Volume 8, Number 2 The newsletter of Forests Forever Fall, 2004

Victory for Oak Woodlands Protection Act!Jackson Forest and Heritage Tree bills killed

Administration throws out roadless rule

Fooling with the federal forests...6

activist strikes a blow for ancient trees...8

Oaks still need a lot of saving...2

Presidential Candidates: Babes in the woods...3

Poisoning Forests to make trees grow...4

Inside The Watershed

The U.S. Forest Service on July12 issued a proposed rule that, ifadopted, would eliminate theRoadless Area Conservation Rule.

The roadless rule was writtenduring the Clinton administrationand put in place in January 2001.It was developed in 600 publicmeetings, and received 2.2 millionsupportive public comments.

It protects 58.5 million road-less acres of national forest fromdevelopment, helping to ensureclean water, wilderness recreation,and habitat protection.

Last year, the administrationannounced it was going to allow

governors to exempt their statesfrom the rule if public health andsafety were at issue.

The proposed new regula-tions, however, turn this promiseon its head. Under the new rule,governors would be required topetition the Secretary of Agri-culture to protect roadless areas intheir states.

The secretary would have finalsay on such proposals. For exam-ple, if California Gov. ArnoldSchwarzenegger wanted to protectthe roadless areas in Los PadresNational Forest from oil and gasexploration (potential drilling sites

See “Roadless rule,” p. 10

The native oak woodlandsthat cover about one-third ofCalifornia gained increased pro-tection on Sept. 24 when Gov.Arnold Schwarzenegger signedSenate Bill 1334 into law.

The Oak Woodlands Protec-tion Act cleared the Assemblyfloor Aug. 23 on a vote of 41 to34. The bill had been ForestsForever’s primary campaignsince November 2003.

Two other forestry meas-ures did not fare as well in this

year’s legislative session.The State Forest System

Reform Act, SB 1648, authoredby Sen. Wesley Chesbro (D-Arcata), passed the Assembly onAug. 27 by a vote of 43 to 34, thenthe Senate, 22 to 13. But on Sept.16 Schwarzenegger returned it tothe legislature unsigned.

And the Heritage Tree Pres-ervation Act (SB 754), intro-duced by Sen. Don Perata (D-Oakland), expired with the leg-islative session.

The Oak WoodlandsProtection Act

The oak woodlands bill,authored by Sen. Sheila Kuehl(D-Santa Monica), requirescounties to consider possibleadverse impacts to oak wood-lands in planning developmentprojects covered by the Califor-nia Environmental Quality Act.

The new law also requiresmitigation measures if a projectwill have a significant impact onoak woodlands.

These mitigations includepurchase of conservation ease-ments to preserve oak wood-lands, replanting or restoringformer oak woodlands, and con-tributing to the Oak WoodlandsConservation Fund. Discretionis given to counties to develop awide range of alternatives.

“We were thrilled to see thegovernor sign this bill toimprove protection for our oakwoodlands,” said Paul Hughes,

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The Watershed

See “Oaks bill,” p. 12

Fall, 20042 The Watershed

from the Executive Director

Beneath the strong and shelteringlimbs of a large coast live oak tree on asummer afternoon in 1842, FranciscoLopez awoke hungry from a nap.

Gathering nearby wild onion for hismeal, the story goes, he noticed goldflecks on the plants’ roots. His find ledto the state's first gold strike, pre-datingthe big one in ’48.

What came next, history tellsus, was a radical transformation ofCalifornia’s oak woodlands andits entire natural environment.

As Forests Forever supporterscelebrate the enactment of the OakWoodlands Protection Act (seestory, page 1), we should also con-sider the unfinished agenda.

The bill signed by Gov. ArnoldSchwarzenegger on Sept. 24 makesimportant improvements in the regulation of oak woodland “conversions” (i.e., destruction).

The new statute requires thatadverse impacts to oaks be formallyconsidered in planning many develop-ment projects. Developers now willhave to apply specified mitigations tooffset damage done to oak habitat.

The net effect should be to reducethe rate and intensity of oak woodlandsdestruction and provide citizen activistswith more tools, legal and regulatory, tosafeguard oaks.

We need these tools. Oak woodlandshave been disappearing at a staggeringrate– estimated at one to two millionacres since World War II– mostly to makeway for agriculture, subdivisions, shop-ping centers and roads. While these rateshave slowed somewhat in recent years,another quarter million oak-covered acrescould be destroyed or degraded by 2010.

Oak woodlands are among the mostproductive forest ecosystems in thestate, housing more species of wildlife–331 vertebrates, including 32 types ofbirds and 39 kinds of mammals– thanany other vegetation type.

Oaks were a mainstay for Native

Americans before European settlement.Five mature black oaks could provideenough easily stored, high-carb acornsto produce enough meal to feed a typi-cal family for a year.

Oaks provide wildlife with a uniquearray of goods and services, includingtemperature-moderating canopy, nesting

locations and materials, trunk cavities,understory shrubs, litter and moisture atground level, and below-ground habitatfor burrowing rodents, spiders, and inver-tebrates. And of course food in everyform, from acorns and leaves to twigs,sap, roots, pollen and catkins.

But the chief threats to these beauti-ful and rich ecosystems are not fullyaddressed in the bill just signed into law.

The greatest threat is the conversionof oaks for agriculture. The state’s mus-cular agribusiness lobby got its backersexempted from the oaks bill just enacted.Yet ranching gobbled up about 32,000acres of oaks a year between 1945 and1973. Many thousands of acres a yearstill are bulldozed for grazing, as well asfor row crops, orchards and vineyards.

An array of factors keeps oaks fromregenerating. These include soil com-paction by livestock (preventing acornpenetration), and fire suppression– wild-fire historically swept the seedbed clear ofduff and debris, leaving usable nutrientsbehind in the ash.

Predator control has led to increasesin the number of acorn- and seedling-munching deer and rodents. Levees anddams eliminated natural flood cycles,starving riparian forests of their regulardelivery of nutrient-laden silt.

All these problems facing oaks, andothers too numerous to list here, have

solutions. More-compact urban develop-

ment is one. Greater reliance onmass transportation instead of land-gobbling freeways will go a longway too.

And greater emphasis must beplaced on preserving undisturbedoak woodlands, restoring damagedareas by planting oaks and nativegrasses, controlled burning, andremoving exotics; and increasingsustainable economic uses of oaks.

Oak woodlands can be parks,natural laboratories and class-rooms, and a limited source of fire-

wood. We can even develop markets forwood products from downed oak. Wecan improve grazing practices.

