This post is not really about the multifaceted and fascinating roadless controversies; it’s about clarity of communication in the press-where citizens should become informed on public policy issues.
Suppose you read this piece, “Forest Service cuts back logging in Oregon roadless area on fire safety project”
Here’s a quote:
The project scaled back commercial logging from 621 acres within roadless areas to 78 acres. It is all along a road on the western side of Diamond Lake that serves 102 private cabins on federal land, Dils said. Without the logging there is nowhere for firefighters to make a stand against a fire moving out of the roadless area toward the cabins, Dils said.
“When they designed this plan it really looked like they wanted to test the limits of the Obama administration on roadless,” said Steve Pedery, conservation director for Oregon Wild. “And from our cursory look the new plan looks like it scaled that way, way back, but it seems they still can’t resist pushing the envelope a little bit.”
People who take the English language literally might wonder how cutting trees along a road would impact “roadless” values.
I italicized the sentence about the fuelbreak for firefighters because that is a very clear statement of the objectives of fuel treatment in a WUI area, whether the trees are dead or alive.
Here’s another quote:
The two-year-old project was widely seen as a test of President Barack Obama’s campaign promise to protect the 58 million acres of backcountry that has never been commercially logged on national forests across the country.
But how can an area next to a road be considered “backcountry”? I am mystified as to why this apparent paradox does not seem to be addressed in this article.
30 thoughts on “The Roaded Roadless Paradox”
Sharon, you ask: “But how can an area next to a road be considered “backcountry”? I am mystified as to why this apparent paradox does not seem to be addressed in this article.”
Well, I would ask how can an area next to a road be considered “Wilderness?” Easy, we have plenty of official Wilderness Areas in this country that are border by roads or start at a developed trailhead, etc.
The same for an inventoried roadless area. Just because a road might make up one part of the Roadless Area boundary doesn’t mean that the roadless area isn’t roadless, right? I’m not familiar with this specific case in Oregon; however, it seems pretty clear to me that a 50,000 acre IRA could easily be bordered on a side by a road and still rightfully be considered “roadless.”
Roads are used as boundaries for several reasons. Why not use watershed boundaries, or, when not possible, have a “road buffer zone”, which allows management from the road, while still barring activities like landing building and temporary roads. Roads have already been used as boundaries, and I don’t see much sense in re-drawing the maps.
The idea that the “backcountry that has never been commercially logged” is ludicrous! Helicopter salvage has occurred in a great many Roadless Areas over the decades. And, how about the existence of skid trails and overgrown roads within the designated Roadless Areas?!?
If the Clinton “legacy” is shot down, and Obama steps up and pushes his own (as he has already stated), that might be the time to install reasonable road buffers that still protect the Roadless Areas and allow hazard tree projects.
I predict that we’ll see more helicopter salvage projects within Roadless Areas, and the controversy will rage on. Snaghuggers will sue!!
Well maybe we need a new 2011 roadless rule with a “buffer” provision 🙂
Joking aside, backcountry/wilderness/roadless areas have to begin somewhere right? Right or wrong, federal agencies (and local governments) use roads all the time to make basic zoning decisions (residential, industrial, to distinct population segments under the ESA).
What I don’t know about this story is how exactly this is a litmus test for the 2001 rule and Obama’s administration of it. The 2001 rule contains exceptions, including for road building if necessary, for “protection mesures, such as protection of public health and safety from IMMINENT THREATS of flood and fire….”
Another angle that could have been taken here is how much the USFS spends in protecting structures like these (inholdings?) and other residential subdivisions in the WUI.
Yes, Matthew and Martin, I agree that roadless has to start somewhere.
My point was that it’s a bit of a paradox to talk about “roadless values” with regard to this specific project … that is along a road.
At the risk of seeming a hopeless roadless geek, the 2001 Rule does allow cutting trees for fuels reduction according to the exception ” To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects, within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period.”
