To: State Board of Forestry, 8/6/03

CLEARCUT ADJACENCY RULE (913.1; 33.1; 53.1)

With the existing rule, there is a colloquial saying, "4 makes 3 go away," that is: 913. 4 makes 913.3 inoperable.

The effect of that is that a clearcut unit may be butted up against another as soon as the trees in the first unit are five feet tall OR five years old.

And the effect of THAT (including other provisions of that rule re separation etc.,) is that hill slopes above rivers and creeks may be peppered with blocks, with trees anywhere from zero to five years old . Trees moderate air flow and air temperature--but not much when five feet tall, or smaller, and none when clearcut.

Science now tells us that AIR temperature is the single most influential element governing WATER temperature. We cannot influence sun spots and major climate events and conditions, so it behooves us to work doubly hard at controlling those elements over which we do have control.

So I am proposing a rule that would substitute 25 years for 5 years of age for the trees in the clearcut blocks, and 25 feet for 5 feet tall, before a unit within 300 feet in any direction may be harvested using the clearcut or other even-aged regeneration method.

In addition to cooling air temperature, so vital for amphibians and the water temperature for threatened and endangered fish, this rule would reduce erosion and slow down habitat loss. See accompanying scientific literature.

Helen Libeu