HomeMy WebLinkAbout3.04 Correspondence - James Beckwith 09.17.2002JAMES A. BECKWITH
Attorney and Counselor at Law
7910 Ralston Rd., Suite 7
Arvada, CO 80002
303-431-9966 // FAX 303-431-2803 / E -Mail Ithamer@aol.com
September 17, 2002
Mr. Mark Bean, Director
Garfield County Planning Department
Garfield County Annex
Glenwood Springs, CO 81601
RE: Application:
Existing Permit:
Applicants:
Zone District:
Dear Mr. Bean:
Amend Special Use Permit
Res. 97-70 / Timber Harvest
Norman A. Carpenter
Intermountain Resources, LLC
R/L (Resource/Lands); Extraction
Enclosed please find an original and eight (8) copies of the Application for Special Use
Permit. As your are aware, the Applicants currently hold and operate a Special Use Permit for
Timber Harvesting in Tepee Park, located south ofRifle, Colorado. The SUP was issued on October
October 29, 2001, and is based upon Resolution 97-70, rendered on August 4, 1997.
Pursuant to your form application, we provide the following data:
A. Applicants / Name and Address:
Mr. Norman A. Carpenter
Tepee Park Ranch
12403 Nacogdoches, Suite 110
San Antonio, TX 78217
210-599-7926
Mr. Christopher C. Meyers, Manager
Intermountain Resources, LLC
P.O. Box 670
Montrose, CO 81402
970-249-0812
Mr. Carpenter is the owner of the real property known as "Tepee Park". Intermountain
Resources, LLC is the logging entity conducting the timber harvest under contract with Mr.
Carpenter..
Mr. Mark Bean / Garfield County Planning
September 17, 2002
Page Two.
B. Applicants' Representative:
Mr. James A. Beckwith
Attorney at Law
7910 Ralston Rd., Suite 7
Arvada, CO 80002
Telephone, FAX and E-mail in Letterhead
C. Legal Description / Copy of Deed
These are currently on file with your office under the Existing SUP and Resolution 97-70.
D. Scope of Application (Limited):
Mr. Carpenter and Intermountain Resources ("Carpenter/IMR") currently hold and operate
a Special Use Permit / Extraction from Garfield County. This was authorized by Res. 97-70 (August
4, 1997) and issued on October 29, 2001. [The ensuring 4 years involved resolution of the required
right-of-way litigation in Intermountain Resources, Et Al. v. Katharine Honea, Et Al. USDC/
Colorado / Case No. 00 PC 1243]
Pursuant to directive of the Garfield Board of County Commissioners (August 5, 2002),
Carpenter/IMR must seek approval of any major changes in their operations, as originally described
in the Official Forest Management Plan (OFMP) dated April, 1996. Such changes have become
necessary. Attached is the Applicants ' Statement of Requested Amendments. There are three groups
of amendments to the existing SUP: (1) Amendments for Accuracy; (2) Amendments for Operating
Convenience; and, (3) Amendments to Operations, concerning adjustments to yarding areas and new
roads to be constructed.
The Garfield County Land Use Code (April, 2002), however, does not provide for the
amendment of an SUP. Therefore, this application is submitted only for approval of the specific
amendments described in the attached Statement.. Except for those amendments, Carpenter/IMR are
not seeking any other revisions of the Existing Special Use Permit. Carpenter/IMR reserve the right
to object to any public hearings relating to the origial issuance, terms and conditions of the Existing
SUP.
E. Maps
All maps contained in the Statement of Requested Amendments are taken from USGS
topographical maps. An Assessor's ownership map is appended to this letter.
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Mr. Mark Bean / Garfield County Planning
September 17, 2002
Page Three
F.
Adjacent Property Owners: The U.S. Government is the sole owner of lands lying within
200 ft. of the boundaries of Tepee Park. There are two federal agencies involved:
Rifle Ranger District
U.S. Forest Service
94 County Road 244
Rifle, CO 81650
970-625-2371
Bureau of Land Management
U.S. Department of Interior
USHwy6&24
Glenwood Springs, CO 81602
970-945-2341
G. Impact Statement
Sec. 5.03: Land Use Code (Conditional and Special Uses)
In accordance with this section, the Applicants state as follows:
•
Utilities: Utility installations are not required since there are neither residences nor
commercial structures on the property which require such utility installations.
Street Improvements: All improvements to Garfield County Road 317, and USFS Road
824 (including the public right-of-way across Katharine Honea's property) were completed,
inspected and approved by Garfield County Road & Bridge, and U.S. Forest Service / Rifle
Ranger District by October, 2001. All such improvements were in accordance with Res. 97-
70 (GCR 317) and U.S. Forest Service Easement and Construction Stipulation (USFS Road
824 / "VonDette Raod") by Garfield Road & Bridge in accordance with the requirements
stated in Res. 97-70.
Mitigation of Impacts: The requested amendments (operations) involve the same activities
and impacts on neighboring properties as discussed in the OFMP and Res. 97-70. Res. 97-70
and the OFMP were issued and approved by Garfield BOCC to mitigate or avoid impacts
upon neighboring properties. The requested amendments do not alter the conditions set forth
in Res. 97-70 or the OFMP. The mitigation activities are on-going.
Sec. 5.03.07: Land Use Code (Industrial Operations)
In accordance with this section, the Applicants incorporate the statements in the OFMP
relating to yarding, slash and other harvesting operations. In addition, the Applicants state as follows:
Water Usage: The timber harvest operation does not use groundwater nor does it impound
surface water (creeks) or surface water drainage.
Mr. Mark Bean / Garfield County Planning
September 17, 2002
Page Four
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Impacts on Adjacent Land: The mitigation activites are set forth in the OFMP, and in the
conditions contained in Res. 97-70. Applicants are in compliance with these conditions, and
that compliance remains on-going.
Truck/Auto Traffic: Res. 97-70 specify the hours of log hauling, the routes for log hauling,
the hours of timbering activity, and the means of personnel transport to/from the logging sites.