So, in a ponderosa pine stand, it happens that thinning for fuels treatment neatly fits. In a lodgepole stand, on the other hand, many people have spent much time discussing whether it fits or not. You can imagine. discussions along the lines of “what are “uncharacteristic” wildfire effects?” “Who knows what the “natural” disturbance regimes are in this changing climate period?” But people have been using this exception for a variety of fuel treatments.
We have been told by those who should know (those of the legal persuasion) that “imminent threat” has been defined by case law to mean when the smoke is in the air and people are calling out airplanes (or not, Andy :)) and fuel reduction projects don’t fit that exception.
You did raise a good question, Martin, how much more restrictive than the 2001 Rule does the Obama administration need to be? When there was no 2001 rule, that Rule’s restrictions were the litmus test; now that it is back, in the 9th Circuit, what is the litmus test?
I am quite familiar with this project. My grandfather owned one of the cabins to be protected and i have reviewed the draft DEIS in great detail. A few things to keep in mind:
(1) this part of the project area is high elevation mixed-conifer forests. This is not a frequent fire regime. The fire season up here is short. During many of the field tours for this project we have stood around in thawing snow banks.
(2) There is already a significant amount of fuel reduction proposed on the non-roadless side of the loop road closer to the cabins. Maybe that is enough to protect the cabins.
(3) The FS rejected our suggestion to treat the edge of the roadless area with _non-commercial_ fuel reduction methods. It strains logic to think that there is only one right way to reduce fuels in this IRA and it _requires_ commercial removal.
This project also involves commercial logging in two other types of roadless areas: (A) an uninventoried roadless area that is directly adjacent to Crater lake National Park. Why this unroaded forest (many tens of thousands of acres in size) was not included the RARE II inventoried remains unclear to me, and (B) roadless areas not quite protected by the congressionally designated Oregon Cascades Recreation Area.
Finally, this is an HFRA project that is supposed to (a) follow the forest plan and (b) restore old growth, but they are (a) amending the forest plan, and (b) significantly reducing some late successional fores types.
Doug- it’s great to hear from someone who knows the area. Thanks for contributing!
It would be helpful to our discussion to have a map of the proposed 78 acres, the roadless inventory area, the road and the recreation residences. Here is the link to the project documents.
I used the Google Earth link on the page. Wow! I suppose I’m easily impressed by technology but… Unfortunately I didn’t know the latitude and longitude of the recreation residence area.
I found this photo of prescription 10- Doug, is that the prescription used in the roadless 78 acres?
I am trying to understand the concern about “commercial” logging. I can understand a concern about “big trees” but I don’t understand the way you use the term as somehow being worse than noncommercial treatments. What about the “commercial” part is undesirable in terms of environmental effects on the land?
Where I live we have miles of decks of dead trees along roads that most people wish could be sold and removed, rather than burned or left on site. You all could sell your dead trees but are concerned about doing so.
It sounds like you are concerned that the non IRA areas that are roadless because they are not “protected”- what specific things do you think it’s important for them to be protected from?
RARE II was a long time ago and there were many problems associated with using those boundaries. At that time GIS was not even a gleam in anyone’s eye.
The inventory used for the 2001 Rule was the best people had at the time. Some have argued that if there is a need for a new national rule that the first thing to do would be to update the inventory. That’s what we did in Colorado; but that’s another story.
The IRA logging in question is west of the lake, colored dark green, and labeled with an “8” here: http://imgur.com/5qGaQ
Opponents of all logging like to label projectsd as “commercial”, to plant in the public’s mind that HUGE trees are being cut for excessive profits. Today’s projects use the “commercial” part of the project to help pay for the non-commercial activities always included in each and every timber sale. Without the “commercial” part of the project, nothing gets done! If the commercial aspect doesn’t meet with the mill’s bottom line, they won’t bid on it, and the Forest Service loses the significant prep costs (which are growing bigger and bigger every year! My “billable rate” on projects two years ago was $66 per hour, to do specialized timber work, for Ranger Districts that didn’t have the qualified personnel!)
