Proposed High-Speed Freeway Threatens
Northern Rockies’ Wildlife Linkages from
Greater Yellowstone Ecosystem to
Greater Glacier/Bob Marshall Ecosystem

By Paul Richards

Many westerners are familiar with Highway 69, the scenic rural route that runs alongside the Boulder River, between the Elkhorn Mountains and Bull Mountain from Boulder to Cardwell.  The Boulder Valley is one of Montana’s most beautiful drives, filled with abundant wildlife and breathtaking scenery.

This pastoral scene is gradually turning into a nightmare.  Canadian truckers, fully aware that law enforcement on Highway 69 is minimal at best, drive in convoys at speeds up to 85 mph, endangering all local traffic.

For almost 10 years, Boulder Valley residents have petitioned the Montana Department of Transportation (MDOT) for a safer Highway 69.  We have asked for:

*  A pedestrian walkway and bicycle path along the highway’s current route;
*  Safe crosswalks at the Jefferson County Fairgrounds, Boulder Hot Springs, and other frequently utilized junctions;
*  Retention of the valley’s lush aspen and cottonwood;
*  Underpasses or overpasses for elk, deer, moose, bear, pronghorn and other wildlife;
*  A full-time truck weighing station;
*  Lower speed limits for the safety of vehicles, trucks, pedestrians, ranchers and their equipment, bicycles, wildlife and livestock, and
*  Strict enforcement of these lower speed limits.

In early 2005, we submitted an official “Citizens’ Alternative” to MDOT Director Jim Lynch and MDOT Butte Division Administrator Jeff Ebert.  “MDOT is legally bound to offer a wide range of alternatives,” we wrote.  “Any public meetings to discuss alternatives need to have the above alternative before it for consideration.”

MDOT’s response was swift and deadly.  At a June 1, 2005, hearing, MDOT presented its “nuclear option” — a new high-speed freeway to be built on the river’s east bench — a stake right through the hearts of all Boulder Valley ranches.

Legally, according to the National Environmental Policy Act (NEPA), this was a “scoping” hearing, where MDOT was supposed to receive public comments concerning features we wanted for Highway 69.

But, there was no “hearing.”  MDOT never asked what we wanted. And, MDOT never mentioned our “Citizens’ Alternative.”

Instead, MDOT told us that its already-approved “preferred alternative” for a new high-speed international highway corridor was a fait accompli.

Needless to say, MDOT’s circumvention of NEPA, its premature and illegal designation of a “preferred alternative” without any public input; the agency’s violation of state and federal public participation and environmental protection mandates; and its devastating “nuclear option” did not go over particularly well.

More than 100 Boulder Valley residents at the 2005 “hearing” unanimously shouted “NO!”

Now, flash ahead five years to MDOT’s March 23, 2010, hearing. Due to steadfast community opposition, MDOT finally announced it was abandoning its “nuclear option.”

However, in the years between the 2005 and 2010 hearings, NONE of the concerns expressed by area residents have been addressed!

Even though more than 200 residents signed petitions requesting the pedestrian walkway and bike path and even though MDOT promised us in writing in 2008 they would explore this proposal, MDOT did not mention it.

MDOT did not mention safe crosswalks, truck weighing station, lower speed limits, and enforcement of speed limits.  On questioning, MDOT said it would take an act of the Legislature to lower vehicular speeds to make our neighborhood safer.  That is absolute nonsense.

Instead of strictly-enforced lower speed limits, MDOT actually told us it wants to “speed up” Highway 69, so Canadian truckers can drive faster and get home sooner to spend more time with their wives and kids!

MDOT did not mention wildlife collisions, although the agency’s own in-house data are overwhelming.  MDOT refused to discuss underpasses and overpasses, even though studies have deemed them biologically critical to maintain existing wildlife corridors and linkages from the Greater Yellowstone Ecosystem to the Greater Glacier/Bob Marshall Ecosystem.

MDOT told us “we have to design this highway for morons” who drive too fast for road conditions!

Montana’s magnificent Boulder Valley and the priceless wildlife corridors it provides need your help!

Using the contact information provided below, please tell MDOT that:

1.  You support the bicycle and pedestrian path, with well-marked crossings;
2.  You support wildlife underpasses and overpasses;
3.  Flashing signs alerting motorists to crossings and reduced speed limits have proven effective in Montana’s wildlife-rich Bitterroot Valley on Highway 93, Gallatin Valley on Highway 191, Clark Fork Valley on Highway 200, and Mission Valley on Highway 93 — MDOT must do this in the Boulder Valley on Highway 69;
4.  Since the Boulder River is officially “impaired,” MDOT cannot contribute further to its “Total Maximum Daily Loads” or “TMDLs.”
5.  Highway 69 is a rural state route, not a U.S. Highway or an Interstate Highway;
6.  Highway 69 is not designed for high-speed truck traffic, nor should it be;
7.  Nearby and parallel Interstate 15 is the north-south freeway specifically designed for high-speed truck traffic;
8.  If MDOT continues its misguided, NAFTA-driven efforts to convert Highway 69 from a pastoral rural route into a high-speed freeway for international truck traffic, the agency must first prepare a full Environmental Impact Statement.
9.  The Boulder Valley is a community of sane people that doesn’t need “morons” driving through it at unsafe speeds; and
10.  Give Boulder Valley residents, ranchers, kids, pedestrians, bicyclists, and wildlife a brake!

To comment, title your comments “Boulder South EA,” submit them on-line at: http://www.mdt.mt.gov/mdt/comment_form.shtml and http://governor.mt.gov/contact/commentsform.asp ; e-mail them to  jebert@mt.gov ; dwambach@mt.gov ; snicolai@dowlhkm.com ; jilynch@mt.gov ; and bbrosten@mt.gov ; and/or snail-mail them to:

Boulder South EA
DOWL HKM
P.O. Box 1009
Helena, MT  59624.

Provide your contact information and ask MDOT to keep you posted concerning all stages of this project and all subsequent projects concerning the Boulder Valley and Highway 69 .

Thank you!
____________________________________________________________________

Dispatches from the Wildlands™ ©2010, Paul Richards

Paul Richards is a Helena native, Boulder area businessman, former member of the Montana House of Representatives, and former candidate for U.S. Senate.  For further information, contact him at:  30 Brown’s Gulch Road, Boulder, MT  59632, or by e-mail at:  Paul@PRMediaConsultants.com .

Editor’s Note:

Different versions of this piece have appeared in the:

1.  (Butte) Montana Standard, located at: http://www.mtstandard.com/news/opinion/columnists/article_50f70b0e-49a6-11df-9d2c-001cc4c03286.html

2.  (Helena, MT) Queen City News, located at: http://www.queencitynews.com/modules.php?op=modload&name=News&file=article&sid=11387&mode=flat&order=0&thold=0

3. Boulder (MT ) Monitor.  No Internet posting–no URL.

RESTORING BULL TROUT TO THE
UPPER CLARK FORK RIVER DRAINAGES,

INCLUDING THE GEORGETOWN LAKE ECOSYSTEM OF SOUTHWESTERN MONTANA.