Applicants are in compliance with these conditions, and such compliance remains on-going.
Distance From Abutting Properties: The only abutting property to Tepee Park is the White
River National Forest. Applicants hold a Special Use Permit from US Forest Service for their
activities, and are in compliance with the terms and conditions of the USFS Permit. There are
neither residential nor commercial structures abutting Tepee Park.
• Mitigation Measures: These are set forth in the OFMP and the additional conditions
imposed by Res. 97-70. These documents are currently on file with Garfield County
Planning.
Attached hereto is the Applicant's check, in the sum of $400.00 payable to Garfield County
Planning, covering the requisite application fee. Request is made for scheduling of this matter for
public hearing before the Garfield County Commissioners. Time is of the essence in this request, due
to the impending Winter Season, and the necessity for immediate road construction.
Verifications of newspaper publication, mailings to surrounding landowners and posting of
the property will be provided at or immediately before the public hearing.
Should you have needs for further data, do not hesitate to contact me.
Ydu, A-.
ours truly,
James A. Beckwith
Enclosures
TEPEE PARK HARVEST PROJECT
INDEX TO REQUESTED AMENDMENTS
SUMMARY 1
I. AMENDMENTS FOR OPERATING CONVENIENCE 2
A. Resolution 97-70 2
(1) Personnel Transports 2
(2) Logging Transports / Variable Hours 2
(3) Selection of Harvested Trees 3
B. Official Forest Management Plan (OFMP) 3
(1) Road Building Materials / Storage on Site 3
II. AMENDMENTS FOR ACCURACY 4
A. Vegetation Maps / Harvest Area Size 4
B. Porcupine Fire Road / Main Hauling Road 4
C. Mamm Creek Harvesting 4
D. Marking of Harvested Trees 5
E. Identified Existing and Proposed Roads 5
F. Roads Identification 6
G. Culvert Size Designations 6
H. Watercourse Protective Zones 7
I. Fuels Reduction 7
J. Public Access To and Through Tepee Park 7
K. Personnel / Pertinent Information 8
III. AMENDMENTS RELATING TO OPERATIONS 9
A. Yarding Area Designations 9
(1) Management Objectives / Selective Harvest 9
(2) The OFMP Yarding Zones and Criteria 9
(3) Economies of Yarding Methods / Comparison to MBF Yields 10
(4) Advancements in Tractor Yarding Equipment 11
(5) Revision of OFMP Yarding Maps 11
B. Additional New Roads 12
IV. TIME IS OF THE ESSENCE 13
V. CONCLUSION 13
VII. APPENDICES:
A. Tepee Park / Vicinity Map / 1998 BLM Land Status Map / Carbondale
B. Tepee Park / Vegetation Types 2002 (USFS Aerial Photos)
C. Tepee Park / Slopes Greater Than 50% / 2002
D. Timbco Hydraulics / Materials on Hydro-Buncher
E. Tepee Park / Yarding Systems / OFMP 1996 and 2002 Update
F. Tepee Park / Roads / OFMP 1996 and 2002 Update
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TEPEE PARK HARVEST PROJECT
AMENDMENTS TO OFFICIAL FOREST MANAGEMENT PLAN
Summary
Request is herewith made to amend the Official Forest Management Plan, April, 1996,
("OFMP") for the Tepee Park Harvest Project. ("The Project" or "Project Area") The requested
amendments are in three categories. First, there are amendments for operating convenience. These
include personnel transportation, materials storage and other related subjects.
Second, there are amendments intended to make the OFMP currently accurate. These
include: memorialization of the Porcupine Fire Road as a main interior hauling route; updated
vegetation maps; accurate revisions of new and proposed roads; and other similar topics.
The final category includes a major amendment to allow expanded tractor yarding, and
consequent adjustments to cable and helicopter yarding within the Project Area. As a corollary to
the yarding revisions, request is made to build new and additional roads into areas where tractor
yarding - as opposed to helicopter yarding - would be performed.
This final, and major, amendment is based upon several considerations. First, infestations of
the Spruce Bark Beetle, Spruce Budworm and the Western Balsam Bark Beetle have been discovered
to be more wide -spread than originally assessed in the OFMP. To reduce further spreading, logging
must be performed in areas not originally identified in the OFMP. Second, Applicants employ "state-
of-the-art" hydro-bunchers, enabling the performance of tractor yarding on slope 5 5% of less, rather
than being limited to 35% or less slopes in the OFMP. This allows expansion of the efficient tractor
yarding method into areas where the OFMP either limited itself to helicopter and cable yarding or
avoided any yarding at all: such as in West Mamm Creek. . Third, an unemphasized tenet of the
OFMP is that the harvest project is both economical and . - - w�
Time is of the essence in these major amendments. Winter will be approaching, and road
construction equipment is already stationed near the areas of Houston Mountain. We all hope - or
maybe "pray" is a better term - for a heavy winter. While the logging equipment can operate in such
conditions, road construction is best done before heavy snows.
This request is made in comportment with the meeting of August 5, 2002, before the Board
of County Commissioners of Garfield County ("BOCC") and Paras. (1), (2) and (9), BOCC
Resolution 97-70 [August 4, 1997]. Hereafter, the Permits Holders, Intermountain Resources, LLC
and Mr. Norman A. Carpenter shall be identified as "IMR", collectively.
A Vicinity Map is attached as Appendix A.
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I. AMENDMENTS FOR OPERATING CONVENIENCE
A. Resolution 97-70
(1) Personnel Transports
PROPOSAL: Eliminate Para. (12), Res. 97-70 OR amend Res. 97-70(12) to read
as follows: "Personnel involved in the harvesting operation shall be allowed to
travel to and from the job site by personal vehicles".
Res. 97-70(12) currently requires crew cab pickups to transport logging crews in one group,
as opposed to multiple vehicles. Given the working schedule of the crews, however, this has become
quite impractical. Personnel in the harvest operation go to work at different hours. For example, the
loader operator must be on site for the first truck at 6:00 A.M., while the skidder operator does not
start work until 7:00 A.M. MIR therefore requests either deletion of Item (12) from Resolution 97-
70 or the amendment as set forth above.