Also, I wouldn’t consider the Diamond Lake area to be “high elevation”. The lodgepole forests there have also reached the end of the line, where diseases are severely impacting the bark beetle survivors. There are hundreds of structures in the Diamond Lake area, all of them at-risk, especially where lodgepoles have invaded into mixed conifer stands.
“Commercial logging” includes cutting trees all the way down to 10″ in diameter, and “large trees” already have absolute protections above 21″ dbh. I’m not sure but, that 21″ limit might be different in the mixed conifer/true fir areas.
To me there is a meaningful difference between commercial and non-commercial treatments. Commercial logging means that some of the productive capacity of the site is being exported so it cannot contribute to the ecological functions at the site. Commercial logging means that some biological material is being removed. Wood that is big large to be turned into dimensional lumber is also biologically valuable as snags and coarse wood. Non-commercial treatments tend to focus on smaller material that is less likely to serve ecological functions while still reducing fuels and fire hazard.
Here is a great read about the values of dead wood: Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., Waddell, K.L., Lindely, D.L., and B. Schrieber. 2001. Decaying Wood in Pacific Northwest Forests: Concepts and Tools for Habitat Management, Chapter 24 in Wildlife-Habitat Relationships in Oregon and Washington (Johnson, D. H. and T. A. O’Neil. OSU Press. 2001) http://web.archive.org/web/20060708035905/http://www.nwhi.org/inc/data/GISdata/docs/chapter24.pdf
Forgot to mention … there is no 21″ dbh limit in this project. Lots of trees larger than 21″ will be removed in mixed conifer areas (hopefully not in the roadless area, but there are no guarantees.)
So, basically, you are saying that “commercial-sized” trees are never overstocked and never need to be thinned?!? That once invading lodgepoles reach “commercial size”, that they should never be cut?!? That we should let fuels build-up until a Biscuit-like fire rages through and “re-sets” forests back to zero?
There are, indeed, ample areas in Oregon where the lodgepole forest meet the mixed conifer forests, and we have allowed the flammable lodgepole to become ladders fuels underneath the old growth. I’d say the Diamond Lake areas fits into that description rather nicely.
There will never be a shortage of decaying wood in our National Forests, unless we let them burn at high intensities. Fuels are fuels, whether they are live or dead.
Indians in the area knew very well that they had to alter their landscapes, through prescribed fires, for their very survival. Why not mimic those “cultural landscapes”, which worked quite well, over many centuries?
Personally, I think that mills should merely break even on Forest Service projects, considering it to be their “patriotic duty”. It’ll never happen but, that’s my opinion.
@Fotoware I was trying to clarify the ecological difference between commercial and non-commercial logging. I did not say that “trees are never overstocked and never need to be thinned….”
Thinning lodgepole is not ecologically supported. Late successional lodgepole may not look pretty to people who like neat forests of vigorous trees, but black-backed woodpecker and other species like the “mess.” We need to evaluate our prejudices against certain natural cycles?
And I did not say we need to thin in pure lodgepole stands. Don’t you think it’s important to restore forests which aren’t in balance? Forests where lodgepoles have invaded and put the entire stand under stress. What I am saying is that forest resilience and vigor could be enhanced by restoring species composition and stand densities. That being said, insisting on embedding a timber sale into a designated Roadless Area doesn’t seem like the greatest idea. The Forest Service should be avoiding that kind of controversy, if they want to accelerate emergency fuels projects. However, if hazardous trees do have value, they cannot be removed without an embedded timber sale. Since this is supposed to be a fuels project, leaving merchantable fuels seem counterproductive to the project’s purpose.
Now, I cannot understand why some people are actually against forest restoration. Those people would rather let “nature” takes its course, ignoring risks, impacts and uncertainties, hoping for the best. I think that is why many eco-groups don’t want to even talk about forests, anymore. They don’t want consensus or compromise, preferring to ignore man’s role in today’s “nature”, still “fighting commercial extraction”.
Doug- you said “Commercial logging means that some of the productive capacity of the site is being exported so it cannot contribute to the ecological functions at the site.”