U.S. Fish and Wildlife Service
Public Comments Processing
Attn: RIN 1018-AW88
Division of Policy and Directives Mgmt.
4401 N. Fairfax Drive, Suite # 222
Arlington, VA   22203

Federal e-Rulemaking Portal: http://www.regulations.gov .
Keyword or ID:  FWSR1-ES-2009-0085.
“Open for Comment/Submission”Search button.  Icon that reads “Submit a Comment.”

Dear Friends of the U.S. Fish and Wildlife Service,

I hope this letter finds you well.

I write today in full support of a very important indigenous species to Montana and the Northern Rockies, the magnificent bull trout.

In the past, the U.S. Fish and Wildlife Service failed miserably to protect bull trout, a threatened species, by proposing to protect only fragmented and unconnected bull trout habitat.

I have just reviewed the map comparing the 2005 “Final Critical Habitat” to the 2010 “Proposed Final Critical Habitat,” available at:

http://www.fws.gov/pacific/bulltrout/pdf/20102005%20comparison.pdf .

Your proposed “2010 Final Critical Habitat” is a much more definitive step towards protecting this threatened species that is supposed to be fully protected under the Endangered Species Act.  It seems as though you are now finally recognizing the biological imperatives of maintaining connectivity and of reconnecting core areas.  Thank you!

However, in examining your documents and your maps, it seems as though you have not yet fully recognized the importance of protecting presently-and-temporarily unoccupied habitat.  Protection of temporarily unoccupied habitat as transportation corridors is absolutely crucial to fully recovering bull trout throughout Montana and the Northern Rockies.

FLINT CREEK DRAINAGE:

For example, in reviewing the map available at:  http://www.fws.gov/pacific/bulltrout/crithab/mtnv/31%20Upper%20Clark%20Fork%20River.pdf , I can’t help but wonder why all of Flint Creek and its tributaries aren’t proposed as protected bull trout habitat.

This also might be a good time to reestablish a bull trout population in Georgetown Lake, extirpated so many years ago.  Montana Department of Fish, Wildlife, and Parks’ examination of about 5500 trout captured by anglers between 1984 and 2002 revealed no bull trout, westslope cutthroat trout, or even bull trout hybrids.

However, the potential DOES exist for reestablishing bull trout in Georgetown Lake.  Montana Department of Fish, Wildlife, and Parks data indicate that at one time bull trout originated in Silver Lake and migrated to Georgetown Lake via Hardtla Creek.  Can the U.S. Fish and Wildlife Service work to reestablish this passageway?

Could the U.S. Fish and Wildlife Service work to help ensure that drastic drawdowns of Georgetown Lake, resultant low dissolved oxygen, and ensuing fish kills are avoided in the future?  This would help native fish like bull trout and westslope cutthroat trout tremendously.  Also, could the U.S. Fish and Wildlife Service work to establish fish ladders from Flint Creek up to Georgetown Lake?  Again, this would help native fish tremendously.

Of course, it will take a while to reestablish native species to the Georgetown Lake ecosystem.  Non-native invasives like brook trout interbreed with bull trout, damaging those few pure populations that remain.  Brook trout also voraciously out-compete native cutthroat for habitat. Because of these threats, brook trout are being removed from many streams with poisons, and prevented from invading upstream refuges for native trout with barriers.  The U.S. Fish and Wildlife Service would have to work closely with Montana Department of Fish, Wildlife, and Parks to change the emphasis for the Georgetown Lake area from invasive non-native species like brook trout to native species like cutthroat and bull trout.

The Flint Creek drainage has seen some ill-advised road building, unsustainable logging, and the creation of polluting hard-rock mining sites.  It is time for the Beaverhead-Deerlodge National Forest to initiate an intensive and aggressive program of road and mine reclamation and forest restoration with native plant species and emphases on naturally draining watersheds.

The Beaverhead-Deerlodge National Forest needs to be encouraged to proceed with closing, re-contouring, and completely reclaiming unnecessary roads, with emphases on natural water drainage and restoring habitat for secluded wildlife species such as elk.  For roads determined to be absolutely essential, the Forest Service needs to install stream crossing structures that allow for upstream movement of all life stages of fish such as bull trout.

The Pintler Ranger District of the Beaverhead-Deerlodge National Forest has begun  identifying undersized culverts and is proposing to the public that these undersized culverts be replaced by stream crossing structures (bridges or larger culverts) that allow for migration for all life stages of fish such as cutthroat trout (sensitive species), bull trout (threatened species), and other native aquatic organisms.

Particularly regarding the Boulder Creek watershed of the Flint Creek drainage, these actions by the Pintler Ranger District of the Beaverhead-Deerlodge National Forest would help reconnect now-isolated populations of bull trout with the bull trout populations of Flint Creek and the Clark Fork River.

I support the efforts of the Pintler Ranger District in this regard.  I offer the hope that the Pintler Ranger District will continue identifying biological “bottlenecks” throughout the entire Ranger District and proposing restoration and remediation alternatives that will well serve native fish and wildlife populations, particularly those species that are rare, threatened, endangered, secluded, sensitive, or species of special concern.

I am sending a copy of this statement to the Pintler Ranger District in care of Don Despain ( ddespain@fs.fed.us ) and Steve Gerdes ( sgerdes@fs.fed.us ) in the hopes these comments will be incorporated into all proposals and documents regarding the identification of undersized culverts, ORVs and ATVs crossing through streambeds, and other factors that radically diminish aquatic habitat and potential for native fish propagation and migration.

WARMS SPRINGS CREEK DRAINAGE AND

CLARK FORK RIVER SYSTEM FROM

WARM SPRINGS CREEK TO FLINT CREEK:

The entire Warm Springs Creek drainage needs to be included in the “Proposed Final Critical Habitat.”  In their “Bull Trout Population Genetic Structure and Entrainment in Warm Springs Creek, Montana” Report, submitted on June 2, 2009, Patrick DeHaan and Lindsay Godfrey of the U.S. Fish and Wildlife Service write:

The Clark Fork River system west of the Continental Divide in Montana historically

contained one of the largest metapopulations of bull trout (Salvelinus confluentus) throughout the species range. Historically, bull trout were likely distributed throughout the upper Clark Fork River upstream of Milltown Dam (near Missoula, MT) as there are no major natural barriers excluding bull trout from major portions of the drainage.

The Warm Springs Creek watershed likely provided a significant portion of the spawning and rearing habitat for bull trout in the upper Clark Fork River due to the large area of the drainage, the geology of the drainage, and the diversity of habitats. However, a century of mining and smelting polluted streams in the upper Clark Fork River system with toxic metals and other chemicals (MBTSG 1995), and such mining-related habitat degradation effectively extirpated migratory bull trout from much of the system.

The US Fish and Wildlife Service (USFWS) designated seven local populations within the upper Clark Fork River core area (USFWS 2002). However, more recent information suggests that bull trout in this core area have been reduced to only three viable populations, including Warm Springs, Boulder, and perhaps Harvey Creeks (USFWS 2009). Currently these populations are isolated from one another. Of these three locations, Warm Springs Creek contains the most-upstream population of bull trout in the Clark Fork River, is comprised of multiple demes (discrete spawning units in individual tributaries), and is likely the largest among the upper Clark Fork bull trout populations in terms of number of individuals and extent of occupied habitat.

