300R04906
APPENDIX M
RESPONSE TO COMMENTSI RECEIVED ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
SECTION 1.
SECTION 2.
SECTION 3.
SECTION 4.
SECTION 5.
SECTION 6.
SECTION 7.
SECTION 8.
SECTION 9.
SECTION 10.
SECTION 11.
SECTION 12.
SECTION 13.
PROPOSED ACTION
ALTERNATIVES, RESTORATION AND MONITORING
SOILS AND WATERSHEDS
FISHERIES
FIRE AND FUELS
AIR QUALITY
RECREATION
TRANSPORTATION
VEGETATION
WILDLIFE
SOCIO-ECONOMIC
ROADLESS
NEZPERCE TRIBE
1 Note: The Content Analysis Report and individual comment letters received for this project have been filed
in the project file and are available to the public upon request.
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American River/Crooked River- Final Environmental Impact Ste&ement
SECTION 1 - PROPOSED ACTION
GENERAL OPPOSITION/SUPPORT FOR PROJECT IMPLEMENTATION
1. THE NEZ PERCE NATIONAL FOREST SHOULD IMPLEMENT THE AMERICAN AND
CROOKED RIVER PROJECT.
A. The plan for extensive thinning makes excellent sense, and I can find no good
arguments against the amount of roadside salvage being planned here. If the
temporary roads are indeed temporary, and are, as described in the mitigation
language, in reality kept free ofATV use, then I would have to conclude that the
road and road management package is logical. (Individual, Moscow, ID -
#6.4.20000.410)
RESPONSE: Comment acknowledged
B. BECAUSE THE PROJECT is OF BENEFIT TO ELK CITY'S FIRE SAFETY. LOCALECONOMY
AND ELK HERDS
The concerned Sportsmen of Idaho, INC., (CSI) supports the referenced project
as being professionally organized and of benefit to Elk City's fire safety, the local
economy, and elk herds in the area. (Recreation/Conservation Organization,
Viola, ID-#2.1.20000.002)
RESPONSE: Comment acknowledged
OSOS08
C. BECAUSE THE PROJECT WOULD HELP TO UNDO THE NEGLECT OF OUR FOREST LANDS
We are afraid too little has been done to late (like 25 years) to help our area.
Let's get the American/Crooked project and Red River out as soon as possible to
help undo this neglect of our forest lands. (Individual, Elk City, ID -
#14.3.20000.205)
RESPONSE: Comment acknowledged
(33(33(33
D. BECAUSE OPPOSITION TO THIS PROJECT is BASED ON FALSE INFORMATION REGARDING
FISH AND SEDIMENT
/ fully approve of this project, although I feel it is too little to late. The fact that
this worthy project has been delayed for 20 years is caused by false information
regarding fish and sediment. Anyone caring to read the facts should study the
early history of the South Fork and its tributaries, which will show that from 1862
to 1940, a period of heaviest mining, where millions of tons of earth were
discharged into the headwaters, the fish numbers remained the highest ever
recorded. (Individual, Grangeville, ID-#18.2.20000.210)
RESPONSE: Comment acknowledged
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American River/Crooked River- Final Environmental Impact Statement
E. BECAUSE WHAT is BEING PLANNED is WELL SUITED TO THE HABITAT AND SOIL TYPES OF
THE PROJECT AREAS
The real test of a forest decision like this one, especially when plenty of tree
cutting and some (temporary) road building is planned, is the issue of suitability.
In this case, I think that you have demonstrated that what is being planned is, in
fact, suited to the habitat and soil types. This whole piece of the country is not
too steep, and it gets plenty of moisture. It is also not prone to the catastrophic
mass failures and erosion patterns that exist just a little to the east near and
south of Anderson Butte. (Individual, Moscow, ID - #6.3.20000.230)
RESPONSE: Comment acknowledged
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F. BECAUSE OF MOUNTAIN PINE BEETLE INFESTATIONS
The RAC (Resource Advisory Committee- North Central Idaho) appreciates the
opportunity to comment on the American and Crooked River Project. It is the
type of project that is needed in the Elk City area in response to the ongoing
mountain pine beetle epidemic. Please keep the RAC informed as the planning
progresses and the project is implemented. If the RAC can help with any aspect
of implementation, please let us know. (Place Based Group, Lewiston, ID -
#3.9.20000.373)
I fully approve of this project, although I feel it is too little to late. It is sad to think
of the millions of feet of timber wasted by the delay of this project and the
negative effect it has had on Idaho County's economy. We need to have 20 of
these projects going at this time to curb the bug infestations. At one time, this
beetle problem could have easily been controlled, prior to 1984, when the
infested area was small, along the Darby road. Now it has spread in all
directions, south to Mallard Cr. Ranches where 50% of the trees on our property
were killed last year. (Individual, Grangeville, ID-#18.1.20000.373)
RESPONSE: Comment acknowledged
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2. THE NEZ PERCE NATIONAL FOREST SHOULD IMPLEMENT THIS PROJECT PROMPTLY.
A. GIVEN DECLINING FOREST CONDITIONS AND INCREASED RISK OF FIRE
With the continuing decline in forest conditions, and the resulting increased risk
of a damaging catastrophic fire, we encourage you to proceed rapidly with the
completion of the project design, contract advertisement and awards, and
implementation on the ground. (Timber/Wood Products Industry, Kamiah, ID -
#5.20.12300.330)
RESPONSE: Comment acknowledged. We will proceed as rapidly as
possible.
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American River/Crooked River- Final Environmental Impact Statement
3. THE NEZ PERCE NATIONAL FOREST SHOULD CONTINUE TO DEMONSTRATE
COMMITMENT TO GOOD SCIENCE AND PUBLIC PARTICIPATION.
A. The process used to date to develop these projects and the DEIS is, in my mind,
one of the best that I have ever seen. There was full and frequent public
disclosure and a genuine sense of communication and openness. As a result,
not only has the proposed decision been improved, but a good model of how to
better do business has also been developed. (Individual, Moscow, ID -
#6.1.20000.060)
RESPONSE: Comment acknowledged.
030303
B. BY CLARIFYING HOW THE PROGRAM WILL SOLVE EXISTING WATER QUALITY
PROBLEMS
The Nez Perce National Forest has proposed here a plan that strikes me as
being thoughtful and based on good science. The important test of suitability has
been met, but the commitment to some serious fixes for existing water quality
problems needs a whole lot of clarification. The forest should also be proud of its
methodology, both in the scientific aspects of the plan, and also in how it has
worked with citizens in the preparation of this proposal. (Individual, Moscow, ID -
#6.9.10000.246)
RESPONSE: Comment acknowledged
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4. THE NEZ PERCE NATIONAL FOREST SHOULD ACTIVELY MANAGE THE FORESTS.
The National Forests inevitably degenerate from neglect and mismanagement,
becoming overgrown, bug-infested and disease-ridden, dead and dying. They
become tinderboxes, a starting point for the kind of wildfire that will ravage the west's
homes, and work places are destroyed. The hillsides and valleys of our clean, vital
watersheds are blackened and denuded. Habitat supporting Idaho's rich diverse
wildlife populations and protecting our fragile salmon and steelhead runs are
befouled and laid to waste. Lives are lost. Let's try to undo this damage of neglect
and mismanagement, and leave a legacy for future generations that hope to live,
work, recreate and raise families in and around healthy productive and sustainable
forests. (Individual, Elk City, ID-#14.2.30000.002)
The Forest Service has been doing a great disservice to the forest since I can
remember. What's the matter with you guys? Mismanagement of resources is now
an American tradition - nothing to be proud of. (Individual, Ukiah, CA -
#13.1.30000.203)
RESPONSE: Comments acknowledged
OS OS OS 05 OS OS
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American River/Crooked River- Final Environmental Impact Statement
5. THE NEZ PERCE NATIONAL FOREST SHOULD BE ALLOWED TO ASSERT AUTHORITY
TO MANAGE.
BECAUSE LAWSUITS HAVE INHIBITED MANAGEMENT
We have lived here 35 years and watched our Forest Land managers be forced into
a state of inertia by lawsuits from outsiders calling themselves "Conservationists".
(Individual, Elk City, ID - #14.1.10100.051)
RESPONSE: Comment acknowledged
0»0*O* O8 080*
6. THE NEZ PERCE NATIONAL FOREST SHOULD DELAY THIS PROJECT UNTIL THE
FOREST PLAN is REVISED.
GIVEN CONTROVERSIAL NATURE OF DEVELOPMENT IN ROADLESS AREAS
The fact that the forest plan will be revised soon makes a strong argument for
delaying this process until after completion of the forest plan revision. Such a
controversial proposal that involves extensive roadless area development ought to
wait for to have the benefit of a newly revised and updated forest plan.
(Preservation/Conservation Organization, Moscow, ID-#22.88.12300.621)
RESPONSE:
It is important to proceed with implementation as soon as possible, due to the rapidly
progressing pine beetle situation in the area. Please refer to socio/economic
discussion in the FEIS, Chapter 3, Section 3.12.
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7. THE NEZ PERCE NATIONAL FOREST SHOULD NOT IMPLEMENT THE AMERICAN AND
CROOKED RIVER PROJECT.
A. / would like to register my opposition to the Crooked/American Timber sale.
(Individual, Pullman, WA - #33.1.20000.001)
Please, as a woman, perhaps you can help to turn it around. The South fork
Clearwater project does not need more roads, more logging and more human
greed. A natural fire is eventually good for the watershed. Arson is not.
(Individual, Ukiah, CA - #13.2.20000.270)
RESPONSE:
The areas proposed for treatment are not within an area where allowing natural
fires to burn (Wildland Fire Use) is permitted by the Forest Plan and/or the Fire
Management Plan. As a result, all fire starts within the project area require
suppression responses. By carrying out fuels treatment in strategic locations, we
will be better able to safely carry out suppression tactics and protect resources
such as "at risk communities", road infrastructure, and natural resources from
negative fire effects.
0*0808
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American River/Crooked River- Final Environmental Impact Statement
B. BECAUSE THE PROPOSED PROJECT CONTRADICTS ITS OWN FOREST PLAN AND ITS
RESPONSIBILITIES UNDER THE LAW
/ wish to voice my strenuous opposition to the Crooked/American Timber Sale
proposed for the South Fork Clearwater watershed in the Nez Perce National
Forest. By proposing to build some 14 miles of new roads and log thousands of
acres in the East Fork of the American River and Kirks Fork in its draft
environmental impact statement, the Forest Service contradicts its own Forest
Plan and its responsibilities under the law. I have been informed that your
agency has refused even to analyze an alternative that does not damage
watershed through logging and road building. (Individual, Delmar, NY -
#28.1.23400.100)
RESPONSE:
This project is consistent with the Forest Plan and fully conforms to all applicable
standards and guidelines. A restoration only alternative was considered but not
analyzed in detail because it would not be responsive to the Purpose and Need
of this project.
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C. BECAUSE PUBLIC PROPERTY is NOT FOR LOGGERS
/ am writing to say I greatly oppose the logging proposed in the Nez Perce
National Forest. This is public property, not for loggers. It was set aside for
human and animal use, as so little space is, not to make the loggers rich.
(Individual, Coeur D Alene, ID - #11.1.20000.820)
RESPONSE: Comment acknowledged.
08 08 OS
D. BECAUSE THE PROJECT PROPOSES TO ENTER " ROADLESS" AREAS
/ am not in favor of this sale! The 14 miles of newly proposed road will threaten
the already sensitive watershed in an area that is already deemed "roadless".
(Individual, Moscow, ID - #23.1.20000.002)
Crooked/American timber sale apparently involves 14 miles of new road
construction and logging thousands of acres. I object to the project because it
proposes to enter the Meadow Creek Inventoried Roadless Area, which is
protected by the Roadless Rule, which the present administration is unwisely
attempting to overturn. (Individual, Minneapolis, MN - #32.1.20000.160)
RESPONSE:
We have considered the sensitivities of each watershed in the project area. No
part of this project involves the Meadow Creek Inventoried Roadless Area.
Please refer to Section 1.1 of the FEIS and Map 1 for the project area location.
080808
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American River/Crooked River- Final Environmental Impact Statement
E. BECAUSE THE PROJECT INVOLVES BUILDING NEW ROADS IN WATERSHED AREAS AND
LOGGING IN ALREADY HIGHLY " MANAGED" AREAS
/ am against the proposed management plan proposed for the South Fork of the
Clearwater. The most disturbing points of the proposed plan include building
new roads in watershed areas and potentially logging thousands of acres in an
already highly "managed" area. (Individual, Moscow, ID - #10.1.20000.247)
RESPONSE: Comment acknowledged.
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F. BECAUSE THE PROPOSED PROJECT WOULD CAUSE MORE ENVIRONMENTAL DAMAGE
THAN IT WOULD CORRECT
/ sincerely sympathize with the problem of significant fuel loading that is claimed
in the American and Crooked River systems. However, I also am deeply
concerned that the proposed cure to reduce this fire risk posses more
environmental damage than it corrects. This DEIS, as is typical of these
documents, suggest that there may be some short term watershed degradation
but promises eventual upward trend improvement in these watersheds. One has
to be extremely naive not to recognize the very likelihood that these rivers may
never recover from management decisions that remove a major quantity of the
forest canopy. Given that you are proposing to cut over 25 MMBF (Alternative C)
on approximately 2,700 acres of ground and build 15 miles of "temporary" road in
watersheds that are already suffering from past activity clearly indicates to me to
be very skeptical of such promises. (Individual, Post Falls, ID - #19.1.20000.247)
RESPONSE:
The Bonneville Power Administration funded research in Crooked River
(Intensive Evaluation and Monitoring of Chinook Salmon and Steelhead Trout
Production, Crooked River and Upper Salmon River Sites, 1995 and 1993
Annual Reports). Their work has found that in streams degraded by dredge
mining, connecting off-channel ponds to the stream can increase the carrying
capacity for Chinook salmon parr (Kiefer and Foster, 1991), and complex
instream structures can increase the carrying capacity for steelhead trout parr
(Kiefer and Lockhart, 1993). Both American River and Crooked Rivers have
been dredge mined. Past instream improvement work completed by the Nez
Perce Forest in Crooked River includes approximately 15,000 square meters of
juvenile rearing and winter habitat through side channel construction and pond
connection (P.Siddell, 1992). This work included the addition of instream
structures, which accounted for 37.4 percent of the total pool habitat in the
project area. The past work is obviously helping Crooked River recover from
past management decisions. American River has seen similar instream work
completed by the BLM.
This project will both improve on the existing in channel work and provide
additional stream reaches containing complex instream structures as well as off
channel rearing areas with the objective of increasing fish habitat carrying
capacity and leading to an upward trend in fish/water quality (FEIS, Chapter 3,
Sections 3.2, 3.3, and Appendix E).
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American River/Crooked River- Final Environmental Impact Statement
03(35(33030303
PURPOSE AND NEED
8. THE NEZ PERCE NATIONAL FOREST SHOULD RECOGNIZE THE FULL RANGE OF
PUBLIC INTERESTS AND MAXIMIZE LONG-TERM BENEFITS.
GIVEN THE ROLE OF FORESTS IN PRESERVING QUALITY OF LIFE
The U.S. National Forest System is the greatest in the world. It is the legacy of
generations that have come before us, and this present generation has the moral as
well as the legal responsibility to leave it intact for future generations. As
ecosystems all across the planet are placed under ever greater stresses, large intact
forests will play an even greater role in preserving the earth's ability to sustain a
quality of life worth living. As a citizen and tax payer, I call upon my government to
protect the public interest of the many against the greed of a few powerful insiders
who've shown they care little for any but themselves. (Individual, Delmar, NY -
#28.10.11200.060)
RESPONSE: Comment acknowledged.
OS OS (33 OS OS (33
9. THE NEZ PERCE NATIONAL FOREST SHOULD CLARIFY RELATIVE IMPORTANCE OF
SOCIAL AND SCIENTIFIC GOALS AS JUSTIFICATION FOR TIMBER HARVEST.
GIVEN PAST RELUCTANCE TO HARVEST TIMBER BASED ON CUMULATIVE WATER QUALITY
IMPACTS
Regardless of the current condition of the South Fork, the agency would say it is
somehow out of whack and prescribe logging as the cure. The simple matter of fact
is, prior to the Rey/Craig dog and pony show in Grangeville in 2003, there was no
immediate plan to log these areas, likely due to concerns over cumulative impacts on
water quality. The so-called reasons for logging are based upon politics, not
science, and that should be made clear in the DEIS as the decision to log and build
roads is a social one, not a scientific one. (Preservation/Conservation Organization,
Moscow, ID - #22.56.11000.700)
RESPONSE:
Comment acknowledged. Refer to Chapter 1 of the FEIS for an explanation of
the Purpose and Need of this project.
0* (S3 0* OS 05 05
10. THE NEZ PERCE NATIONAL FOREST SHOULD AMEND THE STATEMENT OF PURPOSE
AND NEED TO MEET KEY NATIONAL, REGIONAL AND LOCAL PRIORITIES CONCERNING
WATERSHED AND FISH HABITAT RESTORATION.
Use of the overly limited statement of purpose and need to formulate alternatives
omits key national, regional and local priorities in terms of restoring watersheds and
fisheries habitat without further ecological degradation. As we know, the upper
Columbia River basin anadromous fisheries are in steep decline and their recovery is
of paramount importance to the region. The Forest Service owns and manages most
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
of the headwaters of the Clearwater River which is critical spawning grounds for
native and anadromous fish.
The Forest Service holds a grave responsibility to the Columbia River Tribes, and to
all citizens, to do its utmost to improve spawning habitat. The federal government,
including the Forest Service, has a legal and moral obligation to do all it can to
reverse this trend to meet treaty rights and environmental laws. When fish stocks
are at such critical lows, it is the federal government's responsibility to not only
minimize the habitat degradation - but also to maximize restoration.
In fact, this is the policy adopted by the government in the salmon recovery strategy
(AII-H paper) and in the NMFS biological opinion. The government chose not to
remove the lower 4 Snake River dams at this time and instead focused on habitat.
Status quo is insufficient. (Preservation/Conservation Organization, Moscow, ID -
#22.15.32300.381)
RESPONSE:
Please refer to the fish viability/population trend analysis in Chapter 3 of the FEIS.
We agree that the status quo is not an option and this project was designed to meet
the Forest Plan objective of improving fish/water quality in streams that are below
their objective. Restoration activities are included for all watersheds within the
project area. The BLM has taken the lead for mainstem fish habitat improvements in
American River and will continue their work under proposals currently being planned
(FEIS, Chapter 3). The American and Crooked River Project includes instream work
in Crooked River and Relief Creek (23.8 mi). This work will modify and improve the
work done by the Forest Service in 1984-1988. Additional reaches will be enhanced
as well using the best available science and restoration techniques. Along with the
instream improvements will be road decommissioning, soil restoration and culvert
removal and replacements, all designed to improve fish habitat and water quality in
these important streams. Refer to FEIS, Appendix D for more information.
In addition, the Nez Perce National Forest has pursued an active and ongoing
dialogue with the Nez Perce Tribe at key points during the development of this
proposed project. Additionally, their advice and input has been sought at all phases
and is continually being incorporated into this document. Refer to the Responses to
Comments from Nez Perce Tribe, which immediately following the responses to
public comments.
C3O3 C3 O£ 03 C3
11. THE NEZ PERCE NATIONAL FOREST SHOULD BALANCE THE PROJECTS STATED
PURPOSE AND NEED WITH OTHER MANDATES IN THE FOREST PLAN REGARDING
WATERSHED AND SPECIES PROTECTION.
The project's stated purpose, to recover economic value and contribute to the
economic and social well being of local communities, needs to be balanced with
other mandates in the Forest Plan regarding watershed and species protection.
Continuing shortsighted logging and road construction in this heavily impacted area
will only exacerbate water quality and wildlife habitat problems. Unfortunately, this
project is based on short-term economics with disastrous ecological consequences,
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American River/Crooked River - Final Environmental Impact Statement
which will negatively affect the region's long-term economy.
(Preservation/Conservation Organization, Boise, ID-#15.9.20000.700)
RESPONSE:
We strongly disagree with your conclusion/prediction that there will be disastrous
ecological consequences. Please refer to the response to # 10, above. The above-
mentioned restoration work will also contribute to the economic and social well being
of the local communities both in the short term and in the long term.
With respect to wildlife species, the project actually will modestly improve habitats for
some species (elk, wolves), and may serve to reduce future risks losses of some old
growth stands in near adjacency to treatment units. In all, none of the activities
would result in adverse effects to any terrestrial federally listed species or their
habitats. Refer to the Biological Assessment for FEIS for details.
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12. THE NEZ PERCE NATIONAL FOREST SHOULD CLARIFY REASONS FOR MANAGEMENT
ACTIVITIES.
BECAUSE RISK OF FIRE is BEING FALSELY USED AS JUSTIFICATION FOR TIMBER HARVEST
/ think that our present federal administration is using the public's general belief that
forest fires are bad, to try to push through road building and timber cutting to "save"
the forests. (Individual, Loveland, CO - #12.1.10100.720)
RESPONSE: Comment acknowledged.
08 08 OS O8 08 08
13. THE NEZ PERCE NATIONAL FOREST SHOULD BE HONEST ABOUT WHY THEY ARE
LOGGING.
BECAUSE OF ECONOMIC REASONS FOR ELK CITY
/ have asked many questions in this comment letter. Perhaps many are
rhetorical. I firmly believe that this large timber sale is being proposed to feed
logs to a certain mill near Elk City. By selling this sale, the PR of the Forest
Service will be heightened in the small town of Elk City where the mill is located.
There is little doubt in my mind that log acquisition this is clearly the primary
purpose and need for this logging proposal. (Individual, Grangeville, ID -
#30.9.34000.720)
RESPONSE: Comment acknowledged
O8O8O808O808
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American River/Crooked River- Final Environmental Impact Statement
14. THE NEZ PERCE NATIONAL FOREST SHOULD NOT FALSIFY THE PURPOSE AND NEED
IN THE DEIS IN ORDER TO MAKE A PROJECT APPEAR MORE LEGITIMATE AND
ACCEPTABLE.
The way the purpose and need is written up in the DEIS, jobs and community
stability is shown as the 3 rd reason for the project in kind of an "oh by the way"
content. Job creation and community stability are actually shown as a secondary
benefit of the project to remove the fuels. You cannot have two co-purpose and
needs (fuels reduction and job creation) that are so different in their objectives. As I
said earlier, one is the purpose and need for the project, and the other is a
secondary outcome from implementing the project. You would be violating the
NEPA to call them both your primary purpose and need. I will remind you that
falsifying a NEPA purpose and need in order to make a project appear more
legitimate and acceptable to the public is a clear violation of the NEPA. (Individual,
Grangeville, ID - #30.10.20000.131)
The majority of units being ground-skidded and machine piled, gives the clear
impression that the primary objective of the project is to maximize net economic
return. It should be noted that this is not one of the stated objectives in the Purpose
and Need section. (Preservation/Conservation Organization, Boise, ID -
#15.121.20000.720)
If the Forest Service is selling the timber sale to help a small, local mill, why can't the
Forest Service tell the truth and insert this as the primary purpose and need? I am
quite certain that is the mill is in as much trouble as I have heard, the Forest Service
could easily justify a timber sale for "jobs and community stability" near Elk City.
(Individual, Grangeville, ID-#30.12.20000.820)
RESPONSE:
The purpose and need statement is balanced, clear, and consistent throughout the
development of this project. It is appropriate for conditions within the project area
and follows the Forest Plan and addresses issued raised during scoping.
One purpose of the project is to reduce current and future fuel loads within the
watersheds which are being affected by the mountain pine beetle; it is not designed
to solely reduce the risk of catastrophic wildfire to Elk City. The proposed treatments
would modify fire behavior by lowering fire intensities for fires occurring in the
treatment areas, which would help to protect resource values of all types within the
watershed such as; water quality, wildlife habitat, old growth, recreation
opportunities, and air quality as well as infrastructure investments such as roads,
bridges, campgrounds, etc. The result of having lower fire intensities would give fire
suppression resources the opportunity to utilize the treatment areas during
suppression activities, which would allow for the control of a fire at a smaller size,
less cost, and less resource loss within the watersheds.
OS O* C* 0* 0* CJ
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PROCESS AND IMPLEMENTATION CONSIDERATIONS
15. THE FINAL EIS SHOULD PROVIDE ADDITIONAL JUSTIFICATION FOR QUESTIONABLE
TIMBER HARVESTS AND ROAD CONSTRUCTION IN THE AMERICAN RlVER WATERSHED.
GIVEN RELATIVELY LOW FIRE REGIME AND POTENTIAL FOR ENVIRONMENTAL IMPACTS
FROM HARVESTS IN THE AMERICAN RIVER AREA
In looking at the sections of the DEIS addressing fire (3.4. Indicator 1-Fire Regime)
you show Table 3.37 Fire Regime Acreage in the Project Area. Reviewing this
information plus your Fire Regime maps 9A, 9B, 10A and 10B raises a big question.
That question is why are you doing the extensive logging in the American River as its
Fire Regime is almost entirely comprised of either of Infrequent, Mixed or Infrequent
to Very Infrequent, Lethal? The maps (not map 5 you refer to) corroborate this
classification although the maps describe each classification somewhat differently.
In any event, it seems the American River water shed is very different than the
Crooked River system in terms of fire risk. Fire ignitions between every 75 to 300
years in the American River do not suggest to me that this water shed is faced with
any more of a fire risk than countless other public lands that are reasonably in a state
of balance in terms of types of fuel and its risk of catastrophic fire. Obviously, even
your best-conditioned lands pose as lethal fire regimes when environmental
conditions are such as to place said land in jeopardy. Your data indicates about 43
percent of the project area is not threatened with frequent fire and yet your proposed
logging acreage is 32 per cent from this river. Why is the Nez Perce NF advocating
such extensive timber removal from an area that seems to be well within some
reasonable balance regarding fuel types and fuel loading? Considering the
previously discussed danger of further watershed habitat degradation, I have to
question the wisdom of doing that much longing and road building in an area that
does not seem to warrant such fire reduction; especially when one honestly
considers the probable down side of such activity. You do not have to log over 700
acres of the American River to protect the tow of Elk City! (Individual, Post Falls, ID -
#19.10.13110.277)
RESPONSE:
Fire regime is used as an indicator to demonstrate the historic patterns of fire and not
as design criteria for the project. The treatment units are not based on the fire
regime but are based on the need for fuels treatments in the areas of dead and dying
stands of timber. While there are areas within the project area that have historic fire
regimes of infrequent mixed and lethal regimes that would have historically burned
with severe stand replacing fires, allowing these types of fires to burn may be socially
unacceptable. If left untreated these stands of dead and dying timber will increase
the fuel loading to levels where fire suppression would be extremely difficult under
normal fire conditions due to increased fire behavior. With the increased fire
behavior comes the increased possibility of a severe fire which may degrade
resources such as water quality, habitat, air quality, etc. Additionally, by treating the
stands suppression resources will have an opportunity to safely utilize the treated
areas during the suppression activities due to lower fuel loadings and decreased fire
behavior.
CZ 08 08 C* OS <&
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American River/Crooked River- Final Environmental Impact Statement
16. THE NEZ PERCE NATIONAL FOREST SHOULD ADOPT STEWARDSHIP PRINCIPLES
WHEN IMPLEMENTING RESTORATION ACTIVITIES.
A. TO ENSURE EFFICIENT USE OF TAX DOLLARS AND BENEFIT LOCAL ECONOMIES
We encourage you to be more strategic in your planning and project design with
regard to reducing fire risks. This project seems to be more of the same that has
already occurred in the South Fork Clearwater Watershed and would not reduce
the fire risk. In order to ensure that tax dollars are wisely spent, projects should
be more strategic in terms of designing them to address fire risk, while
concurrently providing revenue to the U.S. Treasury and providing resource-
based jobs to the local communities. (Preservation/Conservation Organization,
Boise, ID - #15.108.10000.800)
RESPONSE:
Comment acknowledged. We believe this project strategically addresses fire risk
while concurrently providing local employment opportunities.
OS CSCS
B. BECAUSE PAST STEWARDSHIP PROGRAMS REVEALED THE VALUE OF SERVICES
PROVIDED
Involvement in stewardship projects has taught the Concerned Sportsmen of
Idaho members the value of including additional service component, restoration
activities in projects such as fish passage improvements. Please consider using
the proceeds of an increased timber harvest project component to fund project
service components through employment of the "goods for service" stewardship
principle. (Recreation/Conservation Organization, Viola, ID - #2.3.10000.381)
CERT members have extensive experience in failed Stewardship projects on
both Basin forests. The CERT believes that this project offers a golden
opportunity to employ "goods for services" stewardship features to accomplish
fish passage improvements and other service oriented restoration activities.
(Recreation/Conservation Organization, Moscow, ID - #1.5.20000.381)
RESPONSE: See response to 16(D).
03(3303
C. BECAUSE TIMBER HARVEST GENERATES SIGNIFICANT REVENUES
The American and Crooked River Project seems to encompass the essential
elements that would make an excellent stewardship proposal. Under the
Stewardship authorities, receipts generated from the sale of commercial products
could be retained to fund the fuel reduction and watershed improvements that
have been identified as part of this project. We urge that you consider the
potential benefits of stewardship contracting in the implementation of this project.
(Place Based Group, Lewiston, ID - #3.8.10000.835)
RESPONSE: See response to 16(D).
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D. BECAUSE SIMILAR STEWARDSHIP PROJECTS ARE LIKELY TO BE SUCCESSFUL
This [project] fits well with BLM project design in the Elk City area. It appears the
Whiskey South stewardship project will successfully proceed. The American and
Crooked River Project is of similar nature, with similar objectives. (Timber/Wood
Products Industry, Kamiah, ID - #5.19.10200.160)
RESPONSE:
It is our intent to include stewardship contracting among the implementation
options, in part to secure funding for a substantial watershed restoration
component. Refer to the tables in Appendix D and the Cost/Revenue Tables
in Chapter 3, Section 3.12.
eg 03 eg 03 eg 03
17. THE NEZ PERCE NATIONAL FOREST SHOULD CLARIFY THE ROLE OF THIS PROJECT
UNDER THE HEALTHY FOREST RESTORATION ACT (HFRA), AND DEMONSTRATE
COMPLIANCE WITH HFRA AS NECESSARY.
A. BY PERFORMING REVISED SCOPING AND ADDITIONAL COLLABORATION
Of significant concern to us is the proposed application of the project under the
so-called Healthy Forest Restoration Act of 2003 or HFRA (H.R. 1904). If this is
the intent, as described in the DEIS, the project must be scoped as such in a
revised scoping notice to all interested parties. Further, meaningful collaboration
must take place in order to ascertain whether the current design of the project
meets the direction of the HFRA. (Preservation/Conservation Organization,
Boise, ID - #15.1.10400.160)
RESPONSE:
The text has been corrected for FEIS. While this project would fit under an
authorized project for HFRA, it is not being implemented as such since the
project was scoped prior to the passage of HFRA.
CSSOSOS
B. GIVEN QUESTIONABLE REFERENCES TO THIS PROJECT AS AN HFRA APPLICATION
1. According to certain portions of the DEIS, notably on page 150, the assertion
is made that this project is considered an "authorized project" under the
Healthy Forest Restoration Act of 2003. This is inappropriate because no
mention of the project's applicability under the HFRA has been mentioned in
any previous NEPA preparation or documentation. Further, the project is not
identified in the Community Wildfire Protection Plan (Idaho County Wildland
Fire Mitigation Plan, August 2003), that was prepared prior to the passage of
the HFRA, and fails to fully meet the definition of an approved CWPP under
the HFRA. (Preservation/Conservation Organization, Boise, ID -
#15.15.10400.160)
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RESPONSE: Please refer to response to 17(A).
C8CS08
2. It is also curious that the HFRA is not listed under Section 1.4 of the DEIS
(Planning and Direction). We strongly object to the application of this project
under the HFRA for the aforementioned reasons and urge you to proceed
with the project as a "regular" timber sale project.
(Preservation/Conservation Organization, Boise, ID-#15.17.10400.160)
RESPONSE: Please refer to response to 17(A).
OS OS OJ OJ OJ O3
18. THE NEZ PERCE NATIONAL FOREST SHOULD INVOLVE THE US FISH AND WILDLIFE
SERVICE AND THE NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION IN THE
ASSESSMENT OF INDICATOR SPECIES BEFORE AND AFTER TREATMENTS.
A. BY ARRANGING FOR THESE AGENCIES TO DEVELOP A BIOLOGICAL OPINION
The Fish and Wildlife Service and NOAA Fisheries need to evaluate this
assessment in a Biological Opinion. The most appropriate species should be
selected as indicators to assess ecosystem integrity before, during, and after the
proposed treatment. The assessment should describe the effects of the
proposed activities on all forest indicator species for each treatment site.
(Preservation/Conservation Organization, Boise, ID - #15.124.10200.340)
RESPONSE:
In 1987, the current Forest Plan recognized westslope cutthroat trout,
steelhead trout and spring Chinook salmon as management indicator species
that occurred on the Nez Perce National Forest (USDA, 1987). Since then,
steelhead trout and bull trout have been listed as threatened under the
Endangered Species Act (Federal Register Vol.62, No. 159, August 18, 1997,
and Federal Register Vol. 63, No. 111, June 10, 1968).
Steelhead trout and the bull trout have both been listed as threatened under
the Endangered Species Act (Federal Register Vol. 62, No. 159, August 18,
1997 and Federal Register Vol. 63, No. 111, June 10, 1998).
In 1999, USDA Forest Service Northern Region Sensitive Species list was
updated and it now includes not only westslope cutthroat trout and spring
Chinook salmon but added to the list was interior redband trout. Redband
trout will likely be considered threatened under ESA like steelhead trout.
The management indicator species have been reviewed in relation to this
proposed project (FEIS, Section 3.3). Cumulative effects to management
indicator species and their habitats are described in the FEIS, Chapter 3.
A Biological Assessment has been completed and consultation with NOAA
Fisheries and US Fish and Wildlife Service has been conducted as required
under ESA (FEIS and ROD). A draft Biological Opinion was issued on
December 2, 2004.
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During the project planning process, the Forest Service will consult with the
Fish and Wildlife Service and NOAA Fisheries when the project has impacts
to Threatened, Endangered, and Proposed species. The Forest Service
prepares a biological assessment for Federally listed or proposed species.
The Fish and Wildlife Service prepares a biological opinion and NOAA
Fisheries when there are adverse effects to federally listed species. The Fish
and Wildlife Service and NOAA Fisheries do not consult on Forest Service
management indicator species.
B. BY CONSULTING WITH THESE AGENCIES ON SENSITIVE SALMONIDS AND PACIFIC
LAMPREY
Snake River Steelhead Trout, Columbia River Bull Trout, Snake River
Spring/Summer Chinook Salmon, Interior Redband Trout, and Westslope
Cutthroat Trout, and Pacific Lamprey all occupy the project area. Consultations
with both the NOAA Fishen'es and the U.S. Fish and Wildlife Service should be
incorporated into the EA. (Preservation/Conservation Organization, Boise, ID -
#15.131.10200.380)
RESPONSE:
NOAA Fisheries and the U.S. Fish and Wildlife Service were provided copies
of the DEIS and were asked to provide comments. In addition, both agencies
fulfilled their consultation responsibilities under the Endangered Species Act.
Biological Opinions from both Agencies are appended to the ROD for this
EIS.
0* (33 OS 08 US OS
1 9. THE NEZ PERCE NATIONAL FOREST SHOULD MANAGE THIS PROJECT JOINTLY WITH
THE EASTSIDE TOWNSHIP PROPOSED PROJECT.
BECAUSE THESE PROJECTS ARE LINKED DUE TO TEMPORARY ROAD ACCESS
The DEIS gives the impression that the Record of Decision for the Crooked-
American Project will be based in part on the temporary road access provided to
BLM parcels designated for logging in the Eastside Township proposed project. This
is inappropriate. If the projects are intricately intertwined, they should be managed
as a single project. (Preservation/Conservation Organization, Boise, ID -
#15.20.10200.170)
RESPONSE:
The American and Crooked River project and the Bureau of Land Management's
(BLM) proposed Eastside Township project are discrete projects. The two projects
are proposed under separate authorities, the National Forest Management Act and
the Healthy Forest Restoration Act, respectively. They are being planned under
different schedules. The Nez Perce National Forest is on a schedule to begin
implementing the American and Crooked River project during the spring and summer
of 2005. The BLM is currently preparing to publish a Notice of Intent and initiation of
scoping on a proposed action for the Eastside Township EIS. It is unlikely that the
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BLM would be in a position to implement its project until late 2005 or 2006. The two
projects are being planned under separate administrative and supervisory controls.
It is premature to conclude that the BLM would access their lands from temporary
roads needed to conduct proposed activities on the American and Crooked River
project because the BLM has not yet completed the analysis of alternatives for the
Eastside Township project. If the BLM needed access across Forest Service lands
in order to achieve its management objectives, it would initiate a request for a permit
to do so, regardless of Forest Service activities on adjacent lands. The BLM has not
initiated such a request.
A portion of the American and Crooked River project (the American River portion)
occurs in the same watershed as the proposed Eastside Township project but
disparities exist related to: authorities, schedules, administrative boundaries,
ownership patterns and related objectives, and administrative/supervisory controls.
Considering these factors, it is clear these two actions have independent utility.
08 eg egos eg eg
20. THE FINAL EIS SHOULD DOCUMENT COMPLIANCE WITH TRUST AND CONSULTATION
RESPONSIBILITIES TO TRIBAL TREATIES.
A. TO ENSURE THAT TREATY RIGHTS AND PRIVILEDGES ARE ADDRESSED IN
ACCORDANCE WITH EO 13175
The EIS should document that any existing treaty rights and privileges are
addressed appropriately. If the proposed project may have impacts on Tribes,
the draft EIS should describe the results of the consultation that took place with
all affected tribal governments, consistent with Executive Order (EO) 13175
(Consultation and Coordination with Indian Tribal Governments). EO 13175
states that the U.S. government will continue "to work with Indian tribes on a
government-to-government basis to address issues that pertain to Indian tribal
self- government, trust resources, and Indian tribal treaty and other rights."
(Federal Agency Official, Seattle, WA - #24.28.10300.040)
RESPONSE:
Refer to formal correspondence with the Nez Perce Tribe, immediately
following the responses to public comments section and the response to
20(B).
08 OS 0#
B. To ENSURE TRIBAL RIGHTS TO SUSTAINABLE RESOURCES FOR FISHING. HUNTING.
AND OTHER ACTIVITIES
This project does not honor legal commitments to the Nez Perce Tribal treaty
rights that are supposed to ensure a sustainable fishery. Please honor these
rights to the Tribe as well as the species that .call this roadless area home.
(Individual, Moscow, ID - #9.3.10300.150)
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RESPONSE:
The American and Crooked River Project is located within that area ceded to
the United States in 1855 by the Nez Perce people. The Treaty was
subsequently ratified by Congress and proclaimed by the President in 1859.
Although the Forest Service, through the Secretary of Agriculture, is vested
with statutory authority and responsibility for managing resources of the
National Forests such as areas within the project area, no sharing of
administrative or management decision-making power is held with the Nez
Perce Tribe. However, commensurate with the authority and responsibility to
manage resources, is the obligation to consult, cooperate and coordinate with
the Nez Perce Tribe in developing and planning projects within the project
area, and on other areas of National Forest system land, that may affect tribal
rights.
As a result of the 1855 Treaty, elements of Nez Perce culture such as tribal
welfare, land and resources were entrusted to the United States government.
Trust responsibilities resulting from the Treaty dictate, in part, that the United
States government facilitate the execution of treaty rights and traditional
cultural practices of the Nez Perce Indians by working with them on a
government to government basis in a manner that attempts a reasonable
accommodation of their needs, without compromising the legal positions of
the Nez Perce Tribe or the Federal government. Because tribal trust
activities often occur in common with the public, the Nez Perce National
Forest strives to manage Nez Perce ceded land in favor of the concerns of
the Nez Perce Indians, as far as is practicable, while still providing goods and
services to all the people.
Specific Nez Perce treaty rights applicable to the American and Crooked
River project area and other areas managed by the Nez Perce National
Forest are generally articulated in Article III of the 1855 Treaty, and include:
"The exclusive right of taking fish in all the streams where running
through or bordering said reservation is further secured to said
Indians; as also the right of taking fish at all usual and accustomed
places in common with citizens of the Territory; and of erecting
temporary buildings for curing, together with the privilege of
hunting, gathering roots and berries, and pasturing their horses
and cattle upon open and unclaimed land."
Although the 1855 Treaty does not specifically mandate the federal
government to manage habitats, there is an implied assumption that an
adequate reserve of water be available for executing treaty related hunting
and fishing activities.
Treaty rights as well as implied rights applying to grazing and wildlife habitat
are incorporated into the Nez Perce Forest Plan. Forest Plan Amendment #7
addressed Tribal concerns with the Plan about monitoring and mitigation of
impacts on elk and their habitats. Compliance with the Forest Plan and its
subsequent amendments by the American and Crooked River Project
presumes that compliance with trust and treaty responsibilities is incorporated
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area. Refer to FEIS, Chapter 1, Section 1.5
Please refer to the Purpose and Need and Forest Plan direction from the FEIS,
Chapter 1 , Section 3. The Forest Plan and Fire Management Plan currently do
not allow for Wildland Fire Use (WFU) within any portion of the project area.
Without the authority for WFU, all fire ignitions within the project area require a
suppression response and can not be allowed to play its natural role.
C. BY REMOVING IMPEDIMENTS TO NATURAL RECOVERY
Goals for the area include fully functioning stream ecosystems that include healthy,
resilient populations of native trout and salmon. The highest priority management
actions in the project area are those that remove impediments to natural recovery.
The task of management should be the reversal of artificial legacies to allow
restoration of natural, self-sustaining ecosystem processes. If natural disturbance
patterns are the best way to maintain or restore desired ecosystem values, then
nature should be able to accomplish this task very well without human intervention
(Frissell and Bayles, 1996). That is why we requested a real restoration alternative
that did not log or build roads.
We conclude this section of the comment letter with this passage from Frissell and
Bayles (1996):
Most philosophies and approaches for ecosystem management put forward
to date are limited (perhaps doomed) by a failure to acknowledge and
rationally address the overriding problems of uncertainty and ignorance about
the mechanisms by which complex ecosystems respond to human actions.
They lack humility and historical perspective about science and about our
past failures in management. They still implicitly subscribe to the scientifically
discredited illusion that humans are fully in control of an ecosystemic
machine and can foresee and manipulate all the possible consequences of
particular actions while deliberately altering the ecosystem to produce only
predictable, optimized and socially desirable outputs. Moreover, despite our
well-demonstrated inability to prescribe and forge institutional arrangements
capable of successfully implementing the principles and practice of integrated
ecosystem management over a sustained time frame an at sufficiently large
spatial scales, would-be ecosystem managers have neglected to
acknowledge and critically analyze past institutional and policy failures.
(Preservation/Conservation Organization, Moscow, ID -#22.58.1 1200.330)
They say we need ecosystem management because public opinion has changed,
neglecting the obvious point that public opinion has been shaped by the glowing
promises of past managers and by their clear and spectacular failure to deliver on
such promises. (Preservation/Conservation Organization, Moscow, ID -
#22.59.11200.330)
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area. Refer to FEIS Chapter 1, Section 1.5.
Please refer also to the Purpose and Need and Forest Plan direction from the
FEIS Chapter 1, pages 2-7.
as as as c# os ea
124. The Nez Perce National Forest should consider naturally occurring
ecosystem function.
A. TO EXAMINE DISEASE ORGANISMS
Some spec/es of frees, native insects, and disease organisms are often
described by the FS as invasive" or somehow bad for the ecosystem. Such
contentions that conditions are somehow "unnatural" runs counter to more
enlightened thinking on such matters. For example, Harvey et al, 1994 state:
Although usually viewed as pests at the tree and stand scale, insects and
disease organisms perform functions on a broader scale.
Pests are a part of even the healthiest eastside ecosystems. Pest roles-such as
the removal of poorly adapted individuals, accelerated decomposition, and
reduced stand density-may be critical to rapid ecosystem adjustment
In some areas of the eastside and Blue Mountain forests, at least, the
ecosystem has been altered, setting the stage for high pest activity (Cast and
others, 1991). This increased activity does not mean that the ecosystem is
broken or dying; rather, it is demonstrating functionality, as programmed during
its developmental (evolutionary) history. (Preservation/Conservation
Organization, Moscow, ID-#22.42.32510.370)
RESPONSE:
This project is treating less than 9 percent of the analysis area. The disturbance
process of insect infestation is occurring on many of the untreated acres. The
natural fire process is likely to occur on the untreated areas. There are also
more than a million acres in wilderness and many thousands of acres in roadless
areas that have not been managed and are in a natural state (excluding fire
suppression).
This project responds to public input received from people who use and reside
within the project and surrounding area. Please review the purpose and need
and forest Plan direction from the DEIS Chapter 1 pages 2-7.
080*08
B. BECAUSE INSECT INFESTATION AND FIRE ARE PART OF THE NATURAL STAND
REPLACEMENT CYCLE
The presence of some percentage of dying or at risk trees is not sufficient as a
reason to log the entire stand. Not all Lodgepole Pine trees will succumb to the
Mountain Pine Beetle and those that survive could potentially provide a genetic
resistance to beetle in the future. This genetic resistance to beetles would be
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lost if the trees were logged. (Preservation/Conservation Organization, Boise,
ID-#15.14.34000.373)
We are concerned with the statement that currently uninfected but "high risk"
trees would be harvested given the fact that, "There is little opportunity to further
prevent additional mountain pine beetle Lodgepole pine mortality in the Red
River, Crooked River, and American River watersheds (Red River Salvage EA.
p. 1). This statement is based solely on short-term economic goals and has no
ecological value: Mountain pine beetles prefer larger-diameter Lodgepole pine,
implying that all larger trees could be harvested. Further, according to
discussions with leading forest pathologists, it is impossible to predict where
Mountain Pine Beetles will go, and therefore these stands should not be logged.
(Preservation/Conservation Organization, Boise, ID-#15.116.34000.373)
RESPONSE:
This project is treating less than 9% of the analysis area. The disturbance
process of insect infestation is occurring on many of the untreated acres. The
natural fire process is likely to occur on the untreated areas. There are also
more than a million acres in wilderness and many thousands of acres in roadless
areas that have not been managed and are in a natural state (excluding fire
suppression)
Trees are prescribed to be left in all stands if still alive to meet green tree
replacements for snags. If the trees have dwarf mistletoe they are to be removed to
prevent infection of the regeneration. I have seen no literature on genetic resistance
to beetle. The beetle epidemic currently covers- the entire analysis area and the
majority of high risk stands have mortality.
O3 OSOSCSOSOS
125. The Nez Perce National Forest should use best available science to define
historical ranges of variability (HRV) and to justify characterizations of
current forest conditions and disturbance regimes.
A. BY ADHERING TO NATIONAL FOREST MANAGEMENT ACT (NFMA) DEFINITIONS OF
" RANGE OF VARIATION"
It becomes very difficult to subscribe to the DES arguments when the definitions are
not precise. For this discussion, let us use a definition of range of variability as found
in the 20(X) NFMA regulations (currently in stasis due to the administration's
politics). The definition may be instructive to the writers of the DES. Range of
variability is defined here at Sec. 21936 as:
"The expected range of variation in ecosystem composition, and structure that would
be expected under natural disturbance regimes in the current climatic period. These
regimes include the type, frequency, severity, and magnitude of disturbance in the
absence of fire suppression and extensive commodity extraction."
Current climatic period is further defined as:
"The period of time since establishment of the modem major vegetation types, which
typically encompass the late Holocene Epoch including the present, including likely
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climatic conditions within the planning period. The climatic period is typically
centuries to millennia in length, a period of time that is long enough to encompass
the variability that species and ecosystems have experienced." (Id.)
To paraphrase the definition, for a project to claim that an area is outside of the
range of variability, according to the 2000 NFMA definition, it would need to make the
case that the area has not seen current conditions in a length of time encompassing
the late Holocene Epoch- a period of centuries to millennia in length. The DEIS
utterly fails to make the case that the current vegetative condition failed to exist at
any time within the late Holocene Epoch. (Preservation/Conservation Organization,
Moscow, ID - #22.33.13100.133)
RESPONSE:
A characterization of range of variability within a given time scale requires historical
data with enough statistical integrity to be meaningful. Although there are a few
historical records mostly in narrative form, comparing those records with the current
data set is arbitrary at best due to changing definitions of terms. At best, those
records extend back to 1860. Therefore, to attempt to manage within the range of
the Holocene Epoch would encompass such fluctuation and variability as to be
meaningless. This project is not based on range of variability and does not rely on
conjecture as to the former vegetative state of the area. Instead, the treatments
proposed are designed to promote the health and vigor of timber stands and improve
the environment for long-lived, fire resistant species.
OS 0*0*
B. BY RECOGNIZING THAT DEFINITIONS OF HRV SHOULD BE BASED ON DATA FROM
EXTENDED TIME PERIODS
In the mid-1800s, the event known as the Little Ice Age was ending. It may be that
climatic change made conditions for fires like those in the early 1900s which to occur
and become the major determinants of the landscape of today. It is also possible
that fires like those in the past century occurred on more than one occasion since the
retreat of the glaciers. Paleoecological research shows the importance of climate
change in governing vegetation (Webb and Bartlein 1992).
Vegetation changes seem to lag behind climate change (Johnson et a/. 1994).
When looking at the bigger picture that takes into account climatic shins, and not
some narrow, snapshot-in-time view, the concept of a normal fire frequency may not
be valid. (Walder 1995). Research being conducted by Grant Meyer and others on
the Boise National Forest shows this to be the case. In that case, it appears big
stand replacing events occurred in ponderosa pine forests between 900 and 1200
due to climatic conditions.
Given climate change and the very real possibility that site potential for various types
have changed (soil pH and chemistry, moisture, soil temperature) because of it, the
view of HRV on anything less than a time scale that takes into account climate shifts
may be inadequate. That is especially true given the dramatic and scientifically
documented increases in global temperature over the past few years. The past
decade was the warmest on record. Again, the DEIS and supporting documents do
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not define the HRV so it is impossible to assess the assumptions behind the HRV,
(Preservation/Conservation Organization, Moscow, ID -#22.36.13100.260)
The DEIS's apparent definition of HRV seems very narrow, without conclusive
justification and focusing mainly on ponderosa pine types. The SFLA notes much of
the analysis area is outside the HRV and the DEIS implies this is because of fire
suppression (NOTE: The SFLA is not completely clear on the current conditions and
their causes, there is equivocation and inconsistency in that document) yet it would
seem the DEIS maintains that the big fires of the early 1900s, natural events as far
as we know, put this area outside the HRV. Thus, it would appear the HRV ought to
be able to account for these events. (Preservation/Conservation Organization,
Moscow, ID - #22.34. 13100.277)
What range of time is being used to determine HRV and is it long enough to be
accurate? What proof is there to refute scientific findings that forest conditions in
1850 or 1900 were only a few frames and not representative of an ecological
perspective that should be from two to three thousand years in length (see Walder
1995 and Johnson et. al 1994)?
The steady-state theory of ecology is inappropriate for time scales more than 200
years in length. (Webb and Bartlein 1992) Certainly, the goal is to have national
forests in perpetuity. A time frame of 200 years only takes us back to Lewis and
Clark, a time not so distant when the Nez Perce National Forest was considered
pad of the public domain of the USA by the federal government (though disputed
with the British) just as it is today. (Preservation/Conservation Organization,
Moscow, ID - #22.35. 13100.330)
RESPONSE
Refer to response to comment 125. A review of recent literature which
documents vegetative changes during the Holocene Epoch (Brunelle and
Whitlock, 2002; Mayewski, et al, 2004; Davis et al; 2002) that wide fluctuations
have occurred in species composition, density, and fire regimes. The purpose
and need (Section 1 .3) does not use HRV as an analysis parameter.
C. BY DESCRIBING THE FACTORS. SUCH AS FIRE AND INSECTS. ASSUMED TO BE AFFECTING
STRUCTURAL CONDITIONS OVER TIME.
Any forest condition that is maintained through intense mechanical manipulation is
not maintaining ecosystem function. We request site-specific disclosure of the
historical data used to arrive at any assumption of "desired conditions." We don't
believe the proposed management activities are designed to foster the processes
that naturally shaped the ecosystem and resulted in a range of natural structural
conditions, they are merely designed to recreate what the agency believes were
structural conditions in a single point in time that the FS considers "natural."
Generally, past process regimes are better understood than past forest structure.
How are you factoring in fire, insects, tree diseases, and other natural disturbances
in specifying the structural conditions you assume to be representative of the historic
range? (Preservation/Conservation Organization, Moscow, ID -#22.38.13100.330)
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area (refer to FEIS, Chapter 1, Section 1.5.
Please review the purpose and need and forest Plan direction from the FEIS
Chapter 1, Section 3.
as as as os os os
126. The Final EIS should define the terms "dying" and "at risk".
The FE/S needs to clearly define the following terms: "dying" and "at risk to Mountain
Pine Beetle attack" (Page III). (Preservation/Conservation Organization, Boise, ID -
#15.13.21100.001)
RESPONSE:
The term "dying" refers to the cessation of transport of water and nutrients within a tree.
