natural
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channel including those in the Bob Marshall Wilderness where there had
been no road construction or timber harvest. The streams are just
beginning to heal from that flood. As a consequence, man-caused activity
has a potential for retarding recovery. ~~"
A great deal of the adverse effects of road construction can be
eliminated if roads are properly layed out and adequate drainage provided.
One concern is over the amount of a drainage that can be safely cut at
one time and how long it is necessary to wait before it is safe to go
back into a drainage for another harvest.
One of the problems the specialists face is that about 200 miles
of new roads are built each year. It is difficult to keep ahead. But
in addition, there are more than 2,000 miles of old roads, many of them
poorly layed out, which need maintenance or perhaps need to be "put to
bed"; the specialists haven't time to review that backlog.
Soil scarification has been a standard silvicultural recommendation
to provide a seedbed and to reduce competition for tree regeneration.
Its use, particularly with clearcutting has left the soil in almost a
plowed and cultivated condition. On steep slopes with erodible soils
the effect on erosion and siltation could become serious. On the advice
of specialists the amount of scarification is reduced to 40 to 50 percent.
The reduction in the amount of slash by harvesting to a three inch top
and the use of slash reduction machines reduces soil disturbance. Dozer
piling of slash can also be done lightly enough to cause less soil distur-
bance. Old habits are hard to break, however, and cat skinners still
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tend to do too much| (close supervision is required.
Policies and guidelines have been developed to prevent construction
of roads in or near streams. Buffer strips are established along streams
in timber sale areas and along roads. Distribution of fine materials
is the greatest concern in regard to trout habitat. Most of this silt
comes from poor road location or placement of culverts. Ph ratios are
considered to be acceptable at the present time.
Some drainages that have been heavily cut or burned, need to be
left undisturbed for a period of years to allow revegetation. For example,
specialists felt that any further cutting at present in Hay Creek on
the North Fork would destroy the Cutthroat Trout habitat.
There was a great deal of talk about the importance of water in the
management of the Flathead Forest and especially the significance of
water quality as a measure of forest management quality. There was
universal acceptance of that fact by all the staff as well as the
specialists. The native Cutthroat Trout was also regularly mentioned as
the best measure of water quality. Beyond that there was a lack of
quantified data to identify goals or criteria for the measurement of water
quality.
Some of the specialists critized the lack of regional or Washington.
guidelines on water quality. A group of hydrologists put together such a
statement and it is now under consideration in the Regional Office.
(see appendix) They expressed a considerable need for hydrologic data which
is not now available. The data needs expressed in hydrology were reiter-
ated in virtually every field: soils, silviculture, wildlife and fisheries,
geology, etc.
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To make their analyses and recommendations, the specialists now
depend on observation which 1n turn is based on their academic training
and more recent experience. They recognize that these are educated
guesses, often approximations. They would like to start developing data
beyond the experience they may be accumulating. They can draw on Forest
Service Experiment Station data, but too often these have to be extrapolated
and interpreted for conditions on the Flathead and too often such data do
not apply. Nevertheless, an important part of the specialist's job is to
accummulate benchmark data on the Flathead by monitoring programs that
test cause and effect relationships from on-going activities, but little
time is available for this activity. The recommendation for monitoring
arose both from specialists and from field managers but has not yet been
put into practice.
Lack of inventory data was recognized as a general weakness. There is
no inventory of soils except for a few local areas. There is a geology
map available but it is not reliable in particular areas. As a consequence,
areas of possible mass failure cannot always be predicted. The cause and
effect relationships on fish and wildlife are recognized as weak.
Growth and volume estimates for timber are unreliable. A complete
inventory of the total forest resource is a massive job but must be
undertaken soon if long range planning is to have a sound basis.
The development of knowledge for predictability in all resource fields
will be an expensive and long time operation, but it is basic to sound
management. There are ways in which this information can be drawn together
into useable ways in the short run as a starting point.
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Specialist's Needs
The specialists and field personnel recommended an increase in the
number of specialists. They agreed that there should be specialists
gathering scientific data now; others should be translating it for
management and others working on the long range plan. At least a
doubling of specialists' staff is needed to place the forest on a sound
scientific management basis.
Specialists should also be developing training programs for the field
people in each of the resource areas. Specialists should also have more
opportunity to meet with each other, to attend special programs to keep
current in their fields and to attend regional and national professional
meetings in their areas to meet and exchange ideas with their colleagues.
The region -should also make arrangements to use analytical laboratories
in soils, hydrology, etc. They could establish their own lab facilities, or
develop cooperation with such laboratories in other State and Federal
agencies, universities or private organizations.
There also needs to be developed a system of follow-up so that the
specialists have the opportunity to review the work that has been done
not only to see whether or not their recommendations have been followed
but also to give them every opportunity to learn from their experiences.
This experience should help improve their capability and increase their
usefulness to the agency.
An underlying concern of all the specialists we met with was career
development. They were interested in their work but they all considered
their job at a dead end. There seemed to be no career ladder evident to
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them. In most cases the job they have appears to be as far as they can
go in the Forest Service. There are exceptions, of course, but most of
them thought that their future lay in eventually moving to another agency.
This situation might be alleviated with the employment of more specialists
and developing several levels in each field. There may also be
opportunities by moving into administration or broader specialist area.
But so far these seem to be limited. This is not yet a serious problem
on the Flathead: the men seemed to be happy and excited about what they
were doing. But they have it in mind and it is sure to become
progressively of greater concern to them.
£. A_ Case Study - Lower Sullivan Creek Sale
In order to illustrate how the specialists work on going projects
a case study was made of the Lower Sullivan Creek Sale.
In this case study examination was made as to how the project was
carried out, how the specialists worked and to what extent their recom-
mendations were used and what effect they had on planning and practice.
Some questions of procedure were also examined.
The Lower Sullivan Creek Sale on the Spotted Bear Ranger District,
was finalized in July 1973. Because of the emphasis on minimizing
aesthetic degradation and unfavorable impacts on a stream recognized as
important to the local fishery, the sale provides an interesting case
study. Additionally, the general area is recognized as a winter range for
wildlife, and some of the sale's units are virtually contiguous with the
Hungry Horse Reservoir (units 2 and 3) or a major access route (Road 895)
to the Bob Marshall Wilderness (units 5, 6 and 7). Because of the area's
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cited high timber producing potential, its importance as a watershed, its
value for wildlife and, at least indirectly, its use by recreationists,
the Lower Sullivan Creek Sale represents a recent Flathead management
decision made on a system possessing true multiple-use characteristics.
The following description of the documents reviewed in the Lower
Sullivan Creek case is presented for several purposes. First, the
documents clearly indicate the commitment of present forest personnel to
environmental protection. Second, they also suggest some important data
which are unavailable to specialists at this time. Finally, the documents
provide insight into the use of environmental analysis in determining forest
management activities and lead to several conclusions drawn on policy and
enforcement at the Forest level.
An environmental statement was completed in January 1972 and
included statements on hydrology, timber, recreation, transportation,
wildlife and fisheries. The statement clearly identifies the Lower
Sullivan Creek area as one with value for several resources and also as
hydrologically sensitive based on the drainages' past fire and logging
history, "numerous wet areas" and noted erosion problems on some roads
in the vicinity. Three creeks, Sullivan, Quintonkon and Clark, were cited
as excellent spawning streams, "primarily for west slope Cutthroat trout, an
endangered species." These spawning grounds were suggested as having very
high economic value based on studies conducted elsewhere.
. The hydrologic report for the major Sullivan drainage basin stated
that channel conditions were not good. The reasons suggested to explain
these poor conditions were (1) wildfires which burned more than 57 percent
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of the watershed in 1919 and more than 25 percent in 1929; (2) more recent
logging activities; and (3) the flood of 1964. Using regional guidelines,
the hydrologist estimated percentage changes of mean annual run-off, peak
flow and maximum channel impact period of several drainages in the sale area
compared to those expected under fully forested conditions. Without further
management activity, estimates for each parameter were above those expected
from forested watersheds (Table 1).
Table 1: Estimated changes for three hydrologic parameters in Sullivan
Creek drainage compared to the same drainage if it were fully
forested. Data abstracted from Flathead Forest Environmental
Statement for Lower Sullivan Creek Sale.
Watershed Unit
Sullivan
Quintonkon
Total
Mean Annual
Runoff (%)
+ 8
+ 8
+ 7
Peak Flow
(«
+ 12
+ 11
+ 10
Maximum Channel
Impact Period (%)
+ 26
+ 20
+ 25
Maximum allowable
change for streams
in poor condition from +6-10 + 15-20 + 20
regional guidelines
The estimated values for the two drainages contracted for logging
exceeded the regionally suggested maximum for maximum channel impact
period and were clearly approaching the maximum for mean annual flow.
At least partially based on the hydrologic condition of the area, the
Lower Sullivan Creek sale seems clearly designed to minimize impact both
on aesthetics and a stream recognized as one of the most important
spawning streams for the Hungry Horse Reservoir. On paper, much care
was taken to prevent deterioration of the Sullivan and Quintonkon Creek
spawning grounds. According to the contract, timber is to be logged
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only between January 1 and March 15 of the five year period of the
contract, tractor skidding is not permitted in the bottom of draws or live
streams, skid roads crossing streams will be minimized, there will be no
tractor logging on slopes exceeding 35 percent, and numerous special
treatment areas were established along stream channels. In any special
c
treatment areas, cable skidding or winching will be used and trees will be
felled in such a way that they require little movement before extraction
from the forest. Of the 766 acres which are to be cut, 122 are
special treatment areas because of streams or reservoirs; 128 are special
because of roadside; .and 12 because of being in natural meadows, for a
total of 262 special treatment acres.
The major concern hydrologically, while not stated, appears to be
minimization of sediments generated by logging. Using a major control
method recommended in a recent EPA Study (Midwest Research Institute, 1973),
harvesting and reforestation systems were selected which would minimize
soil disturbance. Selection cutting of individually marked trees was
designated for all but a few acres of overstory removal. Selection cutting
can be expected to increase streamflow less than clearcutting, and natural
regeneration should be established with minimal site preparation, although
some scarification was recommended to favor western larch establishment.
The winter logging should decrease soil disturbance considerably, assuming
an established snow pack during that period. Road construction was also
minimized and most new roads are scheduled for closing at the conclusion of
the sale. Streamside vegetation left in place will hopefully prevent
undesirable thermal pollution of the stream, a phenonmenon which is
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0
reported to occur on the Forest when buffer strips are not left (Casey, 1971)
In general, the environmental statement and the sale contract indicate
the Forest's awareness of both (1) the value of Sullivan Creek as a
watershed and (2) reasonable management procedures which would minimize
stream damage given the commitment to log. Theoretically, the sale is
designed to minimally disrupt the ecosystem relative to almost all alterna-
tive harvesting procedures except prohibitively expensive one. The state-
ment seems to meet many rules and regulations concerning the content of
environmental statements (Federal Register, 1973).
When the environmental statement and contract for the sale are
considered specifically, some difficulties in protecting Lower Sullivan
Creek become manifest. Certain restraints in the contract are vague, and
are worded in a way that prohibits evaluation of their probable
effectiveness. For example, "In event debris...enters stream courses in
amounts which may adversely affect the natural flow of the stream, water
quality or fishery resources, purchaser shall remove such debris as soon
as practicable..." (Contract, page 36). What amounts to an "adverse affect
on water quality?" Will there be adequate supervision of this issue when
interviews have indicated that sale administrators are overworked? In
fact, discussions with a Forest specialist suggested that a road had
already been constructed closer to the stream than permitted by the
contract. The specialist attributed this to inadequate Forest supervision
of the sale. Although the plans for the sale included preliminary discuss-
ion of environmental impacts and issues with logging personnel, it is
difficult to assume restrictions like the debris statement will be met
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with no quantitative guidelines or, for that matter, data upon which
to develop this quantitative information. However, there is some explicit-
ness in the contract that was not contained in the environmental statement.
For example, skid roads are not allowed within 100 feet of live streams
and no skid roads are allowed in live or intermittent streams.
The environmental statement contains some quantitative information
which at least initially seems questionable based on interviews with the
specialists. Although the following relate only indirectly to water
quality, they are significant. (1) "Only trees that will not survive
5-10 years will be classified as high risk and marked for cutting."
(Page 1) (2) "The entire sale will be partial cutting, with plans to
remove 25 percent to 50 percent of the vo'lume." (Page 1) (3) "Where
studies have been made, spawning areas annually yield from 1,000 to
300,000 dollars per acre. Any and all amount of measures to protect this
valuable resource is economically, aesthetically, and socially
justifiable" (Page 3). If the Sullivan Creek area is a productive
timber site, it is surprising that 25-50 percent of the volume will not
live for another ten years, particularly since portions of the area were
already salvaged following the bark beetle epidemic. Despite the fact that
"many of these trees exhibit signs of being overmature, deformed or
diseased" (Page 1). The dearth of published knowledge of mortality rates
for the species involved would preclude such statements.
The actual volume to be removed was estimated at 25-50 percent of the
total volume. Based on notes of inventory data in the sale file, the esti-
mate must be for the entire sale area of 1,200-1,500 acres, not for the 766
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acres of stands specifically outlined for cutting. Despite the fact that
the area to be harvested is less than 2 percent of the stated area of the
Sullivan Creek drainage (46,200 acres), the described hydrologic condition
of Sullivan and Ouintonkon Creeks and the propinquity of the sales to
those creeks, indicate that hydrologic conditions following harvesting
that small area should also have been estimated before the contract was
let.
The high economic value for spawning gravel cited was extrapolated
from another area. However, since quantitative values were used to
partially indicate the value of the fisheries resource, it would have been
useful if estimates of gravel area to be affected had been obtained. Based
on interviews, the specialists usually do not have time to pursue
investigations of individual projects as fully as they might wish. It is
clear that the fisheries resource of Sullivan Creek is viewed as very
important by Forest and Montana Fish and Game personnel, and that any
increased channel damage or water quality reduction could probably damage
that resource. There was no quantitative evidence that the amount of
streamside vegetation to be left standing would be adequate to avoid
thermal pollution or, if some pollution is allowed, how much would be accep-
table. More specific study also should be cited concerning the locations of
particularly critical spawning beds within the stream system and in
relation to stands to be cut.
In summary, a hydrologic analysis of Sullivan Creek indicated, based
on two major fires, past logging and a flood, that there probably should
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be minimal disturbance to this watershed until it has recovered more
fully. In response to this hydrologic problem and because of the Creek's
importance as a spawning ground, the Environmental Statement and Contract
indicate that care will be taken to reduce hydrologic disturbance.
A major question remains: why should any timber be removed from this
area if fisheries values are as high as some specialists claim they are
and when the primary reason for removing timber was stated as an economic
one? Four of the six paragraphs included in the environment statement
on favorable environmental effects are related to timber production.
One of the remaining two notes the aesthetic value of western larch in
the autumn, and the final paragraph speculates concerning possibly positive
wildlife benefits. No adverse environmental effects are specifically
stated beyond the fact that slash will accumulate, there will be some
aesthetic impact in travel zones, and the thermal pollution might arise
if streamside vegetation is not carefully marked. Quantitative information
is not presented for any of these issues. No baseline data are given
on water quality or predicted changes resulting from the proposed management
activities. Furthermore, no consideration is given to possible changes
of dissolved chemicals in the stream water.
Although the Lower Sullivan Creek information indicates increased
sensitivity toward water quality than the earlier case studies, it seems
inadequate for wise decision-making among alternatives. Despite the
importance of Sullivan Creek and its apparently degraded condition and
1 On reviewing the draft of this report, one specialist noted that he
felt Lower Sullivan Creek could undergo even further harvesting
without hydrologic damage.
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the verbal statements by the Flathead Forest leaders that water was currently
the Forest's most important resource, no discussion was made of restoring
the watershed. Also, data used in the statement was either estimated,
or extrapolated from uncited studies in other areas. The environmental
analysis could be viewed more as a justification for the sale than as
a truly viable tool for use in the decision-making process.
Besides the paucity of various kinds of data, a final and major
weakness observed in the Lower Sullivan Creek case is the timing of the
specialists' input to the decision-making process. The specialists usually
analyze a given sale after it has been essentially laid out by the district
staff. Then, recognizing the position the district people are in, the
specialists appear to shape their recommendations to best meet the sale
goals within the constraints of the landscape. That is, environmental
constraints and resources other than timber may not be adequately considered
when the initial sale is laid out. An extremely important change is
that the Flathead has begun to send the experts in prior to the district
people setting up the sales. Only a general area for a possible sale
is selected, and then the specialists are asked to come in and analyze
the site. The specialists clearly favor the pre-sale observation much
more than the de facto post-sale operation. To one specialist's knowledge,
a review undertaken in the spring of 1973 was the first time this new
procedure was used. It is essential that this new process become policy
and it seems likely it will on the Flathead, if adequate funding is
available.
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£. Budgets and Budget Preparation
The Forest "management team" consisting of the supervisor, his top
staff, and the district rangers, establishes each year the "program
priorities." This was their listing for fiscal year 1973:
Program Priorities
1. Protection of existing resource values
. Fire control
. Hazard reduction
. Maintenance (Other)
. Protection of other resources (range, special use, wildlife,
soils, water)
. Recreation administration
. Roads and trails
. Sales administration
2. Land use planning
3. Timber "sell" program
4. Timber stand improvement and reforestation
(This listing and the data to follow are drawn from a document
entitled: "Flathead National Forest Program of Work 1973 F.Y.")
This represents a kind of "prevent defense" strategy in a budget
climate of extreme austerity. The Flathead people wanted first to protect
the resource values charged to their responsibility, and only much later
would they be concerned with improving them (through ."timber stand
improvement," for example) or incurring additional administrative obliga-
tions by selling more timber. In dollar terms, its meager funding for
the "timber 'sell' program" or "timber stand improvement and reforestation,"
and relatively healthy funding for such items as "maintenance (other),"
"protection of other resources," and "recreation administration" would be
expected. This listing was in accord with the typical Flathead attitude
of independent, localized decisions based on localized productivity; in
short if expresses the "policy-of-intentions."
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When the budget allocations were finalized, however, the "policy-of-
fact" emerged.