Elevations within the Warm Springs Creek drainage range from 1,524 to 3,139 meters (5,000-10,300 ft) and the drainage encompasses over 40,499 ha (100,077 acres). This system is unique in that both resident and migratory (ad fluvial and fluvial) life history type bull trout occur over a range of habitats including a series of lakes (Upper and Lower Twin Lakes), reservoirs (Silver Lake) and tributaries (Foster, Twin Lake, Storm Lake, Warm Springs and Barker Creeks). Predictions about the response of bull trout to climate change (Rieman et al. 2007) suggest that local populations like Warm Springs Creek will represent important conservation units.

Since the early 1900s, bull trout habitat within the Warm Springs Creek drainage has been extensively fragmented by development and utilization of a water supply system for large-scale smelting operations based in Anaconda, MT. Warm Springs Creek, Silver Lake, Storm Lake Creek and Twin Lakes Creek contain an intricate water conveyance system, including diversion structures, aqueducts, exposed and buried pipes, and pumping stations.

These structures clearly influence habitat connectivity within the system, and have caused the isolation of bull trout populations in Twin Lakes and Storm Lake Creeks. Moreover, bull trout from Storm Lake and Twin Lakes Creeks may also be entrained into Silver Lake, which could represent a demographic loss to source populations and constrain expression of a migratory life history if entrained individuals cannot return to spawn in their natal habitats.

DeHaan and Godfrey also write:  “Bull trout habitat in Warm Springs Creek has been fragmented by a series of water diversions for nearly 100 years. Isolation of bull trout populations above barriers has apparently contributed to reduced levels of genetic variation for bull trout within different tributaries of Warm Springs Creek (relative to the Clark Fork River and elsewhere in the species range), low effective population sizes and restricted gene flow among populations. Water diversions within the system have apparently led to the entrainment and loss of important migratory bull trout from Storm Lake Creek. Bull trout populations within the system would likely benefit from the re-establishment of migratory corridors as well as measures aimed at reducing the threats posed by non-native brook trout in the system” (emphasis added).

Obviously, this fragmentation of habitat needs to be addressed.  As written above, migratory corridors must be reestablished.  This will not occur until the entire Warm Springs Creek drainage is considered as “Proposed Final Critical Habitat.”

Once the entire Warm Springs Creek drainage is considered as “Proposed Final Critical Habitat,” it should go without saying that the entire Clark Fork River from Warm Springs Creek to Flint Creek must also be “Proposed Final Critical Habitat.”  The map you have posted at:  http://www.fws.gov/pacific/bulltrout/crithab/mtnv/31%20Upper%20Clark%20Fork%20River.pdf abruptly cuts off the “Proposed Final Critical Habitat” for bull trout at the confluence of Flint Creek and the Clark Fork River.  This does not serve the long-term interests of the bull trout!

We have already established that:

The Clark Fork River system west of the Continental Divide in Montana historically contained one of the largest metapopulations of bull trout (Salvelinus confluentus) throughout the species range. Historically, bull trout were likely distributed throughout the upper Clark Fork River upstream of Milltown Dam (near Missoula, MT) as there are no major natural barriers excluding bull trout from major portions of the drainage.

The Warm Springs Creek watershed likely provided a significant portion of the spawning and rearing habitat for bull trout in the upper Clark Fork River due to the large area of the drainage, the geology of the drainage, and the diversity of habitats.

We have also established that “Bull trout populations within the system would likely benefit from the re-establishment of migratory corridors.”

Now that the Clark Fork River is being cleaned up, we have to honor its proud history as prime bull trout habitat.  So, instead of arbitrarily, capriciously, and mistakenly cutting off “Proposed Final Critical Habitat” for the bull trout at the confluence of Flint Creek and the Clark Fork River, we must continue the “Proposed Final Critical Habitat” upstream from the Flint Creek confluence all the way to the confluence of Warm Springs Creek and the Clark Fork River.

CONCLUSION:

Since bull trout depend on cold, clear, and clean water, they are excellent indicators of water quality.  Protecting and restoring their habitat contributes to the water quality of rivers and lakes throughout Montana and the Northwest.  We all benefit from cleaner water and bountiful fisheries.

Federal, state, and tribal land managers must manage public land for the benefit of fish and wildlife, with emphases on indigenous species and protecting biodiversity.  Where indigenous species have been extirpated, our responsibilities as stewards require us to provide the necessary migration corridors to suitable-but-temporarily-unoccupied habitat.

This is particularly true regarding bull trout.  Bull trout need cool water with little-to-no fine sediment in order to successfully spawn and rear. At about two years of age they migrate from their spawning streams and mature in lakes or rivers, traveling as far as 150 miles.  They return to their native stream to spawn.  Unlike salmon, bull trout journey between spawning streams and rivers and lakes many times.

In order to save bull trout from extinction, all public lands must be managed to maintain the steady flows of pure and clean water required by this magnificent species.  Existing public roadless wildlands and all at-risk species must be protected.  And, damaged forests, plains, and watersheds must be restored.

If we manage all federal lands (U.S. Department of Agriculture, U.S. Forest Service; U.S. Department of Interior; U.S. Bureau of Land Management; National Park Service; et al), all state lands (Montana Department of Fish, Wildlife, and Parks; Montana Department of Natural Resources and Conservation Lands, et al), all tribal lands whenever possible, and all community watersheds for bull trout, cutthroat trout, and other species that require a clean environment, we humans are assured a healthy future.  If we choose instead to continue degrading our public lands and watersheds, we humans will suffer impoverishment of both health and spirit.

I respectfully ask you, our public employees of the U.S. Fish and Wildlife Service and other agencies, to do everything within your power to protect the habitat essential for the survival of species that characterize the wild nature of the northern Rockies, such as the bull trout, cutthroat trout (Montana’s official state fish), arctic grayling, gray wolf, otter, mountain goat, mountain sheep, elk, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, Montana vole, sage thrasher, sage grouse, wild bison, peregrine falcon, bald eagle, golden eagle, pine marten, fisher, lynx, wolverine, and grizzly bear (Montana’s official state animal).

Thank you for your consideration.  Please place these comments in the hearing record.

Please keep me notified of any and all proposed U.S. Fish and Wildlife Service decisions regarding the bull trout and other rare, threatened, endangered, secluded, sensitive, or species of special concern to Montana and the Northern Rockies Ecosystem.

Sincerely,
Paul Richards
Founder and Board Member, Deerlodge Forest Defense Fund
Co-Founder and Board Member, Southwest Montana Wildlands Alliance
Member, Advisory Board, Alliance for the Wild Rockies
P.O. Box 780
Boulder, MT   59632
DFDF@PRMediaConsultants.com

Editor’s Notes:

1. This comment was submitted to the U.S. Fish and Wildlife Service on February 28, 2010.

2. Bull trout were listed as a threatened species due to many, many years of hard work by the Alliance for the Wild Rockies, a coalition of conservation groups supporting wildlands and dependent species in the Northern Rockies.  Further information at: http://www.wildrockiesalliance.org/issues/bulltrout/index.html and: http://www.wildrockiesalliance.org/ .