The first sign of beetle-caused mortality is generally discolored foliage. Needles on
successfully infested trees begin fading and changing color several months to 1 year
after the trees have been attacked. The needles change from green to yellowish green,
then sorrel, red, and finally rusty brown. Fading begins in the lower crown and
progresses upward. Besides having pitch tubes, successfully infested trees will have dry
boring dust, similar to fine sawdust, in bark crevices and around the base of the tree.
Sometimes, however, infested trees can have boring dust, but not pitch tubes. These
trees, called blind attacks, are common during drought years when trees produce little
pitch. When the beetles attack, they carry blue-staining fungi into the tree. After one to
several months, the sapwood begins to discolor.
The term "at risk to Mountain Pine Beetle attack" refers to any species of pinus. In the
American and Crooked River project area the majority of the pinus is lodgepole pine.
Beetles usually select larger lodgepole pines that have thick phloem. They need
adequate food, found in large- diameter trees, for their population to build up. After the
larger lodgepole pines are killed, beetles infest smaller and smaller trees, where phloem
is thin and excessive drying occurs. Beetle populations then decline to endemic levels.
High-risk lodgepole pine stands have an average age of more than 80, an average
diameter at breast height of more than 8 inches (20 cm), and a suitable climate for
beetle development based on elevation and latitude.
In second-growth ponderosa pine, high-risk stands have a high stand basal area, a
single story, and an average diameter at breast height more than 10 inches (25 cm).
03 03 O3 OS OS OS
Timber Management
127. The Nez Perce National Forest should not harvest timber.
A. In particular, I oppose plans to log in the East Fork of the American River and
Kirks Fork. (Individual, Seattle, WA - #8.2.34000.001)
I am of the opinion that logging will continue to damage this area. (Individual,
Minneapolis, MN - #17.2.34000.200)
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We believe that the large amount of road construction and salvage harvests
proposed are completely inappropriate given the degraded condition of this
drainage. (Preservation/Conservation Organization, Boise, ID
#15.2.34000.247)
RESPONSE:
The proposed logging in the American and Crooked River project is one method
which can be used to respond to the Purpose and Need (refer to FEIS, Chapter 1,
Section 1.3). Briefly, the purpose of the project is to reduce existing and potential
forest fuels, create conditions that will contribute to sustaining long-lived fire tolerant
tree species (ponderosa pine, western larch) and contribute to the economic and
social well-being of people who use and reside within the surrounding area.
The analysis of each alternative displays the effects to various resources.
Standards and guidelines from the Forest Plan will maintain effects within
accepted limits of change (refer to Regulatory Framework. The proposed -
restoration projects and mitigations will offset any potential damage from logging
and result in an upward trend for the watersheds as a whole.
0*050*
B. BECAUSE TIMBER HARVESTING AND ROADBUILDING DESTROY THE ECOSYSTEM
1. Road building and logging destroy ecosystems. (Individual, Loveland, CO -
#12.4.34000.201)
RESPONSE:
Analysis of the effects of the proposed actions on various resources
demonstrate that the project will help restore landscape patterns which have
been fragmented from past actions. Ecosystem processes and functions will
remain intact.
With respect to terrestrial wildlife, some of the impacts to wildlife will be
positive including improvement of elk habitat effectiveness. Reductions in
miles of road, which is also part of this project, will offer restorative habitat
quality improvements for other species as well.
of this project, will offer restorative habitat quality improvements for other
species as well.
0*0*0*0*0*0*
2. / understand that the Forest Service is proposing to build some 14 miles of
new roads and log thousands of acres. The Forest Service has good
intentions to help improve the watershed, and I think that other options need
to be considered before logging. Please don't let the road-building and
logging take place. (Individual, Pullman, WA - #33.2.34000.247)
RESPONSE: Comment acknowledged
0*0*0*
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C. BECAUSE TIMBER HARVESTING SPEEDS UP THE PROGRESS OF FIRE AND COMPROMISES
SOIL QUALITY
Logging the biggest and strongest trees speeds up the progress of a fire and
compromises soil quality. (Individual, Loveland, CO-#12.2.34000.002)
RESPONSE:
The biggest, strongest trees which appear to be most resistant to effects of a
changing climate are the trees that will remain in the treated areas. Refer to the
objectives portion of Chapter 1, Section 1.3.
O8C8O8
D. BECAUSE TIMBER HARVESTING DOES NOT REDUCE FIRE DANGER
/ invite you to review the quotes I have supplied in the Appendix [ATTMT:1].
Some are from government documents and some are from environmental
groups. All are valid. They all relate to why logging, timber harvest, and
mechanical fuel removal actually increase the fire risk in the forest. I will expect
a response to each quote in our FEIS telling me: 1) why the quote does not
apply to your project, and/or, 2) why the science (which was the basis for the
quote) is incorrect. All of the quotes say that logging large commercial sized
stems does not reduce fire danger. In fact, some of the quotes say that due to
the small activity fuels left after logging, commercial logging actually increases
fire danger. (Individual, Grangeville, ID-#30.13.34000.270)
The activities (road construction and salvage harvest) described do little to
protect homes and communities from fire in any meaningful way, and may in
fact exacerbate fire danger, severity and intensity. (Preservation/Conservation
Organization, Boise, ID - #15.4.34000.271)
RESPONSE:
This project's purpose is to reduce fuels at the individual treatment site and also
at the watershed levels. Other projects such as Crooked River Defensible Space
are designed specifically to protect structures. The way this project is designed it
will help to protect other critical resources such as wildlife habitat, water quality,
recreation opportunities, and infrastructures such as roads and bridges to name
a few.
08 IDS (!S O* (SS (S3
128. The Nez Perce National Forest should harvest timber.
A. BECAUSE WILDLAND FIRE CAN LEAD TO INCREASED SEDIMENT LOADS
/ understand some sediment may find its way into the creeks and rivers from the
logging and road building. This situation is only short-term, however, and is
much preferred to the stream-choking mud slides that frequently happen after a
wildfire burns off the vegetation and sterilizes the soil. (Individual, Lewiston, ID -
#7.2.34000.230)
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RESPONSE:
Comparing the sediment produced by road building and harvest to sediment
from a potential wildfire is a complicated task. Some of the factors that need to
be considered:
• Logging and harvest effects are relatively known quantities, predictable in
extent, time and location. Severe storm years can heighten impacts of
logging and road building. Permanent roads do produce peak sediment for
a few years after construction, and continue to produce chronic levels of
sediment throughout their life. Sediment from most harvest units typically
declines to negligible after 5 years (Cline, et a/, 1981). Modeled effects of
sediment due to past wildfires, road building and logging are shown in the
watershed section of the FEIS. These estimates indicate that although peak
sediment from fires was high, chronically elevated sediment from roads
continues to affect watersheds in the project area.
• Sediment effects from any particular fire are influenced by fire size,
severity, and location, interaction with existing road systems or susceptible
soils, and intense storms or rapid spring runoff during the 1-10 years
following wildfire (Wondzell and King 2003). Large severe fires in the
project area occur under a combination of drought, high temperatures, low
humidity, and strong winds (Schoennagel et a/., 2004). Under these
conditions, scattered fuel treatments may have slight effects on overall fire
size and severity. This means that such a fire could occur even with the
proposed harvest, so effects of fire might not be averted by harvest and
road building, but compounded.
• Under more moderate burning conditions, fires could be more easily
suppressed, and potential fire size reduced, by using harvest areas as
control points and fuel breaks. This is part of the rationale for the proposed
harvest and fuel reduction. See Section 3.4.2.
• Effects on streams from fires and road building are complex in time and
space. Road building generally produces fine sediments, and may little
affect flow quantity, so that streambeds are more susceptible to filling of
pools and spawning gravels with sand and silt. Fire effects on streams can
vary from negligible to dramatic, short-lived to long term. Aquatic
researchers now acknowledge the important role of natural wildfires in
structuring stream habitats, providing not only fine sediments, but also large
wood and large sediments (Bisson et a/., 2003). Fires also may result in
increased flows that arrange these materials in the stream to build pools and
spawning gravels. Some effects can be negative, especially considered
over the short term, when individual fish may be killed, fine sediments
increased, or channels scoured in tributaries.
OS 03 03
B. BECAUSE IT WILL ASSIST THE LOCAL ECONOMY
The logging will add to the local economy and provide enough lumber to build
some 1,500 average-sized family homes. (Individual, Lewiston, ID -
#7.4.34000.814)
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We believe cut levels can be increased to better accomplish project objectives,
and improve the economics of the project. (Timber/Wood Products Industry,
Kamiah, ID-#5.18.34300.800)
RESPONSE: Comment acknowledged
C. BECAUSE TIMBER HARVESTING INCREASES OPENINGS AND CREATES BIG GAME FORAGE
The Concerned Sportsmen of Idaho believes that more trees could and should
be harvested to increase the openings in closed forest canopy areas so that
grasses, forbs and brush can be grown to create much-needed elk forage.
(Recreation/Conservation Organization, Viola, ID - #2.2.34300.330)
RESPONSE:
There are a number of issues and considerations that had to be integrated into
the proposal to limit impacts on resources. The increased habitat effectiveness
resulting from overall reduction in miles of open roads and reduced human
disturbances will benefit elk.
C8C8CS
D. TO EXPAND TIMBER VOLUME FOR BIG GAME
1. The timber harvest units remove only an average of 8.6 MBF/acre, bringing
into question whether enough volume is being removed to open crown
canopies to sufficiently reduce competition and encourage big game forage
production. We further question if the removal of only 1.3 MBF/acre in the
roadside salvage will accomplish objectives. (Timber/Wood Products
Industry, Kamiah, ID - #5.8.34300.330)
RESPONSE:
The intensity of planned harvests along with liberal use of prescription fire
afterward, will serve to stimulate resprouting and growth of additional nutritious
forage for big game in most units. In the roadside salvage, the more limited
removal of standing timber was planned in part, to incorporate some protection
for minimal amounts of hiding cover along roads which would generate additional
forage without sacrificing large amounts of hiding cover adjacent to roads.
esses cs
2. While creating elk forage on the spectrum of range referred to above, the
CERT (Clearwater Elk Recovery Team) encourages you to expand the
timber volume taken so as to insure [sic] that openings in the forest are
numerous enough to accomplish the task for depleted elk herds while
remaining within Forest Plan old growth standards.
(Recreation/Conservation Organization, Moscow, ID - #1.4.34300.350)
RESPONSE:
A number of issues and considerations had to be integrated into the proposal,
not just producing elk forage. The intensity of planned harvests along with liberal
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American River/Crooked River- Final Environmental Impact Statement
use of prescription fire afterward, will serve to stimulate resprouting and growth of
additional nutritious forage for big game in most units. Forest plan old growth
standards for old growth will be met.
(33 US (33 (S3 (38 (33
129. The Nez Perce National Forest should consider research that addresses
timber harvest.
A. BECAUSE RESEARCH ADDRESSES POST-HARVEST SLASH DISPOSAL
Research from the Hayman Fire (2002) has determined that pine needles, if not
burned by the fire, can provide significant protection to the soil surface when
they fall to the ground (Interim and Final Hayman Fire Case Study Analyses,
2002 & 2003). By applying regeneration harvests, the beneficial impact of this
material is not realized. Instead, slash is deposited on the ground and burned in
piles, thereby vastly increasing the potential for soil erosion and subsequent
sedimentation of critical spawning habitat forESA listed species.
Post-logging slash disposal is critical and a number of factors should be
considered in the project design and implementation. Machine and jackpot burn
piles restricted, and if necessitated, should be evenly distributed throughout
logging units. Large piles create excessive heat, create potassium and nitrogen
overloading in small areas, and can negatively impact soil resources. Smaller
piles, evenly distributed, or broadcast burning is preferred. However, the
burning of these materials still can contribute to significant erosion problems on
the forest. (Preservation/Conservation Organization, Boise, ID -
#15.105.34400.201)
RESPONSE:
Design criteria will be incorporated into silvicultural prescriptions, which will
include the method/amount of retention and/or removal of materials. In addition,
contract clauses will include design criteria that limit the size, location, and
structure of piles. Furthermore, site-specific burn plans will be developed for
each burn unit. This will include pre-ignition analysis of factors such as wind
speed, humidity, temperature, slope, aspect and duff moisture. Ignitions
performed under these conditions would limit the detrimental effects to residual
stands and the soil resource.
Post harvest slash disposal, broadcast and jackpot burning, is typically
accomplished during times of the year when duff moistures are high enough to
prevent the total consumption of the duff. The duff that remains provides soil
protection against runoff, and continues to provide nutrient cycling to the soil.
Machine piles located within the unit are typically smaller in size and distributed
fairly evenly throughout the units.
(33(33(33
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B. BECAUSE RESEARCH INDICATES TIMBER HARVESTING. ROADS. AND OTHER HUMAN
DISTURBANCES PROMOTE THE SPREAD OF TREE DISEASE AND INSECT INFESTATION
The FS often makes a case for logging as a way to reduce insect and disease
damage to timber stands As far as we are aware, the FS has no empirical
evidence to indicate its "treatments" for "forest health" decrease, rather than
increase, the incidence of insects and diseases in the forest. Since the FS
doesn't cite research that proves otherwise in this DEIS we can only conclude
that "forest health" discussions are unscientific and biased toward logging as a
"solution." Please consider the large body of research that indicates logging,
roads, and other human caused disturbance promote the spread of tree
diseases and insect infestation.
For example, multiple studies have shown that annosus root disease
(Heterobasidion annosum, formerly named Fomes annosus), a fungal root
pathogen that is often fatal or damaging for pine, fir, and hemlock in western
forests, has increased in western forests as a result of logging (Smith 1989).
And researchers have noted that the incidence of annosus root disease in true
fir and ponderosa pine stands increased with the number of logging entries
(Goheen and Goheen 1989). Large stumps served as infection foci for the
stands, although significant mortality was not obvious until 10 to 15 years after
logging (Id).
The proportion of western hemlock trees infected by annosus root disease
increased after pre-commercial thinning, due to infection of stumps and logging
equipment wounds (Edmonds et al 1989, Chavez, et al. 1980).
Armillaria, a primary, aggressive root pathogen of pines, true firs, and Douglas-
fir in western interior forests, spreads into healthy stands from the stumps and
roots of cut trees (Wargo and Shaw 1985). The fungus colonizes stumps and
roots of cut trees, then spreads to adjacent healthy trees. Roots of large trees
in particular can support the fungus for many years because they are moist and
large enough for the fungus to survive, and disease centers can expand to
several hectares in size, with greater than 25% of the trees affected in a stand
(id) Roth et al. (1980) also noted that Armillaria was present in stumps of old-
growth ponderosa pine logged up to 35 years earlier, with the oldest stumps
having the highest rate of infection.
Filip (1979) observed that mortality of saplings was significant correlated to the
number of Douglas-fir stumps infected with Armillaria me/tea and laminated root
rot (Phellinus weirii). McDonald, et al. (1987) concluded the pathogenic fungus
Armillaria had a threefold higher occurrence on disturbed plots compared to
pristine plots at high productivity sites in the Northern Rockies. Those authors
also reviewed past studies on Armillaria, noting a clear link between
management and the severity of Armillaria-caused disease.
Morrison and Mallett (1996) observed that infection and mortality from the root
disease Armillaria ostoyae was several times higher in forest stands with
logging disturbance than in undisturbed stands, and that adjacent residual trees
as well as new regeneration became infected when their roots came into
contact with roots from infected stumps.
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Pre-commercial thinning and soil disturbance led to an increased risk of
infection and mortality by black- stain root disease (Leptographium wageneri) in
Douglas-fir, with the majority of infection centers being close to roads and skid
trails (Hansen et al. 1988) Also another Black-stain root disease (Verticicladiella
wagenerii) occurred at a greater frequency in Douglas-fir trees close to roads
than in trees located 25 in or more from roads (Hansen 1978). Witcosky et al.
(1986) also noted that pre-commercially thinned stands attracted a greater
number of black-stain root disease insect vectors.
Complex interactions involve mechanical damage from logging, infestation by
root diseases, and attacks by insects. Aho et al. (1987) saw that mechanical
wounding of grand fir and white fir by logging equipment activated dormant
decay fungi, including the Indian paint fungus (Echinodontium tinctorium).
Trees stressed by logging, and therefore more susceptible to root diseases are,
in turn, more susceptible to attack by insects. Goheen and Hansen (1993)
reviewed the association between pathogenic fungi and bark beetles in
coniferous forests, noting that root disease fungi predispose some conifer
species to bark beetle attack and/or help maintain endemic populations of bark
beetles.
Goheen and Hansen (1993) observed that live trees infected with Laminated
root rot (Phellinus weirii) have a greater likelihood of attack by Douglas-fir
beetles (Dendroctonus pseudotsugae). Also, Douglas- fir trees weakened by
Black-stain root disease (Leptographium wageneri var. pseudotsugae) are
attacked and killed by a variety of bark beetle species, including the Douglas-fir
bark beetle (D. pseudotsugae) and the Douglas-fir engraver (Scolytus
unispinosis) (id.).
The root disease Leptographium wageneri var. ponderosurn predisposes
ponderosa pine to several bark beetle species, including the mountain pine
beetle (D. ponderosae) and the western pine beetle (D. brevicomis) (Goheen
and Hansen 1993).
A variety of root diseases, including black-slain, Armillaria, and brown cubical
butt rot (Phaeolus schweinitzii). predispose lodgepole pine to attack by
mountain pine beetles in the interior west The diseases are also believed to
provide stressed host trees that help maintain endemic populations of mountain
pine beetle or trigger population increases at the start of an outbreak (Goheen
and Hansen 1993).
Grand and white fir trees in interior mixed-conifer forests have been found to
have a high likelihood of attack by the fir engraver (Scolytus ventralis) when
they are infected by root diseases, such as laminated root rot, Armillaria, and
annosus (Goheen and Hansen 1993).
More western pine beetles (Dendroetonus breviformis) and mountain pine
beetles (D. ponderosae) were captured on trees infected by black-stain root
disease (Ceratocystis wageneri) than on uninfected trees (Goheen et al. 1985).
The two species of beetle were more frequently attracted to wounds on trees
that were also diseased than to uninfected trees. They also noted that the red
turpentine beetle (Dendroctonus valens) attacked trees at wounds, with attack
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American River/Crooked River - Final Environmental Impact Statement
rates seven-to-eight times higher on trees infected with black-stain root disease
than uninfected trees. Spondylis upiformis attacked only wounded trees, not
unwounded trees. (Preservation/Conservation Organization, Moscow, ID -
#22.46.34000.373)
RESPONSE:
Comment acknowledged.
The stands proposed for treatment are susceptible and contain some of the
pathogens and insects described. Most have a negative growth value (more dying
than growing) and are in a state of decline. The purpose of the project is to reduce
existing and potential forest fuels, create conditions that will contribute to sustaining
long-lived fire tolerant tree species (ponderosa pine, western larch). Refer to FEIS,
Chapter 1, Section 1.3. Ponderosa pine and western larch are the forest tree
species most resistant to fire, insects, and diseases found in the project area.
0$ 0* 080* (IS 03
130. The Nez Perce National Forest should focus on stands farthest outside the
historic range.
The Forest Service should focus on those stands that are the farthest outside of the
historic range (i.e. the 3.2% of the project area that exhibits frequent, non-lethal fire
regimes). (Preservation/Conservation Organization, Boise, ID - #15.96.33000.277)
RESPONSE:
Comment acknowledged. Historic range is a concept based on scale (e.g., temporal
and spatial). Only focusing only on the stands that are farthest outside of their
historic range would not fulfill the purpose of this project - which is related to reducing
existing and potential forest fuels by removing the dead, dying, and downed trees
that would otherwise result in high fuel loadings
o* us e* Q& oa <&
131. The Nez Perce National Forest should conduct an inventory of the types
and sizes of downed woody material.
Fallen snags that lean against other trees serve as important subnivean access points
for mesocarnivores such as Fisher and American Marten. An inventory of the types and
sizes of downed woody material should be included in the treatments.
(Preservation/Conservation Organization, Boise, ID - #15.129.30100.330)
RESPONSE:
Over the next 10 years or so, many thousands of acres of unharvested lodgepole
pine will progressively convert to snags, most of which will fall, lean or "jackstraw"
forming excellent subnivean habitat. Given the vast amounts of dead and dying
lodgepole pine in the analysis area, and the fact that planned treatment acreage
would fall far short of even 10 percent of the local landscape, the growth of important
subnivean habitats formed by fallen snags from many acres of unharvested dead
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by reference to the Forest Plan. Refer to Chapter 3 of the FEIS for additional
information.
as as 05 as
-------
American River/Crooked River - Final Environmental Impact Statement
analysis identified opportunities to improve existing conditions. Decisions concerning
these opportunities, however, are left to a site-specific NEPA analysis (such as this).
(S3 (S3
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
An adequate range of alternatives was considered. A restoration only alternative
was considered but not analyzed in detail because it would not be responsive to
the Purpose and Need of this project. (Refer to FEIS, Chapter 1.)
03 03 OS (IS OS OS
24. THE NEZ PERCE NATIONAL FOREST SHOULD OBJECTIVELY COMPARE THE
ALTERNATIVES REGARDING VISUAL QUALITY OBJECTIVES.
The Forest Service needs to objectively compare the alternatives regarding visual quality
objectives. Although dead and dying trees would still remain visible with less harvesting,
the Forest Service needs to consider that when the needles drop off the red crowns will
be replaced by much /ess striking bare limbs. The Red Tree Fuels Reduction Project in
the Sawtooth NRA cites this fact as a reason to leave many stands intact. In areas that
are not logged, natural regeneration (through forest successional cycles) will also
replace the forest where trees have been killed by mountain pine beetles without the
negative association with clear-cuts. (Preservation/Conservation Organization, Boise, ID
-#15.138.23000.715)
RESPONSE:
The VQOs specified in the Forest Plan are not similar to those of the Sawtooth
National Recreation Area.
The FEIS (Chapter 3, Section 3.6), objectively compares the alternatives regarding
visual quality objectives. This project is treating less than nine percent of the
analysis area. The disturbance process of insect infestation and subsequent
mortality is occurring on many of the untreated acres and may be viewed there.
oj os os ca o» (x
25. THE NEZ PERCE NATIONAL FOREST SHOULD ADOPT AN ALTERNATIVE THAT
EMPHASIZES ECOSYSTEM QUALITY AND INTEGRITY.
Please consider an alternative that addresses diversity, quality of animal and plant
habitat, soil health, and water quality. (Individual, Moscow, ID-#23.3.23100.201)
RESPONSE:
A restoration only alternative was considered but not analyzed in detail because it
would not be responsive to the Purpose and Need of this project (FEIS Chapter 1,
Section 1.3).
The alternatives were analyzed for effects on wildlife, fish, soil conditions, and water
quality. Please see FEIS Chapter 3 - Sections 3.1-3.3 and 3.11. Forest composition
and structural diversity were addressed in the Section 3.10. Extensive design criteria
and mitigation measures (refer to Chapter 2, Table 2.1) were developed to protect
old growth, riparian areas, snags, sensitive slopes, listed, sensitive, and
management indicator species, down wood, water quality, fish habitat, and soils.
Additional soil and water improvement activities were identified which are expected
to result in improved long-term conditions for the affected watersheds, including
wildlife security as well as soil and water quality. Please see Appendix D.
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o*
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American River/Crooked River- Final Environmental Impact Statement
Thinning of ladder fuels, as called for in one of the comments, would reduce the
possibility for fire to transition from a surface to a crown fire for a short time frame.
Though as the dead and dying trees in the stands start to fall we will again have a
high potential for fire transition to occur due to the high fire intensities generated by
this type of fuel bed.
Please also refer to responses to items 7(B), 7(D) and 25.
as o*e*e#c«os
No ACTION ALTERNATIVE
28. THE NEZ PERCE NATIONAL FOREST SHOULD NOT ADOPT THE No ACTION'
ALTERNATIVE.'
BECAUSE THE NO ACTION ALTERNATIVE IGNORES WHAT CATASTROPHIC FIRE WOULD DO
TO WILDLIFE AND OTHER RESOURCES
The purpose and objectives are adequate and focused. The No Action Alternative
ignores what catastrophic fire can and would do to fish and other resources and,
therefore, does not comply with the project's purpose and objectives.
(Recreation/Conservation Organization, Moscow, ID - #1.3.23510.270)
RESPONSE: Comment acknowledged.
03 OS OS OS OJ OS
ALTERNATIVE C
29. THE NEZ PERCE NATIONAL FOREST SHOULD NOT ADOPT ALTERNATIVE C.
BECAUSE IT is TOO SIMPLISTIC AND UNDERSTATES THE DAMAGE CREATED BY THESE
PROJECTS
The public is not well served by overt emphasis put upon simplified projects to
supposedly overcome this fire problem while completely understating the
accompanying damage created by these projects. What we may well end up with is
a very good stream of timber to the timber industry (this is not to suggest that this is,
in itself, bad) while continuing to inflict near irreversible damage to other aspects of
the forest ecosystem. Until these risks are all given equal weight and are fully
disclosed to the public I am adamantly opposed to the selection of Alternative C
because it is dangerously too simplistic. (Individual, Post Falls, ID -
#19.12.23530.200)
RESPONSE:
Comment acknowledged. Alternative D is the selected alternative. This alternative
includes increased emphasis on watershed restoration.
OS O3 OS O3 OS OS
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American River/Crooked River- Final Environmental Impact Statement
ALTERNATIVE D
30. THE NEZ PERCE NATIONAL FOREST SHOULD ADOPT THE PREFERRED ALTERNATIVE
D.
A. BECAUSE ALTERNATIVE D INTEGRATES WELL WITH OTHER POTENTIAL PROJECTS ON
BLM AND PRIVATE LANDS.
The RAC (Resource Advisory Committee- North Central Idaho) endorses the
preferred alternative D, as described in the DEIS, because the alternative would
integrate well with other potential projects on BLM and private lands near Elk
City. (Place Based Group, Lewiston, ID - #3.4.23540. 100)
RESPONSE: Comment acknowledged. Please refer to response to item 29.
B. BECAUSE ALTERNATIVE D WOULD PROVIDE A HIGH LEVEL OF HAZARDOUS FUEL
REDUCTION IN CRITICAL AREAS NEAR ELK CITY
7776 RAC (Resource Advisory Committee- North Central Idaho) endorses the
preferred alternative D, as described in the DEIS, because the alternative would
provide a high level of hazardous fuel reduction in critical areas near Elk City.
(Place Based Group, Lewiston, ID - #3.1.23540.271)
RESPONSE: Comment acknowledged. Please refer to response to item 29.
csosea
C. BECAUSE ALTERNATIVE D WOULD RESULT IN LONG-TERM IMPROVEMENTS IN
ANADROMOUS FISH HABITAT AND ELK HABITAT
The RAC (Resource Advisory Committee- North Central Idaho) endorses the
preferred alternative D, as described in the DEIS, Because the alternative would
result in long-term improvements in anadromous fish habitat and elk habitat while
incorporating design elements minimizing possible short-term adverse effects to
these important resources. (Place Based Group, Lewiston, ID - #3.5.23540.300)
RESPONSE: Comment acknowledged. Please refer to response to item 29.
caches
D. BECAUSE ALTERNATIVE D WOULD PROMOTE HEALTHY FOREST AND WATERSHED
CONDITIONS
The RAC (Resource Advisory Committee- North Central Idaho) endorses the
preferred alternative D, as described in the DEIS, because the alternative would
promote healthy forest and watershed conditions. (Place Based Group,
Lewiston, ID -#3.2.23540.330)
RESPONSE: Comment acknowledged. Please refer to response to item 29.
oaosca
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American River/Crooked River- Final Environmental Impact Statement
E. BECAUSE ALTERNATIVE D WOULD CONTRIBUTE TO THE SOCIAL AND ECONOMIC
WELL-BEING OF THE LOCAL AREA
The RAC (Resource Advisory Committee- North Central Idaho) endorses the
preferred alternative D, as described in the DEIS, because the alternative would
contribute to the social and economic well-being of the local area. (Place Based
Group, Lewiston, ID - #3.3.23540.800)
RESPONSE: Comment acknowledged. Please refer to response to item 29.
oa osoao*oje*
31 . THE NEZ PERCE NATIONAL FOREST SHOULD NOT ADOPT THE PREFERRED
ALTERNATIVE D.
A. BECAUSE THE PREFERRED ALTERNATIVE D PROPOSES ACTIVITIES THAT WILL
INCREASE SHORT-TERM SEDIMENTATION
1 . The South fork of the Clearwater is listed for water temperature and sediment.
On page 89 it is noted that, "No specific targets were set for tributaries, but it
was recognized that much of the sediment yield reduction would need to take
place in the tributaries. " The Proposed Action undermines the intent and goal
of designation by proposing activities that the DEIS acknowledges will
increase short-term sedimentation. (Preservation/Conservation Organization,
Boise, ID - #15.27.23540. 137)
RESPONSE:
The implementation plan for the South Fork Clearwater River TMDLs
has not yet been developed. However, the IDEQ has recognized that
short term increases in sediment yield may be allowed in a 303(d) listed
water body listed for sediment, as long as a net decrease in sediment
yield is shown and beneficial uses are not impaired. We believe that
this Project meets these criteria. These concepts are documented in a
November 4, 2003, letter from IDEQ to the Idaho Panhandle National
Forests and in draft guidance posted on IDEQ's website on April 8,
2004.
2. We have assigned a rating of EC-2 (Environmental Concerns - Insufficient
Information) to the preferred alternative D. EPA appreciates the U.S. Forest
Service's (USFS's) efforts to minimize adverse environmental impacts from
timber harvest and commitment to working toward restoring water quality and
fish habitat in the American and Crooked Rivers. However, we are
concerned about the potential impacts of timber harvest and construction of
new roads on sediment yields to streams that are impaired from sediment
and toss of shade. (Federal Agency Official, Seattle, WA - #24. 1.23540.234)
RESPONSE:
The impacts of timber harvest and construction of new roads on
sediment yields are disclosed in Chapter 3 and Appendix E of the FEIS.
These impacts are believed to be in compliance with the Clean Water
Appendix M
Page M-25
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American River/Crooked River - Final Environmental Impact Statement
Act, Idaho State Water Quality Standards and the South Fork
Clearwater River TMDLs.
o*c«ca
B. BECAUSE THE PREFERRED ALTERNATIVE D WOULD VIOLATE FISH/WATER
QUALITY OBJECTIVES UNDER THE FOREST PLAN
Given that Bull Trout, Steelhead Trout and Chinook Salmon exist in the Rivers,
and the risk of sedimentation is high in the short-term under the proposed action,
the Proposed Action clearly does not meet the goal and intent of the Forest Plan
in this regard. The Proposed Action would also violate fish/water quality
objectives under the Forest Plan. On page 89 it is stated that, "The Plan
recognizes that many of these watersheds do not meet fish/water quality
objectives under current conditions. The Plan stipulates that an upward trend in
aquatic habitat carrying capacity be established in below objective watersheds.
This is accomplished by limiting new disturbance. By proposing new roads and
timber harvesting that will further degrade the watersheds; the project clearly fails
to limit new disturbances. Allowing short-term degradation while proposing long-
term restoration is contrary to the objectives and intent of the Plan since it clearly
states that a limitation of new disturbance is necessary. Offsets are not enough
to meet this criterion. (Preservation/Conservation Organization, Boise, ID -
#15.49.23540.160)
RESPONSE:
It has been determined that the selected alternative meets the upward trend
requirements stated in Appendix A of the Forest Plan. The rationale for this
conclusion is found in Chapter 3 and Appendix E of the FEIS.
C. BECAUSE THE PREFERRED ALTERNATIVE D WOULD NOT MINIMIZE THE SPREAD
AND ESTABLISHMENT OF NOXIOUS WEEDS
The Forest Plan requires that the Forest Service minimize the creation of sites
suitable for weed establishment (Noxious Weed Management, Supplement No,
R1 2000-2002-1). The proposed action will not minimize and will in fact
exacerbate the spread and establishment of noxious weeds through 15 miles of
road construction and 24 miles of reconstruction. (Preservation/Conservation
Organization, Boise, ID -#15.89.23540.1 60)
Appendix M
Page M-26
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Through the analysis a set of project design criteria or mitigation requirements
have been established to address the risk of weed spread and colonization
resulting from the proposed project. The design criteria include prevention
measures, spot treatment, monitoring, re-survey of risk zones for changes in
weed infestations and, where appropriate, the re-vegetation of disturbed soil
(Chapter 2 Design Criteria). The implementation of these invasive plant design
criteria would insure that weed spread from ground disturbing actions is
minimized or eliminated.
0*0*0*
D. BECAUSE THE PREFERRED ALTERNATIVE D WOULD NOT MEET SOIL QUALITY
STANDARDS UNDER THE FOREST PLAN
So/V quality standards under the Forest Plan will not be met under the Preferred
Action. The DEIS concedes the potential problems (at page 40) when it states,
"?58% [American watershed, 53% for Crooked] of all logging areas would not
meet the Forest Plan Soil quality standard 2?" This makes suspect the
subsequent claim made that mitigation measures may offset any differences in
cumulative effects for each of the alternatives. (Preservation/Conservation
Organization, Boise, ID-#15.40.23540.230)
RESPONSE:
The analysis of compliance with soil quality standards has been
augmented. Please see the revised narrative in FEIS Chapter 3, Section
3.1, summary of cumulative effects for soil physical properties and
compliance with Forest Plan standards.
0*0*0*
E. BECAUSE THE PREFERRED ALTERNATIVE D WOULD HAVE NEGATIVE IMPACTS ON
PINE MARTEN HABITAT
While old growth stands are supposedly protected from logging under the project,
we believe the impacts of the Proposed Action on pine marten are dramatically
understated. The DEIS acknowledges that clear-cutting of mature stands and
habitat fragmentation have "seriously affected distribution of marten" (P. 308). It
also notes that, "While habitat quantity has increased, habitat quality has likely
declined due to loss of larger snags and habitat heterogeneity from fuel-wooding,
fire suppression, and loss of large diameter trees due to past timber harvest."
(Preservation/Conservation Organization, Boise, ID-#15.85.23540.330)
RESPONSE:
The FEIS acknowledges effects of additional harvest and fragmentation
effects on pine marten habitats, but also the discussion cites work from
Coffin, et al. 2002, which indicates that despite heavily logged and roaded
areas, pine marten can tolerate and remain in such areas (see FEIS,
Chapter 3, Section 3.11). The analysis further discusses and assesses
fragmentation effects and the impacts of the activities.
Appendix M
Page M-27
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American River/Crooked River- Final Environmental Impact Statement
F. BECAUSE THE PREFERRED ALTERNATIVE D WOULD NOT DO ENOUGH TO LIMIT
IRRESPONSIBLE OHV USE
The damaging effects of irresponsible OHV use are well documented and could
be contributing to water quality problems among others. It is clear that the
Proposed Action will not do enough to curtail trail blazing. It is mentioned that
current restrictions will be maintained and that the effectiveness is rated as
"high". However, on page 39 it states, "Numerous undocumented user-created
ATV trails exist, which add to the amount of detrimental disturbance in the project
area." This contradiction is highly confusing and leaves one to wonder if
management has fallen behind the reality of the current situation. Accordingly,
restrictions and monitoring should be increased. This is also a reason to
minimize road construction to prevent further intrusion into areas.
(Preservation/Conservation Organization, Boise, ID - #15.51.23540.501)
RESPONSE:
Illegal OHV use does exist presently and will continue in the future no
matter which alternative is selected or if any alternative is selected.
Unfortunately, at present funding levels the problem can not be addressed.
Illegal use is not expected to change due to implementing any of these
alternatives.
03 OS OS OS O3 OS
32. THE NEZ PERCE NATIONAL FOREST SHOULD INCREASE EMPHASIS ON FISH HABITAT
RESTORATION IN ALTERNATIVE D.
Alternative D appears to be an economically viable proposal. If there is sufficient
latitude within your budget or projected revenues to increase the level of fish habitat
restoration above that shown in Alternative D, we would strongly recommend that
you give habitat restoration additional emphasis in your final decision. Increased
emphasis on fish habitat restoration, particularly stream improvements, would not
only help recover ESA-listed fish at a faster pace, but would also provide additional
employment opportunities to the potential contractors involved with implementing
those actions on the ground. (Place Based Group, Lewiston, ID - #3.6.32300.340)
RESPONSE:
Comment acknowledged. Effects of additional restoration activities were also
analyzed as Alternative D (modified) for the FEIS.
-------
American River/Crooked River- Final Environmental Impact Statement
RESPONSE: Comment acknowledged
(S3 (XC8 O3O3V3
ADEQUACY OF DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS)
34. THE NEZ PERCE NATIONAL FOREST SHOULD ACKNOWLEDGE AND ADDRESS THE
SHORTCOMINGS AND INCONSISTENCIES OF THE AMERICAN AND CROOKED RlVER
DEIS.
A. Very frankly, everything about this DEIS stinks. It is obvious that the Forest
Service is trying to pass-off their hidden agenda on the public under the mask of
a fuels reduction project. (Individual, Grangeville, ID - #30.11.21000.820)
There are several issues that need to be addressed in this document. They
include baseline data, the cumulative impacts on the South Fork Clearwater, the
indicators and parameters identified in the DEIS, the disconnect between water
quality based upon modeling and fish habitat and how that does not meet the
forest plan, and the very different impacts of pulse disturbances (fire) versus
press disturbances (logging and road building). (Preservation/Conservation
Organization, Moscow, ID - #22.18.21100.002)
RESPONSE:
The FEIS covers each of these concerns in Chapter 3 and/or Appendix E.
The issue of Forest Plan compliance is discussed above in the response to
comment 32. The linkage between water quality modeling and fish habitat
is discussed in the FEIS. The effects of pulse versus press disturbances
due to fire, logging, and road building are disclosed in the Chapter 3.
080* OS
B. BECAUSE THE DEIS FAILS ITS DUTY UNDER NEPA TO OFFER AND DISCLOSE TO THE
PUBLIC A RESONABLE RANGE OF ALTERNATIVES
The DEIS fails its duty under NEPA to offer and disclose to the public a
reasonable range of alternatives that includes scientifically and ecologically
sound management proposals. The purpose and need was designed in such a
way as to constrain alternatives and, in so doing, pie-determined the decision
prior to issuance of even the DEIS. (Preservation/Conservation Organization,
Moscow, ID - #22.13.21000.131)
A basic requirement of NEPA is that federal agencies must consider a
reasonable range of alternative actions in an as. 42 U.S.C. B 4332(2XcXiii); 40
C.F.R. B 1502.14; Bob Marshall Alliance v. 1-lodel, 852 F.2d 1223(9th Or. 1988),
cert, denied, 489 U.S. 1066(1988). The range of alternatives should 'sharply
[define] the issues and [provide] a clear basis for choice among options by the
decision maker and the public." Id. Under NEPA, alternatives analysis must:
(a) Rigorously explore and objectively evaluate all reasonable
alternatives, and for alternatives which were eliminated from
detailed study, briefly discuss the reasons for their having been
eliminated.
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
(c) Include reasonable alternatives not within the jurisdiction of the
lead agency.
40 C.F.R. 8 1502.14 (a) and (a). See California v. Block, 690 R2d 753,765-
69(9th Cir. 1982) (reversing EIS for failure to address reasonable range of
alternatives); see also Muckleshoot Indian Tribe v. USFS, 177 F.3d 800(9th Cir.
1999) (reversing EIS for failure to address reasonable range of alternatives).
There is a lack of a range of alternatives-or any alternative-thai examines the
implications of changing forest plan management direction as noted above.
There was no real restoration alternative without logging. Conflation of those
opposites—logging and mad building which are damaging and restoration which
seeks to restore the damage from the pervious two-is dishonest. Furthermore,
narrowly defining the purpose and need to require removal of vegetation (a
euphemism for logging) violates NEPA. (Preservation/Conservation
Organization, Moscow, ID-#22.14.23100.002)
The Seventh Circuit recently explained:
No decision is more important than delimiting what these 'reasonable
alternatives" are... One obvious way for an agency to slip past the strictures of
NEPA is to contrive a purpose so slender as to define competing reasonable
alternatives out of consideration (and even out of existence). If the agency
constricts the definition of the project's purpose and thereby excludes what truly
are reasonable alternatives, the EIS cannot fulfill its role.
This DEIS follows that pattern mentioned by the Court. In coming up with the
purpose and need, the agency has defined the issues to preclude a reasonable
array of alternatives. (Preservation/Conservation Organization, Moscow, ID -
#22.16.23100.131)
RESPONSE:
Contrary to your statement above, there is no change in Forest Plan
management direction proposed by this project. The range of alternatives
was developed in response to the Purpose and Need and issues identified
through scoping. (Refer to FEIS, Chapters 1 and 2).
O«C8OS
C. BECAUSE THE DEIS USES NON-NEPA DOCUMENTS TO ESTABLISH MANAGEMENT
DIRECTION
The DEIS fails to meet the spirit and intent of NEPA and NFMA requirements by
using non-NEPA documents to establish management direction, that coupled
with an overly narrow Purpose and Need will lead to a predetermined decision
and constrains the array of alternatives. In this case, programmatic decisions in
the South Fork Landscape Assessment, or presumed to be in that assessment,
to meet some so-called historic range of variability and establish goals for
vegetation (less lodgepole and fir and more ponderosa pine and western larch).
(Preservation/Conservation Organization, Moscow, ID-#22.9.21000.330)
Appendix M
Page M-30
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE: See response to item 21.
(3303(13
D. BECAUSE THE DEIS OFFERS NO EVIDENCE THAT THE CURRENT CONDITION OF
STREAMS SHOWS AN UPWARD TREND IN WATER QUALITY AND FISH HABITAT
STANDARDS
The DEIS recognizes that these streams do not meet forest plan water quality
and fish habitat standards. Cobble embeddedness is significant and predicted to
increase. Appendix A of the forest plan is quite clear most if not all of the
streams fall below the mandated percentage of Fishery Water Quality Objectives.
The DEIS offers no evidence the current condition of those streams has changed
since Appendix A of the forest plan was completed.
Appendix A is also clear that streams below objectives must show (present
tense) and upward trend before logging can take place. A future predicted
upward tend is not sufficient. The plan is clear on this point. Real recovery must
be taking place before logging and road building can be allowed. The DEIS
offers no monitoring data that is indeed the case.
The DEIS does not seem to indicate whether the entry frequency guidelines in
appendix A have been met or exceeded. Is that information available and if so,
where is it? (Preservation/Conservation Organization, Moscow, ID -
#22.22.21000.002)
RESPONSE:
The issue of Forest Plan compliance, including upward trend requirements,
is discussed above in the response to comment 31 (B). We disagree that
the Forest Plan requires that an upward trend must show before logging
can take place. The Forest issued a guidance document in 1991 that
states, in part, "The Plan did not specifically intend that the improving trend
be in place prior to initiation of new activities ..." (Gerhardt, et al, 1991).
Rather, in the watersheds within the project area, the Forest Plan provided
for timber management and improvement activities to occur concurrently.
Refer to Chapter 3, Section 3.3.3 and Appendix A.
(fSCXOS
E. BECAUSE THE DEIS is UNCLEAR HOW THE PROPOSED TIMBER HARVESTS RELATE TO
THE PROPOSED WATERSHED IMPROVEMENTS
That is especially true [that an economic analysis be provided for each
alternative] in light of the lack of clear language in the DEIS connecting the tree
removal part of the plan with the superb list of watershed improvements provided
in two appendices to the DEIS. These appendices offer a clear and very well
thought out plan to make long term watershed improvements in this portion of the
Forest - a place where just this type of improvement is badly needed. These
efforts can also be very labor intensive, which is not a bad idea in a place where
more jobs are certainly needed. But, and I am sorry to say, as usual, no clear
plan is provided to answer these questions: how will these improvements be
timed? Will they for certain be accomplished? Are they a prerequisite for any
other part of your proposed decision? Will they be done by the same people who
Appendix M
Page M-31
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American River/Crooked River- Final Environmental Impact Statement
remove the trees? Is their actual completion a key part of both the monitoring
effort, and more importantly, is their completion factored into the many tables that
show the overall water quality situation in these two drainages. (Individual,
Moscow, ID - #6.7.21100.247)
It is not clear from the DEIS of the timing of the watershed restoration activities
listed in Appendix D. (Federal Agency Official, Seattle, WA - #24.14.21100.249)
RESPONSE:
The Nez Perce National Forest is committed to completing the aquatic
restoration that is part of this action. Please refer to the FEIS Record of Decision
including the Biological Evaluation/Assessment. The aquatic improvement
activities will occur concurrently with the vegetation treatments. Activities will be
planned to achieve a balance over the life of the timber sale contract. The exact
mechanism is not final at this stage and implementation will either occur under
the same contract or by separate contracts.
OSCaJCS
F. BECAUSE THE DEIS FAILS OT SUBSTANTIATE HOW THE MITIGATION WORK PROPOSED
IN THIS PROJECT WILL RESULT IN LONG TERM IMPROVEMENT TRENDS
1. Regarding this over generalization of future habitat improvements, your DEIS
frequently admits that these rivers are in poor condition and/or are very
vulnerable to further degradation. As an example of this, on page 146 you
frankly state "In summary, American River and tributaries are subject to
cumulative sediment effects due to past impacts in the watershed and the
existing degraded condition" (holding added).
On the bottom of page 147, you make the simple and flat statement "Fish
habitat in the analysis area is in poor condition". You continue on page 148
to describe just how poor of a condition these rivers and tributary streams are
in. Yet, in spite of these type of assessments, the DEIS constantly implies, in
a very blurred way, that road decommissioning and the use of "temporary
roads" will eventually offset any further damage caused by this proposal. I
am aware of the other mitigation work proposed in this project which is
commendable but you submit no supportable evidence substantiating the
contention that this work will more than offset the short term impacts of
Alternative C. Although I applaud such mitigation work, it is pure speculation
that the net effect of taking 25 MMBF of timber off of 2,700 acres will result in
a long term improvement trend. (Individual, Post Falls, ID - #19.5.21000.720)
RESPONSE:
The documentation for the conclusion that an upward trend in aquatic
condition is expected to result from this project is found in Appendix E of
the FEIS. In addition, 2,700 acres represents only seven percent of the
project area.
o»o* os
Appendix M
Page M-32
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American River/Crooked River- Final Environmental'Impact Statement
2. Proposals such as the American and Crooked River Project coyly imply that
after this project is completed, there essentially will be no other subsequent
proposals that would add additional short term or long term negative impacts.
This is done by almost promising the reader that following some undefined
period of time of "short term" degradation, these watersheds "are expected to
result in long-term improvements in habitat condition (page V; page 111).
What is so astounding about such assertions is you present not one iota of
information or data to support that critical commitment. That is just not
probable nor does it suggest reality. No, in all likely hood, some years after
the American and Crooked Rivers are logged, the temporary roads are
decommissioned (more on that later), existing non-used roads are
decommissioned and the affected area commences to recover, the Nez
Perce NP will come forth with another proposal to attempt to "manage1 some
form of risk in the same watersheds. In other words, it seems to me to be
incredibly idealistic to expect that there will be no further negative impacting
projects to those watersheds. Certainly that has not been my experience up
here in the Panhandle National Forest. So, for the USFS to say that if this
project is initiated, it will lead to long term improvements in the watershed are,
as they say, a bit of a stretch. (Individual, Post Falls, ID - #19.2.21100.160)
RESPONSE:
Currently, there are no additional proposals planned within this project
area. The assertion of long-term improvement is based on actions that
we can currently assess. Unless the requirements for upward trend in
aquatic condition are removed at some point, future projects would be
subject to the same direction.
080*0*
G. BECAUSE THE DEIS is UNCLEAR WHETHER THE USDA FOREST SERVICE WILL
CONTINUE TO PROVIDE STAFF AND FUNDING TO SUSTAIN EFFECTIVE MITIGATION
PROJECTS AND RESTORATION PROJECTS
Adding to this dubious claim that the forest silviculture and watersheds will
eventually be in better condition is the question of whether the US Forest Service
will continue to provide staff and funding to sustain effective mitigation programs.
There certainly is valid concern that programs originally committed to in a given
project never actually gel completed as originally orchestrated or, at the very
least, takes inordinately long to complete. I am sure that this continual under
funding of the USFS, and hence the downsizing, is as agonizing to the agency as
it is to the general public. None-the-less, this raises serious doubt that the Forest
Service can, in fact, deliver on the constant promise that things will get better in
the long term IF THE PRESENT PROPOSED PROJECT IS AUTHORIZED.
(Individual, Post Falls, ID-#19.3.21100.835)
It is not clear from the DEIS whether the funding is certain for all or some of the
watershed restoration activities. (Federal Agency Official, Seattle, WA -
#24.15.21100.835)
Appendix M
Page M-33
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Most restoration work associated with this project will be accomplished
through the use of various contracting mechanisms. Some of the work,
streamside planting for example, may be accomplished through
participating, volunteer, and challenge cost-share agreements.
The various types of contracting authorities being considered to implement
the project include stewardship, service, and timber sale contracts, each of
which offers a different opportunity to apply funds or contract specifications
toward completing restoration activities.
We are confident that restoration funds will be made available from a
variety of sources over the life of the project.
Funding Sources
• Appropriated funds have been requested for Fiscal Year 2005 and
beyond to accomplish restoration work in the upper South Fork
Clearwater River, including the American and Crooked River Project
area.
• The North Central Resource Advisory Council (RAC) is on record
supporting this Project and has the capability to fund a significant
portion of the restoration once the Project is approved.
• Many road improvements and a portion of the existing road
decommissioning would be accomplished through timber sale
contract provisions where such roads would be used for hauling and
removing forest products.
• Where forest product revenues are projected to exceed operational
logging and site treatment costs, stewardship contracting authorities
would be used to allow the Forest Service to direct those revenues
toward restoration activities.
• A substantial portion of the restoration work fits well under
partnership and grant opportunities:
-> A recent addition to the potential sources of funding for
restoration activities is the Pacific Salmon Recovery Fund
(PSRF). At least one grant proposal from a local non-profit
organization has already been submitted, through the PSRF
process, to do restoration work in the project area.
-» Restoration work associated with this Project, once approved,
will be incorporated into the South Fork Clearwater River TMDL
implementation plan, which is under development by the SFCR
Watershed Advisory Group.
-> Many of the proposed restoration projects would be competitive
for BPA funds and work could be accomplished in partnership
with the Nez Perce Tribe.
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
In the event of significantly changed conditions due to natural events related to
large floods, wind, or fire affecting the project area, the project would be
reevaluated. Significant delays in project implementation could affect the overall
economics of the project. National funding priorities could temporarily shift in the
event of large-scale catastrophic events in other parts of the country. The
difficulty in accurately predicting the future makes it impossible to guarantee
funding or results. We can, however, provide assurance of our intent to
implement the full range of actions identified in the FEIS and Record of Decision
and that the tools to do so are reasonably available at this time.
caouos
H. BECAUSE THE CUMULATIVE IMPACTS ANALYSES IN THE DEIS ARE INADEQUATE
1. The cumulative impacts analyses in the DEIS are disjointed (for example see
pages 109, 110 and 147) and somewhat contradictory. Page 110 indicates
sediment horn only four projects was analyzed in a cumulative fashion, yet
table 3.0 lists many more future projects. Even table 3.0 is not clear whether
it covers all of the mining projects in the area as, for example, Crooked River
Mining Activity is so general it may take in several projects which are not
explicitly mentioned. Mining projects have been proposed and/or approved in
the past few years in the South Fork drainage which are not mentioned on
the chart (Siegel Creek, El Lucky Duk, Cypress Hill, and Petsite), timber sales
are not mentioned (Mackey Day) and other timber sales (Ridge Running)
apparently are considered past (a Hungry mill EIS sale, as per
communication with the USFS) when we understand that are still ongoing
though nearing completion.
As of today, the TMDL for the South Fork has just been or is on the verge of
being approved. Sediment is a major problem in the South Fork Clearwater.
The problems noted in the above paragraph of the DEIS make it impossible
to determine whether the TMDL is being met. However, the evidence that is
available leads one to conclude the TMDL, which requires a reduction of 25%
in sediment won't be met. How can the agency produce more sediment and
still meet the TMDL that calls for sediment reduction?
(Preservation/Conservation Organization, Moscow, ID-#22.20.21000.137)
RESPONSE:
The cumulative effects discussion was supplemented with additional
analysis in the FEIS. Not all ongoing and proposed activities are
modeled in the sediment analysis. The types of activities and effects
that are modeled are disclosed in Appendix E. The concern regarding
compliance with the South Fork Clearwater River TMDLs is discussed
above in the response to comment 31.
C3O80S
2. The DEIS failed to adequately consider the cumulative impacts of other
federal actions in the area on Fisheries, Soils, Wildlife, Management Indicator
Species, TE&S Species, Water Quality, Forest Stand Dynamics and other
resources. Some of the other projects that should be incorporated into the
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
Cumulative Effects Analysis include the Eastside Township (BLM), Whiskey-
South (BLM and FS), Crooked River Road Demonstration project, the
mysterious Orogrande Defensible Space project, Newsome Creek Defensible
Space, Red River Defensible Space, Red River Administrative Sites, Blacktail
Fuels, American River Drainage Fisheries (BLM), Buffalo Gulch Culvert
Replacement (BLM), Dixie Summit Tree Removal, Crooked River Channel,
Genesis Minerals, Red River Hazard Tree Removal, Newsome Creek
Channel Restoration, Upper Red River Watershed Restoration project, "This
is it" placer mining, EMC #1 placer mines on Newsome Creek, Forestwide
Thinning project (scoping notice of March 29, 2004) Red River Campground,
and last but certainly not least, Red Pines. Additional effects analysis is
warranted for the historic, current and foreseeable mining activities located
throughout the watershed, as these legacy and continuing projects carry
significant risks to values and resources within and adjacent to the project
area.