Many of these solutions are under-way; now we must accelerate them.

The oak under which Francisco Lopeznapped is still standing, in PlaceritaCanyon in Los Angeles County. Likemany of California’s legendary oaks ithas a name: People call it the Oak of theGolden Dream.

Today many of us would define a“golden dream” a little differently thanthey did in 1842. One would hope it willnot, like the dreams of Mr. Lopez, foretellthe destruction of our most-iconic Cali-fornia landscape. We’d rather it be a dreamof the future– of the oaks’ salvation.

—Paul Hughes

“Developers will have to apply specified

mitigations to offset damage done to

oak habitat.”

Despite welcome newly enacted protections,California’s oaks not yet out of the woods

Fall, 2004 The Watershed 3

Forests in the Voting BoothAs the election draws near, The Watershed takes a look at the positions

and public statements of the presidential candidates on America’s forests.

Amid the white noise often generated bythe presidential campaigns, it can be hard toget a fix on the issues you care about.

And even when the candidates speakclearly about where they stand, the envi-ronment generally gets little air time.

The Watershed has gone to the candidates’websites, speeches, and public statements,hoping to shed some light on their ideasabout forest protection. Here, in alphabeticalorder by party, are a sampling of the candi-dates’ positions:

Democratic PartyJohn Kerry/John Edwards

The Kerry/ Edwardscampaign promises toredress changes madeby the Bush adminis-tration to the NationalEnvironmental PolicyAct, and to increasefunding for fire protec-tion in Wildland-Urban

Interface zones from the 50 percent of fundsgranted under the Healthy Forests Res-toration Act to “a minimum of 70 percent.”

They promise to restore “meaningfulpublic participation” and provide for greaterlocal input into fuels-reduction projects.

The campaign ties the creation of jobs torestoration forestry and fire prevention.They would transfer $100 million “from gov-ernment subsidies to the timber industry”and create a Forest Restoration Corps.

This would create jobs by restoringforests, streams and rangelands that havesuffered fire damage or poor management.

The campaign promises loans and gov-ernment partnerships for businesses thatcreate sustainable forest products and bio-mass energy.

They promise support for firefightersand grants for small businesses that fire-proof homes or provide fuels treatment inlow-income communities.

More broadly, Kerry/Edwards prom-ises to keep old growth off limits to loggingin national forests.

Kerry is a co-sponsor of a bill authoredby Sen. Maria Cantwell (D-OR) that wouldpreserve as wilderness the roadless areasthat until recently were protected under theClinton-era Roadless Area ConservationRule. (See story on page 1.)

The national League of Conservation

Voters gave Kerry a lifetime grade of 96 per-cent for his voting record on environmentalissues.

Quote: “Where we see a pristine old-growth forest, George Bush sees toothpicks.”–John Kerry, in a speech at the University ofNew Hampshire on Oct. 20, 2003.

Green PartyDavid Cobb/Pat LaMarche

The Green Partyoffers the most detailon forest issues.

Their environ-mental platform citesstewardship, sustain-ability, and balance inland use.

The Greens want to eliminate policiesthat lead to destruction of forest ecosystemsaround the world. They support paper-recy-cling laws and sustainable forestry practices.They want to protect old growth, and call fora “zero-cut” policy forbidding industrialtimber harvesting on public forestlands.

They want to stop all clearcutting, andreduce roadbuilding on public lands, andsupport hand-thinning and weeding offorests to replace use of chemical herbicides.

They call for increased public involve-ment in the management of public landsthrough community management districtsand councils.

More broadly, the Greens favor pre-serving complete ecosystems and opposeprivatizing public lands.

Quote: "We feel that, just as the planetaryecology consists of nested systems at variousscales, so must our programs and institutions ofecological stewardship be scaled appropriately."– Green Party platform statement on Land Use.

Nader CampaignRalph Nader/Peter Camejo

Ralph Nader’scampaign literaturemakes little mentionof forests. Nader’sposition on energy,like Kerry’s, ties envi-ronmental protec-tions to the creation ofnew technologies and

jobs. Forest issues are included by inference

in the citing of biomass as an energy technol-ogy worth supporting.

Nader’s critique of corporations lam-bastes the corporate approach to forestry.And Nader has spoken out against theBush administration’s practice of appoint-ing former industry executives to impor-tant posts in government agencies that reg-ulate those industries.

In recent speeches Nader has called foran end to commercial logging on nationalforests, and pointed out that the economicbenefits of recreational use outweigh thoseof logging.

Quote: “It gradually became clear there wasa common link between unsafe cars, contaminat-ed drinking water, destruction of rain forests, andcollapsing job opportunities . . . and that link wasrunaway unaccountable corporate power.”—Ralph Nader, in a speech to student voters.

Republican PartyGeorge W. Bush/Dick Cheney

The Healthy For-ests Initiative is theBush campaign’s flag-ship for forest policy.

According to thecampaign website,the Healthy ForestsRestoration Act re-

duces the complexity of environmentalanalysis, encourages early public participa-tion in project planning, and issues clearguidance to the courts in trying casesagainst “forest health projects.”

The campaign’s presentation of the actfocuses on the benefits of reducing cata-strophic wildfire and reducing insect infestation.

Bush was given an “F” on the environ-ment by the national League ofConservation Voters.

Quote: “The President’s [Healthy Forests]initiative is helping restore the health and vital-ity of forests and rangelands, and helpingreduce the threat of catastrophic wildfires.”

—M.L.

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John Kerry

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George W. Bush

Campaign websitesBush/Cheney: http://www.georgewbush.com/Green Party: http://www.gp.org/Kerry/Edwards: http://www.johnkerry.comNader Campaign: http://www.votenader.org/

Atrazine, an herbicide shown to changethe gender of frogs and suspected of

increasing cancer risk in humans, has beenbanned in several European countries.

Yet in 2002, timber companies sprayedover 32,000 pounds of the stuff in Californiaforests.

Atrazine is only one of the herbicideswidely used in the state’sforests that are suspected ofcausing serious health prob-lems in humans and animals.

Pesticides are poisonssuch as rodenticides, fungi-cides and insecticides, tar-geted to harm specificgroups of living things.Federal agencies and pri-vate timber companiestogether sprayed 264,539pounds of pesticides inCalifornia’s forests in 2002.

Herbicides are a type ofpesticide used to kill vege-tation. The U.S. ForestService and the timberindustry use them mostoften to prepare clearcut orburned-over areas for replanting; they aresometimes used to prepare sites for harvest-ing, and to clear brush from roadsides.