Dispatches from the Wildlands™ ©2010, Paul Richards

Sixteen Major Errors of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill

Analysis by Paul Richards, PR  Media Consultants®

Sixteen Major Errors of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill:

All of the sixteen following errors, flaws, and weaknesses of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill, were covered in my July 2009 in-depth analysis posted the day that Tester announced this legislation at a Townsend, Montana, sawmill at:  www.NewWest.net.

On July 17, 2009, NewWest.Net offered Sen. Jon Tester an opportunity to rebut all of these points.  As of this writing (January 7, 2010), he is still “considering it.”

It should be noted that, on July 17, 2009, Peter Aengst of the Wilderness Society did issue statements calling this analysis and the resultant NewWest.Net investigative piece a “rant.”  Aengst refrained from addressing any specifics.

1. The public was completely shut out of the drafting of S. 1470, the Tester Wildlands Logging Bill.  The bill was drafted in an underhanded manner by a handful of insiders, sworn to secrecy.  Rather than incorporating meaningful public involvement, Tester chose the path of “fait accompli.”  This has created enormous resentment from all quarters.

DETAILS:  I, for example, am a member of the National Wildlife Federation, Trout Unlimited, and Montana Wilderness Association.  I served on the board of the Montana Wilderness Association and have received the organization’s “Brass Lantern” Award.

Years ago, when these three conservation groups and the timber industry first formed the “Beaverhead-Deerlodge Partnership,” I approached the players.  As one who had been involved at the grassroots level with the Deerlodge National Forest for over 27 years, and as an official member of the Deerlodge National Forest Technical Advisory Committee, I thought my presence might be an asset during negotiations.  I had been involved with the successful appeal and resultant “Settlement Agreement” of the Deerlodge Forest Plan, which had been heralded region-wide as a model for citizen participation.

Over a two-year period, I sent numerous e-mails and made numerous phone calls, trying to get into the negotiations or at least monitor them.  All my attempts were rebuffed, as were all attempts by many other members of the public. We, as members of the National Wildlife Federation, Trout Unlimited, and Montana Wilderness Association, were kept entirely in the dark as our organizations’ staffs compromised away our public wildlands.

I have also been a member of the Wilderness Society for 40 years.  At NO time were Wilderness Society members ever appraised as to deals, trade-offs, and The Wilderness Society’s staff actually supporting the removal of current administrative and Congressional protections for our public wildlands.

Wildlands proponents weren’t the only ones excluded.  People in favor of resource development, county officials, and state legislators were also kept in the dark.  U.S. Forest Service officials, scientists, biologists, botanists, silviculturalists, and public information specialists were purposefully excluded from participation and denied access to all drafts of the Tester Wildlands Logging Bill.

In short:  There was NO public information and NO  public discussion.  Countless interest groups and individuals were surgically removed from every major decision regarding their own public lands.

Instead being forged by well-informed public debate, reviewed by U.S. Forest Service scientists and experts, and exposed to the healing properties of disinfecting sunlight, Tester’s bill was clandestinely and sloppily cobbled together behind-the-scenes.

2.  S. 1470, the Tester Wildlands Logging Bill, violates Tester’s 2006 campaign promise “to protect all of Montana’s remaining roadless areas.”

DETAILS:  With only a week to go, polls showed State Sen. Jon Tester and State Auditor John Morrison at a dead heat in the June 2006 Democratic primary race for U.S. Senate.  Tester operative Missoula attorney Pat Smith directly contacted former state Rep. Paul Richards (me), who was running third of five candidates in the race, concerning Richards’ possible endorsement of Tester.

Richards agreed to meet twice with Tester in Helena, Montana, on Tuesday, May 30, 2006, to see if terms could be worked out for this endorsement.

As a result of these two negotiating sessions, Tester agreed to terms detailed at:  www.Richards2006.us, including the specific promise that:  “If elected, Jon Tester will work to protect all of Montana’s remaining roadless areas.”

In exchange for these mutually-agreed-upon-with-witnesses (including Tester’s wife, Shar, and Tester’s son, Shon) terms, Paul Richards agreed to withdraw from the race for U.S. Senate and publicly ask his supporters to vote for Jon Tester.  After the agreement was reached, Richards personally contacted his extensive network of environmental advocates throughout the state, detailed Tester’s commitment to “protect all of Montana’s remaining roadless areas,” and asked his supporters to vote for Tester  in the June 2006 Democratic primary election, rather than Richards.

News of Richards’ endorsement appeared on front pages of most Montana daily newspapers and was prominent in all other media the final week before the election.  Tester and Richards celebrated the win jointly at a June 6, 2006, election night party in Missoula, MT.

3. S. 1470, the Tester Wildlands Logging Bill, alienates Tester’s main supporters from the 2006 election.

DETAILS:  Conservationists provided the margin of victory that allowed Tester to defeat incumbent Sen. Conrad Burns in the general election of 2006.  In tacking solely towards the timber industry, moneyed corporations that never previously supported him in any fashion, Tester has abandoned his true constituency.

To date, due to interminable efforts by countless pro-logging public relations specialists, reporters and editors that know better have been forced into states of profound stupor.  As a result of this lethargy, Montana’s corporate media have largely bought into the “spin” created by timber corporations, Tester, Baucus, Wilderness Society, National Wildlife Federation, Trout Unlimited, Montana Wilderness Association, and Greater Yellowstone Coalition.

Instead of raising necessary questions concerning potential loss of our public wildlands legacy and expenditures of well over $100 million in taxpayer timber subsidies, corporate media in Montana have cast legitimate public debate aside and joined the spinmasters’ choir, making Tester’s bill the “feel good” legislation of the year!

National media, on the other hand, will likely see through the smoke and mirrors, no matter how numerous and gregarious the spinmasters, how “nice” the legislation’s sponsor, or how desperately the sawmills crave even more taxpayer subsidies.

As the actual implications of the Tester Wildlands Logging Bill become known to public lands stakeholders throughout the nation, Tester’s credibility among public lands advocates and true conservationists will suffer accordingly.  Ultimately, this will become reflected in his in-state standing.  Instead of longtime dedicated conservationist like the esteemed Senator Lee Metcalf representing the long-term interests of our public lands legacy, Montanans are now looking at a one-term flash in the pan.

4. S. 1470, the Tester Wildlands Logging Bill, “undesignates” S 393 wildlands and loots the wildlands legacy of former Senator Lee Metcalf – Montana’s greatest conservationist.

DETAILS:  Tester’s bill is a full-scale pillaging of the legacy of Montana’s greatest conservationist and my mentor, U.S. Senator Lee Metcalf.  In 1977, Sen. Metcalf, only a year before he died, worked tirelessly to pass Senate Bill 393, the Montana Wilderness Study Act.

Sen. Metcalf’s magnificent legacy protected nine roadless wildland areas, while they were studied for official designation as wilderness under the Wilderness Act of 1964, a bill which Sen. Metcalf had earlier personally shepherded through Congress, with the conscientious advocacy of Wilderness Society Executive Director Stewart Brandborg and Wilderness Society Field Director Clif Merritt, both Montana natives.