Given the inextricable relationship of this impressive (yet likely not
comprehensive) list of related activities, many of these projects should be
analyzed under one comprehensive EIS. The Forest Service also needs to
analyze the cumulative effects of the Slims Fire Contingency Fire Line and
any other emergency projects that arise. (Preservation/Conservation
Organization, Boise, ID-#15.143.30310.002)
RESPONSE:
For water quality cumulative effects, please see response above. The
analysis of cumulative effects for soils was also supplemented. See this
section in FEIS 3 at the end of Section 3.1. The analysis of cumulative
effects for vegetation was supplemented in the FEIS. See this section
in FEIS 3 at the end of Section 3.10. The analysis of cumulative effects
for fisheries has been updated in the FEIS. Please refer to Section 3.2
in that documents.
OS 03 OS
3. The DEIS does not clearly show or evaluate cumulative the impacts from
livestock grazing on the watershed. There are as few allotments in the
planning area.
(Preservation/Conservation Organization, Moscow, ID-#22.2921100.247)
RESPONSE: The evaluation of cumulative effects from livestock grazing on
the watershed has been strengthened in the Final EIS.
0303(13
BECAUSE THE DEIS is NOT PRECISE IN HOW IT DEFINES FOREST HEALTH
The DES and associated documents are not precise in how to define forest
health, /s it merely an expression of being within historical range of variability (or
does it include human economic concerns as well? lithe latter, how can science
define what is healthy since the economic values are simply that, expressions of
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
a value system, and not based in value-neutral science? (see Walder 1995)
(Preservation/Conservation Organization, Moscow, ID-#22.32.21000.205)
RESPONSE:
We consider a healthy forest ecosystem to have the following characteristics:
1) The physical environment, biotic resources and trophic networks to
support productive forests during at least some serai stages;
2) Resistance to dramatic change in populations of important organisms
within the ecosystem not accounted for by predicted successional trends;
3) A functional equilibrium between supply and demand of essential
resources (water, nutrients, light, growing space) for major portions of .the
vegetation; and
4) A diversity of serai stages, cover types, and stand structures that provide
habitat for many native species and all essential ecosystem processes.
OSOJOS
J. BECAUSE THE DEIS DOES NOT EXPLAIN THE MAPPING DIFFERENCES BETWEEN IT
AND THE SOUTH FORK OF THE-CLEARWATER RIVER LANDSCAPE ASSESSMENT
(SFLA) CONCERNING FIRE REGIMES
The DEIS does not explain the mapping differences between fire regimes
between it and the SFLA, though minor, and the assumptions behind the
departure from historic. Without this information, it is impossible to test the
validity of the assumptions made in the DEIS. (Preservation/Conservation
Organization, Moscow, ID-#22.61.21000.210)
The DEIS is not clear how the assumptions made in the SFLA and other
documents were derived. For example, the SFLA reaches some different
site-specific conclusions about extent of certain habitat types (and
therefore, about fire regimes) in the South Fork Clearwater than does
ICBEMP. However, neither the SFLA nor DEIS explain the site-specific
science behind those differences. (Preservation/Conservation
Organization, Moscow, ID-#22.60.21000.210)
RESPONSE:
The modest inconsistencies are due to the methods of deriving fire
regimes. In both analyses, combinations of potential vegetation and terrain
setting were used with a rule set to estimate historic fire regimes. In the
case of the South Fork assessment, the resultant maps were refined using
site-specific potential vegetation data where they were available.
In the case of the American Crooked River Project, no site-specific
corrections were made. Both these and the historic fire regimes derived for
the Idaho Cohesive Strategy
(http://www.fs.fed.us/r4/id_fire_assessment/id_haz_risk_review.html), which
will replace in the FEIS data used for the DEIS, are based on modeling of
potential vegetation, and the use of rule sets to derive fire regimes. The
Forest and Idaho-scale processes are likely to result in differing fire regime
Appendix M
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American River/Crooked River - Final Environmental Impact Statement
assignments and could affect consequent estimation of fire regime
condition class. Recognition of variability in these areas of mixed and lethal
fire, and landscape and stand-specific evaluations, are important to
interpreting existing condition with respect to historic process.
0*0*0*
K. BECAUSE THE DEIS is INCONSISTENT IN ITS DESCRIPTION OF THE AREA AND FIRE
REGIMES VERSUS THE MAPS IN THE APPENDIX
The DEIS is inconsistent between description of the area, and fire regimes,
versus the maps in the appendix which delineate Fire Regimes. The FINAL EIS
should clarify these discrepancies. (Preservation/Conservation Organization,
Boise, ID-#15.44.21000.277)
RESPONSE:
The description of the area and the map legend for the fire regimes now
correspond.
0*050*
L. BECAUSE THE DEIS PRESENTS INCORRECT ASSUMPTIONS CONCERNING DAMAGE TO
WATERSHEDS FROM STAND-REPLACEMENT FIRE
One of the wrong assumptions in the DEIS is the damage to watersheds from
stand-replacing fires. The SFLA clearly notes the difference between pulse
events like stand-replacing fires (which are necessary for watershed function)
and press events (road building and logging). "Predominantly pulse disturbances
of fire and flood have been supplanted by wide scale press disturbances of
harvest and mad-related sediment regimes that have impacted aquatic integrity."
Enclosed is a paper from agency personnel that look at this issue. It is
particularly important to note that logging for watershed health is misguided.
(Preservation/Conservation Organization, Moscow, ID - #22.23.21000.333)
RESPONSE:
The need to log for watershed health is not a primary purpose of this
project. Stand replacing fire, and the pulse watershed responses that
ensue, are intrinsic to historic and projected fire activity in the American and
Crooked River watersheds. The FEIS, Chapter 1, Section 1.3, Conditions
Contributing to the Purpose and Need for Action, describes vegetation
changes associated with past fire suppression, succession, and mountain
pine beetle activity. Refer to FEIS, Chapter 3, Sections 3.2, 3.3, and 3.4
regarding the relationship of fire to these disturbances. Furthermore, a
robust program of watershed improvements (see Appendix D) should help
improve resiliency to fire when it does occur.
eaoaea
M. BECAUSE THE DEIS DOES NOT EXPLAIN HOW DIFFERENT SITE-SPECIFIC
CONCLUSIONS WERE DERIVED
The DEIS is not clear how the assumptions made in the SFLA and other
documents were derived. For example, the SFLA reaches some different site-
Appendix M
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American River/Crooked River - Final Environmental Impact Statement
specific conclusions about extent of certain habitat types (and therefore, about
fire regimes) in the South Fork Clearwater than does ICBEMP. However, neither
the SFLA nor DEIS explain the site-specific science behind those differences.
(Preservation/Conservation Organization, Moscow, ID - #22.60.21000.210)
NEPA requires information be available before decisions are made. The DEIS
does not indicate whether the inventories conducted to date are adequate site-
specific analysis for this project. (Preservation/Conservation Organization,
Moscow, ID - #22.94.21100.131)
RESPONSE:
The Analysis Methods described under each resource area in the FEIS,
Chapter 3, have been augmented to describe data sources, including field
inventories.
08C9CJ
N. BECAUSE THE DEIS FAILS TO ADDRESS ISSUES CONCERNING WILDLIFE AND WILDLIFE
HABITAT
There is inadequate information provided regarding the Flammulated owl. While
it is stated that there is extremely limited owl habitat within the Crooked River, an
estimate of how many owls are located in the area is appropriate.
(Preservation/Conservation Organization, Boise, ID-#15.83.21100.390)
The Forest Service failed to address the fact that harvest units adjacent to
previous units could create combined openings that are too large to be used by
goshawks. (Preservation/Conservation Organization, Boise, ID
#15.79.21100.391)
It is particularly confusing that the environmental effects that are analyzed only
consider habitat in ponderosa pine. It should analyze other potential nesting
trees such as Douglas fir, which the owls are also known to utilize in Idaho.
Given the extent of logging in the area, it is likely that there would be impacts on
the limited population that is present in the area. These impacts should have
been fully considered in the DEIS, and must be duly incorporated into the FINAL
EIS. (Preservation/Conservation Organization, Boise, ID-#15.84.21100.391)
The DEIS specifies that project nest site mitigation will only protect 10-15 acres
of forest around nest trees. This is inadequate. The Forest Service should leave
a 30-acre buffer around active and previously existing but unoccupied nest sites
as specified in the Management Recommendations for the Northern Goshawk
(Reynolds 1992). Due to parasites or previous disturbances, goshawks often
alternate between existing nests. These existing alternate nests may well be
located within or adjacent to the proposed patch clear-cuts and other units. The
proposed action could remove or make these otherwise viable nests unusable.
(Preservation/Conservation Organization, Boise, ID-#15.78.23540.391)
RESPONSE:
Xeric ponderosa pine/Douglas-fir habitats are extremely limiting in the
American and Crooked River drainages. The extent of flammulated owl
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
habitat and its isolation from such other is not extensive enough to support
a breeding population. See FEIS, Chapter 3, Section 3.11.
The goshawk is a habitat generalist and uses variety of structural/age
classes to meet its life history requirements. With the majority of the
harvest within the American and Crooked River drainages having occurred
between the 1950's and 1980s, these areas are fully stocked and could
provide foraging habitat for goshawks. New units would create openings,
which in turn would provide habitat. See FEIS, wildlife cumulative effects
sections in Chapter 3, for further discussion of habitat fragmentation and
related impacts.
Management recommendations proposed by Reynolds et al., 1992, were
developed specifically for the southwestern United States. Thus, it would
be inappropriate to apply these guidelines to the moister, intermountain
west. Given that this project will not harvest old growth stands and that
active or newly discovered goshawk nests will be protected, goshawks
nests should be adequately protected.
OtfOJOS
O. BECAUSE THE DEIS FAILS TO RECOGNIZE THE ROLE MOUNTAIN PINE BEETLE PLAYS
IN THE SUCCESSIONAL STAGES OF THE FORESTS.
The DEIS fails to recognize the role Mountain Pine Beetle plays in the
successional stages of the forests. Lodgepole Pine is a serai species and should
be recognized as such in the FINAL EIS. While in certain areas, Lodgepole Pine
can be viewed as a type of serai/climax species due the long fire interval (i.e. as
witnessed at Yellowstone National Park), throughout much of the West, beetles
and other disturbance mechanisms play an integral role in the succession
through to climax forests. While fire may play a role in some of these forests, the
DEIS gives the impression that there are two stark options: Clear-cutting or
Stand Replacing Fire. Is this the position of the Nez Perce National Forest? This
is misleading and disingenuous. (Preservation/Conservation Organization,
Boise, ID - #15.109.21100.373)
RESPONSE:
The role the mountain pine beetle plays in the successional stages of the
forest vary according to the function of Rocky Mountain lodgepole pine in
the stand: whether serai, persistent, or climax. Section 3.10 of the FEIS for
additional information regarding this topic.
o»e*e«
P. BECAUSE THE DEIS FIALS TO ADEQUATELY CONSIDER AND ADDRESS ISSUES
CONCERING " ROADLESS" AREAS
Unmanaged, roadless areas provide important habitat. The Summary of
Scientific Findings for the Interior Columbia Basin Ecosystem Management
Project (PNW-GTR-385) found that undeveloped, roadless areas are important
for providing habitat for native fish and water quality; are economically valuable
to society; and are in relatively good ecological condition.
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
"Because roads crisscross so many forested areas in Eastside (Columbia Basin),
existing roadless regions have enormous ecological value. Existing roadless
regions offer important sanctuary. Roadless regions constitute the least-human-
disturbed forest and stream systems, the last reservoirs of ecological diversity,
and the primary benchmarks for restoring ecological health and integrity."
(Rhodes et al. 1994).
The DEIS fails to consider the importance of roadless in those regards. Instead,
it is as if the roadless areas are targeted Because of some ill-informed belief that
they need manipulation and/or corrective action than do roaded areas. Clearly,
with regard to watershed integrity, that is not the case.
(Preservation/Conservation Organization, Moscow, ID - #22.91.21100.621)
The DEIS does not analyze the so-called temporary impacts on roadless values.
Since project implementation is expected to take at several years, those impacts
could be substantial. (Preservation/Conservation Organization, Moscow, ID -
#22.89.21100.621)
Nowhere in the DEIS does it distinguish between roaded and unroaded
landscapes with regard to fire severity, HRV, or other similar ecological factors.
There is ample evidence, including the agency's own ICBEMP studies that
roadless areas are in far better health than roaded landscapes. For example,
Evan Frost prepared a detailed paper, submitted to the agency as comments on
the roadless policy which used the agency's own scientific reports citing the
health of roadless areas (see Frost 1999). (Preservation/Conservation
Organization, Moscow, ID-#22.90.21100.621)
The DEIS fails to clarify whether any management of non-system roads, trails, or
skid trails would occur with the project. (Preservation/Conservation Organization,
Boise, ID-#15.53.21100.410)
RESPONSE:
The cumulative effects analysis for Roadless areas is discussed in Chapter 3,
Section 3.13, Wilderness, Inventoried Roadless Areas, and Unroaded Areas.
Additional information regarding effects to areas identified as fish habitat
unroaded areas can be found in the FEIS, Chapter 3, Section 3.3.
0*0305
Q. BECAUSE THE DEIS FAILS TO ADEQUATELY EVALUATE THE IMPACTS FROM THE
VARIOUS ALTERNATIVES ON WEED SPREAD
The section on weed spread does not evaluate the impacts from the various
alternatives other than displaying a chart of harvest unit acreage and road
miles...This is a major failing of the DEIS.
The reason this is important is because the DEIS also claims that various HTGs
are different susceptibility to weeds. It does not, however, indicate what HTGs
are being logged or roaded so it is impossible to determine what the potential
impacts of weed spread are from the various alternatives.
Furthermore, if the areas targeted to be logged are HTGs or VRUs (or whatever
habitat/land typing is used) with little chance of weed spread, that should be
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American River/Crooked River- Final Environmental Impact Statement
shown. There is an interesting correlation between those types and infrequent
but lethal fire regimes. (Preservation/Conservation Organization, Moscow, ID -
#22.62.21000.371)
RESPONSE:
The result of the weed risk assessment reflect a concern for the potential of weed
spread from ground disturbing activities from all alternatives, taking into account
the level of disturbance and, type and condition of the vegetation communities
within the project area. To reduce the risk of continued weed spread design
criteria (Chapter 2 Design Criteria pg 28-29) is integrated into the project and will
be a requirement of the proposed project and applies to all alternatives.
C8O808
R. BECAUSE THE DEIS FAILS TO ADDRESS MAJOR ISSUES CONCERNING HERITAGE
VALUES
The DEIS gives some important and interesting background information on
heritage values. However, the big questions are avoided. Will there be an on-
site inventory? What are the impacts from the various alternatives? What
measures will be taken to ensure protection of heritage values?
(Preservation/Conservation Organization, Moscow, ID-#22.93.21000.730)
RESPONSE:
A heritage resource inventory specific to the American and Crooked River
project occurred throughout the project area during 2003 and 2004. The
level of inventory was predicated on sufficing requirements within 36 CFR
800.4.
No adverse effects to historic properties are anticipated by the
implementation of any of the alternatives proposed for the American and
Crooked River project. Refer to FEIS, Chapter 3, Section 3.9. Historic
properties will either be avoided entirely from project activity, or specific
mitigation measures implemented in consultation with the Idaho State
Historic Preservation Office and 36 CFR 800.6, will be instituted to arrive at
a "No Adverse Effect" determination for this project.
OS 08 08
S. BECAUSE THE DEIS is NOT CLEAR WHETHER FOREST PLAN SOILS STANDARDS WILL
BE MET
The DEIS is not clear whether forest plan soils standards will be met. It assumes
that can be held to 20% but it does not conclude that indeed it will. Furthermore,
it is not evident that regional soils guidelines will be met.
(Preservation/Conservation Organization, Moscow, ID-#22.28.21100.230)
RESPONSE:
The Regional soil quality guidelines have not been adopted Forest-wide through
a Forest Plan amendment, so the Forest Plan standards are in effect. The
discussion of soil quality standards and the assumption that impacts can be held
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American River/Crooked River- Final Environmental Impact Statement
to 20 percent has been supplemented. Please see FEIS, Chapter 3, Section 3.1,
Summary of Cumulative Effects.
O3 (38 OJ OS OS (X
35. THE NEZ PERCE NATIONAL FOREST SHOULD DEVELOP A SUPPLEMENTAL DEIS
WHICH CONSIDERS A DEFENSIBLE SPACE ALTERNATIVE.
The assertion that a defensible space project was not warranted Because of the
implementation of the Crooked River Road Demo Project is outrageous. The
Crooked River Road Demo Project treated approximately 24 acres. The DEIS
further states that because the Orogrande Defensible Space Project has been
envisioned, that a defensible space alternative is not warranted. No information
whatsoever has been provided to the public about this project, no scoping letter has
been disseminated and there is absolutely no assurance that the project will ever get
past the conceptual phase. Additionally, the DEIS (at page VIII) states, "The size
and scope of these treatments are small, designed to protect only the structure
themselves, so the treatments would have little effect on the project area." On the
basis of these considerations, a Supplemental DEIS is clearly warranted which
considers a Defensible Space alternative. (Preservation/Conservation Organization,
Boise, ID - #15.19.23400.275)
RESPONSE:
The scoping letter for the proposed Crooked River Defensible Space project
was mailed on September 13, 2004. This project proposes fuels treatments on
nine sites located along County Road 223. The proposed treatments include
thinning small diameter trees and pruning large diameter trees within 200 feet
of structures to create a safer area for firefighters to work and to help protect
private properties.
o* o# os o« os c*
TECHNICAL AND EDITORIAL COMMENTS ON THE DEIS
36. THE NEZ PERCE NATIONAL FOREST SHOULD MAKE NECESSARY AMENDMENTS TO
SECTION 2.2, DESCRIPTION OF ALTERNATIVES.
Section 2.2 Description of Alternatives: We recommend adding a Table 2.3 similar to
Table 0.1 that compares the alternatives for the combined American/Crooked River
project. (Federal Agency Official, Seattle, WA-#24.29.21200.210)
Section 2.2 Description of Alternatives: We recommend that Table 2.1 and 2.2 have
a reference to the list of stream improvement treatments contained in Appendix D.
(Federal Agency Official, Seattle, WA - #24.30.21200.249)
RESPONSE: Comment acknowledged.
OS 03 03 03 03 O#
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American River/Crooked River- Final Environmental Impact Statement
37. THE NEZ PERCE NATIONAL FOREST SHOULD CLARIFY THE VRU CHART ON PAGE
221 AND 250 TO DISPLAY THE VRU DISTRIBUTION OF THE AMERICAN RlVER.
VRU Chart, Figure 3/13, Page 250 - this chart appears to display the VRU
distribution of American River rather than Crooked Fork (as labeled), and is the same
as the chart on page 221. (Timber/Wood Products Industry, Kamiah, ID -
#5.13.30100.001)
RESPONSE: Comment acknowledged. The VRU chart has been updated in the FEIS
(X c# ea (x o* m
38. THE NEZ PERCE NATIONAL FOREST SHOULD PROVIDE A SHORT NARRATIVE FOR THE
ECONOMIC ANALYSIS OF EACH ALTERNATIVE.
The economic analysis provided for each alternative is reasonable, but could be
improved with at least a short narrative for each. (Individual, Moscow, ID -
#6.6.21200.800)
RESPONSE:
Comment acknowledged. The economic analysis section has been improved in the
FEIS.
OS O3 OS OS OS OS
39. THE NEZ PERCE NATIONAL FOREST SHOULD PROVIDE ADDITIONAL NEPA
DOCUMENTATION FOR THE AMERICAN AND CROOKED RlVER PROJECT.
If the intent is to proceed with the project as an authorized, additional NEPA
documentation (i.e. rescoping and supplemental DEIS) is required under current
regulations. Similar efforts to apply the Biscuit Fire Salvage Project post hoc were
withdrawn as a result of this incompatibility. (Preservation/Conservation
Organization, Boise, ID - #15.16.21000.160)
RESPONSE: See response to comment 17
OS 03 OS OS 03 OS
FINAL ENVIRONMENTAL IMPACT STATEMENT (FEIS)
40. THE FINAL EIS SHOULD SUMMARIZE SIGNIFICANT ISSUES RAISED BY THE PUBLIC
AND PROVIDE DETAIL ON THE PROCESS USED TO MODIFY THE PROPOSED
ALTERNATIVE.
In Chapter 2, Section 2.2, the DEIS states that the preferred alternative was
prepared in response to significant issues raised by the public. We recommend that
the final Environmental Impact Statement (FINAL EIS) summarize the significant
issues that were raised by the public and provide more detail on the process used to
modify the proposed alternative to address those concerns. (Federal Agency
Official, Seattle, WA-#24.3.21100.060)
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Alternatives to the proposed action were developed based on public comments
received during scoping. A detailed list and analysis of issues raised by the
public is in project file for this EIS.
as os ex os os 03
41. THE FINAL EIS SHOULD ADDRESS THE EFFECTS OF DROUGHT AND CLIMATE CHANGE
IN THE PROJECT AREA.
The effect of drought and climate change /s not adequately considered as one of the
root causes for the issues of concern in the project area. This should be amended in
the FINAL EIS. (Preservation/Conservation Organization, Boise, ID -
#15.45.21100.260)
RESPONSE:
Since it is not possible to determine if, when, or severity of drought or other climatic
changes, it is beyond what is defined as reasonably foreseeable and is not analyzed
in this EIS.
0* 08 0* OS (ff3 (S3
42. THE FINAL EIS SHOULD INCLUDE THE RESULTS OF THE BIOLOGICAL ASSESSMENT
(BA).
We recommend that the final EIS contain the results of the Biological Assessment
(BA) for threatened and endangered species affected by the proposed project or that
the Record of Decision discuss the process used to address the results of BA in
determining final action. (Federal Agency Official, Seattle, WA - #24.27.21100.340)
RESPONSE:
Comment acknowledged. We will include the Biological Assessments with the
FEIS or ROD.
C3 OS (S3 08 (S3 (33
RESTORATION
RESTORATION GENERAL
43. THE NEZ PERCE NATIONAL FOREST SHOULD CONDUCT RESTORATION.
A. To RESTORE THE WATERSHED
1. A better way to contribute to the economic and social well being of the local
communities is to repair the decades of abuse the landscape has suffered
and restore the watershed so that it supports thriving populations of Chinook
Salmon, Steelhead Trout, Bull Trout, Lampreys and other species. There are
decades worth of restoration projects in this area needing skilled forest
workers. In addition, fishing continues to bring significant income to the local
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American River/Crooked River- Final Environmental Impact Statement
economies. (Preservation/Conservation Organization, Boise, ID -
#15.11.30000.800)
The proposed restoration package is very limited on the American River.
This is difficult to comprehend given that there are many more improvements
proposed for the Crooked River and there seems to be very similar problems
for both of the rivers. The restoration package should be significantly
increased. This should be the highest priority for the watershed given that on
page 37 of the DEIS it is noted that, "The South Fork Clearwater River
Landscape Assessment identifies 'Restore aquatic processes' as the area
theme for the American River watershed within which the project area
occurs." It also states that "Restoration is to include both restoration of
aquatic conditions and processes in the watershed and adjustments to the
road and trail system to support aquatic restoration and provide for
administrative and public uses and maintain wildlife security." The
improvements proposed for this watershed do not seem to include restoration
of aquatic conditions and processes in the watershed.
(Preservation/Conservation Organization, Boise, ID - #15.38.31100.201)
RESPONSE:
Refer to Chapter 2 for summary tables of watershed restoration
improvements. In addition, Appendix D of the FEIS details the
restoration planned under this action. In American River, this work
includes decommissioning of over 20 miles of road, doing watershed
improvements on over 6 miles of road, and improving fish passage and
increasing the size of 10 culverts. In addition, over 50 acres of soil
improvement will be approved for completion. Crooked River does
include more of this type of work including in channel improvements.
The history of work in American River has the BLM taking the lead in
mainstem improvements. These actions will continue, as evidenced by
BLM's recent proposal to:
• Do 2.5 miles of road to trail conversion,
• Rehab the upper American River Ford,
• Replace the culvert at the mouth of East Fork American River,
• Connect Telephone, Queen and Whitaker Creeks to the
mainstem American River,
• Perform 2.2 miles of in-channel improvements, and
• Install riparian enhancements on an additional 5 miles of the
mainstem.
• The work proposed by both agencies will improve watershed
process and function.
03C3C3
2. EPA encourages the USFS to continue in the direction of implementing
restoration projects in the American and Crooked Rivers that will result in
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American River/Crooked River- Final Environmental Impact Statement
water quality and aquatic habitat improvements. (Federal Agency Official,
Seattle, WA - #24.8.34500.240)
RESPONSE: See response to 43(D) above.
cgoaoa
B. To RESTORE THE SOUTH FORK CLEARWATER
For the restoration of the South Fork Clearwater, it would be better to use plans
which concentrate on development of habitat for diverse wildlife and fish and
improvement of soil conditions. (Individual, Loveland, CO-#12.3.32000.002)
RESPONSE:
While the American and Crooked River Project focuses on timber salvage
and fuel removal, there are a number of key restorative actions that this
project implements as well. Roads decommissioning is one of the most
important from a wildlife and fish habitat viewpoint. See Appendix D for
details on the watershed and fish habitat improvements.
C3OSO*
C. BY CONSIDERING THAT THE DEIS ALREADY ACKNOWLEDGES THAT TIMBER HARVEST
AND ROADS CAUSE ENVIRONMENTAL PROBLEMS
In attempting to replicate some as yet to be defined HRV, the DEIS adopts a
strategy nearly identical to the logging of the past which resulted in forest
fragmentation and the conditions of today. In other words, the DEIS grudgingly
acknowledges that logging and road building has led to the problem (although
the emphasis seems to be on fire suppression, the effects of which are not clear
for most of the South Fork), yet proposes the solution to be more logging and
road building. (Preservation/Conservation Organization, Moscow, ID -
#22.39.13100.330)
RESPONSE:
The project is not attempting to replicate HRV. Chapter 1, Section 1.3 of the
FEIS defines the Purpose and Need of this project, as well as conditions that
contributed to the purpose and need for action. See also response to 43(D),
below
oscaea
D. BY CONSIDERING EVIDENCE THAT TIMBER HARVEST AND THINNING DO NOT MINIMIZE
EFFECTS OF FIRE
The DEIS fails to analyze some important findings about logging and fire. Both
the Sierra Nevada and Interior Columbia Basin Ecosystem Management Projects
found that logging was a major reason for increased intensity and severity of
wildland fire. Delia Sala et al (1995 and 1995a) and Henjum et al.(1994) argue
that scientific evidence does not support the hypothesis that logging, thinning,
minimize the effects of fire. (Preservation/Conservation Organization, Moscow,
ID-#22.53.13110.270)
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RESPONSE:
This is a complex issue and it is important to examine findings in the
context of biophysical setting and management history. Factors associated
with increased likelihood of high-intensity fire in managed forests include
some appropriate to this project area. For example, harvest-created fuels
will add to the fuel load for a short period until slash treatments are
complete, adding to the risk of locally severe fire effects under severe
burning conditions. However, some findings are more associated with low
elevation forests, in formerly frequent fire regimes, where past harvest has
reduced stand resistance to fire by removing the fire tolerant trees and
leaving younger and more fire sensitive species (Quigley and Arbelbide,
1997: McKelvey et al., 1996), and leaving slash untreated. Weatherspoon
(1997) compared fire and fire surrogates (logging and prescribed fire) for
their ecological effects. Many important questions remain unanswered,
even in the low elevation frequent fire regimes. Designed studies and
modeling, as well as fire case studies, have provided some insights.
Schoennagel et al. (2004) conclude that severe fires at long intervals in
lodgepole and spruce-fir forests are weather driven and not by fuels, stand
age, or fire-fighting activities. These fire situations are not those being
addressed by this project. In mixed severity regimes, or under moderate
burning conditions, climate and fuels interact in a complex manner. Using
the Hayman fire as an example, reviewers found that during severe burning
weather, most fuel treatments had little impact on the severity or direction of
fire (Finney et al., 2003), especially if area of fuel treatment was small.
During moderate weather, fuel modifications did influence fire spread and
severity. Agee et al. (2000) present a reasoned discussion of the utility and
limitations of fuel breaks in affecting fire behavior.
(35 (33 OS (3S (33 (35
44. THE NEZ PERCE NATIONAL FOREST SHOULD ADOPT THE RESTORATION PRINCIPLES
AS A SCREEN FOR THE ACTION IN THIS PROJECT.
We request the FS adopt the Restoration Principles (DellaSala, et al., 2003) as a
screen for proposed actions such as this one. We incorporate them by reference
into this DEIS comment. (Preservation/Conservation Organization, Moscow, ID -
#22.57.13100.160)
RESPONSE:
While the Restoration Principles proposed by Dellasala et. al. may contain valuable
insights to the overall effort of ecosystem restoration, the Forest Service is mandated
to by Congress to follow NFMA and NEPA regulations. The Nez Perce Forest Plan
provides the overall guidance for management of the specific management areas.
The NEPA document (American and Crooked River Project EIS) details the purpose
and need for the proposed action (Chapter 1 FEIS), a full range of alternatives which
will achieve the purpose and need (Chapter 2), and analysis of the effects of those
alternatives (Chapter 3). These do not necessarily correspond directly with all the
principles and criteria outlined in the Restoration Principles. During the NEPA
process, publics have the opportunity to comment and state their opinions as you
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American River/Crooked River - Final Environmental Impact Statement
have done. Any action taken to adopt guidelines (such as Dellasala et. al.) which
vary from those already established and approved through the planning process may
require an extra level of involvement, or a Forest Plan Amendment.
There are some similarities between the proposed activities and the Restoration
Principles, however. The table below provides a checklist of the similarities between
the eight sub-principles and the FEIS, and where they may be reviewed in more
detail.
Ecological Forest Restoration Principles and Criteria Checklist
DellaSala, et al., 2003
Core Principle
\. Ecoloaical Forest Restoration — Enhance
ecoloaical intearitv bv restorina natural
processes and resiliency
Sub principles
1. Ecological Forest Restoration — Enhance
ecological integrity by restoring natural
processes and resiliency
2. Forest Restoration Assessment Principle —
Conduct a restoration assessment prior to
restoration activities
3. Ecological Restoration Approaches
Principle — Determine the appropriate use of
protection, passive and active restoration
based on restoration assessments
4. Community Protection Zone Principle —
Distinguish between fuel-reduction treatments
that restore ecological integrity and those that
serve primarily to protect property and human
life.
5. Adaptive Management Principle —
Monitoring and evaluation must be assured
before restoration proceeds, and be
incorporated into the cost of the project
Monitoring and Evaluation Criteria.
II. Ecoloqical Economics — Develop or
make use of restoration incentives that
protect or restore ecoloaical intearitv
6. Economic Framework Principle — Develop
positive incentives to encourage ecologically
FEIS - American and Crooked River Project
2005
See Sub-principles below.
The purpose of the project is to reduce existing
and potential forest fuels, create conditions that
will contribute to sustaining long-lived fire
tolerant tree species (ponderosa pine, western
larch) and contribute to the economic and social
well-being of people who use, and reside, within
the local area.2 FEIS Chapter 1, Purpose and
Need.
The area's existing condition was determined
using field data and the findings and
recommendations from the South Fork
Clearwater River Landscape Assessment
(SFLA). FEIS Chapter!
Specialists' effects analysis of the alternatives
and the responsible official's decision. FEIS
Chapter 3 and Record of Decision (ROD).
WUI and non-WUI designations within the
analysis area. FEIS Chapter 2, description of
the alternatives and Chapter 3, Effects of the
Alternatives.
FEIS Appendix I Monitoring Plan. FEIS Chapter
2, description of the alternatives and Chapter 3,
Effects of the Alternatives.
See Sub-principles below.
FEIS chapter three, economic analysis, effects
of the alternatives on vegetation.
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
DellaSala, et at., 2003
sound restoration.
III. Communities and Work Force — Make
use of or train a hiqhlv skilled, well-
comoensated work force to conduct
restoration
7. Community/Work Force Sustainability
Principle — Effective restoration depends on
strong, healthy, and diverse communities and
a skilled, committed work force.
8. Participatory Principle — Encourage
involvement of a diversity of communities,
interest groups, agencies, and other
stakeholders at all levels
FEIS - American and Crooked River Project
2005
See Sub-principles below.
Meetings with Nez Perce Tribe, Framing Our
Community, Bennett Forest Industries.
t
NEPA scoping, meetings with Nez Perce Tribe,
Framing Our Community, ILC, Friends of the
Clearwater, open houses, field trips, etc. See
FEIS response to DEIS comments.
(SS OS (S3 (S3 OS O*
MONITORING
MONITORING GENERAL
45. THE NEZ PERCE NATIONAL FOREST SHOULD MONITOR.
A. 1. Monitoring should be a high priority item, and funding must be secured. Only
through sound project level monitoring will there be proof that land
management activities can be conducted with modern harvest systems
without a negative impact on other resource values, particularly water quality
and fish. (Timber/Wood Products Industry, Kamiah, ID - #5. 14.30100. 720)
RESPONSE:
Comment acknowledged. The monitoring plan has been amended with
more specific information in the FEIS. Please see Appendix I.
(S8C8CS
2. Additional issues of concern include a lack of monitoring and discussion of
Heritage issues, Wild and Scenic Rivers (existing and proposed), and
monitoring and evaluation. (Preservation/Conservation Organization, Boise,
ID -#15.145.30100.730)
RESPONSE: Comment acknowledged.
B. 1. FOR INDICATOR SPECIES THAT INCLUDES ELK
Monitoring impacts on indicator species must include elk. We must be able
to evaluate timber harvest activities to determine if timber stands are opened
sufficiently to provide quality summer forage. Both the Idaho Fish and Game
Department and Nez Perce Tribe should be involved in this activity.
(Timber/Wood Products Industry, Kamiah, ID -#5.16.30100.340)
RESPONSE:
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Staffing and funding levels must be considered by line officers when
prioritizing all required Forest activities and completing all desired tasks
becomes difficult when budgets become constrained.
C. FOR THREATENED. ENDANAGERED. AND SENSITIVE PLANTS AND ANIMALS AS PART OF
THE BIOLOGICAL ASSESSMENT
A thorough field survey for threatened, endangered, and sensitive plants and
animals should be undertaken as part of the biological assessment. Areas
containing threatened, endangered, and sensitive plant and wildlife species
within the proposed treatment areas should be mapped, avoided, and monitored
prior to and after management activities. (Preservation/Conservation
Organization, Boise, ID -#15.1 22.301 00.340)
RESPONSE:
The FEIS Appendix A maps 8-a and 8-b show fish distribution including
TES species. Section 3.3 of the FEIS provides baseline information for the
fish and discusses how the activities will be managed to protect these fish.
Pre-project field surveys for wildlife have been conducted for this project
(See American/Crooked Project Wildlife Observation Table - in the project
file). This information was incorporated into the biological assessment and
evaluation. Further details on mitigation and monitoring can be found in the
FEIS Section 2.3.
D. FOR POPULATION TRENDS
Temporal considerations of the impacts on wildlife population viability from
implementing something with such long duration as a Forest Plan must be
considered (id.) but this has never been done by the Nez Perce NF. It is also of
paramount importance to monitor population trends (as mandated by the Forest
Plan) during the implementation of the Forest Plan in order to validate
assumptions used about long-term species persistence i.e., population viability
(Marcot and Murphy, 1992; Lacy and Clark, 1993). (Preservation/Conservation
Organization, Moscow, ID -#22.68.301 00.350)
RESPONSE:
The Forest Plan monitoring and evaluation reports annually related species
monitoring results and general trends. In addition, the project file holds a
document titled: "Habitat-based Terrestrial Vertebrate Populations Viability
Related to the American and Crooked River Project (USDA FS, 2004a),
which holds a summary of species monitoring over the past sixteen years.
O* (33 O8 0« 08 <&
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46. THE FINAL EIS SHOULD INCLUDE PAST EXPERIENCE AND MONITORING ASSOCIATED
WITH THE NEZSED MODEL.
Past experience and monitoring associated with the NEZSED model should be
provided in the FINAL EIS in order to allow for the appropriate consideration of the
models shortcomings, especially for a project of this magnitude.
(Preservation/Conservation Organization, Boise, ID-#15.37.21100.210)
RESPONSE:
A summary of NEZSED limitations and field tests was provided in Chapter 3 of
the DEIS. A more detailed discussion has been added to Appendix E of the
FEIS.
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RESPONSE:
Both broad-scale and locally relevant studies have examined the role of fire
within the last 1,000 years. Many studies have concluded that, despite
considerable local or temporal variability, fire suppression has tended to
change stand structure and composition in areas of frequent, low severity fire.
In areas of longer interval, mixed and more severe fire regimes, like much of
the project area, fire suppression has resulted in changes in landscape-scale
pattern and the proportion of different forest age classes represented in a
landscape (Quigley and Arbelbide, 1997, page 855; USDA FS, 1998, 2000,
2001, 2002, 2003). The South Fork Landscape Assessment, page 89, found
that fires affected almost 6000 acres per year on average from about 1880 to
1930, and since then have burned about 400 acres annually, a more than 90
percent decline. Fire history mapping and fire scar studies in other areas of the
forest corroborate the pervasive role of fire within at least the last 300 years
(Barrett, 1993).
Although harvest in the American and Crooked River watersheds has been
extensive, it has not simulated the pattern or processes of natural fire. The
resultant vegetation pattern in some areas is harvest units dispersed in a matrix
of mature forest. These forests, with their significant proportion of dying
lodgepole pine, are susceptible to wind driven lethal fires under the appropriate
weather conditions. While not unnatural, such fires could be difficult to
suppress. Community concerns for property and firefighter safety suggested
the purpose and need: to reduce fuels in strategic locations to improve fire
suppression effectiveness, increase the proportion of fire resistant tree species,
and reduce likelihood of locally severe fire effects in areas of high fuel
accumulations. Refer to Chapter 1, Section 1.3.
Changes due to logging, mining and grazing were assessed for the American
and Crooked River watersheds in the South Fork Landscape Assessment
(USDA FS 1998), the South Fork Clearwater Biological Assessment (1999),
and have been updated and made more site-specific in the discussion of the
affected environment for the project area. See FEIS 3 under the discussion of
existing conditions for each resource area.
as os as as os as
SECTION 3 - SOILS AND WATERSHEDS
SOILS AND SEDIMENTATION
49. THE NEZ PERCE NATIONAL FOREST SHOULD ANALYZE ACTIVITIES THAT AFFECT
SOILS.
Among other things, we are concerned that project activities will accelerate soil
erosion, increase soil compaction, and degrade soil productivity. NFMA requires the
FS to "not allow significant or permanent impairment of the productivity of the land."
136 C.F.R. 2. NFMA requires the Forest Service to "ensure that timber will be
harvested from National Forest System lands only where-soil, slope, or other
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American River/Crooked River- Final Environmental Impact Statement
watershed conditions will not be irreversibly damaged." [16 U.S.C. 1604 (g)(3)(E)]
(Preservation/Conservation Organization, Moscow, ID-#22.26.31200.133)
RESPONSE:
The regulatory framework for protection of soil resources is displayed in FEIS,
Chapter 3, Section 3.1. The analysis of effects on soils, including compaction,
displacement, erosion, mass wasting, nitrogen, potassium, and soil wood, is also
in this Section. Project design and mitigation measures developed to keep soil
effects within Forest Plan standards, protect slope stability, and to respond to
additional productivity concerns, are in Table 2.3. Additional soil improvement
projects to help restore soil productivity on other sites within the project area are
shown in Appendix D.
cs (ss as ca as ds
50. THE NEZ PERCE NATIONAL FOREST SHOULD SELECT HARVEST TECHNIQUES WITH
THE LEAST AMOUNT OF SOIL DISTURBANCE.
A. The methods that are proposed to harvest trees from the project area are likely to
compact soil, increase erosion, and incur more disturbance than is acceptable.
In areas where treatments are ecologically appropriate, the Forest Service
should select harvesting techniques with the least amount of soil disturbance.
Multi-span cable yarding with a full-tree suspension system and helicopter
logging should be considered instead of tractor-jammer systems where feasible.
We recommend that any and all harvesting occur over frozen or dry soil, with
recognition of sensitivity to nesting or denning species. An increase in hand
thinning and a decrease in mechanized thinning would also lower detrimental soil
disturbance factors. Vehicles which destroy ground cover, expose mineral soil to
erosion, and compact soils for reduced absorption and increased runoff should
be specifically prohibited. (Preservation/Conservation Organization, Boise, ID -
#15.118.34400.231)
B. BY MINIMIZING GROUND BASED LOGGING
Ground-based logging should be minimized as much as possible since it would
further degrade soil quality via compaction. Not only should logging be scaled
back, but the logging which does occur should include those methods that have
the least impact on soil quality. (Preservation/Conservation Organization, Boise,
ID-#15.41.34400.231)
RESPONSE:
Logging systems are chosen based on a combination of cost, terrain, and
silvicultural prescription and are described in Chapter 1 of the FEIS. Cable
logging is prescribed for about 41 percent of the proposed harvest acres and
ground-based systems for 59 percent. Effects of ground-based logging
including compaction, displacement and erosion are analyzed in the FEIS
Chapter 3, Section 3.1. Extensive design criteria and mitigation measures
have been developed for this project to limit detrimental soil physical
disturbance from ground-based logging (refer to Table 2.1). Monitoring is
also proposed during and after implementation to validate soil resource
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American River/Crooked River- Final Environmental Impact Statement
protection measures. Monitoring will be done to identify units with cumulative
soil disturbance in excess of Forest Plan standards and they will be treated
through post-activity soil restoration work. See the Monitoring Plan in
Appendix I.
51 . THE NEZ PERCE NATIONAL FOREST SHOULD CONFIRM THAT SOIL COMPACTION
THRESHOLDS COMPLY WITH FS HANDBOOK FSH 2509.18.
The Forest Management Handbook at FSH 2509.18 directs the FS to do validation
monitoring to "Determine if coefficients, S&Gs, and requirements meet regulations,
goals and policy" (2. 1 - Exhibit 01). It asks what we are asking: "Are the threshold
levels for soil compaction adequate for maintaining soil productivity? Is allowing 15%
of an area to be impaired appropriate to meet planning goals?" The Ecology Center
recently asked the Northern Region if they have ever performed this validation
monitoring of its 15% Standard, in their February 26,2002 Freedom of Information
Act request to the Regional Forester, requesting:
The Forest Management Handbook at FSH 2509. 18 provides the Forest Service with
examples of validation monitoring to "Determine if coefficients, S&Gs, and
requirements meet regulations, goals and policy." It asks "Are the threshold levels
for soil compaction adequate for maintaining soil productivity? Is allowing 15% of an
area to be impaired appropriate to meet planning goals?" We request all
documentation of validation monitoring by the Forest Service in the Northern Region
that answers those two questions.
The Northern Region office's reply letter stated that them is no documentation that
responds to this request. If the Nez Perce NF is aware of any new or other
documentation that would respond to this request, we ask that you please disclose it
to us now. (Preservation/Conservation Organization, Moscow, ID -
#22.27.30100.230)
RESPONSE:
The soil quality standards applied to this project are those of the Forest Plan. The
validation of soil quality standards requires a well-designed research program
addressing differences in soils, forest types, climates and treatment types.
Dumroese et al. (2000) found that the same standard for displacement would result
in widely varying amounts of carbon and nitrogen loss depending on soil type, while
effects on seedling survival and growth of compaction or displacement also varied
widely in many cited studies. Soil compaction and displacement effects are being
studied under the North American Long-Term Soil Productivity Study, which
replicates treatments of forest floor removal and compaction across many soil types
and climate zones (Powers, 1990). This study should help us understand degrees
of impacts at a point. Studies to examine the areal extent of impacts on soil,
hydrologic and vegetation processes at a broader scale could be more complicated.
The derivation of the 1 5 percent Region 1 guideline (or 20 percent in the Forest Plan)
for areal extent of disturbance was thought to represent the threshold of statistical
detectability, in its effect on stand productivity (Howes, personal communication,
2004; Cline, personal communication, 2004).
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OS (S3 (33 03 (S3 US
52. THE FINAL EIS SHOULD INCLUDE THE EFFECTS OF THE PROPOSED PROJECT ON SOIL
PRODUCTIVITY.
The FE/S needs to analyze the effects of removing potassium-containing vegetation
on nutrient cycling in the area. (Preservation/Conservation Organization, Boise, ID -
#15.104.21100.232)
RESPONSE:
Analysis of potassium and nitrogen removal is in FEIS Chapter 3, Section 3.1.
The design criteria and mitigation in Table 2.1 specify bole-only yarding to reduce
potassium loss, and additional actions to over-winter slash before burning to
allow for nutrient leaching, to minimize excessive slash piling and redistribution of
nutrients, and to constrain slash burn intensity to reduce the amount of
potassium and nitrogen volatilized.
(S3 (S3 (S3 (S3 OS OS
53. THE FINAL EIS SHOULD CLARIFY AND DOCUMENT HOW LONG-TERM SUSTAINABILITY
OF SOIL CONDITIONS WILL BE PROTECTED.
A. GIVEN POTENTIAL IMPACTS OF GROUND BASED EQUIPMENT AND SLASH TREATMENT
Long term impacts to soil potassium and nitrogen may be unacceptable under
the National Forest Management Act and the existing Forest Plan. Please clarify
in the FEIS how the application of ground based equipment, in concert with high-
severity slash treatments will ensure the long-term sustainability of soil resources
in the project area. (Preservation/Conservation Organization, Boise, ID -
#15.42.10400.230)
RESPONSE: See response to comment 52 above.
escsea
B. GIVEN INADEQUATE EXPLANATION OF HOW FOREST PLAN SOIL STANDARDS WILL BE
MET
The DEIS fails to adequately explain how Forest Plan Soil quality standards will
be met. There is inadequate information provided in several locations including
one at page 44 which states, "Assuming that compaction and displacement can
be held to within the 20 percent area disturbance threshold of Forest Plan Soil
quality standard 2?" The FS must clarify what this assumption is based on since
it appears to be unlikely given the past compaction and displacement that has
occurred from other logging projects in the area.
There are apparent contradictions in the DEIS. At page 87 it states, "All
alternatives may meet Forest Plan soil quality standards on harvest units, if
mitigation and design measures are rigorously implemented, so that cumulative
effects are the same for all alternatives on a site basis." It then goes on to
seemingly discount this prediction when it states, "The likelihood of exceeding
the standards increases with increasing number of activity areas proposed for
ground based logging or temporary road construction." Given that the Preferred
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American River/Crooked River- Final Environmental Impact Statement
Action, Alternative D, is ranked as the worst alternative in this regard, it is highly
questionable whether soil quality standards would be met, regardless of
mitigation measures. (Preservation/Conservation Organization, Boise, ID -
#15.39.10400.231)
RESPONSE:
This discussion has been augmented in the FEIS. Please See FEIS 3,
Section 3.1, summary of cumulative effects for soil physical properties and
compliance with forest plan standards.
08 08 08 (S3 (S3 03
54. THE NEZ PERCE NATIONAL FOREST SHOULD LOOK AT SEDIMENTATION EFFECTS.
A. TO DETERMINE IF ADDITIONAL SEDIMENT REDUCTION PROJECTS COULD BE IDENTIFIED
IN SILVER AND QUARTZ CREEKS
In addition, if this is an area [Silver and Quartz Creeks] of particularly high
sediment loading, perhaps additional sediment reduction projects could be
identified in these watersheds to further reduce sediment levels towards the
TMDL goal. (Federal Agency, Elected Official, Seattle, WA - #24. 12.31200. 180)
RESPONSE:
Additional field assessment and modeling were conducted for Silver and
Quartz Creeks for the FEIS. Site-specific recommendations were made to
reduce sediment yield from existing roads planned for reconditioning, new
temporary roads and harvest units. These recommendations were
incorporated and are documented in the Record of Decision. This review
also resulted in adjustments to the stream crossings planned for upgrades in
Silver Creek.
B. TO CONDUCT ADDITIONAL MITIGATION MEASURES AND DECREASE SOIL
SEDIMENTATION
While road obliteration will improve water quality in the long term, road
obliteration and reconstruction will inevitably entail soil disturbance and short-
term increases in sedimentation rates. Additional mitigation measures, such as
stream bank stabilization upstream and downstream of the site, are needed
which guarantee no near-term net increases in soil disturbance or sedimentation
in the watershed as a whole. (Preservation/Conservation Organization, Boise, ID
-#15.74.31200.230)
RESPONSE:
Stream crossings are given special attention during design and
implementation of road obliteration projects. Site-specific best management
practices are employed to minimize short-term sediment yield and to enhance
stability of the stream and adjacent slopes. Within the crossing site,
measures might include dewatering, drop structures, placement of large
wood, mulching, seeding, and/or planting. Temporary sediment traps might
be utilized downstream of the crossing. In some case, channel gradient and
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American River/Crooked River- Final Environmental Impact Statement
steps need to be reestablished upstream of the site. The mix of measures
applied will vary based on site characteristics.
55. THE FINAL EIS SHOULD PROVIDE MORE INFORMATION AND DISCUSSION ABOUT
ANALYSIS AND CONCLUSIONS RELATED TO SEDIMENT TRANSPORT AND DEPOSITION.
A. TO SUPPORT CLAIMS THAT CURRENTLY DEGRADED STEAM CONDITIONS WILL BE
REVERSED
1 . There is a significant inconsistency between current assessments of river and
stream conditions versus, again, what you augur will happen in some distant
future in terms of habitat improvement. As an example, on pages 12 and 130
you summarize these river systems for their existing condition of Cobble
Embeddedness, Pool: Riffle Ratios, Large Woody Debris and Percent
Surface Fines. This is a pretty good general summation of what condition
these rivers are in regarding fisheries habitat. You also show in the same
tables what the Forest Service objectives are for each of these components.
In the majority of the stream reaches, your own data clearly shows serious
shortcomings in stream health. In my limited experience, when rivers and
tributary streams are allowed to degrade to this extent, it is extremely
questionable if and when they will ever return to any degree of their original
condition. Never the less, this DEIS, by subtle suggestion, predicts that
eventually, these degrading conditions will be reversed. On page 101, you
tell the public that low gradient stream sediment "tends" to have a long
residence time but will "eventually" be transported or reorganized by high
steam flows. You do not describe the sediment as to whether it is fine or
course material nor do you volunteer the fact that often this predicted "high"
stream flow will frequently be the source of additional deposits of sediment of
varying size and weight. High stream flows can and do move fine sediments,
However, when course "bedload" sediments are deposited in the medium
gradient stream segments, it fills virtually every depression, including critical
pools. You are acutely aware of this. I point this out because the previously
referred to tables testify to a very low Pool to Rifle ratio, indicating we are
dealing with sediment of a size and weight nature that is not easily
transported or reorganized as you imply will happen. It is such incredibly
generalized assurances that I challenge. (Individual, Post Falls, ID -
#19.6.13100.234)
RESPONSE:
Further discussion of the characteristics of sediment yield, transport and
deposition in the American and Crooked River watersheds is found in
Appendix E of the DEIS and FEIS. This includes an explanation of the
particle sizes that are expected to be produced from project activities and
those that have been sampled in transport at gauging stations in nearby
streams. The low poohriffle ratios in mainstem reaches of American and
Crooked Rivers are primarily explained by the dredge mining that took
place during the first half of the 20th century. The channel morphology
was drastically altered by this practice, with loss of pools being one
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American River/Crooked River - Final Environmental Impact Statement
outcome. These streams have been partially restored with instream
enhancement projects, and this project will further improve the situation in
Crooked River with maintenance of existing structures and additional
instream enhancements. The dredge mining in American River took
place largely below the Forest boundary. Based on channel observations
and monitoring in nearby Red River, it is evident that the bedload
transport in American and Crooked Rivers consists mostly of sands and
gravels. Coarser cobble materials are also transported, but not in
excessive quantities that result in significant channel aggradation. The
concern with sediment deposition is mostly with fine materials (less than
6mm in diameter) that intrude into coarser substrates. This size of
material can be remobilized by high streamflows. Our approach is
premised on a reduction in chronic sediment yield, which should result in
improved substrate conditions over time. This effect should be further
enhanced by instream improvements, which are in part designed to
improve sediment transport.
usasvs
2. You offer absolutely no credible evidence that such a corrective process will,
in fact take place within any reasonable time frame. (Individual, Post Falls, ID
-#19.7.13100.234)
RESPONSE:
Section 3.3. (Fisheries) of the Final Environmental Impact Statement
supplies information pertaining to past research that provides evidence
that such corrective activities will improve aquatic condition in the
watershed within reasonable time frames. The following is an excerpt
from Section 3.3. (Fisheries) of the FEIS. In this work, Idaho Department
of Fish and Game employee Russ Kiefer (Fisheries Biologist) makes the
following observations:
• Our research indicates that in streams degraded by dredge
mining, connecting off-channel ponds to the stream can
increase the carrying capacity for Chinook salmon parr
(Kiefer and Forster, 1991), and complex instream
structures can increase the carrying capacity for steelhead
trout parr (Kiefer and Lockhart, 1995a).
