page 3 The dead, mature, or large requirement has two primary effects on vegetative management and associated wildlife. First, a young forest needs to be cared for as it grows. This means thinning is essential to promote growth and vigor of the stand. Such thinning is also beneficial to many forms of wildlife, since it opens the stand to allow sunlight to reach the forest floor and promotes growth of wildlife food. Under the court's interpretation of the 1897 Act, throughout the life of the stand immature trees cannot be removed by sale. This means that commercial thinning and intermediate cuts cannot be made to improve the growth and vigor or species composition of the stand, or to open it up to improve browse and forage conditions or favor other resource uses. These limitations on vegetation management affect all the resource values in a complex and interrelated manner. Second, in the removal of sawtimber from the Forest, the definition of physiological maturity of "individual trees" occurs at a significantly later time than our current practice of determining maturity which is dependent on when growth of the "stand" as a whole has slowed materially (culmination of mean annual increment for the stand). We estimate that harvest ages, under the court's interpretation, will have to be established at ages about three to four times those currently envisioned. This will mean that the forest ultimately will consist of substantially larger and older trees than envisioned under current land and resource management plans. Although clearcutting or other even-aged silviculture treatments can continue in such mature stands, the long rotations will create a need to minimize reforestation investments, thus, a shift to shelterwood cutting will take place in many forest types. Over the long-term increasing rotation lengths will result in reducing the annual area of regeneration cutting in stands managed on an even-aged basis. Ultimately the entire area will be harvested but over a longer period of time. Timber Resource Based on the constraints on the type of trees that can be harvested under the court's interpretation we estimate that volumes of timber which can be harvested from the predominately immature eastern National Forests in the next few decades will be only 10 percent of current harvest levels. In the mature forests of the West, we estimate that harvest levels will be reduced to about 50 percent of current harvest levels. In addition, because of the increase in harvest age and inability to harvest immature trees, a buildup in the forest of dead material is likely to occur making the protection of the forest from wildfires and insect and disease attack more difficult and more costly. This difficulty or lack of protection would have a direct effect on the timber resource and a related effect on the other resources. These estimates of reduced timber harvest are based on the application of the court's interpretation to new sales and do not assume a requirement to revise sales presently under contract. If present contracts had to be revised, it would almost completely stop harvest from the National Forest System until contracts were revised or new sales developed, and the Government would face tre possibility of major lawsuits pased on breach of contract arguments. page 4 Wildlife and Fish Resource The effects of the court's interpretation on wildlife in the next several decades would be quite prominent. The reduction in the volume of timber harvested from the National Forests and related shift in cutting systems would result in a major decrease in wildlife numbers for those species that are dependent upon forest openings and early stages of forest succession, such as the white-tailed deer, quail, and many song birds. The change would enhance species dependent upon mature stands of trees, such as squirrels. The major loss in wildlife management terms would be the loss in flexibility to prescribe the management system most appropriate for a given area to meet the needs of specific wildlife species. We do not anticipate a significant impact on the fishery resource as a result of the court's interpretation. Range Resource The court's interpretation would affect the range resource because timber stand improvement and harvest activities, which would be restricted, normally contribute to increases in forage production. The opportunities to increase grazing on forested ranges in the East as part of the recommended Renewable Resource Program would be largely lost. Recreation Resource The quantity of recreation opportunities under the court's interpretation are not expected to change from current projected levels. The quality of the various forms of recreation experience could change depending on whether the roading system or frequency of its use changed. Some short term gain in esthetics would result, but visual diversity would be reduced. Effects on wildlife would affect recreational viewing and hunting. Designated wilderness would not be directly affected by the court's interpretation, except as the interpretation affects the protection of the adjacent lands from fire, insects, and diseases. The competition between the wilderness resource and the timber resource on undeveloped lands would likely increase because of the demand for wood products. Land and Water Resources The primary effect on the land and water resources would be the loss of flexibility to manage the vegetative cover to meet specified land or water objectives. As previously indicated, wildfire and insect and disease protection would be more difficult. We have assumed that a similar ultimate road system would be needed under either present programs or under the court's interpretation. We have not discussed all the effects of the court's interpretation on the various resources. It is clear that a constraint on one aspect of vegetative management has related affects on all other aspects. page 5 In addition to the direct impacts of the court's interpretation on the National Forest System land management opportunities, there are major secondary effects on the cost of National Forest System administration, on private lands, and on prices. Cost of Administration Per Unit Output Although the volume of timber harvested annually from the National Forest System would decrease to 50 percent, we estimate that the total cost of administration would remain about the same, thus cost per unit doubles. This increase in unit cost results from the requirement for a similar road system under both the present management approach and the court's interpretation. More acres of land would be involved to produce the same volume of timber. Brush disposal would be more expensive, and the requirement to individually mark all trees would increase costs. In addition to an estimated doubling of cost per unit output, the cost of protection of the forest from