Nokio Creek culvert blowout - Flathead NF photo.
Keith Hammer has issued three Supplements to his "Roads to Ruin" and "TMRD" reports, providing documents showing logging roads must have their stream-bearing culverts removed, then the roads must be removed from the Flathead Forest Road System and revegetated before they can be omitted from calculations of Total Motorized Route Density.
The Flathead National Forest has been violating these requirements that it wrote into its 1995 Forest Plan Amendment 19 based on grizzly bear research. These requirements were intended to improve habitat for threatened bull trout and other aquatic life while securing habitat for threatened grizzly bear and other terrestrial wildlife. The Flathead intends to do away with Amendment 19 altogether in its revised Forest Plan, largely by reneging on/denying the scientific basis for what Amendment 19 requires!
Click here for the Third Supplement. It describes how Total Motorized Route Density evolved from Total Road Density, how it is based in the South Fork Grizzly Bear Study (Mace and Manley 1993), and how in Flathead Forest Plan Amendment 19 it requires that roads be decommissioned, revegetated and removed from the "system" to lower TMRD. It also shows how Mace and Manley 1993 answered the Flathead's questions about how to calculate road densities, showed that Total Road Density must be considered in addition to Open Road Density, and points to why A19 capped the total miles of road that can exist in griz habitat due to the importance of roadless areas to female griz.
Click here for the Second Supplement, which reviews Forest Service and Fish and Wildlife Service documents since 1995, confirming that Amendment 19 requires roads be decommissioned and no longer serve as a road or trail in order to not be counted in TMRD - serving as a cap on the miles of road that can exist in grizzly bear habitat. It also details how the Flathead NF has invented a new category of "impassable" roads to unlawfully substitute for road decommissioning. This leaves the roads available for both motorized and non-motorized use various parts of the year, without being counted in TMRD and hence allowing an unlimited number of such roads to exist in the habitats of threatened species like grizzly bear, lynx, bull trout, and threatened-candidate wolverine!
Click here for the First Supplement to Keith Hammer's "Roads to Ruin" and "TMRD" Reports, which details requirements that reclaimed/decommissioned roads be revegetated and no longer serve as a motorized or non-motorized trail.
Click here for the "Roads to Ruin: The Flathead National Forest Shirks its Road Reclamation Duties," which includes the TMRD report as an appendix.
Click here to read how Swan View Coalition, Friends of the Wild Swan, and WildEarth Guardians have put the Flathead on notice they will sue over its lack of adequate road and culvert management!
Below are links to SVC's comments on the Draft Revised Flathead Forest Plan, proposed grizzly bear amendments to four other NCDE Forest Plans, and their Draft Environmental Impact Statements (DEISs).
We submitted 12 letters prior to the October 3, 2016 deadline, biting off a few issues at a time. We continue to submit more letters as new information becomes available.
For more background on how and why we commented, see our Summer 2016 alert and newsletter!
Click here for our 8/15/16 letter, which provides a photo of ATV damage in Krause Basin and asks that DEIS Alternative C be applied to finally ban ATVs from the old trail system there.
Click here for our 9/7/16 letter, which asks for a refinement and combining of DEIS Alternatives A and C to follow through on past promises of grizzly bear habitat security and increased wildlife habitat connectivity through the protection of roadless lands as recommended wilderness.
Click here for our 9/8/16 letter, in which we ask that all references to grizzly bears having met Recovery Plan parameters be stricken from the EISs due to the lack of legally mandated habitat-based recovery criteria in the Recovery Plan. This letter also details a number of ways in which all 3 DEISs and the proposed revised Flathead Forest Plan will not maintain grizzly bear habitat security at 2011 levels as promised.
Click here for our 9/9/16 letter regarding budgets, products, jobs, income, and associated bias in the DEISs.
Click here for our 9/12/16 letter regarding how the DEISs lie about definitions and requirements for managing Total Motorized Route Density, reclaimed roads, decommissioned roads, and revegetation of those roads. This letter attaches our Objection to the Trail Creek Fire Salvage Project and our 2/7/16 TMRD paper, which help illustrate with photos and facts why this is a big deal for fish and wildlife.
Click here for our 9/13/16 letter regarding the inadequate range of alternatives in the DEIS, the inappropriate linkage to grizzly bear delisting, and the failure to carry forward essential unfinished programs from the current Forest Plan. Included with the letter is our "Roads to Ruin" report that helps illustrate our point.
Click here for our 9/15/16 submission attaching a letter to the Flathead Conservation District explaining how restoring Krause Basin and removing ATVs will have positive effects on downstream private landowners.
Click here for our 9/19/16 letter regarding how the DEIS and its alternatives fail to use the best available science and fail to propose revision and actions consistent with monitoring and evaluation of the current Forest Plan.
Click here for our 9/23/16 letter regarding mountain bikes and their impacts on public safety, wildlife and other forest users.
Click here for our 9/29/16 letter PDF that summarizes and includes four research papers concerning ecological traps, source-sink populations, and the genetic effects of dispersing grizzly bears.