(2) Logging Transports / Variable Hours
PROPOSAL: Amend Res. 97-70(3) to read as follows: "All timber hauling over
County Roads shall be on Monday through Friday, between the hours of 6 AM
to 6 PM, unless, upon approval by Garfield County Road & Bridge, variable
hours of hauling outside these standard limits are deemed safe and practicable for
public convenience. All helicopter hauling will only occur between the hours of
7 AM to 5 PM, Monday through Friday. (Italicized portion reflects area of
amendment)
Res. 97-70(3) seeks to provide a balance between the need to haul timber from the Project
Area and the amount of public traffic for other uses (school busses, recreational, etc.) on County
Roads near the Project Area. The Project Area (Tepee Park) is remotely located from residential
areas in or near Garfield County Road 320 (Taugenbaugh Mesa). There are no permanent, year-
round residences along GCR 317 (Beaver Creek Road) except within 1/2 mile of the intersection of
GCR 317 and 320.
It should be possible to comply with the standard 6AM-6PM hauling hours and to arrange for
special transports during nightitme or early morning hours. Currently, logging trucks are loaded
between 5 AM and 3 PM for transport. During School Season, the transports may conflict with
school buses on Taugenbaugh Mesa as well as oilfield equipment operating on GCR 317 and 320.
If deemed safe by Garfield Road & Bridge ("GarCo R&B"), logging trucks could operate from 2 AM
to 5 AM moving logs from the Project Area. Scheduling of such special hauling hours can be made
in advance with GarCo R&B. Accordingly, IMR requests that 97-70(3) be amended to insert the
italicized language set forth above.
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(3). Selection of Harvested Trees
PROPOSAL: Amend Res. 97-70(5) to delete the last sentence and substitute the
following: "Harvest trees will be marked and designated according to the
specifications in the Official Forest Management Plan'
The last sentence of Res. 97-70(5) currently requires marking of harvest trees by the Forestry
Consultant and the Colorado Division of Wildlife (CDOW). On August 5, 2002, Mr. Brett
Ackermann, CDOW, emphasized that CDOW does not, itself, have the expertise for silvicultural
husbandry. By comparison, the Colorado State Forest Service, which is not a division of CDOW,
has such expertise. In developing the OFMP, Levy Forest Service had consulted with CSFS.
Accordingly, IMR requests that Res. 97-70(5) [last sentence] be amended to substitute the italicized
language.
B. Official Forest Managment Plan
(1). Road Building Materials Storage
PROPOSAL: Amend OFMP, (Appendix/Water Quality Plan) to read as follows:
"Road building materials shall be maintained on-site when deemed practical, or
may be obtained or stored at off-site locations for resupply as needed during
construction".
The OFMP (Appendix / Water Quality Plan;/ Last Page) currently requires storage, on site,
of straw, plastic items and other materials related to road building within the Project Area. However,
wildlife eat the straw and the finer plastic materials. Tepee Park contains its own source of rock and
gravel. When necessary, larger supplies are ordered directly from suppliers in local communities.
The logging supervisor makes a daily trip through Rifle, CO, when traveling to and from work.
Materials needed for road -building can be obtained in town and delivered to the job site within 2
hours. Accordingly, IMR requests amendment of the Water Quality Plan, in the OFMP to substitute
the language set forth above.
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III. AMENDMENTS FOR ACCURACY
A. Vegetation Maps
PROPOSAL: Amend OFMP (Pgs. 3-4, 11, 25-28) to reflect current, accurate
surveys of vegetation distribution within Tepee Park. SEE: Appendix B.
Based on U.S. Forest Service aerial photos (2000), the distribution ofvegetation within Tepee
Park can be updated over the distribution originally estimated in the OFMP. Attached as Appendix
B is a more current map (2002) of vegetation sites, developed by Mr. William Gherardi, Garfield
County Inspector for the project. Distribution of the vegetation is as follows:
Conifer (Spruce / Fir) 2,129 acres 51%
Aspen -Conifer mix 102 acres 2%
Aspen 773 acres 19%
Gambel Oak 60 acres 1%
Rock 317 acres 8%
Grassland 782 acres 19%
4,163 acres
B. Porcupine Fire Road / Access Road
PROPOSAL: Amend OFMP (Pg. 15) to identify the Porcupine Fire Road as a
primary interior hauling route within the Project Area. SEE: Appendix B.
As discussed at the August 5th BOCC meeting, the main access road was initially cut as a fire
road to fight the Porcupine Fire of July, 2001. After review by the GarCo Inspector (B. Gherardi)
and the Rifle Water Quality Inspector (P. Bussone), this road became the main access road for initial
harvesting. To make the OFMP an accurate reflection of current land use, EAR/Carpenter request
amendment of the OFMP to show the location of the Fire Road as the Main Access Route for timber
harvest and hauling.
C. Mamm Creek Harvesting
PROPOSAL: Amend OFMP (Pg. 26) to reflect scope and need for harvest
within Mamm Creek Drainage Area.
The OFMP (Pg. 26, 3`d Para.) currently states that "...very little harvesting is scheduled for
(the Mamm Creek) drainage....". Based on current surveys of the Mamm Creek Drainage, however,
more extensive harvesting is necessitated.
The OFMP did not designate the amount of Spruce Bark Beetle, Spruce Budworm and
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Western Balsam Bark Beetle populations now discovered to exist within the Mamm Creek Drainage.
One principle Management Objective (OFMP; Pg. 16) is to reduce the populations of conifer pest
infestations in an effort to promote healthy timber stands. Elimination of the beetle population
requires selective harvesting to protect the residual stands of healthy trees. This will require changes
in the yarding areas and road construction, as discussed elsewhere.
