TO: Folio Printing

fax number 364 2443

Valerie voice# 488 8287

Valerie address 6500 NE 171 st Pl. Bothell 98011


by Joe Breskin,

Quilcene Ancient Forest Coalition,

35 George Wye,

Port Townsend, Wa, 98368

Voice phone: (206)385-3771

This version of the document has been spell-checked, but because it has not yet existed on paper, it is inevitable that there are numerous awkward sentances still at large in it...


Executive Summary or Abstract:



The FEIS contends that the adverse impacts of timber harvesting can be mitigated by in-stream structures placed in drainages. There is compelling evidence available that these structures neither work as advertised nor compensate for the destruction of the habitat of native fish.

The mitigation supposedly provided by these structures is in the form of hypothetical fish, not censused fish, and based on Forest-wide average fish outputs, not stream specific census figures of individual species.

The assessment of probable soil loss from slopes, and the related habitat damage caused by its deposition in streams, are both treated as abstract management problems, and the estimated environmental impacts are based on a combination of inadequate data, scientifically indefensible tools and biased guesswork.

The inclusion of unsuitable lands in the timber-base substantially inflates the ASQ, increases the pressure to manage these lands for timber production, and thus increases the probability of large quantities of a non-natural distribution of assorted soil material moving from currently forested slopes into streams. This largely wood-free combination of organic material and rock will degrade the biological diversity and productivity of both of these habitats. Removal of the forest covering these unsuitable lands greatly increases the likelihood of damage to anadromous fish habitat due to slope failure in the aftermath of road-building or logging activities.

The plan calls for entry into roadless areas and areas identified in the SRI as sensitive and claims to mitigate this activity by building habitat-enhancement structures and gating old roads.

The plan calls for significantly expanding the transportation system into currently roadless areas.

Neither the actual costs of true mitigation nor the long-term environmental impacts of these activities are realistically considered in the plan or FEIS.

All of this is contrary to NFMA.


because the development and implementation of management prescriptions based on adequate environmental impact assessment tools and enlightened management directives is necessary to prevent wholesale destruction of numerous non-timber resources on Olympic National Forest and

because these tools and directives are not provided in the Forest Plan and FEIS made law in the Record of Decision, dated July 17, 1990,

as a result of all these failures, and the other failures, conflicts and deficiencies that shall be elaborated herein below and in the appendix attachments hereto, the Quilcene Ancient Forest Coalition and the parties to this Appeal request a stay on all timber sales that require expansion of the transportation system into unroaded areas until the Forest Plan for the Olympic National Forest has been revised to provide the following analytical assessment tools and management directives:



RELIEF REQUESTED: The Quilcene Ancient Forest Coalition requests that the Forest Service immediately:

1) produce scientifically defensible management tools which provide analytical information based on the best available scientific knowledge or else hire acknowledged expert information providers from within the scientific community, and

2) immediately initiate and complete those wildlife, habitat, plant, soil and road inventories required to allow the management decisions and policies of the Forest Service to provide the environmental protection required by law, and

3) institute thorough, integrated and ongoing monitoring programs which are required to provide National Forest Land Managers with realistic and accurate information, and

4) abandon all scientifically indefensible habitat enhancement programs and cease to presume/assume that these programs and the products thereof constitute mitigation for damages done to dependant plant communities, anadromous fish or any other dependant resident or migratory vertebrate species, and

5) immediately abandon all management prescriptions requiring entry into roadless areas, at least until credible evidence can be produced to show that such entry will neither irreversibly degrade or harm the productivity of the impacted local or surrounding lands, rivers, plants, dependant animals or the habitat of dependant animals, and

6) Revise all schedules, budgets, projects, standards and guidelines, contained in the Land and Resource Management Plan and Final Environmental Impact Statement, which (when subject to the proper application of the tools and policies developed in response to items 1 - 5 herein above, and also specified in greater detail in the appendix discussions included herein) maintain conflicting interpretations, and

7) that in the event timber sales are ever again allowed on the Olympic National Forest, that both the overall design of each sale and the attached silvacultural prescriptions must give primacy to providing answers to fundamental questions identified in the development of management tools called for herein above.


