HomeMy WebLinkAbout07-27-21 Public Comment - J. Meyer - BMW ProjectFrom:John Meyer
To:Agenda
Subject:Kirk Hill Old Growth Information/Comments
Date:Tuesday, July 27, 2021 10:31:20 AM
Attachments:BMW Amicus public comments.pdf
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Hello,
Please find attached a document containing information for today’s vote on whether to supportold growth logging outside of Bozeman.
Thank you.
John Meyer
Executive Director & General Counsel
Cottonwood Environmental Law Center
P.O. Box 412 Bozeman, MT 59771
John@Cottonwoodlaw.org
(406) 546-0149
Lawsuits get things done. Click here to support our legal work.
ENVIRONMENTAL LAW CENTER
Cottonwood Environmental Law Center Cottonwoodlaw.org
P.O. Box 412 Info@cottonwoodlaw.org
Bozeman, MT 59771 Phone | 406.546.0149
To: Bozeman City Commissioners
From: Cottonwood Environmental Law Center
Re: Old Growth Amicus Brief
Date: July 27, 2021
The Bozeman-based Cottonwood Environmental Law Center has filed a lawsuit
challenging the Bozeman Municipal Watershed old growth timber sale. Cottonwood
Envt’l L. Ctr v. Marten, et al., 2:20-cv-00031(BMM). On Tuesday, July 27, 2021,
Bozeman City Commissioners will be voting on whether the City should file an amicus
brief in the Ninth Circuit Court of Appeals that supports the logging of 651 acres of “old
growth” as part of the larger Bozeman Municipal Watershed (“BMW”) Project. This
document provides factual background so that the Commissioners can make an informed
decision.
All trees in the photo above that are not painted orange will be cut down as part of the Bozeman
Municipal Watershed Project. The area was once proposed to become the South Cottonwood
Wilderness Study Area by the U.S. House of Representatives.
ENVIRONMENTAL LAW CENTER
Cottonwood Environmental Law Center Cottonwoodlaw.org
P.O. Box 412 Info@cottonwoodlaw.org
Bozeman, MT 59771 Phone | 406.546.0149
Purpose for BMW Project
● The BMW project was approved “to create vegetation and fuel conditions that
will reduce the risk of excess sediment and ash resulting from a wildfire event
from reaching the municipal water treatment plant.” Record of Decision at 1.
● The BMW project was approved on November 29, 2011. Record of Decision at
61.
Factual Background
● The City of Bozeman upgraded its water treatment plant after the BMW project
was approved with the risk of large wildfires in mind.
○ In June 2020, Jill Miller, the manager of the water treatment plant, stated
she is “fairly confident in the water treatment plant’s ability to handle a
pretty good sediment load from the resulting runoff after a forest fire. The
plant was designed with a forest fire in mind[.]”
● After the BMW project was approved, Montana State University professor Cathy
Whitlock and professors from other universities published a peer-reviewed article
in the 2017 National Academy of Sciences that states logging and thinning has
“little influence on wildfire” because only 1% of logged areas experience wildfire
each year.
○ Tania Schoennagel, Adapt to more wildfire in western North American
forests as climate changes, 2017 Proceedings of the National Academy of
Sciences, 4582, 4586 (2017).
● The BMW project will log 651 acres of “old growth” forest in the Kirk Hill and
South Cottonwood areas. Record of Decision at 38.
ENVIRONMENTAL LAW CENTER
Cottonwood Environmental Law Center Cottonwoodlaw.org
P.O. Box 412 Info@cottonwoodlaw.org
Bozeman, MT 59771 Phone | 406.546.0149
● Science says old growth sequesters more carbon than new growth.
○ Harmon ME, Ferrell WK, Franklin JF. Effects on carbon storage of
conversion of old-growth forests to young forests. Science. 1990 Feb
9;247(4943):699-702. doi: 10.1126/science.247.4943.699. PMID:
17771887.
● The National Academy of Sciences article referenced above states that the trees
may not grow back after logging because of climate change/drought.
○ Tania Schoennagel, Adapt to more wildfire in western North American
forests as climate changes, 2017 Proceedings of the National Academy of
Sciences, 4582, 4587 (2017).
● Even if the Kirk Hill and South Cottonwood areas burn in a wildfire, sediment
could not reach the municipal water treatment plant because of the physical
distance involved.
● The Kirk Hill area is loved by Bozeman residents and nearly 2,500 people have
signed a petition asking the Forest Service not to log the Kirk Hill area.
○ https://www.change.org/p/mary-erickson-supervisor-custer-gallatin-
national-forest-don-t-log-kirk-hill
● According to the Record of Decision for the BMW project, the logging will leave
“highly visible” scars that will be visible from Bozeman. Record of Decision at
48.
● The Biden Administration recently announced an end to logging old growth in
Alaska to fight climate change.
Respectfully submitted this 26th day of July, 2021.
/s/ John Meyer
JOHN MEYER
Executive Director