D. Marking of Harvested Trees
PROPOSAL: Amend OFMP (Pgs. 31-34) to provide that IMR foresters will
sample mark stand prescriptions based upon the state silviculture principles
identified herein. The timber stands will be sample marked under the
supervision of a forester
The OFMP (Pg. 31) provides specific procedures for marking trees selected for harvest.
Included therein is reference to marking in cable yarding areas. At Pg. 34, the OFMP states that:
"...the timber stands will be marked under the supervision of a forester prior to harvesting...". Due
to the adjustments in yarding systems areas, IMR/Carpenter propose the change identified above.
E. Identified Existing and Proposed Roads
PROPOSAL: Amend OFMP (Pg. 43) to identify current mileages of both
existing and proposed roads.
Based on adoption of the Porcupine Fire Road as a main interior hauling route, together with
the proposals for new roads discussed elsewhere in this document, the identification of existing and
proposed roads should be as follows:
Drainage Distance
Existing Roads (6.59 miles total)
Beaver Creek 4.77 miles
West Mamm 1.25 miles
Porcupine 0.57 miles
Proposed Roads (8.59 miles total)
Beaver Creek 5.15
West Mamm 1.27
Porcupine 2.17
Total 15.18
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F. Road Identification
PROPOSAL: Amend OFMP (Pg. 45) to identify existing and proposed roads
within the Project Area.
In conjunction with (E), above, the OFMP (Pg. 45) should be amended to reflect the
following existing and proposed roads:
above.
A. Beaver Creek Watershed
1. Existing
la 13,600 ft. North gate to Ridge
lb 8,200 ft. Road below Ridge
1 c 3,400 ft. Ditch road
2. Proposed
2a 3,200 ft. Spur from Ridge
2b 13,400 ft. Ridge to Tepee to Beaver Creek
2c 5,200 ft. South end to Ditch Road
2d 5,400 ft. Spur to Ridge
Mamm Creek
1. Existing
3a 6,600 ft. Ridge to Mamm Creek
2. Proposed
3b 6,700 ft. Mamm Creek to W. Mamm Creek
Porcupine Creek
1. Existing
4a 3,000 ft. Ridge to Creek
2. Proposed
4b 11,400 ft. Creek to Houston Mountain
Attached hereto as Appendix F is a map showing the existing and proposed roads identified
G. Culvert Size Designations
PROPOSAL: Amend OFMP (Pg. 49) to reflect revised designations of culvert
sizes for the existing and proposed roads.
In conjunction with (E) above, the culvert size designations shown in the OFMP (Pg. 49)
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should be modified to provide as follows:
Road Culvert Size Diameter
2b-1 24 inch
2b-2 24 inch
2b-3 36 inch
2c-1 18 inch
2c-2 18 inch
3b-1 36 inch
3b-2 36 inch
3b-3 24 inch
3b-4 24 inch
H. Watercourse Protective Zones
PROPOSAL: Amend OFMP (Pg. 65, 2"d Para.) to reflect adjustments to cable,
helicopter and tractor yarding. Simply delete the last sentence of the 2"d
Paragraph.
The OFMP at Pg. 65, rd Para. currently states that the majority of timber within the Beaver
Creek drainage will be taken out of the drainage by either helicopter or cable yarding. In
comportment with the proposed amendments to the yarding methods, this sentence should be
eliminated.
I. Fuels Reduction
PROPOSAL: Amend OFMP (Pg. 73, Sec. G) to substitute specific language and
procedures governing slash handling.
The subject of slash treatment was discussed at the August 5th BOCC meeting. The OFMP
does not currently specify a method of handling slash: i.e., "Landing" vs. "Left -in -Woods". IMR
proposes that Sec. G be revised to read in its entirety as follows:
Sec. G: The concentration of fuels in the form of logging slash is a major problem in
harvest operations. In an effort to reduce the slash and minimize the fire danger, the
following practices will be required: (1) Harvest trees will be whole tree skidded to
a landing. Limbs will be removed and piled at the landing. The landing will be burned
when weather conditions permit safe burning; (2) All merchantable culls will be
removed from the harvest area if there is an economy of removal.
J. Public Access To and Through Tepee Park
PROPOSAL: Amend OFMP (Pg. 77) to provide corrected designation that
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Tepee Park is not open for public use or access except as provided by agreement
between Landowner and U.S. Forest Service.
This subject was also discussed at the August 5th BOCC meeting. Portions of the OFMP
discuss public access through, or to, Tepee Park. These should be amended to reflect the following
position of the Landowner (Norman A. Carpenter) with regard to public use and access.
Tepee Park is not open to public use by anyone without the specific, written consent
of the landowner. This prohibition extends to all forms of land travel: foot, horseback
or motorized vehicle (including snowmobiles). The Landowner has granted to the
U.S. Forest Service a public hiking trail corridor, within which corridor the U.S.
Forest Service will located and build a trail. Upon completion of the trail, a specific
easement will be granted for public use. Until the USFS hiking trail is built, all
requests to travel across Tepee Park, at any location, must be directed to the
Landowner, the U.S. Forest Service or their designated agents. Without such
approval, all passage on or across Tepee Park is considered to be a trespass.
K. Personnel / Pertinent Information
PROPOSAL: Amend OFMP (Pg. 83, Personnel & Equipment) to prohibit
permanent man -camps and reflect existing axle weight limits.
The OFMP (Pg. 83) currently specifies that man -camps for logging persnnel will not be
allowed. This prohibition may not be viable at various seasons of the year. IlVIR proposes that
permanent man -camps will be prohibited. In addition, Para. 2 of this section incorrectly states that
the GVW limit is 70,000 lbs. Pursuant to current resolutions of the BOCC, the GVW limit for GCR
317 and 320 is 80,000 lbs.
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III. AMENDMENTS RELATING TO OPERATIONS
A. Yarding Areas
PROPOSAL: Amend OFMP (Pg. 42) to: (a) catalog slopes greater than 50%
within Project Area; (b) redesignate zones for cable, tractor and helicopter
yarding based on improved feller-buncher equipment, economies of harvest, and
attainment of Management Objectives; and, (3) authorize adjustments to the
percentages of harvest obtained through cable, tractor and helicopter yarding.