Tester’s bill removes the Sapphire Wilderness Study Area and the West Pioneers Wilderness Study Area from the Congressional protection of Sen. Metcalf’s Senate Bill 393 and opens more than two-thirds of these priceless and irretrievable roadless wildlands to logging.

Only high-elevation “rocks and ice” non-timber producing tracts would be designated wilderness.  Of the 94,000 acres of public roadless wildlands currently in the Sapphire Wilderness Study Area, only 53,000 acres would be protected from development.  Of the 151,000 acres of public roadless wildlands currently in the West Pioneers Wilderness Study Area, only 26,000 acres would be protected from development.

Tester’s bill “undesignates” the Axolotl Lakes Wilderness Study Area, Bell/Limekiln Canyons Wilderness Study Area, East Fork Blacktail Wilderness Study Area, Henneberry Ridge Wilderness Study Area, and Hidden Pasture Wilderness Study Area.  These roadless wildlands would be subjected to “logging without laws,” as Tester’s bill excludes logging them from protective provisions of the Federal Land Policy and Management Act.

5. S. 1470, the Tester Wildlands Logging Bill, pulls roadless areas out from the protection of the Clinton Roadless Rule and the Obama Roadless Initiative.

DETAILS:  Tester’s bill withdraws around one million acres of public roadless wildlands on the Beaverhead-Deerlodge National Forest from the protection of the Clinton Roadless Rule and the Obama Roadless Initiative and opens them to roading and logging.

You won’t find this in the bill.  You have to go to the maps that accompany the bill, maps to which courts will undoubtedly refer, if this misguided legislation actually passes.  The maps (located at:  http://tester.senate.gov/Legislation/upload/Proposed-Land-Designations.pdf ) are very specific in reclassifying the Beaverhead-Deerlodge National Forest’s currently protected roadless wildlands to a new category, officially designated “Timber Suitable or Open to Harvest.”

6. S. 1470, the Tester Wildlands Logging Bill, Congressionally overrides legitimate forest planning processes that involve full public information and participation.

DETAILS:  Tester’s bill circumvents National Forest planning laws, procedures, and regulations.  Currently, the U.S. Forest Service is required to honestly evaluate “site-specific impacts” of proposed logging.

Under Tester’s bill, these requirements would be supplanted by a new system of “Landscape Scale Restoration Projects” where mandated logging takes place in the total absence of well-established forest planning procedures that require state-of-the art science, public information, and public involvement.

Tester’s bill Congressionally mandates cut levels, damn the environmental and financial costs.  Instead of decisions being made at local levels by informed forest science professionals, Tester’s bill dictates a one-size-fits-all prescription that prioritizes logging above all other uses.

Under Tester’s bill, taxpayer subsidies to timber corporations are more important than anything, be it elk hunting (which would diminish as elk security is logged away by mandated timber cutting), fishing (drastically debilitated by inevitable water degradation caused by unsustainable logging), steady supplies of clean irrigation water (logging causes much faster watershed runoffs and increased sedimentation), pure community water supplies (most western Montana cities get their water from our public roadless wildlands), diminished wildlife habitat, you name it.

7. S. 1470, the Tester Wildlands Logging Bill, promotes “logging without laws.”

DETAILS:  By mandating timber cuts be placed above all other concerns, Tester’s bill could statutorily exempt timber cutting from the Clean Water Act, Endangered Species Act, National Environmental Policy Act (which Tester’s bill mistakenly calls the “National Environmental Protection Act”), Wilderness Act, National Forest Management Act, and the Federal Land Policy and Management Act.  This is a point of contention.  Tester claims environmental laws will be adhered to.  To the uninitiated, that sounds just great!  However, the initiated know full well that when Congress mandates timber cutting quotas, federal courts have consistently held that the Congressional mandate to cut down the public’s trees trumps federal environmental and land use laws.

We’ve been through all this before.  For over 20 years, politicians have claimed environmental laws would be followed, at the same time that they have imposed mandatory cutting quotas on public lands.  While Tester’s public relations have lulled gullible “conservationists” into believing we can get the cut out and follow environmental laws, the courts consistently rule that the mandated cuts are paramount and that environmental laws don’t have to be respected.

The legal track record is available to anyone that can Google.  The court precedents have already been established:  If you have a conflict in law, “the specific overrides the general.”  That is, Congressionally-mandated cutting quotas preempt such laws as the Clean Water Act, Endangered Species Act, Wilderness Act, National Environmental Policy Act, National Forest Management Act, and the Federal Land Policy and Management Act.

Thus, despite proclamations to the contrary from Tester’s “conservation” collaborationists, if the Tester bill’s forced cutting quotas are approved by Congress, environmental laws would likely fall helplessly by the wayside.

8. S. 1470, the Tester Wildlands Logging Bill, mandates a cut of 7,000 acres a year for 10 years on a forest that sustainably produces, according to Beaverhead-Deerlodge National Forest officials, only between 500 and 2800 acres a year.

DETAILS:  As a lifelong resident of the area and as a long-time member of the U.S. Forest Service’s Technical Advisory Committee, I know full well that the Beaverhead-Deerlodge National Forest is not productive timberland.  Much of the forest is east of the Continental Divide, receives little precipitation, and has an extremely short growing season, due to its high altitude.  Due to these limiting factors, it costs the public at least $1,400 per acre to log in the Beaverhead-Deerlodge National Forest.

Tester claims the mandated cut will come from the Beaverhead-Deerlodge National Forest’s suitable timber base and that inventoried roadless areas are not threatened.  But, Tester is ignoring reality.  In recent years, logging professionals with the Beaverhead-Deerlodge National Forest have established the Forest’s sustainable yearly harvest at 500 acres.  The most they’ve cut, even during the years of the housing boom, is 2,800 acres a year.

Can Tester mandate a cut of 70,000 acres (7,000 acres a year for 10 years) on a forest that is not productive timberland, without entering and developing undeveloped (roadless) lands?  For a clue, review the maps located at:  http://tester.senate.gov/Legislation/upload/Proposed-Land-Designations.pdf and note that, under the Tester bill, the Beaverhead-Deerlodge National Forest’s inventoried roadless wildlands are officially re-designated as “Timber Suitable or Open to Harvest.”

9. S. 1470, the Tester Wildlands Logging Bill, mandates a cut of 30,000 acres of grizzly bear habitat on the Kootenai National Forest, causing distress and disturbance that some biologists say will force the dwindling Yaak grizzly bears into insecure habitat and ultimately extinction.

DETAILS:  Wildlife consultant Brian Peck reports, “I have worked for 15 years to try and save the imperiled 30-40 grizzlies in the Cabinet-Yaak Ecosystem in a landscape where the “Cores” are too small, the “Buffers” are over-logged and roaded, and the “Linkages” are non-existent.

Tester’s bill mandates the cutting of 3,000 acres per year for ten years on the Kootenai National Forest, a forest that already looks like a moonscape in many areas from decades of U.S. Forest Service abuse. How is another 30,000 acres of logging not going to be the last nail in these bear’s coffin?”

10. S. 1470, the Tester Wildlands Logging Bill, could have a severe adverse impact upon rare, threatened, and endangered species.