The agency and private companies alsouse some pesticides to kill insects androdents that harm trees, but most of the pes-ticides they apply are herbicides used to killplants that compete with replanted trees forsunlight and nutrients.

Herbicides’ potential for ecological dam-age is worsened by ingredients called surfac-tants. Surfactants are added to the activeingredients of pesticides to improve theireffectiveness, enhancing penetration andcoverage, for instance.

Glyphosate (better known by its brandname “Roundup”) is the most heavily usedherbicide in California forests. “In the case ofglyphosate,” says Vivian Parker, a biologistwith the California Indian BasketweaversAssociation (CIBA), “the surfactants usedmost commonly by the timber companiesand the Forest Service make the product sig-nificantly more toxic. Many surfactants arealso known endocrine disruptors.”

Parker says that the figures for annual pes-ticide use published by state agencies includeonly active ingredients, not surfactants.

“Bad Actors”Three herbicides commonly used in

California forests– hexazinone, atrazine and2,4-D– are considered highly toxic “badactors” by the San Francisco-based PesticideAction Network. “Bad actors” have at leastone of the following characteristics:

1) Are known or probable carcinogens;

2) Are known to cause birth defects orinterfere with normal development;

3) Are cholinesterase inhibitors (theenzyme cholinesterase is essential for trans-mission of nerve impulses);

4) Are known groundwater contaminants;5) Are highly toxic, meaning they can

cause extreme illness or death within sevendays of exposure.

A chemical is only deemed a bad actorby PAN if it has undergone a “weight of theevidence” evaluation, in which a panel ofexperts examines all available studies todetermine the risk. Because of the expenseand time involved, not all chemicals areevaluated in this manner.

Chemicals shown to be harmful in pre-liminary studies should be given highest pri-ority for evaluation, says Susan Kegley, sen-ior scientist with PAN. But some toxic chem-icals remain unevaluated because of indus-try efforts to prevent their listing by the U.S.Environmental Protection Agency.

“When there’s a lot of money to be made,the company will try very hard to keep itsproduct from getting a negative listing,” shesaid.

And that, according to Kegley, is exactly

what happened in the case of atrazine. In a 2003 study, U.C. Berkeley scientist

Tyrone Hayes found that atrazine causedhermaphroditism in frogs at less than 0.1parts per billion, an extremely low amounteasily found in run-off from sprayed areas.

An August 2003 report by the EPA’sindependent scientific advisory panel con-

cluded that atrazine couldnot be ruled out as thecause of cancers observedin studies of the chemical.

Yet in October theagency decided not torestrict atrazine use, sayingit found the chemical is notlikely to cause cancer inhumans. This was a directresult of the industry pres-suring the EPA not to listatrazine as a carcinogen,Kegley said.

The National Re-sources Defense Councilhas filed a lawsuit charg-ing the EPA with failing toprotect endangeredspecies from atrazine.

Typically, such suits are the only wayharmful chemicals are taken off the market,conservation groups say. Even then, Kegleysays, it is difficult to convince courts of achemical’s threat.

Poisoning wild plants and animalsOn July 27 the Center for Biological

Diversity released a report– Silent SpringRevisited: Pesticide Use and EndangeredSpecies– detailing the failure of the EPA toregulate pesticides that harm endangeredspecies. The report identifies over 375species listed under the Endangered SpeciesAct that are harmed by pesticides.

“The EPA is definitely subservient to thepesticide industry,” said Jeff Miller of thegroup’s Oakland office. “In the face of over-whelming scientific evidence of pesticides’dangers, they’re reluctant to put restrictionson them.”

One of the species cited in the report isthe California red-legged frog, listed asthreatened by the EPA and found in foreststreams throughout the state. According tothe U.S. Fish and Wildlife Service (FWS),pesticides can cause deformities, immunesystem dysfunction, diseases, injuries anddeath in the frogs.

Spraying the life out of forests

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Spraying pesticides by helicopter

Logging for profit and poisonous chemicals go hand in glove in California’s forests

The FWS says that tadpoles are likely tobe killed by chemicals such as triclopyr, anherbicide commonly used in the state’sforests. (17,699 pounds of two types of tri-clopyr were sprayed in California forests in2002, for example. See chart on page 11.)

Triclopyr is one of 25 chemicals the FWSidentifies as particularly dangerous to thefrogs; the list also includes the frequentlyused glyphosate.

Two of the other threatened or endan-gered species named in the report are theCoho salmon and steelhead trout, bothfound in California forest watersheds.

The Center’s report cites the EPA’s ownpesticide registration documents asacknowledging the danger pesticides poseto salmonid species. According to the EPAdocuments, at least 36 pesticides used in thePacific Northwest are expected to have anegative impact on salmonids.

The private timber industry sprayedover 23,000 pounds of the compound 2,4-D,which has been shown to impair trout swim-ming ability, in California forests in 2002.

Environmental, commercial fishing andprivate angler groups recently obtained acourt order preventing the use of more than30 pesticides near salmon streams inCalifornia, Oregon and Washington.

“It’s a start,” Miller said. “It’s anacknowledgement that the worst chemicalsshouldn’t be sprayed right by the stream.”

How much is enough?Over objections from environmental and

Native American organizations, the ForestService in July approved a plan to sprayalmost 5,000 acres of Stanislaus NationalForest near Yosemite National Park. Knownas the Larson area, it burned in 1987, thenwas salvage-logged.

The Forest Service said the spraying isnecessary to clear brush in order to returnthe area to its “natural” state.

But John Buckley of the Central Sierra

Environmental Resource Center (CSERC)said the agency’s true aim is to turn the areainto a pine plantation that eventually can belogged for profit. The “brush” the ForestService refers to in its reports includes thou-sands of native oak trees, maples, dogwoodsand alders, many between 10 and 20 feethigh, he says. The agency’s planned spray-ing will kill the majority of the oaks in thearea, destroying habitat for species such assongbirds.

Buckley said the spraying will alsodestroy habitat for the mountain yellow-legged frog– an endangered species named

in the Silent Spring Revisitedreport as especially vulnerableto pesticides. Buckley said thenarrow 20-foot vegetativebuffer the Forest Service plansto leave along streams in theLarson area will severelyrestrict the frogs’ habitat range.

“Not having additional veg-etative cover upslope from thestreams means the forestbecomes almost a desert inmany of these treated areas.”