Without question, this amendment is one of the two major revisions of the OFMP, as that
document was originally designed and conceived by Levy Forest Services. To understand the basis
for this amendment, it is necessary to provide the original and current background for selective
harvest logging.
(1) Management Objectives / Selective Harvest
The OFMP (Pg. 16) establishes four principal objectives from this timber harvest:
• Long-term sustained timber yield by reducing the density of timber stands and removal of
older growth trees which are decadent by insects and diseases;
• Protection of watersheds and improvement by reduction in "overstory" (old growth trees)
thereby reducing the water consumption taken by such older growth overstory;
• Improvement of wildlife habitat by removing overstory to allow increases in sunlight
penetration that will promote growth of understory: to wit, grasses, forbs and shrubs, and
Aspen sprouts;
• Improvement of fire -fighting access through road construction and reduction in fire fuels by
removal of older growth overstory and dense understory.
The OFMP proposed accomplishment of these objectives through the "selective harvest"
method: i.e., selection of felled timber based on age, density, disease and other specific silvicultural
criteria. Obviously, there were two fundamental assumptions to this method. First, the yarding
method employed would be both economical to perform, and safe for personnel to employ. Second,
the equipment used - and therefore the yarding method employed - would cause the least amount of
soil disturbance to the forested areas.
(2) The OFMP Yarding Zones and Criteria
The OFMP (Pgs. 40-42) selected three methods of yarding: Tractor; Cable; and, Helicopter.
Based on the use of so-called "conventional" logging equipment, the OFMP (Pg. 40) designated the
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areas for yarding system employment: (SEE: Appendix E, attached.:
Yarding Criteria Acreage Percentage
Tractor Slopes not greater than 35% 672 46%
Cable None specified 456 29%
Helicopter Slopes greater than 50% 356 24%
Total 1,484
You will note that the West Mamm Creek area of Tepee Park is comparatively ignored for
timber harvest. Under the OFMP, this area was substantially omitted from logging, and roads were
not designed to be built into these areas. Such omission can not now be countenanced. The Spruce
Bark Beetle infestation among Engelman Spruce in West Mamm Creek has been found to be quite
high. In addition, populations of the Western Balsam Bark Beetle (which attacks sub -alpine fir
species) has been found in the West Mamm Creek Area. The OFMP omits reference to such beetle
infestation in the Mamm Creek area. However, one of the stated Management Objectives was to
reduce or eliminate conifer pest infestations.
(3) Economies of Yarding Methods / Comparison to MBF Yields
The OFMP does not identify or discuss the estimated costs per MBF ("1,000 Board Feet")
for the differing yarding methods. Based on current costs, these are estimated at:
Method
Tractor
Cable
Helicopter
Cost
$100 per MBF
$160 per MBF
$245 per MBF
Avg.: $168.33/MBF
To place these operating costs in correct perspective, it is also necessary to understand
"MBF": the measuring standard for the purchase price of unmilled timber. Felled timber is sold to
a mill based on the realizable amount of milled lumber that can be obtained. Because trees are
tapered, the industry employs a "scaling" method to evaluate the timber. The current method of
scaling employed is the Scribner Decimal C, Net Scale Eastside Standard Taper Rules. (More easily
referred to as "Scribner Decimal C, Eastside Rules") It is applied only by "Certified Check Scaled
Scalers" trained and experienced in its use. It is not necessary to provide an education in the Scribner
Decimal C method. Suffice it to say here that a truckload of logs will commonly "scale" at 4.4 (avg.)
MBF. Felled timber is currently purchased at $225 per MBF (FOB: forest) . The contract between
Norman Carpenter and IMR calls for a variable price of $150-$200 per MBF.
Using $225/MBF, a truckload of Engelmann Spruce, having 4.4 scaled MBF, will sell to the
mill for $990. That same load, however, will cost $309 (tractor yarding), $494.40 (cable yarding)
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or $757.05 (helicopter yarding) to remove from the forest. This is without considering the transport
costs from forest to mill and other incidental expenses: e.g. re -seeding; road construction, etc.!
(4) Advancements in Tractor Yarding Equipment
Tractor yarding is the preferred method. It has a lower operating cost. It does not disturb
as much soil as cable yarding. It is not dependent upon weather - as is helicopter yarding. Its
historical limitation has been the percentage of slope on which the "feller-buncher" would operate.
For example, the OFMP limited tractor yarding to 35% or lesser slopes, although some 50% slopes
would be permitted. (OFMP; Pg. 40)
Engineering advancements in the past 10 years, however, have substantially overcome this
limitation. Companies, such as Timbco Hydraulics, have developed "feller-bunchers" which feasibly
operate on 50-60% slopes. The Timbco styled feller-buncher is designed to work within dense timber
stands since its rotating cab and motor have short movement radii - thereby protecting trees which
are not marked for felling. Materials taken from the Internet on Timbco feller-bunchers are attached
as Appendix D IMR employs the Timbco styled equipment, which allows IMR to expand the tractor
yarding areas initially designated in the OFMP.
It appears that the OFMP, as conceived by Levy Forest Services, intended to use conventional
tractor yarding equipment, as opposed to the more modern Timbco styled equipment. Using
conventional equipment, the OFMP was forced to employ helicopter and cable yarding on over 50%
of all harvest activities. Using Timbco style equipment, IMR does not have this limitation. Indeed,
its only limitation is the OFMP itself - which should now be amended.
(5) Revision of OFMP Yarding Maps
Attached as Appendix C is a catalog of slopes greater than 50% within the Project Area.
Attached as Appendix E is a revised Tepee Park Yarding Map, showing the revised areas in which:
(a) tractor yarding would be increased; (b) cable yarding would be reduced; and, (c) helicopter
yarding would be reduced in scope but retained in very steep areas.