• We observed a shift in spawning areas by adult Chinook
salmon to cleaner gravel areas produced by habitat
rehabilitation structures in Crooked River (Kiefer and
Lockhart, 1993). In streams with more than 30 percent
sand in spawning areas, habitat structures that collect
cleaner gravel with less than 30 percent should increase
smolt production.
• Complex habitat enhancement structures apparently can
increase the carrying capacity for age-1+ steelhead trout in
streams with low habitat complexity. Dredge mining has
reduced the habitat complexity in the upper meadow
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American River/Crooked River- Final Environmental Impact Statement
section of Crooked River (Middle Crooked River) by forcing
the channel against the canyon wall on the east side of the
meadow. We observed more than double the density of
age-1+ steelhead in complex habitat study sites than we
observed in control or simple sill log habitat sites in 1992
(Kieferand Lockhart, 1995).
O3C3OS
B. BY CHARACTERIZING PARAMETER VALUES. ASSUMPTIONS. POTENTIAL BIAS. AND
UNCERTAINTY ASSOCIATED WITH THE NEZSED SEDIMENT MODEL. IN THE ABSENCE
OF MONITORING DATA
There is an increasing reliance on modeled parameters at the expense of
continuing needed monitoring as required by the forest plan. NEZSED is used
as the model in spite of serious problems with it. There is one critiques of
NEZSED referenced in the DEIS (Gloss 1995). However, the DEIS fails to
capture the serious problems with this model uncovered in that master's thesis.
Even more critical is the omission Mickey's research of WATBAL NEZSED is a
"version" of WATBAL and it is very similar. This peer-reviewed study by Mickey
(1997) has documented that the WATBAL model consistently underestimates the
amount of sediment actually reaching streams. WATBAL underestimates
sedimentation for a number of reasons. One example is that the model assumes
that all sedimentation effects front roads significantly diminish after a brief period
In fact, as the 1995-96 slides, particularly on the adjacent Clearwater National
Forest graphically demonstrated, roads and road failures can continue to
contribute sediment to streams, often on a massive scale, for literally decades
(McClelland et al. 1997; Pipp et al. 1997; Espinosa, 1998). Another major flaw
illustrated by Mickey was the manner in which the model deals with precipitation
especially storm events. The model deals with average conditions, and does not
consider intense storm events, such as the 1995-96 events. Indeed, the
McClelland study similarly noted (Vol. II, p.4) that 'WATBAL is not an episodic
simulator and was never intended to model events. The program's source
information was (and continues to be) based on long-term measured averages."
Many of the watersheds that were blown-out by the flooding and landslides in
1995-96 were assessed as "recovered" by WATBAL.
The DEIS claims all /s well with water quality, based upon NEZSED and other
predictions. This is not based upon monitoring data. (Preservation/Conservation
Organization, Moscow, ID - #22.21.13100.234)
The reliance of the project on the NEZSED model is problematic. The FEIS
should consider and discuss limitations and requirements of the model to provide
accurate estimates for sediment delivery. (Preservation/Conservation
Organization, Boise, ID-#15.36.13000.234)
RESPONSE:
The section on model limitations and tests, found in Chapter 3 of the DEIS,
has been expanded in Appendix E of the FEIS. The results of four
NEZSED model tests are discussed, including a new test by Thomas and
King (2004). WATBAL and NEZSED share certain common ancestry with
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regard to surface erosion sediment yield and equivalent clearcut area
computations. They are different in that NEZSED does not estimate
activity-related mass erosion events greater then 10 cubic yards in size,
nor does NEZSED compute water yield increases. NEZSED coefficients
show that sediment yield from roads decreases after initial construction, but
not to zero.
The Mickey (1997) report compared WATBAL results against measured
sediment yield data. Although there are similarities between WATBAL and
NEZSED, there are enough differences that direct comparisons are
problematic. NEZSED has been tested against local field data and those
results are presented in Appendix E of the FEIS.
The 1 995-1 996 storms on the Clearwater and Nez Perce National Forests
resulted in numerous landslides from roads. Few if any of these occurred
in the American and Crooked River watersheds. This is due in part to the
generally low landslide hazard of land types in the project area.
The DEIS did not claim that "all is well" with water quality. It used a
combination of field data, observations, modeling and professional
judgment to disclose current conditions and estimated effects of the
alternatives.
C. BY CLARIFYING THE RELATIONSHIP BETWEEN SEDIMENTATION. HIGH FLOW EVENTS,
AND CANOPY REMOVAL
There /s another issue that is being avoided in your DEIS; I suspect this
avoidance is intentional as I cannot nor do I believe the Nez Perce NF is
unaware of the water release changes brought about by excessive canopy
removal. Your DEIS very briefly discusses this problem on page 91 where you
refer to research in nearby Horse Creek which "demonstrated instantaneous
peak flow increase up to 34 percent and maximum daily flow increases up to 87
percent, ". You also cite work done by King and Gerhardt regarding this peak
flow problem. Garry Kappesser Studied this phenomena extensively and
determined that large, and some not so large, removals of the overstory
produced significant changes in snow deposition and melting processes. As
referred to in the DEIS, this work has been studied extensively by Mr. King on the
H. J. Andrews Experimental Forest in Oregon. Further studies of the effects of
large clearcut openings and increased flows has been studied on the H. J.
Andrews (see Water Resources Research, Vol. 32, No. 4, April 1996, Jones and
Grant; and Vol. 37, No. 1, Jan. 2001, Jones and Grant) which corroborated the
conclusions that clear cuts, especially large cut areas, exacerbate the peak
runoff of snow melt, causing mi damage to down stream watersheds. The
presence of roads significantly aggravates this problem but the excessive
sediment deposition is not exclusive to roads alone. This very probably explains,
at least in part, the low Pool to Rifle ratios in the American and Crooked River
systems. With the typical aggregate size deposited due to these peak flow
events, it is extremely doubtful that this sediment or bedload can be removed by
a high flow transportation event. Even if such an event does happen (75 to 100
year or greater event) the ensuing damage from that high flow often is counter
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American River/Crooked River - Final Environmental Impact Statement
productive in correcting past depositions. This DEIS completely ignores or
avoids serious discussion of this very common problem.
Your Appendix E, page E-26 shows again, a vague prediction that "vegetation
treatments (logging and thinning) will have a Low negative impact over the short
term on aquatic conditions but you completely disregard any long term impacts to
the hydrologic process due to this logging.
It is for the above reasons that I make the statement that while attempting to
reduce fire risk you are probably going to do so at the expense of further
degradation of the watershed be cause of the extensive removal ofoverstory and
the inclusion of new "temporary" roads. (Individual, Post Falls, ID -
#19.9.13100.241)
RESPONSE:
The DEIS and FEIS disclose the effects of timber harvest on water yield
changes, peak flows and stream channels using a combination of research
data, field data, EGA modeling and professional judgment. The concerns
expressed by the commenter with regard to excessive coarse bedload
deposition have not been observed to a large degree in the upper South
Fork Clearwater subbasin. This is primarily due to the climate, flow regime,
geology and stream types of the area. Refer to the cumulative effects
analysis in Chapter 3.
OS 080*
D. TO SUPPORT QUESTIONABLE CLAIMS THAT TIMBER HARVEST. ON AREAS AT RISK
FROM LANDSLIDES. IS NOT OF CONCERN
The DEIS claims, without offering any evidence, that logging in areas with
moderate hazard for landslides is not a concern. Given that areas naturally slide
in the Clearwater drainage, such an approach if far too cavalier. There is no
evidence presented that areas at risk for landslides can be logged without
threatening the watershed.
BMPs won't prevent landslides. In fact, Magistrate Judge Erickson sided with
plaintiffs on the adjacent Clearwater National Forest on the Fish Bate timber sale.
The judge noted (NO. CV-97-208-M-LBE):
Because BMPs have not been assessed for their effectiveness against landslide
events and because a high risk of landslides is acknowledged in the Fish Bate
preferred alternative, the Court finds it is not reasonable for the Defendants to
just summarily rely on BMPs to mitigate this environmental impact Therefore, the
Court finds the FEIS conclusion that the project will have no effect on water
quality to be arbitrary and capricious based on the undisputed risk of landslides
in the FEIS. Accordingly, the decision is reversed and remanded. This issue is
applicable here. (Preservation/Conservation Organization, Moscow, ID -
#22.24.13100.247)
RESPONSE:
The discussion of landslide analysis and management has been expanded
in the FEIS. Please see FEIS, Chapter 3, Section 3.1.
Appendix M
Page M-62
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American River/Crooked River- Final Environmental Impact Statement
longer than predicted. (Preservation/Conservation Organization, Boise, ID -
#15.32.21100.160)
RESPONSE: No such amendments are proposed with this project.
OS C3 0» O* C8 OS
59. THE FINAL EIS SHOULD PROVIDE EVIDENCE SUPPORTING QUESTIONABLE CLAIMS
THAT MITIGATION EFFORTS, SUCH AS DECOMMISSIONING ROADS, CAN OFFSET
DAMAGES CAUSED BY TIMBER HARVEST.
There is the continuation of a serious problem in these DEIS's, and this project is
replete with this problem, of the very vague assurance to the public that certain
mitigation work, such as "decommissioning" older roads, will produce tangible
improvements in the watershed; enough so as to offset damage caused by the
project itself On page 145, Cumulative Effects, you refer to Table 3 on page 33 as
listing of projects that supposedly will have some undefined effect on improving
fisheries. Yet, out of a list of 42 projects, there seems to be only one project or
activity that could possibly be construed as benefiting fisheries and that, again, is
very general by saying "Improving road surface—graveling and grading work".
Appendix D does a very good job in detailing mitigation work to be performed under
the various alternatives. However, it remains to be seen whether this work is
sufficient to truly overcome the negative impacts of the projects main objective and
that is to getting 25 MMBF off of the land. (Individual, Post Falls, ID -
#19.4.13100.381)
RESPONSE;
The aquatic trend analysis in Appendix E of the FEIS is the documentation
leading to the conclusion that an upward trend in aquatic condition is predicted
in the long term. This analysis takes into account the positive and negative
effects of the project activities in the short and long term.
See response to comment 7, above, for further discussion of fish habitat
improvements planned under this action. The proposed action would treat
approximately seven percent of the project area. Refer to the tables in FEIS,
Chapter 2
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60. THE NEZ PERCE NATIONAL FOREST SHOULD PROVIDE A DETAILED ANALYSIS OF
SEDIMENT SOURCES COMPARING CONTRIBUTIONS FROM ROAD DECOMMISSIONING
AND NEW ROAD CONSTRUCTION FOR EACH ALTERNATIVE.
The Forest Service should provide a detailed analysis of the sediment sources
comparing contributions from road decommissioning and new road construction for
each alternative. Predictions of sediment delivery to streams need to take into
account the fact that PACFISH and INFISH buffers rely on intact buffer zones not
impacted by previous road construction, harvesting, and mining activities.
(Preservation/Conservation Organization, Boise, ID-#15.29.30300.234)
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
The sediment yield analysis is done by summing the effects of each project
activity that could be modeled. A summary of sediment yield from new road
construction, road decommissioning and other project components for the
selected alternative is found in the Biological Assessment, which is an
appendix to the Record of Decision. We do not believe it necessary to disclose
this level of detail for each alternative. Since this information is not directly
related to the condition of PACFISH RHCAs, it was determined that it was
unnecessary to provide this level of detail for each alternative.
INFISH buffers do not apply to the Nez Perce National Forest.
(33 (33 (S3 (yi (33 (33
61. THE NEZ PERCE NATIONAL FOREST SHOULD QUANTIFY CHANGES IN SEDIMENT
LEVELS IN THE SILVER AND QUARTZ CREEKS.
S/Vver and Quartz Creeks are stated to have high sediment levels, but these levels
are not quantified. In order to fully evaluate this project, we believe it would be useful
to attempt to quantify these levels and, if possible, document how they may change
with the different alternatives. (Federal Agency, Elected Official, Seattle, WA -
#24.11.13110.234)
RESPONSE:
This analysis was completed for the FEIS. The results are found in Table 3.17
with accompanying narrative.
(S3 (33(33(33(33(33
WATERSHEDS
62. THE NEZ PERCE NATIONAL FOREST SHOULD PRIORITIZE WATER QUALITY, FISH
POPULATIONS, SOIL PRODUCTIVITY AND WILDLIFE PROTECTION.
Water quality, anadromous fish populations, soil productivity, and wildlife protection
must be the priorities of national forest managers, not below-cost timber sales that
wreak damage, requiring centuries of nature's repairs. Road-building and clear
cutting are not consistent with these objectives, given the cumulative impacts of past
sales such as Whiskey South, Blacktail Butte, and Red Pines. (Individual,
Minneapolis, MN - #32.2.30000.360)
RESPONSE:
Comment acknowledged. The selected alternative is consistent with the Forest Plan,
which considers these values in context.cs (33(3303(33(33
63. THE NEZ PERCE NATIONAL FOREST SHOULD PROTECT RIPARIAN AREAS.
A. BY PRESCRIBING NEW BUFFER ZONES
The Forest Service should prescribe new buffer zones, which will adequately
protect riparian areas from sedimentation stemming from road construction and
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
management-related mass wasting events. (Preservation/Conservation
Organization, Boise, ID - #15.30.31120.234)
RESPONSE:
The Interim Strategies for Managing Anadromous Fish-Producing
Watersheds on Federal Lands in Eastern Oregon and Washington, Idaho
and Portions of California (PACFISH) and supporting literature (February
24, 1995) establishes default Riparian Habitat Conservation Areas
(RHCAs) which were shown to protect streams from management activities.
These RHCAs have been incorporated into the design criteria for this
project (FEIS Section 3.3).
ososcs
B. BY LIMITING ACTIVITIES TO ONLY WATERSHED RESTORATION PROJECTS
According to the DEIS, "Management activities in riparian areas would be
minimized," at page 17. Activities in RHCAs should be limited to include ONLY
watershed restoration projects. No other activities should be permitted within
RHCAs. (Preservation/Conservation Organization, Boise, ID
#15.135.31120.247)
RESPONSE:
No timber harvest is proposed in the streamside RHCAs. Temporary roads
have been located to avoid RHCAs. In the event that RHCAs are
encountered during construction, these activities will be conducted to
minimize impacts following recommendations contained in PACFISH (see
response to comment 62, above).
OS (S3 OS OS 0* O*
64. THE NEZ PERCE NATIONAL FOREST SHOULD RESTORE THE WATERSHED.
A. TO SUPPORT FISH POPULATIONS
A better way to contribute to the economic and social well being of the local
communities is to repair the decades of abuse the landscape has suffered and
restore the watershed so that it supports thriving populations of Chinook Salmon,
Steelhead Trout, Bull Trout, Lampreys and other species. There are decades
worth of restoration projects in this area needing skilled forest workers. In
addition, fishing continues to bring significant income to the local economies.
(Preservation/Conservation Organization, Boise, ID-#15.11.30000.800)
RESPONSE:
This project includes all watershed and fish habitat restoration needs
identified in the FEIS. See response to comments 7 and 43, above.
0803CS
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
B. FOR AQUATIC LIFE FORMS INCLUDING LISTED AND SENSITIVE FISH SPECIES
One of the most important issues in the area is water quality, watershed health,
and hydrological integrity and how they affect aquatic life forms including the
listed and sensitive fish species. These fish are an important part of Idaho's
heritage and Forest Service has a grave responsibility to ensure fish populations
are available to meet the treaties, made between sovereigns, with the Columbia
Basin Tribes. Furthermore, all Americans and Idahoans have a keen interest in
the recovery of native fish. (Preservation/Conservation Organization, Moscow,
ID-#22.17.32300.380)
RESPONSE:
This project has been designed to meet the needs of the aquatic resources,
including fish. The Nez Perce NF has pursued an active and ongoing
dialogue with the Nez Perce Tribe at key points during the development of
this proposed project. Additionally, their advice and input has been sought
at various stages and is continually being incorporated into this document.
Also refer to the individual response to the Nez Perce Tribe's letters in
Appendix M and the response to comment 20.
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C. WITH THE USE OF FIRE
If you are trying to protect watersheds from adjacent fire, why? A little soot in the
water from a fire is much better in the watershed than petroleum product spills
from logging equipment, and sediment from roads, skid trails, and landings.
(Individual, Grangeville, ID-#30.4.31100.270)
RESPONSE:
The project is designed to minimize the risk of introduced sediment and
toxics. See FEIS Section 2.3.
(33 <33 03 <33 OS OS
65. THE NEZ PERCE NATIONAL FOREST SHOULD DESCRIBE WATERSHED CONDITIONS
THAT EXISTED PRIOR TO THE PRESENCE OF TIMBER HARVEST, RESOURCE
EXTRACTION, AND DEVELOPMENT.
A. TO COMPARE TO CURRENT CONDITIONS AND BETTER ASSESS CUMULATIVE IMPACTS
When such information is provided, comparison with the current conditions (after
impacts of development) would aid in the assessment of cumulative effects of all
alternatives. It appears such information is not available in the DEIS.
(Preservation/Conservation Organization, Moscow, ID-#22.19.13100.002)
RESPONSE:
Baseline conditions are identified in the FEIS, Chapter 3, Section 3, Tables
3.24 and 3.27. Both the DFC Analysis (Espinosa, 1992) and the Revised
Matrix Pathways and Indicators of Watershed Condition (Revised 3/9/98).
Appendix M
Page M-67
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American River/Crooked River- Final Environmental Impact Statement
These documents and methodologies provide a numeric reference of
optimal fish habitat conditions.
The USDA Forest Service with funding from the Bonneville Power
Administration began restoration of Crooked River in 1984. This Project will
continue the restoration effort in Crooked River, which was begun in 1984.
American River has seen similar dredging activity and restoration work. For
a cumulative effects discussion refer to the FEIS, Chapter 3, Sections 3.2
and 3.3, and Appendix E.
Both mainstem American River and Crooked River occupy wide valley
bottoms. Fifth order streams in this undisturbed setting will typically
meander across the valley bottom in a C channel type (Rosgen , 1994).
These channels are often lined with hardwoods and provide stable undercut
banks with good shade and high quality pools in the meanders. The
potential is high for spawning habitat in these areas. A large bucket line
dredge (Mount Vernon Boat) was moved to Crooked River in 1938 and
operated there till 1942 when activities were curtailed by the War
Production Board (Sharon Murray, The Mount Vernon Dredge, ?). In 1939
alone, this dredge moved 218,335 cubic yards of gravel. Dredge mining
began again in 1946 for a short time and started again in 1952, continuing
until 1958 or 1959. Records (S. Murray) show well over 1,400,000 cubic
yards of gravel dug from the Crooked River valley during this period. The
dredge mining activities turned several miles of the valley bottom meadow
into an almost barren strip of rubble piles and a stream channel devoid of
fish habitat features.
The U.S. Forest Service with funding from the Bonneville Power
Administration began restoration of Crooked River in 1984. In summary,
this project installed over 660 pool and cover-creating instream structures;
creation of some 15,000 square meters of juvenile rearing and winter
habitat through side channel construction and pond connection;
rehabilitation of approximately 9,230 square meters of flood plain; and the
planting of some 30,000 hardwood shrubs and small conifers in riparian
areas (Siddall, 1992). American River has seen similar bucket line
dredging and restoration work. This project will continue the restoration
effort in Crooked River began in 1984.
B. BY USING MEASURES SUCH AS VALUES OF RIPARIAN MANAGEMENT OBJECTIVES
It is not clear from the DEIS whether an environmental baseline for watersheds is
included. Generally, this means their condition before development or resource
exploitation was initiated. For example, the baseline condition of a stream
means the habitat conditions for fish and other aquatic species prior to the
impacts of road building, logging, livestock grazing, etc. Proper disclosure of
baseline conditions would mean estimates of stream stability, pool frequency
conditions, water temperature range -essentially the values of Riparian
Management Objectives along with such parameters as sediment levels.
(Preservation/Conservation Organization, Moscow, ID - #22.19.13100.002)
Appendix M
Page M-68
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Section 3.3 of the FEIS identifies baseline conditions using both the DFC
Analysis (Espinosa, 1992) and the Revised Matrix of Pathways and
Indicators of Watershed Condition (Revised 3/9/98). These documents and
methodologies provide a numeric reference of optimal fish habitat
conditions that could be expected in undisturbed watersheds (prior to
development). Both mainstem American River and Crooked River occupy
wide valleys. Prior to development, of which dredge mining was the
primary influence, these rivers meandered across the valley bottom. The
rivers were likely lined with abundant grasses and woody vegetation
providing stable banks and shade. The pool to riffle ratio was likely high
with complex and high quality pools providing good quality habitat. Pool
tailouts were made up of high quality spawning habitat. The DFC Analysis
and Matrix of Pathways and Indicators use reference conditions from
similar undisturbed streams to quantify the optimum conditions, and these
are referenced to today's measurements to determine existing conditions
(FEIS Chapter 3.3)
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66. THE NEZ PERCE NATIONAL FOREST SHOULD DESIGN THIS PROJECT so THAT IT
MEETS EXISTING WATER QUALITY AND HABITAT STANDARDS.
A. TO CORRECT CURRENT VIOLATIONS OF FOREST PLAN AND IDAHO TMDL (TOTAL
MAXIMUM DAILY LOAD) GOALS FOR SEDIMENT AND TEMPERATURE
The proposed salvage harvest and road maintenance, reconstruction, and
construction design criteria and best management practices need to be designed
and implemented to significantly improve existing aquatic conditions. Existing
aquatic conditions are in violation of Forest Plan standards for sediment and
temperature and must be significantly improved in order to comply with the
Forest Plan and the Idaho Department of Environmental Quality TMDLs.
(Preservation/Conservation Organization, Boise, ID-#15.133.10400.100)
RESPONSE:
The FEIS recognizes the below-objective conditions of these watersheds.
The aquatic trend analysis documented in Appendix E suggests that an
upward trend in aquatic condition is expected to be achieved with this
project.
030S03
B. The draft sediment TMDL for the South Fork Clearwater River requires a 25%
decrease in sediment, most of which would need to take place in tributaries such
as the Crooked River, American River, and tributaries. The Forest Service
should consider whether the planned harvest and road construction in these
drainages is warranted given the large portion of the South Fork Clearwater
sediment budget these watersheds will occupy. (Preservation/Conservation
Organization, Boise, ID - #15.28.10400.137)
Appendix M
Page M-69
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
This project is predicted to result in a net decrease in sediment yield to the
South Fork Clearwater River over time (refer FEIS, Chapter 3). An
implementation plan for the South Fork Clearwater River TMDLs is
scheduled to be completed in 2005. No single project will be expected to
achieve the entire TMDL sediment reduction goal. However, this project
will contribute toward that goal.
C. TO AVOID THE NEED TO EXEMPT PORTIONS OF THE PROJECT FROM FOREST PLAN
STANDARDS
In order for the project to comply with the Forest Plan, amendments would have
to be included to exempt certain portions of the project from Forest Plan
standards. While this is true, we do not advocate for Forest Plan Amendments
which lower the standards for sediment, so/7s, Equivalent Clearcut Areas, fish
habitat, water quality, stream productivity, or other issues. Instead we urge you
to modify the project in order to comply with the existing Forest Plan.
(Preservation/Conservation Organization, Boise, ID - #15.50.10400.160)
RESPONSE:
The proposed project is in compliance with the Forest Plan and no amendments
would be required.
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D. TO ENSURE THAT THE PROJECT SCHEDULE IS CONSISTENT WITH IDAHO TMDL
TIMELINES
We encourage the USFS to evaluate whether the proposed timeline will be
consistent with Idaho Department of Environmental Quality's (IDEQ's) draft
Guidance for Forest Practices Discharging Sediment Into 303(d) Listed
Waterbodies. (Federal Agency, Elected Official, Seattle, WA -
#24.17.10400.180)
RESPONSE:
Comment acknowledged. We are familiar with the draft guidance and believe
this project is consistent with it.
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E. BY EXAMINING IMPACTS OF ROAD AND LAND USE CHANGES AT SUBWATERSHED
LEVEL
The analysis must examine changes in subwatershed and riparian road
densities, road/stream crossings, ECAs, and sediment yields above baseline.
(Preservation/Conservation Organization, Boise, ID - #15. 133. 10400. 100).
RESPONSE:
Subwatershed road densities and sediment yields above baseline are
disclosed by alternative in the FEIS, Chapter 3, Tables 3.7, 3.10, 3.14, and
Appendix M
Page M-70
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American River/Crooked River - Final Environmental Impact Statement
3.17. Additionally, existing riparian road densities are shown in Tables 3.6
and 3.13. These figures are not expected to change much by alternative
since all temporary roads are being decommissioned and few of the
existing roads planned for decommissioning are located in riparian areas.
Existing stream crossings are shown in Tables 3.21 and 3.22. Although
road/stream crossings are not enumerated by alternative, miles of stream
with improved access are shown in Tables 3.32 and 3.36.
OtfOfJC*
F. BY ANALYZING CUMULATIVE EFFECTS WITHIN BIOLOGICAL ASSESSMENTS AND
EVALUATIONS
It has been well-established that site- specific Biological Evaluations (BEs) or
Biological Assessments (BAs) must be prepared for all actions such as this.
Further, the Forest Service Manual requires that BEs/BAs consider cumulative
effects. The Forest Service Manual states that project BEs/BAs must contain "a
discussion of cumulative effects resulting from the planned project in relationship
to existing conditions and other related projects" [FSM 2672.42(4)]. "Existing
conditions" obviously are the current conditions of the resources as a result of
past actions. (Preservation/Conservation Organization, Moscow, ID -
#22.66.10400.130)
RESPONSE:
A site-specific BE has been prepared for this project and is included with
the FEIS and ROD. Non-federal activities are included in the cumulative
effects section to the BE.
O* OS OS OS OS OS
67. THE FINAL EIS SHOULD INCLUDE ADDITIONAL INFORMATION ON THE ASSUMPTIONS
AND PARAMETERS USED TO PREDICT SEDIMENT YIELD AND CUMULATIVE EFFECTS ON
WATER QUALITY.
A. The riparian buffers and watershed restoration activities will have a beneficial
effect on reducing sediment loads to the streams; however, there is a need for
the EIS to contain additional information on the assumptions and parameters
used to predict the sediment yield to streams from the project. (Federal Agency,
Elected Official, Seattle, WA - #24.2.21100.234)
RESPONSE:
The section on model assumptions, limitations and tests, found in Chapter
3 of the DEIS, has been expanded in Appendix E of the FEIS.
OS OS OS OS OS 0$
B. We recommend that the document list any land management activities by private
land owners in the South Fork of the Clearwater River basin that may be
adversely contributing to sediment and shade targets and therefore having
cumulative effects on water quality. (Federal Agency, Elected Official, Seattle,
WA-#24.7.21100.234)
Appendix M
Page M-71
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
The cumulative effects of activities occurring on private lands are
accounted for in the FEIS, to the extent that information has been obtained
from 2002 aerial photographs and through field knowledge of the area.
OS
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American River/Crooked River- Final Environmental Impact Statement
American and Crooked River watersheds. Figures E.4 and E.5 graphically
show the results for each subwatershed and the differences between
alternatives are more apparent.
(33 (33 (33(13(33 as
70. THE NEZ PERCE NATIONAL FOREST SHOULD INCORPORATE THE DESCRIPTION OF
THE WATERSHED IMPROVEMENT PROJECTS ON PAGES D-2 THROUGH D-3 INTO THE
BODYOFTHEFEIS.
We recommend that the description of the watershed improvement projects on
pages D-2 through D-3 be incorporated into the body of the final EIS. It is important
that readers understand the scope of the measures and process the USFS will use
to select treatments that would be implemented on a site specific basis, (Federal
Agency, Elected Official, Seattle, WA - #24.5.21100.247)
RESPONSE:
It was the editor's feeling that this table was too extensive to incorporate into
the main text of the FEIS. However, these tables are referenced in the text.
(33 (33 (33 (33 (33 (33
71. THE NEZ PERCE NATIONAL FOREST SHOULD CONSULT THE IDAHO WATER QUALITY
STANDARDS.
TO DETERMINE IF THIS PROJECT MEETS THOSE STANDARDS
Temperature has been identified as exceeding Idaho Water Quality Standards at
certain times of the year. Increased sedimentation could alter the channel
morphology, further increasing water temperatures in the streams. This problem is
further highlighted on page 14 of the DEIS, "Short-term increases in sediment yield
from proposed activities might contribute to degraded substrate conditions and
further reduce carrying capacity and quality of spawning habitat." This indicates that
existing "poor" conditions are likely to deteriorate and with the implementation of this
project will lower even further. (Preservation/Conservation Organization, Boise, ID -
#15.26.34000.246)
RESPONSE:
Water temperature increases are not predicted to occur as a result of this
project. Increases in sediment yield are not estimated to be of a magnitude
that would result in changes in channel morphology. Draft guidance posted on
the IDEQ website on April 8, 2004, indicates that short-term increases in
sediment yield may be allowable as long as beneficial uses are not impaired. It
will be up to IDEQ to determine if the impacts predicted to occur with this
project are of a magnitude that would impair beneficial uses.
(13(13(13(33(33(33
Appendix M
Page M-73
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American River/Crooked River- Final Environmental Impact Statement
72. THE NEZ PERCE NATIONAL FOREST SHOULD WORK WITH THE BLM AND THE NEZ
PERCE TRIBE TO DESIGN A CUMULATIVE WATER QUALITY IMPACT MONITORING PLAN
FOR THE SOUTH FORK CLEARWATER RIVER.
We highly recommend the Forest Service and BLM work with the Nez Perce Tribe to
design a cumulative water quality impact-monitoring plan for the South Fork
Clearwater River. With so much activity planned over a relatively short time period in
drainages tributary to the South Fork, a credible monitoring plan that can satisfy
public concerns is necessary. (Timber/Wood Products Industry, Kamiah, ID -
#5.15.30100.240)
Also, because of the variety of fuel reduction projects that are approved or being
planned in the Elk City area, we suggest that your Forest work cooperatively with the
BLM in developing an integrated monitoring plan for the affected streams in the
upper South Fork Clearwater River to assure that water quality objectives are being
met. (Place Based Group, Lewiston, ID - #3.7.30100.246)
RESPONSE:
Response to both comments: The Nez Perce National Forest is committed to
working with the Nez Perce Tribe, state and federal agencies and the South
Fork Clearwater Watershed Advisory Group to develop a monitoring plan for
the South Fork Clearwater River.
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American River/Crooked River - Final Environmental Impact Statement
74. THE FINAL EIS SHOULD DETAIL REASONS FOR THE SEVEN YEAR LAG BETWEEN
COMPLETION OF WATERSHED RESTORATION ACTIVITIES AND SEDIMENT REDUCTION
BENEFITS.
Although we realize that watershed restoration activities cannot be completed at the
same time as timber harvest, EPA suggests that the final EIS describe in more detail
the reasons for the seven year period from the time of project completion to achieve
sediment reduction benefits. (Federal Agency, Elected Official, Seattle, WA -
#24.16.12300.234)
RESPONSE:
The "seven-year lag" presumably refers to the years 2005 and 2012 shown in
Tables 3.35, 3.36, 3.43, and 3.44. These are key points in the sediment yield
modeling process only. They are not meant to imply when improvement
projects might be implemented or effective. The year 2005 is the assumed
peak year of sediment yield and 2012 is as far as the modeling was carried into
the future. The graphs in Figures E.4 and E.5 display the model results of each
year, individually. Some improvement projects are immediately effective upon
implementation, while the benefits of others accrue over time.
0* OS OS 0* 0# 0«
75. THE NEZ PERCE NATIONAL FOREST SHOULD NOT HARVEST TIMBER.
BECAUSE TIMBER HARVESTING AFFECTS WATER QUALITY
The cumulative impact of the timber sales in the Whiskey South, Meadow Face,
Red Pines, Blacktail Butte, and Eastside Township and this one should be
considered. Logging has not shown to make the watershed quality any better.
It makes it worse, by creating areas that are easily erodible from removed
vegetation. (Individual, CoeurDAIene, ID-#11.2.34000.247)
RESPONSE:
Percent EGA and percent sediment yield over base were included in the South Fork
Clearwater River cumulative effects analysis for Whiskey South, Meadow Face, Red
Pines, and Eastside Township projects. These figures were not yet available for the
Blacktail project. The effects of logging on watershed resources and water quality
are disclosed in Chapter 3 of the FEIS.
76. THE NEZ PERCE NATIONAL FOREST SHOULD ANALYZE IMPACTS THE PROJECT WILL
CREATE ON THE BENNETT PROPERTY AS WELL AS TO OTHER PRIVATE LAND
HOLDINGS.
The Forest Service needs to analyze the impacts of clear cutting, road construction,
mining, construction, travel and management on Bennett property as well as other
private lands in the watershed. (Preservation/Conservation Organization, Boise, ID -
#15.144.30300.650)
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
A site-specific BE has been prepared for this project and is included with the
FEIS and ROD. Non-federal activities are included in the cumulative effects
section to the BE.
The cumulative effects of activities occurring on private lands are accounted for in
the FEIS, to the extent that' information has been obtained from 2002 aerial
photographs and through field knowledge of the area.
(S3 (S3 (S3 (33 (S3 (S3
SECTION 4 - FISHERIES
77. THE NEZ PERCE NATIONAL FOREST SHOULD MAINTAIN AND IMPROVE ALL
RESOURCE ATTRIBUTES, INCLUDING WATER QUALITY AND FISH HABITAT.
BECAUSE THE FOREST HAS LEGAL RESPONSIBILITIES TO TRIBAL TREATIES AND THE
PUBLIC:
The Forest Service, as a publicly supported entity has legal commitments to the Nez
Perce Tribal treaty rights and to the public to maintain and improve water quality, fish
habitat, and an intact forest for all to enjoy. (Individual, Coeur D Alene, ID -
#11.5.10000.002)
RESPONSE:
The Nez Perce National Forest Land and Resource Management Plan (USDA
FS, 1987a) recognizes this commitment to the Nez Perce Tribe in Forestwide
Management Direction (page 11-18). Furthermore, the Nez Perce NF has
pursued an active and ongoing dialogue with the Nez Perce Tribe at key points
during the development of this proposed project. The Tribe's advice and input
have been sought at all phases and are continually being incorporated into this
document. Also, refer to the individual responses to the Nez Perce Tribe's
comments section in this document.
The commitment to the public to maintain and improve water quality and fish
habitat is detailed in the FEIS, Chapter 3, Section 3.3.
(33 (S3 (S3 (S3 (33 (33
78. THE FINAL EIS SHOULD ADDRESS THE RELATIONSHIP BETWEEN WATER QUALITY
AND FISH HABITAT.
The DEIS fails to draw adequate attention to the obvious relationship between water
quality and fish habitat. The linkages between these issues need to be fully explored
in the FEIS. (Preservation/Conservation Organization, Boise, ID -
#15.34.21100.381)
RESPONSE:
The FEIS, Chapter 3, Section 3.3 Analysis Methods, clearly shows and
recognizes the important linkage between fish and water quality. Both
resource areas (Fisheries and Watershed) document existing conditions and
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changes resulting from this planned action using common indicators of
condition like sediment, water temperature, and water yield.
VS OS <38
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American River/Crooked River- Final Environmental Impact Statement
meet the Riparian Management Objectives (RMOs) as defined in the Forest
Plan and PACFISH.
82. THE FINAL EIS SHOULD ADDRESS OPPORTUNITIES TO REDUCE THE RISK OF
ADVERSE EFFECTS TO BULL TROUT.
The Department recommends that the Forest seek opportunities in the FEIS to
further reduce the risk of adverse effects to bull trout by either decreasing the
amount of road construction and harvest acres in the most critical areas, or by
expanding the watershed improvements closer to what is shown in Alternative E, or a
combination of both. We believe that taking proactive steps to improve conditions in
affected watersheds will reduce the risks to bull trout conservation and recovery
associated with multiple concurrent fuels treatment projects within the same sub-
basin. (Federal Agency Official, Portland, OR - #35.4.23400.380)
RESPONSE:
Comment acknowledged. The selected alternative (Alternative D, modified)
reflects an increased emphasis on watershed restoration.
O80* 08 030308
83. THE NEZ PERCE NATIONAL FOREST SHOULD CONSIDER CUMULATIVE EFFECTS ON
THE BULL TROUT IN UPPER SOUTH FORK CLEARWATER DRAINAGE DUE TO FOREST
SERVICE AND BLM FUEL TREATMENT PROJECTS.
Bull trout conservation and recovery is of particular concern in the Upper South Fork
Clearwater drainage where many fuels treatment projects similar to the Project are
currently proposed, including the Bureau of Land Management's Whiskey South and
Eastside Projects and the Forest's Red Pine Project. Concurrent implementation of
these fuels treatment projects and similar activities on private lands have a high
potential for cumulative and additive effects to all aquatic resources, including bull
trout. (Federal Agency Official, Portland, OR - #35.3.30300.380)
RESPONSE:
The FEIS Record of Decision (ROD) lists the projects you mention. These
activities are considered in the Cumulative Effects, Section 3.2 and 3.3. The
ROD also contains the final Biological Assessment in which it is recognized
that there will be a short period of increased sedimentation associated with
vegetation treatments, road construction/reconstruction, road
decommissioning, culvert replacement, and in channel improvements (FEIS,
Section 3.3, Environmental Consequences). This same section also highlights
that following this short term pulse of sediment will be a long term improvement
in fish habitat carrying capacity. This long term improvement will result from
culvert replacement leading to increased stream access, road
decommissioning, riparian planting leading to increased stream shade, and up
to 20 miles of in channel stream improvements. These actions will in turn lead
improved conditions for bull trout and other TES fish species.
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(33 08O8O80808
SECTION 5 - FIRE AND FUELS
84. THE NEZ PERCE NATIONAL FOREST SHOULD CONDUCT FUEL REDUCTION.
A. FOR WATER QUALITY
Fuel reduction is essential to protect long-term water quality from the severe
impact of catastrophic wildfire. Without adequate streamside vegetation,
sediment and high water temperatures will damage fish populations.
(Timber/Wood Products Industry, Kamiah, ID - #5.2.33400.246)
RESPONSE:
Fuel reduction would help to lessen the potential fire effects to riparian areas
located near the proposed treatment units, by lowering the possibility of a
severe fire burning into the riparian areas. Additionally, minimal vegetative
treatment activity would occur within the riparian areas thus conserving
current vegetation to offer streamside shading and sediment trapping.
Furthermore, as stated in the FEIS, Section 1.4, PACFISH RHCA buffers
would be in place for the duration of the project.
08O8O8
B. WITH MANUAL REMOVAL OF FINE FUELS
Any and all concern about fuels should focus on the manual removal of fine fuels
(dead grass, deal limbs, twigs on the ground, cones and needles, and Christmas
tree sized live trees: within 200 feet of a house or bam. (Individual, Grangeville,
ID-#30.8.33400.271)
RESPONSE:
While it is acknowledged that an efficient and effective method to protect
structures is by conducting work within the home ignitability zone, structure
protection is not the primary purpose and objective of this project (refer to
FEIS, Chapter 1, Section 1.3). Additionally, the Crooked River Defensible
Space project, which was scoped September 13, 2004, proposes to complete
vegetative management within 200 feet of private structures adjacent to lands
managed by the Forest Service.
0808O8
C. FOR BIG GAME SUMMER HABITAT
Both timber harvest and controlled burns will significantly increase big game
summer habitat, benefiting the stressed elk population of the Clearwater Basin.
(Timber/Wood Products Industry, Kamiah, ID - #5.4.23100.160)
RESPONSE:
Comment acknowledged. Harvest and burning will help create and
rejuvenate nutritious forage plants as discussed in the FEIS, Chapter 3,
Section 3.11.
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events that support gradual shifts in species dominance or migration to newly
suitable habitats. Use of fire and judicious harvest may help in this regard.
US (S3 OS OS (S3 03
86. THE NEZ PERCE NATIONAL FOREST SHOULD DESIGN A LONG-TERM VISION FOR THE
FUEL REDUCTION PROJECT AREA.
The DE/S a/so discussed Fuel Reduction Effectiveness and states as one of its
purposes to " Reduce the risk of large-scale crown fire by creating vegetative
patterns through harvest." Much of the project area has already been
fragmented through past logging, road construction, thinning, natural and
human burns, dredging and other disturbances. What is the long-term vision for
the project area? According to the aerial photo provided for the August 8, 2003
field trip to the project area, much of the project area has already been
subjected to "active management." We are curious what the end result would
look like, and whether or not the Forest Service foresees additional projects in
the near future to continue to "break up fuel continuity."
(Preservation/Conservation Organization, Boise, ID - #15.21.33400.279)
RESPONSE:
The long-term vision for the project area is being addressed in multiple planning
efforts. All will require integration of complex terrestrial, aquatic, and social
concerns, and integration with BLM activities. In American and Crooked River,
concerns include high aquatic potential, past management impacts, mixed and stand
replacing fire regimes, intermingled homes and communities, and nearness to
wilderness and roadless areas.
At the state and national scales, the Idaho Cohesive Strategy
(http://www.fs.fed.us/r4/id fire assessment/descriptions.html) and LANDFIRE
(http://www.landfire.gov/) are projects designed to develop consistent and accurate
data of vegetation conditions, fire fuels, risks, and ecosystem status at the national,
regional, and local scales for implementation of the National Fire Plan. These
projects could be used to prioritize areas for fuel treatments, which might target
areas within these watersheds. However, neither project provides guidance on
landscape design or how to reconcile conflicting terrestrial, aquatic, and social
values.
In the short term, and at the forest scale, a vegetation management strategy is being
developed that considers, by subwatershed, issues of aquatic values and sensitivity,
and vegetation and fire risk in comparison to natural disturbance dynamics. The
social context and the suite of appropriate management tools are also considered.
This is in progress.
In the longer term, forest plan revision may provide additional guidance that helps
establish objectives for watershed condition and landscapes considering terrestrial,
aquatic, and social factors.
US
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American River/Crooked River - Final Environmental Impact Statement
87. THE NEZ PERCE NATIONAL FOREST SHOULD SECURE FUNDING FOR MAINTENANCE
OF FUEL TREATMENT AREAS.
It would be useful for the final EIS to describe the funding source for long term
maintenance of these areas. Existing information strongly suggests that fuels
treatment areas that are not properly maintained over the long-term can increase the
risk of fire as slopes are opened up to sunlight and undergrowth is stimulated.
(Federal Agency Official, Seattle, WA-#24.25.14120.273)
RESPONSE:
The Nez Perce National Forest will continue to seek funding for the maintenance of
fuel treatment areas. Current sources include appropriated funds, trust funds, monies
from the North Central RAC (Resource Advisory Committee) and The Rocky
Mountain Elk Foundation. All of these funds fluctuate from year to year and must be
competed for with other Forests and Regions.
08 08 0*0* OS oa
88. THE NEZ PERCE NATIONAL FOREST SHOULD REDUCE THE RISK OF WILDFIRES.
A. TO PROTECT FOREST HEALTH. WATER QUALITY. HUMAN LIFE. AND PRIVATE
PROPERTY
By reducing the risk of wildfire, you are protecting forest health and water
quality as well as human life and private property. (Individual, Lewiston, ID -
#7.3.33000.002)
RESPONSE: Comment acknowledged
O808C8
B. WITH THE CONNECTION OF CLEARCUTS
In terms of hazardous fuels reduction and structural protection, this project,
as designed, is both inefficient and ineffective. Much of the surrounding
area has been heavily logged and, in the interest of community protection,
"connecting the clear cuts" could be more effective than laying out units on
the basis of pine beetle mortality, and/or economic factors.
(Preservation/Conservation Organization, Boise, ID - #15.106.33000.279)
RESPONSE:
The project would create breaks in the continuity of fuel arrangement within the
project area. These breaks would help to achieve two purposes; the first would
be to modify the fire behavior to produce a less intense fire. Also by lowering the
fire intensity these breaks will slow and modify the fire spread (Finney 2001) and
give suppression resources a safe area to initiate suppression responses. The
proposed treatment units would tie in with the past harvesting within the area to
create the spatial patterns referred to by Finney for landscape treatment to
modify the fire behavior.o* o* o*
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C. To PROTECT WILDLAND-URBAN INTERFACE AREAS
1. Creation and maintenance of an extensive fuels treatment network has
the potential to adversely affect water quality and wildlife habitat. We
agree with the USFS goal of concentrating fuels treatment areas near
urban interface areas. We also recommend attempting to locate them in
areas where impacts to water quality and sensitive habitats will be
minimized and where the vegetation is adapted to frequent fire return
intervals. (Federal Agency Official, Seattle, WA - #24.24.33400.240)
RESPONSE:
Fuels treatments can affect wildlife species and their habitats (See FEIS,
Chapter 3, Section 3.11). Forest Plan standards as well as the mitigation
and design factors applied to this project help reduce or eliminate most
risks (Refer to Chapter 2). Some of these include protection of old growth
and replacement stands, protection of buffers around goshawk nests,
incorporation of road decommissioning, reporting newly discovered dens
and nests of federally listed species and rare species, and protecting key
habitat components all help eliminate adverse impacts. (See FEIS,
Chapter 2, Table 2.3)
080*08
2. While clear [purpose and objectives], you may have expanded on the
need to protect the Elk City community. This project is but a part of the
master plan to treat rapidly deteriorating forests that provide a major
threat to the Elk City community by decreasing dangerous, unnatural
fuel levels. (Timber/Wood Products Industry, Kamiah, ID -
#5.1.33000.271)
The project will also help fireproof Elk City and provide some much-
needed forest product resources to the local economy.
(Recreation/Conservation Organization, Moscow, ID-#1.2.33470.810)
If there is to be any type of project, it needs to be located within the
wildland urban interface in order to provide protection from wildfires.
(Preservation/Conservation Organization, Boise, ID-#15.8.23000.271)
RESPONSE:
While conducting fuels treatments only near the wildland-urban interface
areas would help to protect these areas, it would not reduce fuel loadings
in the outlying areas away from the WUI. By not treating those outlying
areas, the treatments would not fully meet the purpose of the project
(FEIS, Chapter 1).
08 08 08 08 08 08
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89. THE NEZ PERCE NATIONAL FOREST SHOULD RELY ON BEST AVAILABLE SCIENCE TO
REDUCE RISK, INTENSITY, AND SEVERITY OF FIRES.
A. BY CONSIDERING THE WlLDLAND FlRE USE PROGRAM PRIOR TO IMPLEMENTING
FUELS REDUCTION OUTSIDE Will AREAS
Once the WUI areas on the Nez Pence National Forest have been treated, it may
be appropriate to consider fuels reduction efforts extending into the forest in
order to restore certain and selected fire-adapted ecosystems. However, such
future projects must be based on the "best available science" that relates to
reducing the intensity and severity of wildland fire. Further, the Wildland Fire Use
program may be a cost-efficient and effective method to reduce fuel loads,
restore fire-adapted ecosystems and to create heterogeneous landscapes that
would be less prone to large-scale fire events. We are aware that WFU is
outside the scope of this project, but feel that it is pertinent to consider the
potential for WFU in certain areas, in lieu of currently proposed logging.
(Preservation/Conservation Organization, Boise, ID -#15.92. 13000.330)
RESPONSE:
While a Wildland Fire Use (WFU) program may be a cost-effective method to
reduce fuel loads and restore fire adapted ecosystems, the Forest Plan and
Fire Management Plan currently do not allow for WFU within any portion of
the project area. Without the authority for WFU all fire ignitions within the
project area require a suppression response.
The analyses conducted as part of the FEIS are based on thorough
application of the best scientific information currently available to the project
Interdisciplinary Team. The information considered consists of scientific
literature, research findings, models and other information that apply to local
conditions within the project area or similar conditions in other nearby areas
that are relevant and can be extrapolated to the area affected by the project.
Use of the best science in the evaluation of this project includes consideration
of opposing viewpoints and disclosure of model and data limitations. Further,
the Forest's consideration and use of science has been coordinated with and
reviewed by other technical experts. Any comments received by those
experts have been considered and, as appropriate, included in the FEIS.
B. BY ACKNOWLEDGING THAT FUELS REDUCTION IS AN UNPROVEN SCIENCE AND ROADS
CAN EXACERBATE RUNOFF AND SEDIMENTATION
The DEIS acknowledges that the existing road network has negatively impacted
the watershed and that a fire would multiply these effects: "If the heavy fuel
accumulations were to burn under extreme conditions, the large number of roads
in the analysis area would tend to exacerbate an increase in run-off and
associated sedimentation from the burned area during post-fire precipitation
events" (P. 3). Instead of taking a logical approach of reducing the road system,
the Forest Service plans on removing the fuels using more roads, relying on
unproven science to justify these actions. (Preservation/Conservation
Organization, Boise, ID -#15.57.13000.410)
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RESPONSE:
No new, permanent road construction will occur with this project, and all
temporary roads constructed to facilitate treatment activities will be
decommissioned within a three-year period following their construction. Refer
to FEIS, Chapter 2, Tables 2.1 and 2.2. In addition, a minimum of 19.7 miles
of existing road will be decommissioned with this project (refer to Appendix D
in the FEIS). Additional miles of existing road may be decommissioned at the
discretion of the deciding official as stated in the ROD..
(3303(33
C. BY CONSIDERING HOME IGNITABILITY AND EVIDENCE SUGGESTING THAT FUEL
REDUCTIONS NEED ONLY OCCUR WITHIN TENS OF METERS FROM STRUCTURES
The FS (Cohen, 1999) reviewed current scientific evidence and policy directives
on the issue of fire in the wildland/urban interface and recommended an
alternative focus on home ignitability rather than extensive wildland fuel
management:
The congruence of research findings from different analytical methods suggests
that home ignitability is the principal cause of home losses during wildland fires.
Home ignitability also dictates that effective mitigating actions focus on the home
and its immediate surroundings rather than on extensive wildland fuel
management.
[Research shows] that effective fuel modification for reducing potential Will fire
losses need only occur within a few tens of meters from a home, not hundreds of
meters or more from a home. This research indicates that home losses can be
effectively reduced by focusing mitigation efforts on the structure and its
immediate surroundings. Those characteristics of a structure's materials and
design and the surrounding flammables that determine the potential for a home
to ignite during wildland fires (or any fires outside the home) will, hereafter, be
referred to as home ignitability.
The evidence suggests that wildland fuel reduction for reducing home losses
may be inefficient and ineffective. Inefficient because wildland fuel reduction for
several hundred meters or more around homes is greater than necessary for
reducing ignitions from flames Ineffective because it does not sufficiently reduce
firebrand ignitions (Cohen, 1999)
That research also recognizes "the imperative to separate the problem of the
Midland fire threat to homes from the problem of ecosystem sustainability due to
changes in wildland fuels" (Id). (Preservation/Conservation Organization,
Moscow, ID-#22.3.13100.270)
RESPONSE:
While it is acknowledged that an efficient and effective method to protect
structures is by conducting work within the home ignitability zone, structure
protection is not the primary purpose and objective of this project (refer to
FEIS, Chapter 1, Section 1.3). Additionally, the Crooked River Defensible
Space project, which was scoped September 13, 2004, proposes to complete
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vegetative management within 200 feet of private structures adjacent to lands
managed by the Forest Service.
D. BY APPLYING RESEARCH BY JACK COHEN REGARDING RISK OF STRUCTURAL FIRE
If you are trying to protect human structures and improvement, why is the DEIS
silent about the recent research finding by Forest Service fire physicist Jack
Cohen? Applying the Cohen finding to human structures, so when a fire does
get started, the risk of the structure burning is greatly reduced. (Individual,
Grangeville, ID - #30.5. 131 10.400)
RESPONSE:
Comment acknowledge. Refer to response to comment 89(C), above.
03O3OS
E. BY EVALUATING THE UTILITY OF FIRE SCARS TO ESTABLISH FIRE REGIMES IN A
VARIETY OF FOREST TYPES
Baker and Ehle paper ca//s into question the use of fire scars in establishing
mean fire intervals and suggests that previous reports based upon lire scars may
be biased. Most research, including that in the supporting documents for the
South Fork Clearwater, is based upon fire scars.
Regardless of whether Baker and Ehle are right, those using fire scars to
establish fire regimes are right, none are right, or all have validity, the fact
remains these scientists appear to have somewhat different view of ponderosa
pine systems, or at least what we think we know about them. The same
questions about fire scars need to be asked about other forest types as well.
This should have been fully recognized and evaluated in the DEIS.
(Preservation/Conservation Organization, Moscow, ID -#22.49. 131 10.277)
RESPONSE:
The focus of the paper by Baker and Ehle was on nearly pure ponderosa
forest, which make up a small portion of the project area. Ponderosa pine
systems are of very limited extent in the project area. The fire regimes
shown in Maps 9a and 9b of the FEIS are derived using the potential
vegetation data derived from the Idaho Cohesive Strategy
(http://www.fs.fed.us/r4/id_fire_assessment/id_haz_n'sk_review.html). They show areas of
frequent non-lethal fire limited to small warm steep slopes, mostly in
Crooked River.