Sure big trees and little trees are both needed for ecological function. But it is hard to imagine that they are all (each and every one) “needed”. I don’t know of anything scientific that would say ALL of the big trees currently there need to stay- in fact they won’t if a fire runs through and burns too hot.
I guess my view is that if you have to take certain kinds and mixes of trees off anyway to meet the purpose and need of the project (and this seems to be the area of disagreement), it shouldn’t matter if you sell them or not. At the risk of leaping into an even more controversial topic, it seems like certain uses of commercial trees could have some carbon and other environmental benefits.
I would just remind you that we’re talking about an inventoried roadless area. I would like to respect natural processes rather than consider how much to “take.” Due to past mismanagement, there is a shortage of large snags and down wood in our forests. Restoring forest health therefore requires that we recruit more, and commercial logging will tend to delay attainment of restoration objectives. Can we at least refrain from that in a roadless area?
Scientific evidence does not support the notion that commercial logging can benefit carbon and climate goals. The only exception is removing the smallest fuels from forests with the most frequent fire regime which is not the case here. Mitchell, Harmon, O’Connell. 2009. Forest fuel reduction alters fire severity and long-term carbon storage in three Pacific Northwest ecosystems. Ecological Applications. 19(3), 2009, pp. 643–655 http://ecoinformatics.oregonstate.edu/new/FuelRedux_FS_CStorage_Revision2.pdf Although thinning can affect fire, logging is likely to remove more carbon by logging than will be saved by avoiding fire.
Doug thumps on the “natural” drum while at the same time talking about “restoration objectives”. You cannot “restore” forests by doing nothing! There are all these claims about fire suppression and grazing and “climate change” impacting forests, while at the same time talking about “pristine wilderness”, “natural” forests and carbon sequestration. When up to 300 TONS of carbon goes up into our atmosphere per acre in catastrophic wildfires, preserving vast tinderboxes of dead and dying forests doesn’t seem like a good idea. I’m sure eco-groups would have considered the Biscuit Fire area to be similarly “pristine”, “natural” and in need of “protection”, before it burned.
Chances are, wherever lodgepoles and other mixed conifer species are together, that means those lodgepoles have invaded, and are probably outside of their “natural” ranges. In fact, when fires burn in such forests, it’s the lodgepoles which grow back quicker and squeeze out the previous forest. Voila! A “natural” monoculture!!
What I envision happening is that “preservationists” don’t want ANY management to go on in Roadless Areas (despite forest health issues!), late successional reserves, potential “wildlife corridors” and potential new Wilderness Areas. They fear that any management at all would disqualify some areas from Wilderness consideration. The vast proposed “wildlife corridors” have died since the idea first came out and now, those areas just aren’t suitable for that use. Preservationists want very much to have these corridors so that “charismatic” species can roam to their former historic ranges, despite the severe unsuitability, the human factors and the lack of prey.
With 22 million acres of dead forests, I really don’t think there is a shortage of black-backed woodepecker habitat, as well as other species who depend on snags. I’d even be willing to go as far to say that there is MORE snag habitat now than there has been in the last 12,000 years! I’d also be willing to say that there is more “arsonist habitat” than ever, as well (with arsonists being a “natural” phenomenon in all historical societies).
The biggest “dead forest” problem we have in Oregon is related to clearcutting on non-federal forest lands. We don’t have a significant problem with beetle killed forests in Oregon. Where natural mortality occurs, it seems to be within natural limits. Some mortality events are large some are high severity, but most events exhibit a mix of scales and severity levels that do not raise ecological concerns among knowledgeable people.
We may have a lot of small snags in some areas. However, due to past logging, plus fire suppression, plus salvage logging, plus repeated thinning entries that “capture mortality” before it can become a snag, there is a significant shortage of large snags and large dead wood in Oregon’s forests. You can disagree but that is what the science says.