IMR/Carpenter hereby request an amendment of the OFMP adopting Appendix H under
which yarding activities would be distributed as follows:
Yarding Criteria Acreage Percentage
Tractor Slopes not greater than 60% 1,510 68%
Cable None specified 293 13%
Helicopter Slopes greater than 60% 412 1 9%
It should be noted that the selection criteria for harvesting trees within the Project Area will
remain the same as set in the OFMP (Pgs. 31-34). Thus, the amendment merely alters the method
11
by which the yarding occurs - but does not alter the criteria for which trees will be felled.
As noted in Appendix H, many of the original Helicopter Yarding areas are preserved by the
amendment. This is due to the extreme slopes on which the trees are situated. Cable yarding is
reduced by 16% (29 to 13) and Helicopter yarding is reduced by only 5% (24 to 19) Tractor yarding,
using the Timbco-styled equipment, is increased from 46% to 68%.
B. Additional New Roads
Since tractor yarding areas would be increased then access roads must also be built into those
areas where the tractor yarding will be performed. Accordingly, IMR requests amendment of the
Road Map (OFMP: Pg. 15) to reflect new and additional roads to be cut for the additional areas in
which tractor yarding would be employed. These new and proposed routes are shown on Appendix
F. Maps showing the overlay of yarding systems and roads are attached as Appendix G.
These roads will be constructed to the same standards as set in the OFMP (Pgs. 44, 52-54).
All of these roads will remain, after harvest, to serve as fire roads in wildland fire -fighting operations.
12
IV. TIME IS OF THE ESSENCE
It is imperative that the new roads - and yarding areas - in the NW quadrant of Tepee Park
(near Houston Mountain) be constructed within the next 75 days. Winter - and hopefully a heavy
winter - will be upon us within 90 days. IMR's equipment for road construction and tractor yarding
is already operating near this NW quadrant. Under the current provisions of the OFMP (Pgs. 64, 83),
tractor yarding can continue into the Winter Season..
Accordingly, IMR requests approval of the yarding revisions and new road identification as
soon as possible, so that construction crews can prepare for Winter Season.
V. CONCLUSION
While using sound methodology, the OFMP conceived by Levy Forestry Services was not
wholly "site specific" to Colorado timber operations. The OFMP did not, perhaps, foresee the
engineering advances in tractor yarding equipment which now enables efficient access to steeper
slopes by the Timbco-styled equipment. The OFMP could not, obviously, envision the continued
spread of the Spruce Bark Beetle, Spruce Budworm and Western Balsam Bark Beetle infestations
to drainages within Tepee Park beyond Beaver Creek. Certainly, the OFMP could not have predicted
the severe and extreme drought which has devastated Colorado's forest areas - both public and
private - and which compels major "re -definitions" to our conceptions of forest management,
silvicultural husbandry, and wildfire prevention.
To make the OFMP more "Colorado specific" - and to maximize the efficiencies allowed by
the advanced yarding equipment - IMR/Carpenter have proposed the described operating
amendments. These operating amendments will not have an adverse impact upon watersheds of
either Beaver Creek, Porcupine Creek or West Mamm Creek. Indeed, the Timbco-styled equipment,
and the methods of road construction, have not caused any adverse impact upon Beaver Creek: the
initial harvest area.
Accordingly, Intermountain Resources, LLC, and Norman A. Carpenter request approval of
the amendments described herein, and within the immediate future to allow for construction before
Winter Season.
spectfully sub
ted,
James A. Beckwith
13
APPENDICES:
A. Tepee Park / Vicinity Map / from 1998 BLM Land Status Map / Carbondale
B. Tepee Park / Vegetation Types 2002 (USFS Aerial Photos)
C. Tepee Park / Slopes Greater Than 50% / 2002
D. Timbco Hydraulics / Materials on Hydro-Buncher
E. Tepee Park / Yarding Systems / OFMP 1996 and 2002 Update
F. Tepee Park / Roads / OFMP 1996 and 2002 Update
G. Tepee Park / Yarding and Roads / OFMP 1996 and 2002 Update
APPENDIX A
MIL
N r N 11111 N 11111 M IMMI I NE N N IN111 INIII I V
;ARBQNDALE. COLORADO Tepee Park /Vicinity Map
;
ti t5v r,. "•41,1 iztV. ►t'i`t'
(,ARF1LLD CO -
MESA CO
MP.vNIr r
•
FS 824
WHITE• RIVER
GCR 317
A a {�f�L�L. ..--
•ee
AKA
Bafflement ; Mesa
w),
r, C,
APPENDIX B
I MN NM MI I-- N w- s N N-- OM- M I
4
Vegetation Types
2002 Update
Vegetation Types:
Conifer (Green)
Aspen & Aspen Mix (Yellow)
Grass (Pin(}
Gambel Oak (Blue)
Rock (Red)
a
6,--r4
1
--7).i'
...
24 c , > - / 7 4 c : "
•to
+6
---
N
Tepee Park Harvest Project
APPENDIX C
NMI N M = N M MI ME N M 111111 N 1111111 E E
771
Slopes Greater Than 50%
•
1
N
Slops
Exceding 50% (Blue)
All Others (Green)
j
Tepee Park Harvest Proect
APPENDIX D
Often Copied... NEVER Equaled
Built By Loggers For Loggers
Feller-Buncher Innovation Since 1980
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T445 -C i ith gle-mount CTL processor in.
uth Wales, Australia - January, 1999
2
In 1972, a northern Wisconsin logger
named Pat Crawford patented a tree cutting
shear and began looking for a cost-effective
machine to mount it on. His first attempt
was to modify a Timberjack 404 skidder by
reversing the operator's seat and installing
the shear on a boom.
Pat then purchased a Drott excavator feller-
buncher in 1975 and used it for four years.
Most of his logging jobs were in national
forests and tight selective cuts were
becoming very common. The Drott had a
large counterweight and a long tail swing
which made it almost impossible to
selective cut without damaging standing
trees. To solve this problem, Pat designed a
new boom geometry.
