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Battling over the Battle Mountain

More Information Regarding Public Lands and Pine Nuts

Battle Mountain BLM
Battle Mountain Field Office
50 Bastian Road
Battle Mountain, NV 89820

Dear Battle Mountain BLM,

August 15, 2003

Subject: Fuels reduction   

    I work with pinyon pine nuts harvested in Nevada, species p.monophylla. My comments focus upon the BLM’s repeated failure to manage and plan for a significant resource, the pinyon pine nut.   It is most interesting, the the Battle Mountain field area has pulled the pine nut units from the Harvest Areas for the 2003 auction.  I am concerned that this is an attempt by the Battle Mountain District to avoid it responsibility of multiple use and sustainable yield in order to further the grazing industry, by destroying the opportunity for pine nut harvest in the region.

    Additionally, I wish to provide new information, which must be considered in the course of your planning. In particular, of the changing conditions in the Southwestern United States of pinyon forests. Because the Nevada pinyon ranges are sub-parts of larger ecosystems, it is important to examine and plan, based upon larger regional conditions and circumstances.
      There has been no harvest of species p.edulis pine nuts for the last FOUR  years. The Arizona, New Mexico and Colorado wild life species are in crises as a result of drought which has destroyed their food chain. The primary reason for the edulis crash is the drought, which is especially bad in the edulis forests. The lack of water has made the trees susceptible to insect infestation, which is destroying huge tracts of forest.

    The pinon pine nut is an indicator of forest health. One must examine the history of the pinon nut in the Southwest, to understand the importance of what the nuts are indicating. Prior to World War II, the edulis pinon harvest was up to 8 million pounds yearly. Please see,
     The Southwestern drought has put entire pinyon forest systems into jeopardy. In Arizona the pinyon forest already stressed by record-low rainfall, has been infested by a beetle wiping out sections of trees at a time. (2) "We're talking statewide. How are we going to treat the whole state," said Joel McMillin, a U.S. Forest Service entomologist, noting that the bark beetle has spread to a landscape level." "There is nothing that's going on nationwide that would be covering any kind of a problematic assessment within forest plans." "It's got a stranglehold east of Walnut Canyon," Manthei said, noting the 100,000 dead pinyon-juniper in the transitional forest area. 1.3 million trees have been ravaged in the Coconino National Forest alone, in an area ranging from Twin Arrows to Blue Ridge. (3) A pinyon pine group of 700,000 trees between Winona and Twin Arrows has fallen to the bark beetle, and the rim country alone has suffered losses as high as 500,000 acres.
     These pinyon trees and their nuts, will not be replaced for 50 years, or 150 years in the case of p. monophylla. Therefore, the resource management plans need to be amended according.
     The relationship between pinyon nuts and migratory birds is well documented in Avian Impacts on Pinyon-Juniper Woodlands, Russel P. Balada. Pinyon- Juniper Conference, 1984 p. 525. Collectively 70 species are known to breed in these woodlands. The larger the pinyon seed available, the better health one sees in these bird communities. No aspect of the relationship between pine nuts and forest animals has been considered in this plan. P.monophylla nuts are becoming very important to the entire southwestern ecosystem. These migratory birds are going to rely upon the areas of pinyon forest with nut producing trees, as do deer.
At this time, it is impossible to predict what numbers and types of wild life species may be migrating into Nevada, where there are pine nuts. While black bears are not currently included as inhabitants of this eco-system, I offer the following information as an example of the importance of indigenous nuts to animal populations. The natural diet of bears is 90 percent made up of nutritious plants - especially nuts, berries and grasses. Early-season frosts followed by the drought all but wiped out the bears' traditional diet. Those that didn’t build up enough fat face starvation in their dens. Underweight females may end their pregnancies by reabsorbing their fetuses into their bodies or bear cubs too weak to survive. 1 We personally provided 1,000 lb. of p.monophylla pine nuts, for wild life rehabilitation centers, and research protects involving wildlife, which would normally utilize p.edulis.
      One indication of bears in search of food is human/bear encounters. Complaints about nuisance bears have soared by 7,000 percent in northern Nevada in the last 12 years.(4) In as much as a bear can travel 40 miles a day in search of food, it is not beyond reason, that some of these starving animals might end up in this region, looking for food.
      I am offering the new information about the edulis harvest, together with realization that no problematic assessment address the larger issue of overall health of all pinyon species. This plan fails even to address, even in the simplest terms, the issue of pine nut production. Additionally, the Nevada nuts are currently replacing the HUGE commercial market left void as the result of the p.edulis crises. In those traditional p.edulis markets, the whole sale price of p.monophylla went as high as $8.00 per pound. It is imperative that the resource management plans be revised to reflect the significance of the pinyon pine nut. Goods From The Woods, only marginally tapped into the market this year. Had we been aware of the huge demand for the nuts, we would have tripled our orders and sales. We discovered in October that there are hundreds of roadside venders who make a livelihood from the sale of pinyon pine nuts. The monophylla nut, was very successfully introduced as a substitute for the edulis. Thus, the economic impact of the woodland forest product plans must be revisited to include this new information. The fire plan would then need to be revised according.