DETAILS:  Since the Tester bill Congressionally-mandates timber cuts, curtails forest planning, and severely restricts the U.S. Forest Service from accurately assessing logging’s impacts; environmental protections provided by the Clean Water Act, Endangered Species Act, National Environmental Policy Act (mistakenly called the “National Environmental Protection Act” by Tester’s bill), National Forest Management Act, Federal Land Policy and Management Act, and Wilderness Act will likely be preempted.

If this scenario plays out, the public will never know the full extent to which secluded, rare, threatened, and endangered species will be adversely impacted, particularly in the Kootenai National Forest and the Beaverhead-Deerlodge National Forest.

By forcing unsustainable industrial-scale logging upon our public lands, Tester’s bill would irrevocably harm essential habitat of species that characterize the wild nature of the northern Rockies, such as the gray wolf, bull trout, cutthroat trout (Montana’s official state fish), otter, mountain goat, mountain sheep, elk, arctic grayling, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, Montana vole, sage thrasher, wild bison, peregrine falcon, bald eagle, pine marten, fisher, lynx, wolverine, and grizzly bear (Montana’s official state animal).

11. S. 1470, the Tester Wildlands Logging Bill, ignores the scientific need to protect different elevation habitats and their dependent species.

DETAILS:  Conservation biologists have long understood the need to protect different elevation habitats and their dependent species, with core areas, buffer zones, and connecting biological corridors, or linkages.

More recently, scientists have documented that forest habitats are changing radically, due to global climate change.  The species depending on our National Forests for survival are increasingly stressed by climate change and are increasingly in need of broader migration opportunities.

The “conservation” collaborationists (Wilderness Society, National Wildlife Federation, Trout Unlimited, Montana Wilderness Association, and Greater Yellowstone Coalition) publicly boast that, by supporting Tester’s bill, they are “creating” new wilderness areas.

These areas fail to pass scientific muster.  A handful of nonproductive, high-altitude, limited-habitat “rocks and ice” wilderness areas, allocated to human recreational enjoyment does nothing for the vast majority of forest species.  Unconnected islands of  “rocks and ice” provide no biological integrity and no potential for sustaining biodiversity.

12. S. 1470, the Tester Wildlands Logging Bill, costs over $100 million for taxpayer-subsidized timber sales and lavish new sawmill power plants.

DETAILS:  It costs the public at least $1,400 per acre to log in the Beaverhead-Deerlodge National Forest.  Mandating logging of 7,000 acres will cost the public $9,800,000 a year.  Mandating this level of cutting for 10 years, as Tester proposes, will cost taxpayers at least $98 million dollars.

In fact, the cost of these timber industry subsidies will be considerably higher, as the above economic figures date from the housing boom, three-to-four years ago.  Now, that we are in economic depression, there is no housing construction and hardly anyone is buying timber.

In today’s depressed market for timber, the “hard money” subsidies for loggers that the Tester bill mandates will likely reach into the hundreds of millions of dollars over the next 10 years.

In addition to these taxpayer subsidies, Tester wants additional untold millions in taxpayer subsidies to build costly on-site power plants for the timber corporations promoting his bill.  The taxpayer-financed power plants will only serve the timber corporations, not the communities of western Montana.

It is more corporate pork, plain and simple.

Tester’s power plants also make absolutely no sense.  Trucking biomass to large, centralized power plants is grossly inefficient, when compared to utilizing numerous small-scale portable decentralized facilities.

It is far more practical to truck numerous inexpensive portable generators to the biomass, than to truck the biomass increasingly long distances to expensive and instantaneously obsolete centralized power facilities at sawmills.

13.  S. 1470, the Tester Wildlands Logging Bill, negligently ignores the fact that there is no current demand for timber.

DETAILS:  Since there is no demand for sawmills’ lumber, Tester’s bill defies basic common sense.  The legislation is blatantly undisguised in its privatization of public resources and its forcing the public assumption of lumber mills’ private debt.

A mere four corporations:  Pyramid Mountain Lumber (Seeley Lake), Roseburg Lumber (Missoula), RY Timber (Townsend and Livingston), and Sun Mountain Lumber (Deerlodge) will receive well over $100 million courtesy of the kind Senator, with taxpayers picking up the tab in tax dollars spent, watersheds degraded, habitat lost, and public wildlands destroyed.

14. S. 1470, the Tester Wildlands Logging Bill, mandates timber cutting, while leaving ensuing forest restoration optional.

DETAILS:  This is the elephant in the living room.  If Tester’s bill passes, by Congressional mandate, public wildlands will be roaded and their trees cut down.  Then, after the trees are long gone, there will be no forest restoration.

Tester’s bill contains absolutely NO restoration mandates.

National Forests are littered with giant messes of logging restoration left unfunded and undone.  It’s the U.S. Forest Service’s dirtiest secret:  After the public’s trees are cut down and the logs hauled out, somehow, the agency just never seems to be able to find the money to honor its once-so-earnest promises of restoration.

There isn’t a national forest in the country that has actually delivered on its past commitments to restore public lands and watersheds wounded by logging.  When it comes to budget priorities, post-logging forest reclamation and restoration has always been the U.S. Forest Service’s neglected and unwanted step-child.

Maintaining a brave posture in the face of this undeniable track record, Tester claims that revenues from mandated logging will pay for forest restoration projects.  But, inconvenient truth again rears its ugly head:  In lodgepole pine-dominant forests, there simply won’t be any revenues!  At taxpayer-subsidies of $1,400 for every acre logged, just how will Tester’s restoration funds be magically generated?

This giant Ponzi scheme will likely be the undoing of the Tester Wildlands Logging Bill.

15. “Conservation” collaborationists supporting S. 1470, the Tester Wildlands Logging Bill, have all received massive funding from the Pew Charitable Trusts, which works to “confine wilderness legislation to rocks-and-ice regions by co-opting gullible or calculating people in the wilderness movement.”

DETAILS:  The Pew Charitable Trusts are an independent nonprofit organization–the sole beneficiary of seven individual charitable funds, with assets of $5.2 billion at the end of June 2008, established by two sons and two daughters of Sun Oil Company founder, Joseph N. Pew, and his wife, Mary Anderson Pew.

Pew works to “confine wilderness legislation to rocks-and-ice regions by co-opting gullible or calculating people in the wilderness movement,” according to former Montana Wilderness Association President Elaine Snyder and former MWA Board Member Ross Titus.

“Organizations that have gained access to Pew money are expected to show short-term gains in wilderness protection regardless of the cost to other public resources and political efforts,” according to Snyder and Titus.

The Montana Wilderness Association has received tens of thousands of dollars of Pew money.  The National Wildlife Federation, Trout Unlimited, and the Wilderness Society have each received many millions of dollars from the Pew Charitable Trusts.  National Wildlife Federation staffers are even housed at Pew’s Washington, D.C. headquarters.

Pew tipped its hand concerning the Tester Wildlands Logging Bill with a preemptive Thursday, July 9, 2009, e-mail “Alert” entitled “Sen. Tester Leads on Wilderness” from Mike Matz, executive director of the Pew-funded “Campaign for America’s Wilderness” (formerly known as the “Pew Wilderness Center”).  “We need to THANK Senator Tester for showing positive leadership to protect the best of Montana’s pristine national forests,” Matz wrote.