Pat Crawford and his inventions
"June„�18i _
The new boom geometry located the
boom and lift cylinder pivots well behind
the center of a rotating turntable. This
made the boom's mass act as a
counterweight, eliminating the large
parasitic counterweight and tail swing.
The boom also knuckled over the cab
making it possible to cut a tree right next
to the machine and then swing with the
tree while staying almost within the
machine's width. The new boom could
also be extended vertically to delimb a
tree from the top down.
Initially, the new boom geometry was
installed on a rubber -tired machine with
side-to-side cab leveling, but hydraulic
problems meant replacing the tires with
tracks. A patent was filed on this machine
in February, 1980 and
another patent with additional
claims was issued in April,
1986. With the success of
this first machine Pat asked
Larry Klement, who had
helped build the machine, to
become his partner... Timbco
Hyttraulics, Inc. was formed.
A small 6,000 sq. ft. shop
was built in Shawano, Wisconsin where the first production
Timbco Hydro-Buncher was built and sold in July, 1980.
In January, 1982, Timbco was challenged to build a 4 -way cab
leveling machine. With this challenge, Timbco produced its first
4 -cylinder, 4 -way cab leveling machine in only three months.
This new machine was
introduced in April, 1982
at the Intermountain
Logging Show in
Spokane, Washington. The
design was a huge success
and approximately 600 of
the 4 -cylinder, 4 -way cab
leveling machines were
eventually built.
Timbco redesigned the
machine again in 1987 to an
engine -up configuration with
the 4 -cylinder cab leveling
being abandoned for a much improved 2 -cylinder design. This
new generation T400 Series Hydro-Buncher has proven to be an
even greater success. The new T400 -D Series Hydro-Bunchers
now offer even more improvements such as lighter and stronger
boom construction, an entirely new electrical system, and a 20%
increase in cooling capacity.
Since its beginning, Timbco Hydraulics, Inc. has expanded five
times and as of June, 1999 has produced over 1,550 T400 Series
Hydro-Bunchers. Timbco is continuously testing designs for new
products like the TF800 Series Hydro-Skidders introduced in
1996. The "Timbco family" still numbers just under fifty
employees, all proudly supplying products to loggers around the
world. Timbco is a company whose success is built on
innovation, integrity, and remaining close to the logging industry.
Being founded by loggers, we believe all loggers have a very
basic need... equipment that is simple, easy to service
and maintain, and has the flexibility to "fit" into their
operation. Whether it be on steep slopes, in wet swamps, in
tight selective cuts, or with any cutting attachment... Timbco
products have, and always will, fulfill that need.
3
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1 16
•
•.. • •
A ..`a•`�
T.
Timbco's unique 2 -cylinder, 4 -way cab leveling keeps the operator comfortable and productive in a level position, even when
working on 51 % slopes. Cab leveling allows the mass of the entire upper structure to be shifted towards the slope to increase
stability. To put it in more familar terms, we naturally do the same thing by leaning forward when walking uphill.
Timbco's 2 -cylinder leveling system is simpler, "cleaner", and faster than other manufacturer's leveling systems. Cab leveling
controls are also very simple and easy to operate, one button for each direction of travel. Compound leveling (leveling in two axis
simultaneously), is done by operating the controls for two directions at the same time.
Cab Leveling Capabilities
Forward
Rear
27° (51% slope)
7° (12% slope)
Side 20° (36% slope)
•
illllllrl!IIIlllllllill' 3'31
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Timbco's current 2 -cylinder, 4 -way cab leveling
system has many advantages over 4 -cylinder
systems, including Timbco's original cab leveling
system used in the engine -down machines.
• A 2 -cylinder cab leveling system weighs less and
requires fewer hydraulic lines and connections
than a 4 -cylinder cab leveling system.
• Two cab leveling cylinders can be positioned at
the rear -most corners of the leveling mechanism,
outside the swing bearing race. This position
provides the most leverage and stability because
the cylinders are located the furthest away from
the leveling pivots and each other.
• Every pivot must have some tolerance (play) built into it for
assembly purposes. A 2 -cylinder cab leveling system has at
least four fewer pivot points, therefore, less built-in tolerance.
In addition, Timbco uses its PATENTED tapered hub pin
retaining system in the front -to -back and side-to-side pivots,
leaving minimal tolerance.
• A 2 -cylinder cab leveling system has fewer pivot points to grease and fewer
cylinders to maintain.
• Timbco uses a solid steel casting, heavy-duty steel weldment, and a 51"
(130 cm) diameter swing bearing rated to 1,200,000 Ib. (544 316 kg) capacity
for maximum strength and rigidity. Improvements in the T400 -D Series
Hydro-Bunchers include larger 6-1/2" (16,5 cm) diameter cab level cylinders
with heavy-duty, bolt -on pistons for additional strength and ruggedness.
Side -To -Side Pivot
Front -To -Back Pivot
A) The longer dimension "A" is, the more leverage the cylinders have to
level the upper turntable from side-to-side.
B) The longer dimension "B" is, the more leverage the cylinders have to
level the upper turntable from front -to -back.
The longer dimension "A & B" are, the more stable the entire leveling
mechanism will be.
17
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Timbco's PATENTED boom design locates the main boom pivot well behind the center of rotation where the
mass of the boom itself acts as a counterweight. This feature eliminates the need for a large parasitic
counterweight*. The main lift cylinder pivot is also located behind the center of rotation to allow the boom
to knuckle over the cab. This feature allows cutting a tree right next to the tracks and the boom can lift
heavier loads closer to the machine with less stress on the swing bearing. The boom can also be
extended almost 30' (9,14 m) vertically to delimb a tree from the top down.
The Timbco "D" model Hydro-Bunchers also feature new "box -construction" boom
weldments. The new design is engineered to produce a boom that is stronger and
1 distributes load stress better. A reduction of weight towards the tip of the boom
increases lift capacity at full extended reach.
In addition to the standard boom choices, there are three additional boom
configurations available. All boom configurations are interchangeable and can
adapt to any logging application as required.