Only 4% of the Biscuit Fire was salvage logged so, there should be “ample” amounts of snags over 500,000 acres (I have pictures!). You seem to forget that eastern Oregon is riddled with bark beetles and mortality, with lodgepoles squeezing out the fire and drought-adapted P. pines. Your plan would further reduce P. pine populations, as well as those endangered species that depend on having long-lived, resilient forests.
You simply want to return our forests to pre-man conditions, without knowing what those were, and sacrificing too much to get there (if we would actually know when we got “there”). When 100 and 200 year old P pines meet an early demise, endangered species lose their habitat.
Sure, let’s consider letting PURE stands of lodgepoles “do their thing”. However, in “unnatural” forests, we need to intervene and restore forests to a more “natural” state. You don’t offer “restoration”. You like the power of the word but, you don’t like the definition.
And, what about historical “cultural landscapes” created before the Europeans came? Do we toss away that wonderful form of stewardship in favor of “Gaia worship”?!? There’s little room for “faith-based” forest unmanagement.
The acres may be in an “inventoried roadless area” but they may not have roadless character to protect.. say if they are along a highway or next to a house. Some have argued that cleaning up the inventory (swapping out roaded roadless acres and adding unroaded acres) would be a great way to not have this discussion over and over again.
I think we are approaching it from different angles.
Here is my logic path. There are houses with dead trees around them. If we accept this quote at face value,
the goal is to make a firebreak safe for firefighters around these homes. To do that we need to remove dead trees (of different sizes, I assume) that will fall on them or make a mess of jackstrawed logs for them to work in.
So my logic is GIVEN THAT WE NEED TO REMOVE TREES for these firefighter safety purposes, and thereby remove some soil carbon, it is better to use the trees for something (replacing fossil fuels or other building materials) from the carbon perspective. That is not the same argument as the “avoiding fire” vs. “treatment impact on carbon” discussion.
You seem to be thinking that taking off the large trees would be bad for restoration.. but firebreaks are intended to be firebreaks first.
So your argument seems to be that “restoration” should be the target for vegetation treatment in roadless areas. I would tend to generally agree with you if we had no homes or other infrastructure to protect from fire in IRAs (or on the border). So maybe redrawing boundaries so there is a fuel break distance from roads and structures, and swapping the same amount of unroaded acres (not currently in IRAs) into IRA boundaries would work for everyone? It shouldn’t be hard to find 78 acres of unroaded area with a high level of roadless characteristics that are not in an IRA.
Yes, restoration should be the focus in IRAs. It is very clear where the roadless area starts – at the road. All roadless areas are bounded by roads; that’s what makes them roadless and unique. To debate another definition of where roadlessness starts and ends opens a huge can of worms. It also shrinks the scope of areas we’ve fought so hard to protect.
Just to be clear, this project is not focused on removing just dead trees. Many live tree will be removed. There is no diameter limit. (Though hopefully “thinning from below” will protect the larger trees).
In the roadless areas slated for commercial logging the FS could accomplish most if not all of the hazard reduction objective through non-commercial methods (surface and ladder fuel reduction, with handpile and burn). It is unreasonable to assume that commercial logging is the ONLY way to accomplish objectives in this roadless area. The agency often claims that “canopy fuels” (coincidentally attached to big trees) must be removed, but Jim Agee and others say that is the least important element of hazard reduction. Also, canopy removal can have contrary effects by making the stand hotter, dryer, and windier.
Elsewhere in this project, there are hundreds of acres of commercial logging along roads that conservationists are NOT objecting to, which can facilitate the non-commercial treatment of these few roadless acres.
I’m not at all questioning whether it is wise to use a commercial timber sale in a Designated Roadless Area (if that is what it really is!). Simply to reduce controversy and litigation, it would be very foolish to ignore the options of other treatments. For example, instead of selling those logs to a mill, why not sell the cut wood to firewood vendors, instead? Or give it away to non-profit groups? Or build forest improvements out of it?