     It is well understood by Fire Professionals that the amount of "green moisture" in any given area is the indicator of how susceptible the area is to fire. Dead vegetation, such as grasses, and certain invasive weeds, such as cheat grass(Bromus tectorum) are extremely combustible, and represent the primary source of catastrophic fire.  Yet the BLM continues to develop land use plans, which destroy the primary green vegitation in the region, the pinyon pine trees.
Thes BLM land use plans repeated fail as a matter of law.  Pursuant to the Federal Land Policy and Management Act of 1976 (FLPMA), 43 U.S.C. secs. 1701-1784, the Ely BLM must manage its lands under principles of multiple use and sustained yield in accordance with land use plans developed by the agency. 43 U.S.C. secs. 1701(a)(7), 1732(a). BLM has failed to inventory all of its lands and develop land use plans, that among other things: reflect the principles of multiple use and sustained yield; take a multidisciplinary approach involving physical, biological, economical, and other sciences; consider present and future uses; 43 U.S.C. sec. 1712(c).
    I have been bringing these issues to the table for the last 4 years and NEVER received so much as an acknowledgement of the correspondence., let alone a serious dialogue about the issues.
Singleleaf pinyon (Pinus monophylla), also called pinyon is a slow-growing, that grows on dry, low mountain slopes of the Great Basin.5
         Singleleaf pinyon is one of the slowest growing conifers. It usually requires about 60 years to attain a height of 2 m (6.6 ft). 5 Generally, singleleaf pinyon trees do not begin bearing cones before they are 35 years old and do not begin producing good seed crops earlier than 100 years. Pinyon depends upon a standing crop of seedlings for species perpetuation. Seedlings require a nurse crop; thus, most seedlings are found under shrubs in mid succession and under the tree crown in late succession.5
Singleleaf  pinyon trees more than 300 years old are fairly common on poor sites but rare on good sites. It appears that all the better sites were either burned in the past 300 years or have been cut over in the past century or so.5
The poorer sites are virtually fireproof because their sparse vegetation will not carry fire, and these sites were not cut because of the small size and poor form of their trees. 5
Singleleaf pinyon communities does not carry fire well, and fire return intervals of several hundred years are considered typical [6,7]. For example, singleleaf pinyon communities in the San Bernardino Mountains have experienced long-interval stand-replacement fires both before and during suppression with an estimated fire interval of 450 years, resulting in a mosaic of small scattered patches within uniform old-growth stands across the landscape [8,9]
Burning in pinyon-juniper woodlands requires at least 600 to 700 lb/acre of
fine fuel [8]. In the absence of fire and the presence of grazing, tree densities have increased and undergrowth is so sparse in many areas that surface fuels do not support fire [9,10,11,12,14]
. Susceptibility to fire depends on the stage of development of the pinyon stand. In young stands, enough shrubby and herbaceous vegetation often exists to carry fire over extensive areas. As the stand develops, understory vegetation becomes too sparse to carry fire, and the trees generally are too widely spaced to carry a crown fire except with the aid of extremely high winds (5). Thus, fire is ordinarily confined to younger stands and to a few individual lightning-struck trees in older stands.
In short, fire suppression efforts over the period of 30 -40 years have had a minimal impact on the pinyon forests. However, massive vegetation conversion projects, prescribed burning, rangeland improvement projects have radically altered the region, as grassland development for cattle grazing has been the primary focus of land managers in the Western United States and the Nevada District as a whole. The fine fuel load of grasses, in particularly cheatgrass is the true cause of the catastrophic wild fire problem in Nevada.
While the plan addresses cheat grass as a primary fire culprit, the vast amount of action, in terms of treatment is on other species of plants. In short, the plan correctly points out the problem, but rather than address the problem, it goes about its decades old cut the trees and make more range solutions. In short, this plan does next to nothing to correct the catastrophic circumstances creating the flash fuel loads. In fact the plan erroneously states that "live biomass" represents high fuel loads and greater risk of large fires. I will gladly provide citations on fuel loads and moisture content of live vegetation, in comparison to fine flash fuels, such as cheatgrass.
Looking back into 2001 to fires in the Elko area, the Buffalo Complex fires consisted of the Buffalo Fire and Hot Lake Fire, both located about two miles south of Midas, Nevada. These fires covered 93,092 acres, yet this plan states, "fire history is minimal" p2-24, A1 Urban Interface. That, like most large Nevada fires was a grassland fire:
"At first, firefighters weren't sure what there was to save, as they traveled through parched range land and alongside the treeless Snowstorm Mountains and over drying creeks. This wasn't at all like the tall timber fires of the Pacific Northwest, where flames leap across trees and shoot 100 feet into the air. Here they saw fire sweeping across a desert floor that from a distance didn't even appear flammable." (LA Times 8/17/01)
Eight-hundred firefighters received military assistance in battling this fire at a cost of cost $1.7 Million. Similarly, the Spaulding fire was located thirty miles southwest of Winnemucca, Nevada, near the Clear Creek Fire occurred the same year. The Spaulding Fire burned through desert country with cheat grass, sagebrush and juniper. Small patches of forest, about 12% of the area inside the fire perimeter of 75,137 acres burned at higher elevations. Why treat trees (live biomass), when it is flash fuel which is the source of the problem?
I began correspondence with the Nevada BLM about my concerns in August of 2000 about the number of forested public lands which have been deforested as the result of fuel reduction, maintenance, bush clearing and other treatment methods which favor grazing over sustainable forestry for these public lands. In particular the lack of consideration for the mature pinon pine trees, both from the commercial harvest and the obligatory species perspectives.
There exists only the most minimal research on p.monophylla seed production, harvest levels, and mature nut producing pinyon tree stands. The entire Nevada BLM has repeatedly failed to consider the economic value of pinon pine nuts in its resource planning. This country imports between 5 and 8 million pounds yearly. It is a huge industry. Yet, the BLM is failing in every aspect to manage the resource. The management efforts have been to date concentrated upon the cattle industry. The amount of destruction to our public lands, by cattle grazing, is phenomenal. These practices are leading to a legacy of desertification of forested lands. All the while, the Nevada BLM has ignored a food source that is 28 times more efficient in terms of land use and protein produced. The lack of care of the pinyon trees as a resource amounts to supreme negligence and waste (in legal context).
     Very little is done to monitor harvest levels, and only a small percentage of harvested nuts are reported to the BLM. There has been a contrived effort to ignore the pinon pine nut as a resource and I have found my company thwarted in participation in land planning involvement, time and again. Please see my web site, for a list of correspondence, which to date remains unaddressed.

