38 



bearing these costs directly and indirectly throughout, but the 

 heaviest impacts are falling on rural communities. 



As a side-bar, after the administrative appeals continue to close 

 the mills in Fredonia, Arizona, and potentially the mill in 

 Panguitch, Utah, will be closed, the Dixie National Forest, as you, 

 Mr. Chairman, pointed out earlier, has put out a notice indicating 

 that they are looking for purchasers to come to the area from a 

 500-mile radius. 



A friend of mine from the Black Hills wrote, and he said, "Oh, 

 and if you are looking for a partner to build a mill and take advan- 

 tage of the wonderful Forest Service opportunity, please don't call 

 me." 



Trust in the situation is totally lacking in this process, and you 

 can imagine a firm or a company and their bankers trying to figure 

 out how to commit $8 to $10 million to be able to take advantage 

 of this. 



And I guess the question I would ask you all here in this room 

 today, would you invest your savings on a venture such as this 

 with the threat or the potential of appeals stopping the supply of 

 raw material for such a venture? I don't think so. 



I would also like to point out that the closing of these two mills 

 resulted in the local area loosing the only area's capability of han- 

 dling these kind of volumes. These two mill complexes could have 

 handled logs ranging in size from six inches in diameter to 25 

 inches in diameter. Eighty-eight percent of that volume could have 

 been 16 inches or less, and today the issue in the West is what are 

 we going to do with small timber, fire killed, insect killed, and so 

 on. 



The preservationists really have used a bait-and-switch tactic 

 that has evolved a strategy of goading the Forest Service about the 

 low cost timber sales, and then turn right around and start delay- 

 ing those same programs and increasing those costs. 



Eventually, it became impossible for the Forest Service to meet 

 its goals and budget objectives. Before long, the media and others 

 were clamoring for answers as to why costs were higher than reve- 

 nues. The leading reason for the higher cost is administrative ap- 

 peals and resulting delays. I have thought from time to time and 

 mused about this as why would the Administration and the Forest 

 Service continue a system that would have those kind of impacts 

 on its own self? 



Recommendations: one, I think we should take the free out of the 

 appeal system. If the appellant loses, he pays. Two, on emergency 

 programs and certified emergency, we should limit the appeal to 15 

 working days so that we can get about the business of salvaging 

 insect and fire-killed timber. 



Intervention, as you mentioned before, Mr. Chairman, should be 

 left on the basis to valid standing positions. And then we need to 

 shorten and fast-track the whole program so that we do not exceed 

 30 working days, about six weeks in the whole thing, so that we 

 can get about our business. 



I have another recommendation, and that would be that under 

 the appeals process that from a Federal standpoint that we direct 

 the States, where they have State agencies involved in appeals, 