Thinning from below and crown seperation are proven techniques for improving fire safety and forest resilience. If a suppressed 28″ white fir is growing underneath a 48″ ponderosa pine, that would be a good candidate to cut, helping to pay for non-commercial parts of the project. Have you considered how much hand-piling and burning costs, these days?!?!? It has to get paid for, or the mills aren’t going to bid on it, and cabins might burn (as well as your precious Roadless Area!)
I tend to think that the Forest Service is trying to set a precedent (and that certainly scares the preservationist types). They have to assume that this project WILL go to court, and they want to be able to use the provision of forest health as a reason to commercially enter Roadless Areas, yet again. Hey, if the preservationists are OK with the rest of the project, I’d want to take another look at doing the work without sending those roaded roadless logs to the mill.
Doug- you said
But my suggestion was not a net loss of roadless acres; I specifically said it would be possible to swap out 1 for 1 acres. Get another acre not along a road or next to residences.
First, I don’t think commercial logging is EVER the only way to accomplish objectives for fuel treatment. Otherwise, those of us without convenient mills would never do fuels treatments. I think the logic may have been “as long as we need to take out trees that are commercial sized, we might as well sell them.” If the prescription is “thinning from below” that would seem to mean that they are not actually taking out the biggest trees. My understanding of that prescription is that the biggest trees are left and other trees close to them and under them are taken out.
Foto- you said
Aren’t firewood vendors a commercial use? wouldn’t you need a sawmill of some kind to make forest improvements (not 28″ logs)?
My point is that if the environmental effects of removal are the same, the commercial or non-commercial nature of the use shouldn’t matter, just the comparative environmental effects of the different uses of the wood.
The idea of a swap is not appealing because the proximity of these proposed “traded” acres adjacent to a huge roadless area is a valued-added feature that cannot be recreated elsewhere. One of the most critical ecological values of roadless areas is their size. Historically, most habitat was found in large intact blocks. Now, habitat is mostly found in predominately in small fragmented blocks. It does not sound like a good idea to swap unfragmented habitat for fragmented habitat.
It seems like we should be able to respect roadless values in places where we have never previously found a need to build roads or log.
You suggest that the commercial size trees “need” to be removed and should be put to good use. Another view is that commercial sized trees do not “need” to be removed. Large trees do not significantly contribute to fire hazard, and their removal will reduce habitat values associated with dead wood.
I am simply suggesting that the multiple public objectives (e.g. roadless conservation AND fire hazard reduction) can be best harmonized by non-commercially thinning from below, focusing on surface and ladder fuels. Commercial removal has two unnecessary adverse effects: loss of habitat, and soil compaction and disturbance associated with commercial extraction. Non-commercial implementation will mitigate both of these concerns.
Let me try to spell this out, once and for all. Doug’s main issue seems to be the commercial removal of logs from the Roadless side of the road. There is no doubt that merchantable, and even quite large trees will be cut as hazard trees, due to the decadence and damage to old growth trees during the original road building. Public safety, the timber sale contract and OSHA laws require hazards to be dealt with. It doesn’t matter if the road borders a Roadless Area, safety is safety and law is law. (Remember, Region 6 DOES have a hazard tree marking certification program!)
So, now that we have established that, we can talk about post-felling scenarios. If that substantial amount of merchantable hazard trees are left in place, as Doug prefers, what is to stop woodcutters from driving in, bucking them up and driving away with “easy pickens”?? Or, we can use their value to offset other non-commercial tasks included in the project, such as piling and burning (without installing skid trails and landings within the Roadless Area). I have seen where logs can be removed with very little damage or impact. I have pictures of how carefully trees can be cut and removed, even within an archeological site. With the road directly adjacent, a wheeled loader or processor could easily pick up logs along a road. Also, those trees on the Roadless side could be “jacked” to fall towards, or even across the road, with even less impacts.
Well, just what is being done with unmerchantable material in other parts of the project? Piled and burned? I was merely suggesting that not sending logs to the mill might be an alternative more palatable to potential litigants. Lodgepole logs could also easily be made into campground fences or other useful items. A non-commercial treatment probably wouldn’t include cutting larger trees over 12″ dbh. However, such areas CANNOT be made safe to firefighters without cutting hazard trees along roads, regardless of the lines on the maps. The winds generated from fires are substantial enough to topple unstable trees. If the road cannot be made safe, then it needs to be closed. Doug doesn’t seem to agree with these facts.
