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,
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
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
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, http://www.nau.edu/library/speccoll/exhibits/traders/trade/pinon.html
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
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
FIRE ECOLOGY and BLM POLICIES
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.
PINYON PINE And FIRE ECOLOGY
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
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
fine fuel . 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
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, www.pinenut.com 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.
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:
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. 
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:
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.
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the wood chips in the hot desert sun, in the name of fuel reduction
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