If the program priorities 1 through 10 are ranked as listed, and the
budget allocations 1 through 10 are ranked in descending order, it is
found that the "policy-of-intention" has been nearly inverted:
Program Budget
Priorities Allocations
Category Ranking Ranking Budget
(Policy of Intent) (Policy of Fact) ($ Thousand)
Roads and Trails 6 1 1,551.6
Timber stand improvement,
Reforestation 10 2 938.0
Hazard Reduction 2 3 400.0
Timber "sell" Program 9 4 372.3
Sales administration 7 5 350.9
Fire Control 1 6 231.0
Subtotal 3,843.8
Maintenance (Other) 3 7 212.0
Recreation administration 5 8 140.2
Protection of other
resources 4 9 98.2
Land Use Planning 8 10 90.2
Subtotal 54"O~
Grand Total 4,384.4
Given there is room here for varying definitions, by this analysis
timber and timber-related activities on the Flathead account for 87.8% of
its budget; all other activities account for 12.2%. If policy is what
administrators do, the primacy of timber is not only conspicuous, it is
overwhelming; and the "Policy-of-intentions," becomes, by comparison
almost a contradiction.
The budget is the determinant in "policy-of-fact." The budget which
the Flathead Forest receives is now strongly biased against the
accomplishment of a sound environmental program. The Flathead staff is
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being constantly constrained by the limitations of their budget. A
balanced program of resource management that can include goals of
environmental programs will not be possible until the needs and support
for such a program are expressly budgeted.
H^ Enforcement
Accountability by the Flathead staff is the first step toward improving
enforcement and developing an attitude toward living within contract
specifications. The older functional organization made accountability
more difficult. The timber staff might accede to demands or accept layouts
violating the contract without the agreement of the line officers. The
district ranger is now responsible for all decisions and activities on his
district. In the new program approach the decisions are not made on a
functional basis but in terms of program. The supervisor has taken some
strong actions where contracts were violated. While accountability is a
basic first step, there remains considerably more to be done before
enforcement can really be considered an accomplished fact.
The-contractors and operators on road construction and timber sales
have by habit done only the minimum. Contract violations were common
and patterns developed. Precedent for shutting down a contract for
noncompliance has recently been established in the case of truck overloads.
Suspension of contract still remains to be tested for other violations
including those regarding environmental protection.
Under the policy of operator construction of roads the problem of
enforcement is very difficult, almost insuperable. In most cases the man
who has purchased the contract will subcontract road construction. Usually
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he shaves the price as much as possible, particularly when he has had to
bid high for the sale. Consequently the road subcontractor cuts corners
and barely meets standards, but the cost of road construction is low. A
margin for profit and risk goes into the timber sale appraisal but this
margin is often dealt out in the subcontract.
Some timber sale purchasers expect to make money on the road. A
few efficient purchasers who have their own road building machinery expect
to make a good share of their profit out of the sale from their ability
to build the roads cheaply. Some purchasers bid in the sale, construct
the roads and then sell the timber to someone else. In this case the
subcontractor for the timber may not meet the standards on the timber
harvest in an attempt to increase profits.
This arrangement leads to one of the major sources of environmental
degradation. It requires very close supervision, virtually one Forest
Service employee to watch each tractor. The threat of cancellation of
the sale seems to be the only effective recourse and this has been
accomplished only recently with the agreement of the Regional Forester.
The contract cancellation was on the basis of repeated violation of
load limits on Forest Service roads. This has only an incidental
relationship with environmental damage. However, the Forest Supervisor
feels now that his authority to cancel contracts for violation has been
established, he has the authority to cancel contracts on the basis of
violation of environmental stipulations. This authority has yet to be
asserted.
The right to cancel contracts for violation has been included as a
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contract clause for a number of years but until recently, it was never
enforced. A new amendment to the regulation on cancellation of contracts
became effective on September 10, 1973. An account of the new amendments
was published in the National Forest Products Association's "Government
and Forestry Affairs Report" recently:
Regulation on Cancellation of_ Contracts
A new amendment to the Agriculture Department Regulation on
Cancellation of Contracts became effective September 10, 1973. Two
new cancellation provisions give the Chief of the Forest Service the
authority to cancel timber sale contracts (a) for purchaser violation
of Federal, state or local environmental quality standards, and
(b) for cases where sale operations "would result in serious
environmental degradation or resource damage."
The Regulation amendment proposal to Section 221.17 of 36 CFR
was first published in the Federal Register on April 23, 1973 and
provided for a 60-day period for public comment. Industry written
comments objecting to the provisions for the proposed amendment and
suggesting needed revisions to the proposal were submitted during
that period to the Forest Service for consideration.
NFPA's Federal Timber Purchasers Committee reviewed a draft of
the proposed amendment as early as May, 1972 and further discussed
the two new provisions with the Forest Service at the May 17, 1973
meeting in Washington, D. C. Several of the industry-suggested
changes were incorporated, but industry's objections against the
need for the two new provisions were of no avail.
The following three provisions had been in effect and are still
unchanged:
Timber sale contracts and permits may be canceled:
(1) For serious or continued violation of their terms.
(2) Upon application, or with the consent of, the
purchaser, when such action is of advantage to the United
States or not prejudicial to its interests.
(3) Upon application of the purchaser if the value of
the timber remaining to be cut is diminished materially
because of catastrophic damage caused by forces beyond the
control of the purchaser resulting in (i) physical change
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in the sale area or access to it, or (ii) damage to timber
remaining to be cut.
The following two provisions are the new additions:
(4) For conviction of violation of criminal statutes or
for violation of civil standards, orders permits, or other
regulations for the protection of environmental quality issued
by a Federal agency, state agency, or political subdivision
thereof, in the conduct of operations thereunder, on National
Forest land, unless compliance with such laws or regulations
would preclude performance of other contractual requirements.
(5) Upon determiniation by the Chief, Forest Service,
that operations, thereunder would result in serious
environmental degradation or resource damage.
The two new provisions are aimed directly at strict observance of
provisions for environmental protection. Provision number (4) is of
special significance since it forces compliance of the operator to
the "civil standards, orders, permits, or other regulations for the
protection of environmental quality issued by a Federal agency, State
agency, or political subdivision thereof." This clause places new
responsibilities on the operator as well as the Forest Service to comply
to the new Federal, State and local laws and regulations which have
resulted from NEPA and the air and water pollution control laws. This
emphasizes the stipulations in these acts that all Federal agencies are
subject to them and are expected to take leadership in carrying them out.
The Forest Service has assumed the responsibility for enforcement
of contract provisions on its own lands. It has developed cooperative
arrangements with State and local law enforcement programs. In other
cases it has called for support from Federal enforcement agents. The
new environmental laws require new cooperative arrangements and new defin-
ition of responsibility in law enforcement. The limits of discretionary
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interpretation of the enforcement of laws have been considerably reduced.
To the extent that contract provisions are based in environmental law,
their enforcement may no longer be the sole responsibility of the Forest
Service. It may have to share responsibility or be subject to review
by State and local officials as well as subject to citizen suit.
The Flathead staff did not believe that they had authority to debar
anyone from bidding on future sales, but a recent new regulation does
permit the Forest Service to do so, and the grounds include protection of
soil and water resources. The following excerpt from the NFPA's
"Government and Forest Affairs Report" July 15, 1973 mentions the new
regulation and describes the industry's reaction to it:
Regulation on_ Debarment of Bidders
On May 15, 1973, an Agriculture Department Regulation amendment
on Debarment and Suspension of Bidders was put into effect. The
new Regulation, Section 221.lOa of 36 CFR, outlines six specific
areas where timber sale contract violations are regarded by the
Forest Service as so serious as to justify debarment or suspension .
The Forest Service..had general department authority in the past,
never for specific contract violations.
The proposals on debarment of bidders were initially given
to the industry in March, 1972. They were thoroughly reviewed by
the industry and discussed as several Forest Service-Industry
meetings the past year. The proposed amendment was published in
the Federal Register last February and was subject to public comment
for a 60-day period. Industry comments and objections to the proposed
amendment were sent to the Forest Service for consideration. None
of the industry suggested changes, however, were incorporated in the
final version of the May 15 Regulation amendment.
Violations of the following timber sale contract provisions by
the purchaser are regarded by the Forest Service to be so serious
as to justify debarment or suspension of bidders:
(a) Fire suppression or prevention and the dispoal of
slash;
(b) Protection of soil, water and residual trees when
such failure causes significant environmental or resource
damage;
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(c) Removal of designated timber when such failure causes
substantial product deterioration or conditions favorable to
insect epidemics;
(d) Restrictions on the exportation of timber included
under the contract;
(e) Access by the Forest Service upon its request to
purchaser's books and accounts; and
(f) Processing by small business on set-aside timber
sales.
In summary, the Flathead supervisor and staff consider that the system
of contracting and sub-contracting for road construction and timber
harvest is the cause of the most serious enforcement problems on the Flat-
head National Forest. Since these activities are also the principal sources
of air and water pollution, enforcement becomes a crucial issue in pollution
prevention and control. Because of weak enforcement in the past, operators
tend to do only the minimum required and to do even this has required close
supervision, which has not always been possible. Placing accountability on
the ranger has given focus to enforcement.
The authority to close down sales has been recently excercised on the
Flathead. The further authority to exclude chronic violators from bidding
on Forest Service contracts further strengthens enforcement authority.
A_ General Statement with Regard to_ Roads
The engineering specifications with regard to road construction
are very complete. However, road planning, reconnaissance, design, and
subsequent maintenance are equally as important as the specifics of construc-
tion. The Environmental Statement--"Three year Road Construction Program
for Flathead National Forest" conveys very little in the say of specifics.
Here are some examples:
"Water: the quality of water will remain high. Planning, construction,
and maintenance of roads will be controlled to reflect water quality
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considerations. Every effort will be used to insure water quality continues
to meet or exceed current state and Federal standards."
Another quote, "Engineering standards such as width of road, grades,
and surfacing material, are continually being examined and brought into
accord with land-use planning decisions."
Road planning represents a thorough analysis of need as well as
complete examination or route alternatives. The most experienced and
competent talent is a necessary and first step toward location. The design
should provide for a safe, utilitarian facility, but it should be
recognized that, with few exceptions, forest roads are not high-speed roads.
Road width is frequently held up as an example of "overbuilding" when in
fact it is only one factor in the total sphere of topographic or landscape
modification. Road width increases exponentially as the steepness of
the topography increases. Further, environmental impact increases as
horizontal and vertical alignment standards are increased. The expression
that roads should "lay easy on the land" is of particular importance in the
development of forest roads.
The importance of adequate road maintenance is a factor that receives
minimal consideration in the Forest Service road construction activities.
The mileage of constructed roads far outstrips the money available for
adequate road maintenace. The agency commits the lion's share of its
appropriated funds to construction of new roads at the expense of providing
maintenance. (Refer p. 132).
The Forest Service believes that most of the problems caused by roads
can be eliminated if the road is carefully laid out, carefully constructed,
has proper drainage and maintenance. But only in a few cases has this
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happened. The best example on the Flathead appears to be the Griffin
Creek road. There will very likely always be some run-off and erosion from
even the best designed and constructed road during construction and for a
few years or so after completion.
One of the problems that concerned the Flathead staff was that
roads tended to be over-built and perhaps over designed. As one ranger put
it, there was too much engineering input and not enough environmental input.
Awareness of this problem is a start. Part of the problem apparently lies
with the construction machinery available. It is hard to build a 12 or 14
foot road with a 16 foot blade. In the past concern was with meeting
minimum width and so the pressure was toward over construction. Long
tangents were favored over design with the land. Roads can be built with
far less earth moving and disturbance than has been the practice. Again,
close supervision will be necessary.
Road closure is now required and enforced for most of the skid roads
or lesser roads. "Putting to bed" by seeding and cross drainage reduces
sources of possible continued erosion. Part of the concept for road
construction seems to be a belief that future harvest technology will
require the roads. The system built ten to fifteen years ago already
demonstrate that this is hardly valid.
The fact that earlier harvest has been on the best sites means that
future timber harvest will need to go to progressively poorer sites where
conditions tend to be more fragile and where more acres will have to
be harvested to get a given amount of timber. The environmental hazards
are going to increase under these conditions. The requirements for
supervision^ c,an only increase unless some conditions change. One ranger
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stated that he had made a point of getting together with the operators,
equipment drivers and others to explain the problem of environmental
protection and inviting their help in meeting standards. He reported
encouraging success with this approach. He said that they not only did
more careful work themselves but pointed it out to others. He admitted
limitations in that some people tended to be uncooperative or not willing
to go to added expense because of the subcontract under which they worked.
There are two possible actions which might be helpful here. One would
be to let separate bids for the road construction and for the timber
harvesting. The other would be for the Forest Service to build the roads
itself. Both of these ideas have been under discussion for some time.
The first would largely avoid the subcontract which causes a man to cut
corners. It might also make it easier to revise contracts when the need
arose. Because environmental measures are new and planned practices may
not always be sufficient, the ranger needs the power to require extra or
revised provisions when he sees the need.
Road construction by government has been proposed many times.
It would very likely be more costly but- it would make supervision
and enforcement far easier. One problem that has also been foreseen
might be a tendency for the Forest Service to overbuild or to build roads
into more areas before they were needed or before the situation had been
thoroughly considered. If mistakes occurred, there would be no question
of accountability.
There are some side benefits from government construction. Contractors
now have to bear the cost of road construction which might be considerable.
Very often they have all available credit tied up in road equipment and
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construction. This tie-up of capital may reduce the industry's potential
for investment in mills which could improve utilization of raw material
or the development of new products.
Government construction of roads could also increase competition in
bidding on timber sales. A major road now requires a large sale which
eliminates all but the largest mills. The opportunity to make smaller
sales or sales of more variety in size might also make it more possible to
avoid environmental damage by permitting better design with the land.
I_. Regional Inspection Report of_ the Flathead N£
The regional inspection report of August 6-10, 1972 has been referred
to several times throughout our report. It is appropriate because of its
timing and because it dealt directly with the water and air quality effects
of forest activities on the Flathead National Forest. Prepared by Carl W.
Wetterstrom and James E. Eggleston of the Missoula regional office, it is
labeled: "Technical and Managerial Inspection-Soil, Air, and Water
Management, and Water Resources Related Development Activities, Flathead
National Forest."
This report has been referred to and quoted from earlier mainly to
provide documentation of the recognition by the Forest Service of past
environmental degradation resulting from earlier forest management activities
on the Flathead National Forest and also recognition that major steps
have been taken to change these earlier practices.
Included from this report are the recommendations by the review
team which refer to additional improvements needed to further advance
programs for protection of water and air quality. The report recognizes
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that the steps taken so far, while greatly advancing measures for the
protection of water and air quality, are not yet sufficient.
The report is interesting as a measure of the level of protection
which the Forest Service considered necessary in 1972. The hydromet
system, additional specialists, continuing education for the specialists,
watershed-by-watershed use of their vegetation manipulation procedure to
calculate allowable clearcut condition, stringent supervision, etc. are
all calculated to provide more understanding and control. There is agree-
ment with the merits of each. The questions which need to be raised are
largely of degree.
The report does not base its recommendations on any specific criteria
except general criteria of improvement or adequacy "to meet future needs
for quality management," or "to prevent unnecessary soil and water damage."
The report makes no mention of the criteria laid down in the Water
Pollution Control Amendments Act of 1972. It may not have been available
and the Forest Service had not yet established its own operating
procedures under the Act. The recommendations in this report were
considered as well as other operating procedures, plans, and proposals in
order to identify and assess the present awareness and activity regarding
water and air pollution control.
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Recommendations and Discussion
(emphasis added TrTall cases)
1. The Forest consider the hiring of another team consisting of
a soil scientist and hydrologlst to work primarily on project (or
long-range planning) work.
2. The Forest plan, establish, and operate a Forest-wide hydromet
network, including water quality monitoring, adequate to meet future
needs of quality management.
3. The Forest consider the hiring of a technician primarily to
operate the hydromet network and process the data. This technician
position should be multiresource financed and can do other priority
jobs.
The Region's soil and water program is directed toward involvement
in long-range planning, short-range planning, project planning, and for
hydrologists, establishment and operation of a Forest-wide hydro-
meteorological network. The soil scientist and the hydrologist on the
Flathead Forest are deeply involved in the long-range planning effort,
spending about 75 to 80 percent of their time in this type of work. This
is the approximate amount of time that the Regional Office has suggested
for Forest-based soil scientists and hydrologists to spend on this
activity.
The soil scientist and hydrologist are working well together as a
team in their own right, and they have also been assigned leadership
on the Forest long-range planning team. The team's work being
accomplished in planning as well as on projects, seems to be very well
accepted by the Supervisor, Staff, and Ranger District personnel.
(See attached 6520 memo of February 8, 1972, in appendix, page 20.)
This leaves about 20 to 25 percent of their time for short-range
planning and project work, with the hydrologist also responsible for
setting up the hydromet network. On the Flathead Forest, however,
short-range planning and project work is of such magnitude and of such
volume, that the specialists cannot do justice to this type of work as
well as maintain their necessary leadership in long-range planning. As
a result, specialist input to_ project work j£ limited, and practices
that degrade quality are occurring at a_ rate which is not considered
acceptable. One example of this is~~the Puzzle CreelTsale which the
Forest is now trying to modify extensively or to close out completely.
The soil scientist and hydro!ogist did not visit the sale area until
after the sale was made. Soil and water problem impacts of an
irreversible nature have been encountered" Quality has beenTmpaired
and rehabilitation js_ needed. Many of the problem areas could have been
eTTminated had the specialists had time to participate at the project
level.
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Likewise, the hydro!ogist does not have time to adequately maintain
the meager hydromet and water quality network that has been established
on the Forest. The Flathead Forest, approximately 2,350,000 acres, has
only three operating stream gages and seven water quality stations. The
stream gages are all on tributaries to South Fork Flathead River above
Hungry Horse Dam while the water quality stations are all on the Flathead
River (North Fork) which is being studied as a Wild River. Of a potential
90 months of station records, only 19.5 months (20 percent) of record
are available for analysis, and this is very discontinuous. (See 2530
memo of September 6, 1972, in appendix.)
The above facts indicate three areas of concern. These are: (1)
the soil scientist and hydrologist do not have time to properly investigate
all projects—planned or operating, (2) the Forest essentially has no
hydromet system, and (3) the instruments that are installed are not being
operated adequately. We strongly believe that the Forest should improve
their performance in these areas of consideration. We do agree with the
Forest in their basic philosophy concerning the hydromet network. That
is, if you can't do it right—don't do it at all. We believe that it
should be done, however, and done right.
7. It is recommended that allocation of WRDRA funds be continued to
the Flathead Forest in connection with the Hungry Horse project.