The Forest Service's mandate to manage the various vertebrate species in the Olympic National Forest is governed by several laws, which make it clear that:

1) the legally prohibited extinction of native co-evolved anadromous fish species cannot be mitigated through the introduction of hatchery stocks.

2) Legally prohibited damage to native co-evolved anadromous fish species cannot be mitigated through the installation of downstream habitat enhancement structures whose effectiveness has not been established.

3) Logging most currently unroaded areas will in all probability violate federal laws governing forest management and if actual costs of these activities (including the true costs of mitigation are considered) timber sales in most such areas will be found to be uneconomical.


Projects which will degrade or harm habitat or the productivity of the soil are not prohibited by the Plan

"The principal goals of habitat management are 1) protection of existing high quality habitat and the prevention of future degradation, and 2) restoration of degraded habitat and enhancement of habitat with naturally low productivity. (Bottom, et al 1985)"

Yet the Plan proposes numerous projects which will degrade the last remaining examples of high quality habitat (appendix __, page __-__), and fails to adequately fund the restoration of lands and habitat substantially degraded by past management activities. The Plan further fails to provide an adequate description of the criteria and the methodology utilized in removing from the harvestable timber (resource) base those lands which pose risk of irreversible damage to Soils, Slope and Watersheds, the Habitat of anadromous and resident fish, and on which adequate re-stocking within the 5-year period specified in NFMA section 6(g)3(E)i and in 36 CFR ss 219.27(c)3 cannot be given a high assurance.




"Designation of numerous high-erosion-risk lands as suitable for timber harvest may, if these lands are not logged, 1) inflate the apparent timber base, 2) inflate the Plan's Potential and realized values for timber harvests, and 3) increase pressure in the future to log high erosion risk lands, or if these lands are logged, 4) underestimate the total costs of timber harvest, including the effects of harvest on erosion, sedimentation, fish production and mitigation attempts. (Frissell and Nawa, 1988)"

The failure to remove unsuitable lands from the timber base does more than unrealistically inflate the ASQ and increase the pressure on adjacent lands, which is why it is required by NFMA. It provides ongoing temptation to ignore existing information and enter the area, with potentially undesirable environmental consequences which are virtually impossible to mitigate. The temptation to enter unsuitable lands to meet the inflated ASQ is combined with the current management tools, particularly the sediment yield model and the belief in the mitigating effects of enhancement structures. This combination can make it difficult for managers to justify denying entry into truly unsuitable lands, because the management tools provided in the Land and Resource Management Plan not produce realistic or accurate answers to the questions managers are required to ask.

Inadequate tools added to insufficient data and defective guidelines results in dangerous decisions

One of the most powerful analytical tools available to forest managers is the Sediment Yield Model (OSYM). It is used to produce the Environmental Assessments required for timber sales, and to provide comparisons of alternative land management scenarios. Unfortunately, the sediment model in use on the Olympic National Forest is not a precise tool, and in its simplification of the landscape to a manageable number of variables, it has a tendency to toward reductio ad absurdum. For example: the Sediment Yield Model's comparison of post-logging activity sediment delivery with "natural" levels of sediment output from a drainage is highly misleading, because so many of the characteristics of the sediments delivered are not the same.

A recent study in the Cascades (Kennard, 1990) found that the incidence of debris flows was 15 times as great in managed areas than in unmanaged areas of the Tolt Watershed. Even if we were to assume that the frequency of major slope failure and debris-flows remains the same between managed and natural conditions, the character of the sediments delivered by logged and unlogged slopes differs greatly.

Consider the implications of the following: Current understanding of the flow of large woody debris is incomplete. Models presently in use can only account for approximately 40% of the large woody debris in riparian zones. It has been postulated that the dynamics of recruitment of large woody debris into riparian areas requires the input of trees that are provided by debris flows in upland areas. Once this process is short circuited by the removal of the wood through logging, the riparian zones down-slope will gradually become depleted. (Stan Gregory/John VanSicle, 1990 in press)

By failing to adequately address standards for removing unsuitable lands from the timber base, the plan continues a long-standing management bias in favor of development in the face of uncertainty.

