|
ELY Resource Management EIS Scoping Documents
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). Gene Drais Project Manager Elko District Fire Officer, Dear Mr. Drais : I work with pinyon pine nuts harvested in Nevada, species p.monophylla, primarily for BLM lands. My company, Goods From The Woods, has written many, many letters to the Ely district, about the failure to manage the pinyon resource for pine nut production. Those letters have never been addressed. I believe this amounts to gross negligence. However, a new opportunity exists with the Resource Management Plan. I would like to start with reviewing BLM’s responsibilities. These responsibilities have not been met. It is a good time, to reexamine the factors leading to that mismanagement. First, the BLM must become aware of the commercial value of the pine nut, both domestically, and on a global scale. In, the year 2000, the United States imported, 4,198,792.4 kg of shelled pine nuts with a tariff value of $17,066,000.00. I am including some tables, which graphically illustrate the global pine nut market. Prior to World War II, our American Public lands produced up to 8 million pounds of pine nuts per year in high cycle years. There is no reason why this industry can not be revitalized. This valuable commodity has been ignored by land managers and as a result, the American citizens are losing huge sums of potential revenues from a sustainable resource. As stated, the root of the problem is a failure to adequately value the resource. It has been squandered as the result of little to no monitoring of harvests. A mature acre of pinyon will produce about 200 lbs per acre. The figure has been verified by people who harvest pine nuts. Yet, most harvest areas are sold for the minium bid of 4000 lbs, at .25 lb. or, $1,000 per area. Harvesters are then to report harvests amounts in excess of those bids. The result of this self reporting is a hideously low estimate of pine nuts yielded. It becomes a vicious cycle: no monitoring because the yields are so low, low reported yields as the result of lack of monitoring. I know no other resource mismanaged in such a fashion. Each acre of mature, pinyon trees with pine nuts is worth $50.00, using the current fee of .25 per pound X 200 lbs. Hypothetically, 100,000 acres of mature pinyon properly managed for pine nut production would produce 20,000,000 lbs every 5 years, with a value of $5,000.000. There are over 4 million acres of pinyon in the Ely District. This target figure could be obtained over the course of a few years, if the resource were properly managed, and the mature trees are not destroyed by fuels reductions projects. |
There are many statements in BLM planning
documents, which indicate the lack of basic understanding of the life cycle
and nut production cycles in the pinyon trees. The scientific information
is readily available. Indeed, many of my letters have addressed errors in
failing to consider such research and included the citations for the research.
I will gladly provide copies of any of my research. Likewise, I am
familiar with experts on a global scale, who could advice the BLM in the
development of a sustainable management plan. The Koreans, the
Chinese and the Italians have all developed methods of working with the cyclical
nature of pine species for nut production. Our country has not. The
information is available, and I have contact by a number or foreign interests
about the possibilities. I would like to give one small example of the lack of knowledge and the resultant mismanagement. The Ely Natural Managed Fire plan states pine nut production is a matter of climate, and thus, are outside the scope of the plan. In response to a letter written by an environmental group, Mr. Kolkman stated that rain was the primary factor in pine nut product . This is incorrect. The size and quality of a pine nut is related to moisture content, however, the trees produce nuts on a 5-7 year cycle, all over the globe. This is well documented. It is a fine example of how much education needs to be done within the Ely BLM. I would highly suggest, that a forester is needed to assist with management decisions, for this non-timber forest product. 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 area subpart of a 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 three 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. This all the more reason to manage p.monophylla with greater care. We need a problematic assessment, to take the regions issues into consideration. Finally, many of the hazardous fuels projects, I have reviewed contained erroneous information, and need to be updated to include the pine nut within their scope, and the fire resistant properties of consider in planning, and better documentation of the role of grasses and range “improvements” as causes of catastrophic fire. I think you for your time, and look forward to active participation in this EIS. Sincerely, Penny Frazier |
| History of Pinon Penny and BLM Home Page |
A few other
unanswered letters:
702601blmletter.htm Leter re: Elko Nevad Fire Plan CHEATGRASS and FIRE MYTHS and the some real stories |
| UNDERSTANDING
BIODIVERSITY and NTFP |
Raw Fooders Cooking with pine nuts |