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Glen Spain and Zeke Grader
Pacific Coast Federation of Fishermen's Associations
Fish do not arise from nowhere. They require nursery beds, spawning and rearing habitat, and a narrow range of environmental conditions to support them as they grow to maturity.
Some species such as salmon depend heavily on forests (particularly old growth forests) for these conditions. Other species such as Dungeness crab, sturgeon and shrimp are also highly dependent on nearshore conditions which can be dramatically affected by what happens on inland forests.
Three quarters of the nation's fish production depends on near shore estuaries, marshes and other wetland environments which, in their turn, are fed by waters coming primarily from forested lands, and which can be dramatically affected (for good or ill) by how those upriver forests are managed.
In other words, forestry is a fish issue. Salmon fishing is the number two most valuable forest-dependent industry on the west coast, right after logging, and in some coastal communities has historically been number one. Sediment washed down from poorly managed forests can destroy estuaries, drown out crab and shrimp nurseries, lead to or exacerbate flooding of coastal communities, and kill salmon production entirely. Poor forestry practices in the past have stripped protective vegetation from salmon producing streams, elevated water temperatures to the point where salmon die, and channelized river systems so badly that they may take generations to naturally recover. In many cases, the health of forested watersheds determines the health of our near shore fisheries and the economic future of our communities.
This is why PCFFA and many other fisheries organizations find themselves inevitably drawn into the debate about forestry reform in every western state. In fact, a fair bit of our time has been spent in past years pushing for forestry reforms that are more "fish friendly" and which avoid the extinction of salmon. Healthier forests are a key to the recovery of many salmon runs, as well as the protection of coastal estuaries and wetlands that support other valuable species as well.
Here are some of the current forest reform issues, state by state and in Congress, that fishermen should be concerned about.
Today almost all of the best remaining salmon spawning and rearing habitat is on federal public lands. Wild coastal coho salmon, once the workhorse of the Pacific salmon fleet, are now listed in both California and Oregon as "threatened with extinction" under the federal Endangered Species Act. Roughly one third of all available coho salmon habitat is on federal lands, and thus federal forest management is crucial to the eventual recovery of that species.
What salmon need most are old growth forests. The west coast's last stands of old growth forest are on federal lands. No significant old growth remains on private forestlands anywhere on the west coast with the sole exception of the Headwaters Forest's old growth redwood stands owned by Pacific Lumber Company (PALCO). Though mismanagement of federal lands in the past has lead to serious salmon declines, these lands still have been FAR better managed than surrounding private industrial forestlands, where many runs of salmon are already extinct and watersheds have been seriously damaged. However, federal land protections are constantly under attack in Congress.
Attacks on Getting Good Science: The Northwest Forest Plan, originally implemented to resolve the "northern spotted owl" problem, also contained some truly progressive aquatic protection measures, including 300-foot no-harvest stream buffers, the obligation to do full watershed analysis to determine cumulative effects, and to do full biological surveys for the many species dependant on those forests.
Unfortunately, the U.S. Forest Service has dragged its feet and consistently failed to conduct scientific surveys for many forest species as required by law. As a result of recent court rulings blocking timber sales on this basis, the Forest Service's timber sales program is on hold in coastal areas covered by the Plan. However, instead of seeing that the Forest Service gets the additional resources they need to get these scientific surveys done, Senator Slade Gorton, at the behest of the timber industry (among his major campaign contributors), introduced a rider (Section 329 to the Interior Appropriations Bill, S. 1292) intended to give the U.S. Forest Service and Bureau of Land Management complete carte blanc discretion over when, how or whether to conduct necessary scientific species surveys.
PCFFA strenuously opposes riders of this kind, just as we did the infamous 'timber salvage rider' of a few years ago, which was a disaster for fisheries protections (See March, 1996 FN, "Fishermen Get Shafted by the 'Salvage' Rider," <http://www.pcffa.org/fn-mar96.htm>). Such a rider would relieve the Forest Service from any obligation whatsoever to assess the impact of timber sales on species such as salmon. Without scientific surveys, there is no baseline data by which to measure any impacts. In effect, riders of this sort attempt to re- institutionalize scientific ignorance as forest policy in order to "get the cut out" at all costs, and to continue the flow of federally subsidized timber while destroying more fisheries.
Senator Gorton's rider is one of many thinly veiled recent attempts to gut science-based forest planning, and thus to eliminate all ecological restrictions on federal timber sales. The Northwest Forest Plan, PACFISH and other modern forest plans, in spite of their flaws, still offer the best protections for salmon and aquatic areas ever developed on federal lands protections long called for by scientists as necessary steps in salmon recovery.