True cost of mitigation is ignored in the Plan

Habitat protection is generally cheaper, simpler, and more effective (than mitigation). For example the cost to replace the structure provided by a large conifer in a stream with a gabion or log weir greatly exceeds the value of that tree as a merchantable log. (Sedell et al. undated).

If the total annual costs of effective enhancement and mitigation programs and an appropriate share of the cost of building and maintaining and mitigating the associated roads are added to the cost of timber sale administration, these annual costs in a very few years will have significantly exceeded the value of the harvested timber, and many of these costs continue in perpetuity.

There are few streams that still retain relatively pristine characteristics. These unaltered streams are literally invaluable, not only for their own fisheries but they are irreplaceable models of natural systems needed to further understand the principles of stream ecology and to develop protection, restoration and enhancement techniques for managing the rest of the streams in the state. Wild streams are also yardsticks with which habitat changes in other streams can be measured. (Bottom, et all 1985)

Numerous co-evolved native salmon are expected to be listed under ESA. Local stocks which are extremely depleted or are believed to be extinct include: the Dosewallips, Wynoochee, Elwha and Skokomish Spring Chinook stocks; the Dosewallips, Duckabush, Quillayute and Dungeness Rivers summer/fall Chinook stocks; the Lyre and Elwha Coho stocks; the Elwha River and Hood Canal Chum stocks; the Elwha and Skokomish Pink Salmon stocks. (most data are from W. Nehlsen, J. E. Williams and J. A. Lichatowich. 1990. Pacific salmon at the crossroads: West coast stocks of salmon, steelhead and sea-run cutthroat trout at risk. American Fisheries Society. Petition to file for protection under ESA In preparation (verify this point with licatowich)).


Substitution of "enhancement structures for protection

"Any Forest Service activity which causes a decline in fish habitat capability will be mitigated by the initiation of a habitat improvement program which will bring the fish habitat up to or above the previous condition. The removal of a human caused barrier to an anadromous fish stream would be an example of such a project." FEIS IV-65

One of the significant consequences of management activity, especially a "habitat enhancement" activity, is the selective negative effect it inevitably has on species diversity. This one-dimensional output does not adequately consider the true impact of management alternatives on species diversity. All management activities, almost by definition, provide a differential, filtering effect on the various components in the community. In the face of major disturbances like debris flows: Coho may respond positively, while the trout components, Steelhead and Chinook and Chum, are impacted negatively (Carnation Creek Study: Blair Holtby 1988 Scribner & Holtby 1989 and (Reeves et al in prep.):

The statement calling for mitigation through the institution of habitat improvement programs, on page IV-65 of the FEIS makes it sound like mitigation is a simple and inexpensive business, and that the habitat available for inexpensive and effective enhancement is unlimited, but this is not true. If you examine the proportion of the budget proposed for this mitigation it becomes clear that it is a very expensive proposition.

"Millions of dollars of public funds have been budgeted for 'enhancement' projects that are expected to do little more than compensate for the further damage to fish habitat caused by the timber program over the next 20 years. In fact... information has emerged that many such projects are biologically ineffective or even detrimental (Everest and Sedell 1984, Petrosky and Holubetz 1986, Fontaine 1987, Fressell and Nawa, 1990). Certain biological resources, such as the multitude of locally-adapted, co-evolved stocks of salmon and steelhead... when lost are gone forever. We say this to emphasizes the inestimable value of those habitats and populations that we still have... (which) provide the genetic resources necessary for reestablishment of fish runs in nearby basins whose stocks have been lost. (Frissell and Nawa, proceedings: Salmon & Steelhead restoration conference 1989 Arcata, Ca.)"

Evidence that "enhancement structures" are either beneficial or permanent is totally lacking

Given that there is little to no scientifically credible evidence that these "enhancement" strategies are effective, and a growing body of evidence (Everest and Sedell 1984, Petrosky and Holubetz 1986, Fontaine 1987, Frissel and Nawa, 1990) that they are either ineffective or Detrimental to wildlife, this is scandalous.