Fire scar studies must be combined with landscape scale age-class
studies to understand fire regimes and fire patterns in areas of mixed and
lethal fire such as the project area. This has been done in the course of
preparation of the South Fork, Selway, and Slate Creek assessments
(USDA FS, 1997a, 1998, 2001), in which thousands of timber stand exam
plots were analyzed for evidence of non-lethal, mixed severity, or lethal
fire. We summarized these data by Vegetation Response Unit and the
inferred fire regimes are presented in those assessments by VRU. Fire
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ecology compilations such as Kapler-Smith and Fischer (1997) were also
used to validate these interpretations, and traditional fire scar studies
were used in areas of frequent low severity fire.
Baker and Ehle state in their paper that mean fire intervals based on fire
scar data may have uncertainties and biases and actually lead to longer
fire intervals than previously thought. They also state that fires are also
unrecorded upon trees (i.e., no fire scar), "Trees are often charred by a
surface fire, but fires do not always leave scars in particular areas or even
a whole stand, so fires may be unrecorded in fire scars", "It is uncertain
for example, whether a tree without a scar did or did not burn in a fire that
scarred nearby trees", and "The abundance of unrecorded fires is largely
unknown." This lack of an evident fire scar may actually lead
investigators to infer longer fire intervals than actually occurred.
Additionally, while Baker and Ehle suggest that there may be
uncertainties in the use of fire scars to determine fire intervals, they do
not offer any suggestions to reduce or mitigate these biases other than
bracketing fire intervals, which is what we have done in using fire regimes
and an associated range of fire intervals (e.g.,. 75 to150 years "for
infrequent fire regimes) for this project.
(3SOSOS
F. BY CONSIDERING EVIDENCE SUGGESTING THAT STAND-REPLACEMENT FIRE IS
NORMAL
Baker and Ehle paper calls into question the use of fire scars in establishing
mean fire intervals and suggests that previous reports based upon lire scars may
be biased. Most research, including that in the supporting documents for the
South Fork Clearwater, is based upon fire scars.
Regardless of whether Baker and Ehle are right, those using fire scars to
establish fire regimes are right, none are right, or all have validity, the fact
remains these scientists appear to have somewhat different view of ponderosa
pine systems, or at least what we think we know about them. The same
questions about fire scars need to be asked about other forest types as well.
This should have been fully recognized and evaluated in the DEIS.
(Preservation/Conservation Organization, Moscow, ID-#22.49.13110.277)
The DEIS indicates that large stand-replacing fires are not desired. Yet, they
were in the range of variability.
The attempts at breaking up the landscape to prevent or reduce large, stand-
replacing fires may be useless. If not, there is no real need to create anymore
breaks in the landscape as any aerial photograph or satellite imagery will attest
much has already occurred in those two drainages (see also DEIS maps 14 a
and b).
One of the major assumptions in the DES is that the no action alternative will
increase the probability of stand-replacing fires. Yet, that assumption is not
quantified. What will it do, increase it by 1%, 50% or 90%? Without some
quantification, so-called stand-replacing fife prevention under the various action
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alternatives is meaningless. (Preservation/Conservation Organization, Moscow,
ID -#22.52.13110.277)
RESPONSE:
Stand replacing fire, and the pulse watershed responses that ensue, are
intrinsic to historic and projected fire activity in the American and Crooked
River watersheds. The FEIS Chapter 1 - Conditions Contributing to the
Purpose and Need for Action, describes vegetation changes associated
with past fire suppression, succession, and mountain pine beetle activity.
These are believed to contribute to an enhanced potential for transition
from a ground fire to a crown fire, which could contribute to increased fire
size or severity under moderate burning conditions, and increased
difficulty of suppression. Current developing fuel conditions may have
occurred historically in these fire regimes, but the with the proximity to Elk
City and other residences and developments, large fires may not be
socially acceptable due to possible loss of life, property and/or resources.
Additionally, with no Wildland Fire Use plan for the project area, the
Forest Plan requires that suppression actions take place to control all new
fire starts within the project area. This sets a management context
under which some harvest and fuel reduction could be designed to
increase fire suppression effectiveness under moderate burning
conditions (Finney, 2001). A robust program of watershed improvements
(see Appendix D) should help improve resiliency to fire when one does
occur.
Quantifying the probability of a stand replacing fire occurrence is
impossible without specifying climate, ignition, burning weather and time
frame. Without those parameters, it can be assumed that the probability
of a stand replacing fire occurring under normal conditions would be
100%. The estimate that the no-action alternative would increase the
probability of stand-replacing fire is based on the premise that strategic
placement of fuel reduction areas in relation to existing areas of low
potential for fire spread or low resistance to control can help fire
suppression be more effective, which could prevent a small fire from
becoming large, if burning conditions are not severe (Finney, 2001). This
is described in the FEIS, Chapter 3, Section 3.4.
G. BY APPLYING LANDSCAPE-SCALE FIRE MODELING TO DETERMINE LOCATIONS OF
TIMBER HARVEST PRESCRIPTIONS
In order to be more efficient and effective, the NPNF should apply landscape
scale fire modeling, i.e. using FARSITE, to determine what the effects of the
proposed treatments would be. Such an analysis could also help to determine
more effective location of logging and silvicultural prescriptions in the interest of
reducing rates of fire spread, intensity and severity. (Preservation/Conservation
Organization, Boise, ID -#15.1 07.1 3000.270)
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RESPONSE:
The Nez Perce NF does not currently have good enough data for this
type of modeling to be effective over the whole forest.
(33O3O8
H. BY CONSIDERING EVIDENCE SUGGESTING THAT FIRE SUPPRESSION AND FUEL LOADS
ARE NOT WELL CORRELATED WITH SEVERE FIRES
Lodgepole pine (in fire groups three and four, see Smith and Fischer 1997) are in
stand-replacing fire regimes (Cooper et al. 1991, Barrett 1982 and Green 1994 in
Smith and Fischer 1997). Research from lodgepole pine in Yellowstone found
stand-replacing or severe fires are a function of weather, not fuel load (Turner et
al. 1994). This contradicts an important assumption in the DEIS.
The DEIS presents a version of history that is speculative, at best, given the
information—the science is not definitive on historical conditions, though the DES
pretends it is in certain instances. The belief that small, cool fires shaped the
landscape of the South Fork is not consistent with the data, especially the events
on the early 1900s. The belief that fire suppression everywhere had led to hotter
fires currently is not consistent with the burn intensity and severity of recent fires
(see for example, the Poet and Slims fire BAER report). Even if it were true fires
are burning hotter now, there is considerable evidence it is because of climate
change, not fuel amounts. (Preservation/Conservation Organization, Moscow, ID
-#22.55.13110.277)
RESPONSE:
Climate and fuels are closely related when discussing them in the context of fire
behavior. Climate can drive the fuels in availability for combustion, resulting
flame length and heat output, and future fuel loadings.
The cumulative effects of climate change, fire suppression, and short-term
climatic variability can interact to result in altered fire regimes, over which
management may have little control. Variations in climate are strongly correlated
over a wide region, so that historically severe fire years tended to occur
synchronously over large areas, coinciding with regional drought periods (Barrett
et al., 1997). Drought effects were strongly influenced by more variable factors
including large dry-lightning storms that produced mass ignitions and occurrence
of strong winds during fire events. If we experience a trend toward warmer,
wetter conditions, as several climate models suggest, but with the increased
precipitation occurring in primarily in the winter, there would be more severe
summer moisture deficits. If prolonged seasons of moisture deficits occur over a
wider area, larger areas could be prone to lethal fire, at least until species and
stand structure equilibrate to more frequent fire, assuming both frequency and
intensity of drought increase. Changes in wind, insects, and disease are also
likely, probably in the direction of increased drought stress and more
susceptibility to pathogens, which result in increased fuel loadings.
Healthy, vigorous stands of lodgepole pine generally have a high crown height
with little surface fuels and are typically classified as a fuel model 8. These
stands do require extreme weather conditions to create fire intensities hot
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enough to transition from a surface fire to a crown fire. Historically, these stands
would have had fires occurring during both extreme and normal weather
conditions. During the normal weather conditions fires would have burned with
low enough intensity to prevent transition from surface to crown fire, these low
intensity fires would have reduced the surface fuel loading within the stands.
During the extreme weather conditions those surface fires would have enough
intensity to transition to crown fires even with low fuel loadings due to the fact
that fuels were dryer and produced more energy during combustion.
With the mountain pine beetle epidemic occurring in the project area, and no
natural mechanism for removal of fuel accumulations due to fire suppression
requirements in the project area, these are no longer healthy stands with little
surface fuels, but rather are stands that already have high fuel loadings or will
have high fuel loadings as dead trees start to fall over, and are or soon will
become classified as being fuel model 10 or 13. Because of these higher fuel
loadings, a fire burning in these stands will burn with a greater intensity under
less than extreme weather conditions due to the amount of energy created when
more fuel is consumed during combustion. These higher intensities result in
higher flame lengths and heat produced which will allow for a surface fire to more
easily transition to a crown fire under more normal weather conditions. Please
refer to the fuel model discussion in the Chapter 3, Section 3.4 of the FEIS for
further discussion of the fuel models within the project area.
oseso*
I. BY CONSIDERING EVIDENCE SUGGESTING THAT FIRE SUPPRESSION IS NOT
CORRELATED WITH SEVERE FIRES IN OLD GROWTH AREAS
The DEIS is based on the premise that fire threatens old growth because of fire
suppression. However, most of the project area's old growth consists of areas
with very long and lethal fire intervals. Furthermore, the 80 year figure for fire
suppression is longer than the fire data indicate. When looking at historical data,
it becomes clear that prior to 1950, fire suppression seems to have been.
ineffective when looking at the acres of national forests burned.
(Preservation/Conservation Organization, Moscow, ID-#22.73.13110.365)
RESPONSE:
The old growth analysis has been revised. Please see FEIS Section 3.11.4 Old
Growth Habitat Analysis
The discussion in Chapter 3, Section 3.11 of the FEIS only states that the
current pine beetle infestations within the project area directly threatens
lodgepole pine stands and raises the risk of future fire induced old growth
losses. This is due to patches of old growth becoming more fragmented and
surrounded by large areas of dying lodgepole.
It is generally accepted that fire suppression became effective throughout the
area during the 1930s with the advent of the Civilian Conservation Corp as
large numbers of men went to work in the woods, and the advent of the 10:00
A.M. policy which stipulated control of wildland fires by 10:00 A.M. the following
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American River/Crooked River- Final Environmental Impact Statement
day after a fire was reported. These tools gave fire managers the needed
number of resources to effectively suppression fires.
05 as os (si an os
90. THE NEZ PERCE NATIONAL FOREST SHOULD RETURN FIRE TO THE ECOSYSTEM.
A. TO ALLOW A NATURAL FIRE CYCLE
Clearly, good professional forest management in fire-prone forests would
concentrate on: in the backcountry, let fire play its natural, beneficial role.
(Individual, Grangeville, ID-#30.7.33100.600)
I'll say it again, the real question that needs an answer is why would anyone
want to reduce backcountry fires? How does that logic flow with all the
hoop-la the Forest Service has been giving the importance of returning fire
to the ecosystem? Without providing you a basic course in forest ecology, I
will remind you that the creatures that live in the forest (both flora and fauna)
depend on the benefit from wildfires occurring periodically. You are land
managers with a mission of protecting and conserving the national forests
for 280 million people. How could you even contemplate interrupting this
magnificent natural fire cycle? (Individual, Grangeville, ID -
#30.2.33000.201)
Fire is natural, and can better care for an area than loggers ever could. It
occurs to me this is about lobbying loggers making money, not about what is
best for the forest. (Individual, Coeur D Alene, ID - #11.3.33100.822)
RESPONSE:
The Forest Plan and/or Fire Management Plan currently do not allow for
Wildland Fire Use (WFU) within any portion of the project area. Without the
authority for WFU, all fire ignitions within the project area require a
suppression response.
We acknowledge the integral role of natural fire in terrestrial and aquatic
ecological processes. The combination of past fire suppression, aquatic
habitat degradation, depressed fish populations, and homes and communities
intermingled in the American and Crooked river watersheds create an
environment where we cannot now implement a policy of natural fire use.
The current Forest Plan does not allow wildland fire use within any portion of
the project area. The nearest areas of permitted wildland fire use are the
Gospel Hump Wilderness and the East Meadow Creek roadless area.
Additional roadless areas closer to the project area could be proposed for
wildland fire use planning in the Forest Plan revision process. These include
West Meadow Creek and adjacent unroaded areas within the American River
watershed, and Dixie Summit-Nut Hill and adjacent unroaded areas within
Crooked River watershed.
oscses
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B. TO MAINTAIN WATERSHED INTEGRITY
Research shows the importance of fire in maintaining watersheds. It shows
that logging damages the watersheds while fire is crucial in maintaining
watershed integrity. Logging also dries out the soil, leaves slash on the
ground, and can lead to even hotter fires. Simply put, logging makes
matters far worse. (Individual, Delmar, NY - #28.2.33100.360)
Natural fire in this watershed would actually help maintain the watershed by
controlling bug and ground debris. (Individual, Moscow, ID -
#23.2.33110.002)
RESPONSE:
We acknowledge the integral role of natural fire in terrestrial and aquatic
ecological processes. The combination of past fire suppression, aquatic habitat
degradation, depressed fish populations, and homes and communities
intermingled in the American and Crooked river watersheds create an
environment where we cannot now implement a policy of natural fire use. The
current Forest Plan does not allow wildland fire use within any portion of the
project area. The nearest areas of permitted wildland fire use are the Gospel
Hump Wilderness and the East Meadow Creek roadless area. Additional
roadless areas closer to the project area could be proposed for wildland fire use
planning in the forest plan revision process. These include West Meadow Creek
and adjacent unroaded areas within the American River watershed, and Dixie
Summit-Nut Hill and adjacent unroaded areas within Crooked River watershed.
C. TO INCREASE BIG GAME SUMMER HABITAT FOR ELK
Both timber harvest and controlled burns will significantly increase big game
summer habitat, benefiting the stressed elk population of the Clearwater Basin.
(Timber/Wood Products Industry, Kamiah, ID - #5.3.33400.330)
RESPONSE:
Comment acknowledged. Harvest and burning will help to increase nutritious
foraging habitats for big game (See FEIS, Chapter 3, Section 3.1 1).
(S3 (S3 (19 US 08 O*
91 . THE NEZ PERCE NATIONAL FOREST SHOULD USE PRESCRIBED BURNING.
A. WITH THE USE OF PRESCRIBED BURN ONLY PRESCRIPTIONS
We encourage the Forest Service to expand the use of prescribed burn only
prescriptions, in efforts to decrease fuel loads and create a mosaic of varying
age-classes. It appears from Appendix H, where the silvicultural treatments are
described; that the only burning accomplished will be in areas that have been
harvested. In order to meet the purpose and need, bum only treatments are
appropriate and warranted. (Preservation/Conservation Organization, Boise, ID -
#15.112.33410.273)
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RESPONSE:
The use of prescribed burning only will not effectively reduce the fuel loading
within the stands to be treated. If the burning only is done under the existing live
canopy of the stands one of two results will happen; 1) the fuels will be too wet to
remove enough of fuels to be effective (spring/late fall burning), 2) the burning
would occur during conditions (summer/early fall) when control of the fire will be
difficult to control and the risk of adverse results happening are too great (high
probability for fire to become uncontrolled and transition to a wildfire).
By using burning in conjunction with vegetative treatments, we will be better able
to effectively treat the fuels located within the treatment areas to meet the
purpose and need of the project.
CaJCSOS
B. LEAVING A RANGE OF DOWNED WOODY MATERIAL ON THE GROUND
When planning to bum unnaturally high fuel loads (i.e. logging slash), it is
important to leave a range of downed woody material on the ground in
appropriate areas in order to preserve insect and wildlife species diversity.
(Preservation/Conservation Organization, Boise, ID-#15.130.33410.350)
RESPONSE:
Typically during our prescribed burning of logging slash, we use prescription
parameters that will result in down woody material left remaining for nutrients,
shade, habitat, etc. The maintenance of some down woody material is the
norm during prescribed burning and the total removal of all down woody
materials is the exception.
Prescribed burns are developed and implement with specific results in mind. To
meet these results, the prescription parameters are determined for the fuel and
weather components so that the needed results can be achieved. By having
set parameters, we can determine the resulting fire behavior and fire effects.
When given objectives such as retaining downed woody material for habitat,
and site protection we can determine the prescription parameters need to
successfully accomplish the objectives. To help us determine the parameters
we will use models such as RxWindows, FOFEM (First Order Fire Effects
Model), and Behave.
C. WITH MECHANICAL TREATMENTS
Where uncharacteristic or continuous fuel loads exist, mechanical treatments
may be necessary prior to prescribed burning. These treatments should not
focus on increasing canopy spacing by removing larger trees, but should remove
ladder fuels and brush build ups. Care should be given to areas directly adjacent
to the base of large diameter trees. Debris and fuels should be removed from
these areas to protect tree roots and cambia. The Forest Service needs to
provide details of how and when these adjacent areas are to be treated.
(Preservation/Conservation Organization, Boise, ID - #15.113.33420.273)
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RESPONSE:
Large diameter trees over 21 inches will not be harvested within this project.
Mechanical treatments of uncharacteristic fuel loads will include timber harvest to
remove and capture economic value and fund other treatments. The other
mechanical treatments prescribed for the treated area will vary by stand and
circumstance (slope, fuel load, soils, etc), but may include yarding of
unmerchantable material, machine or hand piling of excessive organic material,
pull-back of fuels from leave trees, jackpot burning of concentrations and piles,
underburning, or broadcast burning. All treatments will have site-specific
silvicultural prescriptions and burn plans will be developed and implemented for
any burning activities.
(S3 (US OS (33 (33 08
92. The Nez Perce National Forest should programmatically assess fire
management policies.
TO ASSURE THAT ECONOMIC INVESTMENTS IN FUEL REDUCTION ARE MOST EFFICIENT
Where past fire suppression is often identified as a culprit, it is necessary for the FS
to programmatically assess its fire management policies so that economic
investments in fuel reduction are most efficient. Throwing money at unnecessary
fire suppression activities followed by throwing money at fuel reduction because of
the adverse effects of fire suppression makes no sense ecologically or
economically. Last year's Slims Fire is a case in point where the damage from
fighting fires that should not have been fought was far greater than any damage
from the fire itself. Likewise, spending money on fuel reduction activities so that fire
suppression can allegedly be carried, resulting in the need to do fuel reduction...
seems like a cycle of management that only protects FSjob security.and damages
ecosystems. (Preservation/Conservation Organization, Moscow, ID -
#22.4.33000.835)
RESPONSE:
The current Forest Plan does not allow for WFU within the project area, thus, all new
fire starts require a suppression response, and fuels treatments undertaken to lessen
the effects of fires.
0# O* (S3 (19 O* 03
93. The Nez Perce National Forest should fully implement the Federal Wildland
Fire policy.
The development of approved fire management plans in compliance with the
Federal Wildland Fire Policy was the number one policy objective intended for
immediate implementation in the Implementation Action Plan Report for the Federal
Wildland Fire Management Policy and Program Review. In general, the FS lags far
behind other federal land management agencies that have already invested
considerable amounts of time, money, and resources to implement the Fire Policy.
Continued mismanagement of national forest lands and FS refusal to fully
implement the Fire Policy puts wildland firefighters at risk if and when they are
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American River/Crooked River - Final Environmental Impact Statement
dispatched to wildfires. This is a programmatic issue, one that the current Forest
Plan does not adequately consider. Please see Amend (1997) as comments on
this proposal, in terms of fire policy and Forest Planning.
(Preservation/Conservation Organization, Moscow, ID - #22.8.33200.163)
RESPONSE:
The zone Fire Management Program for the Clearwater and Nez Perce National
Forests does have an approved fire management plan in compliance with the
Federal Wildland Fire Policy. The plan is updated annually and was most recently
approved in June 2004, by both Forest Supervisors (Clearwater and Nez Perce).
(si OS (S3 OS OS OS
94. The Nez Perce National Forest should consider fire regime condition
classes.
Fire regimes - when proposed treatment areas are overlaid on the map of fire
regime condition classes, the areas of both moderate and significant departure from
historical range, do not match to the extent needed to accomplish project
objectives. This comparison once again focuses attention on factors (standards,
guides, and administrative policy) limiting vegetative management options.
(Timber/Wood Products Industry, Kamiah, ID - #5.12.33000.277)
RESPONSE:
Adherence to the full range of Forest Plan standards limits some vegetative
management options. For example, some of the fire regime condition class
departure areas are located in RHCA and landslide prone areas or would require
road construction through sensitive landscape areas that would necessitate
additional surveys and analysis or Forest Plan amendments in order to implement
some treatments. Additionally economic considerations also came into play in
determining treatment areas.
08 O# 0# OS 0* 08
95. The Nez Perce National Forest should consider fire regime models to
determine fire intervals.
The fact that areas may have missed some fire cycles may not be important at all
for a couple of reasons. First, is the predominance of lethal fire in the area like in
1910 which sefs the successional stages at levels far different than those the
agency claims are historic (see OHS maps). This is true for ponderosa pine types
as well in this area which tend to be a bit wetter than the more typical ponderosa
pine types further south (NOTE: The SFLA admits the ponderosa pine type was not
as common in the South Fork and that lodgepole more common than ICBEMP
would lead one to believe). Second, is the fact that these cycles are not hard and
fast. This second question we address briefly below.
Other models of fire regimes need to be considered. Some research suggests,
even in the most studied ponderosa pine fire types that tire return intervals are far
from certain and may be far different (if valid at all) than previously believed. Baker
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American River/Crooked River- Final Environmental Impact Statement
and Ehle (2001) note in the abstract of their recent peer-reviewed paper note:
"Present understanding of fire ecology in forests subject to surface fires is based on
fire-scar evidence. We present theory and empirical results that suggest that fire-
history data have uncertainties and biases when used to estimate the population
mean fire interval (F or other parameters of the tire regime. First, the population
mean Fl is difficult to estimate precisely because of unrecorded fires and can only
be shown to lie in a broad range. Second, the interval between tree origin and first
fire scar estimates a real fire-free interval that warrants inclusion in mean-FI
calculations. Finally, inadequate sampling and targeting of multiple-scarred trees
and high scar densities bias mean Hs toward shorter intervals.
In ponderosa pine (Pinus ponderosa Dougl. ex P. & C. Laws.) forests of the
western United States, these uncertainties and biases suggest that reported mean
FIs of 2-25 years significantly underestimate population mean FIs, which instead
may be between 22 and 308 years. We suggest that uncertainty be explicitly stated
in fire-history results by bracketing the range of possible population mean FIs.
Research and improved methods may narrow the range, but there is no statistical
or other method that can eliminate all uncertainty. Longer mean FIs in ponderosa
pine forests suggest that (i) surface fire is still important, but less so in maintaining
forest structure, and (ii) some dense patches of trees may have occurred in the pre
Euro-American landscape. Creation of low-density forest structure across all parts
of ponderosa pine landscapes, particularly in valuable parks and reserves, is not
supported by these results."
Given this research, the concept of HRV may not be valid. In fact, the agency
needs to take a look at all the assumptions behind the HRV and compare them with
the differences in the scientific literature. (Preservation/Conservation Organization,
Moscow, ID - #22.48.33110.277)
RESPONSE:
The focus of the paper by Baker and Ehle was on nearly pure ponderosa forest,
which makes up a small portion of the project area. They state in their paper that
mean fire intervals based on fire scar data may have uncertainties and biases and
actually lead to longer fire intervals than previously thought. They also state that
fires are also unrecorded upon some trees (i.e. no fire scar), "Trees are often charred
by a surface fire, but fires do not always leave scars in particular areas or even a
whole stand, so fires may be unrecorded in fire scars", "It is uncertain for example,
whether a tree without a scar did or did not burn in a fire that scarred nearby trees",
and "The abundance of unrecorded fires is largely unknown." This lack of an evident
fire scar may actually lead to inferring a longer fire interval than occurred, which is
contrary to their theory about fire intervals.
While Baker and Ehle suggest that there may be uncertainties in the use of fire scars
to determine fire intervals, they do not offer any suggestions to reduce or mitigate
these biases other than bracketing fire intervals, which is what we have done in
using fire regimes and an associated range of fire intervals (ex. 75 to 150 years for
infrequent fire regimes) for this project.
An important adjunct of fire scar studies is tree age plots at fixed intervals to
characterize stand-replacing fires. We have analyzed thousands of plots by habitat
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American River/Crooked River- Final Environmental Impact Statement
type group and vegetation response unit (VRU) to derive local characterizations of
presettlement fire regimes (data on file at Forest headquarters).
OS OS OS C# 08 V5
Wildland Urban Interface
96. The Nez Perce National Forest should focus on thinning from below in the
Wildland-Urban Interface.
TO REMOVE LADDER AND GROUND FUELS
In the Will, we believe that the Forest Service should place less emphasis on
reducing crown bulk density, and instead focus on thinning from below and
removing ladder and ground fuels. Habitat loss is increased in areas cut by
regeneration, seed tree or shelter wood logging, prescriptions that produce adverse
effects for species relying on more continuous canopies such as snowshoe hare,
lynx, pine marten, and fisher. (Preservation/Conservation Organization, Boise, ID -
#15.95.33470.330)
RESPONSE:
With respect to the WUI areas, any treatment done will result in the reduction of the
crown bulk density of the stand, including thinning from below and removing ladder
fuels, crown bulk density is defined as "the mass of available fuel per unit crown
volume." While these types of treatments (thinning from below and removing ladder
fuels) are effective as a measure to keep fires from transitioning from a surface fire to
a crown fire, they are not as effective in transitioning a crown fire back down to a
surface fire. That transition of a crown to a surface fire is one of the things that larger
blocks that have been harvested will accomplish. This will help to better protect the
private property and road infrastructure within the WUI. Additionally these treatment
areas will provide safer areas for firefighters to initiate suppression tactics within the
WUI areas.
With respect to wildlife habitat, managing various habitat types to maintain or
improve wildlife habitats is usually best done by duplicating the fire regime and
disturbance intervals that each habitat evolved with. Thinning from below to remove
ladder and ground fuels is generally consistent with fire's natural disturbance
patterns in low elevation sites dominated by ponderosa pine and dry Douglas fir
types. However, moderate and higher elevation mixed conifer and spruce-fir zones
experienced a variety of both low and high intensity fires that created a mix of
partially burned and completely regenerated sites. This created the patterns of age
classes and conditions necessary for species such as lynx, snowshoe hares, fisher
and marten. Exclusive use of "thinning from below" strategies would be
inappropriate for higher elevation habitats because of failure to create early serai
habitats critical to production of forage species such as snowshoe hares. Snowshoe
hares are important prey of both lynx and fishers.
Refer to Chapter 3, Section 3.11, for information regarding wildlife habitat and
cumulative effects analysis .
o# os e# oj o« os
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97. The Nez Perce National Forest should not treat areas beyond the Wildland-
Urban Interface.
A. 1. The scoping notice states that one of the purposes is to reduce potential
future fuel loading. The Forest Plan gives direction to protect resource
values through cost effective fire and fuels management (Forest Plan page
11-2). By treating areas beyond the wildland-urban interface (Will), the
Forest Service is being grossly inefficient and negligent in hazardous fuels
reduction efforts. The proposed activities will do nothing to safeguard the
community from wildfires and will only increase the hazardous fuel load and
create a false sense of security, contrary to Forest Plan direction.
(Preservation/Conservation Organization, Boise, ID -#15.10.33470.270)
RESPONSE:
Resource values, as stated in the Forest Plan include not only Wildland
Urban Interfaces, but timber, air quality, terrestrial and aquatic habitat,
recreation opportunities, transportation infrastructure, etc. The proposed
treatments would modify fire behavior by lowering fire intensities for fires
occurring in the treatment areas. This would give suppression resources the
opportunity to utilize the treatment areas during suppression activities, which
would allow for the control of a fire at a smaller size and/or less cost.
0*0308
2. It is suggested that "lethal fires could pose risk to structures and
investments" (P. VI). Clarification and demarcation should be provided that
identifies which structures and investments are specifically at risk from fire.
This is difficult to comprehend given that there are several concurrent
projects occurring and others proposed which focus on fuel reduction in the
Will. The Crooked River Demonstration and Orogrande defensible space
projects and BLM actions are focused on protecting structures. The Forest
needs to justify why fuel reduction is necessary this far away from structures
at risk. (Preservation/Conservation Organization, Boise, ID
#15.43.33470.270)
RESPONSE: Text has been modified in FEIS (refer to page 200)
B. WITH THINNING EFFORTS ON NORTH-FACING SLOPES
Thinning efforts on north-facing slopes should be concentrated within the WUI
so that natural mixed-lethal fires will not threaten structures. Many Lodgepole
Pine stands normally experience stand-replacing events and may not in fact be
outside historic fuel loads or be in danger of uncharacteristic wildfires.
(Preservation/Conservation Organization, Boise, ID -#15.99.33470.270)
On north-facing wetter forest slopes, a mixed severity or lethal fire regime was
more common, as is evident in the DEIS' descriptions. Thinning here should be
concentrated around the WUI. We recommend that no even age treatments be
implemented outside the WUI. Clear cuts, shelter wood and reserve tree
logging activities transfer fuels from the canopy to the ground and increase
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hazardous fuel loading, exacerbating the effects of wildfire. Also, clear cuts and
similar logging prescriptions increase the potential for severe blow-downs by
increasing wind speed and decreasing shelter to the outlying trees, again
increasing the amount of hazardous ground fuels. Clear cuts also encourage
rapid regeneration in Lodgepole pine forests. A dense layer of small saplings
and young trees could support a rapid-spreading low crown fire and increase
the risk of a large-scale wildfire. Any efforts to thin Lodgepole pine should
maintain a sufficient density of trees to serve as windbreaks for each other and
to prevent wind throw. (Preservation/Conservation Organization, Boise, ID -
#15.115.33470.270)
RESPONSE:
Refer to the first two stated objectives of this project (FEIS, Chapter 1, Section 1.3).
The vast majority of all acres proposed for treatment regardless of aspect are in the
mixed severity or lethal fire regime. Silvicultural prescriptions are based on relevance
to meeting the stated objectives within the purpose and need. How well a stand
meets criteria depends upon the vegetative condition of the stands as well as the
juxtaposition to the WUI, past treatment areas and determined fire protection areas.
Social and economic values in the WUI are not the only resources at risk from
wildfire in the project area.
OS OS OS OS OS OS
98. The Nez Perce National Forest should scale back the project since it is not
in the WUI.
Since this is project is not in the WUI, and other projects are currently addressing the
risk to structures and natural resources, the project should be significantly scaled back.
(Preservation/Conservation Organization, Boise, ID - #15.47.10400.002)
RESPONSE: Comment acknowledged. Portions of the project are within WUI.
OS OS OS OS OS OS
99. The Final EIS should discuss the fire behavior in each of the six different
Fuel Models that represent the project area.
The FEIS should also discuss fire behavior in each of the six different Fuel Models that
represent the project area. The DEIS states that Fuel Model 8 represents an elevated
risk only in severe weather conditions. In the next paragraph, at page 153, the
impression is given that Fuel Model 10 exhibits "high fire intensities" regardless of
weather. Is this accurate, or does Fuel Model 10 only exhibit high intensities during
severe weather conditions? Please elaborate in the FEIS. (Preservation/Conservation
Organization, Boise, ID-#15.101.21100.270)
RESPONSE:
The descriptions of the fuel models were taken from Aids to Determining Fuel
Models for Estimating Fire Behavior by Hal Anderson (1982). The descriptions given
are for the typical fire behavior for that fuel model under normal fire conditions during
the fire season. Comparing Fuel Model 8, Fuel Model 10, and Fuel Model 13 fire
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American River/Crooked River- Final Environmental Impact Statement
intensities and spread rates with a dead fuel moisture of 8%, live fuel moisture of
100%, and mid-flame wind speed of 5mph the results are as follows:
Fuel Model
8
10
13
Rate of Spread (chains/hr)
1.6
7.9
13.5
Flame Length (feet)
1.0
4.8
10.5
Fires with a flame length of 4 feet or greater are generally considered to be to in
tense to control by hand and requires equipment such as dozers or air support to
control.
as a>s us as as cs
100. The Final EIS should recognize that thinning and regeneration harvests
may actually increase the short-term risk of high-severity wildfire.
Thinning and regeneration harvests, alone, often result in greater amounts of hazardous
fuels (slash) on the ground than prior to treatment, which may actually increase the
short-term risk of high-severity wildfire. The FEIS must recognize this factor, even
where slash disposal is proposed, timing of slash disposal is contingent on numerous
factors which may not be met in a timely fashion. Moreover, this risk appears to be
considerable given that at page 17 it states, "Slash from salvage would be lopped and
scattered, hand piled and burned in the woods, or removed from the site at the discretion
of the District ranger considering the Forest objective of maintaining less than 12 tons
per acre of fine fuels." This section is particularly vague and could allow accumulation of
slash in areas. This would clearly be counter to the objectives of the project.
(Preservation/Conservation Organization, Boise, ID-#15.111.21100.270)
RESPONSE:
As stated in the hazard discussion of the Fire/Fuels section of the FEIS, it is
acknowledged that the short-term risk of a high severity wildfire is possible
between the time the vegetative treatment occurs and the slash disposal is
completed. The long-term benefits of the treatments (modified fire behavior and
lower future fuel loadings) outweigh this short-term risk. Additionally, after slash
disposal is completed, the fuel loadings within the treatment units will be less than
12 tons per acre. If the treatments are not completed and stands continue to
transition to Fuel Models 10 and 13, we would see fuel loadings in excess of 12
tons per acre.
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101. The Final EIS should describe in detail the fuels treatment areas, Including
the process and criteria used in the selection of the areas and
determination of size and width.
EPA agrees with the need to include fuels treatment into the management of forests to
prevent wildfire. We recommend that the final EIS describe in more detail the fuels
treatment areas, Including the process and criteria used in the selection of the areas and
determination of size and width. (Federal Agency Official, Seattle, WA -
#24.23.21100.273)
According to the DEIS (at page 151), only 1249 acres in the project area represent a
frequent, non-lethal fire regime. This also represents only a small portion of the
proposed logging area. Why then, does the DEIS give the impression that the project is
designed to mitigate for departures from the historic fire regime. For instance, at page
157, the DEIS states: "Under Alternatives B, C, D, and E? This would start to bring
these stands back into their historic fire regime."
The FEIS should clearly delineate the number of acres in each Fire Regime (as
displayed in DEIS at page 151), in order to provide a clearer picture for the actual
percent of treatment in these frequent fire return interval systems. Otherwise, the project
and its DEIS gives false impressions of the result, purpose and need of and for the
project. (Preservation/Conservation Organization, Boise, ID-#15.100.21100.277)
RESPONSE:
The project was not specifically designed to mitigate for the departure from historic
fire regime. Alternatives B, C, D, and D (modified) would serve to return stands
historically associated with very frequent and frequent fire regimes to more natural
conditions through the use of mechanical or prescribed fire as surrogates for
natural fire when those stands are treated.
as os ea as ix as
102. The Final EIS should include the fire histories and historical forest
compositions of the Crooked River and American River watersheds.
It is important to recognize that not all Lodgepole pine stands were characterized by
stand replacement fire regimes. Fire history should be analyzed in the Crooked River
and American River watersheds and utilized to determine appropriate treatments. This
information should be clearly conveyed in the FEIS. (Preservation/Conservation
Organization, Boise, ID-#15.103.21100.277)
Thinning forests is a generally accepted component of decreasing the risk of a severe
fire event on south-facing slopes with dry forest types that were historically characterized
by low density stands ofponderosa pine with large openings between trees. In order to
justify this sort of thinning activity, the FEIS should contain substantive information
concerning the historical nature of these forests. This will help to establish a stand
density target that is within the historical range of natural variability. According to the
DEIS, though, only a small portion (approx. 3.2 percent) of the project area represents
this forest type. (Preservation/Conservation Organization, Boise, ID
#15.114.21100.277)
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
We recognize that not all lodgepole pine stands are characterized by stand
replacement fire regimes, but lodgepole stands located within the project area can
generally all be characterized by mixed and lethal fire regimes. This can be
concluded because the lodgepole stands within the project area are predominately
single storied and even aged stands that would follow a high severity stand
replacing fire event. Furthermore, fire scars are seldom observed.
OS (33 C# C# 08 (S3
103. The Nez Perce National Forest should not harvest timber.
BECAUSE TIMBER HARVESTING AFFECTS WATER QUALITY
In regards to the issue of fire, maps produced by the USFS, BLM, and State of
Idaho show that, after quality fire-prevention projects such as the positive "Dixie
Fuel Breaks" and "Red River Defensible Space", fire risk now to Elk City is low to
moderate. Logging in the American and Crooked River drainages will not change
this, but it will continue to degrade an already-degraded watershed (S. Fork
Clearwater River). (Individual, Moscow, ID-#9.4.34000.270)
RESPONSE:
The purpose and need for this project is broader than fire risk to Elk City. For a review
see Section 1-3 of the FEIS. There are also many restoration activities planned with an
associated "upward trend" to the watershed conditions (Section 3.2. - Watershed).
Fuels projects such as Dixie Fuel Break and Red River Defensible Space were
designed to be site-specific fuels projects. As such they will help to lower the fire risk
in the immediate area, in this case Dixie town and the houses near Red River, and
they are really the last line of defense when trying to protect these structures and
improvements.
With that in mind, those projects in and of themselves would not lower the fire risk to
the town of Elk City or the rest of the project area, nor would they increase fire
suppression efficiency or effectiveness, except in very localized areas.
os ess o» o« o« e*
SECTION 6 - AIR QUALITY
104. THE FINAL EIS SHOULD REFER TO EPA's INTERIM POLICY ON AIR QUALITY
FOR PRESCRIBED FIRES.
TO DEMONSTRATE CONSISTENCY WITH NATIONAL POLICY
EPA encourages federal land managers to refer to the interim Air Quality Policy on
Wildland and Prescribed Fires in their NEPA documents. The interim Policy best
reflects national policy as to how Federal agencies, States, and Tribes will address
the competing needs of clean air and fire in the ecosystem. The Interim Policy was
prepared with the involvement of the Federal land management agencies including
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American River/Crooked River- Final Environmental Impact Statement
that of the Department of Agriculture. By describing this national policy, the Forest
Service further demonstrates how its actions are consistent with national policy. EPA
supports the use of smoke management as a tool for maintaining clean air while
allowing for prescribed fires. Enclosed is a copy of the Interim Policy. (Federal
Agency Official, Seattle, WA - #24.26.10400.250)
RESPONSE:
The Regional smoke guide Describing Air Resource Impacts From Prescribed
Fire Projects in NEPA Documents for Montana and Idaho in Region 1 and
Region 4 (Acheson, et al, 2000) was used as the guide for completing the air
quality description. This guide uses the Interim Policy as guidance. Additionally
the Montana/Idaho Smoke Management Group ensure burners are meeting the
EPA's Interim Policy requirements by coordinating and approving proposed
burns within the airsheds in accordance with their operating guide to minimize
cumulative air quality impacts.
Ctf C8 C* 08 03 V&
SECTION 7 - RECREATION
105. THE NEZ PERCE NATIONAL FOREST SHOULD MANAGE LANDS FOR RECREATION.
/ believe the best use Idaho could have from these national lands lies in the direction of
recreation, not logging. These lands are too hilly for profitable replanting for harvesting
trees. (Individual, Moscow, ID-#21.1.50000.820)
RESPONSE:
Comment acknowledged. The USDA Forest Service is a multiple use agency and is
charged with providing much more than recreation for the public it serves.
O8 C#OS Otf OS C!»
106. The Nez Perce National Forest should describe how they will monitor and
control Off Highway Vehicle use.
The Forest Service needs to describe how they will effectively monitor and control the
use of OHVs on Forest Service and non-system roads, obliterated roads, and trails in
the project area. The analysis should include funding and numbers of personnel
available for these duties. (Preservation/Conservation Organization, Boise, ID -
#15.55.53100.165)
We suggest discussing efforts to discourage off road transportation and to keep ATV
usage concentrated in areas that are more resistant to damage from these vehicles.
(Federal Agency, Elected Official, Seattle, WA-#24.21.53100.234)
Even for the system roads that are proposed for closure, abandonment, or obliteration,
we have yet to see effective closures and enforcement that prevent use by OHVs.
(Preservation/Conservation Organization, Boise, ID-#15.54.30200.410)
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Monitoring will only be conducted during the implementation process and will be funded
as a part of the project implementation.
Thank you for your suggestion. It is hoped that your ideas will be addressed during the
Forest Plan revision process.
Physical closures will need to fit into the terrain to be effective (difficult to pass or get
around).
CS (33 (S3 C# C5J Otf
107. The Final EIS should include more information about effects of all terrain
vehicles (ATVs) in the analysis of roads impacts.
We also recommend that the analysis of roads contain more information on the areas
used by all terrain vehicles (ATVs) and the sediment generated by their use as well as
any other negative impacts associated with off road travel. (Federal Agency, Elected
Official, Seattle, WA - #24.20.13100.500)
RESPONSE:
No complete inventory of all terrain vehicle trails, whether system trails or user-created
trails, was done for this project. Sediment from trails was not explicitly measured or
modeled using NEZSED, but trails on erodible materials were documented in FEIS
Chapter 3, Section 3.1. - Soils, Surface and Substratum Erosion. Specific sites were
identified for restoration. See Appendix D Middle Crooked River.
(IS (S3 (S3 (Si OS OS
SECTION 8 - TRANSPORTATION
ROADS GENERAL
108. THE NEZ PERCE NATIONAL FOREST SHOULD NOT APPROVE NEW ROAD
CONSTRUCTION.
A. We continue to adamantly oppose any new road construction in the project area,
even temporary construction. The proposal for 15 miles of temporary roads, 3 new
stream crossings and 24 miles of reconstruction is absurd given the current
conditions of the watershed from previous roading and management activities and
we are adamantly opposed to this action. (Preservation/Conservation Organization,
Boise, ID - #15.62.41100.247)
RESPONSE:
Please refer to the response to comment 110 for a discussion of the need for
temporary roads and then subsequent decommissioning of these roads.
There are no identified live water stream crossings associated with any of the
proposed temporary roads. Please refer to the Soils, Water Quality, and Fish Habitat
section of the table entitled Project Design and Mitigation Measures for the American
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American River/Crooked River- Final Environmental Impact Statement
and Crooked River Project in Chapter 2 of the FEIS for additional information
regarding live water stream crossings and road decommissioning.
030503
B. ON SOILS HIGHLY SUSCEPTIBLE TO EROSION OR COMPACTION WHEN THE WATERSHEDS
ARE ALREADY IMPACTED BY SEDIMENTATION FROM EROSION
No new road construction should occur on soils highly susceptible to erosion or
compaction. It is particularly troubling that the Proposed Action includes an
estimated 7 acres of temporary road construction (American River) on soil substrata
highly susceptible to erosion. It is absurd and unacceptable that the Forest Service
would propose adding to the acres of current roads in areas at high risk of erosion
when the watersheds are already being heavily impacted and degraded by
sedimentation from this erosion. (Preservation/Conservation Organization, Boise, ID
-#15.61.41100.231)
RESPONSE:
About 7.25 miles of temporary road are proposed (Alternative C) on soil
substrata rated high for erosion hazard, and about 6.75 miles on soils of
moderate erosion hazard. Please see the FEIS, Chapter 3, Section 3.1. - Soils,
Substratum Erosion for this analysis. Compaction hazard is not analyzed in
evaluating road effects, since road prisms are purposely compacted to provide a
firm surface, and then sub-soiled and recontoured during decommissioning to
restore permeability and subsurface hydrologic function. However, displacement
and loss through mixing of the surface soil, usually the more permeable and
productive volcanic ash layer, is a result of all road construction unless topsoil is
stockpiled and replaced. This is also discussed in the FEIS, Chapter 3, Section
3.1 - Soils, Soil Compaction and Displacement.
03 OS 03
C. BECAUSE OF THE IMPACTS ON LISTED FISH SPECIES IN THE PROJECT AREA
As stated in our scoping comments on this project, and on other similar projects in
the area, we believe that new road construction, even temporary, is simply not a
viable option given the Forest Service's own scientific evidence showing the road
system's effect on listed fish species in this watershed. (Preservation/Conservation
Organization, Boise, ID-#15.3.41100.380)
RESPONSE:
The FEIS Chapter 3, Sections 3.2 (Watershed) and 3.3 (Fisheries) discuss the
modeled impacts these road-building activities will have on fish/water quality.
The FEIS Appendix E lists the limitations of both the NEZSED and FISHSED
models. Our analysis shows that when combining these actions with the planned
restoration, the result is an improvement in fish habitat and water quality.
OJ O3 O3 OS OS O3
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109. The Nez Perce National Forest should not approve any construction of
temporary roads.
A. BECAUSE OF THE FOREST SERVICE'S POOR ENFORCEMENT OF ROAD CLOSURES WITHIN
ALL DRAINAGES NOT MEETING BENEFICIAL USES
Given the extremely poor success rate the Forest Service has regarding enforcing
road closures, it is likely that continued user-created resource damage will continue
to occur into the foreseeable future. The most practical way to realize an upward
trend in fish habitat is to reject any temporary roads and to preclude this type of
treatment, especially within all drainages not meeting beneficial uses.
(Preservation/Conservation Organization, Boise, ID-#15.69.41400.165)
RESPONSE:
Please refer to the response to comment no. 107 for a discussion of the need for
temporary roads. Refer also to the comment no. 112 response for a discussion of
the road decommissioning process. The important points to take from these
discussions are: (1) temporary road construction is necessary to satisfy the project
Purpose and Need, and to contribute to the economic viability of the project; (2) all
temporary roads will be decommissioned within three years following their
construction; and (3) every effort is made to limit unauthorized incursions on
decommissioned roads.
OSC80S
B. BECAUSE OF THEIR SEDIMENTATION EFFECTS DURING AND IMMEDIATELY AFTER
THEIR CONSTRUCTION AND OBLITERATION
1. Even with "Temporary Roads", the most significant addition of sediment to
streams is during years 1 and 2, and in response to obliteration. While the
Idaho Conservation League supports, in premise, the concept of "Temporary
Roads," they are not appropriate in these already heavily roaded and
degraded ecosystems. For reference, see Potyondy, J.P., G.F. Cole, and
W.F. Megahan. 1991. A procedure for estimating sediment yields from
forested watersheds. Pages 12-46 to 12-54
RESPONSE:
Please refer to the response to comment #110 for a discussion of the need for
temporary roads and the decommissioning of these roads.
o«c*o*
2. In Proceedings: Fifth Federal Interagency Sedimentation Conference. Federal
Energy Regulatory Commission, Washington, D.C. In fact, according to this
research, over a seven-year period, 77% of soil loss occurs within the first two
years of road construction. Therefore, the impacts from road construction, even
temporary ones, are significant and have very real potential to significantly
impact fisheries habitat. (Preservation/Conservation Organization, Boise, ID -
#15.25.41400.201)
RESPONSE:
The figure of 77 percent of soil loss from roads within the first two years is the
same as the basic erosion rate for roads used in the R1R4 Guide (Cline, et al).
This basic erosion rate for roads was incorporated into the NEZSED model,
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American River/Crooked River- Final Environmental Impact Statement
which was used in the sediment yield analysis for the American and Crooked
River project. The effects of road construction, reconstruction and
decommissioning on sediment yield are disclosed in Chapter 3 of the FEIS.
os os os os os os
110. The Nez Perce National Forest should base this project off of existing
roads and close additional roads.
If there /s to be any type of project, it needs to be based off of existing road systems,
and close additional roads. (Preservation/Conservation Organization, Boise, ID -
#15.7.23000.410)
RESPONSE:
The areas available for prescribed treatment activities that are accessible from
existing roads are insufficient in size and location to satisfy the project's Purpose and
Need and to contribute to the economic viability of the project. The fuels reduction
portion of the project is focused primarily on removing dead, down and dying
lodgepole pine, which must be removed in quantities and at locations sufficient to
create the fuel breaks necessary to achieve the project objectives (FEIS, Chapter 1).
A portion of the timber revenue generated will be used for the proposed watershed
restoration activities. All temporary roads constructed as part of this project would be
decommissioned within three years of their construction (refer to FEIS, Chapter 2).
OSO3OSO3OSO3
111. The Nez Perce National Forest should decommission roads.
A. LOCATED IN RIPARIAN HABITAT CONSERVATION AREAS OR ON HIGHLY ERODIBLE SLOPES
While we understand that access needs to be provided for recreation and forest
maintenance purposes, EPA encourages the USFS to continue to balance the needs
of the public with the need to reduce sediment loading to streams. It appears from
the DEIS that a high percentage of roads that would be decommissioned are the new
roads being constructed for this project. We recommend finding ways to continue to
decommission other roads, especially those that are located in riparian habitat
conservation areas and on highly erodable slopes. (Federal Agency Official, Seattle,
WA-#24.19.41300.002)
RESPONSE:
A roads analysis (conducted as part of this project) identified roads deemed not
essential to management of the proposed project area and were considered as
candidates for decommissioning (refer to Appendix F). Although additional roads
will probably not be recommended for decommissioning for this particular project,
we will continue to reevaluate the need for our roads and decommission more
roads as conditions allow.
As stated in Chapter 2, the miles of roads proposed for decommissioning are not
associated with the miles of temporary road construction proposed in this project.
All temporary roads will be decommissioned following their use, but the roads
proposed for decommissioning as part of the watershed restoration activities are
existing forest system roads.
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O3 (S3 (S3 (33 OS OS
B. WHICH CONTRIBUTE SIGNIFICANTLY TO SEDIMENTATION OR IN AREAS WITH A HIGH RISK
OF LANDSLIDES
Decommissioning roads should be the top priority for the Forest and especially for
the Red River Ranger District. It is unacceptable that road construction is proposed
in an area that is already heavily roaded, and where water quality has been
significantly degraded because of excessive road densities. The DEIS notes this
glaring problem on page IV, "Stream channels have been mostly' affected by
sediment deposition and road encroachment." It is also notable that the DEIS
acknowledges that, "Surveyed streams in the analysis area are below their Forest
Plan objectives (existing and proposed) included in Appendix A [of the Forest Plan]"
(P. V). (Preservation/Conservation Organization, Boise, ID-#15.23.41300.240)
Roads contributing significantly to sedimentation should be decommissioned. 251
acres in the American River watershed and 413 acres in the Crooked River
watershed contain old roads that are on soil rated high for erosion. There are also 1
and 34 acres respectively in areas that are rated as a high risk of landslide. As many
of these roads as possible should be decommissioned. (Preservation/Conservation
Organization, Boise, ID-#15.58.41300.230)
RESPONSE:
Landslide risk and erosion hazard are two factors considered when evaluating roads
for decommissioning. Administrative jurisdiction and public demand for that road are
other factors (e.g., the main Crooked River road is maintained by Idaho County; we
can work cooperatively with the County to reduce erosion, but we could not
decommission it).
Under alternative D, a total of 79 acres of required road decommissioning would
occur (see Appendix D) and another 72 acres if discretionary decommissioning is
implemented. About 38 acres of the required decommissioning would treat soil
substrata with high erosion hazard. The discretionary road decommissioning would
treat an additional 20 acres with high erosion hazard. Please see Section 3.1.1.1
and Section 3.1.2.1 on soil physical effects.
O303O3O30303
C. PRIOR TO THINNING AND BURNING TREATMENTS
The project should decommission and obliterate all high-risk and redundant roads as
determined by a complete Roads Analysis. Road decommissioning must be done
prior to treatments to ensure that decommissioning is achieved and not
overshadowed by the thinning and burning treatments, or that funding for
decommissioning is not diverted for fire suppression activities.
(Preservation/Conservation Organization, Boise, ID-#15.70.41300.270)
RESPONSE:
A roads analysis consistent with the requirements of section 7712.13c of Forest
Service Manual 7700 (FSM 7700) - Transportation System was conducted as
part of this project. All roads within the project area that were deemed not
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American River/Crooked River - Final Environmental Impact Statement
essential for future management of the affected areas, and the decommissioning
of which would presumably benefit watershed health were proposed for
decommissioning. Please refer to the Nez Perce NF response to a comment
received from the Nez Perce Tribal Executive Committee (dated November 19,
2004, which immediately follows the response to public comments section) for a
discussion of the implementation phase of this project.
dS CS OS (S3 C9 (ffS
112. The Nez Perce National Forest should expand and guarantee the
decommissioning of roads in the project area.
We appreciate the efforts to decommission 30 miles of roads, but these efforts need to
be expanded significantly and guaranteed throughout the watershed.
(Preservation/Conservation Organization, Boise, ID-#15.6.41300.247)
RESPONSE:
Refer to response to comment 34(G) for the full text of this response. Most restoration
work associated with this project will be accomplished using various contracting
mechanisms. Some of the work, streamside planting for example, may be accomplished
through participating, volunteer, and challenge cost-share agreements.
The various types of contracting authorities being considered to implement the project
include stewardship, service, and timber sale contracts, each of which offers a different
opportunity to apply funds or contract specifications toward completing restoration
activities.
At this time, a guarantee of funding or results is not possible. However, we can say with
a high degree of confidence that restoration funds will be made available from a variety
of sources over the life of the project, as planned.
In the event of significantly changed conditions due to natural events related to large
floods, wind or fire affecting the project area, the project would be reevaluated.