Attacks on the Forest Service's Road Construction Moratorium: There are currently at least 377,000 miles of logging roads in our National Forests. This is eight times the length of the entire US Interstate Highway system or enough road miles to circle the Earth more than 15 times! Each of these roads is a potential sediment 'time bomb' waiting for the next major flood event to wash tons of sediment downstream into key fish spawning and rearing areas, and eventually into estuaries. Thousands of stream miles have already been destroyed from this cause and will take a very long time to recover.
Recently the U.S. Forest Service imposed a much needed moratorium on new road construction. This angered the timber industry because federally subsidized road construction greatly benefits that industry (at taxpayer expense) by allowing them cheaper access to federal timber. PCFFA believes that construction of new roads should not even be considered when the Forest Service does not have the resources to maintain the roads it currently has in our National Forests. As of March of 1997, the Forest Service reported a $440 million backlog on road maintenance needs for roughly 232,000 miles of its already existing roads. Roughly 60,000 additional miles of "ghost roads" not previously mapped were recently discovered as well, most of them in very poor condition.
There have already been a number of Congressional efforts to overturn the current road construction moratorium and restore the timber industry's fat-cat road subsidy. Efforts to shift money from new road construction to road maintenance and obliteration (as part of salmon recovery efforts) are gaining momentum but have for the most part been blocked by timber interests. PCFFA supports the road moratorium as well as shifting of money from construction of new roads to obliteration of unneeded roads and to road maintenance, as an obvious way to reduce salmon destruction on these lands.
Efforts to Defend Below Cost Timber Sales: The US Forest Service, and to a lesser degree the Bureau of Land Management, have long run their timber sales operations at a substantial loss to taxpayers. In other words, these programs are organized to provide massive federal welfare subsidies directly to the timber industry. In September 1995, the U.S. Government Accounting Office (GAO) estimated that the national forest timber sales program cost the taxpayers nearly $1 billion over the prior three years, about $300 million/year, or a federal subsidy of about $11,000/job directly to the companies for every timber job generated by these sales. These subsidies continue to this day and new ones keep cropping up. Many of these federally subsidized timber sales destroy important salmon habitat.
In other words, these programs requires fishermen (and other taxpayers) to subsidize the destruction of their fishing industry and other public resources just so that timber companies can maintain huge profits.
Most efforts in Congress to curtail these subsidies have thus far failed. However, several conservation groups more and more taxpayer watchdog groups (such as Taxpayers for Common Sense) are pushing for federal timber sale reforms to eliminate these subsidies. PCFFA also supports the elimination of all federal subsidies that encourage the destruction of salmon habitat.
Breaking the Addiction of Counties to Timber Revenues: Since 1908, counties in which there are federal forestlands managed by the US Forest Service have received 25% of timber sales revenues generated from these forests to help pay for local roads and schools. This was intended to compensate them for the loss of these lands from local property tax roles. Unfortunately this means the counties have a huge incentive to lobby for ever higher timber harvests (which give them short-term revenues) at the expense of long term sustainability. Furthermore, world timber prices are now extremely volatile, often determined by international global market forces beyond anyone's control.
The current payment system no longer makes any economic sense, and PCFFA has endorsed current Administration proposals to replace this archaic system with guaranteed flat-amount payments to the counties as a way to stabilize county budgets and to reduce the incentive to cut unsustainably. In addition to the Administration's own proposal, there are at least three competing bills in Congress this year which address this problem: H.R. 1185 (DeFazio) and H.R. 2389 (Boyd) in the House, and S. 1608 (Wyden/Craig) in the Senate. PCFFA has supported the DeFazio bill with some mix of Administration proposals.
World Trade and Dumbing Down of U.S. Standards: Just like they are doing with fisheries protections, various world trade forums are trying to color U.S. environmental restrictions on timber harvests as 'actions in restraint of free trade' subjecting the U.S. to international trade sanctions. This is a thinly veiled effort to eliminate all environmental restrictions in the name of profit for a handful of multinational timber companies. PCFFA opposes the 'dumbing down' of U.S. environmental protections in the name of free trade. Many of those protections are necessary to help assure healthy salmon runs, clean rivers and healthy estuaries for the U.S. fishing industry. (See FN November, 1999, "The World Trade Organization (WTO): Flying Below Fishermen's Rader," for a more thorough analysis of how world trade may affect our industry <http://www.pcffa.org/fn-nov99.htm>).
