147 



Collector roads, while stopping the expansion of "local" roads durintf the 

 Plan revision to an agreed upon level. The bill might direct not more than a 

 certain amount of road system expansion when the Plan is produced. 



3. Regeneration, Sec. 7(g), page 17. 



It is assumed that this bill language contemplates both natural and 

 artificial regeneration. Whether it is necessary to direct that the work be 

 completed in 5 years should be measured by eoals, the area involved, whether 

 natural regeneration is to be used, and the cost. Since commercial timber 

 production is not contemplated in the Preserve, the goal should be to assist 

 natural regeneration that produces the desired ecological outcome. The Plan 

 should define these goals. Operations should be measured against them. It may 

 well be that natural regeneration should prevail in many cases. 



4. Fire Management, Sec. 7(i), page 17-18. 



It needs to be made clear whether "eliminating fire control activities", 

 may lead to creating catastrophic level fires. Fire management and control 

 are not opposing ideas. Research should chart whether limited control burning 

 may continue to play a useful role. 



5. Tinber Cutting Sec. 7(k), pages 18-19. 



At page 19 the bill proposes a 500 vard "no cut" zone. These would be 

 3,000' diameter circles embracing 150 acres. A 220 yard (660 ft.] radius 

 would embrace 31 acres. You may wish to seek the advice of silvics experts as 

 to whether this smaller area provides an adequate buffer for research 

 cuttings and the few cuttings that the fire plan or emergencies may suggest. 



It is not clear whether the fire plan cutting concept rules out cutting 

 for insect, or disease. 



At pages 18-19 timber cutting is not permitted and the timber is removed 

 from the Allowable Sale Quantity Base for the Forest. Further, no commercial 

 sales are to be permitted. There are two exceptions: timber may be cut for 

 scientific study or if consistent with a fire plan the Scientific Advisory 

 Board approves by a 2/3rd majority. Only 1/20 of 1% of the area per year (50 

 acres per 100,000 acres), may be assigned to scientific cutting. 



This restriction raises 2 points. Is such a tight limit on scientific 

 study cutting needed when it takes a 2/3rds vote by the Board to authorize 

 it? Why is there no limit on fire plan cutting? The need for scientific study 

 to warrant cutting should be examined. The 2/3rds vote would seem to provide 

 a safeguard against over use. 



You may want to consider the same procedure for fire plan operations. 



The Board also ought to be empowered to make recommendations on whether 

 commercial use could be made of material cut. NFMA permits the Secretary to 

 sell "trees, portions of trees, or forest products" from National Forests. 

 The Forest Service could conduct the selected felling operation, decking the 



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