The Forest, in a summary writeup plan dated March 25, 1971, analyzed
the water values of the South Fork drainage basin above Hungry Horse
Reservoir. This writeup gave a summary of the inventory data available
and the inventory data needed to complete a soil-hydrologic resource
reconnaissance and the need to write a watershed treatment prescription
using WRDRA funds. The soil-hydrologic resource reconnaissance was to
begin in F. Y. 1972 and to be completed in F. Y. 1975 with the watershed
prescription to be written for the 400,000 acres of the South Fork
drainage basin above the Hungry Horse Reservoir and outside the Bob
Marshall Wilderness area. The South Fork drainage Basin above Hungry
Horse was divided into three working areas for the purpose of completing
the soil-hydrologic reconnaissance work. The reconnaissance work was to
be implemented with water quality sampling including bottom sampling of
the Hungry Horse Reservoir.
The Forest has completed the fieldwork for a soil-hydrologic
reconnaissance in the Spotted Bear River drainage (unit) in connection with
multiple land-use planning. Planning for a portion of the 1972 summer
season continued on a high priority land unit below Hungry Horse Reservoir.
Because of changes in priorities in relation to multiple use planning, the
Forest is currently not on schedule as to the March 25, 1971, plan and
commitment. However, recent changes in multiple use planning because of
Forest financing problems and the BPA change in plans in connection with
the Libby-Conkelley transmission line, the Forest is again accomplishing
soil-hydrologic reconnaissance work in the South Fork drainage basin
above Hungry Horse Reservoir.
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8. The Flathead should give consideration to intensified use of
remote sensing techniques.
Remote sensing on the Flathead Forest has not been extensively
utilized to date. To our knowledge, the only current work has been some
comparisons between infrared and black and white photographs. Remote
sensing can include sensing for water quality, but it is not limited to
that use. Landscape mapping can be improved, and perhaps speeded up,
with color and/or infrared aerial photos.
9. The Forest continues to establish firm controls over project
work in order to achieve quality, balanced soil and water management.
(Special emphasis on road location, construction, road maintenance, and
logging operations.)
The overall Forest planning program objectives based on field-office
evidence and discussion strongly indicate that the long-range planning
in relation to soil and water management appear to be good. This we
believe is particularly true in connection with endeavors to correct
low-quality management. There are indications that phase II of the
multiple use planning will determine the mix of soils and water as to
priority and value. The planning emphasis as to soil and water values
on the Flathead Forest is currently strong and balanced. In the next
2 or 3 years, the balanced emphasis being placed on soil and water
management planning will have to reflect a balanced and unusually strong
effort in the necessary implementation in project work—timber sales, road
construction, etc. Implementation to enhance the predetermined mix of
soil and water tp_ enhance their values as weTl a£ other values will B£
difficult because of_ past traditions ancTpractices.
10. The Division of Soil, Air, and Water Management work out the
necessary details and arrangements to assure the opportunity for the soil
scientists and hydrologists to formally or informally meet with professional
teachers and professors and discuss related academic disciplines.
11. The soil scientist and hydrologist consider formal refresher
academic short courses in the appropriate fields of their professions
every 3 to 5 years.
The Forest Supervisor and planning staff of the Flathead Forest
recognize the need for keeping their soil scientist and hydrologist (and
other specialists) up to date concerning their respective professions.
Technical training sessions, professional societies, symposiums,
industrial seminars, and university programs are approved for attendance
when justified. Special trips to research centers or universities to meet
with selected individuals on selected problems are also approved on
occasion. The soil scientist and hydrologist must stay professionally
viable by searching for and developing new methods and techniques
through attending professional society programs and other meetings.
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Likewise, approval for purchase of technical reference books and
periodicals is also approved, and the specialists are building a sound
reference library. They have also volunteered to take the library of the
Division of Soil, Air, and Water Management should that library be
discontinued.
Concern was expressed for need of informal meetings and get-togethers
with related academic disciplines, university professors, and professional
teachers in the universities.
The Region 1 "Procedure to Evaluate the Hydrologic Effects of
Vegetation Manipulation" is being used on the Flathead Forest. Since the
hydrologist is involved in the long-range planning, District personnel
are using the procedure in a gross manner as a warning system. When this
analysis indicates a problem in overcutting may occur, the services of
the hydrologist are requested on a project basis.
Intensive use of the procedure, on a drainage-by-drainage basis as in
the North Fork Flathead River, presents a calculated "hydrologic
recovery period." This, with other factors is used to determine how much
of_ a_ drainage can be in a clearcut condition at one time without" causing
an Tncrease i_n_ peaFTTow volumes sufficient to cause cha'nnel damage.
wTTen time permits, or need demands, an additTonal step can be taken. This
permits determination of how many acres can be cut per year, without
infringing on the "allowable clearcut condition" previously determined.
A good estimate ,of the time required to convert the remaining old-growth
stands to new, vigorous stands is provided. Available research data and
correspondence with universities and research stations are used throughout
the procedure. Required data are often of a limited nature, however.
The lack of intensively using the procedure throughout the Forest
has recently been the cause for concern py the committee headed by
Dr. Robert Pi Is.. The generaTTnterpretati on of the procedure, plus
estimates, have been used tp_ modify the conversion period of_ oldgrowth
\1
stands from 32_ years to 50 years for the Resource Allocation Model (RA"M)
program operated by tfie DTvision of Timber Management. The 50-year period
is used as an average conversion period for the entire Forest. The
Pi Is Committee felt that the 50-year conversion period ji_s_ not justified
tp_ protect watershed values alone in light of the additional mortality
and loss of timber that would occur. They thought that if any other
constraints exist or\_ the conversion period, they should aTso~be
emphasize'dT These could include aesthetics, road development, wildlife,
fisheries, etc.
Shortly after the Dils Committee visited the Flathead Forest,
Region 1 representatives met with representatives from the Intermountain
Station, Rocky Mountain Station, and Dr. Dils, to discuss the Region 1
procedure. It was the consensus of opinion that the procedure is
technically sound when used on a intensive basis utilizing the B"est
available information on water yield, water yield increases, channel
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condition, allowable in-channel increases, and hydrologic recovery period.
The major .point of discussion was that the 50-year conversion period
was an estimated average for the entire Forest and" that the "procedure had
noT Been workiJTbut for"each" TmTlvidual drainage.
12. The Forest utilizes the vegetation manipulation procedure on a
watershed-by-watersFed basis carry'ing the calculations to the point" th~at
allowable clearcut condition per year can be determined. These figures
should be projected to better estimate the conversion period.
13. The Forest Supervisor continues to take direct aggressive action
to assure that personnel who have the responsibility for planning,
formulating, or executing possible irretrievable land management decisions
know and understand the meaning and objective of the Forest coordinating
requirements.This would include all personneT~directly connected with
field operations—the planner, administrative services, professionals,
foresters, specialists, equipment operators, technicians, engineers,
foremen, strawbosses, and "the man who hangs the red ribbons in the woods"
to indicate a possible road location route.
14. Consider on-the-ground organized training or mutual discussion
sessions to determine what is considered quality management on the
Flathead Forest in connection with resource utilization and management
area development, and the prevention of soil and water degradation.
15. Determine what can and should be done wherever possible to
reduce unnecessary road widths and density, particularly in the high
water-producing basins having sensitive and complex soil and water
relationships.
16. Get compliance to prevent unnecessary soil and water damage in
timber sale or burned areas cleanup operations through stringent supervision
and general understanding of possible potential soil capability damage,
accelerated erosion and water degradation.
17. Develop a sensitive awareness among all field personnel for the
prevention of soil sediment being drained directly into stream channels
from road drainage systems and from all other project development causing
disturbance.
The Flathead has numerous examples and instances where past and some
current road construction practices are allowing water-carrying sediment
from road drainage systems tp_ drain directly into streams (item 12). The
Forest j^ jn_ the process of_ correcting this practice in new construction
projects as_ well as_ endeavoring to eliminate old problems. The Forest
also has examples where the oyirBuilding of roads has added an additional
impact on the water regime. The Forest is aware of this and is analyzing
each case on projected future use and need information (item 14).
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General Forest Zone - Items 5, 10, 11, 12, page 44 - Modification of timber
harvesting in drainages involving unacceptable watershed degradation,
either existing or anticipated, based on hydrologic analysis (items 11 and
12).
The Forest is moving rapidly in implementing items 11 and 12.
Modification of_ current timber sale contracts, use of_ vegetation
manipulation guides and stream channel classification guides, creation o.f-^
marginal timber cutting areas to withhold development until either more Y
hydrologic and soils information is available and/or a compatible system of
logging can be utilized which will prevent watershed or drainage degradation.
Water influence Zone - Item 1, page 46 - We observed instances of past
practices which had viola ted the same coordinating requirements which are
found in the initial Regio'nal MulITpTe Use Guides. The Flathead is moving
to implement this coordinating requirement as found in the current basic
land management plan.
Basic Assumptions - Resources and Uses - item 13, page 35 - The Flathead has
been in the process of modifying timber harvest programs and going
timber sale contracts. This path is currently not an easy one.1 The
Flathead will need administrative line support to maintain quality
management.
General Comments
Several items pertaining to the functional aspects of the Division of
Soil, Air, and Water Management were discussed and several sites were
visited in the field. A general discussion of these items and sites follows,
although no recommendations are made.
The whole cooperative snow survey effort with the Soil Conservation
Service needs to be reviewed. The Forest (among others) would like to get
out of the snow survey business, especially in wilderness areas. This
item needs to be resolved before this snow survey season (1972-1973). The
Division of Soil, Air, and Water Management is working on this problem
and will have recommendations to the Regional Forester's staff by early
winter.
The Annual Watershed Accomplishment Report (form 2500-4) is not
doing the job it~was designed for. This form calls for functional/
reporting when Forests are working CM a_ multiple use basTi"! As a result,
reported units are fictTonal and often deceitful. Basing requesTs for
funds or accomplishment on these records is shaky, at best. Form and
reporting units need to be revised. The Division of Soil, Air, and Water
Management should work through the Washington Office and explain
justification for change. The Flathead Forest has*a deep concern for this
problem and positive action should be taken to determine what can be done
to change the report or reporting procedure.
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The approach used by the soil scientist and hydrologist in giving
information to the land manager is very good. This approach is suggesting
what might happen if the project is consummated, and giving, if possible,
alternatives which will have the least impact on the land. The land
manager is given the choice of making the final decision, for which he is
responsible.
The Forest has only one municipal watershed plan, as such. However,
(the Te7el 1 multTpile use~pTanning now in progress will serve as municipal
watershed plans as long as the municipal watershed is recognized) in the
planning process. Although municipal watershed plans per se have been
de-emphasized in Region 1, a municipal plan of some sort, approved by the
municipality, is required if management activities are taking place. The
Forest has four municipal watersheds.
The Forest has not had a_ major watershed rehabilitation project, as_
such, 2£ recent years. Those that have been accomplished have been in
relation to fires and floods. The Forest does have a backlog of
rehabilitation work that could (should) be accomplished if funds were
available. Most of this work is erosion control on old timber sales and on
abandoned roads and trails.
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V. EVALUATION OF INFORMATION NEEDS FOR PREVENTION
AND CONTROL OF NONPOINT POLLUTION
The study of the Flathead clearly revealed the need for greater
knowledge before the objectives regarding nonpoint sources of pollution
can be met. Some of the information required is specific to the Flathead
National Forest, but many of these data may also be lacking on other Forests
in Region I and, in fact, throughout the Rockies.
The absence of this type of information probably suggests that change
is needed in national attitudes and policy concerning applied research.
Related to this need for applied research and a responsive applied-research
community is the need for mechanisms that more effectively transmit recent,
relevant research findings to the land manager and the public. Conversely,
there should be open communication to the research community from the
manager and the public concerning research needs and desires.
Experience on the Flathead suggests that knowledge is needed at three
levels: (1) baseline data on undisturbed ecosystems and additional research
on ecosystem processes; (2) applied research that would lead to reasonable
accuracy in predicting environmental changes resulting from management
activities; and (3) research on communicating research results, or the
actual education of management personnel at all levels in the Forest con-
cerning existing knowledge in environmental areas, planning, and
decision-making.
Baseline Data and Ecosystem Function
At the present time, most activities with the potential to degrade
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air or water quality on the Flathead National Forest are those associated
with timber harvesting and road building or maintenance. There is no
ma.ior threat of pollution arising from the use of pesticides or fertilizers
(Seastedt and Tibbs, 1973), although this situation could change with the
adoption of more intensive management. Of the remaining major pollutants
arising from silvicultural practices (Midwest Reseach Institute, 1973),
mineral soil, organic matter and thermal pollution all could create
problems on the Flathead. Additionally, dissolved nutrients seem to be
generally overlooked nationally as a potential source of pollution. Recent
studies in New Hampshire suggest, particularly on shallow soils or soils
with relatively low cation exchange capacity, that this oversight should
not be accepted until it is proven that harvesting does not lead to signifi-
cant changes in this important aspect of water quality (Likens et al.,
1970; Pierce et al., 1973).
Specialists on the Flathead are particularly concerned with sediments,
hydrologic budgets and forest management. Most agree that adequate baseline
data on water flow, ground water, soils, and geology are lacking. Additionally,
an inspection report from the Regional Office (August 6-10, 1972) stressed
the need to establish or re-establish a complete hydrometeorological network
on the Forest. The report also commended Forest specialists for not doing
so half-heartedly, however, citing the need for greater financial support
before the network could be properly located, maintained and utilized.
At this time, the Forest Service does not have adequate baseline
information to determine quantitative changes in water quality or quantity
that might result from any management practice. Furthermore, they probably
do not have adequate standards for determining whether any change is or is
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not acceptable. For example, the 1971 edition of water resource data for
Montana (U.S.F.S., 1972) cites only two stations in or very near the forest
at which water quality monitoring was being done. Some base data are
available from the Flathead River near Big Fork in Flathead County, and
fairly extensive temperature data are available from the South Fork near
the south end of Hungry Horse Reservoir. The more extensive data collection
from Big Fork was discontinued in June, 1971, but does contain a fair
amount of information on dissolved nutrients, humidity, temperature, etc.
The drainage area monitored by this station covers 6,300 sq. miles. Some
water quality data have been collected during the planning portion of
Spotted Bear district, (U.S.F.S., 1973). These data, although on a much
smaller drainage area, are minimal in that they were determined on one day
and they do not include measures of sediment or specific chemicals.
According to the Forest hydrologist, the Forest is cooperating with State
agencies when possible to generate new information on baseline water quality
on the Forest.
When determining what would be an acceptable change in any aspect of
water quality, Forest personnel referred to current water condition
criteria from the American Fisheries Society and State standards, which
have been developed from various parts of the country. Since baseline data
are largely lacking, and State standards have not been established for
small streams, these are the oVily data they can rely on.
There is clearly a need to review any standards regularly, but it
would seem nearly impossible to operate under present conditions. Water
quality standards for various ordered drainages must be developed soon and
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must be developed with sensitivity to both biophysical and social
portions of the forest ecosystem. Although an attitudinal rather than a
research need, the Forest, and in fact the Region, should have a clear,
well-defined statement of goals with respect to water resources and
relate these goals to other responsibilities, particularly timber
management. Apparently a draft document concerning Regional water policy
is being considered, but is not now available, (see Appendix)
Because of the relationship between soils and sediments, several specific
topics of concern were cited by the specialists. These included the need
for (1) better surveys to identify areas of high potential mass failure
hazard; (2) more information on mechanical properties of soils; (3) better
understanding of ground water and its variation and importance in terms of
stability on different slope conditions; and (4) information to verify a
bedrock map (Johns, 1964) on potential management areas and to delimit and
describe glacial deposits and lucustrine silts. At a later time, one special-
ist also foresees the need for soil fertility information.
An additional subject that is indirectly related to water quality and
which clearly requires more basic information is allowable cut. Since
this issue was considered in a separate section, it is adequate here to
simply note that the forest specialists are unsure of the reliability
of information on growth rates, mortality rates due to insects and disease,
and regeneration rates. Knowledge of these three rates is basic to establish-
t
ing timber management plans and is, therefore, important when analyzing
the environmental impact of a management objective. Research should be
conducted on each species, but in terms of water quality, the regeneration
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aspects of Engelmann spruce (Plcea enqelmanni) at high elevations and
on steep slopes seem particularly important.
Another subject in need of research is economic analysis and its use
in multiple resource management. Decision-making skills are available,
although they are not used to maximum benefit on the Flathead. A basic
problem which must be addressed when considering impact is that of inte-
grating quantitative data, some of which are readily expressed in dollars,
and qualitative data in the decision-making process. Better or more
utilitarian techniques for arriving at decisions using both types of data
would be a boon to the Flathead. Such procedures would be particularly
valuable for areas currently viewed as marginal for timber production due
to poor growth potential or environmental "sensitivity."
Environmental sensitivity itself must be defined and described in a
defensible manner. Planning efforts which are not based on sound analysis
of the land and ecosystem function are unlikely to accomplish their objectives,
A Rocky Mountain regional survey (TIE, 1974) will determine the research
base for a region-wide ecological zoning, which convincingly and accurately
delimits areas by their sensitivity. Although the Flathead National Forest
alone cannot be expected to accomplish the task of defining sensitivity,
and although its recent efforts in this direction (U.S.F.S, 1972) are a good
sign, it seems impossible to effectively plan and manage a multiple resource
area until sound, scientifically valid procedures for zoning are developed.
Applied Research
The greatest need facing the Flathead personnel in terms of water and
air pollution control is that of being able to predict the effects of road
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bin'lding, timber harvesting and silvicultural practices on the wat€
regime. Other uses, including recreation and grazing, are significant as
possible contributors in localized areas to water degradation, but their
importance generally is overshadowed by timber management. The questions
regarding timber are complicated by the impacts of fire, both wild and
prescribed.
To understand the environmental impact of any timber management
activity, the Forest staff must be able to predict the effects of planned
manipulation of stream channels, water yield, and timing and duration of
flow. Besides having inadequate baseline data and standards for water
quality, forest personnel do not have the capability of predicting changes
in water quality due to manipulation. Although Region I as a whole and
the Flathead Forest in particular have made significant philosophical
strides in terms of protecting water quality, their ability to predict
quantitatively the effects of alternative procedures is almost nil.
Their ability to oredict changes in flow amounts is better, but much work
has to be done to make this type of prediction specific to different areas
of the forest.
The Forest specialists are aware of the potential dangers of
extrapolating results from other regions to the northern Rockies. To make
judgments internally and to portray accurately to the public what the
results of alternative practices will be, forest managers must have more
empirical data, and procedures should be developed to obtain them. Even
changes in water quantity are difficult to predict on a variable area
like the Flathead (Oils et al., 1972; Delk, personal communication).