wildfire and insects and diseases would increase. Effects on Private Lands With the estimated 50-percent reduction in timber supply from the National Forests, private nonindustrial forest lands would have to be the primary domestic source for filling this gap to meet timber demands. It is difficult to predict accurately the size and location of this shift. Regional variations in forest land ownership patterns would influence the ability of forest industries to purchase timber from private lands. For example, only 23 percent of commerical forest land in the Pacific Coast States is in private nonindustrial forest ownership. Nationwide, 59 percent is in this class. Shifts to privately-owned timber would also be governed by forest industry purchases from nondomestic sources, particularly Canadian. It is expected that forest industry relocation from the West to the South would accelerate beyond that currently taking place. The southern forests, comprised primarily of nonindustrial ownerships, would provide an increasing share of the Nation's wood demand. A substantial increase in timber prices would likely occur in association with this shift to private lands. The magnitude of this increase is difficult to predict. Price would probably rise rapidly and then drop somewhat as supply and demand balanced. Price increases would lead directly to increased harvesting on private nonindustrial forest lands. Cutting of mature stands on private lands would be accelerated and early cutting of young, rapidly growing stands probably would also be accelerated to some extent. Although the higher prices for private timber would result in some increased investment in timber production, it is not known whether such response would be sufficient to increase the growth enough to offset the accelerated harvest and avoid excessive liquidation of current inventories. It is unlikely to be sufficient to do so, since we do know that many nonindustrial private landowners have limited ability and willingness to invest in regeneration of harvested wosciands due to a lack of resources and an unwillingness to wait out the long timber production period for returns on their investment. page 6 We are concerned that a large part of the accelerated harvest would take place without the benefit of technical assistance, from either public or private sources. Recent research in the South has shown that nearly three-fifths of the desirable pine forests on nonindustrial forest lands have not been adequately regenerated following harvesting and are converting to lower grade species. Impacts on the Economy On a nationwide basis, National Forests are most important as a source of softwood sawtimber, the raw material base for softwood lumber and plywood. Forest Service lands currently account for nearly one quarter of the softwood sawtimber harvest and contain about 50 percent of the Nation's inventory of this raw material. A reduction in softwood timber output from National Forests will be quickly felt in the Nation's softwood sawlog markets. At current production levels, a 30 percent reduction in harvest from the National Forests would immediately result in about a 6 percent reduction in national softwood sawtimber supply. A 50 percent reduction would result in about a 10 percent immediate reduction in total supply. In a relatively short time, we estimate that supplies from other sources would rise and offset about half the initial reduction in national supplies. A reduction in the amount of timber products offered to consumers would quickly result in increased prices. A number of studies and historical experience indicate that market prices of the major timber products are quite responsive to changes in quantities supplied to the market. Our preliminary estimate indicates that a 50 percent reduction in available Forest Service softwood timber would result in more than a 15 percent increase in wholesale lumber prices and a larger increase in wholesale plywood prices for the period 1980-1990. The immediate impact on lumber and plywood prices could even exceed the above projections. The impact of a shortage in supply would be particularly critical if it occurred at a time when the housing market was expanding. In addition to these national impacts, a major reduction in the supply of softwood sawtimber from the National Forests would have a severe impact on certain local economies. Many areas in the West are dependent on the National Forests for a major part of their supply of raw material. A loss or major reduction in supply would likely force certain mills out of business with accompanying impacts on employment and community stability. Although National Forests supply less than 5 percent of the total hardwood sawtimber, a loss or major reduction in supply would also have a severe impact on local dependent industries and the related communities. To the extent that the reduction in National Forest harvest leads to substitution by imports or by materials with less labor-intensive production processes, there would be a reduction in employment opportunities which would add to the current nacioral long-term unemployment problem. U.S. Department of Agriculture Supplemental Statement Summary Analysis of the Impacts of H.R. 11894 H.R. 11894 would impose major limitations on the multiple use management of the National Forest System. Although its stated purpose is to provide for sound forest management practices consistent with the principles of multiple use and sustained yield, it in fact provides serious constraints on multiple use forestry by requiring specific management prescriptions for certain areas of the country and particular species and resources. The constraints will so limit the flexibility of the land managers as to seriously reduce the capacity of the National Forest System to provide sufficient goods and services to meet national needs, and will prevent a national perspective for management. The processes set forth in the Forest and Rangeland Renewable Resources Planning Act of 1974 would be severely restricted or negated. A number of the limitations imposed by H.R. 11894 such as those pertaining to pesticides, soil resources, and fish and wildlife, would apply to the entire National Forest System. Other limitations would apply only to areas where timber management would be practiced (commercial forest land). Limitations here, reduce the capacity of those lands to provide multiple uses and benefits by restricting the sale of forest products which is presently a principal tool for vegetative management to provide multiple resource benefits. These restrictions take two forms: Reducing the land available for timber management (commercial Limitations on management practices. In addition to the major impact on other resources, there is an estimated In section 3, the definitions either differ from the nationally accepted |