    First and foremost, the BLM must produce a record of the treatments it has implamented on these lands over the last 40 years.  Only when we begin to examine what has been done to the land, can we begin a serious discussion about the causes of the problems and the way to restore and preserve these public lands for future generations.

Should you wish copies of the cited materials, please let me know. Thank you for the opportunity to respond to this plan.

Thank you.
Penny Frazier
1.US News, Science and Technology, August 18, 2002 Left high and dry
2.Arizona Daily Sun, MICHAEL MARIZCO, Staff Reporter 08/12/2002
3. Arizona Daily Sun, MICHAEL MARIZCO, Sun Staff Reporter 11/12/2002
4. Las Vegas, Sun June 22, 2002
5. Meeuwig, R. O.; Budy, J. D.; Everett, R. L. 1990. Pinus monophylla Torr. & Frem. singleleaf pinyon. In: Burns, Russell M.; Honkala, Barbara H., technical coordinators. Silvics of North America. Volume 1. Conifers. Agric. Handb. 654. Washington, DC: U.S. Department of Agriculture, Forest Service: 380-384.
6.Stephenson, John R.; Calcarone, Gena M. 1999. Mountain and foothills ecosystems: habitat and species conservation issues. In: Stephenson, John R.; Calcarone, Gena M. Southern California mountains and foothills assessment. Gen. Tech. Rep. PSW-GTR-172. Albany, CA: U.S. Department of Agriculature, Forest Service, Pacific Southwest Research Station: 15-60. [35514]
7 Wangler, Michael J.; Minnich, Richard A. 1996. Fire and succession in pinyon-juniper woodlands of the San Bernadino Mountains, California. Madrono. 43(4): 493-514.
8.Evans, Raymond A. 1988. Management of pinyon-juniper woodlands. Gen. Tech. Rep. INT-249. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Research Station. 34 p.
9 Burwell, Trevor. 1998. Successional patterns of the lower montane treeline, eastern California. Madrono. 45(1): 12-16.
10 Ernst, Reg; Pieper, Rex D. 1996. Changes in pinon-juniper vegetation: a brief history. Rangelands. 18(1): 14-16
11 Gruell, George E. 1999. Historical and modern roles of fire in pinyon-juniper. In: Monsen, Stephen B.; Stevens, Richard, compilers. Proceedings: ecology and management of pinyon-juniper communities within the Interior West: Sustaining and restoring a diverse ecosystem; 1997 September 15-18; Provo, UT. Proc. RMRS-P-9. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station: 24-28.
12.McCune, Bruce. 1988. Ecological diversity in North American pines. American Journal of Botany. 75(3): 353-368
13. Vogl, Richard J. 1968. Fire adaptations of some southern California plants. In: Proceedings, California Tall Timbers fire ecology conference; 1967 November 9-10; Hoberg, California. No. 7. Tallahassee, FL: Tall Timbers Research Station: 79-109
The beginning of my record of correspondence with the BLM

This is one letter documenting the lack of correspondence over pine nut  issues raised over the years, and the lack of response.
More information to the BLM about pine nuts
Legal Action regarding a plan to chip 30,000 acres of pinyon and leave the wood chips in the hot desert sun, in the name of fuel reduction
What people should know about Western Wildfire - life cycle of pinon pine nut producing tree
radionuclides and pine nuts
Here is the scoop on pine nut nutrician

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