Click here for our 9/30/16 letter as a pdf that attaches documents showing the Flathead must provided grizzly bear habitat security according to the "3 and 7 Rule" until such time as it meets fully its Amendment 19 "19/19/68" standards in each subunit.
Click here for our 10/3/16 letter following up on tidbits and the overall complexity of the planning documents.
Click here for our 11/23/16 letter finding that the DEIS does not adequately address the Pacific Northwest National Scenic Trail proposal, its impacts to grizzly bear Security Core and other wildlife habitat, nor disclose that the Forest Service and National Park Service in 1980 found this proposal to be "neither economically feasible nor desirable."
Click here for our 4/20/17 letter finding there is inadequate regulation of mountain biking and the human use of "stored" logging roads in the NCDE Grizzly Bear Ecosystem.
Our Winter-Spring 2016 newsletter releases our new report "Roads to Ruin," describes how our investigations have already helped secure more road decommissioning for bull trout in the Swan Valley, and describes how the report will help us all wrestle with the revised Flathead Forest Plan and Grizzly Bear De-Listing DEISs due out May 27!
Our "Roads to Ruin" report also describes how "collaborative" groups are being misused to promote the notion that the biggest problem in our public forests is too many trees, when research clearly shows the biggest problem is too many logging roads!
Below is our newsletter's table of contents and you can click here to view or download it as a pdf.
We hope you enjoy the newsletter and our new report - and will join others in supporting our work!
Fish, wildlife, wilderness, and people are counting on us - and you!
Your email to the Flathead National Forest will help stop more of these logging road landslides from trashing fish and wildlife habitat!
The Flathead already has 2,000 miles of roads like this one in Sullivan Creek demoted to Maintenance Level 1 Basic Custodial Care, where they don't receive the care needed to keep their ditches and culverts from plugging and then washing the roads into your trout streams!
(Another 1,400 miles are open to public motor vehicle use and have their own costly maintenance issues).
The Flathead is accepting public comments on its draft Travel Analysis Report, which would simply abandon even more old logging roads rather than carefully decommission them to remove culverts and sediment source problems.
Click here to visit the Flathead's Travel Analysis Report web page.
Click here to read our comments on the Travel Analysis Report.
Click here to read our additional comments on the Travel Analysis Report, made in light of our discovery of slumps in the Sullivan and Quintonkin Creek roads.
Click here to read the Hungry Horse News Article about our discovery of the recent Sullivan Creek landslide.
Click here to read our press release about the Sullivan Creek landslide.
Click here for our letter to state and federal agencies urging that all old logging roads in Sullivan Creek be decommissioned.
Click here to read the Flathead's "Assessment of the Sullivan Creek Mass Failure," which claims it was nature's fault.
Click here to read our response to the Flathead's "Assessment of the Sullivan Creek Mass Failure."
Click here to read the Flathead Beacon's article about the Flathead National Forest still insisting it is an innocent bystander and intends to ignore this road as it continues to collapse, rather than promptly fixing more potential problems further up the road!
Click here to see our video of the Sullivan Creek landslide.
Hammer's testimony includes links to sources indicating the Whitefish Range Partnership intended to front-load the Flathead National Forest's Forest Plan revision collaborative by being "first out of the chute." His testimony and that of F.H. Stoltze Land and Lumber's Paul McKenzie (a Partnership member) showed that the Partnership's proposal to nearly double the lands slated for logging in the Whitefish Range was indeed applied across the Forest during the Forest-wide collaborative and involves relaxing standards for the protection of threatened grizzly bear and lynx habitat.
Frances Alderson, George Alderson, Sandra Babich, Bill Baum, Roger Benson, Edd Blackler, Denise Boggs, Stephen Braun, Henry Bright, William Browne, Larry Campbell, Linda Christensen, Bob Clark, Philip Crissman, Norma DeLang, Ralph DeLang, Sheryl Eaglewoman, Paul Edwards, Larry Evans, Donald Gee, Chris Gotschalk, Reverend Joan Grant, Alan Gratch, Sallie Gratch, Bob Hammer, Kathy Hammer, Keith Hammer, Jon Heberling, Robert Hermes, Joel Holliday, Dr. Brian Horejsi, Cindie Jobe, Todd Johnson, Chris Jolly, Lloyd Jones, Jeff Juel, Steve Kelly, Darlene King, Dennis King, Matthew Koehler, Robert Korechoff, Gayle Langford, Norma Linsky, Norma Lockwood, Gary Macfarlane, Donna Marx, Thomas Marx, Pat McClelland, Dr. Riley McClelland, Eileen McGurty, Brian Mehall, Jill Mehall, Gail Metcalf, Arlene Montgomery, W.R. Montgomery, Anne Morley, Greg Morley, Bob Muth, Laurie Muth, Claudia Narcisco, Laura Negin, George Nickas, Marylin Olsen, Brian Parks, Brian Peck, Helen Pilling, Thomas Powell, Dr. Thomas M. Power, Steve Raiman, Ernie Reed, David Richmond, Kathy Richmond, Joni Schumann, Roger Sherman, Susan Sherman, Jeff Smith, Phyllis Sobczyk, Terry Sobczyk, Edward Sohl, Leslie Stoltz, Margaret Strainer, Jan Verhoef, Joel Vignere, Susan Waldron, Pam Willison, Howie Wolke, Edward Zyniecki.