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Change in sediment load of streams is recognized as the most important
negative effect of forest land management (Midwestern Research Institute,
1973). The importance of dissolved inorganic nutrients (U.S. Senate Hearings,
1972) and dissolved organic compounds (Midwest Reseach Institute) is not
well understood or documented, particularly in the Rocky Mountain Region.
With the common practice of burning as part of the silvicultural program
in this area, it seems particularly important that these lesser understood
pollutant pathways be researched. Changes in water temperature can be
minimized with substantial buffer strips along the streams; but how narrow
these strips can be and still produce their desired effect is unknown.
Standards for stream temperature may be particularly difficult to evolve,
since it is conceivable that raising stream temperatures in some mountain
streams might be desirable in some cases (Oils et al., 1971).
There must be a massive coordinated effort to determine the
environmentally safe limits of forest manipulation in the northern Rockies.
This research effort would have to be directed specifically at gaining the
capacity to predict changes in valuable resources due to land management
practices in the forest. Because of the great variability of the region,
this task seems overwhelming. However, teams of researchers could
accomplish much by working on recently manipulated areas in the region and
comparing these areas with similar undisturbed areas. A concentrated effort
for a relatively few years should provide substantially better information
than is presently available. The possibility of a region-wide effort to
gain reasonable predictability should be seriously pursued.
More empirical research and additional synthesis on the impact of
clearcutting on stream values could be done rather quickly in the major
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l.ogginq regions of the United States. It is clear, however, that a phase
of that type of research would have to determine the effects of timber
harvest on water (or air) at various distances from the actual cutting and
at different times following harvest, concomitant with regeneration.
Research of this nature has been called for by the Forest Service, Congress,
and the National Academy of Science and others (e.g. U. S. Senate Hearings,
1971; N. A. S., letter of David Gates, 1972; The Institute of Ecology's
report: Man in the Living Environment, 1971).
A major problem noted on the Forest is that the reliability of
some predictive exercises is not known. Because of the dearth of
quantitative information, any new data may sway decisions on a multiple-use
area in a way that is not proportional to their accuracy or to the relative
importance of the resource being described. Conversely, if these data
seem contrary to existing plans, they may be discounted as weak. When
meeting individually with members of a planning team, it was apparent that
the specialists had different opinions on the predictive capabilities of
any one discipline. The specialist in a discipline often had less
confidence in his information than his fellow team members in other disci-
plines did. If a little quantitative data can become disproportionately
powerful in decision-making, the historical emphasis on and the heavier
staffing in timber and engineering (compared with landscape architecture,
hydrology, soils, geology and wildlife) must be viewed cautiously by the
Forest. Efforts to increase knowledge of water and other resources,
besides being needed, should help to balance the consideration of different
resources in decision making.
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For example, the key area of specialization in nonpoint pollution
problems is aquatic biology. While soil scientists, hydrologists,
geologists and others all contribute significantly to identification and
solution of problems, without considerable strength in aquatic or fisheries
biology the team is not properly balanced.
Since there is a clear and urgent need for greater predictive ability
on the Forest, the specialist should examine major projects after completion
as well as before. This procedure would permit gathering specific empirical
data on the Forest. At this time, specialists do not have the time to under-
take such activities. Much can be gained by cooperative efforts with the
USGS, SCS, Montana Departments of Fish and Game and Health, and universities.
However, fragmented efforts will not produce rapid, solid findings.
If the need for baseline data, well-designed quality standards, and
predictability is accepted, there must be research to determine these values
by various groups. The research arm of the Forest Service does not supply
the Flathead Forest with needed information on water quality. The
administrative arm of the Forest Service does not appear adequately funded
or able to undertake work on water quality with much rigor or depth.
The fact that some research has not been undertaken and that other
!
research is minimally underway in the region suggests that the research
community has not been promptly responsive to the demands of the NEPA.
Certainly the situation is improving somewhat, but the rate at which it
is improving is much too slow. The importance of NEPA to a forest such as
the Flathead, where almost all high level forest personnel recognize water
as the most important resource of that area, suggests that some sort of
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major coordinated effort to obtain needed water quality information must
be undertaken.
Management Personnel and Research Findings
Available information and new data will not be effectively used unless
they are known and accepted by Forest Service management personnel and timber
purchasers. The Flathead is making efforts to inform its field people and
the purchasers' crews of the reasons for environmental precautions. The
Forest specialists serve as instructors of District personnel, as well as
planners. However, ways of fostering more effective communications among
researchers, specialists and field people should be determined.
A problem referred to frequently in our visits to the Forest was that
of overdoing scarification. Three factors of particular importance in
sediment control are the quantity and intensity of run-off, the
susceptibility of ground cover and mineral soil to erosion, and the quantity
and placement of certain types of forest debris (Midwest Research Institute,
1973). The awareness of the sale administrator and the heavy equipment
operator to the latter two factors and skill to doing something about them
is essential to minimize environmental disruption. Over-scarification is
a prime example of creating conditions which will enhance the erosion
potential of a harvested area.
Another important need at the ground level is more information on
Environmental Impact Statements and more effort to select the best
personnel for preparation of these statements. The Environmental Statement,
if well done and if accepted as positive management concept, can be a very
useful management tool. The approach used by some Forests in preparing
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statements is being investigated in a study funded by CEQ (R. Spray,
Bitterroot National Forest, personal communication). Considerably more
effort could be put into Environmental Statements than has been in the past.
The personnel preparing them should be qualified and willing to undertake
this time-consuming and important procedure.
Environmental Statements seemed to be considered, at least in some
circumstances, a hurdle to management action rather than a tool. Research
should be undertaken (1) to describe statement preparation in greater
detail (i.e., Federal regulations must be more specifically interpolated),
(2) to determine or describe the required background of responsible persons
in statement preparation, and (3) to define the time and staff required to
prepare adequate, useful statements.
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VI. RECOMMENDATIONS
The policies and guidelines of the Forest Service in regard to en-
vironmental legislation show generalized response toward management
practices that prevent and control air and water pollution. However, the
requirements of new legislation and new national policies and guidelines
are not fully recognized. Many of the guidelines and policies are yet to
be incorporated into operating procedures and interpreted into action.
The level of scientific knowledge is never adequate to provide perfect
predicability of the expected consequence of forest resource decisions.
This fact does not eliminate the responsibility to make full use of what is
available and to work constantly toward improving predicability. Changing
conditions, particularly those involving the changing expectations of people,
make new and changing demands on the requirements and dimensions of
knowledge required for forest management decisions.
This study has attempted to point out the strengths of the present
management programs on the Flathead National Forest as well as to identify
weaknesses and needed directions. The strengths and positive directions
are encouraged and supported. It is the responsibility of this report
to make recommendations to improve weaknesses in a realistic and logical
manner.
It is not possible to judge whether or not the Flathead National
Forest meets the environmental criteria established by law. It cannot be
said to be operating consciously within the safe limits imposed by the
natural environment because those limits have not been determined. There
is little data on stream hydrology, soils, sedimentation, nutrient
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movement, channel scouring, productivity, or other information about the
environment which might provide a basis for predicting the results of
management activities. Ocular observation provides the present basis for
determining results. Observation is always useful but it cannot provide
the precision needed to conform to the new environmental laws.
Many studies and documents have been cited in this report that have
made comprehensive recommendations to improve forest management practices.
These recommendations can be reviewed by referring to documents identified
herein. The recommendations developed in this report are intended to
identify methods and approaches for accomplishing specific goals.
The changes needed to comply fully with the present and emerging
requirements are considerable but not impossible. If the Flathead National
Forest> or even the Forest Service as a whole, were required to meet
these changes by itself, the task might well be impossible. However, the
law provides for a widely based, coordinated approach of Federal, State
and local agencies working with citizens to accomplish certain desirable
goals. It calls for establishing new working relationships in accomplish-
ing these goals.
The recommendations, if acted upon, will significantly increase the
level of scientific knowledge necessary to respond adequately to the
national environmental goals and policies that have been established by
legislation and Executive order. The program outlined in the recommendations
is recognized as not being all inclusive. They are intended as a beginning
point, a prelude to more comprehensive and detailed program.
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Recommendation l_
Develop a coordinated air and water quality monitoring program
among Federal and State agencies, for:
A. Air Quality
1. The Forest Service Regional Office (Rl) should take the lead in
meeting with State air quality personnel with the specific goal
of having a system operating in the Flathead National Forest by
the 1975 field season. This system should be designed for
purposes of evaluating effects of slash-burning.
2. The Forest Service should develop a proposal for a system to
predict emmission loading (particulates) from slash burns of
varing intensity and varying fuel loading. This should be an
effort of research with funding by EPA, State of Montana, and
Forest Service programs.
3. Develop a reporting system to be used during slash burning periods
to record information necessary for evaluating effects of slash-
burning. The system need not be complex. This effort should be
coordinated by the State of Montana with cooperation from EPA and
all land management agencies involved in open burning. This should
be in operation by the 1974 fall burning season.
B. Water Quality
1. The Flathead National Forest should design and establish a water
quality monitoring system using the following parameters as a
minimum:
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Temperature
Dissolved Oxygen
PH
Suspended Solids
Flow
Turbidity
Specific Conductance
Additional parameters for recreation areas and municipal watersheds:
Coliform
BOD
The Environmental Protection Agency should assist in designing the
monitoring system. Data from the system should be compatible and
added to the EPA STORET System.
2. The Forest Service Regional Office (Rl) in cooperation with the
Intermountain Forest and Range Experiment Station should^expand
its program to establish a network of benchmark research and
monitoring watersheds to provide the long run knowledge on the
environmental effects of forest manipulation.
The Coram Research Forest may be a convenient starting point,
correlated with other watershed research established in the region
by the Experiment Station. Work on the University of Montana
Forest and Conservation Experiment Station, work at the University
of Idaho and other universities can provide direct and continuing
knowledge for the Flathead and other forests of the region.
The "benchwork" program should be worked out cooperatively
with other federal agencies, appropriate state and local agencies
and institutions.
3. The Forest Service Washington Office develop a coordinated monitor-
ing program, including benchmark and forest operational programs,
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for the Rocky Mountain region. A group of universities from
every state in this region working together as the Eisenhower
Consortium and the Committee on Future Environments of the
Rocky Mountians of The Institute of Ecology are presently
earring out a study of research needs and priorities (Rocky
Mountain Environmental Research - Quest for a Future). The
study is funded by NSF-RANN, the Forest Service and EPA. The
research inventory will prepare the way for broad-guage inter-
disciplinary research programs to be carried out cooperatively
by universities and public agencies. The strength needed in such
a broad and complicated field needs the critical mass provided by
such cooperation.
4. The Flathead Forest should amplify its water quality monitoring
system with temporary systems to monitor individual projects.
Such systems have been recommended from time to time by specialists
on the Flathead and from the regional office. Keyed to the
monitoring system on the forest, such temporary systems can
amplify the permanent system and accelerate knowledge accumulation.
5. The Forest Service Regional Office (Rl) should initiate a workshop
to review existing water quality standards to determine applica-
bility to forest management. This workshop should identify
needed changes and improvements. Involved agencies would be the
State of Montana, The Environmental Protection Agency, and the
Forest Service. This effort should lead to revision of standards
or adoption of additional standards that may be more applicable to
forest management activities.
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Recommendation H_
A. Develop relationships with EPA and the State of Montana in relation
to nonpoint pollution. The Environmental Protection Agency should
hold a workshop to discuss the study findings in relationship to the
National Silviculture! Demonstration Project being carried out by EPA
Region X. This workshop should include EPA Regions VIII and X,
University of Montana Study Team, and Personnel from the Flathead
National Forest and Northern Regional Office. This should be
carried out as soon as possible to maximize benefit to the National
Demonstration Project.
B. The EPA should prepare and present a briefing outlining the strategies
and regulations for achieving prevention and control of nonpoint
source water pollution. This should include key representatives
from the Forest Service Regional Office and from individual^ forests
in the region.
C. The State of Montana should prepare a briefing to outline the area-
wide basin planning effort and identify needed input from forest
management agencies. This should be carried out at a joint conference
of involved agencies.
Recommendation III
Develop a comprehensive and cooperative data storage and retrieval
system as an aid to the forest management decision process to include data
on air and water quality. While it would be desireable to explore a
number of available systems, the Timber RAM model now used in timber
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management has considerable possibilities for adaptation to include more
comprehensive data storage and analysis. Both short run and long run
plans should be initiated:
A. Short Run - There exists a great deal of knowledge, some of it
being used some of it not, which can be made available and put into
use in decision making. The systematic use of present knowledge is
the best and fastest available method for strengthening the scientific
basis for decision making on the Flathead Forest. To initiate this
process two steps are needed:
1. The Regional Office should make available to the Flathead Forest
an analyst who is highly skilled in the use and potential
applications of the RAM program and similar analytical methods,
and assign him the task of quantifying available knowledge.
Staff specialists should assist him by dedicating a reasonable
amount of their time to help collect existing data from all
possible sources--e.g., universities, government agencies,
industrial firms, etc. Where existing information is simply
unavailable or completely unreliable, the analyst should fall
back on expert opinion, heuristics, or other forms of surrogate
data. While a vital need exists for more and better information,
it is abundantly clear that a great deal of existing information
is not being used to maximum advantage. A good analyst on staff
could do much to overcome this situation.
2. The EPA and Forest Service should provide for a workshop involving
the RAM expert, the Flathead staff, regional staff, experts from
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universities, other agencies and other appropriate groups to
help in gathering and making data available. A side benefit of
the workshop would be the identification of critical information
needs that could be passed on to researchers in the Forest
Service and at universities.
B. Long Run - Refinement of knowledge, data storage and retrieval and
its use in decision making needs to become a continuing process.
Exploration of new systems, their use by field administrators and
continued feedback to research and other knowledge sources should
become part of standard operation. To be most effective the process
needs to be coordinated with all appropriate agencies and institutions.
Recommendation IV^
The Flathead National Forest should increase the number of staff
specialists and provide greater opportunity for education, development,
and effectiveness.
A. Additional specialists are needed to carry on new and expanded functions:
1. To install,and maintain monitoring systems
2. To make preliminary studies of planned projects
3. To review completed projects
4. To make inventories needed for long range planning
5. To communicate knowledge to and train field personnel
6. To identify and relate research needs to appropriate organizations
7. To translate research results and other available knowledge to
field use.
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B. More opportunities for self-development need to be provided for
specialists:
1. To attend professional meetings
2. To meet with other specialists from other forests and regions
3. To observe work in other areas
4. To attend refresher courses or enroll for advanced work
5. To have access to current literature and time to assimilate it
6. To generally have more interchange with people in their field
C. Additional specialists are needed in several fields
1. Soil scientists and hydrologists were most frequently mentioned
2. The need for fisheries biologists may not appear so obvious but
the need should be emphasized. An important part of water
quality monitoring involves biological considerations. The
fisheries biologist is best qualified to identify and measure
these. Frequent mention was made in Flathead plans and reports
that the critical consideration in water quality was for the
welfare of the native cutthroat trout. This fish appears to be
the critical natural monitor of water quality in the Flathead.
This fact emphasizes the need for fisheries biologists.
D. Communication between specialists and decision makers should be
strengthened. While it appeared to be generally good, some further
coordination seems desireable, especially as more specialists are
added to the staff.
1. A coordinator of substantive staff recommendations would serve to
strengthen and clarify specialist recommendations. While the
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deputy Supervisor now coordinates the activities and recommenda-
tions of the specialists just as he does those of other program
staff, a coordinator of the scientific areas would help to
balance the recommendations of the specialists and put them in
better perspective. Such a man would have to be a generalist
in a sense but well enough based in the scientific areas to
command the respect and cooperation of the specialists on the
one hand and with an understanding of the Forest Service programs
on the other. Such a man might be hard to find and would require
specific training for the job.
2. Opportunities for interchange of information and training programs
between administrators and specialists should be emphasized. As
each keeps the other informed of his activities, plans, and progress
general effectiveness and job satisfaction will remain high.
Recommendation V^
The Flathead National Forest should shift more manpower to accelerate
the vital resource inventory needed for well based planning. The
planning process is suffering from lack of factual on-site data needed to
translate planning into responsible action. If additional manpower cannot
be made available, some of the effort now devoted to planning should be
shifted to data gathering in order to achieve a better balance needed to
shore up the planning process.
Recommendation VI_
The Flathead National Forest with support of the Regional Office should
expand cooperative relationships and public participation in planning and
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operations. Cumulative effects of all programs must be recognized,
effects are accelerating and their interrelationships are becoming more
complicated. With Flathead Lake the focus of this growth, the importance
of water becomes primary in management decision. The example of Lake
Tahoe vividly illustrates the need for careful, integrated planning as a
coordinated effort of all agencies in the Flathead Valley.
A number of areas for cooperation are apparent:
A. In conjunction with establishing the air and water quality monitoring
program for the Flathead National Forest in cooperation with other
Federal, State and local agencies, comparative programs should be
initiated on three other national forest in the region. The State is
proposing a coordinated monitoring program of State agencies (EQC, 1973
annual report), which should be the nucleus of a coordinated program
involving Federal agencies. Methods, procedures, responsibilities
and financing would need to be developed. Data storage and retrieval
systems could be developed. Goals, standards, criteria and management
recommendations could evolve from the results of such a program.
B. In connection with the new timber management plan to be developed
for the Flathead National Forest during the next eighteen months, the
Forest Service should invite cooperation from other agencies,
universities and others to develop a new program that will provide
additional information and a multiple use approach to forest management.
This interdisciplinary approach should be expanded and used for other
operations on the Forest as directed by NEPA. The cooperative
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arrangements should include the preparation of environmental impact
statements, long range plans, inspections, and programs in substantive
areas, e.g., timber sales, road layout and construction, soils,
hydrology, wildlife, range and fisheries. The Flathead could serve
as a pilot area to develop cooperative interdisciplinary programs
on the national forests which would greatly expand the sources of
knowledge for national forest management.
C. The Forest Service should work with Federal and State agencies to
develop responsibility for enforcement to meet new requirements on a
cooperative basis with State and Federal agencies involved, (an
inspection-review system)
D. The process of public participation should be encouraged and expanded
to include such topics as: the assumptions on which the annual
allowable cut is based; the cause and effect relationships of roads
and timber harvesting and the precautions being taken; forest
stratification; resource inventories; plans and program; the policies
and guidelines under which the Forest Service operates; enforcement
procedures, and other matters.
Recommendation VII
The expertise available at all levels in the Forest Service should be
fully utilized to expand the scientific approach to environmental manage-
ment.