"Mitigation and enhancement opportunities on Olympic National Forest consist primarily of projects that will increase rearing space by improving the quality and quantity of pool habitat. It is estimated that a regular, annual program of pool development, enhancement, and maintenance will, by the end of the first decade, increase on-forest anadromous fish habitat capability by about 20% e associated alternative without mitigation / enhancement."


The preceding statement is a grim testament to the "structural enhancement" frenzy that has struck land management agencies responsible for the management of salmonids in the past decade. In some agencies upwards of 40% of the Fish Biologists on their staffs have been replaced in the budgets by "Capital Improvements" in the form of gabions and log weirs, to enhance pool to riffle ratios and other monuments to creative accounting, in spite of the fact that evidence of the effectiveness of these programs is inconclusive at best.

The recent study (Frissell and Nawa, manuscript) of 161 Artificial Fish Habitat Structures in 15 different streams in western Oregon and southwestern Washington found overwhelming evidence that these structures were ineffective, especially in the low-gradient reaches. This paper also reviews prior studies which found that more than 20 percent of the structures surveyed in Idaho failed within their first winter (Petrosky and Holubetz 1986) and that over 75% of the "enhancement structures" in a Colorado study (Babcock 1986) failed in a 2-5y flood just 2 years after installation, and several of the structures remaining after the flood were suffficeintly damaged to present barriers to migrating fish. Throughout the Plan there are references to enhancing habitat by increasing the number and size of pools by increasing the amount of large woody debris in streams. However the Plan does not present a coherent plan for carrying out stream inventories to accurately estimate fish populations or to evaluate habitat needs. Nor does the plan clearly explain how the studies budgeted will monitor the effects of logging and roads on water quality and fish populations, let alone how it proposes to determine the effectiveness of these enhancement structures.


"During plan implementation, drainage by drainage analysis of cumulative effects will allow us to plan on-forest management activities in drainages which have been relatively unaffected by previous activities rather than those that have been previously highly impacted. This distribution will mitigate potential cumulative effects in given drainages, as will applications of the Standards and Guidelines and Best Management Practices." LRMP or EIS.. Citation lost.. will be found...

The plan attempts to provide for species and habitat diversity through protection of individual streams from total devastation by scheduling a dispersed pattern of harvest. The plan attempts to minimize the total area exposed at any one time, in any particular drainage, but it accomplishes this at the expense of increasing the total area exposed, on a landscape level. There is a compelling and growing body of evidence that this dispersed harvest strategy (in which all drainages are progressively degraded and simultaneously exposed) provides a much greater risk to anadromous fish runs than does an unmanaged landscape in the event of debris flows resulting from major storms.

One of the significant consequences of sedimentation is the effect it has on species diversity. The total number of fish delivered at the output of a drainage or river system must not be used as an indicator of the well-being of the ecosystem. This one-dimensional output does not adequately consider the impact of management alternatives on species diversity. Put simply: not all species respond in the same way to any given change in the environment. See appendix: Filtration effects of management activities and changes in the environment of anadromous fish: Carnation Creek Study: Holtby 1988; also: Hartman and Brown 1988, Scribner and Holtby 1987, Sedell & Bisson 1984


In considering the effects of managing the Olympic National Forest under a "dispersed harvest" or "Staggered Setting" scenario, it will be found that habitat diversity cannot be maintained, on a landscape level, over a historical time-frame. There are two reasons for this. The first is the elimination of the older age classes at all elevations, which is inherent to harvesting on short rotations (short rotations can be stated to be < 250 year on East side of the Olympics or < 500 years on the West side of the Olympics). The second reason is the ever-increasing proportion of the landscape devoted to and impacted by roads.

Because roads "tend to be one of the major contributors to landsliding in steep mountainous terrain (personal communication Gordon Grant, OSU") their presence as long-term openings in the fabric of the forest increases the time component of the danger they provide/contribute. (See also: Sullivan, et al 1987 Proceedings of Symposium in Seattle

Because the primary focus of the Sediment Yield predictions and the Cumulative Effects analysis in use on the Olympic is in the area immediately impacted by logging and roadbuilding activities, much of the impact and much of the sediment yield from these activities is ignored. As a result of the steep gradients of many mountain streams, a great deal (and eventually almost all) of the sediment is transported off-forest. To understand the full effect/impact of cumulative effects, one must look at the unconstrained reaches which are typically both the most productive fish habitats and the places where the finer components of the suspended sediment drop.(Cindy Ricks/Glen Chen, Aug. 1990, Progress report: Siskiyou N.F. direct Jim Sedell, Study of loss of pool habitat on Hoh ? Breitenbush?)