About two-thirds of necessary salmon habitat lies within streams on private land, which also serve as migration corridors for salmon spawning on public lands higher in the watershed. Unfortunately, private lands are generally the most degraded, and all too often have become killing zones for migrating salmon. Many river systems throughout private lands are full of sediment, chemical pollutants, or simply too hot to support healthy salmon populations for lack of large shade trees near stream banks.
Because salmon are forest-dependent, industrial forest practices have also played a very large role historically in creating these problems. Forest health is vitally important to salmon. Most scientists believe that salmon can never achieve full recovery unless private and industrial forestry impacts are also addressed and curtailed. Here are some of the current efforts fishermen are engaged in to reform forest practices on private lands:
Washington State: The recently ended Legislative Session adopted a set of forestry measures that came out of the 10-year negotiations of Washington's "Timber, Fish and Wildlife (TFW) Process." However, these negotiations never included salmon fishermen, and in the last year conservation organizations withdrew because they believed the protections proposed by the timber industry were inadequate to restore salmon. Later a closed-door deal was cut between NMFS, the State of Washington and various timber interests.
The result was quickly jammed through the 1999 Legislature as HB 2091. The bill itself refers to a document known as the "Forests and Fish Report" which will now be the standard for all future forest practices in Washington State (available from the WA Dept. of Natural Resources Web site at: http://www.wa.gov/dnr/). Concessions by the timber industry were also coupled with a $3 billion harvest tax rebate to "compensate" the industry for "giving up" some timber in riparian areas necessary to protect fish (i.e., for giving up the "right" to push fish to extinction!).
In fact, these new standards are political, not biological. Throughout the process there was little or no scientific review. The new riparian protections are merely what the timber industry was willing to give up, not necessarily what biologists believe the fish actually need. Many scientists believe them to be inadequate. Furthermore, the bill requires that these standards become a federally approved Habitat Conservation Plan (HCP) which will legally insulate the entire Washington State timber industry from having to come up with any additional ESA-listed species protections for the next 50 years! This makes it nearly impossible for the Washington Forest Practices Board to impose any additional restrictions. In other words, if these protections turn out to be not good enough, you can kiss Washington's salmon runs goodbye!
It remains to be seen how these provisions will be implemented, or whether they will even be adequate to prevent more salmon extinctions. For more information contact the Washington Environmental Council (WEC) in Seattle at (206) 622-8103. WEC (working with several fishing groups, including PCFFA) will be monitoring implementation of this deal, and if it is not adequate to save salmon we may all challenge it in court.
Oregon State: Oregon coastal coho salmon and several runs of steelhead are already listed under the ESA. As part of its listing process, and in negotiations under the Oregon Salmon Plan, NMFS identified three major areas where current Oregon forest practices are seriously deficient for protecting salmon: (1) inadequate stream buffer protections on medium, small and non-fish bearing streams; (2) inadequate protections for landslide prone areas; (3) virtually no identification or management of cumulative effects.
In response, the Board of Forestry has appointed a stakeholders "Advisory Committee" to review the current rules and make suggestions to the Board of Forestry on how current forest practices could be improved.
However, the "consensus" nature of this Committee, the fact that it is dominated by timber interests, and the contentious nature of the issues themselves pretty much guarantee that the Committee's recommendations will not address fundamental problems nor advocate additional restrictions on timber harvests, however necessary. This Advisory Committee hopes to have recommendations early next year.
However, pressure for change is clearly building. In September of this year the Oregon Plan's Independent Multi-disciplinary Science Team (IMST) formally concluded that Oregon's Forest Practices Act is NOT sufficient to promote salmon recovery on private forestlands, and made a number of suggestions for fundamental change. The IMST Report ("Recovery of Wild Salmonids in Western Oregon Forests," IMST Technical Report 1999-1 (September 8, 1999) is available on the Interet (http: <http://www.oregon-plan.org/reports.html>). PCFFA's Northwest Regional Office continues to monitor that process closely.
California State: After years of Wilson Administration's efforts to delay all salmon recovery efforts and disable California Fish and Game, newly elected Governor Gray Davis, with the backing of a friendly Legislature, has already made major changes to the California Department of Forestry (CDF). Davis has appointed a new CDF Director (an aquatic scientist), and will soon make several important appointments to the Board of Forestry. The Board is currently considering several new rulemaking packages intended to provide additional riparian protections for salmon.