Hydrologists, soils scientists, geologists, biologists, silviculturists
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as well as administrative staff have at various times recommended that
monitoring be done. They have recommended new policy statements and
they have urged the expansion of scientific staff. This is the normal
growth, the expected reaction of new lines of staff in an organization.
The administrator has to balance these demands with the many others he
encounters. The existence of such a staff, pushing for greater respon-
sibility within the organization, displays strength in these fields that
can easily be built upon.
. Recommendation VIII
The staff of the Flathead National Forest should be given freedom
and authority to develop programs (including levels of timber harvest)
and needed budgets to meet established needs and priorities from an
understanding of local conditions.
Recommendation ^X
The programs so developed should be authorized and the budgets funded
S V
by higher levels at the Forest Service and the office of (Manpower and
Budget.
Recommendation X_
The Congress should authorize and fund and the Administration direct
the Office of Manpower and Budget to fully support a new program for the
Forest Service directed toward environmental management of all forest
resources (Spurr, 1974). Such a program to include:
a. An assessment of anticipated demand and supply, possibilities for
improvement, programs, policies, and research.
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b. A new and expanded inventory system of all lands and resources on
an integrated basis.
c. An expanded resource planning program, coordinated with other
agencies, Federal, State and local.
d. A national forest program which recognizes the requirements of
resources: air, fish and wildlife, grazing, recreation, soil, timber,
water, in an optimum way suited to the needs of each forest.
e. The funding necessary to carry out such a program.
Funding in the past has been directed toward consumption of old
growth timber, a depleting activity (Clawson, 1974). The new program for
management of the total forest resource needs to be aimed at productive
activities which should have a cumulative effect of forest improvement
in all aspects including the environment.
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VII. SUMMARY
The study of "Policies, Guidelines and Enforcement Procedures
Affecting Prevention, Control and Abatement of Air and Water Pollution
Resulting from Forestry Practices on the Flathead National Forest,
Montana," analyzed the response to recent Federal legislation. Of special
concern was the provision for identification and control of nonpoint
sources of water pollution as required in the Federal Water Pollution
Control Act Amendments of 1972. The study also analyzed response to the
Clean Air Act, the National Environmental Policy Act, and related Executive
orders and guidelines.
The Flathead National Forest has come a long way under difficult
circumstances to develop a strong environmental program, a program which
constrasts sharply with what existed before 1971. However, it is obvious
that the Flathead National Forest still has some distance to go before it
meets the goals and criteria established by law.
Although hemmed in by budgets and traditions that emphasize timber
production and limit consideration of other uses and environmental effects,
the supervisor and staff of the Flathead Forest have been able to make
substantial changes. It appeared a number of times that the Flathead
Forest was as far ahead as it could possibly get in terms of support and
tolerance from the regional and Washington offices. The opinion was
expressed by many sources both within the Forest Service and outside that
environmental concerns and action on the Flathead are beyond those of most
other national forests in this region and throughout the nation.
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It is the belief of the study team that the main reasons that the
Flathead has not gone further He with the Forest Service itself and with
the forestry profession, neither of which have been able to provide better
knowledge for use of the Flathead and other national forests. The forestry
profession and the Forest Service have been too preoccupied with the
harvesting of timber and have not given sufficient emphasis to developing
knowledge in other areas of forest management. Knowledge of timber
growing is seriously lacking in comparison with timber harvesting, and
only lip service is being paid to multiple use. Because understanding of
uses other than timber is weak and understanding of how these uses
interrelate is even weaker, there is little to offer in facing the new
problems, particularly those involving water pollution control.
The Forest Service is aware of the laws, but specific policy and
guidelines for the Water Pollution Control Act Amendments of 1972 have not
yet appeared. Mentioned so far only in the hydrology handbook, water
pollution control standards do not have direction form Washington or the
Regional Office. There is no awareness of them yet on the Flathead
Forest becuase no direction has come to the field. No effort has yet
been made to work with the State in setting up an areawide waste treatment
planning process in the Flathead Valley. By contrast, an agreement on
slash burning has been worked out with the responsible State agencies and
is in operation. The Flathead is aware of the fact that the State may
halt slash burning and is working on alternative methods of slash disposal.
The most significant determinants of non-point-source air and water
pollution were found to be the magnitude and character of forestry operations,
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primarily timber harvesting and road building. As a consequence of these
activities, watershed balances may be and have been upset and there is
evidence of accelerated erosion and siltation.
The Flathead National Forest is primarily in the timber production
and road construction business. Therefore, with respect to air and water
pollution, the Flathead is in a "high risk" category.
Intolerable levels of water pollution have been generated in the
past, as documented in Forest Service records. There is evidence that
the primary cause of pollution has been the past character of timber
harvesting and road building. The magnitude of harvesting and road
building remains essentially the same today; if this magnitude is to be
maintained, significant improvements in the character of management will
be necessary. The Flathead National Forest has recognized this, and has
made a noteworthy beginning. It is aware that in order to maintain the
present level of timber production, harvest will have to be pushed into
areas of greater risk environmentally.
A number of steps have been taken to reduce the adverse effects of
timber harvest and road construction. The steps that have been taken are
significant. An interdisciplinary approach to problem identification
and solution is provided by a staff of specialists in various resource
areas. New practices and procedures recommended by these experts have
been instituted. However, there is still a lack of data to prove or
disprove the environmental results of forest activities.
At various times Forest personnel have urged monitoring to obtain
knowledge of the effects of forest practices, but at this time almost none
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has been initiated. There are virtually no data on stream hydrology,
soils, sedimentation, nutrient movement, channel scouring, and productivity.
In short, there is no Information about the environment that might provide
the Forest staff with some reasonable basis for predicting the results of
its activities. Passive observation provides the present basis for
determing results. Observation is always useful but it cannot provide the
precision needed to conform to the new environmental laws.
The Flathead Forest cannot be said to be operating consciously within
the safe limits imposed by the natural environment, because these limits
have not been determined; and there was no evidence of an effort to
determine these limits. The process of timber inventory and estimation
of allowable cut were examined, and the basis for environmentally sound
timber management did not appear to be adequate. It was evident at every
turn that there is no monitoring, evaluation or control. Lack of know-
ledge makes it impossible to determine the direct or indirect effects of
forest activity. Little if any consideration is given to cumulative
effects. Some attempt is made at restoring previous damage but there
appears to be no continuing program. In fact, except for observation,
there is no measurement of the extent of past damage. No effort has been
made to supply the data needed by the State because there is little to
offer.
There were instances in which Forest Service timber management
practices were undertaken on the basis of a dangerous environmental
strategy: the assumption of the environmental adequacy of practices in
the absence of contrary proof. This appeared to be a matter of agency
policy, not peculiar to the Flathead. This strategy is in direct conflict
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with the National Environmental Policy Act, and needs to be reversed:
practices should not abe undertaken until they are proven safe.
The weakness of data on cause-and-effect relationships was most
evident in the consideration of alternatives in the environmental
impact statements. No rational range for decision was identified, and
no proof was given that the limited alternatives presented were within
that range. Without such knowledge, the statements became justifications
rather than true evaluations.
The statements are full of justification for cutting, supported by a
considerable amount of data on timber volumes and growth, while information
on the soil, water, geology, and vegetation is meager, particularly as to
the effects of manipulation.
Without the basic knowledge, the Forest Service cannot effectivly
define and defend its decisions, and so the decisions become subject to
outside pressures. The interest group activity thus becomes a game with
short-run winners and losers, but in the long run there are only losers.
Decisions based on knowledge are sources of strength against pressure, and
in the long run there will be only winners.
Knowledge provides for considering a range of alternatives and also
identifies the safe limits of manipulation within which activities can
operate without environmental damage. It does impose restrictions on
activities but these restrictions are now called for by law. The effect of
the new legislation is to require a knowledge base for sound management
not only for environmental protection but for sustained yields of all the
goods and services derived from the forest.
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To operate legally, the Forest Service must develop a system for
gathering knowledge by a greatly improved inventory of the whole forest,
not just the timber; it must monitor and evaluate cause and effect
relationships; it must organize knowledge so that it can be easily
retrieved and used by the decision maker. The decision makers in turn,
must make visible decisions which can be analyzed for improvement. By
doing so, the forester can take his place as a responsible decision maker
and earn the credibility which has been lacking. The Forest Service must
become engaged deliberately and directly in the pollution control
business: it is a matter of law, not choice. But instead, in the Flathead
River drainage today, the Forest Service is almost exclusively in the
timber production business. By no means is this a course preferred by
the Flathead National Forest, nor by some other elements of the agency
hierarchy. One major cause is the action of the Office of Management and
Budget: the Forest.Service and the Flathead are paid only to sell timber
and build roads. Through impoundment of funds, primarily, OMB has
dictated the imbalance of Forest Service programs.
The long range planning program of the Flathead has much merit
and can be adapted to the study team's recommendations. It starts with
generalized virture and gives promise of providing specific answers
sometime later. This it can do if it goes far enough, but it cannot go
far enough under the present state of knowledge. The planning program can
be prepared, however, for the inclusion of the necessary information at a
later date. Meanwhile it should give plenty of leeway for lack of
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knowledge and the attendant uncertainties.
Specific pollution control decision under the new organization are
to be made in the field, and general policy platitudes are largely
inescapable at the Washington, regional and forest levels. But the field
decisions were found to be as broad and general as the Washington office
pronouncements. The generalities expressed in the EIS's on timber
management and roads were also to become specific on the job. But again,
the information is not available for doing that except in a very general
way.
By adding a stage III, IV or V to the long-range planning program,
arrangements can be made to develop the necessary knowledge. This could
start by accumulating the facts now available, with proper help. In so
doing, particular attention must be paid to the information gaps. In
this manner the planning program can help identify the need for knowledge
as a guide for research. It should also provide for data development on
the Forest; by monitoring, and by recording facts gleaned in actual
operations, the Forest can become its own knowledge source.
The new legislation requires new cooperative relationships with other
Federal agencies, state agencies, universities, and the public. The
Forest Service has tended to remain technically and professionally isolated
and autonomous. New cooperative programs need to be developed.
The Flathead should be drawing on outside help at every opportunity
to improve its interdisciplinary approach. It should draw on such help in
its new timber management plan, starting with a new inventory system that
accounts for all forest resources and values. The weakness of forest
-------
-197-
management in the Forest Service has been the weakness of its single-
resource inventories augmented by its assumptions, hidden or declared,
on how the data are used.
The recommendations offered by the study team are aimed first at
developing knowledge and systems for making knowledge available to the
decision makers. Secondly, they emphasize coordinated effort in
monitoring, planning, and management programs. And, finally they call
for a new program for broad based, responsible management of the National
Forests and the necessary funding to carry it out.
-------
-198-
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Bolle, Arnold W. 1959. The basis of multiple use management of public
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Casey, Osborn. 1971. Streamside logging vs. water temperature. Progress
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-199-
Dieterich, J. H. 1970. Air quality aspects of prescribed burning.
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Forcier, Lawrence K. and Robert F. Wambach. 1971. The Lubrecht
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Fritschen, L. 1970. Slash fire atmospheric pollution. USDA Forest Serv.
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Handler, Philip. 1974. President National Academy of Sciences. Letter
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the intermountain west. Symp. Proc. Missoula, Mont.
Johns, W. M. 1964. Progress report on geologic investigations in the
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County and Northern Lake County. Montana Bureau of Mines and
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Johnson, 0. 1959. An examination of vertical wind profiles in the lower
layer of the atmosphere. Jour, of Meterology 16:144-148.
Kirkpatrick, R. 1969. Smoke management systems. Proc. Western Forestry
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Konizeski, R. L. et al. 1968. Geology and ground water resources of the
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Geology Bull. 68. 42 pp.
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-200-
Koppe, R. K. 1970. Dispersion of prescribed fire smoke. Jour, of Air
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Likens, G. E., F. H. Bormann, N. M. Johnson, D. W. Fisher and R. S. Pierce.
1970. Effects of forest cutting and herbicide treatment on nutrient
budgets in the Hubbard Brook watershed-ecosystem. Ecol. Monogr.
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Marks, P. L. 1971. A vision of environment. American Scholar 40:
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Megahan, W. F. and W. J. Kidd. 1972. Effects of logging and logging
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Metcalf, Lee. Senator from Montana. July 21, 1973. Congressional
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Midwest Research Institute. 1973. Processes, Procedures, and Methods
to Control Pollution Resulting from Silviculture! Activities. EPA.
U.S. Govt. Printing Office. Washington D.C.
Montana Fish and Game Laws. Revised from 1971-1973. Helena Fish and Game
Department, Helena, Mont.
Montana Department of Natural Resource and Conservation. 1973. Final
Environmental Impact Statement: Proposed Hungry Horse Weather
Modification Project, Helena, Mont.
Montana State Department of Health and Environmental Sciences, Air
Pollution Control Construction and Operating Permits, Regulation
No. 90-001. Adapted March 23, 1969, Rev. 1/9/70, 7/10/70, 6/24/72;
Regulation 90-002, 90-005, 90-009, 90-011, 90-014. Helena, Mont.
Montana State Department of Health and Environmental Sciences. 1970.
An Air Quality Study of the Libby and Flathead Valleys. Helena, Mont.
. 1972. Summary of Primary Functions and Responsibilities of the
Environmental Sciences Division. Helena, Mont.
. 1973. Montana Laws Regarding Water Pollection 69-4801 to 69-4827.
Helena, Mont.
. 1973. 16-2.14 (10) - SI4480 Water Quality Standards. Helena, Mont.
. 1973. MAC 16-214 (10) - SI4480 Water Quality Standards. Helena, Mont.
The Clean Air Act of Montana, 69-3904 Chapter 313, 1967 Legislative Session,
Helena, Mont.
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-201-
Montana Water Pollution Control Council. 1967. Water Quality Criteria,
Helena, Mont.
Montana, Chapter No. 506, Montana Session Laws. 1973. House Bill 217,
An act to grant additional powers to the Department of Health and
Environmental Sciences — complying with the FWPCA amendments of 1972.
Murphy, J. L. 1970. Research looks at air quality and forest burning.
Jour, of For. 68:530-535.
National Forest Products Association. 1973. Report on Government and
Forestry Affairs. Washington, D.C.
Navon, D. I. 1971. Timber RAM. USDA Forest Serv. Res. Pap. PSW-70.
Pacific Southwest Forest and Range Exp. Sta. Berkeley, Calif.
Packer, P. E. 1967. Criteria for designing and locating logging roads
to control sediment. For. Sci. Vol. 13. P. 107.
. 1971. Terrain and cover effects on snow melts in Western White
Pine forest. For. Sci. Vol. 17, No. 1. P. 125-134.
Pfister, Robert D., Stephen F. Arno, Richard Presby, and Bernard Kovalchik.
1972. Preliminary forest habitat types of western Montana. USDA
Forest Service, Intermountain Forest and Range Exp. Sta. and Region 1.
89 pp.
Pierce, R. S., C. W. Martin, C. C. Reeves, G. E. Likens, and F. H. Bormann.
1972. Nutrient loss from clearcuttings in New Hampshire. Om
Proceedings of a Symposium on Watersheds in Transition, P. 285-295.
Fort Collins, Colorado, June 19-22, 1972. America Water Resources
Association. Urbana, 111.
Seastedt, T. R. and John F. Tibbs. 1974. Land Use and Water Quality in
the Flathead Drainage. Prepared for: Pacific Northwest River Basins
Commissioner, U.S. Environmental Protection Agency, Montana Department
of Natural Resources and Conservation, Montana Department of Health
and Environmental Sciences. Univ. of Mont. 155 pp. (cf. for
additional references)
Smith, William H. 1972. Air Pollution -- Effects on the Quality and
Resilience of the Forest Ecosystem. Paper presented at AAA's Annual
Meeting. Washington D.C.
Spurr, G. 1959. The penetration of the atmosphere imersions by hot plumes.
Jour, of Meteorology 16:30-37.
Spurr, Stephen H. 1974. Timber and the environment -- Reflections on
American Forest Policy. Jour, of For. January. 17-20 pp.
-------
-202-
The Institute of Ecology. 1971. Man in the living environment. Report
of the workshop on global ecological problems. The Institute of
Ecology. Madison, Wise. 267 pp.
. 1974. Rocky Mountain environmental research -- quest for a future.
Progress report: June 1973 - January 1974. (J. M. Neuhold, Director).
Ecology Center. Utah State Univ. 76 pp.
United States Senate. 1972. Clearcutting guidelines on federal timberlands.
Committee on Interior and Insular Affairs. Subcommittee on Public
Lands. 13 pp.
United States Congress, Subcommittee on Public Lands and Committee on
Interior and Insular Affairs. 1972. Clearcutting on federal
timberlands. U.S. Government Printing Office. Washington, D.C.
1247 pp.
United States Congress. 1973. A legislative history of the water pollution
control act amendments of 1972. 2 volumes, U.S. Government Printing
Office. Washington, D.C. 1766 pp.
United States Council on Environmental Quality. 1973. Preparation of
environmental impact statements: guidelines. Federal Register.
Vol. 38, No. 147, Part II. Title 40, Protection of the Environment;
Chapter V. Washington, D.C.
United States Environmental Protection Agency, Office of Air and Water
Programs. 1973. Processes, procedures, and methods to control
pollution resulting from silvicultural activities. U.S. Government
Printing Office. Washington, D.C. 91 pp. (cf. for additional
references)
United States Environmental Protection Agency. 1973. Methods for
identifying and evaluating the nature and extent of nonpoint sources
of pollutants. U.S. Government Printing Office. Washington, D.C.
261 pp.
-__. 1973. The control of pollution from hydrographic modification.
U.S. Government Printing Office. Washington, D.C. 188 pp.
. 1973. Methods and practices for controlling water pollution from
agricultural nonpoint sources. U.S. Government Printing Office.
Washington, D.C. 83 pp.
. 1973. Comparative costs of erosion and sediment control,
construction activities. U.S. Government Printing Office. Washington
D.C. 205 pp.
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-203-
United States Environmental Policy Agency, Office of Air and Water Programs.
1973. Processes, procedures, and methods to control pollution
resulting from all construction activity. U.S. Government Printing
Office. Washington D.C.
United States Environmental Protection Agency Region X. 1973. Clothier,
Wm. D., Gerald N. Patchen, Elbert More, and William B. Johnson
(mimeo). Silviculture project on nonpoint source pollution control.
Seattle, Washingtion.
United States Department of Agriculture, Forest Service, Northern Region.
1958. Full use and development of the timber resources of Montana.
Missoula, Mont.
