The Houston Regional Group and the Lone Star Chapter of the Sierra Club (Sierra Club) commented and objected about a U.S. Forest Service (FS) proposal to salvage log 2,540 acres of Hurricane Ike damaged trees in Compartments 6, 12, 18, 19, 22, 23, 26, 27, 35, 36, 39, 50, and 51 in Sam Houston National Forest (SHNF) as authorized under the Healthy Forests Restoration Act (HFRA).

Usually, the FS operates under an internal administrative appeal process for proposed projects like salvage logging.  However, under the HFRA (as supported and approved by the Bush Administration in 2003) the appeal process was deleted and a weaker objection process was put in its place.  One purpose of the HFRA was to streamline the public input process so logging projects could be conducted more quickly.  The Hurricane Ike salvage logging proposal is the first project that the Sierra Club has commented on and objected to under the HFRA.

Some of the objections that the Sierra Club raised include:

1) The lack of standards for leaving dead downed trees (called by scientists, coarse woody debris) and standing trees (snags) in the 2,540 acres proposed to be logged.  Dead downed and standing trees are very important for the health of the forest.  These "ecological residuals" serve many purposes including nutrient and organic enrichment of soil, water retention, wildlife habitat shelter and food, and soil erosion check dams.

2) The failure to analyze, assess, and evaluate the true risk of fire that the FS says exists if the dead downed and standing trees are not logged.  The Sierra Club calculated from information provided by the FS, for the 10 year period from 1998-2007, in the 13 compartments proposed for salvage logging, that a total of 7 wildfires burned 8.6 acres.  These 7 wildfires resulted in an average of 0.7 wildfires/year for the 13 compartments and a burned acreage average of 0.86 acres/year over the 10 year period.  The Sierra Club view is that the risk of wildfire is low in the area proposed for salvage logging.

3)  The Lone Star Hiking Trail (LSHT) will be impacted by the proposed salvage logging.  The FS tries to minimize these impacts by using phrases like 'skirts the edge' and "meanders through" the "tree removal area".  The FS states that the LSHT will not be affected by the salvage logging.  The Sierra Club disagrees with the FS assessment since areas that will be salvage logged will occur on or near the LSHT in Compartments 6, 12, and 27 and the impacts of the logging will be very visible.

The Sierra Club will meet with the FS about our objection letter in an attempt to resolve some or all of our objections.

January 2009

Last updated:  12/25/2008.   Content © 1999-2008 by the Sierra Club.