**** In the event of a catastrophic event destroying a substantial amount of the habitat in one drainage, adjacent drainages can be expected to provide genetic "refugia" for species dependent on the destroyed habitat. From the point of view of anadromous fish, these catastrophic, habitat destroying events primarily result from two sources: fire and logging.

The principle contributor to the destruction of fish habitat caused by debris flow is channel scouring in the upper drainages, and the resulting destruction of invertebrate habitat, and spawning gravels, and the deposition of fine sediments. Debris flows typically result from the combined effects of numerous minor landslide events in small drainages which sequentially or synchronously contribute debris of all sizes, which together conspire to temporarily obstruct major drainages. The inevitable releases of these obstructions are events characterized by exceptional peak-flow velocities and volumes. The down-stream course of this sediment is described in detail in the attached appendix ___, pages __-__.

In watersheds which have past histories of management for timber production, it can be reasonably assumed that at least 2000 cubic feet of wood per surface acre has been removed from formerly timbered slopes, in the course of the past few decade's management activities. This loss of wood from the slope has serious implications on the downstream effects of debris flows on fish habitat.


On page B-36, the LRMP states, under the heading "Research Needs":

"The Sediment model which was used to make predictions in the Forest planning process needs to be verified. A defensible cumulative effects model should be developed in conjunction with establishing a threshold of concern for increased sediment levels."

In the handbook for the sediment model Published by the Intermountain Research Station, the authors warn:

"All output values in the model are expressed as "average annual" quantities. These events are rarely observed in nature, but they are the most reliable events to statistically evaluate and verify. Average annual sediment yields should be thought of in the same context as the average annual erosion predictions derived using the Universal Soil Loss Equation (USLE). Predictions will differ considerably from actual sediment yield for any single year due to deviations in climatic conditions in any single year from the average." pp26 (Guide for predicting sediment Yields from Forested Watersheds Cline, et al 1981)

"In fact, no one in the Northwest is actually using the USLE because the landslide debris flow is stochastic and no-one has developed a sediment budget that can dynamically incorporate the stochastic part of the sediment yield. Even the modern sediment budgets under development in the northwest, which consider sediments coming from landslides, debris flows and earth flows, and compares it to soil creep, earth throw and stream bank erosion fail to model the stochastic components, but they are definitely more realistic, in terms of northwest conditions than the things they pulled out of region 4." (L. Benda ,Personal communication 1990)

In the next paragraph, the authors argue, in the hope of excusing their decision, to outright ignore the exceptional peak flow events which forest managers are required to consider under the terms of CFR 36 9 :

"...watersheds will react almost identically during low frequency, high intensity events regardless of the degree of management activities superimposed by man. That is to say, tremendous quantities of sediment will be mobilized during these events as part of the natural functioning of the watershed system. Consequently, management effects are best observed and evaluated in relation to more common "average" conditions." ibid 26,27

In fact, it is under these peak conditions that managed and natural watersheds behave most differently. Even though the gross hydrological process may appear to be similar, the downstream impacts are extremely different. It is important to again point out that debris flows resulting from natural events carry large quantities of wood with them, while debris flows that follow logging activity contain little wood and vastly elevated proportions of sediment. As a result, the debris flows resulting from natural processes like fire (or even the massive slope failures that occur naturally on the lands we should be classifying as unsuitable) are much less damaging to the ecosystem. In fact, the wood they contain eventually increases habitat and may prove to be a required and irreplaceable component in the dynamic equilibrium of riparian corridors.

"Very few attempts have been made to verify the reliability of sediment delivery models due to the difficulty of obtaining sufficient data for testing. Op Cit ppIV.62

Had these attempts at verification been made with more frequency or more rigor, perhaps the authors and users of this tool would have noticed this fundamental and obvious difference between the performance and downstream consequences of these inevitable peak events on managed and natural streams.