Buckley said the herbicidessprayed aerially can be farmore damaging than hand-application because of themethod’s inaccuracy.

“From the air it is very difficult to see thetarget area,” he said. “The spray could goway outside the range.”

Buckley said CSERC tried to compro-mise with the Forest Service, asking that theagency use hand-application in the Larsonarea instead of aerial spraying.But Forest Service officials saidspraying the area manuallywould be too hazardous forworkers.

Not the worstForest Service pesticide-use

specialist David Bakke defendshis agency’s use of herbicides inCalifornia, saying it is relativelylimited. Data confirm that theprivate timber industry is by farthe bigger user of herbicides inCalifornia. Figures are not avail-able for individual companies’ her-bicide use.

However, in 2002– the most recent yearfor which data were available– privateindustry accounted for almost 90 percent ofherbicides applied in California’s forests.(About 42 percent of California’s 39.6 millionacres of forestland are privately owned; pub-lic forests– federal, state and municipal–cover about 23 million acres, or 58 percent.)

The Forest Service in California has

almost entirely eliminated use of herbicidessuch as atrazine that are considered to bemost toxic, Bakke says. The agency primari-ly uses glyphosate, which accounted forroughly 19,000 of the 22,000 pounds of her-bicides it used in the state in 2002. It usesother chemicals such as triclopyr and clopy-ralid, but in minimal amounts.

“All of these herbicides have gonethrough a fairly detailed look-at by theForest Service,” Bakke said. “Although wewould never claim that any pesticide is safe,for all of these we’ve determined that thedirected use is acceptably safe.”

Native plants, native craftsVivian Parker acknowledges that the

Forest Service has greatly reduced its use ofherbicides. But, she said, “that’s directly theresult of people working to get the worstchemicals off public land.”

And the agency’s continued use of herbi-cides, particularly in Stanislaus NationalForest, still has serious effects on nativeplants and the people who use them, Parkersays. Herbicide use in Stanislaus accountedfor 50 percent of all herbicides used inCalifornia national forests in 2003.

Parker said herbicides contaminate andkill native plants that are used in NativeAmerican basketweaving and in cere-monies. These plants include oak, elderber-ry, sourberry, hazel, chaparral plants includ-ing deer brush and redbud, wild plums andwild cherries.

“When foresters spray herbicides inforests they’re killing exactly those plants,”Parker said.

Basketweavers depend on materialsfound on public forests for their supplies,she says. “Basketweavers report greater andgreater difficulty all the time in finding thematerials they need.”

In addition to the destruction of materi-als used for baskets and ceremonies, CIBA isconcerned about the hazards herbicidespose to people handling sprayed plants.

Fall, 2004 The Watershed 5

See “Spraying forests,” p. 11

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Red-legged frog (Rana aurora)

Meter-Jet handgun for spot application of herbicides

Bush administration forest policies haveincreased the amount of logging on federallands while reducing public input, limitinglegal recourse, and overriding protectionsfor wilderness, endangered species, waterquality, and old growth.

The administration has implementedits forest policies through rule changes thatcan be put in place without consultingCongress. Another strategy is “sue and set-tle,” wherein the Justice Department re-fuses to defend against anti-environmentallawsuits, “settling” them in favor of indus-try and allowing adverse rulings to gounchallenged.

These tactics have been used to under-mine 30 years of federal forestry law.

The National Environmental Policy ActFinding ways around the National

Environmental Policy Act has been centralto the administration’s attack on forest regulations.

The NEPA is the keystone of federal envi-ronmenta lpolicy. Theact requiresfederal agen-cies and fed-erally fund-ed develop-ers to con-sider the en-viromentalimpacts oftheir pro-posed ac-tions, assessalternatives,and solicitpublic com-ment.

Based onthis evalua-tion, a proj-ect may bemodified to protect environmental values or(rarely) stopped altogether.

The ability of environmental groups(such as Forests Forever) to influence land-use decisions in favor of conservation restslargely on NEPA.

An important provision of NEPA is the

environmental impact statement, which isrequired when a project will have a signifi-cant effect on its surroundings.

Many of the Bush administration’s rulechanges are exemptions from NEPA thatseek to get around these requirements.

Categorical ExclusionsThe administration has used categori-

cal exclusions to exempt fuels-reductionprojects from the reporting requirements ofNEPA. In the past, categorical exclusionstypically have been used to exempt smallprojects that have no significant environ-mental consequences, such as clearingbrush around ranger housing. Yet theadministration would exempt large proj-ects with clear negative effects on the environment:

• “Fuels-reduction projects” of up to1,000 acres would be exempted. These proj-ects can involve logging of large trees, andcould have the same environmental impactas a timber harvest.

• The administration has tried to claim

whole forest management plans as “cate-gorical exclusions”– in spite of the scaleand environmental impacts of such plans.

Stewardship contractsAnother way around NEPA the admin-

istration has exploited is “stewardship con-

tracting.” “Goods for services” contractsare awarded to private timber companies,letting them keep larger trees in paymentfor clearing the brush and smaller trees thatincrease the likelihood of destructive wild-fire. (Larger trees are less flammable, andreduce wildfire hazard by providing shadeand retaining moisture.)

These contracts last for 10 years– withno limits on the size of trees that can be cutor the acreage that can be logged.

National Forest Management ActThe National Forest Management Act

requires each national forest to develop amanagement plan. This plan is meant toensure the protection of wildlife habitat andwatersheds, as well as sustained timberproduction. The Forest Service must devel-op the plans in consultation with scientistsand agency personnel. It must hold publicmeetings to present the plan and mustsolicit public comment.

The Bush administration proposed rulechanges in 2002 that would weakenNFMA-mandated environmentalreview and scientific assessment.

The planned revisions wouldseverely restrict the input of scientistsand the public. They would makeforest management plans virtuallymeaningless by allowing easyexemption of individual projects–including timber harvests. The newrules also would enable regionalforesters to issue, without publicreview, interim amendments thatwould last up to four years. The pro-posed regulations ignore recom-mendations by the federalCommittee of Scientists, which wasformed specifically to review ForestService decisions.

The new rules would restrict pub-lic comment in several ways, includ-ing the elimination of postcards and

form letters as a means of voicing objectionsto management plans.

The Forest Service received 195,787comments on its proposed rule revisions,and has not yet released its final decision.