United States Department of Agriculture, Forest Service. 1971. A procedure
for determining the hydro!ogic impact of vegetation manipulation by
regional hydrologists. Missoula, Mont.
United States Department of Agriculture, Forest Service, Northern Region,
Intermountain Station. 1973. Cooperative studies of the use of
fire in silviculture. Status Report #2. Missoula, Mont.
United States Department of Agriculture, Forest Service. 1973. Spotted
Bear Country. Flathead National Forest. Publ. No. Rl-73-010. 150 pp.
. 1973. Final environmental statement three-year road construction
program for the Flathead National Forest. Kalispell, Mont.
Forest Service Manual, Title 8400, Environmental Statements,
lay, 1973, Washington, D.C.
_. Forest Service Manual, Emergency Directive No. 1, (Chapter 1940 -
"Environmental Statements), July 13, 1971, Washington, D.C.
_. Forest Service Manual, Emergency Directive No. 1, (Chapter 1940 -
"Environmental statements), November 29, 1971, Missoula, Mont.
(A Regional supplement to E.D. No. 1 above, in item 2.)
. Forest Service Manual, Emergency Directive No. 3, (Title 2100),
"October 26, 1972, Washington, D.C.
Forest Service Manual, Emergency Directive No. 1, (Title 2100,
Multiple Use Management), November 9, 1971, Washington D.C.
Forest Service Manual, Emergency Directive No. 1, (Title 2100
ultiple Use Management), March 8, 1972, Missoula, Mont.
_. Forest Service Manual, Emergency Directive No. 2, (Title 2100
"Multiple Use Management), August 10, 1972, Missoula, Mont.
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. Guidelines for development of unit plans, Working Draft III,
"June 1973, Northern Region USDA Forest Service, Missoula, Mont.
_. Northern region program emphasis, December, 1971, revised November,
1972, USDA Forest Service, Missoula, Mont.
_. Management direction for northern region, March, 1972, USDA Forest
Service Region 1, Missoula, Mont.
_. Framework for the future: Forest Service objectives and policy
'guides, May, 1970, USDA Forest Service, Washington, D.C.
. Memorandum, Bitterroot management directive, from Regional Forester
"to Supervisor, Bitterroot National Forest, July 26, 1971.
. National forest management for a quality environment -- timber
"productivity, March 26, 1971, USDA Forest Service, Washington, D.C.
_. Timber management for a quality environment -- national forest
"management practices, Cl Report No. 6, May, 1971, USDA Forest Service,
Washington, D.C.
. National forest in a quality environment -- action plan, June 14,
1972, USDA Forest Service, Washington, D.C.
. National forest in a quality environment -- northern region --
"action plan, November 9, 1972, USDA Forest Service, Missoula, Mont.
. A proposal -- cancel Puzzle Creek timber sale contract, January,
1973, Environmental Analysis Report, USDA Forest Service, Northern
Region, Flathead National Forest, Kalispell, Mont.
. Flathead Forest multiple use plan, part I, October 8, 1971, USDA
":orest Service, Flathead National Forest, Kalispell, Mont.
. Flathead National Forest basic land management plan 1, December 23,
1971, approved by Regional Forester November 1, 1972, USDA Forest
Service Flathead National Forest, Kalispell, Mont.
. Flathead National Forest listening session: a basic step in land
"management planning, July, 1971, USDA Forest Service, Northern Region,
Flathead National Forest, Kalispell, Mont.
. Timber management plan, Flathead working circle, July 1, 1969 to
"June 30, 1979, Flathead National Forest, Kali spell, Mont.
. Draft environmental statement: interim revision — Flathead National
-orest ten-year timber management plan, May, 1973, USDA Forest Service,
Flathead National Forest, Kalispell, Mont.
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_. Forest organization study: Kootenai National Forest, Flathead
National Forest, March, 1971, USDA Forest Service, Northern Region,
Missoula, Mont.
_. Flathead National Forest budgeting and programming process, no date,
"Flathead National Forest, Kalispell, Mont.
. Flathead National Forest program of work 1973 F.Y., no date,
"Flathead National Forest, Kalispell, Mont.
. Flathead National Forest basic land management plan revised
/ebruarv, 1974, February 1, 1974 (approved by Regional Forest February
1, 1974), USDA Forest Service, Flathead National Forest, Kalispell,
Mont.
. Interim guide for water quality surveys in Region I, no date,
USDA Forest Service, Northern Region, Missoula, Mont.
. Highlights -- water pollution control act amendments of 1972 --
PL 92-500, no date, compiled by R. H. Wheeler, USDA Forest Service,
Northern Region, Missoula, Mont.
. Interim handbook on federal and state laws, executive orders, and
rules and regulations pertaining to water quality in Region I, no
date, USDA Forest Service, Northern Region, Missoula, Mont, (in draft)
. Multiple use plan, Spotted Bear planning unit and draft
environmental statement, February 24, 1974, Flathead National Forest,
Kalispell, Mont.
. Clearcutting as a siIvicultural tool in Northern Region National
Forests -- a policy statement. Memo of Steve Yurich to Forest
Supervisors, March 23, 1973, Missoula, Mont.
. Numerous reports, letters, memos from files and personal communi-
cation with many Forest Service staff on the Flathead National Forest,
the Missoula Regional Office and others.
United States Department of Interior, Bonneville Power Administration.
1973. Draft environmental statement: Hungry Horse cloud seeding
program. Portland, Ore.
United States Geological Survery. 1964-1972. Water resources data for
Montana. Surface Water Records for Montana. Water Quality Records
for Montana.
United States Report of the President's Advisory Panel on Timber and the
Environment. 1973. U.S. Government Printing Office. Washington, D.C.
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United States Federal Statutes. The National Environmental Policy Act
of 1969. 42 USC 4321.
. The Clean Air Act. 1970. 42 USC 1857.
. The Federal Water Pollution Control Act Amendments of 1972.
"33 USC 1251.
_. The Solid Waste Disposal Act. 1970. PL 91-512.
. The Federal Environmental Pesticide Control Act of 1972.
>L 92-516.
United States Executive Orders. Executive Order 11514. 1970.
. Executive Order 11602. 1971.
. Executive Order 11752. 1973 Amendments. Prevention Control and
Abatement of Environmental Pollution at Federal Facilities. Federal
Register, Vol. 38, No. 243. Washington, D.C.
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APPENDIX A
SOME RECENT PROPOSED POLICY STATEMENTS AND
GUIDELINES FROM THE FLATHEAD NATIONAL FOREST
AND THE REGION I OFFICE OF THE FOREST SERVICE
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Flathead National Forest
Kali spell, Montana 59901
2500 Watershed November 24, 1972
1440 Inspection
Water Quality Goals
Dave Minister
Program Coordinator
One of the Water Quality Goals the Region should establish is a definite
objective. So little has been done in the field of water quality that
it is difficult to develop a definitve goal. On the Flathead National
Forest, turbidity analysis was carried on for a number of years. There
was no objective established for the sampling and analysis program.
There was no interpretation of the data once it was analyzed.
Very little water quality data had been collected on the three rivers prior
to the start of the Wild Rivers Study. Consequently, it was decided to
establish sampling points at or near U. S. Geological Survey stream gaging
stations. Seven points were selected and samples collected by U. S. Geo-
logical Survey personnel from July 13 to July 16, 1970. The purpose of
this project was a complete sampling to isolate any problem areas. The
seven sampling points selected were:
1. South Fork of the Flathead above Harrison Creek.
2. South Fork of the Flathead above Twin Creek.
3. North Fork of the Flathead at the British Columbia border.
4. Middle Fork of the Flathead above Bear Creek.
5. Middle Fork of the Flathead at West Glacier.
6. Flathead River at Columbia Falls.
7. Flathead River near Columbia Falls at the stream gaging station.
The samples were sent to the U. S. Geological Survey water lab at Austin,
Texas, for insecticide and herbicide analysis. Sediment analysis was done
at the lab in Worland, Wyoming, and carbon samples were sent to Washington,
D. C. Other parameters were analyzed by the water quality lab at Lincoln,
Nebraska.
The parameters analyzed were:
Insecticiess Herbicides
Aldrin 2, 4-D
ODD Si 1 vex
DDE 2, 4, 5-T
DDT
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-209-
Dieldrin
Endrin
Heptachlor
Heptachlor epoxide
Parathion
Methyl Parathion
Diazinon •
All insecticide and herbicide analysis produced negative results.
parameters for which the samples were analyzed included:
Other
CO,
Silica
Aluminum
Iron
Manganese
Calcium
Magnesium
Strontium
Sodium
Lithium
Potassium
Conductivity
Total alkalinity
Total hardness
Temperature
Arsenic
*Beryllium
*Total chromium
Copper
*Nickel
*Silver
Total phosphate
Dissolved solids
CAL dissolved solids
Vindicates 0.00 values in all cases)
This analysis revealed no significant problem or reason to continue with
total analysis. Field sampling for the following parameters, which was
begun for some stations as early as August 1969, was continued:
Temperature
PH
Specific conductance
Total coliform
Dissolved oxygen
Bicarbonate
Carbonate
Alkalinitv or
Sulfate " °
Chloride
Fluoride
Nitrate
Dissolved ortho-phosphate
Boron
nH
Nitrate
Noncarbonate hardness
*Barium
*Cadnium
*Cobalt
*Lead
Molybdenum
Selenium
Carbon dioxide
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-210-
Turbidity
Total alkalinity
Total hardness
Aesthetic appearance
Odor
Deleterious substances
Suspended sediments
The sample site on the Flathead River near Columbia Falls at the gaging
station was dropped. A site on the Middle Fork at Schafer Guard Station
was. added. A Hach portable water lab model DR-EL was used for field
analysis. This model produces reliable results for detecting trends in
water quality. (McKee and Boar, an evaluation of Hach direct reading
engineer's laboratory, Lab. Invest. Series, FW PCA, Cincinnati, Ohio.
Sample sites at Harrison Creek, Bear Creek, and Schafer essentially reflect
"natural" conditions in that there is little'man-caused activity above
these sites. The sites at West Glacier and Twin Creek are affected by
road construction and logging. The site at the British Columbia border
on the North Fork is an indication of the water quality when it enters the
Forest. This is important in that the North Fork is the only one of the
three rivers that does not originate on the Flathead Forest. A total
integration of all three rivers is measured at the Columbia Falls site.
Water quality was generally good. Turbidity fluctuated with volume of flow,
temperatures and dissolved oxygen with time of year. Table 1 presents the
range of values determined as well as the number of times each site is
sampled. Samples were taken during peak flows, base flows, late fall/early
winter, and late winter/early spring.
The sampling system established for the wild rivers study will be continued
as a watershed management project on the Forest. This will provide
continuing refinement to the data as well as monitoring the river system.
It is not likely that any river-oriented recreation activities would be
precluded because of water quality problems on the three rivers. Increased
turbidity during peak flows might curtail some activities; however, weather
is usually poor during this period so that river use is low. Most recre-
ation activities are limited by climate and season and not water quality.
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Table 3 - Range of Values determined for selected water quality
parameters for seven stations within the Flathead Wild
Rivers Study Area.
_ Harrison Twin Schafer Bear W. Glac. Col. Falls B. C.
Inclusive Dates
NO. of Samples
I"
Spec. Cond. (MMHOS)
•is. 0 (mg/1) I/
furb. (J.T.U.)
otal Alk. (mg/1)
Botal Hard, (mg/1)
Total Coliform
1(col/100ml)
us. Sed. (mg/1)
!_/ Dissolved oxygen ranges are due primarily to fluctuations in water termperature.
Values range from 75-130% saturation.
2/ 400 JTU was recorded on 5/28/70 during spring runoff. This site is 1/4 mile
downstream from a large road cut that is a sediment source during high flows
and rain storms (See Photos 4 and 5). Suspended sediment analysis of this
sample measured 197 mg/1.
3_/ There was one pH value of 6.7, which is probably a sampling error.
The capacity of the river to purify itself is excellent. Normal bio-
chemical oxygen demand is very low as evidenced by oxygen levels at or
near saturation throughout the year. All three rivers have good pool/
riffle ratios, rough bottom, and relatively rapid velocities providing
ample recreation. If there is no increase in organic load into the
rivers, water quality will remain excellent.
6/2/70-8/18/72
7
8-9
140-340
8.5-16
0-65
60-137
60-188
0-5.1
i ^
I )
0-60
8/15/69-
8/30/71
10
8-8.5
140-210
8-16
0-400 2/
70-137
60-137
0
4-197
6/2/70-
10/16/72
8
8-8.7
162-340
8-15
0-58
95-205
70-160
0-7
0-101
5/13/70-
9/17/72
9
8-8.5 3_/
180-260
8-14.5
0-65
75-125
65-130
0-4
0-13
9/23/69-
8/17/72
12
7.9-8.7
130-240
8-14
0-95
60-110
70-105
0-4
0-252
5/14/70-
8/17/72
11
8.1-8.6
138-220
10-14
0-80
60-100
70-90
0-5.1
0-29
5/14/70'
10/16/72
9
7.8-8.8
132-270
8-15
0-80
75-160
75-160
0-75
0-17
-------
-212-
Generally speaking, the possibility of bacterial infection due to use of
untreated water from the three rivers is remote. In a study on the North
Fork, Sonstelie reports that the major tributaries are low in total coli-
form count. !_/ The study revealed some possible problem areas that should
be further investigated.
Sources of Sediment and Pollution
All three rivers carry a relatively heavy sediment load during high flows.
This can be observed by visually inspecting the rivers during high flow and
then again during low flows. The sediment sources are primarily the glacial
material through which each river passes. The rivers undercut steep-walled
banks until large portions of vegetation, rocks and soil are deposited in
the channel. This is a naturally occurring process and would be difficult
if not impossible to stop.. Attempts to control natural erosion would require
rehabilitation projects not in keeping with the wild river classification.
Additional sedimentation occurs from road construct!'on.and timber harvesting.
Some of these sources could be eliminated with rehabilitation projects.
Future problems can be avoided with proper planning concerning road location
and silviculture! methods used in timber harvest.
Sheet and gully erosion is minor to non-existent within the study area. The
entire study area lies within a low potential erosion hazard area. (Pacific
N.W. Rivers Basin Com., 1971, App. VIII, 1, p. 145, Fig. 10) Potential
sediment yield from forest land without protective measures is estimated to
be less than .2 acre feet/mi. (Pacific N.W. River Basin, Com., 1971, VIII,
1, p. 144, Tab. 78). While this is a low per square mile figure, the total
volume possible is significant. Consequently, it is important to take
erosion control measures on all timber-harvesting activities.
Sources of probable fecal contamination in the study area are campgrounds,
administrative sites, and areas where big game animals concentrate.
The entire study area lies within the State of Montana and is subject to
water quality standards established by the Montana Water Resources Board.
The State standards provide a guide for water quality management; however,
there are some shortcomings. Dissolved oxygen standards, for example,
should be reflected in percent saturation as well as absolute values in
milligram/liter. Absolute values fluctuate with temperature, and most
temperature changes in the study area are natural.
I/ Sonstelie - Personal communication - 1971.
-------
-213-
The standards refer to natural levels; however, there is no criteria for
determining natural levels. The field checking done on the wild rivers
study provides an indication as to naturally occurring levels; however,
there is little statistical reliability to the sampling and testing
procedure.
Another problem involved with using absolute values is that the standards
for turbidity are violated frequently during road construction. Installation
of a culvert in a live stream temporarily will raise turbidity levels
beyond maximum allowable limits. The same could be said about bridge
construction and other projects associated with timber harvesting and road
construction. A more realistic set of standards would set limits based on
values per volume of water per time. Improvement of water quality on the
three rivers is not so important as maintaining the high level now present.
Man-caused sediment sources can be corrected by rehabilitation and protection
measurements. Future management activities can virtually eliminate man-
caused sediment sources through utilization of proper land management
activities. The Pacific Northwest River Basin Commission has estimated some
costs for these measures. These are presented in Table 2.
Table 2 - Estimated Costs for Natershed Protection Practices on
Forest Land in the Flathead Wild Rivers' Study Area
(Table 88, App. VIII, Pac. N.W. River Basins' Com., 1971).
Practices Unit Cost/Unit
Logging Disturbance Treatment Acre $ 30.00
Harvest Road Treatment !_/ Mile $250.00
Other Watershed Requirements 2/ Acre $ 19.00
]_/ Includes road maintenance.
2/ Includes watershed surveys, prescription and plans, fire protection,
timber cultural practices, special road requirements, and other
indirectly related factors.
CONCLUSIONS
1. Field analysis with the Hach kit may not be producing sufficient
accuracy even for trend determination. Field analysis should be in
conjunction with lab analysis in order to develop confidence limits
for the field determination.
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-214-
2. The Forest needs assistance in establishing sample sites, sample
frequency, and sample parameters.
3. Determination of naturally occurring sediment loads is especially
imnortant to the Flathead.
4. Adequate funding and personnel are needed to do the job.
ROBERT G. DELK
Hydroloqist
RGDelk:da
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-215-
2500 Watershed January 22, 1973
Proposal for Regional Water Policy and Hydromet System
Regional Forester
In our meeting with you last spring, you invited comments from the
field. In response to this invitation, the Forest Hydrologists of the
Northern Region, as a group, respectfully submit these comments and
recommendations.
We are concerned about the passive attitude towards the water resource
which prevails under current multiple-use management and planning within
the Northern Region. Although the importance of water has been recognized
since the inception of the Forest Service, the land manager today all too
often feels that "water comes anyway without our help—why worry;" or water
is merely a design consideration for roads and timber sales. We believe
this attitude exists because a more positive and dynamic Regional water
policy is lacking.
It is our opinion that watershed management is in reality multiple-use
management applied to a watershed, and that the effects of the multiple-
use management can be measured by changes in water quality, quantity,
and timing of flow from the watershed. In this sense monitoring the water
resource is a quality control for the multiple-use management. By the
same token, this measurement of the water resource provides the hydrologic
information necessary in multiple-use long range planning as well as
project level planning. Without this basic hydrologic information it is
impossible to inventory the water resource itself against the likelihood of
increased user demands in the future.
For the above reasons we strongly urge the establishment of Regional
policy spelling out the role of the water resource in multiple-use manage-
ment. If Regional policy concerning water is limited to "keep it
relatively clean" following land management activities, then it should be
so stated. We feel, however, that water should be recognized as being a
natural resource to be managed along with timber, wildlife, range, and
recreation. We, therefore, recommend a policy statement to include:
Water i_s_ a_ valuable resource of_ the forest and range lands of_ the Northern
Region. 11 is the 'policy of the Northern Region of_ the U. S. Forest Service
that multiple-use plans wiTT include provisions to:
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-216-
1. Protect the existing high water quality,
2. Increase the amount of water when a_ need ;is_ demonstrated;
3. Modify the timing of water flow if the need is demonstrated
and tne technique Heveloped.