“His bill would add the first new wilderness in Montana in more than a quarter of a century,” Matz continued. “Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.  Please take a moment to call Senator Tester today and make a difference for Montana’s wilderness.  Dial the nearest local office now and tell them you appreciate Sen. Tester’s leadership on wilderness,” Matz concluded.  Matz then listed the telephone number for each of Tester’s eight Montana field offices.

Matz was asking well-intentioned wilderness advocates, who don’t know the funding sources of the “Campaign for America’s Wilderness,” to praise Tester for a wildlands logging bill that Tester refused to allow the public to see!

On the same afternoon, the Wilderness Society, sent out its own “Wild Alert,” under the name of Kathy Kilmer.  “Montana’s Sen. Jon Tester is considering legislation that would give Montana its first new wilderness designations in decades,” Kilmer wrote.  “Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.  Please call Sen. Tester and thank him for showing positive leadership to protect the best of Montana’s pristine national forests,” Kilmer concluded.  The Wilderness Society used the exact same non-alphabetical listing of Tester’s eight Montana field offices as Matz.

Besides the eeriness of identical non-alphabetical listings and the same language (“Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.”), the incredible thing about the preemptive Pew-funded e-mail campaigns of July 9, 2009, was that no one anywhere had actually seen the Tester Wildlands Logging Bill, other than the timber industry and its collaborationists!  Yet, we grassroots wildlands supporters were supposed to sign a blank check, call Tester, and thank him for drafting a public lands bill in secret!

When I first reported on the Pew-orchestrated campaign, Peter Aengst of the Wilderness Society wrote the following to Jared White of the Wilderness Society:  “Can you check with Kathy Kilmer and see if it is possible to remove certain unsupportive people from our Wild Alert lists?  Like Paul Richards (see his direct quoting of our alert).”

How dramatically have millions of Pew dollars caused the Wilderness Society to stray from its original mission, once pursued so faithfully by such courageous stalwarts as Robert Sterling Yard, Benton MacKaye, Robert and George Marshall, Aldo Leopold, Howard Zahniser, Stewart Brandborg, and Clif Merritt?

How could today’s Pew-funded Wilderness Society take me, a member of 40-years-standing, OFF of its mailing lists for being pro-wildlands and pro-wilderness?

How could today’s Pew-funded Wilderness Society exclude the public from public land decisions; support throwing away untold millions of dollars of pork for taxpayer-subsidized timber sales and lavish new sawmill power plants; exempting public wildlands from federal laws and the protection of a new earnest President; “undesignating” the legacy of Montana’s greatest conservationist; and destroying an irretrievable portion of Montana’s priceless roadless wildlands heritage?

16. S. 1470, the Tester Wildlands Logging Bill, fragments the Northern Rockies Ecosystem, the ONLY functioning ecosystem in the lower 49 states where all native species still reside.

DETAILS:  Northern Rockies wildlands are the only place in the lower 49 states where all native species and wildlife remain!

These are our public wildlands, belonging to all Americans.

The Tester Wildlands Logging Bill strips away the protection of these public wildlands currently provided by the Clinton Roadless Rule, the Obama Roadless Initiative, and Sen. Lee Metcalf’s incredibly farsighted Senate Bill 393.

By fragmenting the Northern Rockies Ecosystem, the Tester Wildlands Logging Bill is a direct assault on the scientific principles of biodiversity and biological integrity for which so many dedicated citizens have worked so hard for the last quarter century.      If Tester’s bill passes:  Secluded, rare, threatened, and endangered species will be adversely impacted, particularly in the Kootenai National Forest and the Beaverhead-Deerlodge National Forest.

By forcing unsustainable industrial-scale logging upon our public lands, Tester’s bill would irrevocably harm essential habitat of species that characterize the wild nature of the northern Rockies, such as the gray wolf, otter, mountain goat, mountain sheep, pika, elk, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, sage grouse, Montana vole, sage thrasher, wild bison, peregrine falcon, bald eagle, pine marten, fisher, lynx, wolverine, arctic grayling, bull trout, cutthroat trout (Montana’s official state fish), and grizzly bear (Montana’s official state animal).

The “wilderness” areas in the Tester bill are fragmented and unconnected islands of largely “rocks and ice,” with no biological integrity and no potential for sustaining biodiversity.

These minimal “wilderness” designations in Tester’s bill fail entirely to protect different elevation habitats and their dependent species with core areas, buffer zones, and connecting biological corridors.

The Tester Wildlands Logging Bill promotes numerous abuses and violations that are clearly incompatible with the 1964 Wilderness Act, including motorized access into and through “wilderness,” low-level military overflights of “wilderness,” military aircraft landings in “wilderness,” possible “wilderness” logging, and other intrusions that violate the intrinsic principles of Wilderness.

As Montana State Rep. Francis Bardanouve used to say:  “This is a BAD, BAD bill”:

As my very dear friend and companion, the late Rep. Francis Bardanouve, the highly-respected Dean of the Montana Legislature, sometimes proclaimed, when I served with him in the Montana House of Representatives, “This is a BAD, BAD bill!”

Francis rarely said this.  But, the few times he did say it, legislators paid attention.  They knew Francis did his homework.

House members understood that Rep. Francis Bardanouve ALWAYS researched exhaustively and deliberated studiously, before arriving at his opinion.  As a result, Francis’s peers in the House of Representatives listened carefully and consistently heeded Francis’s warning that “This is a BAD, BAD bill.”  They always voted the bad, bad bill down.

For all the errors, flaws, and weaknesses detailed above and for many other reasons raised by countless groups, officials, and citizens:  S. 1470, Sen. Jon Tester’s Wildlands Logging Bill, is a BAD, BAD bill.  It needs to die a quick death.

In support of lasting protection for our Nation’s priceless and irretrievable public wildlands legacy,

Respectfully submitted,

Paul Richards
PR  Media Consultants®
Public Interest Media Since 1968
30 Brown’s Gulch Road
Boulder, MT   59632
Paul@PRMediaConsultants.com

www.PRMediaConsultants.com
www.Richards2006.us
http://blogs.alternet.org/paulrichards/

(Editor’s Note: For further extensive in-depth analyses and commentary about the Tester Wildlands Logging Bill and for information about The Last Best Place Wildlands Campaign, a coalition of 55 conservation groups opposed to the Tester Wildlands Logging Bill, go to:  http://testerloggingbilltruths.wordpress.com/ ).

Dispatches from the Wildlands™ ©2010, Paul Richards

30 Brown’s Gulch Road
Boulder, MT   59632
Paul@PRMediaConsultants.com

John Rosenow, Chief Executive
Arbor Day Foundation
100 Arbor Avenue
Nebraska City, NE   68410

April 3, 2010

Dear Mr. Rosenow and Fellow Friends at Arbor Day Foundation,

Have you ever thought of incorporating the best available science into your work?

Your recent letter from Chief Executive John Rosenow requesting my membership renewal says:

“I’m sure you’ve seen the pictures on the news of horrendous forest fires that have devastated many of our nation’s forests.  The fact is, our treasured National Forests are being destroyed as never before, not only by fire, but also by disease and insect infestation.”

