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Cloer-Testimony: H.R. 2153 Page 5 



policy, and SNF standards and guidelines." 



"SNF put fonvard a definition of reforestation success utterly deficient and 

 grossly inconsistent with Forest Service Handbook direction." 



"(The Report) fails to respond to its own data that reveals chronic reforestation 

 failures." 



Dr. Hrubes Declaration includes photos of plantations which he found to be "failed" 

 but which SNF's Report claims are successful. 



Registered Forester James DePree reviewed the Report for the Sierra Club and for 

 Tulare County Audubon. Some of his points include: 



"Besides faulty methodology, the (Report) should have contained proper basis for 

 stocking standards for acceptable reforestation." 



"It is impossible to draw any scientifically based conclusions regarding the 

 suitability of any specific type of site. Because of this fact, the (Report) cannot and 

 should not be used in any other analyses, plans, environmental documents, or 

 public statements by the SNF." 



Greg Harty, a forester, with the Public Forestry Foundation reviewed the Report. Some 

 of his points include: 



"Seldom have we had the opportunity to examine greater amounts of information 

 presented in such a meaningless fashion." 



"We believe that the distribution of seedlings throughout the plantations is so 

 inadequate as to render the future volume projections generated through computer 

 models ...totally meaningless." 



At a recent field trip. Sequoia Forest sitviculturalist, Robert Rogers, acknowledged that 

 data in his 1991 report did not differentiate between seedlings that were planted only a 

 few months before the survey and mature trees which had been growing on a site for 

 decades. When Mr. Rogers made this point, we were at a unit to which we had taken 

 Congressman Dooley and Congressman Jim Jontz in 1991. This unit, 1001 A, had 

 been first logged in 1964 and replanted in 1965. It was declared a failed unit in 1970, 

 and it was enlarged and logged again in 1984. It had been replanted in 1985, 1987, 

 and in 1990. Today, one still has to search for newly planted seedlings among the 

 brush. By most reasonable definitions it is a failed unit, but it has been reported as a 

 successfully stocked 1965 plantation in every reforestation report. In 1987, under 

 penalty of perjury, Steven Pintek, District silviculturalist on the Tule River District, 

 declared that this unit was not only successful but that it was also in good condition. 