On Sept. 29 the administration pub-lished an “interpretive rule” in the Federal

The Bush administration has taken a real issue– wildfire danger in our national forests– and turned it into an excuse to reward Big Timber

Forests Forever analysis

Changing the rules: Federal forests get burned

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Clearcut on Shasta National Forest

Register announcing that forest managerswill no longer have to abide by a 1982 rulerequiring that managers maintain viablewildlife populations on national forests.Instead, managers now need only ensure that“the best science available” has been used.

Healthy Forests Restoration ActThe Healthy Forests Restoration Act

is the centerpiece of Bush administra-tion forest policy. As in other adminis-tration initiatives, the HFRA uses thethreat of wildfire to trump environmen-tal concerns and public review. The actis riddled with loopholes for logging.

Enacted in 2003 over the strongobjections of environmental groups, theHFRA allows the Forest Service tomount “fuels-reduction projects” with-out having to consider their environ-mental impact, and without having toconsider alternatives as mandated byNEPA.

The act severely limits opportunitiesfor public comment, and limits appealsto those who have made “substantive”comments during public comment peri-ods. Little advance notice is given andthe length of the comment period is notdefined.

The act also makes judicial review moredifficult, limiting court injunctions againstfuels-reduction projects to 60 days, andrestricting where cases can be heard.

The best way to prevent wildfires fromdamaging communities, according to theForest Service’s own experts, is brush-clear-ing in 200-foot-wide zones around structures.

But the HFRA concentrates logging upto a mile and a half away from settled areas.The timber harvest it mandates as a meansof paying for “fuels reduction” would levelmany flame-resistant mature trees, not justflammable brush. It also would allow “tem-porary” roads to be built– at taxpayerexpense– into currently roadless areas.

The administration justifies these eva-sions of environmental laws by claiming thatappeals and lawsuits by environmentalistshave kept the Forest Service from preventingwildfires.

But the U.S. General Accounting Officereported that, out of 1,671 fuels-reductionprojects prepared by the Forest Service in thefirst six months of 2001, only 20 wereappealed, and none were litigated.

The Roadless Area Conservation RuleOn July 16 the Forest Service published

a proposed rule in the Federal Registerthat would replace the Clinton-era

Roadless Area Conservation Rule. Thisproposed rule would force state governorsto petition the Secretary of Agriculture ifthey wanted to stop roadbuilding, logging,or mining on inventoried roadless areas intheir states.

If a petition is not filed, guidance onroadbuilding would default to existing for-est management plans, 59 percent of which,according to the Forest Service, allow roadbuilding in roadless areas. (For more on theroadless rule, see story on page 1.)

Even if a governor petitions to protectroadless lands in his or her state, however,the secretary still could reject the petitionand allow roadbuilding to go forward.

And when a petition is accepted, thismerely begins a new rulemaking process–which would not necessarily incorporatethe protections requested in the petition.

The Forest Service recently extendedthe public comment period on the pro-posed rule change until Nov. 15.

The Sierra Nevada FrameworkThe Sierra Nevada Forest Plan (the

Framework) was designed to manage andprotect the 11.5 million acres of federal for-est in the Sierra. It was developed over 10years, incorporating input from scientists,forest managers, and the general public.

The Forest Service’s rewriting of theFramework, unveiled in January 2004,would triple the amount of loggingallowed in the Sierra, increase the size ofthe trees that can be cut, loosen protections

for endangered wildlife, and cut back theamount of fire prevention work close tocommunities.

The Forest Service says these changes areneeded to help prevent catastrophic wildfire.The revised Framework, however, would

reduce the amount of resources devoted tofuels reduction near communities, in thewildland-urban interface zone (WUI), thevery place where forestry scientists say brushremoval and thinning will do the most to pro-tect homes.

The original plan had allocated 75 per-cent of its fuels-reduction work to the WUI;the rewrite reduces this to 50 percent. And,like the HFRA, the revised plan calls for thin-ning as much as a mile and a half away fromstructures.

The revised Framework would permittrees up to 30 inches in diameter to be cut,rather than keeping the 20-inch-diameterlimit of the original Framework. Old-forest areas, critical to listed species suchas the Pacific fisher and the Californiaspotted owl, were previously off-limits tologging.

Under the revised Framework theywould be subject to “fuels-reduction” proj-ects. The plan would allow canopy reduc-tions to 50 percent in old-forest areas, in spiteof the potential impact on listed species.

The Forest Service revisions to theSierra Nevada Framework are currentlybeing appealed by several conservationgroups, among them the Center for

Fall, 2004 The Watershed 7

See “Federal forests,” p. 12

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Susan Moloney has spent most of thepast eight years fighting to keep

California’s ancient forests from being cutdown and sold for lumber.

“These trees have been there for solong,” Moloney says. “They’re some of thelargest, tallest, oldest living thingson the planet. It’s incredible. Theystill exist here in California. Whothe heck are we to destroy them?”

For three years, Moloney hasworked for the Campaign for OldGrowth (CFOG) in Oakland, a non-profit group founded to foster legis-lation to preserve old-growth forests.

In 2001 the group attempted toplace a voter initiative on the ballot,but later threw its support behindSen. Don Perata’s Heritage TreePreservation Act (later SB 754) whenthat bill was introduced in the legis-lature. (The bill died in committeein the state Assembly in August.)But what first drew her to the politi-cal work she’s doing now were theancient trees themselves.

Impressed and alarmedBorn in upstate New York,

Moloney spent her first 30 years onthe East Coast, and didn’t move toCalifornia until 1996.

She came to the West Coast thelong way– by circumnavigating theglobe.

“My partner and I at the time went on abig trip around the world,” she said. “Wetraveled for 20 months outside the country.We visited 17 or 18 different countries.”

Soon after she returned to the UnitedStates she came out to California. There shefound a landscape that moved her likenothing else she had seen in her travels.She also found an issue that would come toabsorb her.

“I’d been to some incredible, amazingplaces around the world,” Moloney said.“I’d seen the Great Barrier Reef and thePyramids and the Red Sea. And yet theredwoods and the forests here were themost incredible things for me.”

But while she was deeply impressed bythe beauty of the redwoods she was horri-fied to find out that the magnificent treeswere being cut down at a rapid pace.

“When I first got here and learned thatwe were still cutting down old-growthtrees it was just mind-boggling,” she said.

Moloney became determined to dosomething about the destruction ofCalifornia’s old growth. Since that first

emotional encounter with ancient trees, shehas worked with forest activists “to seewhat I could best do to make a change inthis issue and stop all this logging.”

She began working at the EnvironmentalProtection Information Center (EPIC) inGarberville, doing administrative work forthem for two years. Impressed by the forestactivists she met through EPIC, she began towork as a nonviolence trainer, preparingpeople for the kinds of situations they wouldface in logging protests.