Alliance for the Wild Rockies, Big Wild Advocates, Conservation Congress, Flathead-Lolo-Bitterroot Citizen Task Force, Friends of the Bitterroot, Friends of the Clearwater, Friends of the West, Friends of the Wild Swan, GOAL - Tribal Coalition to Protect the Grizzly, Jimmy St. Goddard - Blackfoot Tribe's Medicine Chief, Montana Chapter Sierra Club, Montana Ecosystems Defense Council, Rocky Mountain Blues, Swan View Coalition, Wilderness Watch, Wildlands Defense, WildWest Institute.
Big Wild Adventures, Coon Hollow Canvas, Morley Canoes, Silvertree Inc.
Swan View Coalition has issued its General Assessment and Prescriptions for Flathead Forest Plan Revision and, along with Friends of the Wild Swan, its more specific Citizen reVision of the Flathead Forest Plan.
Click here for the most current version of the Assessment and Prescriptions.
Click here for our Citizen reVision of the Flathead Forest Plan or click here for its two-page summary. The Citizen reVision includes the Wildlands Recovery Plan for the Flathead National Forest, below. Click here to see who supports the Citizen reVision.
Click here for the Annotated Bibliography of research supporting the Assessment and Prescriptions and the Citizen reVision.
Click here for a map of abundant public access to the Flathead National Forest.
Click here for our Wildlands Recovery Plan for the Flathead National Forest.
Click here for our more specific Wildlands Recovery Plan for the Northern Swan Range.
Click here to view damage done to the Swan Range by snowmobiles and ATVs, as exhibits to our prior comments on the 2006 Draft Revised Flathead Forest Plan.
Click here to read our letter to the Flathead Forest Supervisor outlining serious concerns with the contracting of Meridian Institute for $285,000 to help conduct Forest Plan revision meetings, but without requiring accurate records and without the Flathead firstly completing its requisite Assessment of the Management Situation.
Click here for our guidance on Recreation Quality in Flathead Forest Plan Revision.
Click here for our comments on Flathead National Forest's draft Wilderness Suitability Inventory.
Click here for our case study showing areas burned by wildfire should be considered suitable for Wilderness designation because prior logging is no longer "substantially noticeable."
Click here for our comments on Flathead National Forest's final Wilderness Suitability Inventory and its Evaluation of those areas for potential recommendations as Wilderness in the Revised Forest Plan. Our comments include 63 great photographs highlighting the wilderness values of the Swan Crest, so it's worth the moment it takes to download the nearly 18 MB pdf!
Click here to read the Flathead and Montana Snowmobile Associations' objections to Flathead Forest Plan Amendment 24 and their withdrawal from the settlement agreement of Montana Wilderness Association's lawsuit.
Click here to read Flathead National Forest's clarification that Montana Wilderness Association did not agree to Amendment 24 allowing snowmobiling in grizzly bear denning habitat as late as May 31, when females with cubs remain near their snowbound winter den sites, rather than cease snowmobiling at den emergence March 15 or April 1 as prior to Amendment 24.
This page lists a number of .kml files for use with Google Earth.
They are compressed into .zip files so your browser will automatically download them to your computer.
They may download in a flash and your browser may display a blank page to indicate it has happened.
If your computer does not automatically decompress the .zip file to a .kml file, you may need to use Stuffit Expander or a similar decompression application on it.
Once you locate the .kml file on your computer, double-clicking on it should automatically start up Google Earth and display the .kml map overlay - be it a point, line or polygon/area, with the file placed and selected in your Temporary Places folder.
If you don't have Google Earth installed on your computer, it is free here.
Here's the list of .kml files:
Click here for our Flathead National Forest Wildlands Recovery Areas.kml
Click here for just our Northern Swan Wildlands Recovery Area.kml (The Northern Swan kml is already included in the above Flathead National Forest-wide kml).
Click here for Quintonkin - Sullivan Example.kml (referenced on page 8 of our Wildlands Recovery Plan for the Northern Swan Range).
Click here for our Roadless Areas Omitted from Flathead NF IRAs.kml. This map layer should be viewed in conjunction with the Inventoried Roadless Areas kmz/kml file available on the Flathead National Forest's Geospatial Data Page.
Click here for the place marks that are companion to our comments on Flathead National Forest's draft Wilderness Suitability Inventory.
Click here for our Sullivan Wildfire example of how wildfire renders logging units no longer "substantially noticeable" when identifying lands suitable for Wilderness designation.
Click here for the Flathead National Forest's Fire History Map 1980-2013.