You know I think we are back to a lack of clarity as to what treatments need to be done to meet the purpose and need. The purpose and need is a firebreak “for firefighters” as it says in this Oct 7 story “The Forest Service says the project will focus on protecting homes and resorts from fire, creating evacuation routes and providing firefighters areas to combat blazes. ”
1) As Foto points out there are hazard trees that need to be removed to make the firebreak safe for firefighters.
2) What other trees need to be removed to make a good firebreak? We don’t know as we currently trying to find out what’s there and what the prescription is. We could disagree but right now we don’t exactly know (I am looking through the documents trying to find out).
We could possibly agree on the prescription meeting the purpose and need, but right now I am not sure. I’m not sure that Doug agrees that the purpose and need is legitimate in a roadless area. Although the 2001 Rule thinks it is.
3) Finally, if we did a)agree that the purpose and need were legitimate, AND b) if we agreed to the prescription for which ones are cut, THEN c) we could disagree about whether they could or should be burned on site or moved off site. If they are moved off site, I was arguing that it shouldn’t make a difference d) if they are sold or not.
I am thinking that Doug may disagree with A and B and C and really not so much about D. My being literal-minded interpreted his original comments as being entirely about D, as in”To sell or not to sell, that is the question.”
Felling trees that represent a real hazard to public use of the road are not at issue. The FS takes care of those hazards that regardless. (And again it can be done non-commercially).
The roadless rule does not endorse logging for fire breaks.
The rule prohibits logging except is specific circumstances and fire breaks are not one of them. Restoring “characteristic structure” is allowed when it will “improve one or more of the roadless area characteristics” (but again “characteristic structure” is best restored via non-commercial methods that retain the larger wood).
Fire breaks do not represent a characteristic structure and they do not enhance any of the recognized roadless values.
Don’t forget, the other side of the road where the cabins are located is already being treated and no one is likely to object to that.
Hmm. It does not look as though there is really an exception for hazard trees, unless road maintenance is thought to be an activity “not otherwise prohibited in this subpart”
But would building fuelbreaks be not “otherwise be prohibited?” same as road maintenance?
Certainly removing hazard trees does not “improve one or more roadless characteristics?”
So I think there are arguments related to the 2001 Rule and what it allows, and also about practices that you agree and disagree with. It sounds like you agree with hazard tree removal, whether or not it is allowed by the 2001 Rule, and against the fuel break on the “roadless” side of the road unless you can make a fuelbreak that also “restores characteristic structure.”
My problem with the 2001 rule language is that people who have ponderosa pine fuelbreaks get to have them because firebreak requirements and characteristic structure happen to coincide. For other ecosystems, they do not coincide, so those people seem, perhaps unjustly, to be out of luck.
Also, your statement “The idea of a swap is not appealing because the proximity of these proposed “traded” acres adjacent to a huge roadless area is a valued-added feature that cannot be recreated elsewhere. One of the most critical ecological values of roadless areas is their size. Historically, most habitat was found in large intact blocks. Now, habitat is mostly found in predominately in small fragmented blocks. It does not sound like a good idea to swap unfragmented habitat for fragmented habitat.”
A look at the map here shows many possibilities for adding acres to decrease fragmentation on the north side of the Mt. Bailey IRA . But perhaps the gaps we see are in other ownerships- couldn’t tell from this map.
Well, if hazard tree removal is deemed to be unsuitable along a road which is a Roadless boundary, that road should be immediately closed, tank-trapped and obliterated to avoid government liability for injuries and deaths. Remove the culverts and let the cabins burn or decay back to nothing. Simple as that! By all means, let’s go to court over this so we can decide the safety issues once and for all. Pretending that hazard trees won’t hurt people isn’t in the best interests of the taxpayers.