“I realized all these incredible youngpeople were coming here and gettingarrested for this issue,” she said. “I wantedto be helpful.”

Coming into contact with people sodevoted to an issue that they would put alltheir time behind it and their own bodieson the line made Moloney curious about

activism, and she became interested in paststruggles for societal change– anti-nuclearprotests, the civil rights campaigns, theright to vote for women– “all the way backto slavery,” she said.

“You realize that none of these changesare made quickly or easily. And I real-ized that people have been engaging inthese issues for years and for centuries,and sometimes their lives are literallyon the line. That gave me a lot of hope,and I still try to maintain that.”

Starving for old growthMoloney put her own life on the

line in 2002 when she staged a 52-dayhunger strike on the Capitol steps inSacramento to draw attention to thelogging of old-growth in California.

Then-governor Gray Davis hadpromised in a campaign speech to“save all the old-growth trees fromthe lumberjack’s axe.” Moloneydecided that Davis had to be held tohis promise.

“It was not a secret that I had beenholding him to those words. We hada petition that was signed by tens ofthousands of people, if not more, thatI personally delivered. And peoplesaid to him, ‘You made this promise,gosh darn it, not only should youkeep your word no matter what it is,

but this is a very vital issue that peoplearound the state, around the country andaround the world believe in.’”

Moloney had friends who were engagedin treesits. (She had been a substitute treesit-ter herself, and had assisted Julia ButterflyHill in her two-year vigil in the ancient red-wood Luna, working on her support team.)

Moloney felt that the destruction of thestate’s old growth was reaching crisis pro-portions, and wanted to bring more pressureto bear on Davis to do something about it

“I had been seeing a lot of big, old treeson the backs of trucks, and I just was think-ing, ‘What can I do, what can I do, what canI do?’” That’s when the idea of holding ahunger strike popped into her head.

“I thought about it and thought about itfor a week or two, and decided this is whatI needed to do.”

Moloney set up in front of the Capitol ina canvas chair. At first most people– includ-

Standing up for the oldest trees:From mounting a hunger strike to campaigning for the Heritage Tree Act,

Susan Moloney has worked hard to save old-growth forests in California.

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Susan Moloney

Fall, 20048 The Watershed

ing the legislators– simply ignored her.“I think that the reason for that is

because I wasn’t relating to them on the levelthat they’re normally usedto relating to people on atthe Capitol,” Moloneysaid. “They don’t relate topeople there that could becharacterized as ‘the crazylady sitting in the canvaschair, that has a sign outthere, and she’s fasting.’”

Davis never spokewith her during herhunger strike but Moloney thinks that shehad an effect nonetheless.

“I know there’s a lot of people that, eventhough they didn’t stop and they didn’tshow their support, now that I go into theiroffices many of them say, ‘Oh, oh yeah, I sawyou all the time, I passed you everyday.’ I didn’t know who they were.Now I know a lot of them.”

The old-growth issue was dis-cussed at a January 2003 hearing ofthe Senate Committee on NaturalResources and Wildlife, a directresult of Moloney’s vigil.

Much of Moloney’s time for thepast two years has been spent in cam-paigning for the Heritage Tree Act, abill that would have protected old-growth California trees.

Under the Heritage Tree Act, alltrees in the state 150 years old or older,and meeting certain species-specificdiameter requirements, would havebeen protected from logging– even onprivate timber land. It was an ambi-tious attempt to preserve the last rem-nants of old growth in the state.

Some of the obstacles Moloneyencountered while working on theHeritage Tree Act in Sacramentomade her 52-day hunger strike seemlike the easy part.

“It really became apparent, theinfluence of money in politics,” shesaid. “The mis-truths and the down-right lies that people are willing to say.”

But in spite of the difficulties,“there are some heroes,” Moloneyadded. “There are some wonderfulpeople I’ve met that came forward to helpour campaign. That’s encouraging. That’swhat keeps you willing to carry on.”

Among the people who pitched in werecelebrity endorsers such as Pierce Brosnan,Jewel, Ralph Nader, Randy Newman,

Bonnie Rait, and Martin Sheen. Twenty-five environmental groups also

endorsed the measure, including Audubon

California, Earth Island Institute and theSierra Club.

Forests Forever endorsed the bill, andactively campaigned for it. Kent Stromsmoe,who sits on the Forests Forever board ofdirectors, wrote most of the initial draft.

Considering its sweeping nature the billdid quite well in the legislature, passing theSenate by a vote of 23 to 14. In the Assemblythe bill got by the Natural Resources andAppropriations committees but never made itto a floor vote.

“We believe it would have had about 39votes for sure. We were very close.”

Moloney has by no means given up onpassing legislation to protectold growth. She thinks herorganization will be morelikely to introduce anotherbill in the legislature, ratherthan pursue CFOG’s originalplan of putting a voter initia-tive on the ballot.

“The bottom line on theinitiative is that you need amillion dollars to get on the

ballot, and we don’t have that right now,” she says.

“I think that we got to a point which wasmuch, much farther than many peoplethought we would ever get,” Moloney said.

By getting as far as they did with thebill, Moloney said, her organization wasable to put it on the radar screen in thelegislature and gain the issue some cred-ibility. Most importantly, she says, theymanaged to educate people about it.

“Now we know that the Speaker ofthe Assembly knows about old-growthissues. And you can’t say enoughabout that.”

Moloney hopes that the lessons herorganization has learned from theattempt to get the bill through the leg-islature will help them succeed nexttime around.

“We don’t have the luxury of timeon this either. Every session that goesby, every voting day that goes by, wehave less and less old growth.”

The importance of ancient treesAt the most basic level, it’s the trees

themselves that keep Moloney work-ing to save them.

“There’s so much on this planetnow that’s paved, and it’s malled, andit’s blacktop and it looks like so manyother places in the state, and so manyother places in the world. But theseforests are unique. And they’ve beenliving for hundreds and thousands ofyears. They’re relics of time and thedistant past. There are fewer and fewerplaces on the planet that are like that.

“It’s not necessary to know the ‘use’they have for humans, but the fact that theywere put here on this planet. They deserveto be here and have the right to exist. It’snot acceptable and it’s not appropriate forus to be destroying the habitat.”

—M.L.

“Every session that goes by, every voting day that goes by, we have

less and less old growth.”

Crazy lady in a canvas chair: Susan Moloney during her hunger strike in Sacramento, November 2002.