4. Improve water quality jn^ degraded streams.
No policy statement is any better than the means to implement it. The
implementation of this policy recommendation will require an aggressive
program to collect and analyze hydrologic data for establishing baseline
information to guide multiple-use management. As pointed out in the
recent Oils' Report, the basic hydrologic inventory is sadly lacking.
Several advanced techniques are available to facilitate the collection
and analysis program, but have not been widely used in the Region. These
techniques include a variety of specialized instruments designed to
measure various hydrologic and meteorologic parameters. Remote sensing
and telemetry systems are also available. Simulation models and other
computer apolications, already developed, could be used if the basic
hydrologic data were available.
Implied in a commitment to a sound hydrological and meteorological
(hydromet) collection and analysis program would be the funding and
personnel to do the job. Each forest would have different funding require-
ments that could be evaluated individually. Each forest would need at
least one full-time technician in the GS-5-9 category. It is possible
that joint hydromet programs with Forest Service research, universities,
and private concerns could be developed, as suggested in the Oils' Report.
Me strongly recommend that the Regional Forester give high priority to
establishing a hydromet program. We realize that if money is made
available for a hydromet program, another program may suffer at least
temporarily, but the long-term benefit of a hydrmet program would out-
weigh any short-term disadvantage. We feel this is a "must do" priority.
In summary, we have the firm conviction that if these recommendations are
adopted, the Northern Region can fully redeem the original Forest Service
mandate of "securing favorable conditions of water flow" for the "future
good of all people".
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/s/ J. Allen Isaacson
J. ALLEN ISAACSON
Coeur d'Alene National Forest
-217-
/s/ Clifford R. Benoit
CLIFFORD R. BENOIT
Northern Region
/s/ Leon D. Logan
LEON D. LOGAN
Gal latin National Forest
/s/ Jack L. Craven
JACK L. CRAVEN
Custer National Forest
/s/ Wallace L. Page
WALLACE L. PAGE
Beaverhead National Forest
/s/ Robert G. Delk
ROBERT G. DELK
Flathead National Forest
/s/ Dale J. Pfankuch
DALE J. PFANKUCH
Lolo National Forest
/s/ James E. Eggleston
JAMES E. EGGLESTON
Northern Region
/s/ David L. Rosgen
DAVID L. ROSGEN
Kaniksu National Forest
/s/ Robert S. Embry, Jr.
ROBERT S. EMBRY, JR.
St. Joe National Forest
/s/ William L. Russell, Jr.
WILLIAM L. RUSSELL, JR.
Clearwater National Forest
/s/ Alan F. Galbraith
ALAN F. GALBRAITH
Kootenai National Forest
/s/ Hilton L. Silvey
HILTON L. SILVEY
Nezperce National Forest
/s/ Herbert S. Garn
HERBERT S. GARN
Bitterroot National Forest
/s/ Richard H. Wheeler
RICHARD H. WHEELER
Northern Region
RGDelk:da
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t
Deportment of Health and Environmental Sciences
IcSTAI I— f*)C l\/im\l"nXIVIA MFIFNIA UTUUTAMA *c*ni
JohnSAndanonM.a
November 20, 1973 °""cro"
Dr. Arnold Bolle
School of Forestry
University of Montana
Missoula, MT 59801
Dear Dr. Bolle:
Pursuant to your November 19, 1973 conversation with Don Willems of
this office, I have bteen requested to outline our cooperative water sampling
program.
Beginning this past spring, we began analyzing stream and lake samples
collected by the Beaverhead and Helena National Forests and the Soil Conserva-
tion Service. Because of a general lack of water quality data in Montana,
the agreement is informal and quite open-ended. Basically, we analyze and
then share the results on any sample submitted. Since the above agencies are
most familiar with drainages in their jurisdiction, when and where to sample
is their prerogative. Generally, we have been analyzing for common chemical
constituents, pH, specific conductivity, plus selected heavy metals.
I doubt that many definite conclusions have been drawn because of the
brief sampling period. However, you may want to contact people we have been
working with. They are Walter Page (Beaverhead National Forest, Dillon) ,
Charles Harnish (Helena National Forest, Helena) , and Phillip Fames (SCS,
Bozeman) .
Unfortunately, our present laboratory capability does not permit
additional cooperative sampling at present. However, I hope this is only
temporary. Lewis and Clark, Gallatin, and Flathead National Forests have
also expressed interest in cooperative sampling/analysis. I'm sure that
others would be similarly interested. "
Sincerely,
Robert D. Braico
Water Quality Bureau
Fjivironmental Sciences Division
RDB:vlf
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-219-
From FSM 2509.21 - Region 1 Handbook on Water Quality Surveys
(in "draft status," November 29, 1973)
Table of Contents
Chapter Section
Chapter Title No. No.
Objectives ..... 10°
Introduction ...<,. 200
Water Quality 200.1
Forest Service Responsibility Toward Water Quality. . 200.2
Characteristics of Water Quality 30°
Natural Characteristics 300.1
Acquired Characteristics 300.2
Effects of Pollution 300.3
Survey Procedures
400
Defining the objectives of the Survey 400.1
Preliminary Planning . . ..... . 400.2
Preliminary Field Operations 400.3
Final or Revised Plan ' 400.4
Field Operations 400.5
Report 400.6
Characterization, Surveillance, and Monitoring . 500
Characterization 500.1
Surveillance 500.2
Monitoring 500-3
Water Quality Stations in Flowing Waters . 600
Chemical and Physical Stations 6QQ.1
Biological Stations 600-2
Bacteriological Stations 600.3
Water Quality Sampling in Lakes and Reservoirs (Standing
Waters) 700
-i-
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-220-
Chapter Section
Chapter Title No. No.
Inlets and Outlets ................ 700.1
Standing Water ................. 700.2
Water Quality Sampling of Ground Water ........ 800
Sampling Procedures .................. 900
Personnel .................... 900.1
Sample Collections .......... ...... 900.2
Sample Treatment for Various Determinations .... 900,3
Sample Containers .......... ...... 900,4
Shipping Samples to Laboratories ........ . 900.5
Legal Ramifications in Water Quality .......... 1000
Documentation ............ . ..... 1000.1
Sampling ................... . . 1000.2
Sample Containers ................ 1000.3
Sample Integrity ................. 1000.4
Report ..................... 1000.5
Interview and Interrogation ........... 1000.6
Case Preparation and Courtroom Procedure ..... 1000.7
Glossary of Terms ...................
Conversion and Classification Tables .......... 1200
Equipment and Laboratories ............... 1300
Equipment ..................... 1300.1
Field Kits . . . . ................ . 1300,11
Instruments ................... 1300.12
Laboratories ................... 1300.2
References .............. ......... 1400
Analytical Techniques ............... 1400.1
Survey Procedures ................. 1400.2
Interpretation .................. 1400.3
Miscellaneous .................. 1400.4
Suggested Reading References ... ........ 1400.5
-ii-
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100—1
-221-
CHAPTER 100 - OBJECTIVES
This handbook assembles subject matter standards an guides for a water
quality survey, sampling criteria and standards, definition of terms,
and other operational guidelines. These are aimed at obtaining comparable
information on effects of land management activities on the water resource
and providing a basis for appraising the water quality situation on the
National Forests and Grasslands.
The general objective of the water quality survey is to determine the
facts regarding the present water resource and to develop from such facts
sound technical interpretation that will provide the land manager a
defensible basis for policy and program decisions. This requires the
collection of basic information on the condition of the water resource:
volume, quality, and location of water supplies; land and water uses, current,
trends, and potential; and related information which bears upon the local
water resource.
The effects of land management activities on the quality of the water
resource are to be adequately analyzed and interpreted, and the findings
issued promptly.
The information in this handbook is currently up-to-date. It may be
revised periodically to reflect new and improved procedures. Your assistance
is requested to help keep this current. Send your suggestion to the
Water Quality Section, Earth Sciences Unit, Division of Natural Resources,
Regional Office.
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-22Z-
CHAPTER 200 - INTRODUCTION
Recent Federal and State legislation, the resurrection of historical
legislation, executive orders, policy statements, courtroom encounters,
congressional investigations, in-Service studies, and others have
emphasized the need to reevaluate ourselves, our activities and priorities,
'and even our basic philosophies to protect and enhance our environment.
Man has caused changes in the environment, many of which affect the
relationship between man and his environment.
In order to protect and enhance our environment, we must attain a
balance with respect to time. Our land, air, and water have a capacity
to biologically and mechanically cleanse themselves. Man has historically
viewed these resources as receptacles of infinite capacity. He is learn-
ing that with today's population and the demands for products and services,
this is no longer true, if it ever really was. If the ecosystem becomes
chronically overloaded, its ability to function can be irreversibly reduced.
Vast natural systems may be severely damaged by the improvident intervention
of man.
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200—2
-223-
200.1 - Water Quality
One measure of the quality of our environment is the quality of our
water resource. Early concern of water quality concentrated on elimina-
ting poor sanitation which encouraged waterborne diseases that periodically
ravaged the population centers of the world. These problems are now largely
under control. The energies which demanded that solution is now being
directed toward a broader concern for the entire environment, though
not always in direct proportion to the seriousness of the problem. Recent
concern for the quality of our waters centers on three aspects:
1. Growth of our industries and cities has multiplied the water
quality problems in many of our waters.
2. The demand for outdoor recreation has grown in a society increasingly
affluent and leisure oriented.
3. Man has an inexplicable affinity for water.
Two natural factors are generally responsible for determining the
quality of our waters: (1) the mineral structure of geological strata, and
(2) the chemistry of the surface soils. These are supplemented by waste
effluent from our agricultural, including forest related, Industrial and
municipal activities. Man has little control over the mineral and soil
qualities, but he does have the potential technical knowledge and engineering
capability to control the quality of his waste effluent. In the interim,
we are faced with uncertainties. To reduce the unpleasant consequences
during the period of uncertainty, we can:
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. • -224- 200~3
1. Conserve our resources for a "rainy day."
2. Keep open as many options as possible.
3. Avoid reaching an irreversible process.
A. Concentrate on learning how to remove the uncertainty.
No matter what the quality of our waters are, we pay for it—poor
e ' • *"
quality reduces productivity and the cost to restore the quality may well
exceed the cost to maintain the natural quality.
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-225- 200—4
200.2 - Forest Service Responsibility Toward Water Quality. The passage by
Congress on October 18, 1972, of the Federal Water Pollution Control
Amendments of 1972 (PL 92-500, 86 Stat. ' ) signals growing national
concern over the quality of the waters of the United States. This concern is
directed at the public, especially Federal agencies, as well as the private
sector. Section 313 (86 Stat.?'- ) states "Each department, agency, or
instrumentality of the executive, legislative, and judicial branches of the
Federal Government (1) having jurisdiction over any property or facility,
or (2) engaged in any activity resulting, or which may result, in the discharge
or runoff of pollutants shall comply with Federal, State, interstate, and
local requirements respecting control and abatement of pollution to the same
extent that any person is subject to such requirements, . . .*'
The Forest Service will now be the object of a watchdog agency, the Environ-
mental Protection Agency, to insure the Forest Service makes a reasonable effort
to minimize unfavorable effects of land management on the aquatic resource.
This EPA role is spelled out in Sec. 304(e) (PL 92-500, 86 Stat. ?'• ). It
states: "The Administrator ... shall issue to appropriate Federal ... agencies
information including (1) Guidelines for identifying and evaluating the
nature and extent of non-point sources of pollutants,and (2) processes,
procedures, and methods to control pollution resulting from - (A) agricultural
and silvicultural activities ...; (B) mining activities ...; (C) all construc-
tion activity ...; ..." This legislative direction encourages the Forest
Service to exert leadership in Its area of responsibility to reduce the chance
EPA reviews of Forest Service management practices will limit viable
management options.
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200—5
-226-
These recent amendments now require all States to establish water quality
criteria and standards for all surface waters of the United States, not just
the interstate waters (Sec. 303(a), 86 Stat. <"•••.- ). When approved by EPA,
these State standards will become Federally-recognized. However, there are
review procedures to modify existing standards and adopt new ones (Sec. 303(c),
86 Stat. '-''/ ) as supporting data becomes available or uses change. The
application of water quality standards to all surface waters has undoubtedly
influenced the Washington Office interpretation of navigable waters. As
defined (Sec. 502, 86 Stat. '. ) it means "the waters of the United States,
including the territorial seas," which is interpreted as all surface waters
regardless of size. This interpretation will remain in effect pending further
clarification by EPA or by the courts.
We are also subject to citizen suits (Sec. 505(a), 86 Stat. f ' ) for alleged
"violation of (A) an effluent standard or limitation under this Act, or
(B) an order issued by the Administrator or a State with respect to such a
standard or limitation." This provision has not appeared in any previous
amendment.
The National Environmental Policy Act of 1969 (PL 91-190) directs us to
"utilize a systematic, interdisciplinary approach ... in planning and decision-
making which may have an impact on man's environment" (Sec. 102A, 83 Stat. 853).
We shall, in addition, "initiate and utilize ecological information in the
i
planning and development of resource-oriented projects" (Sec. 102G, 83 Stat. 854).
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The President in two Executive Orders (E.O. 11507, 11514) has directed all
Federal agencies to insure its facilities and activities do not pollute the
nation's waters.
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-228-
E.G. 11507 directs all Federal agencies to ensure that all facilities
under their jurisdiction are designed, operated, and maintained to conform
to the standards in the Federal Water Pollution Control Act, as Amended, or to
the purposes of the act. E.G. 11514 provides the "how":
1. Monitor, evaluate, and control on a continuing basis their
activities so as to protect and enhance the quality of the
environment. Incorporate this information into plans and programs.
2. Revise where necessary, our statutory authority, administrative
regulations, policies, and procedures where they are deficient
or inconsistent and where they discourage compliance with the
purposes and provisions of the several environmental^oriented
acts.
We are also directed to include the public in the decision-making
process and to cooperate with other agencies, both State and Federal.
Such direction to all Federal agencies requires a formidable store-
house of data and knowledge to carry out. We are just beginning to
realize the implication these acts and orders have upon our activities.
What was sufficient in the past is no longer true. Our decisions must
be based not on assumptions but on facts. We must take a systematic and
interdisciplinary approach to arrive at our decisions. We must begin to
appreciate the enormous interrelated complexities of the environmental
systems. We will weigh the trade-offs of potential environmental and
socioeconomic harm against the benefits of our decisions. We will look
at alternatives and incorporate environmental safeguards into the basic design
of our programs and activities.
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200—8
-229-
One facet of this environmental awareness or consciousness is water
quality. But the classic concern for the bacteriological, chemical, and
physical constituents are no longer sufficient. We need to relate to the
aquatic environment, basically a biological system, and to the uses of
the water at points downstream. The National Forests are not expected to
produce water of so high a quality that treatment for domestic or
municipal uses is unnecessary. Neither can they produce waters so
degraded due to man's activities they produce long-lasting undesirable
effects.
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-230-
APPENDIX B
POLICIES AND GUIDELINES CONCERNING AIR QUALITY RELATED
TO PRESCRIBED BURNING IN FOREST RELATED ACTIVITIES
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" 5153.13-1
TITLE 5100 - FIRE CONTROL
5153.13 - Prescribed Burning Plans.
Air Qua11ty Guidelines. To help achieve necessary prescribed burning
in the Northern Region with minimum impact on air quality while maintain-
ing high quality standards employ the principles contained in the paper
entitled "Principles of Smoke Dispersion from Prescribed Fires in the
Northern Rocky Mountain Forests," by W. R. Beaufait and Owen Cramer.
Through their use smoke from prescribed burning should disperse to create
the least possible impact on air quality. But the guidelines are not to
override all other factors in determining when and how to burn. Instead,
they provide means to consider smoke management as essential for environ-
mental quality along with silvicultural, hazard reduction, or other
management needs of the 1-and. Prescribed fire is all intentional burning
including broadcast burning, dozer piles, range improvement burning, hand-
pile burning, etc.
1. Constraints to be_ Considered on Individual Prescribed Fires.
All forest burning wiTT require speciaTattention to weather forecasts.
The Weather Service will continue to issue a daily forecast on TWX until
November 1. During the slash burning period, the forecast will include
the level of free air convection, winds aloft at 6000, 9000, and 12,000
feet, and the daily temperature, humidity and wind trends. In some cases,
you should be able to apply these trends to your local weather measurements
making it unnecessary to request an individual spot forecast for each and
every burn. In order to prepare accurate spot forecasts the following is
required.
a. Temperature, dry bulb and wet bulb.
b. Wind direction and velocity.
c. Indicate cloud coverage, thunderstorms, etc.
d. Take measurements between 1400 and 1600 at the site the day
prior to the planned burn. Measurements for more than one day prior
to burn may also be helpful, if available at time of request.
e. If hygroaerothermograph readings are being reported, be sure
to note that wind velocities are per-hour averages.
f. Report maximum and minimum readings from-on-site hygrothermo-
graphs for previous 2- or 3-day period when available.
g. Use Fire Weather Special Forecast Request, form Rl-5120-16 when
making requests.
Review the AIR QUALITY GUIDELINES FOR PRESCRIBED BURNING and the PRINCIPLES
OF SMOKE DISPERSION by Beaufait and Cramer before burning.
Forest Service Manual August 1972
R-l Supplement No. 48
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5153.13—2
TITLE 5100 - FIRE CONTROL
2. All burning plans will contain a section on expected smoke
plume behavior to include convection column height, smoke plume direction,
and drift smoke direction. (Refer to Figure 6 in the Principles
package.)
At the time of ignition, fuels should be as dry as practical, consistent
with burning objectives and existing fire control needs. Burning should
be done when the intended fuel burns briskly and completely.
3. Except when control needs dictate otherwise, early to mid-
afternoon burning is encouraged to attain maximum convection column height
and smoke dispersal.
4. On sites where drift smoke may be a problem, ignition will be
scheduled to minimize drift during conditions of downslope winds and low
level smoke accumulation.
5. When burning during dry periods, mop up fires to the same
standards used for extinguishing wildfires.
6. Maximum smoke dispersion is essential for all burning operations;
however, burns planned upwind of any recreational areas, areas of
habitation, main transportation routes, or other urban and industrial areas
may require more stringent precaution measures.
