WOC Wins Ellsbury Timber Sale Appeal

by Steve Jones

In April, WOC, American Wildlands and the Alliance for the Wild Rockies joined forces to challenge (for a second appeal) the proposed Ellsbury Timber Sale along the Clarks Fork of the Yellowstone River in the Shoshone National Forest (SNF). In June, we won our appeal. Again. The Rocky Mountain Regional Office of the U.S. Forest Service ruled in our favor, reversing the SNF’s approval of the Ellsbury Timber Sale.

The SNF’s Ellsbury sale proposal was to log 1.3 million board feet of timber from 140 acres. The sale also required building .8 miles of new road and 2.4 miles of temporary roads as well as reconstructing 1.4 miles of existing roads. The project area is located near the Swamp Lake Botanical Area, which provides habitat for 26 sensitive plants. The Deadman Creek wetland that is part of the sale area may also provide habitat for some of the same plant species. Despite this fact, the SNF failed to discuss sensitive plant species that might exist in the sale area. Sensitive animals for which the area has suitable habitat include lynx, grizzly bear, fisher and spotted frog. More logging would not have improved habitat for elk, bears and lynx who need trees a lot more than they need stumps.

The Forest Service Regional Office ordered the SNF to rewrite its Biological Evaluation so that it includes facts that confirm biologists’ findings about sensitive animal and plant species in the timber sale area and how the sale would affect these species.

Logging for "Forest Health"
A significant lack of documentation characterized the SNF’s timber sale proposal. Even its stated "purpose and need" lack credibility. The SNF maintains that the 1988 Clover-Mist fire generated an explosion of the Douglas fir bark beetle. Its proposal claims the sale would have improved the health of timber stands by reducing the supply of food for the beetle and lessening the possibility of infestation and/or disease among the area’s various tree species.

But how would this "treatment" have improved the health of the trees that remain? The SNF did not describe how cutting trees would increase forest health or the condition of vegetation. It would seem that the real concern here was not forest health, but rather the bottom line on a ledger sheet.

This whole scenario was quite reminiscent of a similar approach used by the Targhee National Forest in years past to provide a rationale for a massive clearcutting program right next to Yellowstone National Park. Yet while Yellowstone did not have the benefit of this "treatment," the Park has much healthier forest stands today (even though nature has most certainly taken its course) than the adjacent Targhee National Forest, despite the fact that the Targhee’s trees were "treated" with clearcuts.

It is interesting that although the alleged purpose and need for this timber sale was to enhance forest vegetative health, the SNF never discussed, even as an alternative, the possibility of conducting a prescribed burn. Why was this alternative — often regarded by forest managers as a good way to enhance forest health by mimicking the natural processes of fire succession — never even considered? The answer is plain enough. The real purpose and need was to "get the cut out," not enhance forest health.

Ignoring the "No Action" Alternative
Another glaring problem with this timber sale proposal was that there was no consideration of a "no action" alternative. This is a basic requirement of any Environmental Assessment (EA), since it provides a baseline for the consideration of all other alternatives. Without a "no action" alternative, it’s impossible to effectively compare the environmental consequences of the other alternatives. But although the SNF did not think this alternative was important to analyze, the Regional Office did. It ordered the District Ranger to consider and analyze the no action alternative in any future EA he might prepare for this timber sale.

No Protection for Class 1 Waters
The timber sale proposed logging on slopes that rise above the Clarks Fork of the Yellowstone River, Wyoming’s only Wild and Scenic River. Yet the SNF failed to consider how the sale might jeopardize the water quality of the river, despite its status among Wyoming’s highest category of protected waters. Although logging activities typically generate stream siltation and sedimentation, the SNF neglected to spell out how it planned to protect the Class 1 waters of the Clarks Fork and its tributaries.

The Regional Office agreed with our objections to this omission, and ordered the SNF to better document the effect of the 1998 Clover-Mist fire on the Deadman Creek watershed and the current condition of the watershed.

So, for the time being, the Ellsbury area of the Clarks Fork drainage has been saved from further damage by unnecessary clearcutting in the name of "forest health."