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Fall, 2004 The Watershed 9

are being studied by the Forest Service) hewould have to petition the secretary. Nomatter how compelling his arguments, how-ever, the secretary could reject the proposal.

“The likelihood of governors filing theserequests is greatly reduced by the fact that

the states would have to foot the bill onpreparing these petitions,” said MarkFletcher, president of the board of directorsof Forests Forever. “Shepherding themthrough a long and contentious processwould be costly too.”

Without a governor’s intervention eachnational forest’s management plan woulddetermine how roadless areas are treated.Unfortunately, 59 percent of forest plans,according to the Forest Service, provide forexploitation of roadless areas.

“Of course, the states that have the mostroadless acreage also tend to be the stateswhere extractive industries have the mostclout with the governor,” Fletcher said.

The Forest Service has cited legal chal-lenges to the Roadless Area ConservationRule as the primary reason for proposing thenew rules. But the legal status of the road-less rule is still in play.

Three days after the rule’s adoption onJan. 5, 2001, a lawsuit was filed by the timberindustry and the state of Idaho claiming theroadless rule was illegal. Initially struckdown in an Idaho district court, the rule wasreinstated by the 9th Circuit Court ofAppeals on Dec. 12, 2002.

However, the state of Wyoming broughta new case in May 2003 in Wyoming districtcourt seeking to invalidate the rule. A sym-pathetic judge, Clarence A. Brimmer, stated

that it was up to Congress to designate fed-eral wilderness areas, not the Forest Service.

Wyoming thus is the only state where therule is completely invalid. In California(along with 48 other states), the original,strong Clinton-era rule still applies and can be

defended incourt byconcernedcitizens orthe govern-ment.

Califor-nians alsowill be ableto defendthe rule re-gardless ofthe 10th Cir-cuit’s deci-sion (asw o u l dWa s h i n g -ton, Ore-gon, Ne-v a d a ,Idaho, andArizona) .

Nevertheless, an unfavorable ruling by the10th Circuit does have national significance.

All eyes now are turned to the 10thCircuit to see whether it upholds Brimmer’sdecision or reverses it and issues a rulingconsistent with the 9th Circuit ruling. IfBrimmer’s decision is upheld, the statesunder the 10th Circuit’s jurisdiction(Oklahoma, Kansas, New Mexico, Colorado,Wyoming, and Utah) will see the roadlessrule invalidated.

Such a decision likely would be appealedto the U.S. Supreme Court. On the otherhand, a decision backing the 9th Circuitwould severely weaken the Forest Service’srationale for proposing new regulations.

Despite these recent setbacks, there hasbeen some good news for roadless areas. Inearly June an amendment to the InteriorAppropriations bill prohibiting governmentfunds from being used for road-building inAlaska’s vast roadless areas in Chugach andTongass national forests was introduced byRep. Steve Chabot (R-OH). (These forestswere exempted from the roadless rule by theBush administration in December 2003.) Themeasure passed the House of Repre-sentatives on a 222-205 vote (with 173Democrats, 48 Republicans and one Inde-pendent voting for it), and goes next to theSenate.

The Roadless Area Conservation Act,

reintroduced in the House in June 2003 byJay Inslee (I-WA) and the Senate by MariaCantwell (D-WA), still is pending in bothhouses of Congress. The act would desig-nate all inventoried roadless areas under therule as Wilderness Areas, and would super-sede any court order on the roadless rule.

Senators Barbara Boxer (D-CA) and JohnKerry (D-MA) both have cosponsored thisbill in the Senate.

But until such legislation is passed, theroadless rule’s fate remains in the hands ofthe 10th Circuit Court. The court’s decisionis expected as soon as mid-fall, or more like-ly by early next year. But if the administra-tion gets rid of the roadless rule, its decisionmay be meaningless.

“Roadless areas are a fast-disappearingresource that is virtually irreplaceable oncealtered,” Fletcher said. “The public wantsthese areas set aside for watershed, wildlife,and recreational use, not just for short-termexploitation.”

(For more information on the roadlessrule and other Bush anti-forest policies, see“Changing the rules: Federal forests getburned” on page 6.)

—Keith Sendziak

“Roadless rule”continued from p. 1

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TAKE ACTION:The Forest Service has extended thecomment period for the proposed rulechanges to Nov. 15.

The proposed rule is available at:http://roadless.fs.fed.us/documents/id_07/2004_07_12_state_petition_pro-posed_rule.html

Send your comments to:Content Analysis TeamATTN: Roadless State Petitions USDA Forest Service P.O. Box 221090 Salt Lake City, UT 84122Fax: (801) 517-1014E-mail: statepetitionroadless@fs.fed.us.

Comments also may be submitted from:http://www.regulations.gov

Write to your congressional representa-tives and ask them to support theRoadless Area Conservation Act, H.R2369/S. 1200, sponsored by Rep. JayInslee (I-WA) and Sen. Maria Cantwell(D-WA). You can locate your represen-tative’s address online athttp://thomas.loc.gov/

Fall, 200410 The Watershed

A publication of Forests Forever, Inc.and the Forest Forever Foundation

50 First St., Suite 401

San Francisco, CA 94105

phone (415) 974-3636

fax (415) 974-3664

mail@forestsforever.org

www.forestsforever.org

The Watershed© 2004

Forests Forever, Inc.Forests Forever Foundation, Inc.

All rights reserved

Printed on 100% post-consumer recycled paper

The Watershed

FORESTS FOREVER

Board of Directors:

Mark A. Fletcher, Ph.D.President

Ken SmithSecretary

James NewmanTreasurer

Kent Stromsmoe

Advisory Council:

Carla Cloer

Richard Gienger

Betsy Herbert

Martin Litton

Jeanne Newman

Jill Ratner

“Restore,Reinhabit,

Re-enchant”

Paul HughesExecutive Editor

Marc LecardEditor

Gary Bentrup Flag Artwork

“Spraying forests”continued from p. 5

FORESTS FOREVER FOUNDATION

Board of Directors:

Paul HughesExecutive Director

Mark A. Fletcher, Ph.D.President

Ken SmithSecretary

James NewmanTreasurer

Fall, 2004 The Watershed 11

While forest workers wear gear to protectthemselves from the chemicals, bas-ketweavers may be unwittingly exposed totreated plants.

The number of people gathering plants inCalifornia’s national forests is too small to do astatistically accurate study of herbicides’impacts to their health, Parker said. However,she says, studies have linked certain herbicideswith human health problems. Swedish studies,for example, have linked glyphosate to non-Hodgkins lymphoma and other studies show alink to hyperactivity in children.