7. Burns will be scheduled to avoid drift smoke accumulation in
adjacent valleys. This may require extra action to mop up smoldering
remnants when a clean burn is not attained as planned.
Reporting and Coordination
Coordination to prevent the accumulation of smoke from several burns in
the same general locality or on a Forest will be the responsibility of
the Forest Supervisor. Coordination of burning on a Regional basis will
be by the Regional Fire Coordinator. He will keep track of all current
burning in the Region, assess potential smoke pollution impacts and
restrict burning when necessary to prevent problem areas from developing
in the Region. In order for the Forest Supervisor and the Regional
Coordinator to coordinate burning in their respective areas the following
reporting schedule will be required.
All burning and planned burning will be reported daily to the Forest
Supervisor and the Regional Office.
August 1972 Forest Service Manual
R-l Supplement No. 48
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The Slash Burning Agreement
Slash burning is used in forestry to dispose of logging wastes for
three purposes:
1. To reduce or remove fire hazards
2. To prepare seedbeds for the next stand of trees
3. To release nutrients for new growth
Slash burning usually is done in the fall after the severe fire danger
is over. Because of the frequent temperature inversions in the fall, slash
burning is a persistent cause of air pollution. To minimize the air
pollution effects the forestry agencies have developed a system of burning:
1. Air Shed Delineation
Three years ago western Montana and northern Idaho were
divided into air sheds. An air shed is similar to a watershed in
that it includes the area through which air tends to drift as
dictated by prevailing winds, local winds, and the channeling
effect of topography. The delineation of air sheds is a new
technique and, no doubt, refinements and changes will occur as
they are used further. Some examples of local airsheds are:
Clark Fork Air Shed, Bitterroot Air Shed, Flathead Valley Air
Shed and Swan Valley Air Shed.
The purpose of the air shed delineation is to provide a smoke
management area which is based upon where the smoke will likely
go rather than by the geographic descriptions such as forest
boundaries, counties, etc. This appears to make sense because
conditions vary between adjacent airsheds and smoke management
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-234-
manipulations could be confined to airsheds and thus be more
flexible and also manageable.
2. Agency Cooperation
The agencies within each separate airshed have cooperated
in the smoke management effort. They include the U.S. Forest
Service, Bureau of Land Management, Bureau of Indian Affairs,
State Forester, County Governments and private forest industries
particularly those owning large acreage of forest lands. The
cooperating agencies elect a monitor whose duty it is to keep
track of the slash burning, to watch smoke accumulation in his
air shed, and to advise districts that burning whether or not
they need to shut down. There is such a monitor in the Flathead
Valley Air Shed.
3. Burn Day Minus One
The district or management unit which intends to burn informs
the Forest Supervisor and the Regional Office of the area planned
for burning. Teletype communications between the Regional
Forester's Office and the State Air Quality Control Office in
Helena are used for informing each other on areas proposed for
tomorrow's burning and visa versa. If the Helena office has
reason to curtail such burning, they can.
The district doing the burning has already prepared a burning
plan for each and every unit of land that is to be burned in a
given season. This plan contains:
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-235-
Total area to be burned
Name of each sale area
Name of each cutting unit
Estimated date for burning (within two weeks),
Type of burning (pile and burn, broadcast, row, etc.)
Water scource
Boundary Protection (firebreaks)
Personnel (overhead and crew)
Equipment (vehicles, special equipment, tools, hand,
power)
Safety training
Ignition procedures map (sequence of ignition, number)
On site weather parameters
example winds 5 to 10 mph
Fuel moisture 9% to 30%
Relative humidity less than 30%
Air unstable
Precipitation - less than 1 in. prior to date
Time of burn
The plan is carried out as closely as possible remembering,
however, that as the burn proceeds, changes in igniting sequence
may be needed or that burning may have to be stopped should
weather conditions change so that a poor burn was resulting.
4. Burn Day
. On the day selected for burning a weather forecast is
received giving:
a. mixing level
b. wind direction and velocity
c. temperature and relative humidity
d. atmospheric stability
After the weather forecast is received, the district person
decides whether to burn or not. He makes this decision from the
forecast to see if the following conditions can be met:
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-236-
a. is the area high enough so the smoke can reach
the mixing level?
b. is the wind direction such that the smoke can
miss any smoke sensitive places?
c. can the burn be completed in time to avoid a
night-time inversion?
d. is the temperature high enough and the relative
humidity low enough for a clean burn?
If the answers to these questions are favorable, then the
burn is attempted.
5. How the System Works
a. Presently, all areas that are burned have had
burning plans made for them.
b. Weather forecasts have been obtained and burn
decisions made after the forecasts have been
received.
c. Administrative offices have been duly informed of
burns and the system has functioned reasonably
well.
6. Special Events in the Flathead Air Shed
On the two occassions that were reported by the regional fire
coordinator, smoke complaints were made for the Flathead Air Shed:
The first one came as a result of smoke from a wildfire in
the Browning, Montana area. This was a very rare case because
the smoke had come from the east to the west, which is against
the prevailing winds and does not often occur.
The second instance came when smoke blew into the valley all
the way from the St. Joe River area and from the Kootenai National
Forest near Libby.
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-237-
In both of these instances, no burning was being done on the
Flathead Air Shed and yet smoke was coming in anyway. In cases
like this the monitor called the Regional Office and burning was
curtailed on air sheds adjacent to the Flathead and in a day or
so the smoke had cleared and the burning could be resumed.
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-238-
Material from: "Fire Quantification for Silvicultural Use" by
William R. Beaufait and Charles E. Hardy, Northern Forest Fire Laboratory,
Missoula.
Resource managers are not satisfied with the results of post.logging
treatment in respect to site preparation, hazard reduction, impact on the
watershed, and air quality maintenance; hence the Miller Creek and Newman
Ridge fire use studies from which this data comes.
1. The height attained by connection columns for 10 acre slash
fires broadcast burned was found to be a function of:
a. mixing depth of the lower atmosphere
b. wind speed
c. buildup index
Neither the amount of fuel consumed nor the relative intensity of
the fire significantly affected smoke convection column height. Buildup
index appears to have by far the greatest influence on smoke column
height, and mixing depth the least.
In order to get smoke dispersal above 11,000 feet, it is important
that slash burning be done when the buildup index is at least 50 or more
and the mixing depth is 9,000 feet or more. These conditions are readily
found in the spring and early fall, but tend to be less and less available
as the autumn progresses. This makes it all the more urgent to do as
much slash burning as possible when the correct atmospheric conditions are
present. This may also add to the cost of slash disposal.
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Table 18.—Convection column height (feet mean sea level) as it varies with
mixing depth, Buildup Index, and 20-foot standard windspeecH
Buildup :
Index :
Windspeed (m.p
2
: 4
: 6 :
8
.h.)
: 10 :
12
14
MIXING DEPTH 3,000 FEET M.S.L.
10
25
50
75
100
125
150
10
25
50
75
100
125
150
10
25
50
75
100
125
150
8,800
10,400
11,500
12,100
12,600
12,900
13,200
9,100
10,600
11,700
12,300
12,800
13,200
13,500
9,300
10,800
11,900
12,600
13,000
13,400
13,700
10,800
12,200
13,300
14,000
14,400
14,800
15,100
11,000
12,400
• 13,600
14,200
14,700
15,000
15,300
11,200
12,700
13,800
14,400
14,900
15,300
15,500
11,200
12,600
13,700
14,400
14,900
15,200
10,800
12,300
13,400
14,100
14,500
14,900
10,000
11,500
12,600
13,200
13,700
14,100
15,500 15,200 14,300
MIXING DEPTH 9,000 FEET M.S.L.
11,400
12,900
14,000
14,600
15,'lOO
15,400
15,700
MIXING DEPTH
11,600
13,100
14,200
14,800
15,300
15,700
16,000
11,100
12,500
13,600
14,300
14,700
15,100
10,200
11,700
12,800
13,500
13,900
14,300
15,400 14,600
15,000 FEET M.S.L.
11,300
12,800
13,900
14,500
15,000
15,300
15,600
10,500
11,900
13,000
13,700
14,200 .
14,500
14,800
8,900
10,300
11,400
12,100
12,500
12,900
13,200
9,100
10,500
11,700
12,300
12)800
13,100
13,400
9,300
10,800
11,900
12,500
13,000
13,400
13,600
7,400
8,900
10,000
10,700
11,100
11,500
11,800
7,700
9,100
10,200
10,900
11,400
11,700
12,000
7,900
9,400
10,500
11,100
11,600'
11,900
12,200
— Approximate range of collected data is indicated by internal line.
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APPENDIX C
TIMBER SALE CONTRACTS AND PROVISIONS FOR
PREVENTION OF ENVIRONMENTAL DEGRADATION
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TIMBER SALE CONTRACTS AND PROVISIONS FOR
PREVENTION OF ENVIRONMENTAL DEGRADATION
Timber Sale Contracts
The Timber Sale Contract for Puzzle Creek awarded on December 11, 1969
contained the standard provisions in effect at that time in three divisions,
A-specific conditions, B-standard provisions, and C-special provision. The
A-clauses were specific for location, volume, etc., but nothing pertaining
to air and water pollution. The B-clauses included some standard provisions
included in all timber sales regarding the Protection of Stream Courses
(Bo.5), Erosion Prevention and Control (B6.6), Erosion Control Structure
Maintenance (B6.63) and Slash Disposal (B6.7). The B.-clauses were all very
general.
The C-clauses contained some specifications affecting air and water
pollution but again provided only broad guidelines. C5.2 required that
"the purchaser shall file a plan with the Forest Service prior to
burning," and admonished that debris should not be deposited in streams.
C6.4 prohibited skidding in live streams and "minimum" crossings. C6.61
contains the major erosion prevention requirements as follows:
Prevention of_ Erosion C6.61
A. Except as provided in item B, purchaser shall locate spur roads
according to operating schedule, B6.31. Such location shall include
the marking of road center!ine or gradeline and the setting of such
construction stakes as are necessary to provide a suitable basis for
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economical construction and the protection of national forest lands.
Maximum sustained qrades for roads in this sale will be 8 percent.
B. Where the location of roads is designated or staked on the ground
by Forest Service, construction shall be upon such locations.
C. Except where waived in writing by Forest Service, roads shall be
so located that the distance between the toe of the fill and the
stream channel shall not be less than 100 feet.
D. Bridges shall be constructed with the minimum encroachment on
stream channels and to the length and height necessary for maximum
streamflow. Approach fills will be riprapped or constructed so as to
prevent fill material from entering the stream.
E. After specified roads are substantially completed for log hauling,
the skidding of logs on the roadbed shall not be permitted.
F. Temporary drainage structures and earth fills in live and
intermittent stream channels shall be removed after logging to
prevent soil washing; except where adequate permanent metal or
concrete culvert is installed, such removal may not be required.
G. Skidding with tractors within 50 feet of live streams shall not
be permitted except in places designated in advance by Forest Service,
and in no event shall skid roads be located in live or intermittent
stream courses. Skid trails will be located high enough out of draws,
swales, and valley bottoms to permit diversion of runoff water to
natural undisturbed forest ground cover.
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H. During periods of accelerated water runoff, especially during the
spring runoff and periods of heavy rainfall, purchaser shall inspect
and open culverts and drainage structures, construct special cross
« ditches for road runoff, and take other reasonable measures needed to
prevent soil erosion and siltation of streams.
I. Tractor skid trails in excess of 25 percent will be permitted only
upon written agreement between purchaser and Forest Service.
J. Spur road surface width shall be limited to truck bunk width plus
4 feet; except where needed turnouts will be permitted equal to two
times the bunk width olus 4 feet. If shovels or cranes with revolving
carriage are used to skid or load, spur road surface width equal to
track width plus tail swing will be permitted.
C6.62 sets forth erosion control required by the purchaser.
C6.7, C6.71 and C6.96 take care of slash disposal.
Erosion Control by_ Purchaser C6.62
A. Not later than 30 days subsequent to the completion of skidding
on each unit or subdivision of the cutting area, unless otherwise
agreed uoon, purchaser may be required to out-slope or construct
diagonal drainage barriers, and/or drainage dips, in all roads,
firebreaks, and skid trails located on gradients above 2 percent.
Such measures shall include:
(1) Discontinued roads—cross ditch, outslope, and remove berm.
(2) Spur roads to be retained—clean culverts and ditches and
construct berms (where necessary).
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(3) Skid trails—cross ditch, place dirt embankment barriers, place
logging slash barriers and gully olugs, and outslope trough-shaped
skid trails.
(4) Firebreaks—cross ditch, place dirt embankment barriers and
•
gully plugs.
Location of all such drainage barriers and dips will be staked or
otherwise marked on the ground by Forest Service.
B. Measures to be completed when road construction or logging is in
progress and not fully completed at the time of shutdown follow:
(1) Roads shall be bladed so they will drain properly and not become
waterways. Spur roads will normally be outsloped to dispose of
surface water.
(2) Cross drains as staked by Forest Service shall be provided to
prevent erosion.
(3) Culvert openings shall be inspected and cleaned.
(4) At locations staked or otherwise marked on the ground, berms and
ins!oping shall be constructed to prevent rainwater and snowmelt
from eroding fill slopes.
(5) Where berms are left, roads shall be insloped and disperal of
water provided by cross ditches or culverts.
Slash Disposal C6.7
Slash consists of all debris resulting from logging and all fuels
associated with construction of specified roads or other improvements.
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Construction of_ Firebreaks C6.71
A firebreak (exposed mineral soil) not less than 14 feet in width
shall be constructed along the high hazard perimeter of each clearcut
unit prior to completion of logging. Purchaser shall construct a
firebreak along the balance of perimeter of each clearcut unit as
completed.
Landing Slash Disposal C6.76
All slash and cull logs accumulated at landings shall be piled in
a manner suitable for burning.
The location of roads for erosion control, channel changes and borrow
pits were included as part of the road design in the contract.
These provisions in addition to the design of the sale and the roads
were believed to offer sufficient environmental protection to recommend
that the area be clearcut.
Standard Contract Provisions
The Puzzle Creek sale is covered under Standard Provisions (Division
B), adopted April 1966, whereas the Gildardt Flats sale is covered under
a revision adopted July 1970. The revision is more extensive, definitive
and precise regarding the stipulations of the Contract and the respective
responsibilities of both buyer and seller. Both contracts stipulate that
a representative of both Forest Service and Purchaser be readily
available to issue and receive notices with respect to the Purchaser's
operations. The policy on the Flathead Forest now is to appoint a
representative whose assignment is to supervise the operations of each
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timber sale throughout the term of that sale, providing a degree of
continuity in Sale Administration that formerly did not exist.
And examination of the B and C clauses in sales contracts does not
show much change between the older and newer contracts. The difference
seems to lie mostly with the enforcement of contract provision. It is
obvious that the contract clause regarding the distance a road should be
from a stream was violated on the Puzzle Creek sale. The toe of the road
slope was into the stream or very close to it instead of the 100 feet
prescribed in the contract. The old habit of not living up to the contract
was still ingrained.
Special Provisions - Division C
The so-called C-Clauses represent special provisions inserted in the
standard contract to meet specific requirements of the individual sale.
This section covers specific requirements with regard to both road
construction and maintenance and the timber extraction process.
Historically, the C-Clauses with regard to the engineering aspects have been
lengthy and detailed, whereas the requirements for the harvesting operation
have been minimal.
The Gildart Flats Contract is somewhat more specific with regard to
C6.6--Erosion Prevention and Control, but not sufficiently different to
represent a great leap forward. Considerable emphasis is placed upon
debris disposal with respect to both road right-of-way clearing and the
harvesting activity, this being a cosmetic requirement to overcome aesthetic
objections. This requirement, however, requires the yarding and decking of
unutilized material, to be burned later. Although the merchantability
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limits have been reduced to 5.5 inches, d.i.b., there will be a considerable
volume of material that will have to be moved from the site to the decks.
The additional site disturbance and associated burning may result in a
greater soil and air pollution impact than 1f a more conventional type of
debris disposal were required. The trade-off here needs further study
before the practice becomes generally accepted.
Several rangers agreed that the guts of the environmental provisions
were contained in the C clauses, and that C clause could be used to
strengthen the environmental requirements. But the rangers largely relied
on the standard approved C clauses. These had been agreed to by the Forest
Service and the timber industry and they could not be changed without
approval. This was not collusion so much as an understanding of what would
be required as protection against imposition of some costs of which the
operator was not fully aware. One ranger wrote a new C clause and included
it in the Gil dart Flats sale. The regional timber staff objected because
this was not one of the agreed-to clauses. The supervisor backed the ranger
and got approval to use the C clause. The opportunity has not been extended,
but it seems that the C clauses need to be re-examined and perhaps
revised to meet new requirements and hopefully added to as quantitative
knowledge on water and air pollution effects are better understood.
One way would be to encourage innovative thinking from the field and to
permit special provisions for particular conditions.
What needs to be encouraged is the type of a site analysis and
decision making which is underway on the Flathead. Much of the
environmental problem on National Forests lies with blanket decision
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making which "emerged from higher offices and which did not consider the
specific field problems. Situational management is an improvement and
needs to be encouraged.
Use of the C clauses is one device and actually only a minor one. The
greater opportunity for the avoidance of environmental damage will have to
come in the whole plan of management of the forest, the selection and design
of the area to be harvested and the necessary roads required, the selection
of harvesting method, the care with which the harvesting is done, and strict
enforcement of the various precautions. This approach will prevent damage
from occurring rather than trying to repair the damage after it has
occurred.
Timber Sale Administration was for years assigned to new employees of
the Agency. Inasmuch as new employees were very transient in the
organization, administrative continuity was lacking—and because of the
inexperience of the personnel, they were reluctant to enforce contractual
provisions. With personnel ceilings the Districts now have a degree of
personnel stability that provides a greater continuity, with associated
responsibility and authority. In personal discussions with field
representatives, they indicated a good deal of personal satisfaction in
having the responsibility and authority—as well as accountability—with
respect to their various assignments.
The point is, that the contract stipulations, even prior to the 1970
revision, were quite specific and contract violations or oversights were
permitted for several reasons: (1) a general insensitivity toward the
several resources, (2) a lack of staff specialists to assist in the
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planning phase (a general reluctance by the Agency to recognize need),
(3) high turnover rates in personnel, as previously mentioned, (4) lack
of back-up support—District Ranger, Supervisor, R. 0., W. 0.
The Forest Service has had, under both contracts, the provision to
suspend or terminate the contract under the Breach Clause B8.25 under the
former contract, B9.3 under the present contract.
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