Additionally, there are a number of pending bills in the Legislature to improve California's forest practices, protect salmon on forestlands, and help restore watersheds damaged by past forest practices. At this writing these include: (1) AB 717 (Keeley) requires CDF to address concerns raised by other natural resource agencies about proposed timber operations, and to fully assess cumulative impacts; (2) AB 748 (Keeley) sets aside more money for inter-agency timber harvest plan (THP) review, and allows either the Dept. of Fish and Game or the Water Resources Control Board to appeal inadequate THP's; (3) SB 620 (Sher) requires Board of Forestry to review and improve protections for steep and landslide prone slopes; (4) SB 621 (Sher) increases penalties for violations of approved timber harvest plans. Though it is too late for movement this session, the issues are not going to go away and it is unclear what the fate of these bills will ultimately be.
Also, a recent comprehensive independent scientific review of California's Forest Practices Act commissioned by the State Resources Agency has also found serious deficiencies in California's forestry laws, concluding that current practices are inadequate to protect salmon from extinction. ("Report of the Scientific Review Panel on California Forest Practice Rules and Salmonid Habitat," June, 1999 <http://www.ceres.ca.gov/cra/srp.html>).
Good forestry should not push species to extinction. Private property rights stop at the point they jeopardize public resources. PCFFA supports necessary and progressive steps toward a sustainable forestry that does not jeopardize salmon or destroy watersheds where salmon reside, and is working to reform the California Forest Practices Act accordingly.
Multiplying HCPs Creating Recovery Swiss Cheese: One of the most troubling current trends is the rush by nearly every large industrial forestland owner to get a special exemption from the Endangered Species Act (ESA) by way of what is called a "Habitat Conversation Plan (HCP)." Once rare, there are now well over 250 such Plans in the works and more to come.
Each HCP operates as in "incidental take permit" allowing the landowner to kill large numbers of endangered and threatened species in the short term (usually a term of 50 to 100 years), based on a promise to provide at least some additional habitat at sometime in the future. Some HCPs are pretty good, but according to a number of independent scientific studies most HCPs have very poor or even no scientific support.
Worse yet, HCPs are NOT required to contribute toward salmon recovery! An HCP merely exempts that landowner from recovery efforts, while pushing the recovery burden onto the shoulders of other adjacent landowners -- or downstream industries like fishing -- that will have to pay a high price for extinction. Each HCP is like a hole in the recovery effort swiss cheese, and with more and more HCPs being approved, pretty soon there are more holes than cheese, and species recovery becomes literally impossible.
PCFFA is pushing for stronger salmon protections in several HCPs (Headwaters Forest HCP, Oregon's Tillamook State Forests HCP and others), and its affiliate organization, the Institute for Fisheries Resources has a whole program devoted to improving HCPs so that they include better salmon protections. Through the Institute we work with many other organizations to improve HCPs generally.
Efforts to plug the HCP loophole have so far failed in Congress. Representative George Miller's ESA reauthorization bill ("The Endangered Species Recovery Act of 1999," H.R.960) would do this, and has 85 cosponsors, but so far this bill has not even been given a hearing by Resources Committee Chairman Don Young. However, a similar bill may soon be offered in the Senate where it is expected to fare better. Unfortunately, no one wants to deal with this issue in an election year, and chances for any meaningful ESA reforms in this Congress are bleak.
Even though our industry can be heavily regulated under the ESA, fishermen need a strong and effective ESA to prevent extinction and to require the recovery of salmon and other important species (see FN, January, 1995, "Why Fishermen Need the Endangered Species Act" <http://www.pcffa.org/fn-jan95.htm>). PCFFA has advocated a number of ESA reforms which would make the ESA work better for salmon recovery (see FN, December, 1995, "A Fishermen's Agenda for the Endangered Species Act," <http://www.pcffa.org/fn-dec95.htm>). We continue to push for these key reforms.
In summary, the fate of our forests and the fate of our salmon and several other fisheries are closely intertwined. Properly and carefully done, good forestry can benefit salmon and protect estuaries. However, current industrial forestry practices have done a very poor job of protecting watersheds, salmon spawning and rearing beds, or estuaries. As a result, fishermen have no choice but to become advocates for better and more sustainable forest practices in order to protect the irreplaceable public resources that support our industry.
PCFFA is the west coasts largest organization of commercial fishermen. PCFFAs Southwest Regional Office can be reached at: PO Box 29370, San Francisco, CA 94129-0370 and by phone (415)561-5080. PCFFAs Northwest Regional Office can be reached at: PO Box 11170, Eugene, OR 97440-3370 and by phone (541)689-2000. PCFFAs Internet Home Page is at <http://www.pcffa.org> or PCFFA can be reached by email at <email@example.com>.
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