Funding Sources:
• Appropriated funds have been requested for fiscal year 2005 and beyond, to
accomplish restoration work in the upper South Fork Clearwater River, including
the American and Crooked River project area.
• The North Central Resource Advisory Committee (RAC) is on record supporting
this project and has the capability to fund a significant portion of the restoration
once the project is approved.
• Many road improvements and a portion of the existing road decommissioning
would be accomplished through timber sale contract provisions where such roads
would be used for hauling and removing forest products.
• Where forest product revenues are projected to exceed operational logging and
site treatment costs, stewardship contracting authorities would be used to allow
the Forest Service to direct those revenues toward restoration activities.
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American River/Crooked River - Final Environmental Impact Statement
• A substantial portion of the restoration work fits well under partnership and grant
opportunities:
o A recent addition to the potential sources of funding for restoration activities is
the Pacific Salmon Recover Fund (PSRF). At least one grant proposal from a
local non-profit organization has already been submitted, through the PSRF
process, to do restoration work in the project area.
o Restoration work associated with this project, once approved, will be
incorporated into the South Fork Clearwater River TMDL implementation
plan, which is under development by the SFCR Watershed Advisory Group.
o Many of the proposed restoration projects would be competitive for BPA
funds and work could be accomplished in partnership with the Nez Perce
Tribe.
(33 as (33 as as (s3
113. The Nez Perce National Forest should close all inappropriate trails.
TO MINIMIZE SEDIMENTATION IN THE WATERSHEDS
Inappropriate trails need to be closed. The DEIS nofes that, "Motorized and non-
motorized trails account for 65 acres of soil disturbance, susceptible to surface and
subsurface erosion. Thirty-five acres are on soil substrata rated high for erosion
hazard." These trails should be closed to motorized use to minimize erosion. This is
necessary given that sedimentation is a huge problem in the watersheds.
(Preservation/Conservation Organization, Boise, ID - #15.52.42300.231)
RESPONSE: Comment acknowledged.
08 C« 0* 03 08 0*
114. The Nez Perce National Forest should close all non-essential roads.
BECAUSE THAT is THE BEST WAY TO RESTORE DAMAGED WATERSHEDS FOR ECONOMIC AND
ENVIRONMENTAL BENEFITS
Road closure is a contentious issue, especially in Idaho County, but is simply the best
way to restore watersheds suffering from legacy problems. Permanently'closing all non-
essential roads will save money, protect water quality, protect wildlife, and safeguard
endangered species and their habitat. (Preservation/Conservation Organization, Boise,
ID-#15.77.41300.002)
RESPONSE: Please refer to the response to comment 111 c.
(13 (S3 OS (X (X (33
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Roads Analysis and Management Considerations
115. The Nez Perce National Forest should actively enforce the closure of roads.
TO PREVENT INCURSIONS BY ORVS
The obliterated road should be gated, signed, and patrolled to prevent incursions by
ORVs. (Preservation/Conservation Organization, Boise, ID-#15.73.43000.501)
RESPONSE:
Roads that are obliterated are generally not gated or signed. The concept behind
this approach is that we do not want to call attention to the fact that a road had
previously existed. Please refer to Environmental Effects in Section 3.8 of the FEIS
for a discussion of unauthorized incursions on decommissioned roads..
Where we might reasonably expect to experience problems with unauthorized
incursions on a decommissioned road we would camouflage the entrances, either by
recontouring the roadway at the entrances or by placing natural barriers, such as
logs and branches. Patrolling of the entrances to decommissioned roads by law
enforcement to prevent unauthorized incursions would be conducted as resources
allow.
(33 OS (S3 (33 (33 (33
116. The Nez Perce National Forest should detail the maintenance plan for all
roads in the project area.
Proper road maintenance is critical for any remaining roads if sediment is to be
controlled. The Forest Service should detail the maintenance plan for all roads in the
project area. (Preservation/Conservation Organization, Boise, ID - #15.76.41200.234)
RESPONSE:
Each forest system road is, and would continue to be, maintained in a manner
consistent with the road management objectives established for the road, if sufficient
funding is available to do so. Please refer to Appendix F of the FEIS for a list of road
management objectives for each road in the project area.
(IS (33 CS (33 (33 (33
117. The Nez Perce National Forest should secure funding for road
decommissioning.
TO GUARANTEE DECOMMISSIONING OF ROADS. REGARDLESS OF TIMBER REVENUES
It is essential that road-decommissioning proposals be guaranteed as part of this, or any
project. We recommend that funds be secured to pay for the decommissioning,
regardless of the revenue generated by the sale of timber. The NPNF should investigate
the potential to acquire appropriated funds for the purpose of road decommissioning. If
timber sales are delayed or fail to attract bidders, roads should still be decommissioned
as part of this project, and should not be contingent upon the sale of timber. Utilizing
congressionally appropriated, cost-share, mitigation and/or restoration funds for road
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American River/Crooked River- Final Environmental Impact Statement
decommissioning should be prioritized for the American and Crooked River Watershed.
(Preservation/Conservation Organization, Boise, ID-#15.67.14100.410)
Any road decommissioning or other watershed improvement activities must be
guaranteed and completed regardless of the successful sale of timber, or the revenue
generated by such sales.
(Preservation/Conservation Organization, Boise, ID-#15.133.10400.100)
RESPONSE:
Refer to response to comment 34(G) and 112. Briefly, most restoration work associated
with this project will be accomplished using various contracting mechanisms. Some of
the work, streamside planting for example, may be accomplished through participating,
volunteer, and challenge cost-share agreements.
The various types of contracting authorities being considered to implement the project
include stewardship, service, and timber sale contracts, each of which offers a different
opportunity to apply funds or contract specifications toward completing restoration
activities.
At this time, a guarantee of funding or results is not possible. However, we can say with
a high degree of confidence that restoration funds will be made available from a variety
of sources over the life of the project, as planned.
In the event of significantly changed conditions due to natural events related to large
floods, wind or fire affecting the project area, the project would be reevaluated.
08 05 0« OS CJ 0*
118. The Nez Perce National Forest should remove all culverts from obliterated
roads.
A. FOR ENVIRONMENTAL REASONS
Culverts of obliterated roads should be removed and restored to reduce the effects
these have on sedimentation, water quality, and soil productivity.
~ (Preservation/Conservation Organization, Boise, ID - #15.71.43000.220)
RESPONSE:
Removal of drainage structures, including culverts, is, in general, an element of
the decommissioning process, regardless of the method of decommissioning.
The only exception in this project is the road-to-trail conversion of road 9833.
The roadway will remain intact for use by snowmobiles and snow grooming
machines during the winter. Please refer to section 3.8. of the FEIS for further
discussion of the various methods of decommissioning.
OaCSCS
B. TO AVOID BLOCKED DRAINAGES AND POTENTIAL BLOWOUTS
All culverts should be removed from obliterated roads. Culverts that are not
maintained may lead to blocked drainages and eventual blowouts.
(Preservation/Conservation Organization, Boise, ID-#15.75.43000.247)
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RESPONSE: Please refer to response to 119(A).
os (3303(3303(33
119. The Final EIS should provide additional information concerning
transportation management for the proposed project and the effects of
transportation management decisions.
A. INCLUDING THE RISK OF EROSION FOR ROADS BEING PROPOSED FOR DECOMMISSIONING
The E/S should provide information regarding what the risk of erosion is for those
roads that are being proposed for decommissioning under the project.
(Preservation/Conservation Organization, Boise, ID-#15.59.21100.231)
RESPONSE:
This information is now included in the FEIS, Section 3.1. - Soils, Surface and
Substratum Erosion
The erosion risk of roads proposed for decommissioning was identified with land
type surveys and field surveys and is documented on the field survey sheets as
part of the project record. Brief summaries of these field surveys are found in
Appendix D of the FEIS under the description/comments column in each of the
road decommissioning tables. Their importance as a contribution to watershed
restoration is also reflected in the two priority columns. Erosion risk of these
roads is also reflected in the sediment modeling coefficients that are associated
with each road segment. These are also part of the project record.
0303(33
B. INCLUDING THE SPECIFIC TERMS OF THE VEHICLES ALLOWED TO OPERATE
The FEIS should be specific in terms of the vehicles allowed to operate in order to
reduce the potential impacts to soils and vegetation. All logs need to be removed by
carrying the entire tree without dragging it and disturbing the soils. No logging within
RHCAs (Riparian Habitat Conservation Area) should be permitted.
(Preservation/Conservation Organization, Boise, ID-it15.119.21100.231)
RESPONSE: No logging is planned in streamside RHCAs - see FEIS Section 3.3
(13(13(33
C. INCLUDING WHEN ROADS PROPOSED FOR DECOMMISSIONING WILL BE OBLITERATED AND
REPLANTED WITH TREES
/ might have missed it, but somewhere there should be a date (or at least an
expected date) when these roads will be obliterated and replanted (one would hope)
with trees. (Individual, Moscow, ID - #6.5.21100.360)
RESPONSE:
Please refer to Table 2.3, item 11 of the FEIS for information regarding the
decommissioning of temporary roads. The temporary roads are generally
decompacted, recontoured, covered with slash, and seeded as needed. Tree
planting is generally not included in the revegetation process of obliterated roads.
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However, roadway openings in forested areas are relatively small, and tree
growth will generally occur over time. Planting with trees and/or shrubs is
prescribed when it is deemed desirable and natural regrowth is not expected in a
timely manner.
080303
D. INCLUDING WHAT EACH CLOSURE METHOD WILL BE FOR EACH ROAD PROPOSED FOR
DECOMMISSIONING
The DEIS discusses various possible scenarios for decommissioning, including
abandonment, gating, and obliteration. It should be made clear what each closure
method will be for each road, as simply abandoning a road that is regularly used as
an ATV route will continue to result in long-term impacts. Further, the DEIS makes
clear (at page 87) that temporary roads are difficult to restore to their former
productivity. Therefore, excessive construction of temporary roads will have lasting
impacts and will jeopardize resource values for years to come. This should be
considered in the FEIS and the Record of Decision. (Preservation/Conservation
Organization, Boise, ID-#15.60.21100.410)
RESPONSE:
Please refer to the tables in Appendix D of the FEIS for the specific methods of
decommissioning recommended for each road. Refer also to the response to
comment 115, above, for a discussion of unauthorized incursions on
decommissioned roads.
We acknowledge that, at present, the soil productivity at locations where roads
were constructed and subsequently obliterated is difficult to reestablish. The
alternative to building temporary roads is to limit the prescribed treatment
activities to areas that can be accessed solely from existing roads. Please refer
to the response to comment 110, above, for a more detailed discussion regarding
the reasons for proposing the use of temporary roads.
eao#o«
E. INCLUDING THE CURRENT AND PROPOSED ROAD DENSITIES DURING PROJECT
IMPLEMENTATION FOR ALL THE ALTERNATIVES
The United States Fish and Wildlife Service Bull Trout Interim Conservation
Guidance states that depressed bull trout populations had an average watershed
road density of 1.4 miles per square mile and were extirpated with road densities
above 1.7 miles per square miles (page 27, BTICG). The DEIS failed to exhibit the
road density by project alternative. The FEIS must show the current and proposed
road densities during project implementation for all the alternatives, Including within
150-ft RHCAs on perennial, non-fish bearing streams and 100-ft. RHCAs on
intermittent streams. (Preservation/Conservation Organization, Boise, ID -
#15.64.21100.410)
RESPONSE:
Subwatershed road densities and over base sediment yields are disclosed by
alternative in the FEIS in Tables 3.35, 3.36, and 3.44. Existing riparian road
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densities are shown in Tables 3.31 and 3.39. These figures are not expected to
change much by alternative since all temporary roads are being decommissioned
and few of the existing roads planned for decommissioning are located in riparian
areas.
The Interim Conservation Guidance states that the document is not intended to
provide site-specific land management prescriptions, but is intended to provide
recommendations that may be adapted to land management activities (USFWS,
December 1998). This same report recognizes that reducing road miles,
improving fish passage, decreasing water temperatures, and improving substrate
and habitat complexity are all important in recovering bull trout populations. This
FEIS contains actions designed to meet these needs (FEIS, Chapter 3, Section
3.3).
C3C303
F. INCLUDING A TABLE SHOWING ROAD DENSITY AMONG ALTERNATIVES FOR THE AMERICAN
RIVER
The draft EIS explains very well the deleterious impact that roads have on water
quality and aquatic habitats. Road densities are high in riparian habitat conservation
areas in the Crooked River basin and the DEIS points out that it has more existing
roads and past timber harvest on landslide prone terrain than the American River.
Table 3. 14 indicates a slight change in road density in the Crooked River basin
between the action alternatives and no action alternative. We recommend a similar
table showing the change in road density among alternatives for the American River.
(Federal Agency Official, Seattle, WA- #24. 18.211 00.410)
RESPONSE: This information is located in the FEIS (and DEIS) in Table 3.31.
G. INCLUDING CLARIFICATION OF THE NUMBER OF MILES OF ROAD IMPROVEMENT AND
WHERE THESE TREATMENTS WOULD OCCUR
Table 0.1 indicates that the project includes 95 miles of road improvement for
Alternative D; however, the same table under Watershed Restoration Package
Improvements lists 15.8 miles of watershed road improvements. It appears from the
tables contained in Section D that improvements would be made on roads outside
the project area but within the South Fork Clearwater River watershed. We
recommend that the final EIS clarify the number of miles of road improvement, and
that the body of the report discuss where these treatments would occur. (Federal
Agency Official, Seattle, WA - #24.4.21 100.410)
RESPONSE:
The miles of road improvement listed in Table 0.1 of the DEIS are not correct; it
should read 90.5 instead of 95. The corresponding footnote (2) is also in error.
There is some ambiguity in the DEIS in the use of the terms road improvement
versus watershed road improvement. The 90.5 miles of road improvements
consists of treatments designed primarily to facilitate hauling of logs, but some of
the treatments would, at the same time, act to improve watershed health. The
15.8 miles of watershed road improvements include only those miles of road
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treatments deemed to contribute to watershed restoration. This has been
clarified with an additional footnote to Table 0.1 of the FEIS.
oacsca
H. INCLUDING PAST EXAMPLES OF THE RANGE OF YEARS THAT TEMPORARY ROADS HAVE
BEEN IN PLACE ON THE NEZ PERCE NATIONAL FOREST. OR OTHER FORESTS IN THE
REGION
The scoping document states that temporary roads would "normally" be
decommissioned within one to three years of construction. This differs from the
statement in the DEIS, which stated that these roads would be decommissioned
within four years. Please cite examples from the NPNF where roads were
decommissioned within pledged timeframes, as well as examples where the
timeframe was extended. Please provide reasons for why these roads were not
decommissioned in a timely manner.
The FEIS needs to give past examples of the range of years that temporary roads
have been in place on the NPNF, or other forests in the region. This will give a
clearer picture of how long roads might be in place. Given the increased flexibility in
timber contracts, we fear that these roads might be in place for several years and
some 'atypical' high-risk roads may be present in degraded watersheds for up to a
decade or more. (Preservation/Conservation Organization, Boise, ID -
#15.68.21100.410)
RESPONSE:
Historically, past NEPA decisions allowed for temporary roads to be constructed,
used, and obliterated in the same season. Implementation of these decisions
found that it was the rare instance when a temporary road remained open for
more than one operating season.
It has only been in the last few years that NEPA decisions have stated that
temporary roads may be open for one to three years. Through timber sale
contract implementation, again, it will be the rare case that a temporary road will
remain open for more than one season. While the 1 to 3 year timing does
provide more flexibility to a logging contractor, they normally do not want to have
the additional expense of meeting mitigations necessary to keep road open over
the winter. The majority of the time, they will still construct, use, and obliterate in
the same season.
C# (X C8 OS O* O*
120. The Nez Perce National Forest should have used their Roads Analysis
Process in the Draft EIS.
Roads often have devastating impacts on water quality and fish habitat by increasing
landslides, erosion, and siltation of streams. Roads also fragment forests and degrade
or eliminate habitat for species that depend on remote landscapes, such as grizzly
bears, wolves, and other large, wide-ranging predators (Trombulak and Frissell 2000).
The DEIS should have used the Roads Analysis Process. However, this analysis has
yet to be completed by the Nez Perce National Forest. (Preservation/Conservation
Organization, Moscow, ID-#22.74.40220.410)
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RESPONSE:
A roads analysis consistent with the requirements of section 7712.13c of Forest Service
Manual 7700 (FSM 7700) - Transportation System was conducted as part of this
project. All roads within the project area that were deemed not essential for future
management of the affected areas, and the decommissioning of which would benefit
watershed health, as well as improve habitat for wildlife, were proposed for
decommissioning.
Please refer to response to comment 111(C).
CJ OS (S3 (18 CS (S3
121. The Nez Perce National Forest should examine how this project will affect
snowmobile use in and adjacent to the project area.
If the Forest Service is unable to demonstrate their capability to manage recreational use
of these roads, no new roads, even temporary ones, should be constructed. The
analysis should a/so examine this project will affect snowmobile use in, and adjacent to
the project area. (Preservation/Conservation Organization, Boise, ID -
#15.56.41100.501)
RESPONSE:
No changes are being planned to managing illegal road use. No changes in snowmobile
use anticipated unless a reroute is needed to mitigate winter hauling on an established
groomed trail.
(S3 CS (33 (33 08 C*
122. The Nez Perce National Forest should recognize the impact of increased
road densities.
Previous management activities have resulted in excessive road densities throughout
our National Forests, including the Nez Perce National Forest, and specifically the
Crooked River and American River watersheds. This density compromises the project
area's ability to support wildlife and fish by promoting further human disturbance,
fragmenting habitat, accelerating sedimentation, and encouraging ORV use.
RESPONSE:
The effects of past management activities, as well as road densities, are described in
the FEIS, Chapter 3, Section 3.11. Restoration activities associated with this project
include reducing the amount of roads within the project area, which are also
discussed in this Section.
The FEIS, Chapter 3, Section 3.3, Tables 3.61 and 3.65 (miles of stream with
improved access), highlight that this action, with the restoration activities, actually
improves fish access to both perennial and intermittent streams.
The roads actions in the American and Crooked River Project decommissions
significant miles of existing roads and should be recognized for the measure of
positive habitat restoration generated for numerous species. The temporary roads
being built for the project will all be decommissioned and thus do not add to the road
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density. Past road density impacts and related cumulative effects analysis
discussions for affected terrestrial wildlife are in the FEIS, Chapter 3.
csososososos
SECTION 9 - VEGETATION
123. THE NEZ PERCE NATIONAL FOREST SHOULD RESTORE NATURAL
DISTURBANCE PROCESSES IN ACCORDANCE WITH THE FOREST PLAN
A. BY ALLOWING PINE BEETLE INFESTATIONS AND WILDFIRES TO OCCUR
One of the tenets of the Plan /s to "restore natural disturbance processes where
feasible." Considering this, the mountain pine beetle infestations and wildfires
should be allowed to a certain extent to meet the Forest Plan. This is particularly
relevant due to the fact that it is acknowledged that lethal fires would be normal for
these fire regimes in the area. (Preservation/Conservation Organization, Boise, ID -
#15.46.10400.160)
RESPONSE:
This project is treating less than nine percent of the analysis area. The
disturbance process of insect infestation is occurring on many of the untreated
acres. The natural fire process is likely to occur on the untreated areas (refer to
Alternatives Maps in Appendix A). There are also more than a million acres in
wilderness and many thousands of acres in roadless areas that have not been
managed and are in a natural state (excluding fire suppression).
The Forest Plan and Fire Management Plan currently do not allow for Wildland
Fire Use (WFU) within any portion of the project area. Without the authority for
WFU all fire ignitions within the project area require a suppression response and
cannot be allowed to play it's natural role.
OSO80S
B. BY ALLOWING FIRE TO OCCUR AS A NATURAL PART OF FOREST SUCCESSION AND NOT
USING HIGH INTENSITY FOREST MANAGEMENT
We believe that high intensity forest manipulation as you are proposing, which is
really designed to replace natural fire, will not lend towards restoring functional
ecosystems. Rather, logging activities will disrupt the natural forest succession. Fire
is a natural and essential component of forest ecosystems, and the presence of
naturally functioning wildland fire indicates a high degree of ecosystem function.
This is particularly true in the American and Crooked River drainages which have
significant portions oflodgepole pine, spruce and other high elevation trees in higher
elevation landscapes. Beschta et a/., 7995 sfate, "Land managers should be
managing for the naturally evolving ecosystems, rather than perpetuating artificial
ones we have attempted to create." (Preservation/Conservation Organization,
Moscow, ID - #22.5.11200.277)
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area. Refer to FEIS, Chapter 1, Section 1.5
Please refer to the Purpose and Need and Forest Plan direction from the FEIS,
Chapter 1 , Section 3. The Forest Plan and Fire Management Plan currently do
not allow for Wildland Fire Use (WFU) within any portion of the project area.
Without the authority for WFU, all fire ignitions within the project area require a
suppression response and can not be allowed to play its natural role.
C. BY REMOVING IMPEDIMENTS TO NATURAL RECOVERY
Goals for the area include fully functioning stream ecosystems that include healthy,
resilient populations of native trout and salmon. The highest priority management
actions in the project area are those that remove impediments to natural recovery.
The task of management should be the reversal of artificial legacies to allow
restoration of natural, self-sustaining ecosystem processes. If natural disturbance
patterns are the best way to maintain or restore desired ecosystem values, then
nature should be able to accomplish this task very well without human intervention
(Frissell and Bayles, 1996). That is why we requested a real restoration alternative
that did not log or build roads.
We conclude this section of the comment letter with this passage from Frissell and
Bayles (1996):
Most philosophies and approaches for ecosystem management put forward
to date are limited (perhaps doomed) by a failure to acknowledge and
rationally address the overriding problems of uncertainty and ignorance about
the mechanisms by which complex ecosystems respond to human actions.
They lack humility and historical perspective about science and about our
past failures in management. They still implicitly subscribe to the scientifically
discredited illusion that humans are fully in control of an ecosystemic
machine and can foresee and manipulate all the possible consequences of
particular actions while deliberately altering the ecosystem to produce only
predictable, optimized and socially desirable outputs. Moreover, despite our
well-demonstrated inability to prescribe and forge institutional arrangements
capable of successfully implementing the principles and practice of integrated
ecosystem management over a sustained time frame an at sufficiently large
spatial scales, would-be ecosystem managers have neglected to
acknowledge and critically analyze past institutional and policy failures.
(Preservation/Conservation Organization, Moscow, ID -#22.58. 11 200.330)
They say we need ecosystem management because public opinion has changed,
neglecting the obvious point that public opinion has been shaped by the glowing
promises of past managers and by their clear and spectacular failure to deliver on
such promises. (Preservation/Conservation Organization, Moscow, ID -
#22.59.11200.330)
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area. Refer to FEIS Chapter 1, Section 1.5.
Please refer also to the Purpose and Need and Forest Plan direction from the
FEIS Chapter 1, pages 2-7.
O3O3O3O30303
124. The Nez Perce National Forest should consider naturally occurring
ecosystem function.
A. TO EXAMINE DISEASE ORGANISMS
Some species of trees, native insects, and disease organisms are often
described by the FS as invasive" or somehow bad for the ecosystem. Such
contentions that conditions are somehow "unnatural" runs counter to more
enlightened thinking on such matters. For example, Harvey et al, 1994 state:
Although usually viewed as pesfs at the tree and stand scale, insects and
disease organisms perform functions on a broader sca/e.
Pesfs are a part of even the healthiest eastside ecosystems. Pest roles-such as
the removal of poorly adapted individuals, accelerated decomposition, and
reduced stand density-may be critical to rapid ecosystem adjustment
In some areas of the eastside and Blue Mountain forests, at least, the
ecosystem has been altered, setting the stage for high pest activity (Gast and
others, 1991). This increased activity does not mean that the ecosystem is
broken or dying; rather, it is demonstrating functionality, as programmed during
its developmental (evolutionary) history. (Preservation/Conservation
Organization, Moscow, ID-#22.42.32510.370)
RESPONSE:
This project is treating less than 9 percent of the analysis area. The disturbance
process of insect infestation is occurring on many of the untreated acres. The
natural fire process is likely to occur on the untreated areas. There are also
more than a million acres in wilderness and many thousands of acres in roadless
areas that have not been managed and are in a natural state (excluding fire
suppression).
This project responds to public input received from people who use and reside
within the project and surrounding area. Please review the purpose and need
and forest Plan direction from the DEIS Chapter 1 pages 2-7.
(330303
B. BECAUSE INSECT INFESTATION AND FIRE ARE PART OF THE NATURAL STAND
REPLACEMENT CYCLE
The presence of some percentage of dying or at risk trees is not sufficient as a
reason to log the entire stand. Not all Lodgepole Pine trees will succumb to the
Mountain Pine Beetle and those that survive could potentially provide a genetic
resistance to beetle in the future. This genetic resistance to beetles would be
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lost if the trees were logged. (Preservation/Conservation Organization, Boise,
ID-#15.14.34000.373)
We are concerned with the statement that currently uninfected but "high risk"
trees would be harvested given the fact that, "There is little opportunity to further
prevent additional mountain pine beetle Lodgepole pine mortality in the Red
River, Crooked River, and American River watersheds (Red River Salvage EA.
p. 1). This statement is based solely on short-term economic goals and has no
ecological value: Mountain pine beetles prefer larger-diameter Lodgepole pine,
implying that all larger trees could be harvested. Further, according to
discussions with leading forest pathologists, it is impossible to predict where
Mountain Pine Beetles will go, and therefore these stands should not be logged.
(Preservation/Conservation Organization, Boise, ID-#15.116.34000.373)
RESPONSE:
This project is treating less than 9% of the analysis area. The disturbance
process of insect infestation is occurring on many of the untreated acres. The
natural fire process is likely to occur on the untreated areas. There are also
more than a million acres in wilderness and many thousands of acres in roadless
areas that have not been managed and are in a natural state (excluding fire
suppression)
Trees are prescribed to be left in all stands if still alive to meet green tree
replacements for snags. If the trees have dwarf mistletoe they are to be removed to
prevent infection of the regeneration. I have seen no literature on genetic resistance
to beetle. The beetle epidemic currently covers- the entire analysis area and the
majority of high risk stands have mortality.
OH OS OS OS OS OS
125. The Nez Perce National Forest should use best available science to define
historical ranges of variability (HRV) and to justify characterizations of
current forest conditions and disturbance regimes.
A. BY ADHERING TO NATIONAL FOREST MANAGEMENT ACT (NFMA) DEFINITIONS OF
" RANGE OF VARIATION"
It becomes very difficult to subscribe to the DES arguments when the definitions are
not precise. For this discussion, let us use a definition of range of variability as found
in the 20(X) NFMA regulations (currently in stasis due to the administration's
politics). The definition may be instructive to the writers of the DES. Range of
variability is defined here at Sec. 21936 as:
"The expected range of variation in ecosystem composition, and structure that would
be expected under natural disturbance regimes in the current climatic period. These
regimes include the type, frequency, severity, and magnitude of disturbance in the
absence of fire suppression and extensive commodity extraction."
Current climatic period is further defined as:
"The period of time since establishment of the modem major vegetation types, which
typically encompass the late Holocene Epoch including the present, including likely
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climatic conditions within the planning period. The climatic period is typically
centuries to millennia in length, a period of time that is long enough to encompass
the variability that species and ecosystems have experienced." (Id.)
To paraphrase the definition, for a project to claim that an area is outside of the
range of variability, according to the 2000 NFMA definition, it would need to make the
case that the area has not seen current conditions in a length of time encompassing
the late Holocene Epoch- a period of centuries to millennia in length. The DEIS
utterly fails to make the case that the current vegetative condition failed to exist at
any time within the late Holocene Epoch. (Preservation/Conservation Organization,
Moscow, ID - #22.33.13100.133)
RESPONSE:
A characterization of range of variability within a given time scale requires historical
data with enough statistical integrity to be meaningful. Although there are a few
historical records mostly in narrative form, comparing those records with the current
data set is arbitrary at best due to changing definitions of terms. At best, those
records extend back to 1860. Therefore, to attempt to manage within the range of
the Holocene Epoch would encompass such fluctuation and variability as to be
meaningless. This project is not based on range of variability and does not rely on
conjecture as to the former vegetative state of the area. Instead, the treatments
proposed are designed to promote the health and vigor of timber stands and improve
the environment for long-lived, fire resistant species.
oaoaea
B. BY RECOGNIZING THAT DEFINITIONS OF HRV SHOULD BE BASED ON DATA FROM
EXTENDED TIME PERIODS
In the mid-1800s, the event known as the Little Ice Age was ending. It may be that
climatic change made conditions for fires like those in the early 1900s which to occur
and become the major determinants of the landscape of today. It is also possible
that fires like those in the past century occurred on more than one occasion since the
retreat of the glaciers. Paleoecological research shows the importance of climate
change in governing vegetation (Webb and Bartlein 1992).
Vegetation changes seem to lag behind climate change (Johnson et al. 1994).
When looking at the bigger picture that takes into account climatic shifts, and not
some narrow, snapshot-in-time view, the concept of a normal fire frequency may not
be valid. (Walder 1995). Research being conducted by Grant Meyer and others on
the Boise National Forest shows this to be the case. In that case, it appears big
stand replacing events occurred in ponderosa pine forests between 900 and 1200
due to climatic conditions.
Given climate change and the very real possibility that site potential for various types
have changed (soil pH and chemistry, moisture, soil temperature) because of it, the
view of HRV on anything less than a time scale that takes into account climate shifts
may be inadequate. That is especially true given the dramatic and scientifically
documented increases in global temperature over the past few years. The past
decade was the warmest on record. Again, the DEIS and supporting documents do
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not define the HRV so it is impossible to assess the assumptions behind the HRV.
(Preservation/Conservation Organization, Moscow, ID - #22.36.13100,260)
The DEIS's apparent definition of HRV seems very narrow, without conclusive
justification and focusing mainly on ponderosa pine types. The SFLA notes much of
the analysis area is outside the HRV and the DEIS implies this is because of fire
suppression (NOTE: The SFLA is not completely clear on the current conditions and
their causes, there is equivocation and inconsistency in that document) yet it would
seem the DEIS maintains that the big fires of the early 1900s, natural events as far
as we know, put this area outside the HRV. Thus, it would appear the HRV ought to
be able to account for these events. (Preservation/Conservation Organization,
Moscow, ID - #22.34.13100.277)
What range of time is being used to determine HRV and is it long enough to be
accurate? What proof is there to refute scientific findings that forest conditions in
1850 or 1900 were only a few frames and not representative of an ecological
perspective that should be from two to three thousand years in length (see Walder
1995 and Johnson et. al 1994)?
The steady-state theory of ecology is inappropriate for time scales more than 200
years in length. (Webb and Bartlein 1992) Certainly, the goal is to have national
forests in perpetuity. A time frame of 200 years only takes us back to Lewis and
Clark, a time not so distant when the Nez Perce National Forest was considered
pad of the public domain of the USA by the federal government (though disputed
with the British) just as it is today. (Preservation/Conservation Organization,
Moscow, ID - #22.35.13100.330)
RESPONSE
Refer to response to comment 125. A review of recent literature which
documents vegetative changes during the Holocene Epoch (Brunelle and
Whitlock, 2002; Mayewski, et al, 2004; Davis ef a/; 2002) that wide fluctuations
have occurred in species composition, density, and fire regimes. The purpose
and need (Section 1.3) does not use HRV as an analysis parameter.
050*08
C. BY DESCRIBING THE FACTORS. SUCH AS FIRE AND INSECTS. ASSUMED TO BE AFFECTING
STRUCTURAL CONDITIONS OVER TIME.
Any forest condition that is maintained through intense mechanical manipulation is
not maintaining ecosystem function. We request site-specific disclosure of the
historical data used to arrive at any assumption of "desired conditions." We don't
believe the proposed management activities are designed to foster the processes
that naturally shaped the ecosystem and resulted in a range of natural structural
conditions, they are merely designed to recreate what the agency believes were
structural conditions in a single point in time that the FS considers "natural."
Generally, past process regimes are better understood than past forest structure.
How are you factoring in fire, insects, tree diseases, and other natural disturbances
in specifying the structural conditions you assume to be representative of the historic
range? (Preservation/Conservation Organization, Moscow, ID-#22.38.13100.330)
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RESPONSE:
This project responds to public input received from people who use and reside
within the project and surrounding area (refer to FEIS, Chapter 1, Section 1.5.
Please review the purpose and need and forest Plan direction from the FEIS
Chapter 1, Section 3.
as as as as o* e*
126. The Final EIS should define the terms " dying" and " at risk".
The FEIS needs to clearly define the following terms: "dying" and "at risk to Mountain
Pine Beetle attack" (Page III). (Preservation/Conservation Organization, Boise, ID -
#15.13.21100.001)
RESPONSE:
The term "dying" refers to the cessation of transport of water and nutrients within a tree.
The first sign of beetle-caused mortality is generally discolored foliage. Needles on
successfully infested trees begin fading and changing color several months to 1 year
after the trees have been attacked. The needles change from green to yellowish green,
then sorrel, red, and finally rusty brown. Fading begins in the lower crown and
progresses upward. Besides having pitch tubes, successfully infested trees will have dry
boring dust, similar to fine sawdust, in bark crevices and around the base of the tree.
Sometimes, however, infested trees can have boring dust, but not pitch tubes. These
trees, called blind attacks, are common during drought years when trees produce little
pitch. When the beetles attack, they carry blue-staining fungi into the tree. After one to
several months, the sapwood begins to discolor.
The term "at risk to Mountain Pine Beetle attack" refers to any species of pinus. In the
American and Crooked River project area the majority of the pinus is lodgepole pine.
Beetles usually select larger lodgepole pines that have thick phloem. They need
adequate food, found in large- diameter trees, for their population to build up. After the
larger lodgepole pines are killed, beetles infest smaller and smaller trees, where phloem
is thin and excessive drying occurs. Beetle populations then decline to endemic levels.
High-risk lodgepole pine stands have an average age of more than 80, an average
diameter at breast height of more than 8 inches (20 cm), and a suitable climate for
beetle development based on elevation and latitude.
In second-growth ponderosa pine, high-risk stands have a high stand basal area, a
single story, and an average diameter at breast height more than 10 inches (25 cm).
(S3 08 (S3 (S3 (33 03
Timber Management
127. The Nez Perce National Forest should not harvest timber.
A. In particular, I oppose plans to log in the East Fork of the American River and
Kirks Fork. (Individual, Seattle, WA-#8.2.34000.001)
I am of the opinion that logging will continue to damage this area. (Individual,
Minneapolis, MN - #17.2.34000.200)
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We believe that the large amount of road construction and salvage harvests
proposed are completely inappropriate given the degraded condition of this
drainage. (Preservation/Conservation Organization, Boise, ID
#15.2.34000.247)
RESPONSE:
The proposed logging in the American and Crooked River project is one method
which can be used to respond to the Purpose and Need (refer to FEIS, Chapter 1,
Section 1.3). Briefly, the purpose of the project is to reduce existing and potential
forest fuels, create conditions that will contribute to sustaining long-lived fire tolerant
tree species (ponderosa pine, western larch) and contribute to the economic and
social well-being of people who use and reside within the surrounding area.
The analysis of each alternative displays the effects to various resources.
Standards and guidelines from the Forest Plan will maintain effects within
accepted limits of change (refer to Regulatory Framework. The proposed
restoration projects and mitigations will offset any potential damage from logging
and result in an upward trend for the watersheds as a whole.
O3OSO3
B. BECAUSE TIMBER HARVESTING AND ROADBUILDING DESTROY THE ECOSYSTEM
1. Road building and logging destroy ecosystems. (Individual, Loveland, CO -
#12.4.34000.201)
RESPONSE:
Analysis of the effects of the proposed actions on various resources
demonstrate that the project will help restore landscape patterns which have
been fragmented from past actions. Ecosystem processes and functions will
remain intact.
With respect to terrestrial wildlife, some of the impacts to wildlife will be
positive including improvement of elk habitat effectiveness. Reductions in
miles of road, which is also part of this project, will offer restorative habitat
quality improvements for other species as well.
of this project, will offer restorative habitat quality improvements for other
species as well.
03 0303030303
2. I understand that the Forest Service is proposing to build some 14 miles of
new roads and log thousands of acres. The Forest Service has good
intentions to help improve the watershed, and I think that other options need
to be considered before logging. Please don't let the road-building and
logging take place. (Individual, Pullman, WA - #33.2.34000.247)
RESPONSE: Comment acknowledged
OSOSO3
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C. BECAUSE TIMBER HARVESTING SPEEDS UP THE PROGRESS OF FIRE AND COMPROMISES
SOIL QUALITY
Logging the biggest and strongest trees speeds up the progress of a fire and
compromises soil quality. (Individual, Loveland, CO-#12.2.34000.002)
RESPONSE:
The biggest, strongest trees which appear to be most resistant to effects of a
changing climate are the trees that will remain in the treated areas, Refer to the
objectives portion of Chapter 1, Section 1.3.
OSO3OS
D. BECAUSE TIMBER HARVESTING DOES NOT REDUCE FIRE DANGER
/ invite you to review the quotes I have supplied in the Appendix [ATTMT:1].
Some are from government documents and some are from environmental
groups. All are valid. They all relate to why logging, timber harvest, and
mechanical fuel removal actually increase the fire risk in the forest. I will expect
a response to each quote in our FEIS telling me: 1) why the quote does not
apply to your project, and/or, 2) why the science (which was the basis for the
quote) is incorrect. All of the quotes say that logging large commercial sized
stems does not reduce fire danger. In fact, some of the quotes say that due to
the small activity fuels left after logging, commercial logging actually increases
fire danger. (Individual, Grangeville, ID - #30.13.34000.270)
The activities (road construction and salvage harvest) described do little to
protect homes and communities from fire in any meaningful way, and may in
fact exacerbate fire danger, severity and intensity. (Preservation/Conservation
Organization, Boise, ID - #15.4.34000.271)
RESPONSE:
This project's purpose is to reduce fuels at the individual treatment site and also
at the watershed levels. Other projects such as Crooked River Defensible Space
are designed specifically to protect structures. The way this project is designed it
will help to protect other critical resources such as wildlife habitat, water quality,
recreation opportunities, and infrastructures such as roads and bridges to name
a few.
o* ea as c* e# eg
128. The Nez Perce National Forest should harvest timber.
A. BECAUSE WILDLAND FIRE CAN LEAD TO INCREASED SEDIMENT LOADS
/ understand some sediment may find its way into the creeks and rivers from the
logging and road building. This situation is only short-term, however, and is
much preferred to the stream-choking mud slides that frequently happen after a
wildfire burns off the vegetation and sterilizes the soil. (Individual, Lewiston, ID -
#7.2.34000.230)
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RESPONSE:
Comparing the sediment produced by road building and harvest to sediment
from a potential wildfire is a complicated task. Some of the factors that need to
be considered:
• Logging and harvest effects are relatively known quantities, predictable in
extent, time and location. Severe storm years can heighten impacts of
logging and road building. Permanent roads do produce peak sediment for
a few years after construction, and continue to produce chronic levels of
sediment throughout their life. Sediment from most harvest units typically
declines to negligible after 5 years (Cline, et a/, 1981). Modeled effects of
sediment due to past wildfires, road building and logging are shown in the
watershed section of the FEIS. These estimates indicate that although peak
sediment from fires was high, chronically elevated sediment from roads
continues to affect watersheds in the project area.
• Sediment effects from any particular fire are influenced by fire size,
severity, and location, interaction with existing road systems or susceptible
soils, and intense storms or rapid spring runoff during the 1-10 years
following wildfire (Wondzell and King 2003). Large severe fires in the
project area occur under a combination of drought, high temperatures, low
humidity, and strong winds (Schoennagel et a/., 2004). Under these
conditions, scattered fuel treatments may have slight effects on overall fire
size and severity. This means that such a fire could occur even with the
proposed harvest, so effects of fire might not be averted by harvest and
road building, but compounded.
• Under more moderate burning conditions, fires could be more easily
suppressed, and potential fire size reduced, by using harvest areas as
control points and fuel breaks. This is part of the rationale for the proposed
harvest and fuel reduction. See Section 3.4.2.
• Effects on streams from fires and road building are complex in time and
space. Road building generally produces fine sediments, and may little
affect flow quantity, so that streambeds are more susceptible to filling of
pools and spawning gravels with sand and silt. Fire effects on streams can
vary from negligible to dramatic, short-lived to long term. Aquatic
researchers now acknowledge the important role of natural wildfires in
structuring stream habitats, providing not only fine sediments, but also large
wood and large sediments (Bisson ef a/., 2003). Fires also may result in
increased flows that arrange these materials in the stream to build pools and
spawning gravels. Some effects can be negative, especially considered
over the short term, when individual fish may be killed, fine sediments
increased, or channels scoured in tributaries.
B. BECAUSE IT WILL ASSIST THE LOCAL ECONOMY
The logging will add to the local economy and provide enough lumber to build
some 1,500 average-sized family homes. (Individual, Lewiston, ID -
#7.4.34000.814)
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We believe cut levels can be increased to better accomplish project objectives,
and improve the economics of the project. (Timber/Wood Products Industry,
Kamiah, ID - #5. 18.34300.800)
RESPONSE: Comment acknowledged
08 CUC*
C. BECAUSE TIMBER HARVESTING INCREASES OPENINGS AND CREATES BIG GAME FORAGE
The Concerned Sportsmen of Idaho believes that more trees could and should
be harvested to increase the openings in closed forest canopy areas so that
grasses, forbs and brush can be grown to create much-needed elk forage.
(Recreation/Conservation Organization, Viola, ID - #2.2.34300.330)
RESPONSE:
There are a number of issues and considerations that had to be integrated into
the proposal to limit impacts on resources. The increased habitat effectiveness
resulting from overall reduction in miles of open roads and reduced human
disturbances will benefit elk.
D. TO EXPAND TIMBER VOLUME FOR BIG GAME
1 . The timber harvest units remove only an average of 8.6 MBF/acre, bringing
into question whether enough volume is being removed to open crown
canopies to sufficiently reduce competition and encourage big game forage
production. We further question if the removal of only 1.3 MBF/acre in the
roadside salvage will accomplish objectives. (Timber/Wood Products
Industry, Kamiah, ID - #5.8.34300.330)
RESPONSE:
The intensity of planned harvests along with liberal use of prescription fire
afterward, will serve to stimulate resprouting and growth of additional nutritious
forage for big game in most units. In the roadside salvage, the more limited
removal of standing timber was planned in part, to incorporate some protection
for minimal amounts of hiding cover along roads which would generate additional
forage without sacrificing large amounts of hiding cover adjacent to roads.
(JiSdSOS
2. While creating elk forage on the spectrum of range referred to above, the
CERT (Clearwater Elk Recovery Team) encourages you to expand the
timber volume taken so as to insure [sic] that openings in the forest are
numerous enough to accomplish the task for depleted elk herds while
remaining within Forest Plan old growth standards.
(Recreation/Conservation Organization, Moscow, ID -#1.4.34300. 350)
RESPONSE:
A number of issues and considerations had to be integrated into the proposal,
not just producing elk forage. The intensity of planned harvests along with liberal
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American River/Crooked River- Final Environmental Impact Statement
use of prescription fire afterward, will serve to stimulate resprouting and growth of
additional nutritious forage for big game in most units. Forest plan old growth
standards for old growth will be met.
(3$ OS US C8 OS OS
129. The Nez Perce National Forest should consider research that addresses
timber harvest.
A. BECAUSE RESEARCH ADDRESSES POST-HARVEST SLASH DISPOSAL
Research from the Hayman Fire (2002) has determined that pine needles, if not
burned by the fire, can provide significant protection to the soil surface when
they fall to the ground (Interim and Final Hayman Fire Case Study Analyses,
2002 & 2003). By applying regeneration harvests, the beneficial impact of this
material is not realized. Instead, slash is deposited on the ground and burned in
piles, thereby vastly increasing the potential for soil erosion and subsequent
sedimentation of critical spawning habitat for ESA listed species.
Post-logging slash disposal is critical and a number of factors should be
considered in the project design and implementation. Machine and jackpot burn
piles restricted, and if necessitated, should be evenly distributed throughout
logging units. Large piles create excessive heat, create potassium and nitrogen
overloading in small areas, and can negatively impact soil resources. Smaller
piles, evenly distributed, or broadcast burning is preferred. However, the
burning of these materials still can contribute to significant erosion problems on
the forest. (Preservation/Conservation Organization, Boise, ID
#15.105.34400.201)
RESPONSE:
Design criteria will be incorporated into silvicultural prescriptions, which will
include the method/amount of retention and/or removal of materials. In addition,
contract clauses will include design criteria that limit the size, location, and
structure of piles. Furthermore, site-specific burn plans will be developed for
each burn unit. This will include pre-ignition analysis of factors such as wind
speed, humidity, temperature, slope, aspect and duff moisture. Ignitions
performed under these conditions would limit the detrimental effects to residual
stands and the soil resource.
Post harvest slash disposal, broadcast and jackpot burning, is typically
accomplished during times of the year when duff moistures are high enough to
prevent the total consumption of the duff. The duff that remains provides soil
protection against runoff, and continues to provide nutrient cycling to the soil.
Machine piles located within the unit are typically smaller in size and distributed
fairly evenly throughout the units.
ososos
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B. BECAUSE RESEARCH INDICATES TIMBER HARVESTING. ROADS. AND OTHER HUMAN
DISTURBANCES PROMOTE THE SPREAD OF TREE DISEASE AND INSECT INFESTATION
The FS often makes a case for logging as a way to reduce insect and disease
damage to timber stands As far as we are aware, the FS has no empirical
evidence to indicate its "treatments" for "forest health" decrease, rather than
increase, the incidence of insects and diseases in the forest. Since the FS
doesn't cite research that proves otherwise in this DEIS we can only conclude
that "forest health" discussions are unscientific and biased toward logging as a
"solution." Please consider the large body of research that indicates logging,
roads, and other human caused disturbance promote the spread of tree
diseases and insect infestation.
For example, multiple studies have shown that annosus root disease
(Heterobasidion annosum, formerly named Fomes annosus), a fungal root
pathogen that is often fatal or damaging for pine, fir, and hemlock in western
forests, has increased in western forests as a result of logging (Smith 1989).
And researchers have noted that the incidence of annosus root disease in true
fir and ponderosa pine stands increased with the number of logging entries
(Goheen and Goheen 1989). Large stumps served as infection foci for the
stands, although significant mortality was not obvious until 10 to 15 years after
logging (Id).
The proportion of western hemlock trees infected by annosus root disease
increased after pre-commercial thinning, due to infection of stumps and logging
equipment wounds (Edmonds et al 1989, Chavez, et al. 1980).
Armillaria, a primary, aggressive root pathogen of pines, true firs, and Douglas-
fir in western interior forests, spreads into healthy stands from the stumps and
roots of cut trees (Wargo and Shaw 1985). The fungus colonizes stumps and
roots of cut trees, then spreads to adjacent healthy trees. Roots of large trees
in particular can support the fungus for many years because they are moist and
large enough for the fungus to survive, and disease centers can expand to
several hectares in size, with greater than 25% of the trees affected in a stand
(id) Roth et al. (1980) also noted that Armillaria was present in stumps of old-
growth ponderosa pine logged up to 35 years earlier, with the oldest stumps
having the highest rate of infection.
Filip (1979) observed that mortality of saplings was significant correlated to the
number of Douglas-fir stumps infected with Armillaria me/tea and laminated root
rot (Phellinus weirii). McDonald, et al. (1987) concluded the pathogenic fungus
Armillaria had a threefold higher occurrence on disturbed plots compared to
pristine plots at high productivity sites in the Northern Rockies. Those authors
also reviewed past studies on Armillaria, noting a clear link between
management and the severity of Armillaria-caused disease.
Morrison and Mallett (1996) observed that infection and mortality from the root
disease Armillaria ostoyae was several times higher in forest stands with
logging disturbance than in undisturbed stands, and that adjacent residual trees
as well as new regeneration became infected when their roots came into
contact with roots from infected stumps.
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Pre-commercial thinning and soil disturbance led to an increased risk of
infection and mortality by black- stain root disease (Leptographium wageneri) in
Douglas-fir, with the majority of infection centers being close to roads and skid
trails (Hansen et al. 1988) Also another Black-stain root disease (Verticicladiella
wagenerii) occurred at a greater frequency in Douglas-fir trees close to roads
than in trees located 25 in or more from roads (Hansen 1978). Witcosky et al.
(1986) also noted that pre-commercially thinned stands attracted a greater
number of black-stain root disease insect vectors.
Complex interactions involve mechanical damage from logging, infestation by
root diseases, and attacks by insects. Aho et al. (1987) saw that mechanical
wounding of grand fir and white fir by logging equipment activated dormant
decay fungi, including the Indian paint fungus (Echinodontium tinctorium).
Trees stressed by logging, and therefore more susceptible to root diseases are,
in turn, more susceptible to attack by insects. Goheen and Hansen (1993)
reviewed the association between pathogenic fungi and bark beetles in
coniferous forests, noting that root disease fungi predispose some conifer
species to bark beetle attack and/or help maintain endemic populations of bark
beetles.
Goheen and Hansen (1993) observed that live trees infected with Laminated
root rot (Phellinus weirii) have a greater likelihood of attack by Douglas-fir
beetles (Dendroctonus pseudotsugae). Also, Douglas- fir trees weakened by
Black-stain root disease (Leptographium wageneri var. pseudotsugae) are
attacked and killed by a variety of bark beetle species, including the Douglas-fir
bark beetle (D. pseudotsugae) and the Douglas-fir engraver (Scolytus
unispinosis) (id.).
The root disease Leptographium wageneri var. ponderosurn predisposes
ponderosa pine to several bark beetle species, including the mountain pine
beetle (D. ponderosae) and the western pine beetle (D. brevicomis) (Goheen
and Hansen 1993).
A variety of root diseases, including black-slain, Armillaria, and brown cubical
butt rot (Phaeolus schweinitzii). predispose lodgepole pine to attack by
mountain pine beetles in the interior west The diseases are also believed to
provide stressed host trees that help maintain endemic populations of mountain
pine beetle or trigger population increases at the start of an outbreak (Goheen
and Hansen 1993).
Grand and white fir trees in interior mixed-conifer forests have been found to
have a high likelihood of attack by the fir engraver (Scolytus ventralis) when
they are infected by root diseases, such as laminated root rot, Armillaria, and
annosus (Goheen and Hansen 1993).
More western pine beetles (Dendroetonus breviformis) and mountain pine
beetles (D. ponderosae) were captured on trees infected by black-stain root
disease (Ceratocystis wageneri) than on uninfected trees (Goheen et al. 1985).
The two species of beetle were more frequently attracted to wounds on trees
that were also diseased than to uninfected trees. They also noted that the red
turpentine beetle (Dendroctonus valens) attacked trees at wounds, with attack
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American River/Crooked River- Final Environmental Impact Statement
rates seven-to-eight times higher on trees infected with black-stain root disease
than uninfected trees. Spondylis upiformis attacked only wounded trees, not
unwounded trees. (Preservation/Conservation Organization, Moscow, ID -
#22.46.34000.373)
RESPONSE:
Comment acknowledged.
The stands proposed for treatment are susceptible and contain some of the
pathogens and insects described. Most have a negative growth value (more dying
than growing) and are in a state of decline. The purpose of the project is to reduce
existing and potential forest fuels, create conditions that will contribute to sustaining
long-lived fire tolerant tree species (ponderosa pine, western larch). Refer to FEIS,
Chapter 1, Section 1.3. Ponderosa pine and western larch are the forest tree
species most resistant to fire, insects, and diseases found in the project area.
09 OS C9 C9 O8 (Si
130. The Nez Perce National Forest should focus on stands farthest outside the
historic range.
The Forest Service should focus on those stands that are the farthest outside of the
historic range (i.e. the 3.2% of the project area that exhibits frequent, non-lethal fire
regimes). (Preservation/Conservation Organization, Boise, ID-#15.96.33000.277)
RESPONSE:
Comment acknowledged. Historic range is a concept based on scale (e.g., temporal
and spatial). Only focusing only on the stands that are farthest outside of their
historic range would not fulfill the purpose of this project - which is related to reducing
existing and potential forest fuels by removing the dead, dying, and downed trees
that would otherwise result in high fuel loadings
05 (33 C* (X 0* 08
131. The Nez Perce National Forest should conduct an inventory of the types
and sizes of downed woody material.
Fallen snags that lean against other trees serve as important subnivean access points
for mesocarnivores such as Fisher and American Marten. An inventory of the types and
sizes of downed woody material should be included in the treatments.
(Preservation/Conservation Organization, Boise, ID - #15.129.30100.330)
RESPONSE:
Over the next 10 years or so, many thousands of acres of unharvested lodgepole
pine will progressively convert to snags, most of which will fall, lean or "jackstraw"
forming excellent subnivean habitat. Given the vast amounts of dead and dying
lodgepole pine in the analysis area, and the fact that planned treatment acreage
would fall far short of even 10 percent of the local landscape, the growth of important
subnivean habitats formed by fallen snags from many acres of unharvested dead
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American River/Crooked River- Final Environmental Impact Statement
and dying lodgepole pine will dwarf present amounts of this habitat condition, which
would make an inventory at this time a relatively meaningless activity.
as cs o* e« e* vs
132. The Nez Perce National Forest should include contributions of woody
debris from sources outside riparian areas when analyzing woody inputs.