None of this is true.  Mr. Rosenow’s statements are scientifically indefensible.  Even novices know that forest fires are an absolutely ESSENTIAL part of forest renewal, particularly in our forests of the West.

Our National Forests are NOT being destroyed by fire, disease and insect infestation!  How does Mr. Rosenow deal with the reality that our forests have gotten along fine WITH fires, diseases and insect infestations for untold millions of years?!  In fact, natural healthy forests can not possibly survive without fires, diseases and insect infestations!

Hysteria, paranoia, and fearmongering may have helped recruit funds for your organization in the past, but it is now time to evolve beyond this crass baseness.  Leave the hysteria, paranoia, and fearmongering and the resultant disempowerment of our human community to the likes of FOX “News.”

Let’s be positive.  Let’s look at the facts:
1.  Fires rejuvenate our forests.  Just look at Yellowstone National Park!
2.  Diseases and insect infestations create vital habitat and food for birds and many other species.
3.  Standing dead trees and downfallen logs create incomparable habitats for countless plant and animal species.
4.  Downfallen logs retain moisture and allow growth of many things, such as 12,000 species of mosses or 3,500 species of grasses, that could not otherwise thrive.  Mr. Rosenow, please ask yourself:  How could we possibly have lynx, without the habitat and security of downfallen trees and their resultant production of food necessary to rabbits, mice, and other essential prey?
5.  Despite what the emotional claims in your letter asking for my membership renewal, the threats to our National Forests are NOT fires, diseases, and insect infestations.  The data are in.  Science has confirmed that the most dire threats to our National Forests and all indigenous old growth are roading, logging, mining and other industrial development, and domestic livestock grazing.
6.  It is roading, logging, mining, and domestic livestock grazing – NOT fires, diseases, and insect infestations – that destroy our National Forests, eliminate crucial wildlife habitats, radically diminish biodiversity, and severely degrade our public watersheds.
7.  Our National Forests need to be National Forests, not private tree farms for timber corporations or private feedlots for anti-wildlife corporate agri-biz!
8.  Instead of being converted to genetically inferior monoculture tree farms that are more susceptible to pathogens and insects, our National Forests must engender thriving and diverse indigenous plant and wildlife communities.
9.  Public lands, especially National Forests, National Grasslands, and National Parks, must be restored to healthy and natural states of biodiversity and resilience.
10. As we finally begin to wisely manage our National Forests to create optimum situations for indigenous plant and wildlife species, we MUST support the vital roles played by fires, diseases, and insect infestations!

Mr. Rosenow, scientific ignorance bodes ill for the future welfare of our National Forests.  I sincerely hope you, your board, and all Arbor Day Foundation members are open to biotic reality and the dramatic changes that respecting indigenous species and biodiversity will entail within our  organization.  The sooner these changes come, the better.

Instead of continuing to plant exotic species where they don’t belong and to condemn the very natural processes that ensure the vitality of forests, it is now time for the Arbor Day Foundation to begin incorporating the best available science.

The Arbor Day Foundation has certainly done some good, particularly for areas, such as Nebraska, where indigenous trees, forests, and dependent species were obliterated by white settlers.  Who could oppose new forests and shelterbelts planted and supported by the Arbor Day Foundation and its dedicated supporters?  For that reason, in the past, I have been proud to be a member of the Arbor Day Foundation.

But, as a native of the Northern Rockies Ecosystem, the LAST remaining functioning ecosystem in the lower 49 states where all native species still reside, I must now ask the Arbor Day Foundation to stop being so shallow concerning the needs of functioning forest ecologies and start helping heal the Earth.

Mr. Rosenow, it is time for the Arbor Day Foundation to abandon its shameless promotion of alien plant species as biotically-meaningless eye candy and face up to basic realities of continued existence of life on Earth.

The Arbor Day Foundation MUST give up its unfortunate, destructive, and outdated addiction to and promotion of exotic species.  To restore the countless ecosystems that white people have damaged almost beyond repair in North America, the Arbor Day Foundation must now instead focus upon indigenous trees, shrubbery, and plants.

By changing its focus from exotic eye candy to restoring indigenous trees, shrubbery, plants and fungi, bugs, and birds, the Arbor Day Foundation will help restore indigenous forests.  And, by the gradual restoration of functioning indigenous forests, the Arbor Day Foundation will bring back indigenous species, many of them now at the brink of extinction.

With revitalized forests will come plentiful wildlife, pure watersheds, abundant fisheries, and the reemergence of amphibians and reptiles who have so quietly and bravely faced doom the last quarter century.

Instead of irresponsibly condemning them, it is now time for the Arbor Day Foundation to embrace the natural processes of fires, diseases, and insect infestations on our National Forests and other public lands.

Instead of perpetuating ignorance, like that demonstrated in Mr. Rosenow’s above quote, it is time for the Arbor Day Foundation to actively help inform the public about scientific necessities involved with forest renewal.

First, we’ve got to protect that which hasn’t yet been broken.  The Arbor Day Foundation must help stop all roading, logging, domestic livestock grazing, and industrial development of our few remaining National Forest and BLM roadless wildlands that still retain biological integrity.

It is time for the Arbor Day Foundation to endorse and actively promote legislation such as the Northern Rockies Ecosystem Protection Act (NREPA), which officially protects the remaining National Forest roadless wildlands in the Northern Rockies by designating them Wilderness.  (Please see the enclosed information about HR 980, the Northern Rockies Ecosystem Protection Act, sponsored by 103 Members of Congress.  This information is from my recent Congressional testimony before the U.S. Senate Subcommittee on Public Lands and Forests.)

As it incorporates the best available science, the Arbor Day Foundation can lead efforts to protect every single remaining acre of natural forest wildland in National Forests, National Parks, National Grasslands, Bureau of Land Management roadless areas, and state-owned lands.

Second, where the wild has been unwisely broken, what could possibly be a better task for the Arbor Day Foundation than to begin reassembling the pieces?  I see the Arbor Day Foundation playing a pivotal role toward the reestablishment of indigenous forests, comprised of indigenous species, where all natural processes are appreciated and allowed.  (Yes, Mr. Rosenow, this most certainly includes fires, bugs, and diseases).

When the Arbor Day Foundation accepts this timely and essential new mission, I will be proud to re-up my membership.

Mr. Rosenow and other friends at Arbor Day Foundation, my e-mail address is below.  Please contact me if you want to discuss any of the above.  I would like to work with you to restore damaged forest ecosystems throughout North America and to protect the few remaining roadless wildlands and dependent indigenous species we have left.

As a native rural Montana elder with a whole lifetime of experiences concerning our National Forests and other public lands, I will be happy to help you redirect the focus of the Arbor Day Foundation toward more productive, Earth-friendly, scientifically-responsible activities that promote indigenous species, biodiversity, biological integrity, and natural ecosystems restoration.

All my best,

Paul Richards
Member # 878-008-1660, Arbor Day Foundation
Paul@PRMediaConsultants.com

www.PRMediaConsultants.com
www.Richards2006.us

More Dispatches from the Wildlands™ at: http://blogs.alternet.org/paulrichards/.

Dispatches from the Wildlands™ ©2010, Paul Richards