Why use herbicides at all?Bakke said the Forest Service uses alterna-

tives to herbicides when possible, primarilymachine mulching or brush cutting, but alsoprescribed burning and animal grazing. Of the53,200 acres in California national forestswhere weeds were eradicated in 2002 and2003, only 21 percent were treated with herbi-cides, he said.

(“This is a smokescreen,” said VivianParker. According to Parker, the agencylumps native plants and non-native invasivestogether as “weeds,” but most herbicide use isdirected at native plants. “Less than one per-cent of the agency’s total use of herbicidesstate-wide were used to kill non-native weedsin 2002 and 2003,” she said.)

The timber industry continues to rely exclu-sively on herbicides, environmental groups say.Sierra Pacific Industries, for example, coats allof its harvested lands with chemicals, Buckleyof CSERC said.

“They use them to kill off everything but acrop of pine trees,” he said.

Sierra Pacific declined to comment for thisarticle.

The Forest Service no longer clearcuts asfreely as it used to. But Buckley said its herbi-cide use (following fires and to restore pastclearcuts) has the same goal as the forestindustry: to farm trees that can be logged forprofit.

“They are committed to the concept thatthey cannot plant an acre of pine trees withoutthe use of chemicals,” Buckley said. “I canpoint to hillsides that have never been treatedwith herbicides and have trees growing all overthem.”

Logging methods are a primary culprit inpesticide use. Harvesting methods such asselective cutting where only target trees arelogged do not require replanting, and herbi-cide use could be reduced or eliminatedentirely.

“If they were not trying to grow tree planta-tions,” Buckley said, “I can’t even think of whythey’d need to use herbicides.”

—Andria Strickley

ChemicalPounds used in CA

forests in 2002Pesticide Action Network

"Bad Actor"Health/environmental

hazards

Glyphosate 52,689 NoPotential groundwater

contaminant

Hexazinone 40,851 YesAcute toxicity, groundwater

contaminant

Atrazine 32,764 YesKnown carcinogen, groundwater

contaminant, suspected endocrinedisruptor

2,4-D 23,226 YesPossible carcinogen, potential

groundwater contaminant, knowndevelopmental or reproductive toxin

Triclopyr (BEE, TEA) 17,699 NoPotential groundwater

contaminant

Imazapyr 14,278 NoNot enough information to deter-

mine toxicity

Sulfometuron methyl 595 NoPotential groundwater

contaminant

Sour

ce: C

alifo

rnia

Dep

artm

ent

of P

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cide

Reg

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Herbicides commonly used in California Forests

FORESTS FOREVER50 First St. #401 San Francisco, CA 94105

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If you do not wish toreceive The Watershedsend this along with themailing panel at right to:

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executive director of Forests Forever. “Whileit doesn’t by any means halt the destructionof oaks, it does strengthen the regulatoryframework protecting them and providesoaks defenders with new legal tools.”

The measure that emerged from monthsof struggle and amendment was not thesame bill that began its journey through thelegislature two years ago, but it managed toretain some important provisions.

Probably the most significant weaken-ing of the original bill was the exemption offarmland and rangeland. Real estate devel-opment, an important factor in the destruc-tion of oak woodlands, has not beenexempted, however.

“Building environmental safeguards isusually an incremental process that takes

many years,” Hughes said. “By strengthen-ing the regulatory framework protecting oakwoodlands, this new statute moves us a bigstep closer to our goal.”

The Heritage Tree Preservation ActThe Heritage Tree Preservation Act

would have protected selected species ofold-growth trees (coast redwood, giantsequoia, Port Orford cedar, douglas-fir andhardwoods) on non-federal forestland,including land owned by timber companies.

The ban would have applied to trees thatmet species-specific minimum diametersand were alive in 1850, California’s first yearof statehood. (For an account of the bill’spassage through the legislature, see“Standing up for the oldest trees” on page 8.)

The State Forest System Reform ActChesbro’s bill would have changed the

purpose of the state forests from “maximumsustainable timber production” to a mix ofuses including restoration, education, andrecreation, as well as timber harvesting. Itwould have protected old-growth groves inJackson Demonstration State Forest fromlogging, and limited the use of clearcutting.

“This is a sad day for the forest, thepeople of California, and the Mendocinocommunity,” said Vince Taylor of theCampaign to Save Jackson State RedwoodForest in a post-veto statement.

Forests Forever campaigned intensive-ly for passage of SB 1334, the oak wood-lands bill, from November 2003. ForestsForever supporters wrote or called statesenators 1,967 times, assemblymembers4,918 times, and Schwarzenegger 2,090times about the bill.

—M.L.

“Oaks bill”continued from p. 1

“Federal forests”continued from p. 7

Biological Diversity, the Sierra Club, andThe Wilderness Society. State AttorneyGeneral Bill Lockyer also has filed anappeal with the Forest Service.

The Northwest Forest PlanOn Mar. 23 the Forest Service and the

federal Bureau of Land Managementannounced amendments to the 1994Northwest Forest Plan. The changes wouldeliminate the Survey and Manage guide-lines and the Aquatic Conservation Strategy.

The Survey and Manage guidelinesrequired surveys of wildlife and plantspecies before logging could proceed. TheAquatic Conservation Strategy required

protection of salmon habitat and drinking-water quality.

The proposed changes by the ForestService and BLM would reduce protectionfor salmon habitat and water quality andallow more logging in old-growth reserves.The changes would also eliminate require-ments to gather biological and ecologicaldata to support habitat protection.

The Northwest Forest Plan covers 24.5million acres of national forests in Oregon,Washington, and Northern California. TheKlamath, Mendocino, Shasta-Trinity andSix Rivers and parts of Modoc and Lassennational forests fall under the 1994 plan’sprovisions. Together the forests cover morethan 4.5 million acres in California.

The Northwest Forest Plan never estab-

lished upper limits on the size of tree thatcould be cut. Without these limits, and withthe Survey and Manage protections forwildlife eliminated, there would be no stan-dards to prevent old-growth forests frombeing logged. There are 150 timber salesdrawn up for the forests covered by the plan.

The Bush administration is nothing ifnot consistent. In each case where it hasweakened or eliminated protections forforests and wildlife, it has claimed wildfiredanger as the reason.

Yet the administration’s policies maycause more long-term damage to the feder-al forests and their wildlife habitats thanforest fires ever have.

—M.L., with research assistance fromKeith Sendziak