EPA recommends that the analysis of large woody debris in the final ETS include
contributions from sources outside the riparian areas. While wood contributions from
riparian reserves is critical, large wood originating outside of riparian areas is also a key
to stream hydrology, fish habitat and water quality on Federal and downstream private
lands. Two large wood studies conducted in Western Oregon found that large wood
inputs from near-stream riparian areas made up only about half of the total, with the
other half coming from up-slope source areas farther from streams. (Federal Agency
Official, Seattle, WA-#24.22.13110.244)
RESPONSE:
Review of the studies mentioned and additional literature supplied by your agency
highlight that the lands under study where large wood is supplied to streams from
outside the RHCA occur mostly from landslides in areas subject to rain on snow
events or in unstable landscapes. The project area streams are not located in high
risk landscapes and rain on snow events are not a frequent event in American and
Crooked Rivers. Streamside and landslide prone RHCAs defined in Section 3.3 of
the FEIS are designed to protect existing potential LWD in the project area.
ca us c* os os en
133. The Nez Perce National Forest should use best available science to define
Vegetative Response Units (VRUs)
USING AGENCY LITERATURE ON WILDFIRE IN IDAHO
One of the biggest problems with the DEIS is the inconsistent analysis lack of
comparability between VRUs (HVGs, HTGs?) and habitat types. For example, it
becomes difficult, if not impossible, to analyze the VRUs in light of important information
contained in agency literature on wildfire in Northern Idaho (see Smith and Fischer
1997). (Preservation/Conservation Organization, Moscow, ID - #22.54.13100.270)
RESPONSE:
We have added a definition of Vegetation Response Units (VRUs) and habitat
type groups (HTGs) to the glossary and augmented the discussion of VRUs in
the FEIS Section 3.10 Vegetation - Analysis Methods. Between the DEIS and
the FEIS we have adopted the habitat type groups used for the Idaho Cohesive
Strategy (Jones, 2003). Appendix N shows the Idaho Cohesive Strategy habitat
type groups by habitat type, so that you can compare them to Kapler-Smith and
Fischer's (1997) fire groups or Green et al. 1992 Old Growth habitat type groups.
The habitat types are from existing classifications, including Cooper et al., 1992,
and Steele et al., 1981. The habitat type groups used in the DEIS are from
Applegate et al., 1995. The habitat type groups used in the FEIS are from Jones,
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American River/Crooked River - Final Environmental Impact Statement
2003, except for the weeds analysis, which uses Applegate et al. It is admittedly
difficult to track all the different habitat type groups developed for different
purposes. We can supply the data table of Jones' habitat type groups upon
request.
(IS (S3 (IS (33 (S3 (S3
134. The Nez Perce National Forest should define and implement diameter
limits and spacing between crowns.
A. Larger diameter frees that are more resistant to ground fire should be ten behind.
The Forest Service needs to define and implement diameter limits and spacing
between crowns for each treatment. Dead and dying Lodgepole pine stands that are
beyond the range of current road systems should be left to regenerate naturally, or
provide opportunities for climax species, in order to maintain natural ecological
cycles. (Preservation/Conservation Organization, Boise, ID-#15.117.34400.201)
Ground-based logging systems and excavator piling of slash should be minimized,
and higher intensity landscape burns should be considered to prevent continuous
fuel loads. It is unfortunate that the majority of units will be ground-skidded and
machine piled, as the impacts from this are much more severe in terms of soil
compaction, erosion and sedimentation. (Preservation/Conservation Organization,
Boise, ID - #15.120.34400.231)
RESPONSE:
At this time the lands within the project area have no approved WFU plan and the
risks in using prescribed fire at mixed and lethal severities is considered too high
in this area, without prior mechanical fuel reduction.
OSCStoJ
B. The above-referenced logging methods have the potential to increase fire risk in the
short term, and therefore would be counter-productive towards meeting the fire risk
reduction purpose of the project. Forest openings can result in increased wind
speed and related blow-down, more rapid drying of the forest vegetation, and dense
tree and shrub regeneration. Additionally, slash on the ground can lead to increased
short-term fire risk as has been demonstrated throughout the industrial forestlands of
North Idaho and beyond. (Preservation/Conservation Organization, Boise, ID -
#15.97.34400.270)
RESPONSE:
It is acknowledged that the short-term risk of a high severity wildfire is possible
between the time of the vegetation treatment and the slash disposal is
completed. The long term benefits of the treatments, modified fire behavior and
lower future fuel loadings, outweigh the short term risk. Additionally after the
slash disposal is completed the fuel loadings within the treatment units will be
less than 12 tons per acre. If the treatments are not completed and stands
continue to transition to Fuel Model 10 and 13 we would see fuel loadings in
excess of 12 tons per acre.
(X 03 (IS C* OS 03
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135. The Nez Perce National Forest should compare present, historic, and post-
treatment fuel loads and canopy densities.
The Forest Service needs to compare present, historic, and post-treatment fuel
loads and canopy densities for each unit within the proposed treatment areas.
(Preservation/Conservation Organization, Boise, ID-#15.93.30300.277)
RESPONSE:
The text has been updated in the FEIS document to address the current, predicted
future, and post-treatment fuel models for the project area. Please see the Fire/Fuels
discussion located within chapter 3 of the American Crooked FEIS.
OS (33 C8 Ci (33 <33
136. The Final EIS should provide more data on current and target crown
densities.
The Forest Service needs to provide more quantified data on the current and target
levels of crown densities in the project area. (Preservation/Conservation Organization,
Boise, ID - #15.94.13110.335)
RESPONSE: See FEIS, Chapters, Section 3.10
e« es e* o# G* ca
137. The Nez Perce National Forest should address shade tolerant species.
On south-facing slopes, the Forest Service should reduce the number of shade tolerant
species. On north-facing slopes, canopies are historically denser with a greater
abundance of shade tolerant species. (Preservation/Conservation Organization, Boise,
ID - #15.98.33000.277)
RESPONSE: See FEIS, Chapter 3, Section 3.10.
o* e# e« cs o# e*
138. The Nez Perce National Forest should use patch cuts.
A. WITH OPENINGS OF FOUR ACRES OR LESS
Any and all patch cute within the entire home range/foraging area should be four
acres or less with reserve trees in order to be consistent with the Management
Recommendations (Reynolds et al. p. 26):
Openings (up to 4 acres), for herbaceous and shrubby under story development and
tree regeneration, are desired in ponderosa pine and mixed-species forests; smaller
openings are desired in spruce-fir forests (Reynolds et al. 1992, p, 6).
Because goshawks are forest and forest-edge predators that scan for prey from
trees, creating openings larger than 4 acres effectively removes these areas from
goshawk foraging habitat and departs from VSS requirements for openings in the
Management Recommendations. (Preservation/Conservation Organization, Boise,
ID-#15.81.34400.391)
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RESPONSE:
The purpose of the project is to reduce existing and potential forest fuels,
encourage conditions for sustaining long-lived, fire tolerant conifer species, and
contribute to both the economic and social well being (safety & economic
security) of local residents. Within this broader objective, we sought to design a
compromise approach, incorporating mitigations as needed to minimize impacts
on goshawks and their habitats.
(S3(J3 G#
B. BECAUSE IT WILL HELP REDUCE DANGER FOR FIREFIGHTERS
/ support your plan to punch clear-cuts into the forests in the American and Crooked
Rivers area. I believe they will help firefighters if a wildfire occurs. (Individual,
Lewiston, ID - #7.1.34410.270)
RESPONSE: Comment acknowledged.
oa c« o« c# vs <&
139. The Nez Perce National Forest should learn from past regeneration
harvests on the Nez Perce and other forests that are dominated by
lodgepole pine stands.
It is critical that the Nez Perce National Forest (NPNF) learn from past examples of
regeneration harvests on the NPNF and other forests that are dominated by
Lodgepole pine stands. Evidence shows that under extreme conditions, young
stands of dense Lodgepole pine will burn. An example of this is visible on the
Caribou-Targhee National Forest, directly adjacent to Yellowstone National Park.
The Clover-Mist Fire (1988) was started by woodcutters in a clear cut stand, which
had re-grown with thick Lodgepole pines. Even though aggressive and responsive
fire suppression actions were undertaken, the fire quickly spread through adjacent
stands and burned into Yellowstone Park, eventually threatening Old Faithful.
Similar examples of clear cutting Lodgepole pine stands should be sought out by
the NPNF, and research conducted to determine the effectiveness of logging
activities on fire behavior. (Preservation/Conservation Organization, Boise, ID -
#15.102.33000.279)
RESPONSE:
It is acknowledged that there is a short timeframe, when canopies grow together in
overstocked stands, where lodgepole pine stands that are regenerating may have
increased fire behavior characteristics until the canopies start to lift off the ground.
As the commenter stated this occurs under extreme conditions (i.e., low fuel
moistures, high temperatures, and high wind conditions). The FEIS, Chapter 3,
Section 3.4, that under extreme fire conditions fire behavior is rarely responsive to
either fuel treatments or suppression actions. What this project is attempting to do is
modify the fire behavior in the conditions that would have historically produced large
fires but are not the worst case conditions.
CS CS CS OS 03 OS
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140. The Nez Perce National Forest should not set unrealistic standards and
guidelines for timber harvesting.
BECAUSE IT PREVENTS AGGRESSIVE TREATMENTS THAT MOVE THE AREA TOWARD NATURAL
DISTRIBUTION OF AGE CLASS AND SPECIES
/Acres treated -only 8.7% of the total project area was treated. While a clear
objective is to protect Elk City from catastrophic fire, one must question if unrealistic
plan standards prevented treatment of sufficient acres to accomplish the project
objective. This is of particular concern since approximately 80% of the area is in
the 9-21 "dbh category, prime for forest health treatment. It would appear that other
resource limitations, possibly unrealistic standards and guides, are preventing more
aggressive treatment to move this area towards the more natural distribution of age
class and species. (TimberAWood Products Industry, Kamiah, ID - #5.7.34300.160)
RESPONSE: Comment Acknowledged
en e* c* o# o« e«
Old Growth
141. The Nez Perce National Forest should conduct field reviews.
A. TO DETERMINE IF TIMBER HARVEST UNITS MEET OLD GROWTH CRITERIA
We question the assertion that that no logging will occur in stands of old growth.
We encourage you to conduct field reviews in order to determine whether or not
any of the logging units currently meet Old Growth Criteria, as described in Old-
Growth Types of the Northern Region (Green et al, 1992). Numerous problems
have been found with old growth inventories on the adjacent Clearwater
National Forest, and to avoid any similar occurrences, the NPNF should
immediately initiate a forest wide analysis of old growth as part of this and other
projects in the Elk City area. (Preservation/Conservation Organization, Boise,
ID-#15.134.30100.365)
RESPONSE:
Between the draft and final documents, we conducted a second analysis of the
project using Forest Plan old growth criteria from Appendix N. This review
resulted in conducting field reviews and plot sampling of planned harvest stands
that were suspected Forest Plan old growth. This resulted in removal of 4
harvest units from the draft to the final project. We then took this follow-up
analysis a step further by carefully evaluating risks that existing old growth units
may have patches or extensions of the old growth conditions which extended into
planned harvest units. All Units were field reviewed by a certified silviculturist and
units which appeared to be old growth were sampled using the National Common
Stand Exam Protocol. Units larger than ten acres that meet the definition of old
growth are to be left untreated.
cscso*
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B. TO DETERMINE IF OLD GROWTH SHOULD BE HARVESTED
The DEIS is not clear whether there has been any site specific analysis of the
cutting units to determine whether extant old growth would be logged. The
DEIS is not clear what definition of old growth is being used, the forest plan
definition or the North Idaho guidelines. (Preservation/Conservation
Organization, Moscow, ID-#22.72.30300.365)
RESPONSE:
The original analysis utilized criteria from the North Idaho guidelines. Between
the draft and final documents, we conducted a second level, more intensive
analysis of the project using Forest Plan old growth criteria from Appendix N.
See response to comment 141 (A).
VI O* 0* (S3 OS V5
142. The Nez Perce National Forest should meet old-growth objectives.
A. BY CONDUCTING INVENTORIES AND MONITORING
The fact that the Nez Perce NF has not monitored the population trends of its
old-growth management indicator species (MIS) as required by the forest plan
bears important mention here. The Nez Perce NF has failed to insure viability
of MIS and TES species to date. The monitoring reports from FOC to the Nez
Perce National Forest (referenced in this comment) bear this out.
Unfortunately, region-wide the FS has failed to meet Forest Plan old-growth
standards, does not keep accurate old-growth inventories, and has not
monitored population trends in response to management activities as required
by Forest Plans and NFMA (Juel, 2003). (Preservation/Conservation
Organization, Moscow, ID - #22.63.30100.210)
RESPONSE:
A complete summary record of our Forest Plan monitoring of MIS and TES
species results is listed at the back of and supports the terrestrial species viability
analysis document titled: "Habitat-Based Terrestrial Vertebrate Populations
Viability Related to the American and Crooked River Project" (USDA FS, 2004a),
available in the project files. Our species viability analysis is more than simply a
"proxy on proxy" approach.
oaeac*
B. THROUGH FLEXIBILITY IN ACCOMPLISHING OLD-GROWTH OBJECTIVES
Old growth - if we understand the data, there is only a total of 13 acres of 21"
dbh + in the total project area. The strategy to meet old growth objectives
would be to preserve these areas, and select the appropriate amount of area
from the 9-21" dbh category to provide old growth replacement. Since almost
80% of the project area is in this size category, there should be considerable
flexibility in accomplishing objectives. (Timber/Wood Products Industry,
Kamiah, ID-#5.6.34100.365)
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RESPONSE:
This comment was generated by a misconception that the size/structure data in
the vegetation section of the DEIS, equated to old growth. While there is certainly
a correlation, the actual old growth habitat has more specific characteristics. The
size and structure data for vegetation in the project area and the American and
Crooked River drainages has been re-analyzed between the DEIS and FEIS
using an updated Region 1 vegetation coverage. As the new analysis portrays, a
large amount of the project area is in the greater than 15 inch dbh size class, and
meeting Forest Plan requirements for replacement old growth is relatively easy to
do and provides some flexibility to accomplish objectives while protecting future
blocks of old growth. This analysis is located in the vegetation section of Chapter
3 in the FEIS.
The further refined old growth habitat analysis is located near the end of the
wildlife section in chapter 3. This analysis received extensive updating between
the DEIS and FEIS. Specifically, the Forest Inventory and Analysis (FIA) plots
were completed and the total old growth forest wide was summarized (see table
in the old growth section of Chapter 3).
Old growth validation surveys were conducted within the project area in
designated old growth stands during the fall of 2004. These stands were
originally designated using data from stand exams that were 15-20 years old. It
was felt that the data may be stale and the stands may have changed enough to
no longer meet the strict Forest Plan definition of old growth (15 trees per acre
>21 inches DBH). The results of the surveys and conclusions are located in the
old growth analysis section of Chapter 3.
OS C# OS C5S OS 08
Weed Management
143. The Nez Perce National Forest should adequately fund and monitor for
weeds.
Monitoring for weeds and acquiring adequate funding for weed treatments need to be
required and guaranteed. (Preservation/Conservation Organization, Boise, ID -
#15.90.30100.001)
RESPONSE:
Through the analysis a set of project design criteria or mitigation requirements have
been established to address the risk of weed spread and colonization resulting from the
proposed project. The design criteria include prevention measures, spot treatment,
monitoring, re-survey of risk zones for changes in weed infestations and, where
appropriate, the re-vegetation of disturbed soil (Chapter 2 - Design Criteria). The
implementation of these invasive plant design criteria would insure that weed spread
from ground disturbing actions is minimized or eliminated.
oa oa os oa oa oa
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144. The Nez Perce National Forest should consider weed management.
A. WITH COORDINATION OF NOXIOUS WEED EFFORTS
We are particularly concerned with noxious weeds because there is no
comprehensive weed management strategy for this area. With the amount of
commercial and recreational activity taking place on private and National Forest
lands in this area, failure to coordinate efforts will make project-level strategies
inadequate. (Preservation/Conservation Organization, Boise, ID
#15.87.30300.371)
RESPONSE:
The American River and Crooked River Watersheds fall within the Clearwater Basin
Weed Management Area (CBWMA). The CBWMA is a community-based effort that
brings together those responsible for weed management within the Clearwater River
Basin, to develop common weed management objectives, set realistic priorities,
facilitate effective treatment and coordinate efforts along logical geographic
boundaries with similar land types, use patterns and problem plants. Partners
involved in the CBWMA include Idaho County, Clearwater County, Lewis County,
Clearwater NF, Nez Perce NF, BLM, Nez Perce Tribe, University of Idaho,
Clearwater RC&D, Back Country Horseman and Private landowners. The intent of
reducing risk of weed spread and establishment, treating small infestation before
they expand, providing focus on the transportation network, and reoccurring surveys
integrate many of the priority elements of the Clearwater Basin Weed Management
Area. Coordination at multiple scales is a tenet of cooperative weed management
programs across jurisdictional boundaries. As a result weed management efforts are
coordinated across local, basin, regional and state levels by the community
partnership of which the National Forest is an active participant.
oaesea
B. TO BE PROACTIVE IN PREVENTING INFESTATION
Although the Forest Service does not consider the weed situation to be severe, the
Forest Service should realize that it is far cheaper to be proactive, in order to prevent
infestation, as opposed to having lax standards and to allow the situation to
deteriorate. This is a potentially large threat considering the level of disturbance that
is proposed and the new road construction that will increase motorized vehicles in
previously non-impacted areas, acting as vectors for new infestations of noxious
weeds. Due to the limitations for herbicide application in these high-priority
watersheds, action must be taken to avoid weed infestations and should have been
addressed as part of this analysis. (Preservation/Conservation Organization, Boise,
ID-#15.91.32510.371)
RESPONSE:
The design criteria (Chapter 2 - Design Criteria) were developed as a result of the
risk assessment conducted as part of the analysis. They reflect a concern for the
potential of weed spread from ground disturbing activities, taking into account the
type and condition of the vegetation communities within the project area. The
proposed mitigation is commensurate with the risk. Integrating project level actions
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
within the broader context of a community-based strategy add strength to the overall
weed management effort in the upper watersheds of the Clearwater basin. Refer,
also to response to comment 144(A), above.
C* CS C# C8 OS C*
145. The Nez Perce National Forest should address how the proposed project
will adversely affect native species.
777e Forest Service has failed to adequately address how the proposed project will
adversely affect native species by allowing noxious weed importation and establishment.
(Preservation/Conservation Organization, Boise, ID-#15.88.21100.371
RESPONSE:
The weed risk assessment in Chapter 3 is based on the susceptibility of the native plant
communities in the project area, weed infestations found in the area, the level of
disturbance and presences of spread corridors. Briefly, the analysis found that there is a
moderate risk of weed spread and establishment as a result of proposed disturbances.
To reduce the risk of continued weed spread design criteria (FEIS, Chapter 2, Design
Criteria) is integrated into the project and will be a requirement of the proposed project.
Noxious weeds will not be allowed to spread nor establish as a result of implementation
of the proposed project. Therefore, it is expected that no adverse affects to native plant
communities will occur.
OS Ctf (IS OS C* O*
SECTION 10-WILDLIFE
146. THE NEZ PERCE NATIONAL FOREST SHOULD CONSIDER POPULATION VIABILITY
AT THE FOREST LEVEL.
For the proposal to be consistent with the Forest Plan, enough habitat for viable
populations of old- growth dependent wildlife species is needed over the landscape.
Considering potential difficulties of using population viability analysis at the project
analysis area level (Ruggiero, et. al, 1994), the cumulative effects of carrying out
multiple projects simultaneously across the Nez Perce NF makes it imperative that
population viability be assessed at least at the forest wide scale (Marcot and Murphy,
1992). (Preservation/Conservation Organization, Moscow, ID - #22.67.32200.350)
RESPONSE:
An analysis of terrestrial species population viability analysis has been prepared and
is available in the project files titled: "Habitat-based Terrestrial Vertebrate
Populations Viability Related to the American and Crooked River Project" (USDA FS,
2004a). This analysis incorporates landscape and local habitat information as well
as a summary of MIS populations monitoring data & trends from the Forest Plan
Monitoring & Evaluation Reporting required by the Forest Plan. It is not simply a
"proxy on proxy" approach to population viability analysis.
cs c« o# o* o* e*
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American River/Crooked River- Final Environmental Impact Statement
147. The Nez Perce National Forest should consider wildlife fragmentation.
A. The fragmentation of wildlife habitat by the proposed treatments needs to be
assessed. The effects of regeneration harvesting on species dependent upon
contiguous forested habitat should be considered. We are particularly concerned
that the proposed action has the potential to negatively impact American Marten,
Fisher, Wolverine, Moose, Elk, and Canada Lynx. (Preservation/Conservation
Organization, Boise, ID-#15.127.30300.331)
RESPONSE:
The fragmentation discussion and effects analysis information for old growth
species is located in the FEIS (Chapter 3, Section 3.11). Fragmentation
analysis and discussions for wolverine, moose, elk, and Canada lynx are
located in the FEIS in Chapter 3, Section 3.11.
osc*e#
B. Treatments need to be timed to reduce the impact on nesting birds and denning
mammals. (Preservation/Conservation Organization, Boise, ID-#15.125.34000.350)
RESPONSE:
Project design and mitigation measures have been added to better address
these concerns in the FEIS. See project design and mitigation section.
US 08 OS CS O* (39
148. The Nez Perce National Forest should consider cumulative and direct
impacts of the treatments on local wildlife populations.
In addition to the direct impacts these treatments will have on local [wildlife] populations,
the cumulative or linked impacts of these activities on adjacent populations needs to be
considered. (Preservation/Conservation Organization, Boise, ID-#15.126.30300.350)
RESPONSE:
Within the FEIS, the cumulative effects or linked impacts are addressed in
Chapter 3, Section 3.11.
0* (33 G# C* C# (Si
149. The Nez Perce National Forest should leave snags for cavity nesters.
A sufficient number of snags need to be left standing in each treatment area for cavity
nesters until snags can be replaced by natural recruitment. Standing trees need to be
overstocked to ensure sufficient habitat until new trees mature.
(Preservation/Conservation Organization, Boise, ID-#15.128.34400.330)
RESPONSE:
The target numbers of snags retained per acre used as an objective is from the
Forest Plan, Appendix N-3, and specific project implementation guidelines for the
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American River/Crooked River- Final Environmental Impact Statement
project follow the "Northern Region Snag Management Protocol", in the project
file.
ex as 03 us e* os
150. The Nez Perce National Forest should consider goshawks and follow
guidelines and requirements.
A. The DE/S implies that no formal surveys for goshawks have occurred in the project
area. At best, there are sighting records. In order to meet the requirements of
NFMA and NEPA, these kinds of surveys need to be conducted for all Ml and TES
species. (Preservation/Conservation Organization, Moscow, ID-#22.65.30100.340)
RESPONSE:
Although no formal surveys were conducted for goshawks, the Forest Wildlife
Biologist spent 5 weeks surveying habitat conditions, reporting incidental
sightings, and searching for suitable harvest sites during early summer of
2003. Several sightings and potential nesting activity areas were thus
identified and are documented in the project files (See Crooked_Amer-
Wiidiife_Observations_Tabie.doc). Conducting individual species surveys
throughout a landscape as extensive as the American/Crooked project was
neither a practical nor affordable alternative given the timeframes to complete
this project.
osojos
B. The DEIS suggests that because of major differences in forest types, habitat, and
availability of riparian zones, the cross-region application of the Management
Recommendations cannot be justified. However, it mentions that no guidelines exist
for goshawk nest and habitat protection within USFS Region 1. Given the lack of
guidelines, the sensitivity of goshawks to disturbance via logging, and the scope of
the project, management should rely on these recommendations to ensure a level of
prudence. (Preservation/Conservation Organization, Boise, ID-#15.82.10400.390)
RESPONSE:
Considering the fact that the large tree component and higher canopy closures
preferred by goshawks for nesting will, in many cases occur within old growth, and
the project harvests no old growth stands (either Forest Plan or North Idaho
standards) nor in Riparian Habitat Conservation Areas, existing and historic nests
identified during layout goshawks nests should be adequately protected. See
Chapter 2: Mitigation and Design Measures Section.
ea oses
C. TO DETERMINE EXISTING ALTERNATIVE GOSHAWK NESTS
In addition to protecting existing alternate nests, the Management Guidelines
specifically recommend that a minimum of three presently suitable nest areas of 30
acres each should be maintained per home range. These nest areas are usually
mature old trees and dense forest canopies: "No adverse management activities
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American River/Crooked River - Final Environmental Impact Statement
should occur at any time in suitable nest areas" (Reynolds et al. 1992). For each
goshawk home range, the Forest Service should have identified three 30-acre stands
of present nest sites for a total of 90 acres. In addition to protecting three suitable
nest areas, the Management Recommendations also suggest that land managers
identify and prepare three 30-acre stands of replacement nest sites for a total of 90
acres in the event that the original nest sites are lost in a wildfire or other event. The
Forest Service should manage these replacement sites to ensure future stand
conditions consisting of dense, mature stands with high tree cover and high basal
area. (Preservation/Conservation Organization, Boise, ID - #15.80.32400.391)
RESPONSE:
See above comments. The Nez Perce National Forest has not inventoried all
potential goshawk nests in the project area, thus protecting currently
unknown nests is not possible at this time. Further, old-growth stands which
tend to have disproportionate amounts of nest selection characteristics
preferred by goshawks are protected from all harvests, further reducing risks
of unknown nest habitat losses to harvesting.
Management recommendations proposed by Reynolds et al., 1992, were
developed specifically for the southwestern United States. Thus, it would be
inappropriate to apply these guidelines to the moister, intermountain west.
Given that this project will not harvest old growth stands and that active or
newly discovered goshawk nests will be protected, goshawks nests should be
adequately protected.
us e* oa c* e* e*
151. The Nez Perce National Forest should design this project such that legal
requirements for protecting habitat of threatened and endangered (TE) and
other sensitive species are recognized.
RESPONSE:
The legal requirements for protecting threatened and endangered and other
sensitive species habitats have been met as addressed in the Biological
Assessments (T&E), and the sensitive species discussions within the FEIS. In
addition, a terrestrial and aquatic species viability analysis is provided which
provides rationale supporting long-term persistence of these species. See FEIS,
ROD, BEs Appendix E and J.
(X ose*
A. BY MEETING EXISTING FOREST PLAN GOALS REGARDING RECOVERY OF
TE HABITAT AND PROMOTION OF INTRINSIC WILDLIFE VALUES
The following goal in the Forest Plan is not being met and would be further
compromised by massive logging and vegetation projects under the ruse of fire
prevention: Provide habitat to contribute to the recovery of Threatened and
Endangered plant and animal species in accordance with approved recovery plans.
(Individual, Delmar, NY-#28.4.10400.340)
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RESPONSE:
Recovery of wolves has been accomplished. The amount of designated lynx
habitat within the project area is extremely limited (see FEIS, Chapter 3 - Section
3.11), and all requisites of the Lynx Conservation Assessment and Strategy have
been satisfied (see lynx section of FEIS). The project occurs outside the
wintering area of bald eagles. The U.S. Fish & Wildlife Service has reviewed and
verbally agreed with the conclusions in the Biological Assessment (see Level 1
consultation notes).
B. BY MEETING FOREST PLAN STANDARDS FOR OLD GROWTH
The Forest Service also has a responsibility to protect replacement old growth areas,
particularly since the NPNF is not meeting the Forest Plan Standards for Old Growth
throughout the majority of these watersheds. (Preservation/Conservation
Organization, Boise, ID -#15.137. 10400.365)
RESPONSE:
After the DEIS and comments, a more extensive and intensive old growth
analysis using Forest Plan standards and field review of stands further removed
harvest units that would meet North Idaho and Forest Plan old growth definitions.
In addition, provisions and mitigations to field inventory units near old growth
patches will be implemented. See FEIS, old growth section.
The American and Crooked River Project was designed to avoid all direct harvest
impacts in old growth and replacement stands.
See response to 142. B.
OS 05 OS
C. BY AVOIDING HABITAT FRAGMENTATION TO COMPLY WITH MARTEN
HABITAT GUIDELINES
Because of the significant extent of logging and clearcutting proposed under the
project, the impacts of each alternative appear to be inadequately analyzed.
According to Forest Management Guidelines for the Provision of Marten Habitat
(Robert Watt, et al.), gaps of open habitat more than 1-2 kilometers should be
avoided. The project proposes a 34% clearcut. Habitat fragmentation and the
proven subsequent decline in pine marten populations appear to be inevitable under
the Proposed Action. (Preservation/Conservation Organization, Boise, ID -
#15.86.13100.330)
RESPONSE:
The impacts of each alternative on marten and their habitat have been discussed in
the FEIS, Chapter 3, Section 3.1 1. In addition, the cumulative effects section has
been updated.
The FEIS acknowledges effects of additional harvest and fragmentation effects on
pine marten habitats, but also the discussion cites work from Coffin, et al. 2002,
which indicates that despite heavily logged and roaded areas, pine marten can
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American River/Crooked River - Final Environmental Impact Statement
tolerate and remain in such areas (see FEIS, Section 3.11 - pine marten). The
analysis further discusses and assesses fragmentation effects and the impacts of the
activities.
(ff3(3S OS
D. BY DEMONSTRATING THAT TIMBER HARVEST ACTIVITIES ARE NOT IN
CONFLICT WITH ESA AND FOREST PLAN HABITAT PROTECTION
REQUIREMENTS FOR FISH
Given the above concerns, it is difficult to see how this project meets the ESA
regarding listed fish species. There is no solid evidence from monitoring that habitat
is recovering and no evidence at all that streams are now meeting forest plan stands
(see appendix A forest plan). /4s such, approval of the non restoration parts of the
project—logging and man-made building-are in conflict with the forest plan, the ESA,
and treaty obligations. (Preservation/Conservation Organization, Moscow, ID -
#22.30.10400.100)
RESPONSE:
Please refer to the FEIS Record of Decision, which includes the Biological
Evaluation for listed fish and wildlife. While current conditions of fish habitat are
below objective in project area streams, this project, as required under the Forest
Plan, is designed to improve these conditions (FEIS, Chapter 3, Section 3.2).
en as us <& us m
152. The Nez Perce National Forest should design this project such that best
available science for protecting sensitive species is acknowledged.
A. BY ADOPTING LANDSCAPE-SCALE MANAGEMENT CONCEPTS WITH
BUFFERS. RESERVES. AND CONNECTORS
State-of-the-art conservation biology and the principles that underlie the agency's
policy of "ecosystem management" dictate an increasing focus on the landscape-
scale concept and design of large biological reserves accompanied by buffer zones
and habitat connectors as the most effective (and perhaps only) way to preserve
wildlife diversity and viability (Woss, 7993;.
The FS has stated: "Well distributed habitat is the amount and location of required
habitat which assure that individuals from demes distributed throughout the
population's existing range, can interact. Habitat should be located so that genetic
exchange among all demes is possible." (Mealey 1983.) (Preservation/Conservation
Organization, Moscow, ID-#22.69.13100.330)
RESPONSE:
The FEIS used best available science and a landscape scale approach in the
analysis through reference to the South Fork Clearwater River Landscape
Assessment as well as consideration and referencing updated theories and
biodiversity studies pertaining to old growth (See FEIS discussion in Chapter 3,
Section 3.11). This discussion addresses ability of the habitat to facilitate genetic
exchange commensurate with historic landscape patterns and disturbance
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American River/Crooked River- Final Environmental Impact Statement
regimes. The discussion also highlights that connectedness must be balanced
with risks of natural disturbance events and must be considered when evaluating
long-term habitat integrity. Additional discussion on neotropical migrant birds
and their habitats is in the FEIS, Chapter 3, Section 3.11. For additional
discussion by old growth indicator species, see FEIS, Chapter 3, Section 3.1 1.
B. BY CONDUCTING MONITORING AND POPULATION VARIABILITY ANALYSIS
FOR AREAS THAT MAY EXCEED THE SIZE OF THE PROJECT AREA
1 . The FS in this region has acknowledged that viability is not merely a project area
consideration, that the scale of analysis must be broader:
Population viability analysis is not plausible or logical at the project level such as
the scale of the Dry Fork Vegetation and Recreation Restoration EA.
Distributions of common wildlife species as well as species at risk encompass
much larger areas than typical project areas and in most cases larger than
National Forest boundaries. No wildlife species that presently occupy the project
area are at such low numbers that potential effects to individuals would
jeopardize species viability. No actions proposed under the preferred alternative
would conceivably lead to loss of population viability. (Lewis and Clark NF, Dry
Fork EA Appendix D at p. 9.) (Preservation/Conservation Organization, Moscow,
ID -#22.69.13100.330)
RESPONSE:
The viability discussion for various wildlife species has been revised and
improved (see wildlife section 3.1 1), as well as Appendix J.
The analysis of effects and species viability discussions for various wildlife
species included in the American and Crooked River project looked beyond
the project level. The majority of the wildlife analysis for this project
encompassed the entire 5th code watersheds associated with this project
(American and Crooked Rivers). Wildlife information related to the amount of
existing habitat potentially available for certain sensitive and management
indicator species was modeled using the Northern Region Vegetation
Mapping Project dataset (R1-VMP) to describe abundance and distribution of
wildlife habitat for American and Crooked River drainages. This information
can be found in Chapter 3, wildlife section, of the FEIS. The Nez Perce
National Forest also used the 2000-2002 Forest Inventory and Analysis (FIA)
survey dataset to ascertain the abundance and distribution of certain wildlife,
old growth and snag habitats at various scales: watershed (5th Hydrologic
Unit Code - HUC), subbasin (4th HUC), and forest-wide. A revised viability
analysis can be found in Appendix J of the FEIS, which incorporates both
R1vmp and the FIA data. Additional information regarding species viability
can also be found in the project file, which incorporates results of the Forest's
monitoring efforts since the Forest Plan was signed in 1987.
c#o#e*
2. The DEIS should have firmly established that the species that exist, or historically
are believed to have been present in the analysis area are still part of viable
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American River/Crooked River- Final Environmental Impact Statement
populations. Since Forest Plan monitoring efforts have failed in this regard, it
must be a priority for project analyses. Yet, the project analysis relies on this
inadequate and/or unavailable forest plan monitoring. Identification of viable
populations is something that must be done at a specific geographic scale. The
analysis must cover a large enough area to include a cumulative effects analysis
area that would include truly viable populations. Analysis must identify viable
populations of MIS, TES, at-risk, focal, and demand species of which the
individuals in the analysis area are members in order to sustain viable
populations. (Preservation/Conservation Organization, Moscow, ID -
#22.70.13100.340)
RESPONSE:
The complete summary record of our Forest Plan monitoring of MIS and TES
species results is located in and supports the terrestrial species viability analysis
document in the American & Crooked River Project File titled: "Habitat-Based
Terrestrial Vertebrate Populations Viability Related to the American and Crooked
River Project" (USDA FS, 2004a), available in the project files. This species
viability analysis incorporates both habitat and population data and is more than
simply a "proxy on proxy" approach.
CSCtfCS
C. BY CONDUCTING OLD GROWTH ANALYSIS THAT IS CONSISTENT WITH
HABITAT ANALYSIS
The old growth analysis is inconsistent with the analyses for various species
dependent on old growth habitats. The DEIS maintains that no old growth would be
affected by any alternative. However, habitat for old growth species would be
affected. (Preservation/Conservation Organization, Moscow, ID - #22.71.13100.365)
RESPONSE:
The American and Crooked River Project was designed to avoid all direct harvest
impacts on old growth and Forest Plan minimum replacement stands. While no
direct effects are realized, NEPA requires that indirect as well as cumulative
effects be disclosed. These disclosures by species are related in the FEIS,
Chapter 3, Section 3.11. Related discussion on Neotropical migrant birds and
their habitats is in the FEIS, Chapter 3, Section 3.11.
us c# ea c« en ca
153. The Nez Perce National Forest should evaluate the impacts of the project
on management indicator species.
Additional issues of concern include evaluation of the impacts of the project on
management indicator species and the impact of this project on the long term viability of
species. (Preservation/Conservation Organization, Boise, ID-#15.146.32.100.340)
RESPONSE:
MIS impacts evaluations are discussed in Chapter 3 of the FEIS in the wildlife and
fisheries section. Long-term viability of these species was summarized in the FEIS
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and Appendix J, and the complete analysis for wildlife is available in the project file
titled: "Habitat-based Terrestrial Vertebrate Populations Viability Related to The
American and Crooked River Project" (USDA FS, 2004a). This analysis incorporates
both habitat data as well as MIS populations monitoring results since the Forest Plan
was signed. It is more than simply a "proxy on proxy" approach.
The Fisheries section (3.3) of the FEIS provides a summary of the status and trends
for management indicator species (MIS) as well as a discussion of population
viability. The complete analysis is contained in the project record.
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American River/Crooked River - Final Environmental Impact Statement
SECTION 11 - SOCIOECONOMIC
156. THE NEZ PERCE NATIONAL FOREST SHOULD WORK WITH INDUSTRIES OTHER
THAN THE TIMBER INDUSTRY.
FOR TOURISM
We could have more tourists than Colorado has in 20 years if our State and your
department could work in harmony with an industry other than timber. My industry is
real estate and I support the forest plan put forth by Friends of the Clearwater. Your
decision concerning the fate of forests within our beloved State of Idaho will impact me
for the rest of my life. (Individual, Moscow, ID - #21.3.34000.810)
RESPONSE: Comment Acknowledged
US C9 08 C* C* 03
157. (old 158.) The Final EIS should be comprehensive in explaining the
economics of the American and Crooked River Project.
A. BY CLARIFYING WHAT " ECONOMIC OBJECTIVE" REFERS TO, FROM PAGE 20 OF THE DEIS.
" ENTRY INTO MIXED CONIFER STANDS is INCLUDED TO MEET THE ECONOMIC OBJECTIVE."
At page 20, the DEIS states, "Entry into mixed conifer stands is included to meet the
economic objective." Please clarify which objective this is referring to, as no
economic objective is provided at page 10, where project objectives are disclosed.
Further, because no economic objective is given at page 10, this alternative falls
outside the scope of this analysis. If an economic objective is part of the purpose
and need of this project, the proposal must be re-scoped.
(Preservation/Conservation Organization, Boise, ID-#15.22.21100.800)
RESPONSE:
The project objectives are discussed in the Purpose and Need For Action Section on
page 2 of the FEIS. The first paragraph of the section defines one purpose of the
project to "contribute to the economic and social well-being of people who use and
reside within the surrounding area." By entering (treating) mixed conifer stands,
additional economic gains can be gained.
C8C8 O*
B. BY EXAMINING THE ECONOMIC EFFECTS OF A RESTORATION ALTERNATIVE
REHABILITATING THESE WATERSHEDS SO THEY MEET BENEFICIAL USES
Any work performed in this watershed will have difficulty paying for itself given the
low value of the timber and the high operating costs necessary to mitigate for
previous legacy problem. The FEIS should examine the economic effects of a
restoration alternative rehabilitating these watersheds so they meet beneficial uses.
Healthy watersheds would improve fisheries and benefit outfitters, guides, and
supporting recreational industries. One need only examine the name of the
drainage, the Clearwater, to remind oneself of what is possible.
(Preservation/Conservation Organization, Boise, ID-#15.142.21100.800)
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RESPONSE:
A restoration alternative was considered and eliminated from detailed study because
it does not respond to the purpose and need. (FEIS chapter 2)
0*0*0*
C. BY DISCUSSING THE IMPACT OF THE UPSWING IN THE TIMBER MARKET. AND IT'S
POTENTIAL IMPACT ON PROPOSED RESTORATION WORK
The FEIS should discuss the impact of the upswing in the timber market, and the
potential impact on proposed restoration work. At the time of the project's
conception, timber prices were extremely low and may have led to limited planning
for restoration. With an ensuing rebound in timber prices, additional restoration may
be feasible. (Preservation/Conservation Organization, Boise, ID
#15.140.21100.820)
RESPONSE:
The economic analysis in Chapter 3 is intended to be used as an indicator of value
and costs. The true value received can only occur when a timber sale is sold. The
economic analysis displays the values and costs available at the time of printing and
have been updated from what was displayed in the DEIS.
0*0* OS
D. BY FACTORING IN THE COSTS TO RETURN THE WATERSHED TO A CONDITION SUPPORTING
BENEFICIAL USES FOR EACH ALTERNATIVE
In addition to analyzing the economic costs and benefits of each alternative in terms
of expected timber yield, benefits, and harvest costs, the FEIS must factor in the
costs to return the watershed to a condition supporting beneficial uses for each
alternative. The FEIS needs to factor in the costs of decommissioning all high-risk
roads, rehabilitating degraded areas, losses in the recreation industry resulting from
decreased and low-level fish production. The FEIS also must address the costs
associated with preparing the EIS, administering the sale and other administrative
costs associated with the planning and preparation of the project. Please include all
costs associated with this sale in the FEIS. (Preservation/Conservation
Organization, Boise, ID-#15.139.21100.830)
RESPONSE:
The alternative tables, displaying the projected revenue and cost of implementation,
in Chapter 3, Section 3.12, do incorporate the direct costs of road decommissioning
and rehabilitating degraded areas (mine sites, soil restoration, etc.) The indirect
effects analysis discusses recreation activity, and an increase in anadromous fish
habitat improvement. The costs associated with planning, preparing, and
administering the project are normally not included in economic analyses.
0*0*0*
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E. BY DISCUSSING THE USE OF OFF-BUDGET FUNDS
The FEIS should also discuss the use of off-budget funds (i.e. KV, BD, Roads and
Trails, etc) in the accomplishment of various components of this proposal.
(Preservation/Conservation Organization, Boise, ID-#15.141.21100.835)
RESPONSE:
The alternative tables, displaying the projected revenue and cost of implementation,
in Chapter 3, Section 3.12, display KV and BD costs. The KV costs are displayed as
reforestation line items. The BD costs are displayed as line items for broadcast
burning, underburning, and excavator pile and burning. The restoration work and
costs associated are also displayed in the tables. How this work is to be funded is to
be determined.
OJ03CS
F. BY INCLUDING THE LONG-TERM OUTLOOK FOR THE PROJECT AREA IN THE ECONOMIC
ANALYSIS
Following implementation of the project, it should be expected that dense thickets of
Lodgepole Pine would regenerate in the logged areas. In the course of 80 years,
this will result in beetle-susceptible stands and if current ideology continues to plague
the Forest Service, this will necessitate identical treatments at that time. This is the
long-term outlook for the project area, based on the likely scenario. This sequence
of events should be considered in the FEIS analysis, and particularly in the economic
analysis. (Preservation/Conservation Organization, Boise, ID - #15.110.21100.820)
RESPONSE:
The scenario described in the comment is an accurate description of the expected
life cycle of Lodgepole pine habitat. However, it would be highly speculative to
include in a current economic analysis, a similar treatment with similar costs what
would be done eighty years from now.
c& ea oa o* ea ea
SECTION 12 - WILDERNESS AND ROADLESS AREAS
ROADLESS AND WILDERNESS AREAS GENERAL
158. THE NEZ PERCE NATIONAL FOREST SHOULD PROTECT LANDS DESIGNATED AS
WILDERNESS OR ROADLESS.
A. BY NOT HARVESTING TIMBER IN ROADLESS AREAS
The merits of protecting roadless lands are many, and crossing the line to log in
roadless lands would set a terrible precedent. (Individual, Seattle, WA -
#8.3.62100.002)
RESPONSE: Comment acknowledged.
cs ose»
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B. BY MAINTAINING THE MEADOW CREEK AREA AS INVENTORIED ROADLESS LAND
Not surprisingly, the DEIS claims the SFLA's identification of inventoried roadless
areas has been rescinded and was under different parameters. This is a transparent
attempt to surreptitiously eliminate acreage from the Meadow Creek roadless area.
When was this rescinded and how was it done? (Preservation/Conservation
Organization, Moscow, ID-#22.76.62110.621)
RESPONSE:
The West Meadow Creek Inventoried Roadless Area was defined in the Forest Plan
and this boundary was used in this document. This is the only official boundary of
that Inventoried Roadless Area. The roadless area that is depicted in the SFLA was
an inventory of lands that met Regional protocols for roadless areas and this
boundary will be assessed during the Forest Plan Revision process.
03 0* (19 0# 05 <&
159. The Nez Perce National Forest should consider reducing limitations to
operate in roadless lands.
TO PROVIDE ACCESS TO TREAT AREAS IN NEED
Roadless- there are significant amount of roadless areas in and adjacent to the project.
We are always concerned that limitation to operating both there and in currently
unroaded areas limits access and treatment of areas in need, and authorized by the
1987 Forest Plan. (TimberAVood Products Industry, Kamiah, ID - #5.10.62100.410)
RESPONSE: Comment acknowledged.
c« cs <& us ea os
160. The Nez Perce National Forest should consider potential conflicts and
access limitations associated with roadless policy.
When [roadless areas limit access] conflict arises [and] it should be highlighted for the
public, and risk clearly explained to higher authorities. Often roadless policy limits the
best economical and environmental access options. (Timber/Wood Products Industry,
Kamiah, ID - #5.11.12100.410)
RESPONSE: Comment acknowledged.
vs oa os c# os c*
161. The Nez Perce National Forest should accurately map and draw inventoried
roadless area boundaries.
TO INCLUDE AND SHOW THE PROPER BOUNDARIES OF THE MEADOW CREEK ROADLESS AREA
TO AVOID THE APPEARANCE OF LEGAL AND ETHICAL PROBLEMS IN THE MAPPING AND
INVENTORYING OF ROADLESS AREAS
The DEIS claims no activities are planned for inventoried roadless areas (IRAs).
However, that assumes, among others, two important points. The first is there is a
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American River/Crooked River- Final Environmental Impact Statement
consistent map showing the IRA boundaries. The second is that the IRA boundaries
were drawn correctly. Neither is accurate.
With regard to the Meadow Creek roadless area, there are two maps that show an IRA
boundary. The first is the forest plan map from 1987. The second is the one in the
SFLA (see map 27, SFLA, Volume II. Since this is an agency document we assume you
have a copy of it. If not, we can send you a color copy of the map). The SFLA map
shows land between Box Sing Creek just past Kirks Fork as inventoried roadless all the
way to the BLM boundary, land in the East Fork of the American River all the way to the
boundary with BLM, and some land at the head of the Flint Creek drainage that is part of
the Meadow Creek IRA. It is quite clear, from our on-the-ground knowledge of the area,
observation of aerial photos, and the DEIS itself that areas that this area is, in fact,
roadless.
Map 11 a in the DEIS makes this point. We will comment on the adequacy of this map
later.
What is important is that the SFLA map shows this area to be inventoried. Furthermore,
this area should be in the inventory and its exclusion indicates ethical and perhaps legal
problems with the mapping and inventories. The SFLA was an honest attempt to reflect
the inventoried roadless boundaries. (Preservation/Conservation Organization, Moscow,
ID-#22.75.40220.621)
RESPONSE:
The inventoried roadless areas (IRAs) for the Nez Perce National Forest were
mapped during development of the Forest Plan. They are displayed in the Nez
Perce National Forest FEIS, Appendix C. No harvest or road building is proposed in
the American and Crooked Rivers Project within these IRAs.
The IRAs in the vicinity of the American and Crooked Rivers Project Area are
displayed in maps 11 a and 11b of the FEIS. The IRA boundaries used in these
maps have been redrawn at a larger scale than that displayed in the Nez Perce
National Forest Plan FEIS Appendix C but represent the same areas as closely as
we can interpret from the small scale maps in the Forest Plan FEIS, Appendix C.
In 1998, the Nez Perce National Forest published the South Fork Clearwater River
Landscape Assessment (SFLA). This document is not a decision document, but an
assessment designed to frame issues and display information to be used during
forest plan revision. As part of that analysis, a preliminary remapping of roadless
areas was conducted using the region's "Roadless Area Inventory Protocol" from
1996. The result of that remapping effort was displayed in maps 3 and 27 of the
SFLA. These maps show the starting point for a reinventory of roadless areas for
consideration during forest plan revision and were not a decision to change IRA
boundaries. The forest plan revision team is currently using the same protocol to
reinventory current Inventoried Roadless Areas and other areas with possible
roadless characteristics to create a new inventory of Inventoried Roadless Areas for
analysis during forest plan revision. They are not using the precise areas displayed
in the SFLA. The areas mapped using this protocol during forest plan revision will be
evaluated for wilderness designation and possible roadless area management in the
revised forest plan.
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The SFLA did not change the IRAs. It was a first step to a re-inventory of roadless
areas to be analyzed during forest plan revision. The effects to IRAs addressed in
the American and Crooked Rivers Project are those to the IRAs defined in the Forest
Plan FEIS, Appendix C. The analysis of affects to these IRAs and other areas with
possible unroaded characteristics has been supplemented in the FEIS. That
reanalysis can be found in Section 3.13. Wilderness, Inventoried Roadless Areas,
and Areas with Possible Unroaded Characteristics in the FEIS.
See response to comment #21.
Ctf VS US (X OS
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American River/Crooked River- Final Environmental Impact Statement
affecting roadless values, and then claim in the forest plan revision those areas are
not longer suitable for wilderness and drop them from the roadless inventory. Thus,
the decision to destroy wilderness character would never have been analyzed and
the "discovery" of the unsuitability of the area only made after the fact. That is
contrary to NEPA, NFMA, and above all, a sense of public trust and integrity that the
agency is supposed to have. (Preservation/Conservation Organization, Moscow, ID
-#22.83.13100.621)
RESPONSE:
No part of this project occurs in the any Inventoried Roadless Area and in
particular, no part of this project occurs in the West Meadow Creek Inventoried
Roadless Area. In addition, see response to comment 161 and response to
comment 21.
0*0* C8
B. BY ACKNOWLEDGING THE GOALS OF EXISTING FOREST PLANS TO PROTECT SENSITIVE
HABITAT
This roadless area provides diversity and quality of habitat for fish - a primary goal of
your own NP Forest Plan. It also provides habitat that contributes to the recovery of
Threatened and Endangered Species - yet another goal in the NP Forest Plan.
Please uphold your own Forest Plan and do what is right for the ecology of this
roadless landscape by considering and selecting an alternative that meets these
goals. (Individual, Moscow, ID - #9.2.10400.002)
RESPONSE:
There are not specific Forest Plan Standards for Roadless Areas in the Nez Perce
Forest Plan. This project was designed to meet or exceed Forest Plan Standards.
Please see the Wilderness, Inventoried Roadless Areas, and Unroaded Area section
of the Document in Chapter three for an analysis of the impacts to Roadless Areas.
O* 03 O* O* (S3 O*
165. The Nez Perce National Forest should comply with guidelines and
regulations for analyzing impacts to roadless areas.
A. SUCH AS CONGRESSIONAL DIRECTION
The agency has clear guidelines on which to analyze and inventory roadless areas
developed in RARE II and the initial rounds of forest plans. These include direction
from congress in evaluating wilderness potential through legislation and various
reports. In essence, it is the physical impacts of roads (real roads, not ways or jeep
trail), logging or other intensive development (with some exceptions for long-past
development) that removes areas from roadless inventories.
(Preservation/Conservation Organization, Moscow, ID - #22.84.10400.610)
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American River/Crooked River- Final Environmental Impact Statement
RESPONSE:
Roadless area inventory has been conducted and is used in the Forest Planning
process. See the FEIS Wilderness, Inventoried Roadless Area, and Unroaded Area
section in Chapter 3 for effects to roadless areas.
B. SUCH AS REGULATORY TRIGGERS TO DOCUMENT IMPACTS FROM TIMBER HARVESTS IN AN
EIS
The agency's own regulations note that "harvesting timber" in a roadless area
triggers the necessity to prepare an EIS, even Wit is "in only one part of the roadless
area.' (Federal Register Vol. 57 No. 152, September 18, 1992. page 43200, FSH
1909. 15 Chapter 20.6(3)). While the preparation of an EIS is not the issue here, the
point is logging significantly affects the undeveloped nature of a roadless area.
(Preservation/Conservation Organization, Moscow, ID - #22.79.10400.621)
RESPONSE:
There are not specific Forest Plan Standards for Roadless Areas in the Nez Perce
Forest Plan (USDA FS, 1987a), but all other Forest Plan Standards must be met in
these areas. This project was designed to meet or exceed Forest Plan Standards,
including those specific to fish and other threatened and endangered species. No
activities associated with this project are proposed in the Meadow Creek Inventories
Roadless Area. Please see Section 3.13. - Wilderness, Inventoried Roadless Areas,
and Unroaded Area in Chapter 3 of the Final Environmental Impact Statement for an
analysis of the impacts to Roadless Areas.
C. SUCH AS APPROVED RECOVERY PLANS AND PENDING ROADLESS MANDATES IN
CONGRESS
Your responsibilities are to maintain the integrity of those national forests and
watersheds in your area. There are many approved recovery plans for areas already
damaged. As to the damaged South Fork Clearwater watershed, I urge you to
adhere to the roadless mandate now threatened in the US congress and to resist the
pressures for logging. I believe you are obliged to analyze current pressures and to
avoid further depletions of national forests and watersheds. (Individual, New York,
NY -#29.1. 10400.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Please see the
Wilderness, Inventoried Roadless Area, and Unroaded Area section in Chapter 3 of
this FEIS for effects to roadless areas.