* An optional 2,100 Ib. (953 kg) counterweight is only recommended on the T415 -D and T416 -D
when using cutting attachments weighing over 5,000 lb. (2 268 kg). Tail swing does not increase
with the addition of the counterweight.
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{gw� P HANDLING
DEVICE
5<1 MATERIAL •.ocd, 107) S. Lincoln
J. Cr 401 5,4166
X76} Invenmr• Patrick J.
of
l21.1 ppPl. ho..001,985
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Dec. 21,
t221 Filed'
ti DOI A9Ptitatinn
Related
connected at its
,.a boom c
Pivotally point
spaced
to the turntablets of the
lower en aom the rotatrn9
a
pivotal movement of
turntable for
the boom in a vertl,ca1 plane over
the turntable by mieans of a
hydraulic ramconnected at its
lower end to the turntable at a
IMO intermediate the rotating
axis of the turntabi of and
Octal connection „
tower end of the boom•..
•
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Timbco's 4 -bar power link allows fixed boom mount cutting
attachments, such as a bar saw, disc saw, or control -fall CTL
processor, to be swept through a 152° arc from full back tilt to full
forward tilt. This feature is especially useful when working in
blow -down timber or for positioning the tree after it has been
• felled. When used with a lateral tilt cutting attachment, a felled tree
can be dragged in and placed right alongside the machine parallel
to the tracks or even dragged past the machine to skidders.
• Large 5" (172 mm) diameter, 40" (102 cm) stroke attachment tilt cylinder has an induction -
hardened and chromed rod for maximum wear resistance. Several improvements, including
additional rod bearing attachment bolts and a heavy-duty bolt -on piston design, have been
incorporated into the cylinder for the T400 -D Series Hydro-Bunchers.
• All linkage and attachment tilt cylinder pins are 2-1/2" (64 mm) induction hardened and chromed for maximum wear
resistance. T400 -D Series Hydro-Buncher linkage pins are also quenched and tempered for additional strength and wear
resistance. All linkage pins are a teardrop design retained by locknuts.
• Steel bushings used in all pivot points.
• The "Y" shaped paddle link is burned and machined from 4" (102 mm) thick steel plate.
• The "dog bone" shaped links are burned and machined from 1-3/4" (44 mm) thick steel plate.
��� `� `��� .^,�����- ` �°�!,;���`�^;�~/
+����'- �
�
^ �
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1 10
Timbco T400 -D Series Hydro-Bunchers are designed to be simple, rugged, and
have the ability to perform under the worst Iogging conditions, whether it be on
steep slopes, in weswamps, or in tight selective cuts. Timbco's solid, time-
p0v0n design, combined with 2 -cylinder, 4 -way cab leveling and the flexibility
and capacity to install any type of cutting attachment, provides the mos
versatile feller-buncher available today.
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The track systems designed for the T450 -D and
T455 -D Hydro-Bunchers are specifically engineered
to give maximum service life in Canada's severe -duty
conditions. These track systems are some of the
most rugged, purpose-built forestry undercarriages
available today.
• Heavy-duty O&K F Series final drives and Rexroth
A6VE Series 2 -speed, bent -axis track motors.
• DFG Tractor -type double flange rollers.
• Tractor -type clipped and relieved track shoes and
sprocket teeth reduce mud and snow buildup.
• Raised idler for better climbability and less ground disturbance.
• Replaceable bolt -on track sliders and track shoe support wear surfaces.
Bottom rollers can be installed in place of the sliders if desired.
• Track frames bolt to the carbody for easy removal.
Track Type Quadco Custom (D6D) Quadco Custom (D7G)
Track Pitch 8.0" (203 mm) 8.5" (216 mm)
Bottom Rollers 9 per side 8 per side
Carrier Type Slider Slider
(Rollers optional) (Rollers optional)
Number of Shoes 48 per side 45 per side
Final Drive O&K F062 O&K F100
168.0:1 ratio
142.0 : 1 ratio
Track Motor Rexroth A6VE80 2 -speed Rexroth A6VE107 2 -speed
Integral track brake Integral track brake
MIN - 2.44 cu. in. (40 cc) MIN - 3.23 cu. in. (53 cc)
MAX - 4.88 cu. in. (80 cc) MAX - 6.53 cu. in. (107 cc)
Tractive Effort (After efficiency reductions) 81,000 Ib. (36 741 kg) 91,000 Ib. (41 277 kg)
Drawbar Pull (After rolling resistance reduction) 77,580 Ib. (35 190 kg) 87,445 Ib. (39 665 kg)
Drawbar -To -Weight Ratio 1.36: 1 1.48 :1
Travel Speed LOW -1.6 mph (2,6 km/h) LOW -1.5 mph (2,4 km/h)
HIGH - 3.2 mph (5,1 km/h) HIGH - 3.0 mph (4,8 km/h)
Ground Pressures:
24"/600 mm SG
28"/700 mm SG (Standard)
30"/750 mm DG
36"/900 mm TG
7.42 psi
6.46 psi
6.05 psi
5.25 psi
7.83 psi
6.82 psi
6.40 psi
5.49 psi
9
APPENDIX E
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MN = EN I 1M11 INII 11M1 N NE 1 I 11111 1M11 N NE M M MN
Yarding Systems
2002 Update
Yarding Systems
Helicopter (Yellow)
Tractor (Blue)
Cable (Purple)
APPENDIX F
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M = = E r ININ N NS INII r MN I N I I N N I
Roads / 2002 Update Roads
. I.
Existing (Blue Dash)
Proposed (Red)
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APPENDIX G
I N N MN N IMI NM MN = = N I MIII I N E MN MI
.' r.1 k �..
•
•
Yarding and Roads
2002 Update
•
•
A.
4.1
•
Roads
Existing (Blue)
Proposed (Red)
Yarding:
Tractor (Blue)
Helicopter (Yellow)
Cable (Purple)
l:
s
I
Tepee Park Harvest Projec