O5CSO8
D. BY ADOPTING A DEFINITION OF 'IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF
RESOURCES' IN ROADLESS AREAS THAT IS CONSISTENT WITH COURT DECISIONS
The DEIS claims that there are no irreversible and irretrievable commitments of
roadless resources under any alternative in spite of the fact roadless land will be
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American River/Crooked River - Final Environmental Impact Statement
logged under the action alternatives except E. The excuse is the impacts would be
temporary.
The courts are clear even though this DEIS ignores the law. A decision to log a
roadless area is "environmentally significant" [Smith v. US Forest Service No. 93-
36187 (9th Cir. Aug. 22, 1994)] and "the decision to harvest timber on a previously
undeveloped tract of land is "an irreversible and irretrievable decision' which could
have 'serious environmental consequences." [National Audubon Society et al v. US
Forest Service 4 F. 3d 832(9th Cir. 1993)].
Such an absurd analysis of irreversible and irretrievable commitment of resources in
the DEIS turns NEPA on its head. To be consistent with this ridiculous roadless
analysis, the DEIS should declare no irreversible or irretrievable loss of soils from the
Mazama eruptions of 6,700 years ago because, at some future date, Mt. Hood, the
Three Sisters, Rainier, Mt. Adams, or some other volcano in the Cascades will erupt
and redeposit a soil ash cap. (Preservation/Conservation Organization, Moscow, ID
-#22.80.13100.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Please see the
Wilderness, Inventoried Roadless Area, and Unroaded Area section in Chapter 3 of
this FEIS for effects to roadless areas.
cacao*
E. BY CONDUCTING SITE-SPECIFIC EIS ANALYSIS FOR DEVELOPMENT IN ROADLESS AREAS
The DEIS erroneously defers evaluation of the loss of potential wilderness from
development of roadless areas. It is the Forest Service itself that set up the policy of
site-specific EISs on development of roadless area in the agency appeal decisions
and subsequent court decisions on the Idaho Panhandle and Flathead National
Forests. In the court decision on the IPNF Forest Ran appeal, the judge concurred
with the agency's argument that EISs would be prepared on development activities in
roadless areas:" . . . any future development which might take place (in roadless
areas) will again be determined by the Forest Service and will be subject to the
requirements of NEPA." [Idaho Conservation League v. Mumma 21 E.L.R.
20666,206668 (D. Mont 1990) upheld on appeal].
The above referenced case is the result of a challenge to the forest plan's
analysis/evaluation/allocation of roadless areas. The court determined that it was
the site-specific decision, not the forest plan, that analyzed the impacts of
development on the roadless area and was, hence, the background document for a
decision on the fate of roadless areas (Preservation/Conservation Organization,
Moscow, ID-#22.81.13100.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Please see the
Wilderness, Inventoried Roadless Area, and Unroaded Area section in Chapter 3 of
this FEIS for effects to roadless areas.
(^
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American River/Crooked River- Final Environmental Impact Statement
166. The Nez Perce National Forest should not harvest timber in roadless areas.
Regarding the proposal to log in the basins of the American and Crooked Rivers -1 am
strongly opposed to any logging in roadless lands. (Individual, Seattle, WA -
#8.1.34000.621)
A. BECAUSE OF PLANNING AND THE FOREST SERVICE LAND ASSESSMENT
The Forest Service's own land assessment indicated there should not be logging or
road building in the Meadow Creek Roadless Area. (Individual, Coeur D Alene, ID -
#11.4.34000.621)
There should be no logging or road building in the Meadow Creek Inventoried
Roadless Area as per the Forest Service's own landscape assessment.
The cumulative impacts of this timber sale plus the Whiskey South, Meadow Face,
Red Pines, Blacktail Butte, and Eastside Township timber sales must be considered.
(Individual, San Francisco, CA - #31.2.34000.621)
Please amend your plan to exclude logging where roadless areas are involved.
(Individual, Seattle, WA-#8.4.34000.621)
RESPONSE:
No treatment is proposed in the West Meadow Creek inventoried Roadless Area.
Please see the Wilderness, Inventoried Roadless Areas, and Unroaded Area section
in Chapter 3 of this FEIS for effects to roadless areas.
CJCSOS
B. BECAUSE IT AFFECTS CLEAN AIR AND WATER
There are resources of clean air and water that are protected when roadless forest is
preserved. The damage done by logging in these areas has been researched and
recorded. (Individual, Laguna Beach, CA - #20.2.34000.220)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Please see the
Wilderness, Inventoried Roadless Areas, and Unroaded Area section in Chapter 3 of
this FEIS for effects to roadless areas.
o#o« cs
C. BECAUSE MEADOW CREEK is A ROADLESS AREA
There should be no logging or road building in the Meadow Creek inventoried
roadless area. Idaho does not need more roads. Why destroy our forests for greed.
(Individual, Moscow, ID-#4.1.34000.621)
RESPONSE:
No treatment is proposed in the West Meadow Creek Inventoried Roadless Areas.
Please see the Wilderness, Inventoried Roadless Areas, and Unroaded Area section
in Chapter 3 of this FEIS for effects to roadless areas.
08O808
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American River/Crooked River- Final Environmental Impact Statement
D. BECAUSE THE AREA MAY NOT HAVE BEEN INCLUDED IN PAST ROADLESS INVENTORIES
With the current uncertainty surrounding the status of roadless areas, we encourage
you to avoid logging in any unroaded areas, which may or may not have been
included in inventories in the past (see South Fork Clearwater River Landscape
Assessment).
These areas provide many benefits to wildlife and forest health through their diversity
of plant life and tree variability, whether or not they are inventoried by the Forest
Service or not. (Preservation/Conservation Organization, Boise, ID -
#15.136.34000.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Previous inventories were
conducted to determine if areas have suitability for future Congressional designation
as Wilderness. These areas are identified as Inventoried Roadless Areas. There
are protocols that are used to determine whether or not the area is suitable. The
West Meadow Creek Inventoried Roadless Area (#1845C) and the Dixie Summit-Nut
Hill Inventoried Roadless Area (#1235) were identified as not suitable for Wilderness
based on the inventory criteria. Please see the Wilderness, Inventoried Roadless
Areas, and Unroaded Area section in Chapter 3 of this FEIS for effects to roadless
areas.
(J303U3
E. BECAUSE USING INSECT INFESTATION AND FIRE DANGER AS A JUSTIFICATION is
CONTRADICTORY
These forests exist in natural insect and fire regimes, which select for trees resistant
to both natural forces. Using insect infestation and fire safety as justifications for
entering these areas is contradictory, since logging will increase the fire danger
through subsequent soil and slash drying, as well as high grade the most disease-
resistant trees in indiscriminate clear cutting. This squandering of natural capital for
an essentially one-time harvest is characteristic of timber mining, not responsible
forestry.
I would like to receive any scooping information on this project, and the draft and
final EIS or EA. (Individual, Minneapolis, MN - #32.3.34000.822)
RESPONSE:
Treated areas would have short term increase in fire hazard as stated in Chapter
3, Section 3.4. - Fire in the FEIS, due to the logging slash, but this short term
hazard will be abated as the prescribed burning is completed and the fuel loads
lowered.
The same process of soil drying and slash accumulating is effectively taking
place in the stands that are infested with the Mountain Pine Beetles. As trees
are killed and the canopies opened more sunlight and wind is allowed to reach
the surface to warm the soil and slash. Additionally as the trees loose their
branches and/or fall over the fuel loadings are increasing to the levels of a post
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American River/Crooked River - Final Environmental Impact Statement
harvest fuel model. These areas if not treated will also increase the fire hazard
within these stands.
The difference between this process happening naturally and through treatment is
that in the natural scenario this fire hazard will remain high for a much longer time.
Also in the natural scenario there will be no places that will modify the fire behavior
and allow for suppression actions to be safely initiated as there would be under the
proposed action.
as <& e# o# e# o#
167. The Nez Perce National Forest should not harvest timber in backcountry
areas.
Why would anyone even propose to log (aka thin or mechanically remove fuels) in the
backcountry in an attempt to reduce wildfires? As a logging engineer by education, I can
say without a doubt that thinning is logging, mechanical fuels reduction is logging, and
salvage is logging. Any time a tree (dead or alive) is felled, skidded, cut into logs,
loaded, and hauled on a truck, it is logging. Whether it is small trees or large trees,
burned trees or green trees, it makes no difference. I realize euphemistically, the Forest
Service prefers to use the term "timber harvest" and "mechanical removal" rather than
logging. (Individual, Grangeville, ID-#30.1.34000.720)
RESPONSE: Comment acknowledged
as o# oa e# c# us
Roadless Areas and Wilderness Characteristics
168. Th.e Nez Perce National Forest should conduct an analysis of the impacts
of timber harvesting on roadless and wilderness character.
A. It doesn't matter that the impacts are termed temporary; any impact can be
considered temporary. The lack of analysis of the impacts of logging and other
development on the wild and wilderness character of the roadless area and the
absence of a specific time frame for recovery proves these are no mere temporary
impacts, particularly in the precise NEPA definition of temporary.
Furthermore, the agency itself maintains logging and road building alters roadless
areas and wilderness character. That is why there is a difference between roaded
and roadless areas in agency policy. (Preservation/Conservation Organization,
Moscow, ID-#22.87.30300.621)
Past case law is clear: EIS's are needed for roadless area development An EIS must
be prepared to take a "hard look" at the cumulative impacts of allowing logging in
these roadless areas, (see Kleppe v. Sierra Club 427 U.S., 390, California v. Block
and Save the Yaak Committee v. Block 840 E 2d)
The cumulative effects analysis in the DEIS is no real analysis. There is no
quantification of the impacts to roadless areas in terms of integrity, size, naturalness,
wildness, or other roadless values. All the narrative provides is that unroaded areas
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(no site-specifics are mentioned) will only be temporarily affected. No site- specific
acreage numbers or locations are given, just a mention of "various intensities."
In essence, the site-specific and cumulative effects analysis does not enlighten us on
the impacts to roadless areas. (Preservation/Conservation Organization, Moscow,
ID-#22.85.30310.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas or in Wilderness. Please
see the Wilderness, Inventoried Roadless Areas, and Unroaded Area section in
Chapter 3 of this FEIS.
csoscs
B. TO CONDUCT SITE SPECIFIC IMPACTS TO ROADLESS AREAS
What the agency is attempting to do is very deceitful. It is required to analyze the
site-specific impacts to roadless areas. The DEIS claims that the analysis of
development and what it might mean for the wilderness suitability of the roadless
areas will be deferred in a different context. That is just opposite of what the law
requires (NOTE: NFMA requires a programmatic roadless area analysis at each
forest plan revision to look at wilderness potential and make recommendations in the
plan, but the impacts from roadless area development must be analyzed at the site-
specific level). (Preservation/Conservation Organization, Moscow, ID -
#22.82.30300.621)
RESPONSE:
No treatment is proposed in inventoried Roadless Areas. Please see the
Wilderness, Inventoried Roadless Areas, and Unroaded Area section in Chapter 3 of
the FEIS for effects to roadless areas.
cs e* ej c«
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American River/Crooked River- Final Environmental Impact Statement
And to designate the Meadow Creek wilderness of 276,503 acres. (Individual,
Minneapolis, MN - #17.1.62200.200)
RESPONSE:
No additional wilderness designation has been recommended in the current Forest
Plan.
oaosc*
B. BECAUSE WILDERNESS is DISAPPEARING AND CANNOT BE VALUED IN DOLLARS
Wilderness is fast disappearing in the American west, and once gone, can never be
restored. The value of these pristine stretches cannot be measured in dollars.
(Individual, Laguna Beach, CA - #20.1.62200.711)
RESPONSE: Comment acknowledged.
e# cs
-------
SECTION 13 - COMMENTS FROM THE NEZ PERCE TRIBE
a 092
..-..".' .. OCi 292003...
NEZ PERCE NATIONAL FOREST
.>-••-.. QRANQeviLLH. IDAHO
TRIBAL EXECUTIVE COMMITTEE
.'P.O. BOXaOS ,- LAPWAI, IDAHp 83540' » (208) -M3-3259 •
Bm~ * -«-~ >»»» uA.ftvuuTe.Com&dtfM (NFIECX please accept this letter in
•. i^ns* to your September .17,2003 request'foE comments oritteproposed-Americm and ' •
ppoked Rcver Project' Tqbal staflf are famlliar.wim the project 'area, and attended a pre^copin«
field tour with Forest staff on August 28,2003, -. .-', ' ' '
TteNezPerce Tijbe is .sHi,ieouioi
aearwwer River, inclndjng Crooked and American Rivers. This area holds tremendous ctdtaral
significance for Ihe Ncz Perec Tribe. Despite' 4e recent history of mining, logging, and road
«nstructfcm!lkttiMUdt64iinimsliM^
centqTy,.salmon and steelhead dan.still be'foijad-ln t&se riyers. The Tribe has invested
cwisjAsable resources to restore and, we-hope,-iprotc^ ttie.natjvc fisheries iri-and-'downsfream
ftotntiw project artfa. 11ius,'aie Tribe takes« very keen interest in the Forest's proposed
'activities in tho South Fork Clearwater River. . ' . ' ' ' • . • .
1- Purpoge and ffcfl^ • • • ! ..• • ' ' ' '
• Ikeistited purpose and need of'file Americmand Crooked River Project is'to: (1) reduce
eMsting-and. potential forest .fuels, (2) create conditions tiat will contribute to sustaining long-
lived fire tolerant species, and'i(3) oontnbute to 4e economic and social .well being of people •
whpiiseandresidewitbmthiesiaroundingarea. The ifesPerce Tribe recommends fihat the
< i of this jn^Ject to inctade aggressive watershed
L salmonids/
Of dbieCconcem to the Tribe is thatthjs 'project appeal? t^-be designed whoUy from the
perspective of economies and industrial logging. 'During the field tour the Trib6 questioned why
. the Forest designed such a. narrow^propose and .need for a project in an area that so richly, jieeds a
gentler touch.. Tie porpose and need should not onty consist of "ecosystem heaWi" of the forest
system but thc'primary purpose of me project should inctade enhancement of critical salmonid
habitat '•".-..• • . . ' ' • . •
-------
American River/Crooked River- Final Environmental Impact Statement
.81003
' , " ' , " * * ' .•"*'"' . ' J • * * •'" ' • •"" *
yfteTHbGisnotoppos^^^^ .
Iftfl" ttt1 11* HA Oh 40 «*»Wl*^ At.* • . , ,. —•, * • > , .*" " f ' .
.. p'
to construct many miles of new road construction; to «ffl!zi.silvicul.fttfal prescnptions-that 1^
Wee clewcut logging, and to make multiple frictor cntriek acres, Bearty.40,000 awes. The Forest .
sea^risTcto^ « .
.-.•.." I ".'•.•'..'"'
.•
ifie^c^proixwestomidgatotherfSxte^floggii^toa^
quality fish babtet of fte aVca ttodugfi an iindisclosed toinbinktion of miUgatioa measures such
.
. tows to Shade streams. Chvcn Ae dinfinfahffll s^ste of cdstJngaquatio-conditic>ns.theTt£biJ^
teappoiwted that the Fonat is placjog a tower prior%.oi tkcse efforts, kathe^'ihatt putting
aggressive watershed ttetoratioQ efiforts as a central piiq>b$eandniedinthepi»nb^c^ of critical watpr.
' '
.
resources. .Ecosysteaa heahU necessarily'iodiid^ enhanccmcnt'of criticai aateonidliabitat The
V**™** ?*?"**** »*« watewbeds ii««*^y-ite^thefore^(i:e.mettw»and . "
, vegetatww) and the hydrologfc propel. Any "edosystemWth^Dioject should include
Crooked1 River watersheds. •
^
'
toa -8rc^^
:pj2h^^ spi^wseattdncedofaggre^e'wa^eyreatoratio^ Therefore, the
Fores^ should consider ahematives that take every oortiinir to naSr the i
AmerlcanaadCrooJcedRJvcr.
Cumulative effects of flus project must be
tfon wth^asl and foreseeable future actions, as well asictioos that haw
occurred m geograpaic proximiry to the proposed project: .
Appendix M
Page M-165
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American River/Crooked River - Final Environmental Impact Statement
141004
.3. . - Noxious Weeds
•As tribal staffrjoied dinfagthrfpnbKc field tarn; 4e.Th1)eiav«y'<»iu:ertiad about tiieinmact
tfajs project will have ooxwxkraa wwd Smukm in ^.project area, We Tribe questions the
F<>^'* past awl cun^swe^
loggirig projects, particularly Clcwcnts.- ^ming-fhe field.toiir, staff from die Forest indicated that
while -wpcds are a major concern in current fbrestiiftmagement, spbtted knapweed {$ naturalized
m thep^ect atro/Sudh^:stateaneots;cp|icen».tn^
to ag^essively treat or present flirflw inVaaiatt of IkaapweeA . How many acres of directwbed
management is.undcrtaleen eadi year on this feangei District? HM Tribe is veiy concerned '
aDOTtfiiewvalierai^tpaohtakmbyaieFoirertwitbttspe^
Proposes dreatmcit'Qfmoxio^ weed p(^afions ^ere feasHJlo/' Hawfeari
requires a calculus of some fand-r-wfaedier sometfu4g is fea^le or i»t^l depends tow hi^i
of % jjnority nonoua wi^.cuttaftment is to dwForept .If th* Forest deteanines thai it is not . .
feasible to remove raustiagpopuMoos-of weeds, exactly what steps wfllT» taken to see ithat
additional'poputefioiis are not created with ftef.pioject area? . .'. .
4.'.
- The Tribe is also coocemed about the project' s-irapscts to sojl conditions.- Just'souai of the Nez
Pero'NationaiFflttestthe^yetteN^
ftom its tractor logging project*. /ThePayeae lias lfbflndthatmm(A cases studied, fljey were.
tinabte to meet Regional soil standards, la wfaay cases fli« detriiaeaital 'disturbance after brash
piliiigwas40%a^;bigneT^npre«^tw^^ The Tribe questions
whether the Nez Perec Natioaai Forest can do"bctter. . , .' • • • ' "
.5-. Water Yiei'dg ' ' . - '. , . • ' '• ' • - : '• .- '' ' '.'
B
-------
American River/Crooked River- Final Environmental Impact Statement
6- ' Prepare an BJS ' '' • ,•, ;': '."'..' •'•.'•'• "...-•''
As notad.«bove, the'.Tnbeis concerned with theFpresfs management philosophy of these ttro
important waterghedfr-nanifily that Jfaere is a ye^lUBTOWpuqKJSe and neodwhidi floes not
address flw Tribe's purpose and need of aggre^vo.waterBh^rtstoratum.- The Trifee 'welcomes-
fwther difiCBSsions on this pipint In themean tuoe^-'theKcz Perec Tribe'strongly encourages flic
Forest to analyze to propose^ action and a reasonable icange of alternatives through fat
pr^aratioa of an «ttvirc»inental impact Statement (EIS); • ' ' ' -
fffiPA requires {bat an acting agency prepare an-J5IS.for aU "major federal actions significantly .
affecting the quality of tte human eflvironrneat.'f 42 US.C. § 4332(2XQ. Prspararion of an BIS
in Sw American and Croofasd River Ihpqject woiflid serve two purposes; (1) to provide fcrest
m^agers witfc enough Jnfonnadpri to aid in the siibstanrivif decision whether to proceed with the
project in light of ^potential environmenfal consequences; and (2)'to provide the'publlc with
'
information wmcenungllie project, andan'cjpcitanrtytopafticirmteinrnega^eringof^
taformation. 40 OFJR. § 1502, 1; see oho Cfdifornla-v. Block, 690 f^d 753, 761 (9&'Ctr. IS
1982).
To determine wheflier the i project will have a significant impacti flbe'Forest must coaiidte the
context and intensity of te actions. 40 CLF.R. § 1508JZ7. CEQjcgutetions'fiirthcr define -
intensity as the severity of flwuhpact ••"''!. ' . ' . - •
sarie«
.'as\..w/<^ .
degree to- which flic possible effects on the human environment are/highly
.uncertain or involve unique or un^ewn-ri^ .me'degrec mat the action may set
, prec«lemrbT&raier.a<^onswim*gnfficantimp^
• action may afrenefy eflfca an endangered or threatened species or its habitat
that has .bcea determined critical • '• " .
40 CJ?JL § l!508^7j>>{«n5>h8sis added). -ReTiew. of m« America? and Crooked River
I^ectuidiiagicafly cr^ical spawhing^groiinds for
anadromous salrnonida species (L«.-sJeelhead toout and chmook sahnqn) hi'flie Soith
Fork qearwater/Riva- drainagis. The protection and enhancement of 'criticai habitat is
essential for, the salmon, w.hich are of ngnificant concern ibrflie Nez Perec Tribe and the
. people of tfK Northwest- Snake River steelheaddre listed as threatened under the- • '
Endangered Species Act (ESA). Tr^e.waferaheds also proyide'crifrcal habitat for .
wcstslope cutthroat trout and bull trout. The project will affect ecologically sensitive
a»as ia the Amerie*ri.and Crookad River watersheds that provide essential spawning
Appendix M
PageM-167
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American River/Crooked River- Final Environmental Impact Statement
grounds for native salmonid .species.','- '."'•.'..-• •' . - '"'•
'^M.to^^^
s of riparian areas and baniera, accumulation of silt in streams
croacm, ete.).tfaat may result in'the o^adation of critical fish habitat and water quality
Furflierdeadatioiiiofticsewaterrfw.is unacceptable dns'to their significsice in the'
b. UpiiTfly ftr TTi|||-r||«wn Rislcg''-' ' ••: •
recomaieDds.that :fte Forest Service Jaepafe an BIS to better understand the khmcdiiue
and cwrohavenslcs this.p»ject wiUhavc ori ifae^cal fishery habitat in tbcsc
'
Forest Service plans to utilize; to enhance- andprotect critical haSitaf 'An BS is also
u
^de^jBhRp^edentfcr.redm^gpubnXre^ewMidenvirciinie^ •
fiiture confiovwsijil-pwjects fiiat affect fbw-orMcaihabitet of salmotudspccies:'. By-not
prepannganEIS fteForest ^e^y^^sef^yKts^prc^^f^^pr^gEI
msitoabona classified astestoratioo e -
prepannganEIS fteForest ^e^y^^sef^yKts^prc
msitoabona classified as.testoratioaor ecosyflem heSltfa proj
S^^ ^JC? v"^11 *° ^.^^de^iwstoration
. .
S^^ ^JC? v"^11 *° ^.^^de^iwstoration or ecosysterVhealth project
.inpse ecosystem health projects do have significant efifecte.on the salmonid critical
hab^ andanElS is needed ^consider aH ajternativea.as wcU as public comments
cpnceaningdiJs project. : . • '''..••• • •
*• - - AdVBrae EfFects on Hndflnjfon^ or Threatened Specie?; .
co » ^etemwled by Wdflgreeto'^nichthe action pay adversely
C^t^B
ni
.Cb9). The iWKJbeHeyw that the Anwrican and Crooked River Projectwilf
nave a sigmficant effect on &e salmonid species and;SaImonid criticai haWtat-'-Snakc ' -
Appendix M
Page M-168
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American River/Crooked River- Final Environmental Impact Statement
' River steelhead are listed under die ESU. and'are.a-treatyrreserved,rcsource pf the Nez . •
Perce Tribe; Theri^X*eT^b«tofi^g^rirotectioaoftlics«^>ecieshaslc)ng .
been recpgoized by the United Statei. "Tie right'to resort to, ..fiahiog place?. ..was a
. part of laxger rights possessed by the Indians,-upon which there was^not'a shadow of ..
impediment..." tfttitedStates v. Wtnaw, 198 VS. 371,381 (1905). To protect the
Tribe's rights to this precious resource, it is essential that the Forest prepare artEIS that
thoroughly, considers .the adverse effects the project will likaly have on salrnomd species
and their critical habitat. Tbaa, tte'Tribe^tr^nglyreconmiends that ftc Forest Service
prepare an EIS. / • ', . ". •. ' ... .' . • >
,7. .. Clean Water j\ct . - ••.,••'.
Under the CJ6an Water Act,,thc South' Forlj.Clearwater River is a 303(d) listed .water
quality'limit^streom for sedimcmtidnaj^faanper^ • .
• issued, and calls for a 25% miictioa '(ffon'enstmg conditions) ui'sedirnent generated by
tuman aotiyity. While'tte dreft TMDL does not qjwntifyaediment reductions ia;tihe key.
tribiitanes, comiaoa sense dictates that'this is where the reductions must occur in order to
zneet.tiie'goals ofthc.TMDL. The TnTwikgestbc'Pprest to closely analyze the likely
sedimentRtion ef this project anil to lay put ».sttaiegy for how this project implements the
draft TMDL's-goal of a'^%iedac^oa in sclent,-particularly iali^ht of other present
and ongoing activities planned in the South Folk ClcarwaterRiver.
' : •"'.'-
8. Cumulative Effects, ' • ,' , • •'.'•':..•
'As noted throughout this conuneot letter toe Tribe is concerned with the project's likely
adverse effects to diminished fisheries and watershed cdnditionsr The American and ,
• (^ked'RivorP^ectujustoiicbffbw
ClewvatoRn^ Whisky Sou& The ; .
cumulative effects of Qua large1 scale timber iakvesV wifl' unquestionably have adverse
cumulative effects to aquatic integrity within the tributanesanddownstream to the Sootb ;
Fork Clear\yater River.-. The Forest must closely analyze .the cumulative effects of. each
oftnescand.o^herpa^i«*sent,reaso^ly6^ .
and federal agencies. Tbisaaaly^s'must alwuK:lnd« an .aquatics analysiis of pri^^
timber operations and-livestock grazing. . ' .•• • •'•' ' •
* - ' ' * " • • * '* • .' ,
Sincerely, .•'•••..'' ' ' • • -
. AmhonyTX Johnson
Cchairraan •
12)007
"•
Appendix M
Page M-169
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American River/Crooked River- Final Environmental Impact Statement
United Statet Forest Neat Perce National Forest Route 2, Bo* 475
Department of Servke GnutgevtUe, ED 83530
Agriculture 208 983-1950
208 983-2280 TTY
File Code: 1950-1
April 6,2004
Honorable Anthony Johnson, Chairman
Nez Perce Tribal Executive Committee
Box 305
Lapwai, ID 83540
Dear Chairman Johnson:
In the interest of govemment-to-govemment consultation and cooperation, this letter is intended to update
you on the progress being made with the Draft Environmental Impact Statement (DEIS) for the American
and Crooked River Project and to express my desire to engage in further coordination relative to the
project. The principal focus of this letter will be on the correspondence we received from you dated
October 29,2003 at the beginning of the project development.
First, I want to express my sincere appreciation for the involvement and communication from your staff,
particularly Ira Jones, Scott Althouse, Stephanie Bransford, and Dave Johnson. Their efforts have
increased our awareness and understanding of Tribal perspectives and concerns, particularly your deeply
held conviction to protect and restore the anadromons fish of the South Fork Clearwater River.
Background
Over the course of last summer and fall, field crews conducted surveys and investigations within and
surrounding the project area for the purpose of defining fish and wildlife habitat, watershed and
headwater conditions, culvert and stream crossing improvement needs on existing roads, vegetative
conditions and trends, cultural resources, sensitive plant locations and protection strategies, and weed
population locations and associated risks among many other things. Nez Perce Tribe crews, under the
supervision of Stephanie Bransford, conducted culvert surveys in Crooked River last summer, as well,
and furnished valuable information, which helped us identify watershed improvement opportunities.
Based on this information, the project area was defined and the nature and purpose of the project was
framed. Prior to developing the project proposal, the Forest invited Tribal representatives to take part in a
field review of the area to discuss issues and conditions leading to the need for a proposal. Mr. Jones and
Mr. Althouse participated. Shortly following the field trip, the proposed action was made available to the
Tribe for comment.
Since we received your comments on the initial proposal, our interdisciplinary team has been busy
considering your comments, in detail, while developing alternatives to the original proposal and analyzing
the effects of those alternatives. 1 believe I can now shed some light on how the project is progressing
with respect to the issues raised in your letter.
Purpose and Need and Range of Alternatives
The Forest Land and Resource Management.Plan provides the overarching management direction,
including standards and guidelines for achieving fish and water quality objectives. In addition, our
interest in respecting the Nez Perce Tribe's treaty rights, according to policies outlined in the Forest
Service Manual (FSM 1563), combined with Clean Water Act and Endangered Species Act
considerations would move this project to include a substantial component of water quality and fish
habitat improvement actions. We are proposing our action within this context. All action alternatives for
Caring for the Land and Serving People
Appendix M
PageM-170
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American River/Crooked River- Final Environmental Impact Statement
the American and Crooked River Project are being developed with restoration that would go beyond
merely maintaining existing water quality and fish habitat conditions. While the amount of restoration
and habitat improvement varies by alternative (some being more aggressive than others), each of the
restoration proposals would treat a range of factors that are currently limiting water quality and fish
habitat.
The interdisciplinary team was instructed to address the project objectives in a manner that would limit
risks to watershed and wildlife resources. Although the amount of management activity varies by
alternative, none of the alternatives being considered in detail in the DEIS would involve harvest units or
fuel treatment units within Riparian Habitat Conservation Areas (RHCA's) or high hazard landslide prone
areas. There is no permanent road construction proposed. There would be no harvest or road
construction planned within old growth areas or inventoried roadless areas. All roads would be temporary
and would be removed promptly following use on this project. Temporary road construction and removal
would occur as a condition of the implementing contracts associated with the project, i.e., the timber sale
and/or stewardship contracts. Temporary roads would be located to minimize effects on RHCA's and
would involve few, if any, live stream crossings.
I understand that these watersheds are vitally important to many people, and particularly important to the
Nez Pence Tribe and its members. While meeting project objectives, our intent is to respect treaty
resources and provide substantial opportunities for watershed and fish habitat restoration.
Noxious Weeds
Approximately 300 acres of priority weeds were treated on the Red River/ Elk City Ranger District during
Fiscal Year 2003. As you are aware, the Nez Perec National Forest is involved in a community-based
weed strategy for the Ciearwater River Basin. This community-based partnership has developed
objectives and priorities for weed management in the basin. The partnership includes local counties, state
and federal agencies and the Nez Perec Tribe. The Forest weed management program is integrated with
the Ciearwater Basin Weed Management Area focus. Neither the Ciearwater Basin Weed Management
Area Steering Committee nor the Nez Perce National Forest view spotted knapweed as naturalized in the
Ciearwater Basin. One of the priorities for tine South Fork Ciearwater River area is to eradicate satellite
infestations of invasive plants including knapweed.
The Forest is currently analyzing the project area in relation to invasive plants. This analysis includes
current infestation, habitat susceptibility, risk of spread, and mitigation measures for the project.
Soils
We share your concern for potential detrimental soil disturbance in this project. Since more than half of
the acres to be treated are on slopes less than thirty-five percent, and are planned for harvest and slash
disposal using ground-based equipment, care must be taken to design and administer these operations to
keep soil disturbance within the parameters identified in the Forest Plan. The interdisciplinary team has
been instructed to develop adequate measures and mitigation to protect the soil resource. These measures
will be identified and analyzed in the DEIS, as part of the restoration package. In addition, the DEIS will
analyze options, as part of the restoration package, to restore soils that may remain in a detrimentally
disturbed condition from past activities.
Water Yield
The American and Crooked River watersheds comprise approximately 104,000 acres, total. This project
proposes to create clearcut-type openings on between 600-1200 acres, depending upon the alternatives
being considered. This is a very small percentage of the watershed acres. There would be an additional
1000-1800 acres of partial canopy removal. We consider water yield at a variety of scales. Our initial
review indicates the proposed activities will be below thresholds of concern, overall, within the two
Appendix M
PageM-171
-------
American River/Crooked River- Final Environmental Impact Statement
watersheds regarding timing and quantities of water flow. We are assessing the potential for exceeding
any thresholds of concern at the sub-watershed level (Forest Plan Prescription Watersheds), as well,
including cumulative effects with other planned actions in the area. The interdisciplinary team is
considering the existing stand conditions, including previously harvested areas, in making their analysis
of water yield.
Preparation of an EIS
The American and Crooked River watersheds are important for their high values to anadromous and
resident fish, as well as other wildlife species. Considering the rationale you presented in your letter in
addition to comments received by others, the Forest is preparing an Environmental Impact Statement for
the American and Crooked River Project.
Clean Water Act
The project will strive to conform to State of Idaho water quality requirements in effect at the time the
Record of Decision is issued, including TMDL's. In order to meet the Forest Plan standards, the project
would produce an upward trend in fish habitat and water quality conditions as a result of the combined
effects of all planned activities. This will result in, among other habitat improvements, a net decrease in
sediment yield from the affected sub-watersheds within the project area and from the project area as a
whole.
Cumulative Effects
Our cumulative effects analysis will take into consideration a long list of actions that have occurred, are
currently active, or are reasonably foreseeable on the federally managed lands as well as on the private
lands in the upper South Fork Clearwater River. These projects include Whiskey South, Red Pines (this
project now includes Red River Salvage), and Eastside Township Project (new BLM proposal).
Funding for Habitat Restoration
Although you did not mention this topic in your letter, the question of how we plan to fund the habitat
restoration component of this project has come up several times in discussions with representatives of the
Nez Perec Tribe. At this time, I can only share the funding mechanisms we plan to pursue since it is
premature to commit to funding of restoration until the NEPA planning phases of the project are complete
and we know the costs involved. A range of restoration alternatives is being considered with differing
costs and effects. Also, the various types of implementation contracting that may be used, such as
stewardship, service, or timber sale contracts, offer differing options to apply funds generated toward
restoration activities. In general, we plan to pursue the following funding sources:
* Appropriated funding for restoration is being requested for fiscal year 2005 and beyond through
the earmarks and reserves process, which is part of the Regional Office, program and budget
planning process. We currently are preparing a request for American and Crooked River as well
as Red River, which will be submitted in early April.
• As the project gets closer to becoming final, I plan to work with the North Central Idaho
Resource Advisory Committee to seek financial support for restoration.
* We are designing road improvements and decommissioning of existing roads to occur and be paid
for as part of the action where such roads would be used for hauling or removing products from
the land.
• Where product values would exceed costs for logging, fuel treatments, reforestation, removal of
temporary roads constructed for the purposes of the action, etc. (we are closely watching the
efficiencies of these measures), we will consider the option to use stewardship contracting which
would allow us to direct generated funds toward restoration activities.
Appendix M
Page M-172
-------
American River/Crooked River- Final Environmental Impact Statement
• In the process of completing the project proposal, we would likely approve an array of restoration
projects that would be over and above what is considered as mitigation. We believe such projects
would compete well for BPA funding or other grant funding sources.
Finally, I want you to know that your letter and our subsequent contacts with Tribal representatives have
been helpful to our team in developing alternatives to the original proposed action. Your efforts to
engage in the development of this project are deeply appreciated If you or any of the Tribal
subcommittees or staff wish to discuss the project in greater detail either prior to the release of the DEIS
or shortly thereafter, please let me know. Our current schedule would produce a DEIS in about a month.
In the mean time, our project leader, Phil Jahn, will continue to work with the Tribal representatives
mentioned previously.
Sincerely,
/$/ Bruce E. Berahardt
BRUCE E. BERNHARDT
Forest Supervisor
cc: Natural Resources Subcommittee
David Johnson, Fisheries Department
Ira Jones, Watershed Department
Regional Forester
Appendix M
Page M-173
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American River/Crooked River- Final Environmental Impact Statement
TRIBAL EXECUTIVE COMMITTEE
P.O. BOX 305 • LAPWAI, IDAHO 83540 • {208)843-2253
July 21,2004
American and Crooked River Project
Nez Perce National Forest
Attn: Phil Jahn
Route 2, Box 475
Grangeville, ED 83530
Sent via email to: comments-northem-nezperoe(@fe.fed.us
RE: Tribal Comments on the DEIS for the American anj Crooked River Project
Dear Phil:
On behalf of the Nez Perce Tribe, (hank you for coming to Lapwai on Tuesday, July 6,2004 to
meet with the Natural Resources Subcommittee and conduct a govcrnment-to^govemment
consultation for the American and Crooked River Project (the Project). As you know, tribal staff
have been in dose coordination with you on this Project, first by attending a public field tour last
summer, then by reviewing and commenting on the scoping proposal,' and through continued
discussion with you throughout the development of this Project The Tribe truly appreciates your
diligent efforts to consult with us on this Project. The South Fork Clearwater River is a critically
important area where tribal members routinely exercise treaty rights to fish, hunt, camp, and
gather. The Tribe urges you to evaluate this and all other projects on the impacts to treaty
reserved resources and their habitats.
Project Pesjjgn
The Tribe understands that the Forest designed this Project in a fashion that avoids timber
harvest in old growth areas and in inventoried roadless areas, and is designed to minimize
impacts to riparian habitat conservation areas (RHCAs), while avoiding high hazard landslide
prone areas. In those respects, the Tribe views this Project as an improvement over recent
projects where the Forest has proposed risky land management in these sensitive areas, justified
by faulty modeling and biased analysis. Fulfillment of the Forest Service's trust responsibility to
protect treaty reserved resources occurs on (he ground, not through justification or analysis on
paper. Therefore, the Tribe is encouraged by the design of this Project and we encourage you to
'The Tribe's scoping comments are incorporated herein by reference.
Appendix M
PageM-174
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American River/Crooked River- Final Environmental Impact Statement
use a similar or more protective approach for all future projects on the Forest. However, in light
of all activities planned along the South Fork of the Clearwater River, the litmus test for tribal
support of this Project will be whether implementation provides an upward trend in water quality
and fish habitat as required by the forest plan for the Nez Perce National Forest.
Cumulative Effects to the South Fork Clearwater River
As we discussed in our meeting on July 6, the Tribe remains vitally concerned about the
cumulative effects that continued logging and road building has on water quality and fish habitat
in the South Fork Clearwater River. As you know, our Fisheries Department has made
substantial investments in watershed restoration throughout the South Fork, and conducts
numerous outplantings of salmon and steelhead from our Newsome Creek satellite facility
associated with the Nez Perce Tribal Hatchery.
The Tribe was also a key player in the development of the TMDL for the South Fork Clearwater
River. The TMDL sets specific sediment reduction targets for the upper South Fork. Unit 36,
which is the uppermost unit listed for the South Fork and includes American River, has a
sediment load reduction target of 25%. This unit is directly upstream of the mouth of Crooked
River. Unit 30 is the segment below the mouth of Crooked River to Ten-mile Creek and also
requires a 25% reduction in sediment. Although the TMDL does not call for specific reductions
of sediment in specific tributaries to the South Fork, clearly that is the Tribe's expectation and it
is the only practical way to achieve the sediment reduction targets of the TMDL.
With numerous timber sales and road building being planned along the South Fork by the Forest
Service, the Bureau of Land Management, and by private industry, the Tribe remains concerned
about how this Project meets the requirements of the TMDL. Fn contrast, the extensive land
management proposals along the South Fork will inhibit this critical watershed from recovery of
excess sediment and high temperatures. Under the TMDL, the American River unit #36 is in
violation of the maximum weekly mean temperature standard. Although no specific temperature
reduction targets are set, the TMDL sets shade targets as a surrogate measure for temperature.
Yet the extensive logging and road building proposed by this Project and other projects along the
South Fork will further retard the attainment of riparian management objectives (RMOs) in
sensitive riparian habitat conservation areas (RHCAs). Such management inhibits the watershed
from recovery by maintaining high temperatures and limiting recruitment of large woody debris.
Maximum Watershed Restoration
The Tribe urges the Forest Service to adopt an action alternative that is gentle on the land scape
and maximizes watershed restoration in an aggressive manner. American River and Crooked
River are two important watersheds that support dwindling populations of salmon and steelhead.
These two watersheds are also primary sources of sediment to the South Fork Clearwater River.
Therefore, any management undertaken by the Forest Service should focus on an aggressive plan
to reduce sediment and recover these watersheds and improving habitat for threatened fisheries.
Review of the DEIS indicates that Alternative E proposes the most watershed restoration
opportunities. Therefore, the Tribe urges you to implement Alternative E.
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American River/Crooked River- Final Environmental Impact Statement
Contracting Mechanisms and Tribal Participation
As was expressed at the Subcommittee meeting, the Tribe is very interested in participating in
the implementation and monitoring of the watershed restoration work identified in Alternative E.
As you know, our Watershed Division has a strong record of working with the Forest Service on
watershed restoration projects such as road obliteration, culvert replacement, riparian plantings,
and watershed monitoring. We would like to expand our partnership throughout the Project area.
We understand that the Forest Service is actively considering using the stewardship contracting
authority to implement this Project. To mat end, we are aware of two stewardship workshops
that you are planning for July 22 and 23. Tribal staff will attend. However, it is unlikely that the
Tribe would be a primary contractor for this Project; therefore, we urge you to help us identify
opportunities for tribal implementation of the watershed restoration work and monitoring.
Fireproofing Elk City
The Tribe remains concerned about the purpose and need for this project. One rationale is to
reduce the risk of a catastrophic wild fire to the surrounding community of Elk City. However,
review of the DEIS reveals that the proposed timber units are pretty far away and therefore
unlikely to reduce the fire risk to Elk City. A second rationale for the Project is to address the
pine beetle infestations in the lodgepole stands. Dead, dying, and at risk stands are proposed for
harvest The Tribe remains skeptical about die need to treat such stands, as fire and insect
infestations are part of the natural stand replacement cycle for lodgepole pine, and these
watersheds are well within their historic range of variability.
Conclusion
The Tribe questions how the Forest Service can meet its trust responsibility to protect treaty
reserved resources and their habitats when there is currently planned well over 100 tnmbf of
timber sales and 50 miles of new roads in the South Fork Clearwater River. These projects place
unnecessary and cumulative risks to already threatened fisheries and impaired water quality. We
urge you to take a hard look at the sedimentation effects of this and all other projects across the
entire watershed, not just in me specific tributaries of American and Crooked River.
Sincerely,
Anthony D. Johnson, Chairman
Appendix M
PageM-176
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American River/Crooked River- Final Environmental Impact Statement
United States
Department of
Agriculture
Forest
Service
Nez Peree National Forent
Route 2, Box 475
Grangevule, ID 83530
208 983-1950
208 983-2280 TTY
File Code: 1950-1
Date: November 19,2004
Honorable Anthony Johnson
Chairman
Nez Perce Tribal Executive Committee
Box 305
Lapwai, ID 83540
Dear Chairman Johnson:
Continuing our government-to-govemment consultation regarding the American and Crooked
River Project (the project) on the Nez Perce National Forest, I am writing to provide an update
and offer some thoughts regarding the issues and concerns you raised in your July 21,2004
letter.
Since our last letter to you on this subject in April (enclosed), your staff; particularly Ira Jones,
Scott Althouse, and Dave Johnson remained engaged in the project and offered many valued
observations and suggestions that have strengthened the project. For this, I am deeply
appreciative. We also gained valuable insights from our meeting with the Natural Resources
Subcommittee in July, when we presented our Draft Environmental Impact Statement (DEIS) for
the project It is my desire that we schedule an additional meeting with the Subcommittee or
with NPTEC in early December to further discuss our proposal prior to issuing the Final EIS and
Record of Decision.
The Nez Perce Tribe and the Forest share many common goals for managing the resources of the
South Fork Clearwater River. We share a history of working together to achieve those goals.
Recent examples include completing the Newsome Creek Watershed Assessment, our joint
submission of restoration proposals to the Idaho Office of Species Conservation, our cooperative
restoration efforts in Newsome Creek, Meadow Creek, Mill Creek, and upper Red River,
working together to complete subbasin assessments for the Salmon and Clearwater Rivers, joint
participation in the South Fork Clearwater River Watershed Advisory Group, joint participation
in the Clearwater Basin Weed Management Partnership, and our mutual efforts to implement the
satellite components of the Nez Perce Tribal Hatchery. The Forest recognizes the critical
importance of the South Fork Clearwater River (SFCR) and its resources to the members of the
Nez Perce Tribe who routinely exercise treaty rights in the area.
With this perspective, I will address the following issues and concerns you brought to my
attention in your letter dated July 21,2004.
Project Design
Much of the area surrounding Elk City, including the American and Crooked River watersheds,
is experiencing a rapid and extensive die-off of mature lodgepole pine due to the mountain pine
beetle. This is resulting in substantial increases in hazardous forest fuels and losses of potential
economic value in the trees-that are experiencing mortality and deterioration. The purpose of the
Caring for the Land and Serving People M
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American River/Crooked River- Final Environmental Impact Statement
project is to reduce existing and potential forest fuels, create conditions that will contribute to
sustaining long-lived fire tolerant tree species, and contribute to the social and economic well-
being of people who use, and reside within, the area.
The project uses timber harvest to accomplish fuel reduction. The project also includes a robust
restoration component, designed by our watershed and fisheries resource specialists, which wilt
result in a long-term improvement in water quality and fish habitat when combined with the
following design elements that limit overall risks to aquatic resources.
The project would not treat fuels, harvest timber, or construct temporary roads in old growth
areas, inventoried roadless areas, riparian habitat conservation areas (RHCA's), or areas with
landslide prone characteristics. Widely dispersed temporary road spurs, generally shorter than
three quarters of a mile in length and located on stable sites, would be used to access units and
landings, where necessary, then obliterated shortly after the intended uses. There would be no
permanent roads constructed with this project.
The American and Crooked River Project planning team put a great deal of effort into designing
this project to recognize the importance of watershed restoration and balance fish and wildlife
needs with the other purposes of the project. We appreciate the positive tone of your comments
regarding project design.
In your letter, you encourage the Forest to,".. .use a similar or more protective approach for all
future projects on the Forest" Since receiving your letter, I have instructed the Red Pines
interdisciplinary team to apply a similar framework of design features to (hat proposed project in
the upper SFCR in order to provide a reasonable expectation that an upward trend hi water
quality and fish habitat can be achieved for the Red River watershed.
Cumulative Effects to the SFCR
Our consultation efforts with the Nez Perce Tribe as well as others who commented on the DEIS
have resulted in a much more comprehensive evaluation of cumulative effects. We are analyzing
the effects of past and ongoing activities in as much detail as our records allow in addition to
evaluating anticipated effects from proposed projects that we believe are reasonably foreseeable.
The geographic context of this analysis is the entire SFCR drainage, as suggested in your letter.
Cumulative effects are a major concern to us. Fish habitat in these watersheds is functioning
below estimated natural potential, due in part, to residual adverse cumulative effects of past
activities that have occurred over the past century. The project addresses existing limiting
factors related to past activities, through restoration, which would result in more rapid fish
habitat recovery than would likely occur through natural processes.
State of Idaho Water Quality Standards, Total Maximum Daily Load (TMDL)
The long-term effects of this project on sediment and temperature are positive. Planned
watershed restoration activities would reduce sediment in all watersheds and would maintain or
reduce temperatures. The project would maintain or improve existing shade and potential for
large woody debris recruitment through avoidance of vegetation treatments and temporary road
Appendix M
PageM-178
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American River/Crooked River- Final Environmental Impact Statement
construction within RHCA's and by planting trees and shrubs along stream reaches where
existing vegetation and shade is sparse.
On September 30, the Forest received a letter from the Idaho Department of Environmental
Quality regarding the project stating, "The information contained with in the DEIS appears to be
consistent with the intent of this TMDL and the agreement between State and Federal Agencies
regarding impacts to this water body."
Maximum Watershed Restoration
Consultation with the Tribe and others who commented on the DEIS, indicated strong support
for increasing emphasis on watershed restoration within, the project Based on this response, I
intend to increase the emphasis on restoration. Our economic analysis indicates that potential
• revenues generated from Alternative D, of the DEIS, would be sufficient, under stewardship
contracting authorities, to implement most of the restoration component of Alternative £ if
timber harvest involving the lodgepole stands can be accomplished before insect mortality
progresses to the point that economic value is lost. Considering these factors, I am developing a
Record of Decision that would maintain, as a requirement, the full amount of restoration
identified in Alternative D and authorize implementation of additional watershed restoration
activities, as identified in Alternative E, depending upon availability of funds.
Contracting Mechanisms and Tribal Participation
I view the American and Crooked River Project, when approved, as an opportunity to expand our
partnership in watershed restoration. I intend to use stewardship contracting authorities to
implement portions of the project During late winter and early spring, 2005, the Forest will be
compiling the information necessary to develop a stewardship contract that focuses on Crooked
River. Following that, we will evaluate additional stewardship contracting opportunities in the
area, including the American River portion of this project.
I hope that representatives from the Nez Perce Tribe who attended our stewardship contracting
workshop in July found it to be informative and helpful in understanding possible roles for the
Tribe in such endeavors. 1 believe the Nez Perce Tribe has much to offer in the areas of
reforestation and watershed restoration. My staff and I will continue to explore opportunities
with you and others who may be working in partnership with us.
Fireproofmg Elk City
Through coordination with Idaho County, we have identified several communities and/or
residential areas in the vicinity of the project where fuel reduction is a priority (reference
enclosed letter from Idaho County). This priority is being addressed by the American and
Crooked River Project and by smaller defensible space projects mat have been approved or are
being planned. Treating and removing hazardous forest fuels in order to reduce the risks to life,
property, and resources, in the event of a large fire, is among the objectives of the project Risk
reduction would be accomplished by reducing hazardous fuels accumulations in community
protection areas and other strategic areas and by creating vegetation patterns that would have the
effect of lowering the potential fire behavior within treatment areas. The result of lower
potential fire behavior would be increased fire suppression and management effectiveness and
Appendix M
PageM-179
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American River/Crooked River- Final Environmental Impact Statement
improved fire fighter safety. The intent of this project is to reduce the potential risks of large
fires in the project area, not to "fireproof Elk City.
Although large-scale, stand-replacing fires are a part of the natural landscape in the Elk City
area, it is currently unacceptable, socially and politically, to allow such fires to threaten
communities and residential areas that have become interspersed within this landscape. Current
management direction under the Forest Plan and Forest Fire Management Plan requires
aggressive suppression response to control all wildfires in the project area. I do not expect this
policy to change in the foreseeable future.
In summary, this project has been designed and modified through consultation with the Nez
Perec Tribe, NOAA Fisheries, the US Fish and Wildlife Service, the Idaho Department of Fish
and Game, and the Idaho Department of Environmental Quality to maintain or improve water
quality and to limit the potential for short-term incidental losses of ESA-listed anadromous fish
and bull trout The project would create aquatic habitat conditions for long-term increases in
abundance of these species. It would also create upland habitat conditions that are projected to
maintain or improve populations of big game species in the area. Additionally, this project
would not impose any restrictions on traditional access rights of Nez Perce tribal members or
restrict, in any way, tribal members' abilities to continue exercising the full range of treaty rights
in the project area over the long term.
I appreciate the efforts of your representatives who have worked with us through the planning
phases of the project and I am committed to pursuing any potential partnership opportunities
between the Nez Perce Tribe and the Forest that this project would create.
Sincerely,
/s/ Steve E. Williams
STEVE E. WILLIAMS
Acting Forest Supervisor
Appendix M
PageM-180
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American River/Crooked River- Final Environmental Impact Statement
stkrncHM
MOOMU.H
BOARD OF COUNTY COMMISSIONERS
Bwoeeunv
»KlkM>aMWMMUI,IIMMa«» ' HU »»*«•.
November 17.2004 RECEIVED
WV 17MW
To; Stove Williams. Fore« Supervisor
_ _, __,,.
Dear Mr. Williams:
The Idaho County Commission would lite Co voice its support for the American and
Crooked River Project You hive provided the Draft Eartronroental Impact Statement
for our review and we have discussed, with the project manager, modification! la the
draft that are being developed to emphasize community protection priorities.
We believe this project would contribute to the racial and economic well-being of die
county by reducing potentially catastrophic risks to life tod property from the buildup of
hazardous fuels that could affect residential and commercial developments in the Hi City
area. The actividesaKSocimed with the Preferred Allcroatiw CD) such a» logging,
reforestation, and watershed restoration would also contribute direct economic benefits in
the form of a diversity of jobs, commercially valuable wood products, and Unproved fish
and wildlife habitat conditions which will enhance natation in the ana.
We also believe it is appropriate that community protection areas are identified
surrounding.each of the residential areas and communities in tf» vicinity of the project
and that major midways servicing these anas be maintained for safe a&d efficient
evacuation, in the cose of emergency. We recommend you proceed with specific
identification of the Ericson Ridge, Upper American River, and Gnome Town-rite
residential areas as well at the community of Orogrande as communities-at-riik, in the
project area, from large scale wildfire. It is extremely important that priority be given to
hazardous fuel reduction within a minimum of one and one-half miles of these
communities and residential areas.
Oar May 2003 Wildfire Mitigation Plan identifies a three mite community protection area
around the town of Elk City to protect several additional outlying residential areas as well
as E!fc City, itself. This plan alto identifies the specific evacuation routes thae we expect
you to consider.
Appendix M
PageM-181
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American River/Crooked River- Final Environmental Impact Statement
We agree that your proposal for the American and Crooked River Project is a much
needed step in the right direction. However, the County is concerned with the safety and
wen-befog of its residents and may find it necessary to add additional community
protection areas and/or expand those already identified as we continue to consider the
risks associated with hazardous forest fuels.
c you for die opportunity to provide comments on this important project.
George
Idaho County Commissioners
Appendix M
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American River/Crooked River- Final Environmental Impact Statement
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